Capital requirements for options are ‘crazy’ – DRW

Wilson says current rules penalise options, but SA-CCR does not go far enough to fix the problem

Don Wilson, DRW
Don Wilson, chief executive of DRW Trading

A new approach to measuring counterparty risk in derivatives transactions proposed by US regulators doesn’t go far enough to lower capital requirements for options portfolios, according to Don Wilson, chief executive of Chicago-based proprietary trading firm DRW Trading.

Wilson said the standardised approach to counterparty credit risk (SA-CCR), which will be used to calculate capital requirements for derivatives exposures, was a step up from its predecessor, the 30-year old current exposure method (CEM). But he said it still does a poor job of measuring options exposures.   

“I don’t think SA-CCR goes far enough in how it measures the risk of the capital impact of these big options portfolios,” said Wilson, speaking on a panel at a Futures Industry Association conference in Boca Raton, Florida on March 12.   

He stressed that SA-CCR is still an improvement over CEM, which generated outlandish capital requirements for some options portfolios.

“It’s not just in the equity options and index options, but also in the futures options, especially energy options – the numbers are just crazy,” Wilson said. “For portfolios that are pretty much risk-neutral or have nominal risk, the risk-weighted asset numbers can be hundreds of millions of dollars.”

The move to SA-CCR has been broadly welcomed by market participants, and there was plenty of support for it among other panellists. Nick Rustad, head of global clearing at JP Morgan, said SA-CCR was “an improvement on CEM,” while John Davidson, chief executive of the Options Clearing Corporation (OCC), called it a “very important change”.   

Under the proposal, banks with $250 billion or more in total consolidated assets, or $10 billion or more of on-balance-sheet foreign exposure, must use SA-CCR to calculate their leverage exposure and standardised risk-weighted assets. Smaller firms can choose whether to use SA-CCR or CEM.   

US banking regulators say SA-CCR will result in “more appropriate capital requirements for derivatives contracts exposure”. The comment period for the proposal expires on March 18.

But the approach has been criticised by some banks for producing “bizarre outcomes”, while regulators at the US Commodity Futures Trading Commission have raised concerns about its impact on clearing services.   

Speaking at the FIA conference earlier today (March 13), CFTC chairman Christopher Giancarlo warned that SA-CCR “would continue to disincentivise clearing members from providing clearing services”.

Giancarlo, along with CFTC commissioners Brian Quintenz, Rostin Behnam and Dan Berkovitz, took the unusual step of submitting a comment letter on the proposal, in which they argued that SA-CCR “would not adequately give credit to the risk-reducing impact of a clearing firm receiving and holding a client’s initial margin against a client’s derivatives position”.

The OCC’s Davidson echoed some of those concerns. The entire post-crisis capital regime “penalises clearing”, he said, calling it “an absurd state of affairs” that encourages further concentration in the marketplace.

“If you go home risk-neutral but still have these horrendous capital requirements, we are on the one hand encouraging concentration within the industry, which is not a good thing, and we are limiting the ability of well-capitalised clearing members, who understand these risks, to actually offer their services,” he said.

DRW’s Wilson said the capital rules, as they stand today, were forcing market participants to make difficult choices on central clearing.

“The reality is the numbers are still out of line of the actual risk [and] that forces changes in behaviour. It forces people to consider self-clearing, or forces people to move to less-capitalised FCMs [futures commission merchants] that are not banks,” he said. “Either way, that is an illogical way to push things.” 

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