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Furthermore, in October 2020, the US Securities and Exchange Commission (SEC) enacted a new regulatory framework, Rule 18f-4, for derivatives use by US mutual funds, business development firms, and exchange-traded funds. The new rule permits funds to use derivatives if they comply with certain conditions designed to protect investors. A fund relying on the rule generally must calculate risk measurements that were not required in the past such as:
- Daily value-at-risk (VaR)
- At least weekly VaR backtesting
- At least weekly stress testing
A fund may rely on the exception for limited users of derivatives if the fund’s derivatives exposure is limited to 10 percent of its net assets, excluding certain currency and interest rate hedging transactions.
Compliance plans must be fully implemented by August 19, 2022. This means that each company’s firmwide risk management team, firmwide legal and compliance executives, and fund board of directors should be engaged in making initial decisions now. Failure to comply could result not only in fines from the SEC but also taking the consequence of reputation risk failure such as withdrawal or lawsuits from investors.
A new set of compliance demands
The rule calls on affected funds to implement a derivatives risk management program that will require them to significantly ramp up several types of risk analysis on a daily or weekly basis.
Affected funds will be required to appoint a derivative risk manager, deliver a written risk management strategy, and stay within limits on fund leverage risk based on VaR. This outer limit is based on a relative VaR test that compares the fund’s VaR to the VaR of a “designated reference portfolio” for that fund. A fund generally can use either an index that meets certain requirements or the fund’s own securities portfolio (excluding derivatives transactions) as its designated reference portfolio. If the fund’s derivatives risk manager reasonably determines that a designated reference portfolio would not provide an appropriate reference portfolio for purposes of the relative VaR test, the fund would be required to comply with an absolute VaR test. The fund’s VaR generally is not permitted to exceed 200 percent of the VaR of the fund’s designated reference portfolio under the relative VaR test or 20 percent of the fund’s net assets under the absolute VaR test.
The new limits on fund leverage risk mean that VaR analysis will need to be done daily, and stress testing and backtests will need to be done weekly. Many firms now do these tests only on an ad hoc or monthly/quarterly basis. Some don’t currently do them at all. To complement the limitations of VaR, stress tests will be an important tool. They should be run at least weekly, incorporating the correlations among the market factors.
A turnkey reporting solution
To properly measure the fund leverage risk, a risk engine requires the terms and conditions of the portfolio holdings and benchmarks, access to historical market data and broad pricing model coverage for various asset classes and derivatives for daily VaR analysis. The risk engine should also have robust stress testing capabilities. Running these calculations on many portfolios tracking large benchmarks will require intensive, scalable computing power.
To stay in compliance with the new rule, Qontigo’s Axioma Risk™ solution enables funds to run the necessary new risk measurements and calculations. Because Axioma Risk is powered by Microsoft Azure, it can scale as needed to help affected firms meet the new rule’s risk measurement requirements. Azure is a highly stable and secure environment that provides the computing power to handle the additional demands caused by this new regulation.
Axioma Risk provides a turnkey reporting package that includes daily derivatives exposure, daily VaR calculations for the SEC’s requirements, as well as relevant stress tests and backtests. VaR can be checked against SEC limits and/or against internal limits.
Axioma Risk also provides an interactive risk diagnostic tool and a web-based pre-trade risk analysis tool for what-if scenarios.
The scalability of the Azure cloud
To implement Axioma Risk, Qontigo’s team of risk experts source the fund holdings and benchmarks for each client and automate the risk calculation workflow. Axioma Risk comes with a rich set of securities master data and historical market data. The system also provides comprehensive securities pricing models, including cash securities in all asset classes: equity, fixed income, commodity, and currency, as well as every derivative commonly used by mutual funds.
The combination of Qontigo’s risk and compliance expertise, the robust data set and risk analytics, and a scalable simulation engine built on the Microsoft Azure cloud provides a very strong package to answer the requirements of the new SEC rule.
Visit the SEC Rule 18f-4 page on the Qontigo website to find out how we can simplify your compliance journey.