Saturday, June 27, 2015

Progress Report from the New York Fed's Tri-Party Repo Task Force

Author: David Schwartz J.D. CPA
The Federal Reserve Bank of New York’s Tri-Party Repo Infrastructure Reform Task Force issued a progress report on June 24, 2015. The report touts some impressive progress since the task force’s last update in 2014, including the implementation of the task force’s new settlement regime by the major tri-party clearing player, Bank of New York Mellon.

 “…Earlier this spring, Bank of New York Mellon completed the final piece of its new settlement process for triparty repo, achieving a number of reform goals and serving to bring all triparty repo trades into alignment with the roadmap originally laid out by the Industry Task Force back in 2012. As a result, the share of triparty repo volume that is financed with intraday credit from a clearing bank has dropped markedly, from 100 percent as recently as 2012, to a level averaging 3 to 5 percent today (as compared with the Task Force’s original target of no more than 10 percent). Clearing banks, dealers and investors all made changes to their practices and processes that helped to achieve this goal…”

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Wednesday, February 11, 2015

Fed Remains Concerned About Firesale Risks

Asset Management Industry Still a Source of Worry

Author: David Schwartz J.D. CPA
In a January 30, 2015 address, Federal Reserve Board Governor Daniel K. Tarullo once again voiced the Fed's concerns about the systemic risk posed by potential firesales in the asset management industry. Tarullo indicated that as regulators implement reforms under the Basel and FSB proposals and frameworks, they should take into account the “system-wide demands on liquidity during stress periods and correlated risks among asset managers that could exacerbate liquidity, redemption and fire-sale pressures."

In his address, Mr. Tarullo noted the rapid growth of the asset management industry  since the financial crisis, both in terms of the dollar amount of assets under management and in the concentration of assets managed by the largest firms. As stricter prudential regulation makes investment in certain forms of assets more costly for banks, this growth is expected to continue apace.
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Thursday, August 28, 2014

Could Redemption Gates Actually Encourage Runs on Funds?

Economists at the NY Fed posit that in some cases redemption gates may the have opposite effect intended

Author: David Schwartz J.D. CPA
Under rules recently finalized by the SEC, all money market funds will be permitted, and under some circumstances required, to impose liquidity fees and gates against investor redemptions if the fund’s weekly liquid assets fall below specified thresholds. In their release, the SEC said the purpose of these new rules is to mitigate money market funds’ susceptibility to heavy redemptions and improve their ability to manage and thwart possible contagion from redemptions.  An April 14, 2014 paper published by the the staff of the New York Fed, however, finds that in some cases the imposition of redemption gates may actually increase, rather than decrease, the possibility of runs on a fund.
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Tuesday, August 12, 2014

Dodd-Frank Implementation: Are We At the End of the Beginning, or the Beginning of the End?

Author: David Schwartz J.D. CPA
With the Dodd-Frank Wall Street Reform and Consumer Protection Act having just celebrated its fourth birthday, where exactly are we in the the reform of our seemingly ever-evolving regulatory framework? Dan Ryan, Chairman of the Financial Services Regulatory Practice at PricewaterhouseCoopers LLP takes a look at this very question to help us determine what is imminent, what is delayed, and what remains in limbo with regard to Dodd-Frank implementation.
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Monday, June 2, 2014

New York Fed Publishes A Primer on the GCF Repo® Service

Quantifying to what extent dealers pursue various strategies trading GCF Repo.

Author: David Schwartz J.D. CPA
The Staff of the Federal Reserve Bank of New York has published a "A Primer on the GCF Repo® Service," the overall goal of which is to to quantify to what extent dealers pursue various strategies trading GCF Repo.
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