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Private & Confidential European Market Infrastructure Regulations (EMIR) 11 December 2012
EMIR
European Market Infrastructure Regulations – An Introduction
11 December 2012
1
Private & Confidential European Market Infrastructure Regulations (EMIR) 11 December 2012 2
All standardised OTC
derivatives will be cleared
through central
counterparties (CCPs)
Harmonised framework
for the provision of
clearing services within
Europe
Non-cleared derivatives
will be subject to
strengthened management
requirements, including the
need to collateralise
positions
All OTC and exchange
traded derivatives will be
reported to trade
repositories (TRs)
EMIR: Central Points
EMIR: Preparing for A Changing Market Environment
• In order to enhance the resilience of the financial system
to any future financial crisis and to increase
transparency, European policymakers are introducing
regulation (termed “EMIR”) to reform the swaps market.
The incoming changes will make the swap market more
similar to the futures market, with trades cleared through
a central counterparty (CCP).
• This introduces additional rules and constraints that
pension funds should be aware of and prepare for.
Private & Confidential European Market Infrastructure Regulations (EMIR) 11 December 2012 3
Important information for pensions funds:
• Pension Funds enjoy a limited exemption from EMIR’s headline
measure – the requirement to clear OTC derivative contracts – until at
least August 2015. However, for new trades there is no exemption
from Initial Margin, providing more incentive for these trades to be
cleared early rather than make use of the pension fund exemption.
• The other key provision – reporting obligations – will apply to
pension funds. The EMIR obligations will take effect on a phased
basis from the beginning of 2013.
• Initial Margin calculations are likely to be 5-10 day VaR to a high
confidence level of 99.5/99.7.
Key questions for pension funds to consider:
• Are you going to use your exemption from EMIR?
• Are your CSAs dirty or clean?
• Have you considered your collateral adequacy under EMIR?
• Have you evaluated novation, rehypothecation and
recouponing as potential options to manage collateral
adequacy?
• What are you going to do with your legacy book of
derivative trades?
* Timeline based on ESMA estimates
Q3 2012 Q4 2012 Q1 2013 Q2 2013 Q3 2013 Q4 2013 Q1 2014 Q2 2014
ESMA publication of
draft technical standards
EMIR: Preparing for A Changing Market Environment
Technical standards
come into force
CCP Application
Deadline
NCA Authorisation of
CCPs
ESMA to submit draft
RTS on the clearing
obligation
Notification for the
clearing obligation
Reporting start date
(IRS, CDS)
Reporting start date (all
other asset classes)
Key:
Technical standards – overall set of rules and regulation
Over-the-Counter (OTC) derivatives clearing
Central Counterparty Clearing (CCP) entities
Trade Repositories (TR) – maintains trade records
Private & Confidential European Market Infrastructure Regulations (EMIR) 11 December 2012 4
We will guide your pension scheme into this new regulatory environment. Providing:
- An analysis of your legacy derivative portfolio.
- An analysis of your collateral requirements and adequacy under a variety of EMIR transition strategies.
- An analysis of your PV01 exposures under a variety of EMIR transition strategies.
- An analysis of your CSA positioning, where necessary managing the transition from dirty to clean.
- Regular scheme updates that inform you of how the regulations are going to affect your scheme.
EMIR: Redington Offering
- Following this analysis we will create and implement a bespoke strategy for your scheme in partnership with your LDI manager.
Private & Confidential European Market Infrastructure Regulations (EMIR) 11 December 2012
13-15 Mallow Street London EC1Y 8RD Telephone : +44 (0) 20 7250 3331 www.redington.co.uk
Contacts
Tom McCartan
Associate
Manager Research
Direct Line: 020 3267 7139
mark.herne@redington.co.uk
5
Disclaimer
For professional investors only. Not suitable for private
customers.
The information herein was obtained from various
sources. We do not guarantee every aspect of its
accuracy. The information is for your private information
and is for discussion purposes only. A variety of market
factors and assumptions may affect this analysis, and
this analysis does not reflect all possible loss scenarios.
There is no certainty that the parameters and
assumptions used in this analysis can be duplicated with
actual trades. Any historical exchange rates, interest
rates or other reference rates or prices which appear
above are not necessarily indicative of future exchange
rates, interest rates, or other reference rates or prices.
Neither the information, recommendations or opinions
expressed herein constitutes an offer to buy or sell any
securities, futures, options, or investment products on
your behalf. Unless otherwise stated, any pricing
information in this message is indicative only, is subject
to change and is not an offer to transact. Where
relevant, the price quoted is exclusive of tax and
delivery costs. Any reference to the terms of executed
transactions should be treated as preliminary and
subject to further due diligence .
Please note, the accurate calculation of the liability
profile used as the basis for implementing any capital
markets transactions is the sole responsibility of the
Trustees' actuarial advisors. Redington Ltd will estimate
the liabilities if required but will not be held responsible
for any loss or damage howsoever sustained as a result
of inaccuracies in that estimation. Additionally, the client
recognizes that Redington Ltd does not owe any party a
duty of care in this respect.
Redington Ltd are investment consultants regulated by
the Financial Services Authority. We do not advise on
all implications of the transactions described herein.
This information is for discussion purposes and prior to
undertaking any trade, you should also discuss with
your professional tax, accounting and / or other relevant
advisers how such particular trade(s) affect you. All
analysis (whether in respect of tax, accounting, law or of
any other nature), should be treated as illustrative only
and not relied upon as accurate.
©Redington Limited 2011. All rights reserved. No
reproduction, copy, transmission or translation in whole
or in part of this presentation may be made without
permission. Application for permission should be made
to Redington Limited at the address below.
Redington Limited (6660006) is registered in England
and Wales. Registered office: 13-15 Mallow Street
London EC1Y 8RD
Kenny Nicoll
Director
Manager Research
Direct Line: 020 3267 7111
patrick.osullivan@redington.co.uk
Freddie Ewer
Analyst
Investment Consulting
Direct Line: 020 3326 7133
dan.mikulskis@redington.co.uk

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European Market Infrastructure Regulations (EMIR) – An Introduction

  • 1. Private & Confidential European Market Infrastructure Regulations (EMIR) 11 December 2012 EMIR European Market Infrastructure Regulations – An Introduction 11 December 2012 1
  • 2. Private & Confidential European Market Infrastructure Regulations (EMIR) 11 December 2012 2 All standardised OTC derivatives will be cleared through central counterparties (CCPs) Harmonised framework for the provision of clearing services within Europe Non-cleared derivatives will be subject to strengthened management requirements, including the need to collateralise positions All OTC and exchange traded derivatives will be reported to trade repositories (TRs) EMIR: Central Points EMIR: Preparing for A Changing Market Environment • In order to enhance the resilience of the financial system to any future financial crisis and to increase transparency, European policymakers are introducing regulation (termed “EMIR”) to reform the swaps market. The incoming changes will make the swap market more similar to the futures market, with trades cleared through a central counterparty (CCP). • This introduces additional rules and constraints that pension funds should be aware of and prepare for.
  • 3. Private & Confidential European Market Infrastructure Regulations (EMIR) 11 December 2012 3 Important information for pensions funds: • Pension Funds enjoy a limited exemption from EMIR’s headline measure – the requirement to clear OTC derivative contracts – until at least August 2015. However, for new trades there is no exemption from Initial Margin, providing more incentive for these trades to be cleared early rather than make use of the pension fund exemption. • The other key provision – reporting obligations – will apply to pension funds. The EMIR obligations will take effect on a phased basis from the beginning of 2013. • Initial Margin calculations are likely to be 5-10 day VaR to a high confidence level of 99.5/99.7. Key questions for pension funds to consider: • Are you going to use your exemption from EMIR? • Are your CSAs dirty or clean? • Have you considered your collateral adequacy under EMIR? • Have you evaluated novation, rehypothecation and recouponing as potential options to manage collateral adequacy? • What are you going to do with your legacy book of derivative trades? * Timeline based on ESMA estimates Q3 2012 Q4 2012 Q1 2013 Q2 2013 Q3 2013 Q4 2013 Q1 2014 Q2 2014 ESMA publication of draft technical standards EMIR: Preparing for A Changing Market Environment Technical standards come into force CCP Application Deadline NCA Authorisation of CCPs ESMA to submit draft RTS on the clearing obligation Notification for the clearing obligation Reporting start date (IRS, CDS) Reporting start date (all other asset classes) Key: Technical standards – overall set of rules and regulation Over-the-Counter (OTC) derivatives clearing Central Counterparty Clearing (CCP) entities Trade Repositories (TR) – maintains trade records
  • 4. Private & Confidential European Market Infrastructure Regulations (EMIR) 11 December 2012 4 We will guide your pension scheme into this new regulatory environment. Providing: - An analysis of your legacy derivative portfolio. - An analysis of your collateral requirements and adequacy under a variety of EMIR transition strategies. - An analysis of your PV01 exposures under a variety of EMIR transition strategies. - An analysis of your CSA positioning, where necessary managing the transition from dirty to clean. - Regular scheme updates that inform you of how the regulations are going to affect your scheme. EMIR: Redington Offering - Following this analysis we will create and implement a bespoke strategy for your scheme in partnership with your LDI manager.
  • 5. Private & Confidential European Market Infrastructure Regulations (EMIR) 11 December 2012 13-15 Mallow Street London EC1Y 8RD Telephone : +44 (0) 20 7250 3331 www.redington.co.uk Contacts Tom McCartan Associate Manager Research Direct Line: 020 3267 7139 mark.herne@redington.co.uk 5 Disclaimer For professional investors only. Not suitable for private customers. The information herein was obtained from various sources. We do not guarantee every aspect of its accuracy. The information is for your private information and is for discussion purposes only. A variety of market factors and assumptions may affect this analysis, and this analysis does not reflect all possible loss scenarios. There is no certainty that the parameters and assumptions used in this analysis can be duplicated with actual trades. Any historical exchange rates, interest rates or other reference rates or prices which appear above are not necessarily indicative of future exchange rates, interest rates, or other reference rates or prices. Neither the information, recommendations or opinions expressed herein constitutes an offer to buy or sell any securities, futures, options, or investment products on your behalf. Unless otherwise stated, any pricing information in this message is indicative only, is subject to change and is not an offer to transact. Where relevant, the price quoted is exclusive of tax and delivery costs. Any reference to the terms of executed transactions should be treated as preliminary and subject to further due diligence . Please note, the accurate calculation of the liability profile used as the basis for implementing any capital markets transactions is the sole responsibility of the Trustees' actuarial advisors. Redington Ltd will estimate the liabilities if required but will not be held responsible for any loss or damage howsoever sustained as a result of inaccuracies in that estimation. Additionally, the client recognizes that Redington Ltd does not owe any party a duty of care in this respect. Redington Ltd are investment consultants regulated by the Financial Services Authority. We do not advise on all implications of the transactions described herein. This information is for discussion purposes and prior to undertaking any trade, you should also discuss with your professional tax, accounting and / or other relevant advisers how such particular trade(s) affect you. All analysis (whether in respect of tax, accounting, law or of any other nature), should be treated as illustrative only and not relied upon as accurate. ©Redington Limited 2011. All rights reserved. No reproduction, copy, transmission or translation in whole or in part of this presentation may be made without permission. Application for permission should be made to Redington Limited at the address below. Redington Limited (6660006) is registered in England and Wales. Registered office: 13-15 Mallow Street London EC1Y 8RD Kenny Nicoll Director Manager Research Direct Line: 020 3267 7111 patrick.osullivan@redington.co.uk Freddie Ewer Analyst Investment Consulting Direct Line: 020 3326 7133 dan.mikulskis@redington.co.uk