Senior Credit Officer Opinion Survey on Dealer Financing Terms September 2016

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1 Page 1 of 93 Senior Credit Officer Opinion Survey on Dealer Financing Terms September 2016 Print Summary Results of the September 2016 Survey Summary The September 2016 Senior Credit Officer Opinion Survey on Dealer Financing Terms collected qualitative information on changes over the previous three months in credit terms and conditions in securities financing and over-the-counter (OTC) derivatives markets. In addition to the core questions, the survey included a set of special questions about the effects on dealer firms of the money market fund (MMF) reforms required by the U.S. Securities and Exchange Commission (SEC), which must be implemented by mid-october The 23 institutions participating in the survey account for almost all dealer financing of dollar-denominated securities to nondealers and are the most active intermediaries in OTC derivatives markets. (Note that 2 of the 23 participants were added to the September round of the survey.) The survey was conducted between August 23, 2016, and September 6, The core questions asked about changes between June 2016 and August Core Questions (Questions 1 79) 2 Responses to the core questions in the September survey offered a few insights regarding the developments in dealer-intermediated markets over the past three months: Price and nonprice terms on securities financing transactions and OTC derivatives were basically unchanged across all classes of counterparties. The use of financial leverage by all classes of counterparties was also reported to have changed little. Initial margin requirements on OTC derivatives were said to be basically unchanged for average and most-favored clients. In addition, the majority of respondents noted that the volume, duration, and persistence of mark and collateral disputes with all counterparty types were basically unchanged. With respect to securities financing transactions, about one-fourth of dealers reported an increase in collateral spreads over the relevant benchmark (financing rates) for high-yield (HY) bonds for both average and preferred clients. Smaller fractions of respondents reported similar increases for high-grade bonds, non-agency residential-mortgage-backed securities (RMBS), and commercial mortgage-backed securities. Other terms under which various types of securities are funded remained largely unchanged since the previous survey. More than one-fourth of dealers reported increased demand to fund non-agency RMBS, while about one-fifth noted greater demand to fund both high-grade and HY bonds as well as consumer asset-backed securities (ABS). Smaller fractions of dealers reported increased demand to fund agency RMBS and equities. A net fraction of more than one-fourth of respondents noted an improvement in liquidity and functioning in the underlying market for consumer ABS. Of note, despite robust issuance in the primary market, a net share of close to one-fifth of respondents reported a deterioration in liquidity and market functioning in the HY bond market over the past three months. For all other products, market functioning and liquidity were little changed. Special Questions on Money Market Fund Reforms (Questions 81 86) The SEC s 2014 MMF reforms have led to changes in the MMF industry, and more changes may occur before the October 2016 deadline for implementing key provisions of the reforms. These developments may have already affected dealers use of short-term funding to finance their activities and may have additional effects in coming months. The September 2016 survey included a set of special questions intended to help us understand the effects of the MMF reforms on institutions use of short-term funding instruments. With respect to how their use of short-term funding instruments and counterparties has changed over the past year, dealers reported the following: The use of various short-term funding instruments has changed noticeably over the past year. Two-fifths of dealers indicated that they had reduced the use of commercial paper (CP) as a source of funding, while one-fourth noted a decline in the use of certificates of deposit (CDs). By contrast, small net fractions of dealers reported an increase in the use of Treasury and agency repos as well as other types of repos.

2 Page 2 of 93 Of the respondents who reported decreased use of CP and CDs, almost all pointed to MMF reforms as at least a somewhat important reason for the decline. In addition, one-half of such respondents pointed to other post-crisis regulatory reforms and institution-specific internal factors as important reasons. Of the respondents who reported increased use of Treasury and agency repos, one-half indicated that MMF reforms were a very important reason for the increase. 3 Among the dealers who reported increased use of other types of repos, one-half noted that other post-crisis reforms and institution-specific internal factors were very important reasons for the change. 4 In terms of counterparties, net fractions of roughly two-fifths and one-third of respondents reported a decrease in funding obtained from money funds via CDs and CP, respectively. By contrast, small net fractions of dealers indicated that Treasury and agency repo funding from money funds had increased. With respect to counterparties other than money funds, a net fraction of about one-fourth of respondents noted that funding from corporations via CDs had increased. Small net fractions of respondents also pointed to increases in funding from corporations and other investment funds via repos other than those backed by Treasury and agency securities. By contrast, dealers indicated that they were receiving less funding via Treasury and agency repos from securities lenders. With respect to how dealers anticipate their use of short-term funding instruments and counterparties to change for the remainder of the year as a result of changes related to MMF reform, respondents indicated the following: About one-fifth of dealers expect their use of Treasury and agency repos to increase, while the vast majority of dealers anticipate the use of other types of repos to remain basically unchanged. More than two-fifths of dealers that use CDs as a funding source expect a decline, and a net fraction of about one-third of dealers that use CP as a funding source anticipate a decline. Several respondents expect to increase their use of other short-term funding instruments like corporate deposits and equity-linked notes. With respect to counterparties, one-fifth of respondents expect Treasury and agency repos provided by MMFs to increase. Conversely, at least one-fourth of dealers anticipate money funds to decrease funding via each of the other types of instruments listed in the survey. A net fraction of one-fourth of respondents expect pension funds to reduce their lending to dealers via CP; a smaller net fraction expect pension funds to reduce their lending via CDs. Dealers were also asked to estimate how they expect price and nonprice terms they will face for the rest of the year to change in response to MMF reforms. Respondents reported the following: One-fourth of respondents anticipate financing rates for Treasury and agency repos to ease somewhat during the remainder of the year. By contrast, more than half of dealers expect rates on CDs and CP to increase. With respect to nonprice terms, one-fifth of dealers foresee an easing of nonprice terms (for example, maximum maturity) for CP, and a smaller net fraction of dealers anticipate easing for CDs. This document was prepared by Charles Press, Division of Monetary Affairs, Board of Governors of the Federal Reserve System. Assistance in developing and administering the survey was provided by staff members in the Statistics Function and the Markets Group at the Federal Reserve Bank of New York. Exhibit 1: Management of Concentrated Credit Exposures and Indicators of Supply of Credit

3 Page 3 of 93 Accessible version Exhibit 2: Use of Financial Leverage

4 Page 4 of 93 Accessible version Exhibit 3: Measures of Demand of Funding and Market Functioning

5 Page 5 of 93 Accessible version Results of the September 2016 Senior Credit Officer Opinion Survey on Dealer Financing Terms Counterparty Types Over-the-Counter Derivatives Securities Financing Optional Question

6 Page 6 of 93 Special Questions The following results include the original instructions provided to the survey respondents. Please note that percentages are based on the number of financial institutions that gave responses other than "Not applicable." Components may not add to totals due to rounding. Counterparty Types Questions 1 through 40 ask about credit terms applicable to, and mark and collateral disputes with, different counterparty types, considering the entire range of securities financing and overthe-counter (OTC) derivatives transactions. Question 1 focuses on dealers and other financial intermediaries as counterparties; questions 2 and 3 on central counterparties and other financial utilities; questions 4 through 10 focus on hedge funds; questions 11 through 16 on trading real estate investment trusts (REITs); questions 17 through 22 on mutual funds, exchange-traded funds (ETFs), pension plans, and endowments; questions 23 through 28 on insurance companies; questions 29 through 34 on separately managed accounts established with investment advisers; and questions 35 through 38 on nonfinancial corporations. Questions 39 and 40 ask about mark and collateral disputes for each of the aforementioned counterparty types. In some questions, the survey differentiates between the compensation demanded for bearing credit risk (price terms) and the contractual provisions used to mitigate exposures (nonprice terms). If your institution's terms have tightened or eased over the past three months, please so report them regardless of how they stand relative to longer-term norms. Please focus your response on dollar-denominated instruments; if material differences exist with respect to instruments denominated in other currencies, please explain in the appropriate comment space. Where material differences exist across different business areas--for example, between traditional prime brokerage and OTC derivatives--please answer with regard to the business area generating the most exposure and explain in the appropriate comment space. Dealers and Other Financial Intermediaries 1. Over the past three months, how has the amount of resources and attention your firm devotes to management of concentrated credit exposure to dealers and other financial intermediaries (such as large banking institutions) changed? In this Section: Dealers and Other Financial Intermediaries Central Counterparties and Other Financial Utilities Hedge Funds Trading Real Estate Investment Trusts Mutual Funds, Exchange- Traded Funds, Pension Plans, and Endowments Insurance Companies Separately Managed Accounts Established with Investment Advisers Nonfinancial Corporations Mark and Collateral Disputes Increased considerably 0 0.0% Increased somewhat % Remained basically unchanged % Decreased considerably 0 0.0% Total % Central Counterparties and Other Financial Utilities 2. Over the past three months, how has the amount of resources and attention your firm devotes to management of concentrated credit exposure to central counterparties and other financial utilities changed? Increased considerably 0 0.0% Increased somewhat 2 8.7% Remained basically unchanged % Decreased somewhat 1 4.3% Decreased considerably 0 0.0%

7 Page 7 of 93 Total % 3. To what extent have changes in the practices of central counterparties, including margin requirements and haircuts, influenced the credit terms your institution applies to clients on bilateral transactions which are not cleared? To a considerable extent 1 4.3% To some extent % To a minimal extent % Not at all % Total % Hedge Funds 4. Over the past three months, how have the price terms (for example, financing rates) offered to hedge funds as reflected across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of nonprice terms? Tightened considerably 0 0.0% Tightened somewhat 0 0.0% Remained basically unchanged % Eased somewhat 1 4.3% Eased considerably 0 0.0% Total % 5. Over the past three months, how has your use of nonprice terms (for example, haircuts, maximum maturity, covenants, cure periods, cross-default provisions or other documentation features) with respect to hedge funds across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of price terms? Tightened considerably 0 0.0% Tightened somewhat 0 0.0% Remained basically unchanged % Eased somewhat 1 4.3% Eased considerably 0 0.0% Total % 6. To the extent that the price or nonprice terms applied to hedge funds have tightened or eased over the past three months (as reflected in your responses to questions 4 and 5), what are the most important reasons for the change? A. Possible reasons for tightening 1. Deterioration in current or expected financial strength of counterparties

8 Page 8 of Reduced willingness of your institution to take on risk 3. Adoption of more-stringent market conventions (that is, collateral terms and agreements, ISDA protocols) 4. Higher internal treasury charges for funding 5. Diminished availability of balance sheet or capital at your institution 6. Worsening in general market liquidity and functioning 7. Less-aggressive competition from other institutions 8. Other (please specify) Number of Respondents Percent

9 Page 9 of 93 B. Possible reasons for easing 1. Improvement in current or expected financial strength of counterparties 2nd Most Important % 2. Increased willingness of your institution to take on risk 3. Adoption of less-stringent market conventions (that is, collateral terms and agreements, ISDA protocols) 4. Lower internal treasury charges for funding 5. Increased availability of balance sheet or capital at your institution 3rd Most Important % 6. Improvement in general market liquidity and functioning

10 Page 10 of More-aggressive competition from other institutions 8. Other (please specify) Most Important % 7. How has the intensity of efforts by hedge funds to negotiate more-favorable price and nonprice terms changed over the past three months? Increased considerably 0 0.0% Increased somewhat % Remained basically unchanged % Decreased considerably 0 0.0% Total % 8. Considering the entire range of transactions facilitated by your institution for such clients, how has the use of financial leverage by hedge funds changed over the past three months? Increased considerably 0 0.0% Increased somewhat 2 8.7% Remained basically unchanged % Decreased somewhat 1 4.3% Decreased considerably 0 0.0% Total % 9. Considering the entire range of transactions facilitated by your institution for such clients, how has the availability of additional (and currently unutilized) financial leverage under agreements currently in place with hedge funds (for example, under prime broker, warehouse agreements, and other committed but undrawn or partly drawn facilities) changed over the past three months? Increased considerably 0 0.0%

11 Page 11 of 93 Increased somewhat % Remained basically unchanged % Decreased considerably 0 0.0% Total % 10. How has the provision of differential terms by your institution to most-favored (as a function of breadth, duration, and extent of relationship) hedge funds changed over the past three months? Increased considerably 0 0.0% Increased somewhat 2 8.7% Remained basically unchanged % Decreased somewhat 1 4.3% Decreased considerably 0 0.0% Total % Trading Real Estate Investment Trusts 11. Over the past three months, how have the price terms (for example, financing rates) offered to trading REITs as reflected across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of nonprice terms? Tightened considerably 0 0.0% Tightened somewhat 0 0.0% Remained basically unchanged % Eased somewhat 0 0.0% Eased considerably 0 0.0% Total % 12. Over the past three months, how has your use of nonprice terms (for example, haircuts, maximum maturity, covenants, cure periods, cross-default provisions or other documentation features) with respect to trading REITs across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of price terms? Tightened considerably 1 5.3% Tightened somewhat 0 0.0% Remained basically unchanged % Eased somewhat 0 0.0% Eased considerably 0 0.0% Total % 13. To the extent that the price or nonprice terms applied to trading REITs have tightened or eased over the past three months (as reflected in your responses to questions 11 and 12), what are the most important reasons for the change? A. Possible reasons for tightening 1. Deterioration in current or expected financial strength of counterparties Number of Respondents Percent

12 Page 12 of Reduced willingness of your institution to take on risk Most Important % 3. Adoption of more-stringent market conventions (that is, collateral terms and agreements, ISDA protocols) 4. Higher internal treasury charges for funding 5. Diminished availability of balance sheet or capital at your institution 6. Worsening in general market liquidity and functioning 7. Less-aggressive competition from other institutions

13 Page 13 of Other (please specify) B. Possible reasons for easing 1. Improvement in current or expected financial strength of counterparties 2. Increased willingness of your institution to take on risk 3. Adoption of less-stringent market conventions (that is, collateral terms and agreements, ISDA protocols) 4. Lower internal treasury charges for funding 5. Increased availability of balance sheet or capital at your institution

14 Page 14 of Improvement in general market liquidity and functioning 7. More-aggressive competition from other institutions 8. Other 14. How has the intensity of efforts by trading REITs to negotiate more-favorable price and nonprice terms changed over the past three months? Increased considerably 0 0.0% Increased somewhat 0 0.0% Remained basically unchanged % Decreased considerably 0 0.0% Total % 15. Considering the entire range of transactions facilitated by your institution for such clients, how has the use of financial leverage by trading REITs changed over the past three months? Increased considerably 0 0.0% Increased somewhat 1 5.3% Remained basically unchanged % Decreased considerably 0 0.0% Total %

15 Page 15 of How has the provision of differential terms by your institution to most-favored (as a function of breadth, duration, and extent of relationship) trading REITs changed over the past three months? Increased considerably 0 0.0% Increased somewhat 0 0.0% Remained basically unchanged % Decreased considerably 0 0.0% Total % Mutual Funds, Exchange-Traded Funds, Pension Plans, and Endowments 17. Over the past three months, how have the price terms (for example, financing rates) offered to mutual funds, ETFs, pension plans, and endowments as reflected across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of nonprice terms? Tightened considerably 0 0.0% Tightened somewhat 0 0.0% Remained basically unchanged % Eased somewhat 0 0.0% Eased considerably 0 0.0% Total % 18. Over the past three months, how has your use of nonprice terms (for example, haircuts, maximum maturity, covenants, cure periods, cross-default provisions or other documentation features) with respect to mutual funds, ETFs, pension plans, and endowments across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of price terms? Tightened considerably 0 0.0% Tightened somewhat 1 4.3% Remained basically unchanged % Eased somewhat 0 0.0% Eased considerably 0 0.0% Total % 19. To the extent that the price or nonprice terms applied to mutual funds, ETFs, pension plans, and endowments have tightened or eased over the past three months (as reflected in your responses to questions 17 and 18) what are the most important reasons for the change? A. Possible reasons for tightening 1. Deterioration in current or expected financial strength of counterparties

16 Page 16 of Reduced willingness of your institution to take on risk Most Important % 3. Adoption of more-stringent market conventions (that is, collateral terms and agreements, ISDA protocols) 4. Higher internal treasury charges for funding 5. Diminished availability of balance sheet or capital at your institution 6. Worsening in general market liquidity and functioning 2nd Most Important % 7. Less-aggressive competition from other institutions 8. Other Number of Respondents Percent

17 Page 17 of 93 B. Possible reasons for easing 1. Improvement in current or expected financial strength of counterparties 2. Increased willingness of your institution to take on risk 3. Adoption of less-stringent market conventions (that is, collateral terms and agreements, ISDA protocols) 4. Lower internal treasury charges for funding 5. Increased availability of balance sheet or capital at your institution 6. Improvement in general market liquidity and functioning

18 Page 18 of More-aggressive competition from other institutions 8. Other 20. How has the intensity of efforts by mutual funds, ETFs, pension plans, and endowments to negotiate more-favorable price and nonprice terms changed over the past three months? Increased considerably 1 4.3% Increased somewhat % Remained basically unchanged % Decreased considerably 0 0.0% Total % 21. Considering the entire range of transactions facilitated by your institution, how has the use of financial leverage by each of the following types of clients changed over the past three months? A. Mutual funds Increased Considerably 0 0.0% Increased Somewhat 1 4.5% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 0 0.0% Total % B. ETFs Increased Considerably 0 0.0% Increased Somewhat 0 0.0%

19 Page 19 of 93 Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 0 0.0% Total % C. Pension plans Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 0 0.0% Total % D. Endowments Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 0 0.0% Total % 22. How has the provision of differential terms by your institution to most-favored (as a function of breadth, duration, and extent of relationship) mutual funds, ETFs, pension plans, and endowments changed over the past three months? Increased considerably 0 0.0% Increased somewhat % Remained basically unchanged % Decreased considerably 0 0.0% Total % Insurance Companies 23. Over the past three months, how have the price terms (for example, financing rates) offered to insurance companies as reflected across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of nonprice terms? Tightened considerably 0 0.0% Tightened somewhat 0 0.0% Remained basically unchanged % Eased somewhat 0 0.0% Eased considerably 0 0.0% Total %

20 Page 20 of Over the past three months, how has your use of nonprice terms (for example, haircuts, maximum maturity, covenants, cure periods, cross-default provisions or other documentation features) with respect to insurance companies across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of price terms? Tightened considerably 0 0.0% Tightened somewhat 0 0.0% Remained basically unchanged % Eased somewhat 1 4.3% Eased considerably 0 0.0% Total % 25. To the extent that the price or nonprice terms applied to insurance companies have tightened or eased over the past three months (as reflected in your responses to questions 23 and 24) what are the most important reasons for the change? A. Possible reasons for tightening 1. Deterioration in current or expected financial strength of counterparties 2. Reduced willingness of your institution to take on risk 3. Adoption of more-stringent market conventions (that is, collateral terms and agreements, ISDA protocols) 4. Higher internal treasury charges for funding 5. Diminished availability of balance sheet or capital at your institution

21 Page 21 of Worsening in general market liquidity and functioning 7. Less-aggressive competition from other institutions 8. Other B. Possible reasons for easing 1. Improvement in current or expected financial strength of counterparties Most Important % 2. Increased willingness of your institution to take on risk 3. Adoption of less-stringent market conventions (that is, collateral terms and agreements, ISDA protocols) Number of Respondents Percent

22 Page 22 of 93 3rd Most Important % 4. Lower internal treasury charges for funding 5. Increased availability of balance sheet or capital at your institution 6. Improvement in general market liquidity and functioning 7. More-aggressive competition from other institutions 2nd Most Important % 8. Other 26. How has the intensity of efforts by insurance companies to negotiate more-favorable price and nonprice terms changed over the past three months? Number of Respondents Percent

23 Page 23 of 93 Increased considerably 0 0.0% Increased somewhat 1 4.3% Remained basically unchanged % Decreased considerably 0 0.0% Total % 27. Considering the entire range of transactions facilitated by your institution for such clients, how has the use of financial leverage by insurance companies changed over the past three months? Increased considerably 0 0.0% Increased somewhat 0 0.0% Remained basically unchanged % Decreased considerably 0 0.0% Total % 28. How has the provision of differential terms by your institution to most-favored (as a function of breadth, duration, and extent of relationship) insurance companies changed over the past three months? Increased considerably 0 0.0% Increased somewhat 0 0.0% Remained basically unchanged % Decreased somewhat 1 4.3% Decreased considerably 0 0.0% Total % Separately Managed Accounts Established with Investment Advisers 29. Over the past three months, how have the price terms (for example, financing rates) offered to separately managed accounts established with investment advisers as reflected across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of nonprice terms? Tightened considerably 0 0.0% Tightened somewhat 0 0.0% Remained basically unchanged % Eased somewhat 0 0.0% Eased considerably 0 0.0% Total % 30. Over the past three months, how has your use of nonprice terms (for example, haircuts, maximum maturity, covenants, cure periods, cross-default provisions or other documentation features) with respect to separately managed accounts established with investment advisers across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of price terms? Number of Respondents Percent

24 Page 24 of 93 Tightened considerably 0 0.0% Tightened somewhat % Remained basically unchanged % Eased somewhat 0 0.0% Eased considerably 0 0.0% Total % 31. To the extent that the price or nonprice terms applied to separately managed accounts established with investment advisers have tightened or eased over the past three months (as reflected in your responses to questions 29 and 30), what are the most important reasons for the change? A. Possible reasons for tightening 1. Deterioration in current or expected financial strength of counterparties 2. Reduced willingness of your institution to take on risk Most Important % 3. Adoption of more-stringent market conventions (that is, collateral terms and agreements, ISDA protocols) 4. Higher internal treasury charges for funding 5. Diminished availability of balance sheet or capital at your institution

25 Page 25 of Worsening in general market liquidity and functioning 2nd Most Important % 7. Less-aggressive competition from other institutions 8. Other Most Important % B. Possible reasons for easing 1. Improvement in current or expected financial strength of counterparties 2. Increased willingness of your institution to take on risk 3. Adoption of less-stringent market conventions (that is, collateral terms and agreements, ISDA protocols)

26 Page 26 of Lower internal treasury charges for funding 5. Increased availability of balance sheet or capital at your institution 6. Improvement in general market liquidity and functioning 7. More-aggressive competition from other institutions 8. Other 32. How has the intensity of efforts by investment advisers to negotiate more-favorable price and nonprice terms on behalf of separately managed accounts changed over the past three months? Increased considerably 0 0.0% Increased somewhat 0 0.0% Remained basically unchanged % Decreased considerably 0 0.0%

27 Page 27 of 93 Total % 33. Considering the entire range of transactions facilitated by your institution for such clients, how has the use of financial leverage by separately managed accounts established with investment advisers changed over the past three months? Increased considerably 0 0.0% Increased somewhat 0 0.0% Remained basically unchanged % Decreased considerably 0 0.0% Total % 34. How has the provision of differential terms by your institution to separately managed accounts established with most-favored (as a function of breadth, duration, and extent of relationship) investment advisers changed over the past three months? Increased considerably 0 0.0% Increased somewhat 0 0.0% Remained basically unchanged % Decreased somewhat 1 5.3% Decreased considerably 0 0.0% Total % Nonfinancial Corporations 35. Over the past three months, how have the price terms (for example, financing rates) offered to nonfinancial corporations as reflected across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of nonprice terms? Tightened considerably 0 0.0% Tightened somewhat 0 0.0% Remained basically unchanged % Eased somewhat 1 4.3% Eased considerably 0 0.0% Total % 36. Over the past three months, how has your use of nonprice terms (for example, haircuts, maximum maturity, covenants, cure periods, cross-default provisions or other documentation features) with respect to nonfinancial corporations across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of price terms? Tightened considerably 0 0.0% Tightened somewhat 0 0.0% Remained basically unchanged % Eased somewhat 0 0.0% Eased considerably 0 0.0% Total %

28 Page 28 of To the extent that the price or nonprice terms applied to nonfinancial corporations have tightened or eased over the past three months (as reflected in your responses to questions 35 and 36) what are the most important reasons for the change? A. Possible reasons for tightening 1. Deterioration in current or expected financial strength of counterparties 2. Reduced willingness of your institution to take on risk 3. Adoption of more-stringent market conventions (that is, collateral terms and agreements, ISDA protocols) 4. Higher internal treasury charges for funding 5. Diminished availability of balance sheet or capital at your institution 6. Worsening in general market liquidity and functioning

29 Page 29 of Less-aggressive competition from other institutions 8. Other B. Possible reasons for easing 1. Improvement in current or expected financial strength of counterparties 2. Increased willingness of your institution to take on risk 3. Adoption of less-stringent market conventions (that is, collateral terms and agreements, ISDA protocols) 4. Lower internal treasury charges for funding

30 Page 30 of Increased availability of balance sheet or capital at your institution 6. Improvement in general market liquidity and functioning Most Important % 7. More-aggressive competition from other institutions 8. Other 38. How has the intensity of efforts by nonfinancial corporations to negotiate more-favorable price and nonprice terms changed over the past three months? Increased considerably 0 0.0% Increased somewhat 1 4.3% Remained basically unchanged % Decreased considerably 0 0.0% Total % Mark and Collateral Disputes 39. Over the past three months, how has the volume of mark and collateral disputes with clients of each of the following types changed? A. Dealers and other financial intermediaries

31 Page 31 of 93 Increased Considerably 0 0.0% Increased Somewhat % Remained Basically Unchanged % Decreased Somewhat 1 4.5% Decreased Considerably 1 4.5% Total % B. Hedge funds Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 2 9.1% Total % C. Trading REITs Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 1 5.0% Total % D. Mutual funds, ETFs, pension plans, and endowments Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 1 4.8% Decreased Considerably 1 4.8% Total % E. Insurance companies Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 1 4.5% Total % F. Separately managed accounts established with investment advisers

32 Page 32 of 93 Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 1 5.3% Total % G. Nonfinancial corporations Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 2 9.5% Total % 40. Over the past three months, how has the duration and persistence of mark and collateral disputes with clients of each of the following types changed? A. Dealers and other financial intermediaries Increased Considerably 0 0.0% Increased Somewhat 1 4.5% Remained Basically Unchanged % Decreased Somewhat 1 4.5% Decreased Considerably 1 4.5% Total % B. Hedge funds Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 2 9.1% Total % C. Trading REITs Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 1 5.0%

33 Page 33 of 93 Total % D. Mutual funds, ETFs, pension plans, and endowments Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 2 9.5% Total % E. Insurance companies Increased Considerably 0 0.0% Increased Somewhat 2 9.1% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 1 4.5% Total % F. Separately managed accounts established with investment advisers Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 1 5.3% Total % G. Nonfinancial corporations Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 2 9.5% Total % Back to section top Over-the-Counter Derivatives Questions 41 through 51 ask about OTC derivatives trades. Question 41 focuses on nonprice terms applicable to new and renegotiated master agreements. Questions 42 through 48 ask about the initial margin requirements for most-favored and average clients applicable to different types of contracts: Question 42 focuses on foreign exchange (FX); question 43 on interest rates; question 44 on equity; question 45 on contracts referencing corporate credits (single-name and In this Section: New and Renegotiated Master Agreements

34 Page 34 of 93 indexes); question 46 on credit derivatives referencing structured products such as mortgagebacked securities (MBS) and asset-backed securities (ABS) (specific tranches and indexes); question 47 on commodities; and question 48 on total return swaps (TRS) referencing nonsecurities (such as bank loans, including, for example, commercial and industrial loans and mortgage whole loans). Question 49 asks about posting of nonstandard collateral pursuant to OTC derivatives contracts. Questions 50 and 51 focus on mark and collateral disputes involving contracts of each of the aforementioned types. Initial Margin Nonstandard Collateral Mark and Collateral Disputes If your institution s terms have tightened or eased over the past three months, please so report them regardless of how they stand relative to longer-term norms. Please focus your response on dollar-denominated instruments; if material differences exist with respect to instruments denominated in other currencies, please explain in the appropriate comment space. New and Renegotiated Master Agreements 41. Over the past three months, how have nonprice terms incorporated in new or renegotiated OTC derivatives master agreements put in place with your institution's client changed? A. Requirements, timelines, and thresholds for posting additional margin Tightened Considerably 1 4.5% Tightened Somewhat 1 4.5% Remained Basically Unchanged % Total % B. Acceptable collateral Tightened Somewhat 1 4.5% Remained Basically Unchanged % Total % C. Recognition of portfolio or diversification benefits (including from securities financing trades where appropriate agreements are in place) Tightened Somewhat 0 0.0% Remained Basically Unchanged % Total % D. Triggers and covenants Tightened Considerably 1 4.5% Tightened Somewhat 0 0.0% Remained Basically Unchanged %

35 Page 35 of 93 Total % E. Other documentation features (including cure periods and cross-default provisions) Tightened Somewhat 0 0.0% Remained Basically Unchanged % Total % F. Other Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 0 0.0% Initial Margin 42. Over the past three months, how have initial margin requirements set by your institution with respect to OTC FX derivatives changed? A. Initial margin requirements for average clients Increased considerably 0 0.0% Increased somewhat 1 4.8% Remained basically unchanged % Decreased considerably 0 0.0% Total % B. Initial margin requirements for most-favored clients, as a consequence of breadth, duration, and/or extent of relationship Increased considerably 0 0.0% Increased somewhat 0 0.0% Remained basically unchanged % Decreased considerably 0 0.0% Total % 43. Over the past three months, how have initial margin requirements set by your institution with respect to OTC interest rate derivatives

36 Page 36 of 93 changed? A. Initial margin requirements for average clients Increased considerably 0 0.0% Increased somewhat 1 4.5% Remained basically unchanged % Decreased considerably 0 0.0% Total % B. Initial margin requirements for most-favored clients, as a consequence of breadth, duration, and/or extent of relationship Increased considerably 0 0.0% Increased somewhat 0 0.0% Remained basically unchanged % Decreased considerably 0 0.0% Total % 44. Over the past three months, how have initial margin requirements set by your institution with respect to OTC equity derivatives changed? A. Initial margin requirements for average clients Increased considerably 1 4.8% Increased somewhat 0 0.0% Remained basically unchanged % Decreased considerably 0 0.0% Total % B. Initial margin requirements for most-favored clients, as a consequence of breadth, duration, and/or extent of relationship Increased considerably 0 0.0% Increased somewhat 0 0.0% Remained basically unchanged % Decreased considerably 0 0.0% Total % 45. Over the past three months, how have initial margin requirements set by your institution with respect to OTC credit derivatives referencing corporates (single-name corporates or corporate indexes) changed? A. Initial margin requirements for average clients Number of Respondents Percent

37 Page 37 of 93 Increased considerably 0 0.0% Increased somewhat 0 0.0% Remained basically unchanged % Decreased considerably 0 0.0% Total % B. Initial margin requirements for most-favored clients, as a consequence of breadth, duration, and/or extent of relationship Increased considerably 0 0.0% Increased somewhat 1 5.3% Remained basically unchanged % Decreased considerably 0 0.0% Total % 46. Over the past three months, how have initial margin requirements set by your institution with respect to OTC credit derivatives referencing securitized products (such as specific ABS or MBS tranches and associated indexes) changed? A. Initial margin requirements for average clients Increased considerably 0 0.0% Increased somewhat 0 0.0% Remained basically unchanged % Decreased considerably 0 0.0% Total % B. Initial margin requirements for most-favored clients, as a consequence of breadth, duration, and/or extent of relationship Increased considerably 0 0.0% Increased somewhat 0 0.0% Remained basically unchanged % Decreased considerably 0 0.0% Total % 47. Over the past three months, how have initial margin requirements set by your institution with respect to OTC commodity derivatives changed? A. Initial margin requirements for average clients Increased considerably 0 0.0% Increased somewhat 0 0.0% Remained basically unchanged %

38 Page 38 of 93 Decreased considerably 0 0.0% Total % B. Initial margin requirements for most-favored clients, as a consequence of breadth, duration, and/or extent of relationship Increased considerably 0 0.0% Increased somewhat 0 0.0% Remained basically unchanged % Decreased considerably 0 0.0% Total % 48. Over the past three months, how have initial margin requirements set by your institution with respect to TRS referencing nonsecurities (such as bank loans, including, for example, commercial and industrial loans and mortgage whole loans) changed? A. Initial margin requirements for average clients Increased considerably 0 0.0% Increased somewhat 0 0.0% Remained basically unchanged % Decreased considerably 0 0.0% Total % B. Initial margin requirements for most-favored clients, as a consequence of breadth, duration, and/or extent of relationship Increased considerably 0 0.0% Increased somewhat 0 0.0% Remained basically unchanged % Decreased considerably 0 0.0% Total % Nonstandard Collateral 49. Over the past three months, how has the posting of nonstandard collateral (that is, other than cash and U.S. Treasury securities) as permitted under relevant agreements changed? Increased considerably 0 0.0% Increased somewhat 0 0.0% Remained basically unchanged % Decreased somewhat 2 8.7% Decreased considerably 0 0.0% Total %

39 Page 39 of 93 Mark and Collateral Disputes 50. Over the past three months, how has the volume of mark and collateral disputes relating to contracts of each of the following types changed? A. FX Increased Considerably 0 0.0% Increased Somewhat 1 5.0% Remained Basically Unchanged % Decreased Somewhat % Decreased Considerably 1 5.0% Total % B. Interest rate Increased Considerably 1 4.8% Increased Somewhat % Remained Basically Unchanged % Decreased Somewhat 1 4.8% Decreased Considerably 1 4.8% Total % C. Equity Increased Considerably 1 5.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 1 5.0% Total % D. Credit referencing corporates Increased Considerably 0 0.0% Increased Somewhat 1 5.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 1 5.0% Total % E. Credit referencing securitized products including MBS and ABS Increased Considerably 0 0.0% Increased Somewhat 0 0.0%

40 Page 40 of 93 Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 1 5.9% Total % F. Commodity Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably % Total % G. TRS referencing nonsecurities (such as bank loans, including, for example, commercial and industrial loans and mortgage whole loans) Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 1 7.1% Total % 51. Over the past three months, how has the duration and persistence of mark and collateral disputes relating to contracts of each of the following types changed? A. FX Increased Considerably 0 0.0% Increased Somewhat 1 5.0% Remained Basically Unchanged % Decreased Somewhat 1 5.0% Decreased Considerably 1 5.0% Total % B. Interest rate Increased Considerably 0 0.0% Increased Somewhat 2 9.5% Remained Basically Unchanged % Decreased Somewhat 1 4.8% Decreased Considerably 1 4.8% Total % C. Equity

41 Page 41 of 93 Increased Considerably 0 0.0% Increased Somewhat % Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 1 5.0% Total % D. Credit referencing corporates Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 1 5.0% Total % E. Credit referencing securitized products including MBS and ABS Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 1 5.9% Total % F. Commodity Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably % Total % G. TRS referencing nonsecurities (such as bank loans, including, for example, commercial and industrial loans and mortgage whole loans) Increased Considerably 0 0.0% Increased Somewhat 0 0.0% Remained Basically Unchanged % Decreased Somewhat 0 0.0% Decreased Considerably 1 7.1% Total %

42 Page 42 of 93 Back to section top Securities Financing Questions 52 through 79 ask about securities funding at your institution--that is, lending to clients collateralized by securities. Such activities may be conducted on a "repo" desk, on a trading desk engaged in facilitation for institutional clients and/or proprietary transactions, on a funding desk, or on a prime brokerage platform. Questions 52 through 55 focus on lending against high-grade corporate bonds; questions 56 through 59 on lending against high-yield corporate bonds; questions 60 and 61 on lending against equities (including through stock loan); questions 62 through 65 on lending against agency residential mortgage-backed securities (agency RMBS); questions 66 through 69 on lending against non-agency residential mortgage-backed securities (non-agency RMBS); questions 70 through 73 on lending against commercial mortgage-backed securities (CMBS); and questions 74 through 77 on consumer ABS (for example, backed by credit card receivables or auto loans). Questions 78 and 79 ask about mark and collateral disputes for lending backed by each of the aforementioned contract types. If your institution s terms have tightened or eased over the past three months, please so report them regardless of how they stand relative to longer-term norms. Please focus your response on dollar-denominated instruments; if material differences exist with respect to instruments denominated in other currencies, please explain in the appropriate comment space. High-Grade Corporate Bonds 52. Over the past three months, how have the terms under which high-grade corporate bonds are funded changed? In this Section: High-Grade Corporate Bonds High-Yield Corporate Bonds Equities (Including through Stock Loan) Agency Residential Mortgage-Backed Securities Non-Agency Residential Mortgage-Backed Securities Commercial Mortgage- Backed Securities Consumer Asset-Backed Securities Mark and Collateral Disputes A. Terms for average clients 1. Maximum amount of funding Tightened Somewhat 0 0.0% Remained Basically Unchanged % Total % 2. Maximum maturity Tightened Somewhat 1 5.0% Remained Basically Unchanged % Total % 3. Haircuts Tightened Somewhat 0 0.0% Remained Basically Unchanged %

43 Page 43 of 93 Total % 4. Collateral spreads over relevant benchmark (effective financing rates) Tightened Somewhat % Remained Basically Unchanged % Total % 5. Other Tightened Somewhat 0 0.0% Remained Basically Unchanged % Eased Somewhat % Total % B. Terms for most-favored clients, as a consequence of breadth, duration and/or extent of relationship 1. Maximum amount of funding Tightened Somewhat 0 0.0% Remained Basically Unchanged % Total % 2. Maximum maturity Tightened Somewhat 1 5.0% Remained Basically Unchanged % Total % 3. Haircuts Tightened Somewhat 0 0.0% Remained Basically Unchanged %

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