Update on the hybrid Euribor methodology

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AL Update on the hybrid Euribor methodology Euro RFR Working Group 18 October 2018 Frankfurt am Main Jean-Louis Schirmann Secretary General

Overview A B C D E Euribor Reform Hybrid Euribor Testing Phase Overview of unsecured market activity Analysis: methodological choices Hybrid Euribor indicators 2

Euribor reform A Euribor Reform evolving the current quote-based determination calculation to a fully transaction-based methodology, in order to provide the market with a more transparent, robust, and representative index. The transaction-based Euribor methodology developed by EMMI sought to meet the following criteria: Be anchored in observable transactions whenever possible; Be robust in the face of market dislocation and command confidence that the benchmark remain resilient in times of stress; Minimize the opportunities for market manipulation. 2016/17 pre-live verification program the daily determination of the index would be based, for most tenors, on a limited number of transactions executed by a limited number of contributors: a fully transaction-based benchmark is not robust. The current quote-based methodology for Euribor is not BMR-compliant. 3

Euribor reform A Benchmark Specification: Euribor s Underlying Interest The current Euribor specification comes with a number of shortcomings, related to elements in its statement that may be considered open for subjective interpretation: the rate at which euro interbank deposits are being offered within the EU and EFTA countries by one Prime Bank to another at 11AM Brussels time. interbank being offered Prime Bank at 11 AM the use of interbank transactions in the original Euribor specification reflects the structure of the money markets in the 1980s and 1990s when bank to bank activity was a predominant source of bank wholesale funding the family of IBOR indices are based upon and aimed at representing funding markets. This is supported by the fact that LIBOR, originally evolved as a standardized benchmark for the pricing of floating rate corporate loans. Prime Bank has never been precisely defined. The Prime Bank historically represented both a concept of the financial standing of the party borrowing funds and of a substantial party supplying funds. wholesale borrowing own cost of funds Euribor is a measure of the rate at which wholesale funds in euro could be borrowed by credit institutions in the EU and EFTA countries in the unsecured money market 4

Euribor reform A Hybrid methodology for Euribor Hybrid methodology supported by transactions whenever available, but relies on other techniques or data sources according to input criteria established by EMMI The hybrid methodology follows a hierarchy. For each day in which the index is calculated, contributing banks will have to base their submissions, for each tenor, on: Schematic description Hybrid Euribor methodology Level 1 Submission based solely on transaction in the Underlying Interest at the Defined Tenor from the prior TARGET date, using a formulaic approach provided by EMMI. Level 2 Submission based on transactions in the Underlying Interest across the money market maturity spectrum and from recent TARGETdays, using a defined range of formulaic calculation techniques provided by EMMI. Level 2.1 Level 2.2 Level 2.3 Spread Adjustment Interpolation based on Level 1 submissions at adjacent tenors Use of Non-Standard Maturity Transactions Submission based on market-adjusted Level 1 submissions from prior dates Level 3 Submission based on transactions in the Underlying Interest and/or other data from a range of markets closely related to the unsecured euro money market, using a combination of modeling techniques and/or the Panel Bank s judgement. 5

Overview A B C D E Euribor Reform Hybrid Euribor Testing Phase Overview of unsecured market activity Analysis: methodological choices Hybrid Euribor indicators 6

Hybrid Euribor Testing Phase B To finalize the design of the methodology, a test under live conditions was conducted by EMMI from May until end of July 2018. Sixteen (16) out of the 20 panel banks agreed to participate in the exercise. All panel banks were asked to develop a Level 3 submission methodology following the guidelines provided by EMMI, and EMMI collected their documented procedure ahead of the start of the Testing Phase. Out of the 16 participating banks, EMMI decided to fully exclude the contributions of one bank, as their submissions were not in line with the underlying interest for Euribor. Publication of Second Public Consultation on Hybrid Methodology for Euribor on 17 October 2018. 7

Overview A B C D E Euribor Reform Hybrid Euribor Testing Phase Overview of unsecured market activity Analysis: methodological choices Hybrid Euribor indicators 8

Overview of unsecured money market activity C 1 Public available sources of data to gauge unsecured money market activity: For overnight interbank lending: EONIA (28 reporting banks) For overnight and term borrowing and lending: ECB s MMSR (52 reporting banks) O/N lending volume Eonia volume EUR Billion 12 10 8 6 4 2 0 Mar 17 May 17 Jun 17 Jul 17 Sep 17 Oct 17 Dec 17 Jan 18 Mar 18 May 18 Jun 18 Jul 18 EUR Billion 140 120 100 80 60 40 20 0 Interbank lending volume Interbank borrowing volume Wholesale Borrowing Volume Mar 17 May 17 Jun 17 Jul 17 Sep 17 Oct 17 Dec 17 Jan 18 Mar 18 May 18 Jun 18 Jul 18 9

Overview of unsecured money market activity C 2 EMMI has gained further visibility on the market underpinning Euribor during the Pre-Live Verification Program (PLVP, which run from Sept 16 Feb 17) and the Hybrid Euribor Testing Phase (HETP, from May 18 July 18). Number of transactions 90 80 70 60 50 40 30 20 10 0 6.0 5.0 4.0 3.0 2.0 1.0 0.0 Volume (EUR billion) PLVP Volume (billions) HETP Volume (billions) PLVP N of transactions HETP N of transactions Average daily PLVP data restricted to common participants in HETP 10

Overview A B C D E Euribor Reform Hybrid Euribor Testing Phase Overview of unsecured market activity Analysis: methodological choices Hybrid Euribor indicators 11

Analysis: methodological choices D 1 The methodology is organized in three levels. The analysis provided a basis for EMMI to decide on the final blueprint: Parameter/feature Considered options # Level 1 (transaction-based) Maturity buckets Narrow or broad 2 Transactions with NFCs* Included or excluded 2 Transactions at a floating rate Included or excluded 2 Volume thresholds None, 10 mio., or 20 mio. 3 Number of transactions threshold 1, 2, or 3 3 Level 2 (transaction-derived) Level 3 (Level 2.1) Spread Adjustment Factor SAF** (Level 2.3) Market Adjustment Factor MAF 1, 3, 5, 10, and without SAF 5 4, 5, 6, 7, and no use of futures 5 Aggregation Outlier removal technique Trim 0.15, Trim 0.20, Median group 3 *NFC stands for Non-Financial Corporate **SAF and MAF stand for Spread Adjustment Factor and Market Adjustment Factor, respectively. A full definition can be found in the Second Consultation on the Hybrid Methodology for Euribor. 5,400 12

Analysis: methodological choices D 2 Analysis structured to separate decisions for Level 1 input data from other parameters and considerations (arising from Level 2 or aggregation method). Level 1 Maturity buckets Transactions with NFCs Transactions at a floating rate Volume thresholds Number of transactions threshold Broad Excluded Included 20 mio. 1 transaction Increase in the average daily volume considered in the determination of the index without significant impact on average rate level and standard deviation. While numerous, analyses conclude its inclusion would increase the index s volatility for reasons not directly related to the ability of a reporting bank to attract funds. Fixed-rate equivalent contribute to the anchoring of the index in real transactions conducted at market price. Significant source of funds for French reporting entities. Analyses reveal a reduction in the standard deviation of the sample when considering a higher threshold. In addition, a higher volume threshold acts as a deterrent for counterparties to panel banks to influence the index. Levels of liquidity in the unsecured euro money market do not allow for a higher threshold. The statistical analysis reveals no significant impact on an increase in the threshold. The number of Level 1 contributors would, however, decrease further. 13

Analysis: methodological choices D 3 Following these choices, 75 designs for the methodology remained eligible. Level 1 (transaction-based) Maturity buckets Broad Parameter/feature Considered options # Transactions with NFCs* Transactions at a floating rate Volume thresholds Excluded Included 20 mio Number of transactions threshold 1 Level 2 (transaction-derived) Level 3 (Level 2.1) Spread Adjustment Factor SAF** (Level 2.3) Market Adjustment Factor MAF 1, 3, 5, 10, and without SAF 5 4, 5, 6, 7, and no use of futures 5 Aggregation Outlier removal technique Trim 0.15, Trim 0.20, Median group 3 *NFC stands for Non-Financial Corporate **SAF and MAF stand for Spread Adjustment Factor and Market Adjustment Factor, respectively. A full definition can be found in the Second Consultation on the Hybrid Methodology for Euribor. 75 14

Analysis: methodological choices D 4 The remaining parameters allow certain level of control on the frequency of reliance of the submitting panel bank in Level 3. [Under the assumption the panel bank has transactions or recent level 1 submissions.] Minimize panel banks reliance on Level 3 The aggregation method allows a certain level of control over the impact of outlier submissions in the index. Control the effect of outlier submissions on the volatility of the index Any choice must guarantee the index s responsiveness to market events, e.g. changes in ECB s key interest rates or changes in funding dynamics in countries in the Eurozone. In this respect, too long lookback periods, or excessive use of market-related information could introduce a lag. 15

Analysis: methodological choices D 5 Each point in this scatterplot represents a particular choice of the triple (SAF, MAF*, aggregation method). 1.15 1.10 1.05 1.00 0.95 0.90 0.85 0.80 Tenor 1W 1M 3M 6M 12M Vola 0.75 0.70 0.65 0.60 0.55 0.50 0.45 0.0 0.2 0.4 0.6 0.8 1.0 0.0 0.2 0.4 0.6 0.8 1.0 0.0 0.2 0.4 0.6 0.8 1.0 0.0 0.2 0.4 0.6 0.8 1.0 0.0 0.2 0.4 0.6 0.8 1.0 Level 3 % Level 3 % Level 3 % Level 3 % Level 3 % *SAF and MAF stand for Spread Adjustment Factor and Market Adjustment Factor, respectively. A full definition can be found in the Second Consultation on the Hybrid Methodology for Euribor. 16

Analysis: methodological choices D 6 SAF = 5 (to allow for the yield curves of the panel banks to reflect the curvature of recent days). 1.15 1.10 1.05 1.00 Tenor 1W 1M 3M 6M 12M MAF = 4 (moderate look back period, to allow for changes in the market to be reflected in panel banks submissions when using prior days data) Need to guarantee rate responsiveness to market events. Alternatives do not offer significant changes on volatility of resulting rate, nor significant reduction on fall-back to Level 3 submissions. Vola 0.95 0.90 0.85 0.80 0.75 0.70 0.65 0.60 0.55 0.50 0.45 0.0 0.5 1.0 0.0 0.5 1.0 0.0 0.5 1.0 0.0 0.5 1.0 0.0 0.5 1.0 Level 3 % Level 3 % Level 3 % Level 3 % Level 3 % 17

Analysis: methodological choices D 7 The final parametrization of the methodology is then: Parameter/feature Considered options Level 1 (transaction-based) Maturity buckets Broad Transactions with NFCs Excluded Transactions at a floating rate Included Volume thresholds 20 mio Number of transactions threshold 1 Level 2 (transaction-derived) Level 3 (Level 2.1) Spread Adjustment Factor (Level 2.3) Market Adjustment Factor 5 4 Aggregation Outlier removal technique Trim 0.15 1 18

Overview A B C D E Euribor Reform Hybrid Euribor Testing Phase Overview of unsecured market activity Analysis: methodological choices Hybrid Euribor indicators 19

Hybrid Euribor indicators Reliance on hybrid methodology levels (SAF = 5, MAF = 4, Trim 0.15) E 1 20

Hybrid Euribor indicators Euribor under quote-based methodology E 2 Current Euribor, 5 tenors Euribor 1W Euribor 1M Euribor 3M Euribor 6M Euribor 12M 0-0.1 Upper C =MovAvg(Eur C 12M + StDev(Eur C 12M ),7) -0.2-0.3-0.4 Lower C =MovAvg(Eur C 1W - StDev(Eur C 1W ),7), -0.5 21

Hybrid Euribor indicators Euribor under hybrid methodology E 3 Current Euribor, 5 tenors Hybrid Euribor, 5 tenors 0-0.1 Upper Hyb =MovAvg(Eur 12M Hyb + StDev(Eur 12M Hyb ),7) -0.2-0.3-0.4 Lower Hyb =MovAvg(Eur 1W Hyb - StDev(Eur 1W Hyb ),7). -0.5 22

Hybrid Euribor indicators Pure Level 1 index, fully transaction-based E 4 Fully Level 1 index, 5 tenors Current Euribor, 5 tenors Hybrid Euribor, 5 tenors 0 Upper L1 =MovAvg(Rate 12M L1 + StDev(Rate 12M L1 ),7) -0.1-0.2-0.3-0.4-0.5 Lower L1 =MovAvg(Rate 1W L1 - StDev(Rate 1W L1 ),7). 23

Appendix: supporting charts 24

Analysis: methodological choices Non-financial corporate counterparties 1 Transactions with non-financial corporate counterparties are ubiquitous S11 All rates Excluding 0 rates 1W 184 153 1M 134 77 3M 69 21 0.4 0.3 0.2 0.1 Tenor Counterparty Sector S2 S11 S13 S121 S122 S123 S124 S125 S128 S129 0.4 0.3 0.2 0.1 Tenor 6M 112 19 12M 249 12 0.0 0.0 No Valid Tenor 1367 1190-0.1-0.1 but the data confirms their pricing is guided by factors not directly related to banks funding needs. -0.2-0.3-0.4-0.2-0.3-0.4-0.5-0.5-0.6-0.6 1W 1M 3M 6M 12M 1W 1M 3M 6M 12M 25

Analysis: methodological choices Floating rate transactions linked to EONIA 2 Floating rate transactions, however, are priced at market levels. They are an important instrument for some tenors for the 12 months, trades executed at a floating rate exceed the volume of trades with fixed rates. 0.4 0.3 0.2 0.1 0.0-0.1-0.2 Tenor Counterparty Sector S2 S13 S121 S122 S123 S124 S125 S128 S129 0.4 0.3 0.2 0.1 0.0-0.1-0.2 Tenor Floating rates 1W 1M 3M 6M 12M -0.3-0.3 Interbank -- -- -- 50 mio 575 mio Official Sector Other Financials -- -- -- -- 925 mio -- -- 360 mio -- -- -0.4-0.5-0.6-0.4-0.5-0.6 1W 1M 3M 6M 12M 1W 1M 3M 6M 12M 26