1. Market needs and developments for liquidity management at the end of day

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1 FEDERATION BANCAIRE DE L'UNION EUROPEENNE BANKING FEDERATION OF THE EUROPEAN UNION BANKENVEREINIGUNG DER EUROPÄISCHEN UNION (aisbl) EUROPEAN SAVINGS BANKS GROUP GROUPEMENT EUROPEEN DES CAISSES D EPARGNE UROPÄISCHE SPARKASSENVEREINIGUNG EUROPEAN ASSOCIATION OF COOPERATIVE BANKS GROUPEMENT EUROPEEN DES BANQUES COOPERATIVES EUROPÄISCHE VEREINIGUNG DER GENOSSENSCHAFTSBANKEN COGESI Secretariat European Central Bank Kaiserstrasse Frankfurt am Main DM/MT EBF_ Brussels, 15 February 2013 Subject: TARGET Working Group response to the COGESI survey on infrastructural requirements supporting liquidity management at end of day Dear Sir/Madam, This response is submitted by the TARGET Working Group (TWG) which is the corresponding European banking industry group to the Eurosystem Working Group TARGET 2 (WGT2). The interest of the TWG in the survey is due to the essentiality of the liquidity provision to the functioning of TARGET2. The TWG is a European WG coordinated by the European Credit Sector Associations (EBF, ESBG, and EACB). Since the survey on Minimum Common Features of Tri-party Interoperability only has an indirect effect on cash operations, the TARGET Working Group does not offer any comments. TARGET WG Avenue des Arts 56, B-1000 Brussels Contact person: Denisa Mularova (d.mularova@ebf-fbe.eu) 1. Market needs and developments for liquidity management at the end of day 1.1 What are the market developments that have a major/irreversible impact on the existing financing arrangements available in the banking system at the end of day? (What is the evidence of this impact?) Since this survey is issued by COGESI we have assumed that comment is only required in respect of euro. - This survey appears to be largely restricted to operational type issues but must, we believe, be considered in relation to Eurosystem monetary policy, including the requirement for equal treatment of all counterparties, on the one hand and bank balance sheet management on the other. These issues are reflected in the further comments below. - A major market development since the financial crisis has undoubtedly been

2 - the requirement for collateralised financing/ support from non-central bank counterparties and FMIs following the financial crisis leading to an increase in the collateralized market Increased use of secured funding, not only in the interbank market but increasingly from traditional unsecured cash depositors (e.g. corporates, asset managers). This is evidenced amongst other things by the creation of dedicated segments in certain organised markets An increased focus on the re-use of collateral towards the central bank, acting as a lender of last resort. Decrease in the EONIA volume The development of securities lending segments on electronic platforms and with CCP functionality - Another important factor is the stability of Eurosystem monetary policy. Over recent years, with the exception of restrictions on Greek bonds for collateral purposes which was partly reversed by the ECB's announcement on 19 December 2012 of a change in the eligibility of debt instruments issued or guaranteed by the Greek government, the trend has been towards relaxation of eligible collateral requirements. This is exemplified by the ECB's announcement on 22 June 2012 of additional measures to improve the access of the banking sector to Eurosystem operations in order to further the provision of credit to households and nonfinancial corporations. - It is considered that end of day liquidity management arrangements must assume the possibility of a tightening of monetary policy at short notice. In this connection, it is noted that the measures to preserve collateral availability announced on 6 September 2012 involve a suspension of the application of the minimum credit rating threshold and temporary acceptance of marketable debt instruments in USD, GBP and JPY albeit in both cases subject to conditions. However, the key point is that these are temporary measures. - Another factor is Eurosystem monetary policy operations including longer - term refinancing operations (LTRO) which have resulted in some banks maintaining large balances under the deposit facility notwithstanding a zero interest rate, thus reducing the need to access the marginal lending facility or other sources of liquidity. - In the longer term, LCR requirements may also affect the amount and type of eligible collateral which banks have available for end of day funding/liquidity management. It follows that banks' use of end of day central bank financing arrangements will need to take into account both the requirement for collateral for other purposes including supporting FMI operations and interbank lending plus potential changes, possibly at short notice, including a tightening of Eurosystem monetary policy. 1.2 What are the market needs for enhancing or changing the current liquidity management at the end of day? In particular, is there a demand for settlement of collateralised (repo) transactions later in the day (i) for funding reasons, (ii) because of globalisation, (iii) other reasons? (please specify) Subject to banks having sufficient eligible collateral, banks need the ability to obtain finance from Eurosystem central banks as late as possible in order to square their positions. This is particularly important where expected payments from third parties do not arrive. This is required: 2

3 (i) for funding purposes in case of a miscalculation of their position or, as stated above, the failure of expected funds to arrive. (ii) because of globalisation where banks manage their liquidity on a multi-currency global basis in different time zones. (iii) to have maximum flexibility in a crisis situation where counterparties may be delaying payments whether because they are concerned about the financial health of the recipient or they themselves do not have sufficient liquidity. There is a need to extend the settlement of collateralised transactions to later in the day. Except for GC Pooling that offers trading until 16h00, O/N electronic trading is possible until 12h00 at the latest. Since the unsecured market no longer provides the certainty to buffer exceptional outflows in the afternoon, the repo markets should be available for this reason. There is also a need to extend the cut-off times for depository transfers and to increase the access to central banks out of the different (I)CSDs. Today, market participants are forced to keep collateral at local depositories for specific markets to balance between access to O/N trading and central banks. Full interoperability must be ensured between trading platforms, CCPs and settlement /triparty agents, allowing trading out of the settlement/triparty agent of choice, through the CCP of choice and on the preferred platform. 1.3 What are the current limitations stemming from rules and procedures of market infrastructures for liquidity management at end of day (please specify for domestic and/or cross-border settlement)? In particular for cross-border settlements, are current arrangements and operating hours 1 of (I)CSDs/links supporting repo (including triparty repo) at the end of day? Are there other limitations (e.g. legal or contractual barriers)? The main current limitations relate to multi-country banks operating cross-border and stem from:- - Slowness of the current CCBM process. - CSDs and other FMIs operating in silos with their own operating hours and detailed procedures. Markets and central banks are not accessible out of every (I) CSD. Cut-off times for same day settlement do not allow the transfer of securities to the required depository later in the day. Hence, banks are required to maintain pockets of collateral in different systems. There is a need for double collateral in certain markets, originating from the requirement to pay early the cash leg of the transaction without having a credit from the collateral leg. Certain markets operate with domestic settlement and others with ICSD settlement, thus leading to the need to maintain collateral sometimes in a domestic system and for other types in an ICSD. Central banks do not always accept eligible collateral originated in certain systems, e.g. triparty collateral. 1 Some CSDs for example, currently do not operate after 3.00 or 4.00 pm CET for same-day settlement and many links have earlier cut-off times. 3

4 Similarly central banks do not always accept all links between (I)CSDs and the Eurosystem - Legal restrictions in some jurisdictions including registration requirements and outsourcing restrictions. A number of these issues are expected to be resolved by the CSDR. - Location of securities and taxation requirements. 1.4 What do you think are the major changes in market practices triggered from an extensive use of collateralised money market transactions for end-of-day liquidity management? This question appears to be reversing cause and effect. Put another way, arguably it is the substantial reduction in unsecured facilities which has driven the requirement for collateralised financing from both central bank and non-central bank sources. The consequence has been the need for banks to manage their balance sheets more proactively in order to ensure they have sufficient eligible collateral available and are in a position to accommodate changes in Eurosystem monetary policy. The major changes in market practices are as follows: Multiplication of domestic market initiatives (E-Mid, Collateral Basket with Pledge) leading to further fragmentation. Increased use of CCPs for collateralised transactions, even if the Initial Margin requirements are significant. Increased importance of the link with the domestic central bank Focus on collateral quality and collateral optimisation/upgrade 1.5 What do you think are the major costs and benefits for infrastructure and participants triggered from an extensive use of collateralised money market transactions for end-ofday liquidity management? The benefit is funding certainty provided banks ensure they have adequate eligible collateral available whereas the cost is carrying such assets on their balance sheets. However, Basel Committee requirements including LCR are likely to exert an increasing influence. Cost Due to the fragmentation/lack of interoperability, there is a need to keep securities in different systems which is inefficient. The use of CCPs leads to costly Default Fund and Initial Margin requirements, especially the additional requirements as the result of the Euro crisis. In certain systems, double collateral is required for intraday liquidity to enable timely settlement The limitation of CCPs to the better spectrum of collateral Benefits Netting benefits from working through a CCP Anonymous trading enables access to market liquidity even in the event of a name crisis Access to a significantly larger pool of liquidity compared to the unsecured market 4

5 2. Improvements in infrastructural rules, procedures and processes 2.1 To what extent will T2S address the identified needs and concerns? There are expected to be two main benefits from T2S once it is fully operational. The first is likely to be increased operational efficiency, particularly on a cross-border basis, allowing participant banks to optimise use of eligible collateral and resulting funding. The second is driving harmonisation of both procedures and especially cut-off times. 2.2 Would T2S introduce limitations to the smooth functioning of repo markets at the end of day? If so, what limitations? In times of crisis banks need to have the possibility to go to the repo market, close to the cut off time of payment/settlement systems. 2.3 Should efforts be devoted to addressing operating hours before the launch of T2S or is it sufficient to await the complete migration of all participating CSDs to T2S at end-2016, by which time there should be common cut-offs? Preparatory work to harmonise operating hours should be undertaken before the launch of T2S and implemented at the earliest realistic opportunity. A major reason for saying this is that we regard it as essential to avoid a situation where T2S does not completely resolve the situation and there is then a further delay. 2.4 In 2014, Eurosystem collateral management procedures will be upgraded to support triparty collateral management services on a cross-border basis. What additional measures (if any) would be needed (from the Eurosystem)? Ideally the implementation of a common collateral system throughout the euro monetary area which also replaces the existing correspondent central banking model as CCBM 2 was intended to do. The acceptance of re-use in triparty, enabling mobilisation of eligible securities received in triparty with the central bank, either for end of day liquidity management or for intraday liquidity to facilitate settlement. The possibility to mobilise all eligible securities via triparty. * * * 5