The regulation for Uncleared Margin Rules (UMR) was set in motion at the 2009 G20 meeting following the global financial crisis.
A triumvirate of the Working Group on Risk-Free Reference Rates (RFRWG), the FCA and the Bank of England published joint statements in March and April (see my previous blog LIBOR Wars) reiterating that firms must move away from referencing LIBOR and reduce the stock of legacy LIBOR contracts.
The effect of the pandemic has been a mixed bag for many involved in our markets. The increase in volatility has seen a boost to trading activities and RegTech has been busy innovating to help overcome the compliance issues of remote working. With banks splitting personnel between the office, disaster recovery sites and working from home, issues have arisen that will spur technological development and system renewals.
Regulations are having a profound effect on the trading landscape alongside a proliferation of Codes of Conduct. In the UK, there are three codes replacing the former NIPS code covering FX, Money Markets and Precious Metals.
We have been seeing a lot of discussion and interest concerning a blog I penned in March last year under the title of “Beware the Ides of March - A Drama of FX Swaps Reporting”.
This March, we had a Consultation from ESMA, nattily entitled, “MiFID II/MiFIR review report on the transparency regime for non-equity instruments and the trading obligation for derivatives”, which may equally be causing this issue to be re-visited.
In my last blog, looking at the rise of the challengers to the traditional banking industry, I stated “these ‘lightweight’ contestants in the banking market have harnessed new technologies and processes to deliver a better customer experience.” The blog elicited a comment from Kevin Gillespie when posted on LinkedIn – “You missed the entrance of mobile phone companies in payments ... mPesa in Kenya is 45% owned by Vodafone and operates payments in Romania on the same platform ... the new competitors may not even bother to get in the ring and still win the fight as they invent new ways of exchanging value”.
Since the Global Financial Crisis (GFC) the banking industry, especially in the UK, has experienced significant growth with the advent of the “Digital Challenger”. These ‘lightweight’ contestants in the banking market have harnessed new technologies and processes to deliver a better customer experience.
We have seen many crises in the past, but this one is in many ways unique and I cannot recall a similar set of circumstances in my 43 years in markets. Financial crises have been global before but have originated within the financial system. Natural disasters have been localised as has dislocation due to terrorism and wars. This pandemic is unique as it is the first time we have seen such dislocation in so many countries at the same time. All financial centres are going through unprecedented emergency implementation of disaster planning activation.
It is unprecedented in Financial Markets (at least in my memory!) to have so many people working from home globally. We have previously seen localised examples such as on Wall Street after the tragic event of 9/11, but nothing on this global scale. As firms dust off the business continuity plans, some are hitting problems such as systems not allowing remote trading. This requires a tweaking of rule books and system settings. For those deploying a unified, modular platform, the task is somewhat easier when suddenly so many core staff are working from home as any system changes can be made once, and once only.
We are living in an unknown world at the moment.
Unknown for our day-to-day working life, unknown for our health, for our relatives , for our holidays and for our immediate future.
Buried in the depths of the Communiqué from the G20 Finance Ministers & Central Bank Governors Meeting on the 23rd of February was a stark call to arms regarding LIBOR transition. Building on the comments from National Competent Authorities (NCA) came a clear G20 statement:
Unsurprisingly, the Future at Lloyd’s took centre stage at this year’s TINtech London Market event. Many were struck by the scale of the proposed changes and what these meant for the market as a whole. From the talks and workshops that I attended, I have picked two key changes that will not only innovate but may redefine how insurance professionals access the market.