Current Release PDF  

Release Date: June 22, 2017

Summary

The June 2017 Senior Credit Officer Opinion Survey on Dealer Financing Terms collected qualitative information on changes over the previous three months in credit terms and conditions in securities financing and over-the-counter (OTC) derivatives markets. In addition to the core questions, the survey included a set of special questions about OTC derivatives that are not centrally cleared (uncleared swaps) and are affected by new margin rules. The 23 institutions participating in the survey account for almost all dealer financing of dollar-denominated securities to nondealers and are the most active intermediaries in OTC derivatives markets. The survey was conducted between May 9, 2017, and May 22, 2017. The core questions asked about changes between March 2017 and May 2017.1

Core Questions
(Questions 1-79)2

Responses to the core questions in the June survey overall suggested an increased supply of and demand for dealer facilitation in OTC derivatives and securities financing markets. With regard to the credit terms applicable to, and mark and collateral disputes with, different counterparty types across the entire range of securities financing and OTC derivatives transactions, responses to the core questions revealed the following:

With respect to the use of financial leverage, on net, dealers indicated little change over the past three months for all classes of counterparties.

With regard to OTC derivatives markets, dealers reported the following:

With respect to securities financing transactions, respondents indicated the following:

Special Questions on Uncleared Swaps
(Questions 81–92)

Title VII of the Dodd-Frank Act requires financial regulators to establish new minimum margin requirements for uncleared swaps. In 2015, the U.S. prudential regulators and the Commodity Futures Trading Commission adopted final rules that began to be implemented in September 2016.3 Under the new rules, parties involved in uncleared swap transactions must exchange initial margin (IM) when a trade is established and provide variation margin (VM) to each other on a daily basis over the life of the derivatives contract.4

In the special questions of the survey this quarter, dealers were queried about the overall use and pricing of uncleared swaps that are affected by the new rules and their experiences in adopting the new VM requirement. The next sections summarize the responses from roughly four-fifths of dealers who indicated that they make markets in uncleared swaps and have thus responded to the special questions.

With respect to how the overall use and pricing of uncleared swaps that are affected by the new rules have changed since September 2016, responses to the special questions showed the following:

With respect to dealers’ experiences in adopting the new VM requirement, responses to the special questions revealed the following:

With respect to the mark and collateral disputes on VM, respondents indicated the following:

This document was prepared by Yesol Huh, Division of Research and Statistics, Board of Governors of the Federal Reserve System. Assistance in developing and administering the survey was provided by staff members in the Statistics Function and the Markets Group at the Federal Reserve Bank of New York.

1. For questions that ask about credit terms, net percentages equal the percentage of institutions that reported tightening terms ("tightened considerably" or "tightened somewhat") minus the percentage of institutions that reported easing terms ("eased considerably" or "eased somewhat"). For questions that ask about demand, net fractions equal the percentage of institutions that reported increased demand ("increased considerably" or "increased somewhat") minus the percentage of institutions that reported decreased demand ("decreased considerably" or "decreased somewhat"). Return to text

2. Question 80, not discussed here, was optional and allowed respondents to provide additional comments. Return to text

3. The term "prudential regulators" refers to the Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Farm Credit Administration, and the Federal Housing Finance Agency. Return to text

4. Office of the Comptroller of the Currency, Treasury; Board of Governors of the Federal Reserve System; Federal Deposit Insurance Corporation; Farm Credit Administration; and Federal Housing Finance Agency (2015), "Margin and Capital Requirements for Covered Swap Entities," final rule (Docket No. R-1415), Federal Register, vol. 80 (November 30), pp. 74839–74914, https://www.federalregister.gov/documents/2015/11/30/2015-28671/margin-and-capital-requirements-for-covered-swap-entities; Commodity Futures Trading Commission (2016), "Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants," final rule and interim final rule, Federal Register, vol. 81 (January 6), pp. 635–709, http://www.cftc.gov/LawRegulation/FederalRegister/FinalRules/2015-32320. Return to text

5. Two-fifths of respondents chose "Other," but their text responses generally indicated nonfinancial corporations that are not subject to the new margin requirements. Return to text

 

Exhibit 1: Management of Concentrated Credit Exposures and Indicators of Supply of Credit

 

Exhibit 1: Management of Concentrated Credit Exposures and Indicators of Supply of Credit. See accessible link for data.

Accessible version

 

Exhibit 2: Use of Financial Leverage

 

Exhibit 2: Use of Financial Leverage. See accessible link for data.

Accessible version

 

Exhibit 3: Measures of Demand for Funding and Market Functioning

 

Exhibit 3: Measures of Demand for Funding and Market Functioning. See accessible link for data.

Accessible version

 

Results of the June 2017 Senior Credit Officer Opinion Survey on Dealer Financing Terms

The following results include the original instructions provided to the survey respondents. Please note that percentages are based on the number of financial institutions that gave responses other than "Not applicable." Components may not add to totals due to rounding.

 


Counterparty Types

Questions 1 through 40 ask about credit terms applicable to, and mark and collateral disputes with, different counterparty types, considering the entire range of securities financing and over-the-counter (OTC) derivatives transactions. Question 1 focuses on dealers and other financial intermediaries as counterparties; questions 2 and 3 on central counterparties and other financial utilities; questions 4 through 10 focus on hedge funds; questions 11 through 16 on trading real estate investment trusts (REITs); questions 17 through 22 on mutual funds, exchange-traded funds (ETFs), pension plans, and endowments; questions 23 through 28 on insurance companies; questions 29 through 34 on separately managed accounts established with investment advisers; and questions 35 through 38 on nonfinancial corporations. Questions 39 and 40 ask about mark and collateral disputes for each of the aforementioned counterparty types.

In some questions, the survey differentiates between the compensation demanded for bearing credit risk (price terms) and the contractual provisions used to mitigate exposures (nonprice terms). If your institution's terms have tightened or eased over the past three months, please so report them regardless of how they stand relative to longer-term norms. Please focus your response on dollar-denominated instruments; if material differences exist with respect to instruments denominated in other currencies, please explain in the appropriate comment space. Where material differences exist across different business areas--for example, between traditional prime brokerage and OTC derivatives--please answer with regard to the business area generating the most exposure and explain in the appropriate comment space.


Dealers and Other Financial Intermediaries

1. Over the past three months, how has the amount of resources and attention your firm devotes to management of concentrated credit exposure to dealers and other financial intermediaries (such as large banking institutions) changed?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 1 4.3%
Remained basically unchanged 21 91.3%
Decreased somewhat 1 4.3%
Decreased considerably 0 0.0%
Total 23 100.0%


Central Counterparties and Other Financial Utilities

2. Over the past three months, how has the amount of resources and attention your firm devotes to management of concentrated credit exposure to central counterparties and other financial utilities changed?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 2 8.7%
Remained basically unchanged 21 91.3%
Decreased somewhat 0 0.0%
Decreased considerably 0 0.0%
Total 23 100.0%

3. To what extent have changes in the practices of central counterparties, including margin requirements and haircuts, influenced the credit terms your institution applies to clients on bilateral transactions which are not cleared?

Number of Respondents Percent
To a considerable extent 0 0.0%
To some extent 3 13.0%
To a minimal extent 8 34.8%
Not at all 12 52.2%
Total 23 100.0%


Hedge Funds

4. Over the past three months, how have the price terms (for example, financing rates) offered to hedge funds as reflected across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of nonprice terms?

Number of Respondents Percent
Tightened considerably 0 0.0%
Tightened somewhat 0 0.0%
Remained basically unchanged 18 78.3%
Eased somewhat 4 17.4%
Eased considerably 1 4.3%
Total 23 100.0%

5. Over the past three months, how has your use of nonprice terms (for example, haircuts, maximum maturity, covenants, cure periods, cross-default provisions or other documentation features) with respect to hedge funds across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of price terms?

Number of Respondents Percent
Tightened considerably 0 0.0%
Tightened somewhat 0 0.0%
Remained basically unchanged 19 82.6%
Eased somewhat 4 17.4%
Eased considerably 0 0.0%
Total 23 100.0%

6. To the extent that the price or nonprice terms applied to hedge funds have tightened or eased over the past three months (as reflected in your responses to questions 4 and 5), what are the most important reasons for the change?

  1. Possible reasons for tightening
    1. Deterioration in current or expected financial strength of counterparties
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    2. Reduced willingness of your institution to take on risk
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    3. Adoption of more-stringent market conventions (that is, collateral terms and agreements, ISDA protocols)
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    4. Higher internal treasury charges for funding
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    5. Diminished availability of balance sheet or capital at your institution
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    6. Worsening in general market liquidity and functioning
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    7. Less-aggressive competition from other institutions
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    8. Other (please specify)
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

  2. Possible reasons for easing
    1. Improvement in current or expected financial strength of counterparties
      Number of Respondents Percent
      Most Important 1 100.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 1 100.0%

    2. Increased willingness of your institution to take on risk
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 1 100.0%
      3rd Most Important 0 0.0%
      Total 1 100.0%

    3. Adoption of less-stringent market conventions (that is, collateral terms and agreements, ISDA protocols)
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    4. Lower internal treasury charges for funding
      Number of Respondents Percent
      Most Important 1 100.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 1 100.0%

    5. Increased availability of balance sheet or capital at your institution
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    6. Improvement in general market liquidity and functioning
      Number of Respondents Percent
      Most Important 1 33.3%
      2nd Most Important 1 33.3%
      3rd Most Important 1 33.3%
      Total 3 100.0%

    7. More-aggressive competition from other institutions
      Number of Respondents Percent
      Most Important 3 75.0%
      2nd Most Important 1 25.0%
      3rd Most Important 0 0.0%
      Total 4 100.0%

    8. Other (please specify)
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

7. How has the intensity of efforts by hedge funds to negotiate more-favorable price and nonprice terms changed over the past three months?

Number of Respondents Percent
Increased considerably 1 4.3%
Increased somewhat 6 26.1%
Remained basically unchanged 16 69.6%
Decreased somewhat 0 0.0%
Decreased considerably 0 0.0%
Total 23 100.0%

8. Considering the entire range of transactions facilitated by your institution for such clients, how has the use of financial leverage by hedge funds changed over the past three months?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 3 13.0%
Remained basically unchanged 18 78.3%
Decreased somewhat 2 8.7%
Decreased considerably 0 0.0%
Total 23 100.0%

9. Considering the entire range of transactions facilitated by your institution for such clients, how has the availability of additional (and currently unutilized) financial leverage under agreements currently in place with hedge funds (for example, under prime broker, warehouse agreements, and other committed but undrawn or partly drawn facilities) changed over the past three months?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 2 8.7%
Remained basically unchanged 21 91.3%
Decreased somewhat 0 0.0%
Decreased considerably 0 0.0%
Total 23 100.0%

10. How has the provision of differential terms by your institution to most-favored (as a function of breadth, duration, and extent of relationship) hedge funds changed over the past three months?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 5 21.7%
Remained basically unchanged 18 78.3%
Decreased somewhat 0 0.0%
Decreased considerably 0 0.0%
Total 23 100.0%


Trading Real Estate Investment Trusts

11. Over the past three months, how have the price terms (for example, financing rates) offered to trading REITs as reflected across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of nonprice terms?

Number of Respondents Percent
Tightened considerably 0 0.0%
Tightened somewhat 1 5.3%
Remained basically unchanged 16 84.2%
Eased somewhat 1 5.3%
Eased considerably 1 5.3%
Total 19 100.0%

12. Over the past three months, how has your use of nonprice terms (for example, haircuts, maximum maturity, covenants, cure periods, cross-default provisions or other documentation features) with respect to trading REITs across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of price terms?

Number of Respondents Percent
Tightened considerably 0 0.0%
Tightened somewhat 1 5.3%
Remained basically unchanged 17 89.5%
Eased somewhat 1 5.3%
Eased considerably 0 0.0%
Total 19 100.0%

13. To the extent that the price or nonprice terms applied to trading REITs have tightened or eased over the past three months (as reflected in your responses to questions 11 and 12), what are the most important reasons for the change?

  1. Possible reasons for tightening
    1. Deterioration in current or expected financial strength of counterparties
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    2. Reduced willingness of your institution to take on risk
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    3. Adoption of more-stringent market conventions (that is, collateral terms and agreements, ISDA protocols)
      Number of Respondents Percent
      Most Important 2 100.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 2 100.0%

    4. Higher internal treasury charges for funding
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    5. Diminished availability of balance sheet or capital at your institution
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    6. Worsening in general market liquidity and functioning
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    7. Less-aggressive competition from other institutions
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    8. Other (please specify)
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

  2. Possible reasons for easing
    1. Improvement in current or expected financial strength of counterparties
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    2. Increased willingness of your institution to take on risk
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    3. Adoption of less-stringent market conventions (that is, collateral terms and agreements, ISDA protocols)
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    4. Lower internal treasury charges for funding
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    5. Increased availability of balance sheet or capital at your institution
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    6. Improvement in general market liquidity and functioning
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 1 100.0%
      3rd Most Important 0 0.0%
      Total 1 100.0%

    7. More-aggressive competition from other institutions
      Number of Respondents Percent
      Most Important 2 100.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 2 100.0%

    8. Other
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

14. How has the intensity of efforts by trading REITs to negotiate more-favorable price and nonprice terms changed over the past three months?

Number of Respondents Percent
Increased considerably 1 5.3%
Increased somewhat 1 5.3%
Remained basically unchanged 16 84.2%
Decreased somewhat 1 5.3%
Decreased considerably 0 0.0%
Total 19 100.0%

15. Considering the entire range of transactions facilitated by your institution for such clients, how has the use of financial leverage by trading REITs changed over the past three months?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 1 5.3%
Remained basically unchanged 17 89.5%
Decreased somewhat 1 5.3%
Decreased considerably 0 0.0%
Total 19 100.0%

16. How has the provision of differential terms by your institution to most-favored (as a function of breadth, duration, and extent of relationship) trading REITs changed over the past three months?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 1 5.3%
Remained basically unchanged 18 94.7%
Decreased somewhat 0 0.0%
Decreased considerably 0 0.0%
Total 19 100.0%


Mutual Funds, Exchange-Traded Funds, Pension Plans, and Endowments

17. Over the past three months, how have the price terms (for example, financing rates) offered to mutual funds, ETFs, pension plans, and endowments as reflected across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of nonprice terms?

Number of Respondents Percent
Tightened considerably 0 0.0%
Tightened somewhat 0 0.0%
Remained basically unchanged 22 95.7%
Eased somewhat 0 0.0%
Eased considerably 1 4.3%
Total 23 100.0%

18. Over the past three months, how has your use of nonprice terms (for example, haircuts, maximum maturity, covenants, cure periods, cross-default provisions or other documentation features) with respect to mutual funds, ETFs, pension plans, and endowments across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of price terms?

Number of Respondents Percent
Tightened considerably 0 0.0%
Tightened somewhat 0 0.0%
Remained basically unchanged 22 95.7%
Eased somewhat 1 4.3%
Eased considerably 0 0.0%
Total 23 100.0%

19. To the extent that the price or nonprice terms applied to mutual funds, ETFs, pension plans, and endowments have tightened or eased over the past three months (as reflected in your responses to questions 17 and 18) what are the most important reasons for the change?

  1. Possible reasons for tightening
    1. Deterioration in current or expected financial strength of counterparties
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    2. Reduced willingness of your institution to take on risk
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    3. Adoption of more-stringent market conventions (that is, collateral terms and agreements, ISDA protocols)
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    4. Higher internal treasury charges for funding
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    5. Diminished availability of balance sheet or capital at your institution
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    6. Worsening in general market liquidity and functioning
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    7. Less-aggressive competition from other institutions
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    8. Other
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

  2. Possible reasons for easing
    1. Improvement in current or expected financial strength of counterparties
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    2. Increased willingness of your institution to take on risk
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    3. Adoption of less-stringent market conventions (that is, collateral terms and agreements, ISDA protocols)
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    4. Lower internal treasury charges for funding
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    5. Increased availability of balance sheet or capital at your institution
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    6. Improvement in general market liquidity and functioning
      Number of Respondents Percent
      Most Important 1 100.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 1 100.0%

    7. More-aggressive competition from other institutions
      Number of Respondents Percent
      Most Important 1 100.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 1 100.0%

    8. Other
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

20. How has the intensity of efforts by mutual funds, ETFs, pension plans, and endowments to negotiate more-favorable price and nonprice terms changed over the past three months?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 0 0.0%
Remained basically unchanged 23 100.0%
Decreased somewhat 0 0.0%
Decreased considerably 0 0.0%
Total 23 100.0%

21. Considering the entire range of transactions facilitated by your institution, how has the use of financial leverage by each of the following types of clients changed over the past three months?

  1. Mutual funds
    Number of Respondents Percent
    Increased Considerably 0 0.0%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 22 100.0%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 0 0.0%
    Total 22 100.0%

  2. ETFs
    Number of Respondents Percent
    Increased Considerably 0 0.0%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 22 100.0%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 0 0.0%
    Total 22 100.0%

  3. Pension plans
    Number of Respondents Percent
    Increased Considerably 0 0.0%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 22 100.0%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 0 0.0%
    Total 22 100.0%

  4. Endowments
    Number of Respondents Percent
    Increased Considerably 0 0.0%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 21 100.0%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 0 0.0%
    Total 21 100.0%

22. How has the provision of differential terms by your institution to most-favored (as a function of breadth, duration, and extent of relationship) mutual funds, ETFs, pension plans, and endowments changed over the past three months?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 2 8.7%
Remained basically unchanged 21 91.3%
Decreased somewhat 0 0.0%
Decreased considerably 0 0.0%
Total 23 100.0%


Insurance Companies

23. Over the past three months, how have the price terms (for example, financing rates) offered to insurance companies as reflected across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of nonprice terms?

Number of Respondents Percent
Tightened considerably 0 0.0%
Tightened somewhat 0 0.0%
Remained basically unchanged 21 95.5%
Eased somewhat 1 4.5%
Eased considerably 0 0.0%
Total 22 100.0%

24. Over the past three months, how has your use of nonprice terms (for example, haircuts, maximum maturity, covenants, cure periods, cross-default provisions or other documentation features) with respect to insurance companies across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of price terms?

Number of Respondents Percent
Tightened considerably 0 0.0%
Tightened somewhat 1 4.5%
Remained basically unchanged 21 95.5%
Eased somewhat 0 0.0%
Eased considerably 0 0.0%
Total 22 100.0%

25. To the extent that the price or nonprice terms applied to insurance companies have tightened or eased over the past three months (as reflected in your responses to questions 23 and 24) what are the most important reasons for the change?

  1. Possible reasons for tightening
    1. Deterioration in current or expected financial strength of counterparties
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    2. Reduced willingness of your institution to take on risk
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    3. Adoption of more-stringent market conventions (that is, collateral terms and agreements, ISDA protocols)
      Number of Respondents Percent
      Most Important 1 100.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 1 100.0%

    4. Higher internal treasury charges for funding
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    5. Diminished availability of balance sheet or capital at your institution
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    6. Worsening in general market liquidity and functioning
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    7. Less-aggressive competition from other institutions
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    8. Other
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

  2. Possible reasons for easing
    1. Improvement in current or expected financial strength of counterparties
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    2. Increased willingness of your institution to take on risk
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    3. Adoption of less-stringent market conventions (that is, collateral terms and agreements, ISDA protocols)
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    4. Lower internal treasury charges for funding
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    5. Increased availability of balance sheet or capital at your institution
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    6. Improvement in general market liquidity and functioning
      Number of Respondents Percent
      Most Important 1 100.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 1 100.0%

    7. More-aggressive competition from other institutions
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    8. Other
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

26. How has the intensity of efforts by insurance companies to negotiate more-favorable price and nonprice terms changed over the past three months?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 1 4.5%
Remained basically unchanged 21 95.5%
Decreased somewhat 0 0.0%
Decreased considerably 0 0.0%
Total 22 100.0%

27. Considering the entire range of transactions facilitated by your institution for such clients, how has the use of financial leverage by insurance companies changed over the past three months?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 0 0.0%
Remained basically unchanged 22 100.0%
Decreased somewhat 0 0.0%
Decreased considerably 0 0.0%
Total 22 100.0%

28. How has the provision of differential terms by your institution to most-favored (as a function of breadth, duration, and extent of relationship) insurance companies changed over the past three months?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 0 0.0%
Remained basically unchanged 22 100.0%
Decreased somewhat 0 0.0%
Decreased considerably 0 0.0%
Total 22 100.0%


Separately Managed Accounts Established with Investment Advisers

29. Over the past three months, how have the price terms (for example, financing rates) offered to separately managed accounts established with investment advisers as reflected across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of nonprice terms?

Number of Respondents Percent
Tightened considerably 0 0.0%
Tightened somewhat 1 4.8%
Remained basically unchanged 18 85.7%
Eased somewhat 2 9.5%
Eased considerably 0 0.0%
Total 21 100.0%

30. Over the past three months, how has your use of nonprice terms (for example, haircuts, maximum maturity, covenants, cure periods, cross-default provisions or other documentation features) with respect to separately managed accounts established with investment advisers across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of price terms?

Number of Respondents Percent
Tightened considerably 0 0.0%
Tightened somewhat 0 0.0%
Remained basically unchanged 20 95.2%
Eased somewhat 1 4.8%
Eased considerably 0 0.0%
Total 21 100.0%

31. To the extent that the price or nonprice terms applied to separately managed accounts established with investment advisers have tightened or eased over the past three months (as reflected in your responses to questions 29 and 30), what are the most important reasons for the change?

  1. Possible reasons for tightening
    1. Deterioration in current or expected financial strength of counterparties
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    2. Reduced willingness of your institution to take on risk
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    3. Adoption of more-stringent market conventions (that is, collateral terms and agreements, ISDA protocols)
      Number of Respondents Percent
      Most Important 1 100.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 1 100.0%

    4. Higher internal treasury charges for funding
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    5. Diminished availability of balance sheet or capital at your institution
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    6. Worsening in general market liquidity and functioning
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    7. Less-aggressive competition from other institutions
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    8. Other
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

  2. Possible reasons for easing
    1. Improvement in current or expected financial strength of counterparties
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    2. Increased willingness of your institution to take on risk
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    3. Adoption of less-stringent market conventions (that is, collateral terms and agreements, ISDA protocols)
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    4. Lower internal treasury charges for funding
      Number of Respondents Percent
      Most Important 1 100.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 1 100.0%

    5. Increased availability of balance sheet or capital at your institution
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    6. Improvement in general market liquidity and functioning
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    7. More-aggressive competition from other institutions
      Number of Respondents Percent
      Most Important 2 100.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 2 100.0%

    8. Other
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

32. How has the intensity of efforts by investment advisers to negotiate more-favorable price and nonprice terms on behalf of separately managed accounts changed over the past three months?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 1 4.8%
Remained basically unchanged 20 95.2%
Decreased somewhat 0 0.0%
Decreased considerably 0 0.0%
Total 21 100.0%

33. Considering the entire range of transactions facilitated by your institution for such clients, how has the use of financial leverage by separately managed accounts established with investment advisers changed over the past three months?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 0 0.0%
Remained basically unchanged 21 100.0%
Decreased somewhat 0 0.0%
Decreased considerably 0 0.0%
Total 21 100.0%

34. How has the provision of differential terms by your institution to separately managed accounts established with most-favored (as a function of breadth, duration, and extent of relationship) investment advisers changed over the past three months?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 0 0.0%
Remained basically unchanged 21 100.0%
Decreased somewhat 0 0.0%
Decreased considerably 0 0.0%
Total 21 100.0%


Nonfinancial Corporations

35. Over the past three months, how have the price terms (for example, financing rates) offered to nonfinancial corporations as reflected across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of nonprice terms?

Number of Respondents Percent
Tightened considerably 0 0.0%
Tightened somewhat 0 0.0%
Remained basically unchanged 22 95.7%
Eased somewhat 1 4.3%
Eased considerably 0 0.0%
Total 23 100.0%

36. Over the past three months, how has your use of nonprice terms (for example, haircuts, maximum maturity, covenants, cure periods, cross-default provisions or other documentation features) with respect to nonfinancial corporations across the entire spectrum of securities financing and OTC derivatives transaction types changed, regardless of price terms?

Number of Respondents Percent
Tightened considerably 0 0.0%
Tightened somewhat 0 0.0%
Remained basically unchanged 22 95.7%
Eased somewhat 1 4.3%
Eased considerably 0 0.0%
Total 23 100.0%

37. To the extent that the price or nonprice terms applied to nonfinancial corporations have tightened or eased over the past three months (as reflected in your responses to questions 35 and 36) what are the most important reasons for the change?

  1. Possible reasons for tightening
    1. Deterioration in current or expected financial strength of counterparties
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    2. Reduced willingness of your institution to take on risk
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    3. Adoption of more-stringent market conventions (that is, collateral terms and agreements, ISDA protocols)
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    4. Higher internal treasury charges for funding
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    5. Diminished availability of balance sheet or capital at your institution
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    6. Worsening in general market liquidity and functioning
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    7. Less-aggressive competition from other institutions
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    8. Other
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

  2. Possible reasons for easing
    1. Improvement in current or expected financial strength of counterparties
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    2. Increased willingness of your institution to take on risk
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    3. Adoption of less-stringent market conventions (that is, collateral terms and agreements, ISDA protocols)
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    4. Lower internal treasury charges for funding
      Number of Respondents Percent
      Most Important 2 100.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 2 100.0%

    5. Increased availability of balance sheet or capital at your institution
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    6. Improvement in general market liquidity and functioning
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 0 0.0%
      Total 0 0.0%

    7. More-aggressive competition from other institutions
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 1 100.0%
      3rd Most Important 0 0.0%
      Total 1 100.0%

    8. Other
      Number of Respondents Percent
      Most Important 0 0.0%
      2nd Most Important 0 0.0%
      3rd Most Important 1 100.0%
      Total 1 100.0%

38. How has the intensity of efforts by nonfinancial corporations to negotiate more-favorable price and nonprice terms changed over the past three months?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 0 0.0%
Remained basically unchanged 23 100.0%
Decreased somewhat 0 0.0%
Decreased considerably 0 0.0%
Total 23 100.0%


Mark and Collateral Disputes

39. Over the past three months, how has the volume of mark and collateral disputes with clients of each of the following types changed?

  1. Dealers and other financial intermediaries
    Number of Respondents Percent
    Increased Considerably 1 4.8%
    Increased Somewhat 3 14.3%
    Remained Basically Unchanged 16 76.2%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 4.8%
    Total 21 100.0%

  2. Hedge funds
    Number of Respondents Percent
    Increased Considerably 1 4.8%
    Increased Somewhat 1 4.8%
    Remained Basically Unchanged 18 85.7%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 4.8%
    Total 21 100.0%

  3. Trading REITs
    Number of Respondents Percent
    Increased Considerably 0 0.0%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 16 94.1%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 5.9%
    Total 17 100.0%

  4. Mutual funds, ETFs, pension plans, and endowments
    Number of Respondents Percent
    Increased Considerably 1 4.8%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 19 90.5%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 4.8%
    Total 21 100.0%

  5. Insurance companies
    Number of Respondents Percent
    Increased Considerably 2 10.0%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 16 80.0%
    Decreased Somewhat 1 5.0%
    Decreased Considerably 1 5.0%
    Total 20 100.0%

  6. Separately managed accounts established with investment advisers
    Number of Respondents Percent
    Increased Considerably 1 5.3%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 16 84.2%
    Decreased Somewhat 1 5.3%
    Decreased Considerably 1 5.3%
    Total 19 100.0%

  7. Nonfinancial corporations
    Number of Respondents Percent
    Increased Considerably 1 5.3%
    Increased Somewhat 1 5.3%
    Remained Basically Unchanged 16 84.2%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 5.3%
    Total 19 100.0%

40. Over the past three months, how has the duration and persistence of mark and collateral disputes with clients of each of the following types changed?

  1. Dealers and other financial intermediaries
    Number of Respondents Percent
    Increased Considerably 1 4.8%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 19 90.5%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 4.8%
    Total 21 100.0%

  2. Hedge funds
    Number of Respondents Percent
    Increased Considerably 1 4.8%
    Increased Somewhat 1 4.8%
    Remained Basically Unchanged 16 76.2%
    Decreased Somewhat 2 9.5%
    Decreased Considerably 1 4.8%
    Total 21 100.0%

  3. Trading REITs
    Number of Respondents Percent
    Increased Considerably 0 0.0%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 16 94.1%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 5.9%
    Total 17 100.0%

  4. Mutual funds, ETFs, pension plans, and endowments
    Number of Respondents Percent
    Increased Considerably 1 4.8%
    Increased Somewhat 1 4.8%
    Remained Basically Unchanged 17 81.0%
    Decreased Somewhat 1 4.8%
    Decreased Considerably 1 4.8%
    Total 21 100.0%

  5. Insurance companies
    Number of Respondents Percent
    Increased Considerably 1 5.0%
    Increased Somewhat 1 5.0%
    Remained Basically Unchanged 15 75.0%
    Decreased Somewhat 2 10.0%
    Decreased Considerably 1 5.0%
    Total 20 100.0%

  6. Separately managed accounts established with investment advisers
    Number of Respondents Percent
    Increased Considerably 1 5.3%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 16 84.2%
    Decreased Somewhat 1 5.3%
    Decreased Considerably 1 5.3%
    Total 19 100.0%

  7. Nonfinancial corporations
    Number of Respondents Percent
    Increased Considerably 1 5.3%
    Increased Somewhat 1 5.3%
    Remained Basically Unchanged 16 84.2%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 5.3%
    Total 19 100.0%


Over-the-Counter Derivatives

Questions 41 through 51 ask about OTC derivatives trades. Question 41 focuses on nonprice terms applicable to new and renegotiated master agreements. Questions 42 through 48 ask about the initial margin requirements for most-favored and average clients applicable to different types of contracts: Question 42 focuses on foreign exchange (FX); question 43 on interest rates; question 44 on equity; question 45 on contracts referencing corporate credits (single-name and indexes); question 46 on credit derivatives referencing structured products such as mortgage-backed securities (MBS) and asset-backed securities (ABS) (specific tranches and indexes); question 47 on commodities; and question 48 on total return swaps (TRS) referencing nonsecurities (such as bank loans, including, for example, commercial and industrial loans and mortgage whole loans). Question 49 asks about posting of nonstandard collateral pursuant to OTC derivatives contracts. Questions 50 and 51 focus on mark and collateral disputes involving contracts of each of the aforementioned types.

If your institution’s terms have tightened or eased over the past three months, please so report them regardless of how they stand relative to longer-term norms. Please focus your response on dollar-denominated instruments; if material differences exist with respect to instruments denominated in other currencies, please explain in the appropriate comment space.


New and Renegotiated Master Agreements

41. Over the past three months, how have nonprice terms incorporated in new or renegotiated OTC derivatives master agreements put in place with your institution's client changed?

  1. Requirements, timelines, and thresholds for posting additional margin
    Number of Respondents Percent
    Tightened Considerably 0 0.0%
    Tightened Somewhat 2 9.5%
    Remained Basically Unchanged 19 90.5%
    Eased Somewhat 0 0.0%
    Eased Considerably 0 0.0%
    Total 21 100.0%

  2. Acceptable collateral
    Number of Respondents Percent
    Tightened Considerably 0 0.0%
    Tightened Somewhat 3 14.3%
    Remained Basically Unchanged 18 85.7%
    Eased Somewhat 0 0.0%
    Eased Considerably 0 0.0%
    Total 21 100.0%

  3. Recognition of portfolio or diversification benefits (including from securities financing trades where appropriate agreements are in place)
    Number of Respondents Percent
    Tightened Considerably 0 0.0%
    Tightened Somewhat 0 0.0%
    Remained Basically Unchanged 20 100.0%
    Eased Somewhat 0 0.0%
    Eased Considerably 0 0.0%
    Total 20 100.0%

  4. Triggers and covenants
    Number of Respondents Percent
    Tightened Considerably 0 0.0%
    Tightened Somewhat 1 4.8%
    Remained Basically Unchanged 19 90.5%
    Eased Somewhat 1 4.8%
    Eased Considerably 0 0.0%
    Total 21 100.0%

  5. Other documentation features (including cure periods and cross-default provisions)
    Number of Respondents Percent
    Tightened Considerably 0 0.0%
    Tightened Somewhat 1 4.8%
    Remained Basically Unchanged 19 90.5%
    Eased Somewhat 1 4.8%
    Eased Considerably 0 0.0%
    Total 21 100.0%

  6. Other
    Number of Respondents Percent
    Increased Considerably 0 0.0%
    Increased Somewhat 1 100.0%
    Remained Basically Unchanged 0 0.0%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 0 0.0%
    Total 1 100.0%


Initial Margin

42. Over the past three months, how have initial margin requirements set by your institution with respect to OTC FX derivatives changed?

  1. Initial margin requirements for average clients
    Number of Respondents Percent
    Increased considerably 0 0.0%
    Increased somewhat 1 5.0%
    Remained basically unchanged 18 90.0%
    Decreased somewhat 1 5.0%
    Decreased considerably 0 0.0%
    Total 20 100.0%

  2. Initial margin requirements for most-favored clients, as a consequence of breadth, duration, and/or extent of relationship
    Number of Respondents Percent
    Increased considerably 0 0.0%
    Increased somewhat 0 0.0%
    Remained basically unchanged 19 95.0%
    Decreased somewhat 1 5.0%
    Decreased considerably 0 0.0%
    Total 20 100.0%

43. Over the past three months, how have initial margin requirements set by your institution with respect to OTC interest rate derivatives changed?

  1. Initial margin requirements for average clients
    Number of Respondents Percent
    Increased considerably 0 0.0%
    Increased somewhat 0 0.0%
    Remained basically unchanged 19 90.5%
    Decreased somewhat 1 4.8%
    Decreased considerably 1 4.8%
    Total 21 100.0%

  2. Initial margin requirements for most-favored clients, as a consequence of breadth, duration, and/or extent of relationship
    Number of Respondents Percent
    Increased considerably 0 0.0%
    Increased somewhat 0 0.0%
    Remained basically unchanged 20 95.2%
    Decreased somewhat 1 4.8%
    Decreased considerably 0 0.0%
    Total 21 100.0%

44. Over the past three months, how have initial margin requirements set by your institution with respect to OTC equity derivatives changed?

  1. Initial margin requirements for average clients
    Number of Respondents Percent
    Increased considerably 0 0.0%
    Increased somewhat 0 0.0%
    Remained basically unchanged 18 90.0%
    Decreased somewhat 2 10.0%
    Decreased considerably 0 0.0%
    Total 20 100.0%

  2. Initial margin requirements for most-favored clients, as a consequence of breadth, duration, and/or extent of relationship
    Number of Respondents Percent
    Increased considerably 0 0.0%
    Increased somewhat 0 0.0%
    Remained basically unchanged 18 90.0%
    Decreased somewhat 2 10.0%
    Decreased considerably 0 0.0%
    Total 20 100.0%

45. Over the past three months, how have initial margin requirements set by your institution with respect to OTC credit derivatives referencing corporates (single-name corporates or corporate indexes) changed?

  1. Initial margin requirements for average clients
    Number of Respondents Percent
    Increased considerably 0 0.0%
    Increased somewhat 0 0.0%
    Remained basically unchanged 17 94.4%
    Decreased somewhat 1 5.6%
    Decreased considerably 0 0.0%
    Total 18 100.0%

  2. Initial margin requirements for most-favored clients, as a consequence of breadth, duration, and/or extent of relationship
    Number of Respondents Percent
    Increased considerably 0 0.0%
    Increased somewhat 0 0.0%
    Remained basically unchanged 17 94.4%
    Decreased somewhat 1 5.6%
    Decreased considerably 0 0.0%
    Total 18 100.0%

46. Over the past three months, how have initial margin requirements set by your institution with respect to OTC credit derivatives referencing securitized products (such as specific ABS or MBS tranches and associated indexes) changed?

  1. Initial margin requirements for average clients
    Number of Respondents Percent
    Increased considerably 0 0.0%
    Increased somewhat 1 8.3%
    Remained basically unchanged 10 83.3%
    Decreased somewhat 1 8.3%
    Decreased considerably 0 0.0%
    Total 12 100.0%

  2. Initial margin requirements for most-favored clients, as a consequence of breadth, duration, and/or extent of relationship
    Number of Respondents Percent
    Increased considerably 0 0.0%
    Increased somewhat 0 0.0%
    Remained basically unchanged 12 92.3%
    Decreased somewhat 1 7.7%
    Decreased considerably 0 0.0%
    Total 13 100.0%

47. Over the past three months, how have initial margin requirements set by your institution with respect to OTC commodity derivatives changed?

  1. Initial margin requirements for average clients
    Number of Respondents Percent
    Increased considerably 1 6.3%
    Increased somewhat 0 0.0%
    Remained basically unchanged 15 93.8%
    Decreased somewhat 0 0.0%
    Decreased considerably 0 0.0%
    Total 16 100.0%

  2. Initial margin requirements for most-favored clients, as a consequence of breadth, duration, and/or extent of relationship
    Number of Respondents Percent
    Increased considerably 0 0.0%
    Increased somewhat 0 0.0%
    Remained basically unchanged 15 93.8%
    Decreased somewhat 1 6.3%
    Decreased considerably 0 0.0%
    Total 16 100.0%

48. Over the past three months, how have initial margin requirements set by your institution with respect to TRS referencing nonsecurities (such as bank loans, including, for example, commercial and industrial loans and mortgage whole loans) changed?

  1. Initial margin requirements for average clients
    Number of Respondents Percent
    Increased considerably 1 5.9%
    Increased somewhat 0 0.0%
    Remained basically unchanged 16 94.1%
    Decreased somewhat 0 0.0%
    Decreased considerably 0 0.0%
    Total 17 100.0%

  2. Initial margin requirements for most-favored clients, as a consequence of breadth, duration, and/or extent of relationship
    Number of Respondents Percent
    Increased considerably 0 0.0%
    Increased somewhat 0 0.0%
    Remained basically unchanged 16 94.1%
    Decreased somewhat 1 5.9%
    Decreased considerably 0 0.0%
    Total 17 100.0%


Nonstandard Collateral

49. Over the past three months, how has the posting of nonstandard collateral (that is, other than cash and U.S. Treasury securities) as permitted under relevant agreements changed?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 1 4.3%
Remained basically unchanged 20 87.0%
Decreased somewhat 0 0.0%
Decreased considerably 2 8.7%
Total 23 100.0%


Mark and Collateral Disputes

50. Over the past three months, how has the volume of mark and collateral disputes relating to contracts of each of the following types changed?

  1. FX
    Number of Respondents Percent
    Increased Considerably 1 5.0%
    Increased Somewhat 3 15.0%
    Remained Basically Unchanged 15 75.0%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 5.0%
    Total 20 100.0%

  2. Interest rate
    Number of Respondents Percent
    Increased Considerably 1 4.8%
    Increased Somewhat 4 19.0%
    Remained Basically Unchanged 15 71.4%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 4.8%
    Total 21 100.0%

  3. Equity
    Number of Respondents Percent
    Increased Considerably 1 5.0%
    Increased Somewhat 2 10.0%
    Remained Basically Unchanged 16 80.0%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 5.0%
    Total 20 100.0%

  4. Credit referencing corporates
    Number of Respondents Percent
    Increased Considerably 1 5.0%
    Increased Somewhat 1 5.0%
    Remained Basically Unchanged 17 85.0%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 5.0%
    Total 20 100.0%

  5. Credit referencing securitized products including MBS and ABS
    Number of Respondents Percent
    Increased Considerably 1 5.6%
    Increased Somewhat 1 5.6%
    Remained Basically Unchanged 15 83.3%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 5.6%
    Total 18 100.0%

  6. Commodity
    Number of Respondents Percent
    Increased Considerably 1 5.9%
    Increased Somewhat 1 5.9%
    Remained Basically Unchanged 14 82.4%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 5.9%
    Total 17 100.0%

  7. TRS referencing nonsecurities (such as bank loans, including, for example, commercial and industrial loans and mortgage whole loans)
    Number of Respondents Percent
    Increased Considerably 1 6.7%
    Increased Somewhat 1 6.7%
    Remained Basically Unchanged 13 86.7%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 0 0.0%
    Total 15 100.0%

51. Over the past three months, how has the duration and persistence of mark and collateral disputes relating to contracts of each of the following types changed?

  1. FX
    Number of Respondents Percent
    Increased Considerably 1 5.0%
    Increased Somewhat 3 15.0%
    Remained Basically Unchanged 15 75.0%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 5.0%
    Total 20 100.0%

  2. Interest rate
    Number of Respondents Percent
    Increased Considerably 1 4.8%
    Increased Somewhat 2 9.5%
    Remained Basically Unchanged 17 81.0%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 4.8%
    Total 21 100.0%

  3. Equity
    Number of Respondents Percent
    Increased Considerably 1 5.0%
    Increased Somewhat 2 10.0%
    Remained Basically Unchanged 16 80.0%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 5.0%
    Total 20 100.0%

  4. Credit referencing corporates
    Number of Respondents Percent
    Increased Considerably 1 5.0%
    Increased Somewhat 1 5.0%
    Remained Basically Unchanged 17 85.0%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 5.0%
    Total 20 100.0%

  5. Credit referencing securitized products including MBS and ABS
    Number of Respondents Percent
    Increased Considerably 1 5.6%
    Increased Somewhat 1 5.6%
    Remained Basically Unchanged 15 83.3%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 5.6%
    Total 18 100.0%

  6. Commodity
    Number of Respondents Percent
    Increased Considerably 1 6.3%
    Increased Somewhat 2 12.5%
    Remained Basically Unchanged 13 81.3%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 0 0.0%
    Total 16 100.0%

  7. TRS referencing nonsecurities (such as bank loans, including, for example, commercial and industrial loans and mortgage whole loans)
    Number of Respondents Percent
    Increased Considerably 1 6.3%
    Increased Somewhat 1 6.3%
    Remained Basically Unchanged 14 87.5%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 0 0.0%
    Total 16 100.0%


Securities Financing

Questions 52 through 79 ask about securities funding at your institution--that is, lending to clients collateralized by securities. Such activities may be conducted on a "repo" desk, on a trading desk engaged in facilitation for institutional clients and/or proprietary transactions, on a funding desk, or on a prime brokerage platform. Questions 52 through 55 focus on lending against high-grade corporate bonds; questions 56 through 59 on lending against high-yield corporate bonds; questions 60 and 61 on lending against equities (including through stock loan); questions 62 through 65 on lending against agency residential mortgage-backed securities (agency RMBS); questions 66 through 69 on lending against non-agency residential mortgage-backed securities (non-agency RMBS); questions 70 through 73 on lending against commercial mortgage-backed securities (CMBS); and questions 74 through 77 on consumer ABS (for example, backed by credit card receivables or auto loans). Questions 78 and 79 ask about mark and collateral disputes for lending backed by each of the aforementioned contract types.

If your institution’s terms have tightened or eased over the past three months, please so report them regardless of how they stand relative to longer-term norms. Please focus your response on dollar-denominated instruments; if material differences exist with respect to instruments denominated in other currencies, please explain in the appropriate comment space.


High-Grade Corporate Bonds

52. Over the past three months, how have the terms under which high-grade corporate bonds are funded changed?

  1. Terms for average clients
    1. Maximum amount of funding
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 20 95.2%
      Eased Somewhat 1 4.8%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    2. Maximum maturity
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 1 4.8%
      Remained Basically Unchanged 19 90.5%
      Eased Somewhat 1 4.8%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    3. Haircuts
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 21 100.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    4. Collateral spreads over relevant benchmark (effective financing rates)
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 1 4.8%
      Remained Basically Unchanged 19 90.5%
      Eased Somewhat 1 4.8%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    5. Other
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 0 0.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 0 0.0%

  2. Terms for most-favored clients, as a consequence of breadth, duration and/or extent of relationship
    1. Maximum amount of funding
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 20 95.2%
      Eased Somewhat 1 4.8%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    2. Maximum maturity
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 1 4.8%
      Remained Basically Unchanged 19 90.5%
      Eased Somewhat 1 4.8%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    3. Haircuts
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 20 95.2%
      Eased Somewhat 1 4.8%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    4. Collateral spreads over relevant benchmark (effective financing rates)
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 1 4.8%
      Remained Basically Unchanged 19 90.5%
      Eased Somewhat 1 4.8%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    5. Other
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 0 0.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 0 0.0%

53. Over the past three months, how has demand for funding of high-grade corporate bonds by your institution's clients changed?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 1 5.0%
Remained basically unchanged 16 80.0%
Decreased somewhat 3 15.0%
Decreased considerably 0 0.0%
Total 20 100.0%

54. Over the past three months, how has demand for term funding with a maturity greater than 30 days of high-grade corporate bonds by your institution's clients changed?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 1 4.8%
Remained basically unchanged 19 90.5%
Decreased somewhat 1 4.8%
Decreased considerably 0 0.0%
Total 21 100.0%

55. Over the past three months, how have liquidity and functioning in the high-grade corporate bond market changed?

Number of Respondents Percent
Improved considerably 0 0.0%
Improved somewhat 4 18.2%
Remained basically unchanged 17 77.3%
Deteriorated somewhat 1 4.5%
Deteriorated considerably 0 0.0%
Total 22 100.0%


High-Yield Corporate Bonds

56. Over the past three months, how have the terms under which high-yield corporate bonds are funded changed?

  1. Terms for average clients
    1. Maximum amount of funding
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 17 89.5%
      Eased Somewhat 2 10.5%
      Eased Considerably 0 0.0%
      Total 19 100.0%

    2. Maximum maturity
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 1 5.3%
      Remained Basically Unchanged 16 84.2%
      Eased Somewhat 2 10.5%
      Eased Considerably 0 0.0%
      Total 19 100.0%

    3. Haircuts
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 19 100.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 19 100.0%

    4. Collateral spreads over relevant benchmark (effective financing rates)
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 1 5.3%
      Remained Basically Unchanged 14 73.7%
      Eased Somewhat 4 21.1%
      Eased Considerably 0 0.0%
      Total 19 100.0%

    5. Other
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 0 0.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 0 0.0%

  2. Terms for most-favored clients, as a consequence of breadth, duration and/or extent of relationship
    1. Maximum amount of funding
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 17 89.5%
      Eased Somewhat 2 10.5%
      Eased Considerably 0 0.0%
      Total 19 100.0%

    2. Maximum maturity
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 1 5.3%
      Remained Basically Unchanged 16 84.2%
      Eased Somewhat 2 10.5%
      Eased Considerably 0 0.0%
      Total 19 100.0%

    3. Haircuts
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 19 100.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 19 100.0%

    4. Collateral spreads over relevant benchmark (effective financing rates)
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 1 5.3%
      Remained Basically Unchanged 14 73.7%
      Eased Somewhat 4 21.1%
      Eased Considerably 0 0.0%
      Total 19 100.0%

    5. Other
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 0 0.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 0 0.0%

57. Over the past three months, how has demand for funding of high-yield corporate bonds by your institution's clients changed?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 4 20.0%
Remained basically unchanged 14 70.0%
Decreased somewhat 2 10.0%
Decreased considerably 0 0.0%
Total 20 100.0%

58. Over the past three months, how has demand for term funding with a maturity greater than 30 days of high-yield corporate bonds by your institution's clients changed?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 3 15.0%
Remained basically unchanged 17 85.0%
Decreased somewhat 0 0.0%
Decreased considerably 0 0.0%
Total 20 100.0%

59. Over the past three months, how have liquidity and functioning in the high-yield corporate bond market changed?

Number of Respondents Percent
Improved considerably 0 0.0%
Improved somewhat 4 20.0%
Remained basically unchanged 16 80.0%
Deteriorated somewhat 0 0.0%
Deteriorated considerably 0 0.0%
Total 20 100.0%


Equities (Including through Stock Loan)

60. Over the past three months, how have the terms under which equities are funded (including through stock loan) changed?

  1. Terms for average clients
    1. Maximum amount of funding
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 18 85.7%
      Eased Somewhat 3 14.3%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    2. Maximum maturity
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 1 4.8%
      Remained Basically Unchanged 17 81.0%
      Eased Somewhat 3 14.3%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    3. Haircuts
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 21 100.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    4. Collateral spreads over relevant benchmark (effective financing rates)
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 17 81.0%
      Eased Somewhat 4 19.0%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    5. Other
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 0 0.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 0 0.0%

  2. Terms for most-favored clients, as a consequence of breadth, duration and/or extent of relationship
    1. Maximum amount of funding
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 17 81.0%
      Eased Somewhat 3 14.3%
      Eased Considerably 1 4.8%
      Total 21 100.0%

    2. Maximum maturity
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 1 4.8%
      Remained Basically Unchanged 17 81.0%
      Eased Somewhat 3 14.3%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    3. Haircuts
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 21 100.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    4. Collateral spreads over relevant benchmark (effective financing rates)
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 1 4.8%
      Remained Basically Unchanged 16 76.2%
      Eased Somewhat 4 19.0%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    5. Other
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 0 0.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 0 0.0%

61. Over the past three months, how has demand for funding of equities (including through stock loan) by your institution's clients changed?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 10 47.6%
Remained basically unchanged 11 52.4%
Decreased somewhat 0 0.0%
Decreased considerably 0 0.0%
Total 21 100.0%


Agency Residential Mortgage-Backed Securities

62. Over the past three months, how have the terms under which agency RMBS are funded changed?

  1. Terms for average clients
    1. Maximum amount of funding
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 1 4.8%
      Remained Basically Unchanged 19 90.5%
      Eased Somewhat 1 4.8%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    2. Maximum maturity
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 19 90.5%
      Eased Somewhat 2 9.5%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    3. Haircuts
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 21 100.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    4. Collateral spreads over relevant benchmark (effective financing rates)
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 17 81.0%
      Eased Somewhat 3 14.3%
      Eased Considerably 1 4.8%
      Total 21 100.0%

    5. Other
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 0 0.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 0 0.0%

  2. Terms for most-favored clients, as a consequence of breadth, duration and/or extent of relationship
    1. Maximum amount of funding
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 1 4.8%
      Remained Basically Unchanged 19 90.5%
      Eased Somewhat 1 4.8%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    2. Maximum maturity
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 17 81.0%
      Eased Somewhat 4 19.0%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    3. Haircuts
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 21 100.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 21 100.0%

    4. Collateral spreads over relevant benchmark (effective financing rates)
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 17 81.0%
      Eased Somewhat 3 14.3%
      Eased Considerably 1 4.8%
      Total 21 100.0%

    5. Other
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 0 0.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 0 0.0%

63. Over the past three months, how has demand for funding of agency RMBS by your institution's clients changed?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 2 9.5%
Remained basically unchanged 18 85.7%
Decreased somewhat 1 4.8%
Decreased considerably 0 0.0%
Total 21 100.0%

64. Over the past three months, how has demand for term funding with a maturity greater than 30 days of agency RMBS by your institution's clients changed?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 2 9.1%
Remained basically unchanged 19 86.4%
Decreased somewhat 1 4.5%
Decreased considerably 0 0.0%
Total 22 100.0%

65. Over the past three months, how have liquidity and functioning in the agency RMBS market changed?

Number of Respondents Percent
Improved considerably 0 0.0%
Improved somewhat 2 9.1%
Remained basically unchanged 19 86.4%
Deteriorated somewhat 1 4.5%
Deteriorated considerably 0 0.0%
Total 22 100.0%


Non-Agency Residential Mortgage-Backed Securities

66. Over the past three months, how have the terms under which non-agency RMBS are funded changed?

  1. Terms for average clients
    1. Maximum amount of funding
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 14 87.5%
      Eased Somewhat 2 12.5%
      Eased Considerably 0 0.0%
      Total 16 100.0%

    2. Maximum maturity
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 15 93.8%
      Eased Somewhat 1 6.3%
      Eased Considerably 0 0.0%
      Total 16 100.0%

    3. Haircuts
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 11 68.8%
      Eased Somewhat 4 25.0%
      Eased Considerably 1 6.3%
      Total 16 100.0%

    4. Collateral spreads over relevant benchmark (effective financing rates)
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 10 62.5%
      Eased Somewhat 5 31.3%
      Eased Considerably 1 6.3%
      Total 16 100.0%

    5. Other
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 0 0.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 0 0.0%

  2. Terms for most-favored clients, as a consequence of breadth, duration and/or extent of relationship
    1. Maximum amount of funding
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 13 81.3%
      Eased Somewhat 3 18.8%
      Eased Considerably 0 0.0%
      Total 16 100.0%

    2. Maximum maturity
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 15 93.8%
      Eased Somewhat 1 6.3%
      Eased Considerably 0 0.0%
      Total 16 100.0%

    3. Haircuts
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 11 68.8%
      Eased Somewhat 4 25.0%
      Eased Considerably 1 6.3%
      Total 16 100.0%

    4. Collateral spreads over relevant benchmark (effective financing rates)
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 10 62.5%
      Eased Somewhat 5 31.3%
      Eased Considerably 1 6.3%
      Total 16 100.0%

    5. Other
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 0 0.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 0 0.0%

67. Over the past three months, how has demand for funding of non-agency RMBS by your institution's clients changed?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 5 31.3%
Remained basically unchanged 8 50.0%
Decreased somewhat 3 18.8%
Decreased considerably 0 0.0%
Total 16 100.0%

68. Over the past three months, how has demand for term funding with a maturity greater than 30 days of non-agency RMBS by your institution's clients changed?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 3 18.8%
Remained basically unchanged 12 75.0%
Decreased somewhat 1 6.3%
Decreased considerably 0 0.0%
Total 16 100.0%

69. Over the past three months, how have liquidity and functioning in the non-agency RMBS market changed?

Number of Respondents Percent
Improved considerably 1 6.3%
Improved somewhat 5 31.3%
Remained basically unchanged 10 62.5%
Deteriorated somewhat 0 0.0%
Deteriorated considerably 0 0.0%
Total 16 100.0%


Commercial Mortgage-Backed Securities

70. Over the past three months, how have the terms under which CMBS are funded changed?

  1. Terms for average clients
    1. Maximum amount of funding
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 15 100.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 15 100.0%

    2. Maximum maturity
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 15 100.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 15 100.0%

    3. Haircuts
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 12 80.0%
      Eased Somewhat 2 13.3%
      Eased Considerably 1 6.7%
      Total 15 100.0%

    4. Collateral spreads over relevant benchmark (effective financing rates)
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 11 73.3%
      Eased Somewhat 3 20.0%
      Eased Considerably 1 6.7%
      Total 15 100.0%

    5. Other
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 0 0.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 0 0.0%

  2. Terms for most-favored clients, as a consequence of breadth, duration and/or extent of relationship
    1. Maximum amount of funding
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 15 100.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 15 100.0%

    2. Maximum maturity
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 15 100.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 15 100.0%

    3. Haircuts
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 12 80.0%
      Eased Somewhat 2 13.3%
      Eased Considerably 1 6.7%
      Total 15 100.0%

    4. Collateral spreads over relevant benchmark (effective financing rates)
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 11 73.3%
      Eased Somewhat 3 20.0%
      Eased Considerably 1 6.7%
      Total 15 100.0%

    5. Other
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 0 0.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 0 0.0%

71. Over the past three months, how has demand for funding of CMBS by your institution's clients changed?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 0 0.0%
Remained basically unchanged 12 75.0%
Decreased somewhat 3 18.8%
Decreased considerably 1 6.3%
Total 16 100.0%

72. Over the past three months, how has demand for term funding with a maturity greater than 30 days of CMBS by your institution's clients changed?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 0 0.0%
Remained basically unchanged 15 93.8%
Decreased somewhat 0 0.0%
Decreased considerably 1 6.3%
Total 16 100.0%

73. Over the past three months, how have liquidity and functioning in the CMBS market changed?

Number of Respondents Percent
Improved considerably 0 0.0%
Improved somewhat 5 31.3%
Remained basically unchanged 9 56.3%
Deteriorated somewhat 1 6.3%
Deteriorated considerably 1 6.3%
Total 16 100.0%


Consumer Asset-Backed Securities

74. Over the past three months, how have the terms under which consumer ABS (for example, backed by credit card receivables or auto loans) are funded changed?

  1. Terms for average clients
    1. Maximum amount of funding
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 1 9.1%
      Remained Basically Unchanged 10 90.9%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 11 100.0%

    2. Maximum maturity
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 1 9.1%
      Remained Basically Unchanged 10 90.9%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 11 100.0%

    3. Haircuts
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 1 9.1%
      Remained Basically Unchanged 8 72.7%
      Eased Somewhat 1 9.1%
      Eased Considerably 1 9.1%
      Total 11 100.0%

    4. Collateral spreads over relevant benchmark (effective financing rates)
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 1 9.1%
      Remained Basically Unchanged 7 63.6%
      Eased Somewhat 2 18.2%
      Eased Considerably 1 9.1%
      Total 11 100.0%

    5. Other
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 0 0.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 0 0.0%

  2. Terms for most-favored clients, as a consequence of breadth, duration and/or extent of relationship
    1. Maximum amount of funding
      Number of Respondents Percent
      Tightened Considerably 1 8.3%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 11 91.7%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 12 100.0%

    2. Maximum maturity
      Number of Respondents Percent
      Tightened Considerably 1 8.3%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 11 91.7%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 12 100.0%

    3. Haircuts
      Number of Respondents Percent
      Tightened Considerably 1 8.3%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 9 75.0%
      Eased Somewhat 1 8.3%
      Eased Considerably 1 8.3%
      Total 12 100.0%

    4. Collateral spreads over relevant benchmark (effective financing rates)
      Number of Respondents Percent
      Tightened Considerably 1 8.3%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 8 66.7%
      Eased Somewhat 2 16.7%
      Eased Considerably 1 8.3%
      Total 12 100.0%

    5. Other
      Number of Respondents Percent
      Tightened Considerably 0 0.0%
      Tightened Somewhat 0 0.0%
      Remained Basically Unchanged 0 0.0%
      Eased Somewhat 0 0.0%
      Eased Considerably 0 0.0%
      Total 0 0.0%

75. Over the past three months, how has demand for funding of consumer ABS by your institution's clients changed?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 1 8.3%
Remained basically unchanged 9 75.0%
Decreased somewhat 2 16.7%
Decreased considerably 0 0.0%
Total 12 100.0%

76. Over the past three months, how has demand for term funding with a maturity greater than 30 days of consumer ABS by your institution's clients changed?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 1 8.3%
Remained basically unchanged 11 91.7%
Decreased somewhat 0 0.0%
Decreased considerably 0 0.0%
Total 12 100.0%

77. Over the past three months, how have liquidity and functioning in the consumer ABS market changed?

Number of Respondents Percent
Improved considerably 0 0.0%
Improved somewhat 2 15.4%
Remained basically unchanged 11 84.6%
Deteriorated somewhat 0 0.0%
Deteriorated considerably 0 0.0%
Total 13 100.0%


Mark and Collateral Disputes

78. Over the past three months, how has the volume of mark and collateral disputes relating to lending against each of the following collateral types changed?

  1. High-grade corporate bonds
    Number of Respondents Percent
    Increased Considerably 1 5.0%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 18 90.0%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 5.0%
    Total 20 100.0%

  2. High-yield corporate bonds
    Number of Respondents Percent
    Increased Considerably 1 5.6%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 17 94.4%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 0 0.0%
    Total 18 100.0%

  3. Equities
    Number of Respondents Percent
    Increased Considerably 1 5.0%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 18 90.0%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 5.0%
    Total 20 100.0%

  4. Agency RMBS
    Number of Respondents Percent
    Increased Considerably 1 4.8%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 19 90.5%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 4.8%
    Total 21 100.0%

  5. Non-agency RMBS
    Number of Respondents Percent
    Increased Considerably 0 0.0%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 15 88.2%
    Decreased Somewhat 1 5.9%
    Decreased Considerably 1 5.9%
    Total 17 100.0%

  6. CMBS
    Number of Respondents Percent
    Increased Considerably 0 0.0%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 15 93.8%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 6.3%
    Total 16 100.0%

  7. Consumer ABS
    Number of Respondents Percent
    Increased Considerably 1 7.1%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 12 85.7%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 7.1%
    Total 14 100.0%

79. Over the past three months, how has the duration and persistence of mark and collateral disputes relating to lending against each of the following collateral types changed?

  1. High-grade corporate bonds
    Number of Respondents Percent
    Increased Considerably 1 5.0%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 18 90.0%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 5.0%
    Total 20 100.0%

  2. High-yield corporate bonds
    Number of Respondents Percent
    Increased Considerably 1 5.3%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 17 89.5%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 5.3%
    Total 19 100.0%

  3. Equities
    Number of Respondents Percent
    Increased Considerably 1 5.0%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 18 90.0%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 5.0%
    Total 20 100.0%

  4. Agency RMBS
    Number of Respondents Percent
    Increased Considerably 1 4.8%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 19 90.5%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 4.8%
    Total 21 100.0%

  5. Non-agency RMBS
    Number of Respondents Percent
    Increased Considerably 0 0.0%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 16 94.1%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 5.9%
    Total 17 100.0%

  6. CMBS
    Number of Respondents Percent
    Increased Considerably 0 0.0%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 15 93.8%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 6.3%
    Total 16 100.0%

  7. Consumer ABS
    Number of Respondents Percent
    Increased Considerably 1 7.1%
    Increased Somewhat 0 0.0%
    Remained Basically Unchanged 12 85.7%
    Decreased Somewhat 0 0.0%
    Decreased Considerably 1 7.1%
    Total 14 100.0%


Optional Question

Question 80 requests feedback on any other issues you judge to be important relating to credit terms applicable to securities financing transactions and OTC derivatives contracts.


Special Questions on uncleared swaps and new margin rules

Title VII of the Dodd-Frank Act requires financial regulators to establish new minimum margin requirements for OTC derivatives that are not centrally cleared (uncleared swaps). In 2015, the U.S. prudential regulators (PRs) and the Commodity Futures Trading Commission (CFTC) adopted final rules that began to be implemented in September 2016.1 Under the new rules, parties involved in uncleared swap transactions must exchange initial margin (IM) when the trade is established and provide variation margin (VM) to each other on a daily basis over the life of the derivative contract.2
Questions 82 through 84 ask about how the overall use and pricing of uncleared swaps that are affected by the new rules have changed since September 2016. Questions 85 through 92 ask about your firm's and clients' experiences in adopting the new VM requirements.

81. Does your firm make markets in uncleared swaps?

Number of Respondents Percent
Yes 18 78.3%
No 5 21.7%
Total 23 100.0%

82. How has your clients' transaction volume in uncleared swaps that are affected by the new rules changed since September 2016?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 0 0.0%
Remained basically unchanged 16 88.9%
Decreased somewhat 2 11.1%
Decreased considerably 0 0.0%
Total 18 100.0%

83. How has your firm's transaction volume in uncleared swaps that are affected by the new rules changed since September 2016?

Number of Respondents Percent
Increased considerably 0 0.0%
Increased somewhat 0 0.0%
Remained basically unchanged 14 77.8%
Decreased somewhat 4 22.2%
Decreased considerably 0 0.0%
Total 18 100.0%

84. How have prices that your firm quotes to your clients for uncleared swaps that are affected by the new rules changed since September 2016?

Number of Respondents Percent
Considerably more expensive 0 0.0%
Somewhat more expensive 1 5.6%
Remained basically unchanged 17 94.4%
Somewhat cheaper 0 0.0%
Considerably cheaper 0 0.0%
Total 18 100.0%

85. For the transactions that are affected by the new rules, approximately how has the fraction of your clients' uncleared swap transactions that are collateralized by VM (as measured by gross notional amount outstanding) changed since September 2016?

Number of Respondents Percent
Increased more than 50 percentage points 1 5.6%
Increased 25 to 50 percentage points 0 0.0%
Increased 0 to 25 percentage points 4 22.2%
Remained basically unchanged 11 61.1%
Decreased 0 to 25 percentage points 2 11.1%
Decreased 25 to 50 percentage points 0 0.0%
Decreased more than 50 percentage points 0 0.0%
Total 18 100.0%

86. Which set of clients is your firm currently less likely to be collecting from and posting to daily VM?

  1. Dealers and other financial intermediaries
    Number of Respondents Percent
    Least likely 0 0.0%
    2nd least likely 0 0.0%
    3rd least likely 0 0.0%
    Total 0 0.0%

  2. Hedge funds
    Number of Respondents Percent
    Least likely 0 0.0%
    2nd least likely 0 0.0%
    3rd least likely 0 0.0%
    Total 0 0.0%

  3. Trading REITs
    Number of Respondents Percent
    Least likely 1 50.0%
    2nd least likely 0 0.0%
    3rd least likely 1 50.0%
    Total 2 100.0%

  4. Mutual funds, exchange-traded funds, pension plans, and endowments
    Number of Respondents Percent
    Least likely 3 75.0%
    2nd least likely 1 25.0%
    3rd least likely 0 0.0%
    Total 4 100.0%

  5. Insurance companies
    Number of Respondents Percent
    Least likely 0 0.0%
    2nd least likely 0 0.0%
    3rd least likely 0 0.0%
    Total 0 0.0%

  6. Separately managed accounts established with investment advisers
    Number of Respondents Percent
    Least likely 2 50.0%
    2nd least likely 2 50.0%
    3rd least likely 0 0.0%
    Total 4 100.0%

  7. Other (please specify)
    Number of Respondents Percent
    Least likely 6 85.7%
    2nd least likely 0 0.0%
    3rd least likely 1 14.3%
    Total 7 100.0%

  8. None
    Number of Respondents Percent
    Least likely 6 100.0%
    2nd least likely 0 0.0%
    3rd least likely 0 0.0%
    Total 6 100.0%

87. Regarding client types for which your firm does not currently collect or post VM but would be required to do so under the new rules (as reflected in your response to question 86), what are the most important reasons your firm does not collect or post VM?

  1. Do not have the infrastructure set up yet to receive and post margins daily with the client
    Number of Respondents Percent
    Most important 0 0.0%
    2nd Most important 1 100.0%
    3rd Most important 0 0.0%
    Total 1 100.0%

  2. Difficulties in sourcing eligible collateral from the clients' side
    Number of Respondents Percent
    Most important 0 0.0%
    2nd Most important 1 50.0%
    3rd Most important 1 50.0%
    Total 2 100.0%

  3. Difficulties in sourcing eligible collateral from your firm's side
    Number of Respondents Percent
    Most important 0 0.0%
    2nd Most important 0 0.0%
    3rd Most important 0 0.0%
    Total 0 0.0%

  4. Have not yet established or updated necessary credit support annex (CSA) to cover daily VM
    Number of Respondents Percent
    Most important 4 66.7%
    2nd Most important 1 16.7%
    3rd Most important 1 16.7%
    Total 6 100.0%

  5. Lack of segregation arrangements in place
    Number of Respondents Percent
    Most important 2 66.7%
    2nd Most important 1 33.3%
    3rd Most important 0 0.0%
    Total 3 100.0%

  6. Other (please specify)
    Number of Respondents Percent
    Most important 6 85.7%
    2nd Most important 1 14.3%
    3rd Most important 0 0.0%
    Total 7 100.0%

88. For which asset classes is your firm currently less likely to collect and post daily VM?

  1. Commodity derivatives
    Number of Respondents Percent
    Least likely 3 75.0%
    2nd least likely 1 25.0%
    3rd least likely 0 0.0%
    Total 4 100.0%

  2. Credit derivatives
    Number of Respondents Percent
    Least likely 1 100.0%
    2nd least likely 0 0.0%
    3rd least likely 0 0.0%
    Total 1 100.0%

  3. Equity derivatives
    Number of Respondents Percent
    Least likely 0 0.0%
    2nd least likely 1 50.0%
    3rd least likely 1 50.0%
    Total 2 100.0%

  4. Interest rate derivatives
    Number of Respondents Percent
    Least likely 0 0.0%
    2nd least likely 2 100.0%
    3rd least likely 0 0.0%
    Total 2 100.0%

  5. Foreign exchange derivatives (excluding physically settled FX forwards and swaps)
    Number of Respondents Percent
    Least likely 5 71.4%
    2nd least likely 0 0.0%
    3rd least likely 2 28.6%
    Total 7 100.0%

  6. None
    Number of Respondents Percent
    Least likely 9 100.0%
    2nd least likely 0 0.0%
    3rd least likely 0 0.0%
    Total 9 100.0%

89. Regarding asset classes for which your firm is currently less likely to collect or post VM but would be required to under the new rules (as reflected in your response to question 88), what are the most important reasons your firm does not collect or post VM?

  1. Operational readiness (for instance, margins were typically not collected for these asset classes before, so it takes time and effort to establish appropriate infrastructure and legal arrangements)
    Number of Respondents Percent
    Most important 4 80.0%
    2nd most important 0 0.0%
    3rd most important 1 20.0%
    Total 5 100.0%

  2. Insufficient transaction price data
    Number of Respondents Percent
    Most important 0 0.0%
    2nd most important 0 0.0%
    3rd most important 0 0.0%
    Total 0 0.0%

  3. Robust pricing models are not available
    Number of Respondents Percent
    Most important 0 0.0%
    2nd most important 0 0.0%
    3rd most important 0 0.0%
    Total 0 0.0%

  4. Disagreements with clients on valuation frameworks or methodologies
    Number of Respondents Percent
    Most important 0 0.0%
    2nd most important 1 100.0%
    3rd most important 0 0.0%
    Total 1 100.0%

  5. Other (please specify)
    Number of Respondents Percent
    Most important 5 100.0%
    2nd most important 0 0.0%
    3rd most important 0 0.0%
    Total 5 100.0%

90. Regarding the clients for which you have the necessary agreements and documentation in place, to what extent is International Swaps and Derivatives Association (ISDA) 2016 Variation Margin Protocol being utilized?

Number of Respondents Percent
0 to 25 percent 13 72.2%
25 to 50 percent 2 11.1%
50 to 75 percent 1 5.6%
75 to 100 percent 2 11.1%
Total 18 100.0%

91. How has the volume of mark and collateral disputes on VM changed since September 2016?

Number of Respondents Percent
Increased considerably 1 5.6%
Increased somewhat 6 33.3%
Remained basically unchanged 11 61.1%
Decreased somewhat 0 0.0%
Decreased considerably 0 0.0%
Total 18 100.0%

92. On average, how long does it take to resolve a mark and collateral dispute on VM?

Number of Respondents Percent
Two days or fewer 6 33.3%
More than two days but less than a week 11 61.1%
More than a week but less than a month 1 5.6%
More than a month 0 0.0%
Total 18 100.0%

1. Prudential regulators refer to the Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Farm Credit Administration, and the Federal Housing Finance Agency. Return to text

2. The rules apply to uncleared swap transactions between "covered swap entities" or between a "covered swap entity" and a financial end user. The rules apply to all asset classes except for physically settled FX forwards and swaps.
IM is required to be phased in on various dates over four years, from September 1, 2016, for a group of large swap dealers and major market participants to September 1, 2020, for the least active financial institutions covered under the rules. The VM requirements take effect within a short phase-in period, from September 1, 2016, for swap dealers and major participants to March 1, 2017, for other financial institutions. In February 2017, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the CFTC provided regulatory guidance for counterparties to make good faith efforts to comply with the final rule in a timely manner, but no later than September 1, 2017, if no significant credit and market risk exposures are expected. Return to text

Last Update: June 22, 2017