Tax Alert on Recently Announced Relief on Money Market Fund Floating NAV Wash Sale, Form 1099-B and Gain/Loss Calculations

Stevie ConlonGuest Contributor:  Stevie D. Conlon, Senior Director and Tax Counsel, Wolters Kluwer Financial Services

The author thanks John Kareken and Anna Vayser of Wolters Kluwer Financial Services for their assistance.

There were several important announcements made last month by the IRS that provide critical income tax relief for investments in money market funds under new Securities and Exchange Commission (SEC) rules.

Overview

On July 23, 2014, the IRS issued proposed regulations that expand the existing exclusion from gross proceeds reporting and cost basis reporting on Form 1099-B for “floating NAV” money market funds (MMFs) under new SEC rules for certain investment companies.

The IRS also issued proposed regulations providing a taxpayer elective simplified net gain/loss method of reporting gains and losses from floating NAV MMFs. Under the elective reporting method, because no loss is determined for any particular redemption of shares, the IRS has stated that the wash sale rule does not apply. For taxpayers that do not elect the simplified reporting method, the IRS also issued a revenue procedure providing that the wash sale rule does not apply to sales of floating NAV MMF shares. Although this guidance was issued in proposed rather than final form, it is effective immediately.

Explanation

On July 24, 2014, the SEC voted, as noted in a Treasury Department fact sheet of the same date, “to require certain money market funds (MMFs) to price shares in a manner that more accurately reflects the market value of the funds’ underlying portfolios.” These certain MMFs can no longer rely on special SEC exemptions that allowed them to maintain a stable net asset value (NAV). For these funds, the share price will float and the funds will be known as floating-NAV MMFs.

The stable share NAV of money market funds, typically $1 per share, came under pressure in the recent economic crisis, as fund outflows demonstrated the real risk of funds breaking the buck, or being unable to maintain the stable $1 per share NAV.

SEC Rule 2a-7 contains detailed rules for MMFs and the type and quality of assets which the fund is permitted to hold. One requirement is for the fund’s use of the amortized cost method of valuation that calculates NAV by valuing the fund’s portfolio securities at their acquisition cost “as adjusted for amortization of premium or accretion of discount rather than at their value based on current market factors.” Together with this requirement, Rule 2a-7 requires the use of the penny rounding method of pricing – “the method of computing an investment company’s price per share for purposes of distribution, redemption and repurchase whereby the current net asset value per share is rounded to the nearest one percent.” These requirements permit the fund to maintain a stable net asset value, or stable price, per share.

SEC Amendments

The amendments to SEC Rule 2a-7 require certain funds to use market valuation of their portfolio securities for distribution, redemption and repurchase, thus causing the share price to float rather than remain stable at the typical $1.

With a floating NAV, institutional prime money market funds (including institutional municipal money market funds) are required to value their portfolio securities using market-based factors and sell and redeem shares based on a floating NAV. These funds no longer will be allowed to use the special pricing and valuation conventions that currently permit them to maintain a constant share price of $1.00. With liquidity fees and redemption gates, money market fund boards have the ability to impose fees and gates during periods of stress. The final rules also include enhanced diversification, disclosure and stress testing requirements, as well as updated reporting by money market funds and private funds that operate like money market funds.

The final rules provide a two-year transition period to enable both funds and investors time to fully adjust their systems, operations and investing practices.

Treasury and IRS Guidance

In a coordinated action with the SEC last month, the Treasury and IRS issued proposed guidance in the form of proposed regulations (REG-107012-14, published in July 28 Federal Register) that provide a “simplified, aggregate annual method of tax accounting for these gains and losses, simplifying the tax treatment and promoting compliance.” The Treasury Department fact sheet notes that the guidance is “proposed rather than final to provide the public an opportunity for comment. Nevertheless, shareholders in floating NAV MMFs can now rely on these proposed regulations to begin to use the simplified method.”

Simplified accounting

The proposed IRS rules permit a simplified method of accounting (the NAV method) allowing shareholders to aggregate transactions and measure net gain/ loss, using information routinely provided by the funds. Net gain/loss is to be determined by the increase or decrease in share value for a certain period, such as the tax year minus the net investment in the shares, i.e. purchases minus sales for the period.

Wash sale relief

Under IRS Code Sec. 1091, a wash sale occurs when a shareholder sells a security at a loss, and within 30 days before or after the sale, acquires a substantially identical stock or security. The new floating rate funds would cause a shareholder to run afoul of the wash sale rule because the floating rate would generate losses on sales of shares that would be disallowed and cause enormous complications for taxpayers making many purchases and sales of money market shares, including, as the IRS notes, purchases made as a result of sweep arrangements and reinvestments of monthly distributions. As the new IRS proposed rules and a new revenue procedure explain, the wash sale rule would not be triggered by losses that are netted by using the simplified NAV method of reporting. To address the wash sale situation for those that do not use the NAV method, a new and final revenue procedure, Rev. Proc. 2014-45, was issued by the Treasury and IRS. It provides that a redemption of a money market fund share of a 1940 Act investment company shall not be treated as part of a wash sale under these circumstances: (1) The investment company is regulated as an MMF under Rule 2a-7 and holds itself out to investors as an MMF; (2) At the time of the redemption, the investment company is a floating-NAV MMF.

1099-B exemption

The proposed IRS rules exempt the new floating-NAV funds from gross proceeds, basis and holding period reporting under IRS Code Sec. 6045. Stable value money market funds were excluded from such reporting under Treas. Reg. 1.6045-1(c)(3)(vi). This rule states that “no return of information is required with respect to a sale of an interest in a regulated investment company that can hold itself out as a money market fund under Rule 2a-7 under the Investment Company Act of 1940 that computes its current price per share for purposes of distributions, redemptions, and purchases so as to stabilize the price per share at a constant amount that approximates its issue price or the price at which it was originally sold to the public”. The proposed rules eliminate the reference to stable value funds so that the exemption applies to all Rule 2a-7 funds.

The revenue procedure wash sale relief for redemptions is effective for redemption made on or after the effective date of the SEC rules discussed above, expected 60 days after Federal Register publication. The proposed regulations on the NAV method, although not final, can be relied on by shareholders of floating-NAV money market funds for taxable years ending on or after July 28, 2014 and beginning before publication of final regulations.

Stevie Conlon will be a featured speaker at the upcoming CAPCon New York conference on October 16, 2014.   Stevie will be speaking on the “New Corporate Action Burdens Under FATCA” with Dana Pasricha, Vice President at Brown Brothers Harriman.

They will be discussing how the new Foreign Account Tax Compliance Act (FATCA) rules require tax analysis of corporate actions affecting investments in debt securities that can affect U.S. tax obligations that firms must withhold on payments to clients. The new rules for grandfathered FATCA debt obligations and determining when corporate actions adversely impact favored grandfathered status will be explained. The operational and compliance challenges under these new requirements will also be discussed.

 

 

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Software as a (dis) Service – Going in with Your Eyes Wide Open

Jane StabileGuest Contributor: Jane Stabile, President, IMP Consulting, Boston, MA

The asset management business has never been more competitive, and CFOs are under tremendous pressure to keep their firms lean. As CFOs seek solutions to keep the headcount down, the argument for Software as a Service (SaaS) has become particularly appealing. SaaS solutions promise to help your firm focus on investment management and “get out of the software business” by having the vendor run and maintain your systems. The argument is compelling; the vendors will assure you that they can support a high-quality, mission critical service as well or better than your in-house technology group can, and at a much lower cost. If you are looking to make the leap, a SaaS system may do exactly that. If you suspect it might not, how do you evaluate the shortcomings and what can you do about them?

In my experience, there are three critical areas to evaluate:

  • Fit and coverage
  • Flexibility
  • Cost Containment

Fit and Coverage: Most SaaS offerings are not extensible, so you will not be able to manipulate tables or run custom applications against their databases.   If there are significant gaps in functionality, you’ll have to live with them, so make sure the solution fits your business processes. Part of the attraction of the SaaS product may be that the data is included, and the TCO (total cost of ownership) analysis may include a big cost savings over sourcing that data separately. However, some vendors require separate subscriptions to underlying data that you may already have, so those costs will remain. Conversely, you may discover that the SaaS product’s data has some gaps in coverage that can impact your firm’s ability to model portfolios or monitor compliance. Before committing to the deal, take a deep dive into the data model to ensure that the quality and coverage of the data matches the needs of your firm.

Flexibility: Vendors have no incentive to make it easy for you to switch to a competitor, and it can be difficult to decouple systems when you don’t keep them in-house. If your portfolio managers add new strategies or expand into asset classes that are not native to the system your firm has chosen, you may find yourself doing extensive work-arounds to accommodate the change, or hitting a brick wall. For example, forcing complex derivatives onto a system that specializes in corporate bonds or vanilla swaps, may be impossible, and you may end up supporting macro-laden spreadsheets or creating additional workloads for your middle or back-office to maintain accurate holdings. Developing a thorough understanding of the level of standardization that your vendor employs is the key to evaluating your true costs.

Cost Containment:   Are there any penalties of not going live by a certain time, or when the vendor’s “production” license kicks in? Carefully scrutinize the vendor contract and ask for it in writing if it isn’t clear—does the license take effect upon “go-live,” or parallel? What if the timeline is delayed; does the vendor take responsibility or does your firm get stuck with the additional cost? On a recent project, I found myself working with my client to QA the vendor’s configuration and document the problems, just to help the firm avoid the late fees the vendor was attempting to charge. In fact, you may want to add some cost assumptions into your implementation and maintenance calculation to accommodate the QA you may need to do when new releases or patches are issued. Some vendors will allow you to opt out, but some will not, or allow so little time between the announcement of the release and its deployment that it may be impractical to do. Others may allow your firm to have more control, but the time it takes to test and implement a vendor upgrade or patch that may not help your firm could be a costly and time consuming endeavor. Finally, vendors will want to keep the number of users included in a contract to a minimum for performance reasons and to keep their costs down on the hosting side. Consider these costs as your firm grows and needs to add additional users.

Bottom Line:   There are now SaaS products available that can serve mission-critical areas of your firm’s infrastructure—from trading and compliances systems to all areas of the front, middle, and back office. If something goes wrong on the vendor side or you can’t get the attention you need when there is an issue, it will be your firm’s reputation on the line. Ultimately, the risks may be manageable and the benefits substantial, but it is important to go in with your eyes wide open.

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Financial Trading Infrastructure: The Era of Cloud 2.0

Jacob Loveless and Howard Lutnick at Cantor Fitzgerald, NYC 12-20-12Guest Contributor: Jacob Loveless, CEO, Lucera Financial Infrastructures

The freedom to try new things
The equity downturn has fueled a trend in multi-asset trading that is prompting firms to test new strategies. They realize they can no longer merely trade or price a single asset class. To compete, they must have asset diversification and multi-asset trading strategies– but many lack the freedom, infrastructure scalability and resources to do so.

Historically, a firm would have to wait weeks or months to arrange the infrastructure components required to procure, deploy and test a trading strategy in a new asset class or location. This lengthy process slows time-to-market and creates a large resource and monetary investment up-front – a barrier to innovation.

Managed trading services give these firms the ability to quickly deploy secure, high-performance systems, lower total cost of ownership (TCO), predict and scale monthly expenditure and create new possibilities for trade innovation, strategy development and alpha generation. That means financial trading firms can test applications and new ideas in close to real-time, while predicting and controlling costs.

For these reasons, Aite Group projects that global spend on managed services will increase from $500 million in 2012 to $620 million by 2015, and Tabb Group estimates that by 2016 adoption of managed services infrastructure across companies will hit 50%. With efficiency and scalability now under control, organizations are looking to their infrastructure to solve greater problems.

A big red button scenario
High-profile trading freezes and glitches have drawn considerable attention to the industry’s need for a “kill” switch or “big red button.” These could be used in a situation where dangerous order flow needs to be halted to minimize market impact. Regulators agree this could minimize risk but hotly debate who should be able to push that “big red button” and how much of the infrastructure it should shut down when pushed.

The difficulty with the proposed “kill switch” is that it would shut the firm off from the entire market by preventing the flow of information in and out of the company. While in the short-term it would prevent that company from sending potentially compromised orders out into the market, it also handicaps the firm from receiving information from the market that could help identify and reconcile the issue.

Take the centralized limit order book where all participants push data as an example. If something goes wrong and the order book is affected, the firm has to bring the whole system down. But what about a scenario when only one server is impacted? What effect would it have if only the compromised portion of the infrastructure was taken offline? Or better yet, what if an exchange could turn off one market participant from sending orders but still allow them to receive data in order to quickly reconcile its issue without impacting the rest of the market?

These scenarios demonstrate the importance of being able to segment infrastructure into zones – a technique that is becoming critical to deliver operational advantage. The ideal big red button scenario would allow the system to react quickly to protect the business and the market and only turn off the piece of the infrastructure experiencing failure. In the event of a problem in a software-defined network, a company can self-select to shut down a compromised zone, remaining fully operational while the issue is addressed internally. This zoning technique guards both the participant, and the market.

A better cloud model: Cloud 2.0
The traditional multi-tenant cloud model has not been able to meet the latency demands of trading applications, marking a considerable barrier for cloud-based infrastructure. It also does not allow for data collocation. Companies now have to ship data to different data centers and pull it back up over a virtual private network, which increases costs because of the shared storage and bandwidth. Using a single tenant system allows for better performance and is more cost effective.

The move to Cloud 2.0 will not only speed time-to-market, promote innovation and remove cost pressures associated with traditional infrastructure, it can give companies the operational advantage they need to compete in today’s complex financial markets. Firms that embrace Cloud 2.0 will be empowered to utilize new trading strategies and enter new markets with greater control, predictability and scalability around their costs. Disaster scenarios can be more easily contained by understanding how to use a software defined network and zoning to more intelligently respond to infrastructure challenges that might traditionally cripple a company or impact the market. With latency no longer the most important differentiator for firms, the era of Cloud 2.0 will allow firms to meet complex infrastructure requirements in a high-performance, secure environment that can continuously evolve to solve the next big challenges in the market.

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Why Financial Services Brands Aren’t Equipped for Social Media Risk & Compliance

Devin_HeadshotGuest Contributor: Devin Redmond, Nexgate CEO and Co-founder

No longer are financial brands and organizations able to focus solely on storefronts, email aliases and toll free numbers for customer engagement and support. Nowadays, a brand must engage customers 24/7 in social media. However, as we have seen with the rise in social media spam, the increase in social fraud, the continuing social account hacks and the ever increasing regulatory focus on social media, financial services’ social media programs bear the broadest set of risks and compliance challenges.

In fact, each of the specific financial services sub-verticals including retail banking, insurance, wealth management, credit cards, etc., all tend to have two to three major categories of social media programs including centralized brand programs, advisor / agent programs and social customer care programs. Unfortunately, they may only be partially equipped to handle risk and compliance for just one of their social programs.

Brand programs face regulations but also tend to be exposed around fraudulent accounts, account hacks and social media spam. Social care programs have to worry about those same issues as well as regulated and sensitive data handling like PII and PCI on top of violations of FFIEC Regulation Z and DD or FINRA Customer Complaint Risks regulations.  Advisor and agent programs have to tackle industry regulations like FINRA, FFIEC, FTC and SEC, along with corporate standards such as using approved employee bio data, approved publishing tool workflow and keeping the agent or advisor account protected.

Here are several best practices to help financial services organizations address the broad set of risk and compliance challenges they face in social media:

  1. Define Organization Responsibilities & Policies: Establish a cross-departmental working group defining and executing on who is responsible for creating policies, enforcing them and responding to incidents across social programs.
  2. Learn Compliance Context: Social marketers, brokers or agents and IT teams are not inherently compliance experts. Therefore, they must be trained by internal and external compliance experts, so they are informed as to the context of the regulations.
  3. Protect Social Accounts: Maintain access control on social pages, profiles, and accounts by protecting passwords, restricting what tools can publish on the account and monitoring the account to detect and stop account hacks.
  4. Enforce approved tool use: Active monitoring, enforcement and reporting, which identify the right tool that was used to publish, should be in place as a key to establishing workflow, passing audits and demonstrating policy enforcement.
  5. Don’t rely on keyword detection: Less accurate keyword dictionaries and manual workflows don’t scale. Technology that understands the content and context should be used to automate detection, handling and improving retention and eDiscovery search for many compliance, legal and related content violations.

With financial services brands committing more and more resources to social media, the urgency to protect that investment grows with it each day. Without a serious plan and investment in this broader set of social risk and compliance areas, financial services organizations will struggle to efficiently, effectively and safely scale their social programs.

 

Hear more on this topic and more on social media and compliance in financial services at SMAC New York on September 18th.  Check out the speaker line-up and all event details online here.

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The Power of Feedback Loops: Fostering an Environment that Supports a Healthy ERM Program

Steve_TaylorGuest Contributor: Stephen Taylor, Senior Market Manager, U.S. Enterprise Risk & Compliance, Wolters Kluwer Financial Services

In the wake of the financial crisis, strategies for managing enterprise risk have taken center stage of organizational decision making and many institutions have revamped their entire approach to understanding the nature of the risks they face and how to mitigate against them. A sophisticated approach to managing risk is a continual process of systematically assessing, measuring, monitoring and managing risks in an organization. Moreover, it ensures that the “big picture” is not lost to the daily demands of running a business.

One of the best ways for an organization to accomplish this is through establishing a risk management “feedback loop” to continually assess whether the assumed risk is reasonable and appropriate, or whether the situation should be reassessed. Feedback loops are effective tools for positively impacting and changing risk behavior, since they allow the institutions to address minor issues at the lowest level and empower business lines to self-correct—while keeping the focus of the executive team on more high-level business concerns.

Increasingly, boards and senior executives are looking to develop effective key risk indicators (KRIs) to drive success in their ERM process and improve the execution of the organization’s strategy while pushing responsibility and accountability into the front-line business units. These KRIs serve as a type of feedback loop, providing organizations with an early warning sign of increasing risk exposure in various areas of the enterprise.

Getting visibility into specific regulatory rule changes alone isn’t enough, for example. Firms have to be able to pull this information through the business and clearly demonstrate to shareholders, investors and regulators that relevant action has been taken. The ultimate verification is that controls have been put in place to mitigate any potential risk and that these controls have been positively tested.

This is what we think of as a “virtuous circle” of effective risk management and it is critical to success. In order for it to work, however, there has to be the right “tone at the top.”

For a true risk management culture to take hold within a financial services organization, there must be a pervasive philosophy communicated from top management down through the organization and embraced by staff. Every employee must understand the organization’s risk appetite and where the “edges of the envelope” are for each business line, product and geographic unit. Front-line managers must buy into the risk appetite, and operate under it, for the risk culture to be effectively implemented.

As a rule, KRIs should be monitored closer to the “front” than in the higher reaches of management. It is important to establish a good working relationship between the risk management function and the business units, so that employees view risk managers as making a positive contribution—rather than just someone who enforces the rules. Instead of relying on the risk function to manage risk, financial institutions need to hold accountable and empower the front-line managers to make decisions in a more risk-aware way.

The best ERM practice has business managers, profit centers, business units and functional heads assume full responsibility and accountability for the risks they take.

Senior management and boards of directors do not need to know, nor are they necessarily in a position to fully appreciate, all KRIs employed within the organization, but they should be expected to understand and be kept updated on KRIs related to the organization’s top risk exposures.

Having the right culture for compliance is crucial and this can be improved if it’s demonstrated that effective compliance is not to be seen as an ineffective cost center, but as a way of running an ethical business which not only can improve the strategic direction of the organization but can improve the firm’s reputation within the market.

 

Learn more from Wolters Kluwer on October 16th, when they sponsor FTF’s CAPCon New York conference. Stevie D. Conlon, Senior Director and Tax Counsel for Wolters Kluwer will lead a discussion on new corporate action burdens under FATCA.  View the full events agenda online here.

 

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Insurance and Innovation: Are you In or Out?

Sheryl Brown headshot resized

Guest Contributor: Sheryl Brown, Social Media Coordinator, Ash Brokerage

So when you say “financial services” or “insurance” do you immediately think of the word “innovation”? Um … likely not. (Hint: We are not the cool kids on the bus. I hate to break it to you this way.) Why is that? Why, as a group of professionals, are we so far behind in being radically different? What are we scared will happen?

I recently polled all of my friends on Facebook (Hey, I have 500 friends on Facebook, so the poll has a little depth to it … #TongueInCheek). I simply asked them what came to mind when they heard “financial services” and “insurance.” Some of the responses were:

- Medical needs
– Death
– Pushy sales people

Oh my. That’s not very innovative stuff, is it? But wait … there’s more.

How do we describe what we do? What kinds of words SHOULD we be using with our family, friends, clients and businesses so we can change these thoughts? Who should we be talking to about these things?

I believe we need to create a fundamental shift by using the term “community” instead of “industry.” Industries produce widgets. What exactly are we producing? Yeah, yeah … you could say the policy is the widget, but it’s not the same.

Jean Vanier is quoted as saying, “Every human activity can be put at the service of the divine and of love. We should all exercise our gift to build community.” Think about that for a moment. We are a relationship-based business. That’s what communities are built on … relationships. As a community of financial professionals, we provide peace of mind to our family, friends, clients and businesses. I don’t think I remember anyone saying this about coffee, tennis rackets or pallets, do you? Those are widgets from industries … we are a community.

When you sit down with someone, are you still using outdated words like protection (blech), policy (you mean there are rules?) and premium (I get the best!)? Well stop that now! If you think our family, friends, clients and businesses are hearing these words in the way we THINK we are describing them, you’re dead wrong. I challenge you to read Maria Ferrante-Schepis’ book, “Flirting with the Uninterested” from Maddock Douglas and see what you think. WARNING: After reading this book you, might start thinking about your business very differently. I cannot be held responsible for the increase in business you may start to experience.

Who you are talking to is a big deal too … a really big deal! Are you talking to everyone about what you do? Specific people? How do they hear what you are saying? Start considering this today because it matters. If you’re talking about IRR, COI and WOP, they may be thinking OMG!

Encourage your clients to stop you when you go into jargon mode. We are all guilty of this in the financial services community. I’ve done it and you are doing it today. Instead, challenge yourself to talk to everyone differently. Lose all the lingo and listen from your clients’ perspective. Better yet, find someone who knows NOTHING about what you do and start describing things to them. You’ll be amazed at how many times they raise their hand and say, “I dunno what you’re talking about right now.”

Sure, I can give you all the social media advice to help you ramp up and start exploring a new world and way of doing business, but none of this will work unless you’re innovating and doing business differently. Can you commit to getting comfortable with being uncomfortable?

Are you innovative or out?

Hear more from Sheryl and other social media directors at FTF’s annual SMAC Conference in New York on September 18th, 2014! Check out the agenda and speaker line-up at FTF News.

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Utilizing Big Data in the Financial Markets

Larissa J Miller HeadshotGuest Contributor: Larissa J. Miller, Founder and Board Member of Stuart Investments

The financial markets have always been blessed with big data. While other industries are catching up to the markets in terms of size, the financial markets have moved on to the incorporation of the data to existing models, learning models and strategic decision making at both the corporate level and the trading level. Since stepping into the modeling world in 2004, I have seen the markets evolve in terms of both technology and sophistication. Model development has been streamlined by the advancement in programming languages such as R through industry developed packages allowing for programmers to quickly develop prototypes. The level of sophistication of the models has increased by our gained knowledge through the various financial crises in the last decade as well as our deeper incorporation of probability and statistical modeling techniques.

The credit crisis of 2008 changed the viewpoint of the entire industry how to properly model fixed income products. During this time existing modeling standards and assumptions were challenged as past behavior did not indicate future behavior in terms of pre-payments as well as default rates. Prior to the crash many credit analysts were able to use a standard hazard rate which was applied to every customer in a given pool or asset class. This rate described the industry standard on what percentage of the population of the pool would either pre-pay their loan or default on their loan.

The industry has moved away from applying a single rate to the entire group. Rather models are now developed to predict exactly which loan will be either pre-paid or defaulted. Firms within the financial markets benefit from understanding which of the pooled loans to either enhance profits as well as to mitigate risks. The firms enhance profits by building better relationships with their customers. The firm is given an opportunity to proactively keep their customers by working with them to prevent loan pre-payment. This is particularly helpful when the customer has a loan of several millions of dollars. On the other hand, the firm also has the opportunity to work with a customer before a default on the loan occurs. This helps prevent further write-off’s from the balance sheet. Modelers are incorporating more sophisticated modeling techniques into these models by using existing collected loan data from past loans and then generating logistic function factor models. The logistic function allows for the classification of the intensity or sensitivity to the factor in question.

Traders also have the opportunity to enhance their trading profit and loss through the incorporation of more sophisticated statistical modeling techniques. Research has been developed incorporating Markov regime switching algorithms into the trading model. Incorporating the Markov technique allows for the trader to generate a probability matrix of the state of the economy. Traders have ability to determine the number of states in the economy, typically two (a bull state or a bear state). The probability matrix then tells the trader what the probability of the economy being in either state. The information can then be fed into a trading model with different weights based on the probabilities generated by the matrix.

The advancement in both technology and sophistication has lead to better model building causing a better understanding of the risk of the trading world.

 

Larissa Miller was a featured panelist speaker at FTF’s DerivOps Chicago conference this past April 2014.   FTF is currently planning for DerivOps New York on November 6, 2015.  This event will bring updates on OTC regulatory reforms and manual processes, SEF platforms, global perspective on reporting requirements, trade clearing rules, EMIR and global collateral management.  Learn more about this event online here.

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