The TRADE 59 - Q1 2019 | Page 62

[ I N T E R V I E W | C H R I S We know that the CFTC is in the process of incorporating guidance from CPMI-IOSCO in its rewrite of the rules, and we are hopeful that other jurisdictions will align with evolving global consensus. This increase in standardisation, in turn, will open new possibilities for users of trade repository data to extract increasingly greater value from this information. HM: Tell me about the role DTCC’s Trade Information Warehouse (TIW) played at the time of the financial crisis in 2008. CC: At the height of the Lehman crisis there was a lot of uncertain- ty in the industry around market participants’ exposures in the credit defaults swaps (CDS) market. It was the transparency demonstrated by the credit derivatives TIW, operated by DTCC, which played a key role in alleviating market concerns at the time of the Lehman bankruptcy and provided the impetus to the G20’s introduction of trade reporting requirements. The G20, however, recognised that replicating that same transparency across the vast OTC derivatives market would not be achieved on a voluntary basis, as was the case in the credit deriva- tives market, where reporting was a by-product of credit event and settlement automated processing delivered by the TIW. At the time of the crisis, there was "The industry could leverage the data collected to deliver new value-added services, further reduce costs and mitigate both operational and systemic risks." 62 // TheTrade // Spring 2019 C H I L D S ] speculation that CDS exposures could have been as high as $400 billion, but the TIW was able to demonstrate that net exposure was significantly lower than that, at $6 billion, producing a calming impact on the market and allowing regu- lators to understand what the total exposure in fact was. This type of standardised information across the credit derivatives market is what the industry is trying to replicate through mandatory trade reporting to registered trade repositories. HM: What’s the latest on the re-platforming of TIW to a DLT system? CC: In just over two years since the inception of this project, we’ve suc- cessfully completed development of the platform and are now in the process of conducting user accep- tance testing with the market, with plans to go live later this year. Until now, a large number of distributed ledger projects have only been proof of concepts, but this is one of the first projects to enter into produc- tion and is truly a ground-breaking effort pushing the boundaries of technology use in the industry. Where this goes in the future, and the role it could have in process- ing and trade reporting, is largely dependent on a number of factors. Firstly, there needs to be appetite and interest from the industry to invest and change to put more asset classes and functions onto distrib- uted ledgers. Secondly, regulators need to have the ability to access the data and gain full transparency into the market. However, data stan- dards must be in place for reporting requirements, data quality, formats, codes and fields. Concerns have already been raised across the in- dustry that the proliferation of DLT- based initiatives utilising multiple protocols, programming languages, data fields and dictionaries could result in fragmentation, inefficiency and cost. One of the reasons why we were able to start this project is that the TIW had already defined standardised process flows and data models. This helped to make credit derivatives an ideal test case and provide an opportunity to test the technology with appropriate and meaningful scale. Bolstered by common data standards and governance, a DLT-based TIW can enable the industry to process and report to regulators from the same data record. From there, the industry could leverage the data collected to deliv- er new value-added services, fur- ther reduce costs and mitigate both operational and systemic risks. HM: What are your predictions in terms of regulatory change as it relates to derivatives reporting? CC: I am hopeful that regulators across the world will continue to work with the industry and look at ways to harmonise their data re- porting regulations. If you look five years out, I hope that regulatory change will have been transforma- tional and that regulators will have been able to agree on standards and subsequently the broad adoption of a common global framework for derivatives trade reporting. We must ensure we are able to move forward from where we are at the moment, so that greater val- ue can be gained from the data and the infrastructure that has been built to support derivatives trade reporting. This is what regulators and industry participants need to focus on in the years ahead. If jurisdictions choose to mandate reporting according to different standards compliance costs will simply increase and the ability to aggregate data, and hence monitor and mitigate systemic risk will be severely hampered.