MAS publishes Guidelines on Margin Requirements...

MAS Guidelines on Margin Requirements for Non-Centrally Cleared OTC Derivatives Contracts 1

December 2016

MAS publishes Guidelines on Margin Requirements for Non-Centrally Cleared OTC Derivatives Contracts.

Introduction

On 6 December 2016, the Monetary Authority of Singapore (“MAS”)

published its “Guidelines on Margin Requirements for Non-Centrally Cleared

OTC Derivatives Contracts” (the “Margin Guidelines”), which sets out the

margin requirements for non-centrally cleared OTC derivatives (“uncleared

derivatives”). This follows the consultation paper (the “Consultation Paper”)

issued by MAS on 1 October 2015 entitled “Policy Consultation on Margin

Requirements for Non-Centrally Cleared OTC Derivatives” on which see our

client bulletin of October 2015 for more information. MAS also published its

response to the feedback received on the Consultation Paper on the same

day.

This bulletin summarises the key aspects of the Margin Guidelines.

What are the other jurisdictions doing?

Many jurisdictions have implemented or are in the process of implementing

margin rules for uncleared derivatives. For example, the United States (the

“US”), Canada and Japan have finalised their margin rules since 1 September

2016. On 15 December 2016, the European Union (the “EU”) published the

final Regulatory Technical Standards on risk-mitigation techniques for OTC-

derivative contracts not cleared by a CCP under Article 11(5) of Regulation

(EU) No 648/2012 (the “EU RTS”) in the Official Journal on which see our

client bulletin of December 2016 for more information. The EU RTS will come

into force on 4 January 2017 and phase-in of the provisions will commence

from 4 February 2017. The Swiss margin rules are likely to follow in due

course.

In Asia ex-Japan, the Australia, Hong Kong and Singapore margin rules will

go live on 1 March 2017, with a 6-month transition period for compliance.

Australia finalised its margin rules back in October 2016 and Hong Kong has

published a near final version of its margin rules on 6 December 2016 on

which see our client bulletin of December 2016 for more information. It was

therefore no coincidence that MAS also published final Singapore margin

rules in the form of the Margin Guidelines on 6 December 2016.

Contents Introduction ......................... 1

What are the other jurisdictions doing? ................................. 1

Are the Singapore margin rules relevant to you? ................... 2

Margin Guidelines ............... 2

Further information ............ 16

Key Questions

1) Are you an in-scope entity for the purposes of Singapore margin rules? 2) If yes, you should commence your counterparty outreach as soon as possible to assess whether your trading relationships are subject to Singapore margin rules and consider how to repaper all your affected relationships. 3) If no, you should still consider whether you are a covered counterparty for the purposes of Singapore margin rules such that if you are trading with an in-scope entity, your trading relationship will be subject to Singapore margin rules. 4) If Singapore margin rules are either directly or indirectly applicable to you, then it is important to understand what those rules require because your collateral documentation will, subject to substituted compliance, have to comply with those rules.

http://www.linklaters.com/pdfs/mkt/singapore/1.Newsletter_MAS%20CP%20on%20Margining%20Bulletin.pdf

http://linklaters.com/pdfs/mkt/singapore/2.Client%20Briefing_adopted%20Margin%20RTS_Oct%2016.pdf

http://linklaters.com/pdfs/mkt/singapore/3.Near%20Final%20HK%20margin%20rules.pdf


Are the Singapore margin rules relevant to you?

Before considering any jurisdiction’s margin rules, there are certain threshold

questions which you need to keep in mind (see right panel) as they will

determine how that jurisdiction’s margin rules might be relevant to you and/or

impact your trading relationship with certain of your counterparties.

Margin Guidelines

Item Singapore margin rules

1. What products are in scope?

Product Scope All derivatives contracts that are not

centrally cleared.

Exempt Products Physically-settled FX forwards and swaps.

Fixed physically settled FX transactions

associated with the exchange of principal

of cross-currency swaps.

Commodity derivatives contracts entered

into for commercial purposes.

Repurchase agreements.

Securities lending transactions.

Timing of Entry into of

Transaction

The obligation to exchange IM / VM

applies to new transactions entered into

after 1 March 2017 (or the relevant phase-

in date).

There is a 6-month transition period from

1 March 2017 to 1 September 2017.

During the 6-month transition period, MAS

expects MAS Covered Entities (see

below) to make progress to meet

Singapore margin rules as soon as

practicable. As and when the necessary

documentation and arrangements are in

place during the transition period, MAS

Covered Entities should start exchanging

margins for contracts entered into from

that point on.

2. Which entities are in scope?

Entity Scope;

Threshold Requirement

Entities which are:

banks licensed under the Banking Act; or

“derivatives contract”

This term has the meaning given

to it in the Securities and Futures

Act (the “SFA”). It includes

forwards, options and swaps but

excludes securities and futures

contracts (each as defined in the

SFA).

Equity and bond derivatives

The current definition of

“derivatives contract” in the SFA

excludes equity and bond

derivatives because they fall

within the definition of “securities”.

However, the proposed

amendments to the SFA (which

will likely come into force some

time in 2017) will streamline the

various definitions such that

equity and bond derivatives will

be captured by the definition of

“derivatives contract” and will

thereby be in-scope.


merchant banks approved as financial

institutions under section 28 of the

Monetary Authority of Singapore Act

(together, the “MAS Covered Entities”) and

which meet the S$5 billion threshold.

The S$5 billion threshold looks at the MAS

Covered Entity’s aggregate month-end

average outstanding gross notional

amount of all outstanding uncleared

derivatives booked in Singapore (including

all out-of-scope/exempt products and

intragroup transactions) for March, April

and May of the relevant year.

Exempt Entities The following are exempted from the margin

requirements:

Singapore Government.

Statutory board established under any

written law.

Central bank in a jurisdiction other than

Singapore.

Central government in a jurisdiction other

than Singapore.

An agency (of a central government in a

jurisdiction other than Singapore) that is

incorporated or established, in a

jurisdiction other than Singapore, for non-

commercial purposes.

Certain multilateral agencies,

organisations and entities, including the

Asian Development Bank, the Bank for

International Settlements and the

International Bank for Reconstruction and

Development (World Bank).

3. Nexus requirements

Nexus Requirements Broadly speaking, an MAS Covered Entity that

meets the S$5 billion threshold will be subject

to both IM and VM requirements if all of the

following conditions are met:

the transaction is booked in Singapore;

the transaction is entered into with either:

o another MAS Covered Entity that

meets the S$5 billion threshold; or

How to calculate the S$5 billion

threshold?

You will need to consider a

number of questions, including the

following:

(i) is “month-end” the last calendar

day or the last business day of the

month (and does it matter?)?

(ii) for notional amounts not

denominated in Singapore dollars

(“SGD”), what is the FX rate you

will use to convert them into SGD?

Consistency with reporting?

The list of exempt entities for the

purposes of Singapore margin rules

is almost identical to that for the

purposes of the mandatory

reporting rules with the exception of

the Asian Infrastructure Investment

Bank which was included in the

Margin Guidelines but not in the

relevant reporting regulations. MAS

should therefore consider including

this as part of its next round of

amendments to the reporting rules.


o a Foreign Covered Entity; and

the transaction is not an intragroup

transaction (see section 10 below).

Booked in Singapore This means that the uncleared derivative is

entered into on the balance sheet of a person:

who is a party to the uncleared derivative;

and

whose place of business for which the

balance sheet relates to is in Singapore.

Foreign Covered

Entities

A Foreign Covered Entity is a person

operating outside Singapore which, if

operating in Singapore, would have been a

person within the meaning of an “MAS

Covered Entity”.

4. Phase-in schedule

Phase-in

Implementation

Schedule

Obligation to exchange IM / VM will be

phased in by entity type.

At this stage, only banks and merchant

banks (see table below) are phased in.

The phase-in thresholds apply only to IM

while the obligation to exchange VM will

go live on 1 March 2017, subject to the 6-

month transition period.

The phase-in thresholds apply at the

group level in relation to the aggregate

month-end average notional amount of

uncleared derivatives for March, April and

May of the relevant year.1

The other party’s aggregate month-end

average notional amount at the group

level must also exceed the relevant

phase-in threshold which applies.

For the purposes of calculating the phase-

in thresholds, all uncleared derivatives are

included, including exempt products and

uncleared derivatives with exempt entities.

However, intragroup transactions are

excluded.

1 Either in the same year as the relevant commencement date or the previous year if the

relevant commencement date falls on 1 March.

Consistency with reporting?

The nexus required is “booked in

Singapore” and the concept should

be consistent with that used for the

purposes of the mandatory

reporting rules. The current

definition of “booked in Singapore”

in the reporting rules is different

and MAS should therefore consider

aligning it with the new definition in

the Margin Guidelines in the next

round of amendments to the

reporting rules.


Obligation

Belonging to Group

Exceeding Phase-in

Threshold

Commencement Date

Initial

Margin (IM)

S$4.8 trillion 1 March 2017

S$3.6 trillion 1 September 2017



S$13 billion From 1 September 2020

and each subsequent 12-

month period

5. IM and VM requirements

Initial Margin (“IM”) Gross margining (i.e. no netting of IM

payments between two counterparties).

IM Threshold of S$80 million applies,

calculated at the group-consolidated level

based on all uncleared derivatives

between the two consolidated groups.

Call within one local business day after

the transaction date (“T”) or margin

recalculation date (“R”).

Exchange margin within three local

business days (i.e. T+3/R+3).

Minimum transfer amount of not more

than S$800,000 (applied cumulatively with

VM).

Phase-in thresholds apply (see above).

Variation Margin (“VM”) Daily margining.

Zero threshold.

Call within one local business day after

T/R.

Exchange margin within three local

business days (i.e. T+3/R+3).

Minimum transfer amount of not more

than S$800,000 (applied cumulatively with

IM).

Timing of exchange

Singapore margin rules adopt a

more pragmatic approach than

the US and EU which require an

exchange of margin within

effectively T+1. Although there is

an ongoing debate in the EU as

regards the timing requirement,

the reality is that T+1 is an

operational challenge (if not an

impossibility) for many market

participants.

The issues which the market

could face include:

(i) same day transfer for cash is

likely to be challenging for the

vast majority of market

participants;

(ii) it will not be possible to post

securities which have a longer

settlement cycle than the

transfer timing; and

(iii) how to ensure the cut-off for

a margin call is early enough to

comply with the strictest

applicable transfer timing, taking

into account timezone

differences especially between a

US bank and an Asian bank.


6. IM and VM Calculations

IM Calculations

Timing of Exchange IM to be exchanged on a routine and

consistent basis upon changes in the

measured potential future exposures.

Recalculation of IM At a minimum, IM shall be calculated and

exchanged when:

o a new contract is executed with a

counterparty;

o an existing contract with a

counterparty terminates or

expires;

o a significant market disruption

occurs;

o the IM model is recalibrated (if

using the Model);

o changes to the asset classification

of existing trades (if using the

Standardised Schedule); or

o no IM recalculation has been

performed in the last 10 local

business days.

Methodology MAS proposes to allow the required

amount of IM to be calculated by

reference to either:

o a quantitative portfolio margin

model (the “Model”); or

o a standardised margin schedule

(the “Standardised Schedule”).

MAS Covered Entities may opt for either

approach and need not restrict itself to

one approach for all its uncleared

derivatives.

However, the choice should be made

consistently for all transactions within the

same well-defined asset class.

Dispute Resolution MAS Covered Entities must have agreed

with their counterparties rigorous and

robust dispute resolution procedures.

If there is a dispute, any undisputed


amount should first be exchanged and all

necessary and appropriate efforts,

including timely initiation of dispute

resolution protocols should be taken to

resolve the dispute, and to exchange the

disputed margin in a timely fashion.

Documentation

Requirement

Prior to execution of the transaction,

parties must agree in writing or other

equivalent permanent electronic means

on the specific margin calculation method

and the Model to be used.

Model A Model may be internally developed or

provided by a third party.

MAS has imposed certain qualitative

requirements on the Model and, in

particular, the use of any Model is subject

to, among others, the following conditions:

o before using a Model, an MAS

Covered Entity should provide to

MAS the relevant documentation,

which includes the model

methodology, model specifications

and validation reports, to

demonstrate that the Model

satisfies all model standards in

the Margin Guidelines (i.e.

notification rather than approval);

and

o before making any material

changes to a Model, an MAS

Covered Entity should provide to

MAS relevant documentation to

show that the revised Model

would continue to comply with the

Margin Guidelines.

The Model should also be:

o subject to the MAS Covered

Entity’s internal governance

process;

o independently validated before

being used and annually

thereafter; and

o recalibrated at least annually and


subject to a regular back-testing

programme.

There are also various other requirements

which apply to the Model. A couple are

highlighted below:

o the Model may consider all

uncleared derivatives which are

subject to the same “legally

enforceable netting agreement”;

and

o the Model may account for

diversification, hedging and risk

offsets within well-defined asset

classes, but not across asset

classes, provided that they are

covered by the same “legally

enforceable netting agreement”.

Uncleared derivatives for which a firm

faces zero counterparty risk require no IM

to be collected and may be excluded from

the IM calculation.

Standardised

Schedule

MAS Covered Entities which use the

Standardised Schedule will have to

calculate the required IM amounts for

each uncleared derivative based on the

notional amount of the transaction and

certain prescribed net-to-gross ratios

which differ depending on the asset class

and residual duration of the transaction.2

VM Calculations

Purpose MAS Covered Entities must exchange the

full amount of VM necessary to fully

collateralise the mark-to-market exposure

of the uncleared derivative.

Net Basis MAS Covered Entities must calculate and

exchange VM on an aggregate net basis

across all uncleared derivatives that are

executed under a “single, legally

enforceable netting agreement”.

2 See Annex 2 of the Margin Guidelines for further details.


Dispute Resolution MAS Covered Entities must have agreed

with their counterparties rigorous and

robust dispute resolution procedures.

If there is a dispute, any undisputed

amount should first be exchanged and all

necessary and appropriate efforts,

including timely initiation of dispute

resolution protocols should be taken to

resolve the dispute, and to exchange the

disputed margin in a timely fashion.

7. Eligible Collateral and Haircuts

General The eligible collateral for IM and VM are

the same under Singapore margin rules.

Eligible Collateral Cash.

Gold.

Debt securities (AAA to BB- for central

government and central bank issuers;

AAA to BBB- for other issuers) but

excluding securitisations.

Equity securities (including convertible

bonds) in a main stock index of a

regulated exchange.

Units in collective investment schemes

(“CIS”), provided that the CIS meets

certain requirements.

Haircuts MAS Covered Entities should apply the

Standardised Schedule haircuts to the

eligible collateral they include in their

collateral documentation.

Internal or third party quantitiative model-

based haircuts should not be used.

Concentration Risk MAS Covered Entities are expected to

establish policies, procedures and

controls to ensure that the collateral

collected is reasonably diversified and not

overly concentrated in an individual issuer,

issuer type or asset type.

Eligible collateral

The list of eligible collateral is

fairly extensive under Singapore

margin rules.

In particular, there is no

restriction on:

(i) the type of currency which is

eligible for the purposes of cash;

(ii) the governments which may

be the issuer of the government

debt securities which may be

used as eligible collateral,

subject to credit ratings; and

(iii) the stock index on which the

equity securities are listed,

subject to the equities included

in such index being highly liquid

and being able to hold their

value in a time of financial

stress, after accounting for

haircuts.


Wrong-way Risk MAS Covered Entities should ensure that

the value of the collateral does not exhibit

a significant correlation with:

o the creditworthiness of the

counterparty; or

o the value of the underlying

uncleared derivative portfolio.

Securities issued by the either party or its

related entities should not be accepted as

collateral.

FX Risk VM

Applies only to non-cash VM.

Where the collateral is denominated in a

currency other than the ones agreed in

the applicable individual derivatives

contract, a legally enforceable master

netting agreement or a credit support

agreement, an additive FX mismatch

haircut of 8% will be applied.

IM

Applies to both cash and non-cash IM.

Where the collateral is denominated in a

currency other than the termination

currency that the posting counterparty has

designated in the applicable individual

derivatives contract, a legally enforceable

master netting agreement or a credit

support agreement.

Each party may specify one (and only

one) termination currency so there may be

a maximum of two termination currencies

between the parties.

Which currency do you compare

against for the purposes of non-

cash VM?

Singapore margin rules have

adopted a fairly liberal approach in

this regard, similar to the

formulation under the EU rules.

Whilst the reference to the various

agreements in theory gives parties

wide latitude in deciding which

currency to compare against, for

practical purposes, the market is

taking the view that it would be any

Eligible Currency for the purposes

of most jurisdictions (including the

EU).

In other words, it is theoretically

possible to list all the currencies in

which any non-cash VM is

denominated as Eligible

Currencies to avoid any FX haircut,

even though you do not intend to

exchange the full range of those

currencies as cash VM.

What is the “termination

currency” for the purposes of

IM?

Although the term “termination

currency” is not defined in the

Margin Guidelines, the EU rules

have a similar concept and it is

widely understood that this is

referring to the “Termination

Currency” as defined in the ISDA

Master Agreement.


8. Holding of Collateral

Requirements for

Safekeeping of IM

MAS Covered Entities must safekeep the

IM collected in a manner to ensure that

the IM collected:

o is available to the collecting party

on a timely basis, where legally

possible, following a default or

early termination by the posting

party;

o is segregated from the proprietary

moneys and assets of the

collecting party (or held with a

third party custodian) under trust

or custody account arrangements3

to address the insolvency risk of

the collecting party; and

o must be subject to legally

enforceable arrangements that

protect the posting party to the

extent possible under applicable

law in the event that the collecting

party enters insolvency.

MAS Covered Entities may not use the IM

as margin or guarantee for, or to secure

any transaction of, or to extend the credit

of, any person other than the posting

counterparty.

MAS Covered Entities should also give a

counterparty the option to segregate their

IM from the assets of all other

counterparties.

MAS Covered Entities should also

conduct due diligence on the financial

institution with which it opens the trust or

custody account and should maintain

records and documentation of the due

diligence.

o Assessment of suitability to

safekeep IM collected.

o Financial institution cannot

exercise any right of set-off

against the IM for any debt owed

3 The trust or custody account must be held with certain prescribed categories of financial

institutions, including (i) MAS Covered Entities, (ii) finance companies licensed under the Finance Companies Act, (iii) any person licensed under the SFA to provide custodial services for securities and (iv) any person licensed, registered or authorised to conduct banking or custodian business in the country (other than Singapore) where the account is maintained.

“timely basis”; “where legally

possible”

The reference to “timely basis” (as

opposed to “immediately

available”) is a more realistic

requirement because enforcement

of security is rarely ever

immediate.

The reference to “where legally

possible” is also useful in that it

expressly takes into account the

possibility of stays on termination

rights and enforcement of security

under the laws of certain

jurisdictions.

Third party custodian / trust

The reference to a “trust” is apt to

confuse because it does not

reflect how market participants

typically take security in practice.

Market participants will typically

hold IM with a third party

custodian, and it should be

sufficient if it is held in an account

in the name of the posting party,

secured in favour of the collecting

party.

Due diligence

Banks and merchant banks

should take note of this due

diligence requirement which may

impose additional operational

burdens.

The explicit prohibition of set-off

may also raise practical issues

because custodians typically

include a right of set-off in their

custody agreements in respect

of fees payable to them.


by the MAS Covered Entity to the

financial institution.

Withdrawal of IM The MAS Covered Entity may only

withdraw the IM under limited

circumstances.

These are:

o making a payment or delivery to

any person entitled thereto;

o making a payment to meet an

obligation of the posting

counterparty arising from any

uncleared derivative trading by

the MAS Covered Entity for the

posting counterparty;

o making a payment or delivery to

any person or account in

accordance with the written

direction of the posting

counterparty; and

o making a payment or withdrawal

to any other person that is

authorised by law.

Interest on Trust or

Custody Account

Subject to any agreement between the

MAS Covered Entity and the posting

counterparty, all interest and distributions

on the IM collected should accrue to the

posting counterparty.

The MAS Covered Entity should take all

reasonable steps to ensure that the

interest and distributions are paid to or

held for the benefit of the posting

counterparty.

9. Rehypothecation and reinvestment

Non-cash IM Non-cash IM may only be rehypothecated

to a third party in accordance with certain

conditions which are very restrictive.4

The one-time right to rehypothecate only

applies to non-cash IM collected from a

“buy-side financial firm” or “non-financial

entity” which does not regularly hold itself

4 See paragraph 5 of Annex 5 of the Margin Guidelines for further details.

Rehypothecation of IM

Although the rehypothecation of

non-cash IM is not permitted

under the margin rules of

certain jurisdictions (e.g. the

EU), Singapore margin rules

have retained a limited right to

rehypothecate non-cash IM in

light of the mixed feedback

which MAS received during the

public consultation.


out as making a market in derivatives,

routinely quote bid and offer prices on

derivative contracts and routinely respond

to requests for bid or offer prices on

derivative contracts.

Cash IM The MAS Covered Entity may re-invest

cash IM in eligible collateral provided that:

o the counterparty has provided its

prior written consent; and

o the re-invested cash IM (after

application of the relevant

haircuts) meets the Margin

Guidelines.

10. Intra group Transactions

Exemption Intragroup transactions between an MAS

Covered Entity and another entity

belonging to the same consolidation group

as that MAS Covered Entity are exempt

from the margin requirements.

A “consolidation group” means all entities

within the the meaning of a consolidation

group of the Singapore Financial

Reporting Standards FRS 110:

Consolidated Financial Statements or its

equivalent accounting standards.

11. Non-netting jurisdictions

Exemption If an uncleared derivative is governed by a

netting agreement or collateral

arrangement that is not legally

enforceable, then there is no requirement

to exchange VM/IM.

What is a Non-

netting Jurisdiction?

Singapore margin rules do not define a

non-netting jurisdiction by reference to the

location or jurisdiction of incorporation of

the counterparty. Instead, it refers to the

legal enforceability of the relevant netting

agreement or collateral arrangement.

MAS Covered Entities should undertake a

legal review and document the basis of

determining a netting agreement or


collateral arrangement as non-legally

enforceable. Before determining that a

collateral arrangement is not legally

enforceable, the MAS Covered Entity

should explore alternative arrangements

to safeguard IM collateral, taking into

account the legal constraints and the

market practices of the relevant

jurisdiction.

The outcome and basis used by the MAS

Covered Entities for the purpose of

Singapore margin rules should be

consistent with the assessment made by

them with respect to non-netting

jurisdictions for regulatory capital

purposes.

12. Substituted Compliance

Deemed compliance An MAS Covered Entity or its cross border

transactions may be subject to the margin

requirements of a foreign jurisdiction.

In such cases, MAS may deem an MAS

Covered Entitiy to be in compliance with

Singapore margin rules if:

o the margin requirements in the

foreign jurisdiction are assessed

to be comparable to the

Singapore margin rules; and

o the MAS Covered Entity can

demonstrate that it has complied

with the margin requirements of

that foreign jurisdiction.

MAS may impose additional conditions to

be met by an MAS Covered Entity

intending to rely on substituted

compliance.

MAS is currently of the view that the

margin requirements implemented by the

member jurisdictions of the BCBS-IOSCO

Working Group on Margin Requirements

are comparable and compliance with

those margin requirements will be

deemed to be in compliance with the

Singapore margin rules. These

jurisdictions are: Australia, Canada, the

EU, Hong Kong, India, Japan, Korea,


Mexico, Russia, Switzerland and the US.

MAS intends to enter into comparability

assessment discussions with other

regulators in due course.


Author: Kai Loon Loh

This publication is intended merely to highlight issues and not to be comprehensive, nor to provide legal advice. Should you have any questions on issues reported here or on other areas of law, please contact one of your regular contacts, or contact the editors.

© Linklaters Singapore Pte. Ltd. All Rights reserved 2016

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A33065384

Contacts

For further information

please contact:

Singapore

Jacqueline Low

Consultant

(+65) 6692 5761

[email protected]

Kai Loon Loh

Managing Associate

(+65) 6692 5779

[email protected]

Li Ling Tan

Associate

(+65) 6692 5839

[email protected]

Hong Kong

Chin Chong Liew

Partner

(+852) 2842 4857

[email protected]

Victor Wan

Partner

(+852) 2901 5338

[email protected]

Further information

If you would like to discuss the Margin Guidelines or provide feedback, feel free

to contact Jacqueline Low, Kai Loon Loh or any of your other Linklaters

contacts.

MAS publishes Guidelines on Margin Requirements...

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