Response to consultation on RTS defining methodologies for the valuation of derivative liabilities
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Moreover, the period between the notification and the relevant close-out date needs to be pre- defined or at least subject to a pre-defined - and necessarily short - time limit. The resolution authority cannot have complete discretion in setting the close-out date because such complete discretion could effectively undermine the purpose of the strict limitation of the resolution stay and impair the rights of the counterparty.
Furthermore, to ensure that the close-out is accomplished as smoothly as possible and also to reduce the risk of legal challenges, i.e. based on breaches of the no creditor worse off-principle (NCWO-principle), it will be important that all necessary notifications are made in the contractually agreed form and addressed to contractually agreed addressees. This should be expressly clarified.
As to the general concerns regarding reliance on actual (commercially reasonable) replacement trades, see our response to Questions 3 and 4 below.
Article 49(3) BRRD states that, where bail-in applies to liabilities arising from derivatives contracts, the valuation of derivatives under a netting agreement must be carried out in accordance with the terms of that agreement. The approach proposed in the draft RTS contains a number of elements which are not consistent with the terms and concepts of standard netting agreements and thus deviates from market practice and the principle set out in Art. 49 (3) BRRD.
For one, as currently drafted, the RTS only allow closed-out counterparties to contribute to the valuation conducted by the resolution authority or the valuer if they have entered into actual replacement trades before the given deadline. However, pursuant to the terms of standard netting agreements for OTC-derivatives such as ISDA Master Agreements or the German Master Agreement for Financial Derivatives Transactions (Deutscher Rahmenvertrag für Finanztermingeschäfte), the party which determines the relevant close-out amount is not required to enter into actual replacement transactions and can rely on other data than the price of actual replacement trades to determine the close-out amount, such as quotations.
Moreover, under most standard agreements the non-defaulting party (that is the party other than the party in relation to which the termination event exists) calculates the close-out amount. This is also consistent with the concept applicable in many jurisdictions that the party which has suffered damages is the one which is entitled to determine the potential claim, if any. This of course does not preclude the defaulting-party to question the amount so determined and/or require a substantiation of the claim.
In view of the concerns raised in our response to Question 3, we propose to amend the RTS so that the counterparties can calculate the close-out amount in accordance with the terms of the relevant netting agreement which means that they can make use of other data than the price of actual replacement trades.
Question 2: Should the deadline given by the resolution authority to the counterparty be further framed? If yes, explain why and how? Does this drafting allow the resolution authority to conclude resolution actions in a sufficiently swift manner?
Yes: For one, the notice should clearly specify the netting agreement/transactions which should be closed-out and the specific time and date of such close-out (close-out date) and/or the time by which counterparties have to produce information on the replacement trades (or other valuation data, see our responses to Questions 3 and 4).Moreover, the period between the notification and the relevant close-out date needs to be pre- defined or at least subject to a pre-defined - and necessarily short - time limit. The resolution authority cannot have complete discretion in setting the close-out date because such complete discretion could effectively undermine the purpose of the strict limitation of the resolution stay and impair the rights of the counterparty.
Furthermore, to ensure that the close-out is accomplished as smoothly as possible and also to reduce the risk of legal challenges, i.e. based on breaches of the no creditor worse off-principle (NCWO-principle), it will be important that all necessary notifications are made in the contractually agreed form and addressed to contractually agreed addressees. This should be expressly clarified.
As to the general concerns regarding reliance on actual (commercially reasonable) replacement trades, see our response to Questions 3 and 4 below.
Question 3: This valuation principle is intended to be aligned with common market practice that recognises replacement costs in an early termination event, whilst giving certainty to the resolution authority on the methodology to be followed. Do you agree that this valuation principle would result in a fair valuation for the closed-out netting set and as such avoid a breach, from the counterparty’s perspective, of the no-creditor-worse-off principle?
In order to avoid uncertainty and potential legal challenges on the basis of the NCWO-principle, the close-out amount needs to be calculated and valued in accordance with the terms agreed in the relevant master agreement:Article 49(3) BRRD states that, where bail-in applies to liabilities arising from derivatives contracts, the valuation of derivatives under a netting agreement must be carried out in accordance with the terms of that agreement. The approach proposed in the draft RTS contains a number of elements which are not consistent with the terms and concepts of standard netting agreements and thus deviates from market practice and the principle set out in Art. 49 (3) BRRD.
For one, as currently drafted, the RTS only allow closed-out counterparties to contribute to the valuation conducted by the resolution authority or the valuer if they have entered into actual replacement trades before the given deadline. However, pursuant to the terms of standard netting agreements for OTC-derivatives such as ISDA Master Agreements or the German Master Agreement for Financial Derivatives Transactions (Deutscher Rahmenvertrag für Finanztermingeschäfte), the party which determines the relevant close-out amount is not required to enter into actual replacement transactions and can rely on other data than the price of actual replacement trades to determine the close-out amount, such as quotations.
Moreover, under most standard agreements the non-defaulting party (that is the party other than the party in relation to which the termination event exists) calculates the close-out amount. This is also consistent with the concept applicable in many jurisdictions that the party which has suffered damages is the one which is entitled to determine the potential claim, if any. This of course does not preclude the defaulting-party to question the amount so determined and/or require a substantiation of the claim.
Question 4: Do you agree with the preferential status given to commercially reasonable replacement trades? Should there be also a prioritisation among other sources of data?
No. As already mentioned above in our response to Question 1 (regarding the definition of “Commercially Reasonable Replacement Trade”) the concept of commercial reasonableness as it is currently defined raises some concerns and the reliance on actual replacement transactions is inconsistent with market practice.In view of the concerns raised in our response to Question 3, we propose to amend the RTS so that the counterparties can calculate the close-out amount in accordance with the terms of the relevant netting agreement which means that they can make use of other data than the price of actual replacement trades.