Revisiting the Importance of Inventory Management in Collateral and Liquidity

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In this article in Securities Finance Monitor, Transcend’s CEO Bimal Kadikar discusses the opportunities for more effective liquidity and collateral management – and the potential benefits to the bottom line. A solid starting point is inventory management whereby firms can match collateral to needs, improve front-to-back office communications and increase operational efficiency and compliance.

Inventory management is a cornerstone of securities finance, funding and collateral management, but often gets little attention until it is too late. This should not be the case, as inventory management is the first thing that buy-side and sell-side firms should pay attention to when getting serious about collateral and liquidity management. Inventory management is the foundation on which efficient businesses are built, including putting context around a firm’s positions.

Theoretically, it should be possible to aggregate data easily, then buy or build technology to run reports and connect to counterparties later on. After all, there many vendors with algorithms and reports that help a user select the right collateral to deliver. Likewise, there are many ways to connect to the market, between point to point connectivity, FTP, SWIFT and cloud intranets. However, this plan does not always work out well in practice. The development of mono-line systems and use cases means that unless inventory and trade data is harmonized across the enterprise first, reports and counterparty connectivity largely falls short of expectations.

The common challenge that vendors and clients face is how comprehensive and normalized is the information being collected. A collateral management system with only 50% of a firm’s available position and inventory data is less than 50% effective at its objective: successfully delivering the right collateral at the right time or incentivizing the right business behavior to reduce costs, including better risk management.

The natural response to this situation is to collect all pockets of inventory into one pool so traders and allocators of collateral can pull information on all activity and holdings from a single source. This is the point where most firms pause. For example, do they know where all their inventory information is held and in what form across products and geographies? Are all the pricing sources across inventory consistent, or did they grow up independently because of divisions or acquisitions? Do collateral managers know the details behind vast amounts of security line items, CUSIPs and ISINs to make smart decisions? The inventory management organization process can be the start of a reasonably large project.

Why invest strategically?

It often takes an external stimulus to get serious about strategic inventory management; recent mandates for effective liquidity and collateral management are good examples. But it can’t just sound good on paper: the benefits need to be impactful to the bottom line. As a result, it is often helpful to conduct a cost-benefit analysis that shows what is at stake. As a one-time exercise, this can demonstrate the payback on inventory management. We have seen this in practice across multiple firms that initially looked at collateral management technology for reports and straight-through processing, then came to find that the more inventory was available in the system that significant returns could be generated. These returns can more than pay for the cost of an inventory management and optimized collateral technology system combined.

Regulators across the globe have increased their scrutiny on collateral management as well. As part of the Recovery & Resolution Planning and/or Reg YY collateral management requirements, firms have to prove enterprise level collateral and liquidity management capabilities. Very few firms can claim compliance to these requirements in an automated way and will require significant changes in the overall platform. This could be a great opportunity for firms to invest in enterprise level real-time inventory management capabilities that will help them comply with regulatory pressures but also provide significant business and operational benefits for the firm.

Tracking monetary value to collateral utilization

Proper inventory management requires the ability to efficiently utilize collateral by knowing what positions are available at any given time along with having rich context around each position (see Exhibit 1). The context includes for how long will a position be available; who is the owner; is the position owned by the firm or a client; can it be rehypothecated; and where can it be pledged at the lowest haircut. This enrichment process is largely still not conducted by every firm. More often, a lack of understanding the value of collateral results in the asset owner simply losing out with no benefit to anyone else, and a net loss to the market as assets are tied up for the duration of a trade.

Exhibit 1: Generating results from robust inventory management

 

 

 

 

 

 

 

 

 

 

Source: Transcend Street Solutions

A robust view of collateral also means that front to back office communications become more precise and efficient, especially across global firms with different pools of assets. A successful inventory management process can reduce operational duplications, as one operations team can now see and manage one aggregated set of information about the firm’s holdings. More information on inventory means that front office traders can have a real-time window into what collateral is available to trade or post. This is a central tenet of the collateral trading business and serves to augment a trader’s opportunities in the marketplace.

Enhanced optimization opportunities

As firms create central collateral funding desks, reliable inventory management enables the efficient allocation of collateral for proper matching of sources and uses.  This means matching the right asset with the right liability.  Doing so could mean real savings to both capital and liquidity. But having the best model is only as good as one’s ability to see the full collateral picture.  A robust inventory management platform should improve only the visibility into the quantity of collateral held across an organization. It should also improve the confidence and ability of the organization to take actions based on that improved transparency. This better information will incentive trading behavior to maximize financial efficiencies comprehensively across balance sheet, funding and liquidity. Conversely, a collateral shortfall or poor data means that a funding trader is more likely to look outside the firm to access supply, likely resulting in increased balance sheet costs and capital usage.

In a real-world example of how collateral optimization works best with effective inventory management, a collateral manager may want or need to post G7 government bonds as collateral. Presuming five different collateral pools, there are multiple scenarios that can occur:

  1. With visibility into one collateral pools:
    1. The manager would have a limited inventory to source, resulting in few options and the potential need to look outside the firm.
    2. The manager may need to use cash, which would remove the firm’s investment options in other business areas.
    3. The manager could elect to repo in government bonds or borrow in a securities loan to post as collateral. Depending on the scarcity of the government bonds, they could either be paid to lend cash or be obligated to pay to borrow.
  2. With visibility into all five collateral pools:
    1. The manager could evaluate the cost of collateral pre-trade at an affiliate and borrow that collateral in exchange for a known fee that can be priced into a transaction in advance.
      1. This pre-trade analysis can become part of the daily operational trading activities of the firm.
    2. The manager and a collateral operations teams have a better opportunity to allocate cheapest to deliver collateral across all pledge requirements. Avoiding the need to go outside firm helps minimizes balance sheet and RWA costs.

Real-time operational efficiencies

Aggregating collateral yields operational benefits that may be difficult to quantify up front but that result in long-term benefits to the firm. A visibility into position breaks and errors in real time means faster response times to fails. In an era where repeated and unresolved fails have a direct financial impact, faster resolution of fails means money saved in the form of reduced operational RWA, better customer satisfaction, a reduced number of delivery instructions and a faster escalation when greater risks are identified.

Inventory management provides a framework to address typically buried settlement and operations risk. The ability to see and think through potential pitfalls that may have been hidden as a result of lack of inventory clarity gives both the front and back office more precise decision-making capabilities. This allows for root cause analysis of breaks and errors, ideally leading to a virtual elimination of the most frequent causes of fails.

The result of improved operational efficiency means lower collateral turnover and the costs this entails. Our clients also report an improved experience for clients and counterparties in the collateralized trading process. Greater operational efficiencies have a direct and positive outcome of the trading process.

A wider benefit to the firm

Inventory management projects can often be a starting point to greater benefits for a financial services firm. I have already mentioned operational and pricing benefits, but these are just the start. Once an inventory consolidation project is underway, firms may find duplicate vendors and functional roles that can be reorganized as cost savings measures. They may also find that additional trading and portfolio management opportunities appear as a result of better information flows. Inventory management can be difficult to consider, especially for complex institutions, but the financial, operational and risk management benefits are nearly always worth the effort.

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Building a Holistic Collateral Infrastucture

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Following the financial crisis, regulations and their associated reporting have created an opportunity for banks and investment firms to create a single, unified collateral infrastructure across all product siloes. This does not have to be a radical architecture rebuild, but rather can be achieved incrementally.

There are legitimate historical reasons why collateral infrastructure has grown up as a patchwork of systems and processes. For products such as stock lending, repo, futures or contracts for difference (CFDs), the collateral/margining process was generally integral to the products and processing systems. It would not have made sense to break out collateral management into a separate group and hence operating teams and systems were structured around the core product unit. Generally, only OTC derivatives had a relatively clear decoupling between collateral management and other operational processes. Even as business units merged at the top level, this product separation at the collateral management level often continued.

While this situation could stand during non-stress periods, the financial crisis demonstrated the fallacy that siloed, uncoordinated collateral management systems, data and processes could weather any storm. This disjointed view caused a number of specific problems, including: an inability to see the full exposures to counterparties; a lack of organization in cash and non-cash holdings; and substantial inflexibility in mobilizing the overall collateral pool. Even before the crisis, inconsistent or “zero cost allocation” for collateral usage meant that collateral was not always being directed to the parts of the business that needed it most. After the crisis, with collateral and High Quality Liquid Assets at a premium, this became unacceptable.

Today, few banks and investment firms have completed the work of integrating their collateral management functions across products (see Exhibit 1). Some of the largest banks are focused on building capabilities to achieve enterprise-wide collateral optimization, while others are just starting on this effort, at least on a silo basis. Some have bought or built large systems with cross-product support, although this has proven costly. Others are evaluating organizational consolidation. Whatever their current state, a new round of regulatory reporting requirements in the US and Europe means that letting collateral infrastructure sit to one side is no longer viable to meet business or compliance objectives without adding substantial staff. One way or another, long-term solutions must be achieved.

Exhibit 1: Moving past the siloed approach

Source: Transcend Street Solutions

 

The next round of regulatory impact

While nearly all large firms have digested the current waves of regulatory reporting and collateral management requirements, the next round will soon be arriving. Among these are the Federal Reserve’s regulation SR14-1, MiFID II (Revision of the Markets in Financial Instruments Directive), and the Securities Finance Transactions Regulation (SFTR). It is worth looking at some of these requirements in detail to understand what else is being demanded of collateral management infrastructure and departments.

The Federal Reserve’s regulation SR14-1 is aimed at improving the resolution process for US bank holding companies. It includes a high level requirement that banks should have effective processes for managing, identifying, and valuing collateral it receives from and posts to external parties and affiliates.[1] At the close of any business day banks should be able to identify exactly where any counterparty collateral is held, document all netting and rehypothecation arrangements and track inter-entity collateral related to inter-entity credit risk. On a quarterly basis they need to review CSAs, differences in collateral requirements and processes between jurisdictions, and forecast changes in collateral requirements. Also on the theme of improved resolution rules are the record keeping requirements related to “Qualified Financial Contracts” (effectively most non-cleared OTC transactions).[2] These require banks to identify the details and conditions of the master agreements and CSAs applying to the relevant trades.

While the regulatory intent is understandable, these requirements are exceptionally difficult to meet without a unified collateral infrastructure. There is in fact no way to respond without a single, holistic view of collateral and exposure across the enterprise. While SR14-1 impacts only the largest banks, it still means these banks have a mandate to complete the work they have begun in organizing their vast collection of collateral information. This will lead to greater collateral opportunities for the big banks, and may in turn encourage smaller competitors to complete the same work in order to exploit similar new efficiencies.

Article 15 of Europe’s SFTR places restrictions on the reuse of collateral (rehypothecation). The provider of collateral has to be informed in writing of the risk and consequences of their collateral being reused. They also have to provide prior, express consent to the reuse of their collateral. Even with the appropriate documentation and reporting in place, a collateral management department has to carefully ensure that the written agreement on reuse is strictly complied with. While nothing is written in the US yet, market participants believe that the US Office of Financial Research will soon require mandatory reporting that may entail overlapping requirements.

Similarly, MiFID II introduces strict restrictions on the use of customer assets for collateral purposes and potentially has a major impact on collateralized trading products. A complicated analysis must be conducted on best execution, but in OTC and securities financing markets, best execution may be a function of term, price, counterparty risk and/or collateral acceptance. Further, any variation from a standard best price policy needs to be documented to show how the investment firm or intermediary sought to safeguard the interest of the client.

SFTR and MiFID II require that banks rethink their entire reporting methodologies, and in some cases must rethink parts of their business model. A wide range of new information must be captured, analyzed, consolidated, and reported outwards and internally. This will likely generate new ideas and business opportunities around collateral usage and pricing for those firms that can digest the large quantities of new information that will be produced.

A holistic foundation for trading, control, MIS and regulatory reporting

The struggle at many firms to comply with regulations while maximizing profitability has led to two parallel sets of infrastructures: one for the business and another for compliance. This creates two levels of cost that duplicate substantial effort inside the firm. Along the way, business lines get charged twice for this work as costs are allocated back to the business. This is an immediate negative impact on profitability; even firms that have completed collateral optimization immediately lose a piece of that financial benefit.

The cumulative impact of regulation means that banks and investment firms generally cannot afford to wait for consolidation projects to deliver a single integrated platform. The fragmentation of teams, data and processes are hurdles for any institution to overcome but so is the old mindset that simply thinks of collateral management as an isolated operational process.

We identify five critical areas for firms to address in order to create a foundation for their holistic collateral infrastructure:

  • Map the full impacts of regulatory and profitability requirements on businesses, processes, and systems.
  • Recognize that collateral management is an integral part of many key activities at the firm including trading and liquidity management.
  • Understand the core decision making processes at the heart of effective collateral management.
  • Organize and manage the data that is required to drive those processes.
  • Build a functional operating model for collateral management.

The fifth recommendation, building a functional operational model for collateral, means being able to connect together disparate business lines to provide an enterprise view of collateral. It includes mining collateral agreements to make optimal decisions or decisions mandated by regulation. It requires the ability to perform analysis of collateral to balance economic and regulatory drivers, and it requires controls and transparency of client collateral across all margin centers.

At Transcend Street Solutions, we are actively working with our clients to help them develop a strategic roadmap of business and technology deliverables to achieve a holistic collateral infrastructure. While there are always organizational as well as infrastructural nuances in every business, we have seen the framework proposed above yield a positive return for our clients. Our technology platform, CoSMOS, is nimble, modular and customizable to accelerate collateral infrastructure evolution without necessarily having to retire existing systems or undergo a big infrastructural lift.

Getting this right is important for more than just regulatory compliance. It means the collateral function and trading desks can perform the forward processes required to support both profitable trading and firm wide decision making. Pre-trade analytics is needed to ensure that collateral is allocated optimally across portfolios and collateral agreements. Optimization is also needed at the trade level to ensure the most suitable collateral is applied to each trade or structure. Finally, analysis needs to be carried out across the whole inventory of securities and cash positions to ensure collateral is used by the right businesses. After all, correct pricing of collateral across business lines is not only essential for firm level profitability but also incentivizing desirable behavior throughout the organization.

We strongly believe that firms that are successful in achieving a holistic collateral architecture will have a significant competitive advantage in the industry. They will be able to achieve optimization of collateral and liquidity across business silos while meeting most global regulatory requirements, and all that with a much more efficient IT spend.

This article was published on Securities Finance Monitor.

Collateral and Liquidity Data Management: the next big challenge for financial institutions

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The problem is well known: financial institutions have data all over the place. Small institutions tend to face straight-forward challenges, while large ones must identify not only where data are hidden but how can it be aggregated without disrupting other processes. Thankfully, new advances in collateral and liquidity technology are ready to make solutions cost-effective and relatively painless to implement.

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