DEVELOPMENTS IN THE STEP MARKET
The European Central Bank (ECB) and the Eurosystem national central banks continue to
support the Short-Term European Paper (STEP) initiative that was launched in June 2006 by
acting as catalysts, thereby fostering the integration of the euro area’s financial system. The
regular publication of detailed statistics on the STEP market by the ECB contributes to the
transparency in this market and allows the impact of related decisions taken by the ECB’s
Governing Council to be assessed.
In October 2008, the ECB’s Governing Council
decided to temporarily expand the list of
assets eligible as collateral in Eurosystem
credit operations to include STEP-labelled
securities issued by credit institutions, i.e.
certificates of deposit. This measure was
discontinued at the end of 2010. The end of
this exceptional measure could thus have
had a negative impact on the development
of STEP securities, especially those issued
by monetary financial institutions (MFIs),
as shown in the analysis conducted for the
first months of 2011 in the previous article 1 .
The detailed STEP statistics published by
the ECB on a weekly basis 2 however show
that the STEP market has proved its robustness
following the discontinuation of the
specific measure at the end of 2010.
Chart 1: Comparing outstanding amounts for STEP securities with a benchmark
The total outstanding amounts of STEP-labelled
programmes fell for the first semester
of 2011, but have since risen sharply,
to reach €443.5 billion at the end of December
2011 stemming from 169 STEPlabelled
programmes. This level almost
corresponds to the highest level observed
during the first three quarters of 2009. The
relative positive development of STEP-labelled
securities needs to be compared with
an adequate benchmark for euro-denominated
short-term debt securities (Chart 1)
in order to assess the developments in the
STEP market in 2011. Chart 1 highlights
the decrease in the ratio of STEP securities
denominated in euro and issued by nongovernment
sectors to euro-denominated
issuance of debt securities by worldwide
non-government in the second quarter of
2011. However, the strong increase in the
outstanding amounts of STEP programmes
for the third quarter and even more for the
fourth quarter can be seen as a further sign
of the success of the initiative in supporting
financial market integration.
(a) Euro-denominated non-government STEP securities outstanding
(b) Euro-denominated non-government worldwide short-term debt securities outstanding
Share: (a)/(b) (right-hand scale)
1000
50%
800
40%
EUR billions
600
400
30%
20%
percentages
200
10%
0
Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4
2007 2008 2009 2010 2011
0%
67
Maintenance Periods and the Money Supply:
Maintenance periods is an old issue no
longer discussed yet its import should be
understood in order to determine the demand
and supply of money, interest rate
direction and purpose employed through
market mechanisms such as Eonia and
Euribor in Europe and Fed Funds in the
United States. Maintenance periods for
central banks define monetary policy by
pricing a nation’s demand and supply of reserves
to an interest rate. Yet each central
bank that employs a maintenance period
deploys those periods in different ways.
A maintenance period for the Eurozone is
the time between governing council meetings,
an ECB policy rate meeting in market
parlance with a purpose to price excess reserves
placed by banks on account at the
European Central Bank. Reserves are averaged
monthly over the maintenance period
term. The ECB then provides liquidity
to the banking system by bankers who bid
for Euros through weekly and three month
auctions at the Main Refinance Rate, also
termed the Minimum Bid Rate. The Refi
rate is the most important interest rate in
Europe because it influences prices in market
interest rates such as Eonia and Euribor
to satisfy ECB policy to bring price stability
to the European system. More importantly,
the Refi rate is also termed the base rate
because it establishes at what interest rate
reserves are expected to grow or contract
and appears in M3 money supply forecasts.
Reserves are also termed the money supply
and interest rates are termed reserve
rates.
Excess reserves are paid an interest rate
to manage liquidity. For the European system,
the overnight rate termed Euribor or
the Euro Interbank Offered Rate is paid on
excesses for the short term. Reserve deficits
are charged an interest rate termed
Eonia, Euro Overnight Index Average and
a weighted average of Euribor. Eonia is the
rate bankers charge each other for overnight
loans and represents the floor of interest
rates. Eonia is an effective rate to
Euribor and the Refi rate.
Excess reserves once priced are loaned
throughout the banking system by borrowing
at the Eonia rate and lending at Euribor.
Euribor establishes loan rates and are
indexed since 2008. This represents what
is known as the interest rate corridor or
channel for the European system that establishes
a floor and ceiling of daily interest
rates. The purpose of the 1999 introduction
of short rates is to price reserves
on a daily basis and gives indication of
the demand and supply of Euros to meet
the three month, money supply refi target
rate. Above the target means inflation and
an erosion prices, below means deflation.
Both are a cost to reserves.
Euribor and Eonia are tradeable market
rates that trade as futures contracts on Euronext.
Euribor/Eonia Swap Index futures
is one such contract. Since 2008, the one
month Eonia contract and the three month
Eonia swap index aligned in terms of trade
and settlement to central bank maintenance
periods. The Eonia three month contract
trades normal International Money
Market dates while the one month contract
is aligned to European maintenance periods.
Figures 6.8 and 6.9 are charts of the interest
rate corridor for the ECB, US, Japan
and the BOE. Each nation has various
means to achieve the desired three month
money supply target. For the short term,
the Japanese employ Call rates, the BOE
remunerates and indexes reserves at the
Bank rate with Sonia rates as the daily operational
guide and the US employs the
Fed Funds rate. The Japanese, ECB and
the US employs maintenance periods while
Australia, Canada and New Zealand do not.
Most important for the Japanese, ECB and
the US maintenance period time is short
rates establishes the start of the day’s yield
curve. The interest rate releases answers
the question long or short a currency pair
and/or which pair to swap in interest rate
terms.
14 15
Philippe JEANNE
Building the After Crisis Environment
The Financial Markets Association (ACI)
groups more than 13,000 finance professionals
in 64 countries around the world.
ACI Europe is very active within the ACI,
with 33 countries working together alongside
other financial, regulatory and supervisory
associations to continue improving
the standards of the Financial Markets.
The ACI focuses on training (staff certification),
on Ethics, and on Dispute resolutions,
and works with regulatory authorities,
central banks, to give insight into
the best ways to adapt to changes of environment.
Needless to say that present
times are challenging in this matter!
Cooperation with Euribor-EBF has been
very close for a long time. Milestones
have been reached with the creation of
the Euribor fixing, the STEP label and an
ongoing communication with the European
Commission and the European Central
Bank.
Our common ambition is to make sure
that the ongoing developments in the industry
are technically sound and viable
in the long term, to maintain the competitivity
of Europe with the rest of the
world, and to emphasise that Financial
institutions are key players in the economic
field.
In times of crisis, it is all the more important
to take the right decisions, especially
when they drive the future. The
number of members in the ACI and their
vast expertise in all the segments of the
industry, as well as the strong cooperation
with Euribor-EBF and other associations,
constitute a guarantee that regulators
and politicians can obtain all the
advice they need to be able to make the
right decisions.
Let’s hope that this opportunity will be
fully exploited.
Philippe JEANNE
is European President
of ACI-The Financial
Markets Association,
representing 34 countries in Europe.
He is Global Head of Forex Trading at
Natixis, and has a strong expertise in
Derivatives and Emerging Markets,
developed at Calyon, ASLK-CGER and
Barclays.
He has been based in London, in the
US, and now in Paris.
3
Edito
Guido RAVOET
Contributing to a sound and robust european
financial system
Since the beginning of the second crisis wave, in the wake of the sovereign debt crisis in a
number of European countries, the overall European financial system has been put under
serious stress. As a result, it is now facing a critical period which, it is hoped, will lead to
reinforced integrated governance.
Euribor-EBF is constantly working on supporting the transparency and efficiency of shortterm
debt and interbank money markets in order to help the euro area economy be financed
by funds other than those made available by the European Central Bank.
In contrast to the way the general public currently perceives banking institutions, the latter
play clearly a key role in financing the real economy through their traditional activities.
Furthermore, well-functioning interbank markets are at the source of banks’ liquidity.
Therefore, their output has an impact on individual European citizens.
Given the current environment, Euribor-EBF believes that the only way to offer EU regulators
a clear vision of what can, or cannot be done when regulating the banking industry, is
to gather as much expertise and evidence as possible on key issues and to share information
with all stakeholders.
This is the reason why Euribor-EBF has been working more and more closely with other
associations such as The Financial Markets Association (ACI) Europe, Euribor ACI, and the
European Fund and Asset Management Association (EFAMA) over the last few months.
This collaboration should in turn pave the way for improved cooperation with the EU authorities.
Furthermore, Euribor-EBF has been working in partnership with the European Central
Bank on interbank and short-term debt markets for many years and is willing to share its
knowledge with the other European Institutions, in particular, the European Commission
and Parliament.
It is a way for bankers and money market specialists to contribute to a transparent, robust
and sound European financial system.
Guido Ravoet, Chief Executive Euribor-EBF European Banking Federation
€
EUROPEAN BANKING FEDERATION URIBOR
E B F
23
Viktorija PROSKUROVSKA
Lending to the corporate sector was badly hit in
2009 and is still below the peak level (in November
2011 it stood at € 4.8 trillion).
Bank lending to the euro area governments has
jumped during the crisis: in November 2011,
euro area bank lending to governments stood
at € 1.1 trillion, up by 16% from October 2008.
Figure 3: Total euro area MFI lending to governments, € million (ECB)
1.300.000
1.200.000
1.100.000
It has been reported by the European Commission
DG ECFIN, and by the European Central
900.000
Bank that during the crisis, cross-border banking
activity weakened. The EBF is concerned
800.000
with the lack of political ability to solve the
700.000
ongoing sovereign debt crisis in a number of
EU countries, which weighs heavily on the EU
banks’ ability to continue serving the economy.
Furthermore, given the general economic sentiment and the heavy financial regulatory burden,
large European banks’ considerations to pull their subsidiaries out of Eastern Europe
may put in jeopardy financial integration in Europe even further.
2007Jan
2007Mar
2007May
2007Jul
2007Sep
2007Nov
2008Jan
2008Mar
2008May
2008Jul
2008Sep
2008Nov
2009Jan
2009Mar
2009May
2009Jul
2009Sep
2009Nov
2010Jan
2010Mar
2010May
2010Jul
2010Sep
2010Nov
2011Jan
2011Mar
2011May
2011Jul
2011Sep
2011Nov
1.000.000
CALL FOR A BALANCE BETWEEN SYSTEMIC STABILITY AND BUSINESS EFFICIENCY
It should be recalled that prior to the crisis,
the main focus of Europe’s financial institutions
was on efficiency gains, attainable,
and indeed attained, to a larger degree at
the EU rather than at national level. Today,
the regulatory discussion focuses much
more on financial sector stability, a very
welcome approach, but which is, to a certain
degree, in contradiction with the earlier
goal of efficiency. Specifically, current
regulatory framework implies that crossborder
banking groups must ensure capital
and liquidity standards in each branch or
subsidiary, limiting the intra-group flows,
thus making an impact on the choice of
banks’ business model. This impact does
not necessarily favour deeper financial integration;
neither does it help to improve
banks’ group-level efficiency, it does however
facilitate greater financial stability of
each of the banking group’s entities.
Financial integration can only take place in
an environment of financial stability and
economic growth. The EBF realises that
progress in retail integration will only be
gradual, and it is prepared to continue its
long-standing cooperation with the European
Commission on elimination of artificial
barriers to integration in retail as well
as wholesale markets.
Over the past two years, the EU leaders
have been tackling a range of highly challenging
tasks. Not only have they faced the
damage caused by the global economic and
financial crisis, they have also been putting
in place the missing elements of the underlying
EU architecture in order to ensure
that crisis management mechanisms, both
in finance and at the sovereign level, can
be resolved in the future.
It is hoped that strengthened economic
governance will bring confidence back to
the financial markets and economic growth
back on track. This would greatly help the
financial industry meet its new regulatory
requirements as well as adjust to the new
norm, which should contribute to financial
integration, for the good of banks and citizens
alike. Normalisation of the economic
and financial situation will, eventually, create
the right circumstances for banks to
find a new and better level of efficiency in
the new regulatory environment.
Viktorija Proskurovska, Adviser
11
Overview of the proposed FTT Directive
The Commission presented last September
a proposed Directive to introduce
a common system of financial
transactions tax (FTT).
In the context of the current crisis, many
EU Member States believe that additional
taxation of the financial sector may generate
immediate public revenue at the expense
of financial institutions and, at the
same time, help restore financial stability
and economic growth. In addition, it is also
aimed at ensuring that the financial sector
makes a fair contribution to public finance.
The underlying hypothesis is that the sector
is currently under-taxed vis-à-vis other
sectors. This assumption is based, at least
partially, on a biased perception of advantages
that are considered inherent in the
VAT exemption of financial services.
The Commission believes that the proposed
FTT Directive would be able to strengthen
the EU Single Market by setting up a harmonized
framework to FTT. In their view, it
would help reduce competitive distortions,
deter financial institutions from excessive
risk-taking activities, complement regulatory
measures aimed at preventing future
crises and promote common rules for the
introduction of a FTT at global level. To a
certain extent, these objectives, however,
appear to be conflicting. Indeed, there
seems to be a paradox between the requirement
for banks to rebuild and strengthen
their capital base, lend more and pay more
taxes at the same time.
According to the residence principle which
determines the territorial scope of the proposed
legislation, the key connecting factor
for the collection of the tax would be
the involvement in a financial transaction
of a financial institution established in an
EU Member State. A financial institution
will be deemed to be established in the territory
of a Member State if it is authorised
in that Member State, has its registered office
in the Member State, is resident in the
Member State or is acting through a branch
located in the Member State. The FTT will
apply to a financial institution irrespective
of whether it is acting in a principal or
agency capacity. Hence, where a financial
institution established in a Member State is
a party to a financial transaction, it will be
subject to the FTT irrespective of the location
of the counterparty or the location of
trading.
Focusing on financial institutions, the proposed
FTT legislation broadly defines those
institutions by including investment firms,
organised markets, credit institutions, insurance
and re-insurance institutions, collective
investment schemes and their managers,
pension funds and their managers,
holding companies, leasing companies and
special purpose vehicles. The draft Directive
provides for a number of carve-outs,
ring-fencing SMEs and private households,
primary markets, issuing of government
bonds, as well as monetary policy and posttrading
activities.
12 13
The Repo Market: there has to be some funding
alternatives for European Banks 0000 Cédric QUEMENER
Given the ongoing sovereign debt crisis,
along with the growing regulatory need for
banks to find pools of liquidity for funding
purposes, the Repo market is currently playing
a key role in Europe.
The Repo market is not only used by commercial
banks, but also widely used by Central
Banks to process their open markets
operations within the aim of taking liquidity
from the financial system.
It is more and more difficult for a bank to
operate lending/borrowing transactions in a
cautious market, with a strong appetite for
collateralized (credit risk reduced) lending
deals.
The concept of a Repo deal, seen from the
borrower’s side, consists in lending a security
for a determined period (maturity) to
another bank. At the end of the period, the
borrower pays the cash plus the repo interest
rate and receives its security back.
Most of the collaterals used in the repo market
are government bonds, sometimes blue
chips equities or corporate bonds.
Since the creation of the Euro, Euribor–EBF
has been fulfilling its scientific mission towards
the European Banking Industry by
providing the market actors with an accurate,
representative benchmark of the European
Repo market, called Eurepo.
Nonetheless, as the market is constantly
evolving, closely following the macro economic
and political evolutions, financial actors
are focusing more and more on an “as
secure as possible” market, using the same
kind of indicators.
As the Interbank Markets representative for
European Banks, Euribor-EBF is the best
positioned association to lead this kind of
project, benefiting from the extensive expertise
of its Steering Committee Members,
the vast network of European banks, and
the recognized governance principles of its
structure.
Given that the regulatory environment is becoming
stricter, and ever more demanding
for banks in terms of funding whereas the
economy needs banks to spread liquidity by
lending to its actors, we believe that the repo
market usage and its instruments should be
eased by the European authorities.
Yet, as seen from the ongoing Financial Tax
Transaction being discussed by a few EU
Member States, this is decidedly not the current
trend. On the contrary, the Repo market
would technically be the victim of the new
tax pressure on banks. What is more, European
companies would be affected by the
clear potential lack of liquidity available on
the market; even States would be too.
In conclusion, we would strongly wish that
the continued efforts made by European
Banks to improve the market knowledge and
therefore help the Repo market development
would not be annulled by a lack of support
from our leading European Institutions.
Cédric Quéméner, Director EURIBOR-EBF
This is the reason why the Euribor-EBF Secretariat
and the Eurepo Steering Committee
have worked on completing the service
brought by the Eurepo benchmark, by creating
an “overnight” European Repo benchmark.
The concept is to give each day a
sense of the market reality through a fixing
made of the average calculation of the executed
transactions on the most important
repo markets across Europe, taking into account
deals with as many types of collateral
as possible.
5
Short News
Fixings
Euribor-EBF pursues its work to offer a better view
of the interbank market in Europe
STEP
STEP programmes issued by monetary financial
institutions are again ECB eligible
from January 2012
Since January, STEP programmes issued
by monetary financial institutions have become
eligible assets for collateral in European
credit operations. This was already the
case for STEP programmes issued by nonfinancial
corporations. Concretely, credit institutions,
benefitting from the STEP label,
will not have the obligation to list their programme
in order to be ECB eligible. As such,
they reduce their outlay significantly given
the lower costs of the STEP label (€5000 entry
fee and €2000 annual maintenance fee).
Euribor-EBF welcomes the ECB’s decision
and believes that STEP should not only be
a label of transparency and harmonisation
but become a standard in the Short-Term
European Paper market.
Over the last years, the European banks have been
expressing the need to create a Euribor-like benchmark
for dollar-funding purposes. As a response to
the market demand, Euribor-EBF has been developing
a USD Euribor, which has been tested over
the last six months. The launch of the new benchmark
is planned for 2012.
The Eurepo Steering Committee and Euribor-EBF
have been working on the creation of an overnight
repo benchmark, reflecting the effective transactions
on the repo market (see p.5).
Changes in the composition of the Euribor panel
Since its creation in 1998, the Euribor panel has
continuously adapted to the European banking industry
evolution.
Following a common decision of WestLB and the
Euribor Steering Committee, WestLB is no longer
contributing to the Euribor and Eonia fixings since
1 January 2012. The Euribor-EBF team would like
to thank West LB for the rewarding years of collaboration.
The Euribor-EBF Team and the Steering Committee
welcome the inclusion of UBI Banca on to the Euribor/Eonia
panel since February 2012.
STEP statistics to be improved the coming
months
The ECB statistical Team and the STEP Statistics’
Task Force are currently working on
the development of STEP statistics, both on
the content and the format, in order to offer
the buy and the sell side, increased information
on the STEP market. STEP statistics
are calculated and published by the ECB
website.
(http://www.ecb.int/stats/money/step/
html/index.en.html) and also displayed on
the STEP website (http://www.stepmarket.
org/statistics.html).
The Euribor-EBF editorial Team would like to thank
most warmly the ACI Europe President, Mr Philippe
Jeanne, the ECB Statistics Team, the EFAMA Director
of Economics and Research and the EBF advisers;
as well as Mr Brian Twomey (as an independent
writer), for collaborating on this publication. A
special thank to Ms Florence Ranson, EBF Head of
Communications.
17
€
EUROPEAN BANKING FEDERATION
E B F
Guido Ravoet - Responsible Editor
URIBOR
Gaëlle Marques dos Santos - Editor in Chief
Sébastien Dieu - Designer
Euribor-EBF
Rue Montoyer, 10
1000 Brussels
0032(0)2/508.37.11
www.euribor-ebf.eu
Copyright: Euribor-EBF
June 2011
Please mention when quoting
18
Euribor EBF
Newsletter
February 2012
1
Inside the Currency Market
Brian Twomey
Inside the Currency Market: Mechanics,
Valuations and Strategies, published by
John Wiley and Sons and Bloomberg Press
is a book that literally covers all facets that
comprise a currency pair equation from market
to market of the eight major nations as
well as factors to consider to properly trade
any currency pair in any market.
It is a deeply detailed and comprehensive
study into every nation’s financial
market that offers a full load of information
that hasn’t been seen nor properly
explained together in one volume. Much
of the information is original. The Japanese
Yen for example transforms itself from Asia
to Europe to the US to Canada and attaches
itself to various instruments in order to
move in the markets. The Yen is tracked
through the various markets almost by an
hourly basis with explanations and operational
guidance in order to employ a trade
strategy.
All currency pairs are addressed market to
market in terms of trade weight indices,
methodologies, formulas and calculations,
index methodology and histories, weights
and constituents in every index. How to view
currency pairs in each market is considered
as well as major imports and export markets,
major products and important destinations.
All accompany charts and graphs
British Bankers Association Libor as well
as each nations interest rates are fully explained,
fully outlined, fully addressed in
terms of movement, direction, purpose, histories,
times of trade, seasonality, overnight
rates and always accompanied by currency
pair charts and graphs as well as each nation’s
interest rate charts for comparision.
Yield curves in terms of histories,
each nation’s curve,
bonds vs yields in each
market, yield spread formulas
and calculations between two nations as
well as single nation bond maturities are
explained and factored to a currency pair.
Each nation’s bonds are listed and calculated
at every maturity. Carry trades and yield
spreads are explained and accompanied by
examples and charts.
Interest Rate Swaps, Cross Currency Basis
Swaps, Foreign Exchange Swaps and outright
forwards in each nation is explained,
trade strategies offered and explained as
well as methodologies and histories. OIS
swaps are also explained. A deep discussion
of forward points is offered as well as two
examples to calculate a forward point to a
yield curve.
Each nation’s stock market, calculations of
each index, types of index to know for economic
and market purposes, currency pairs
in terms of stock, bond and yields are offered
as trade strategies and methodologies
nation to nation.
This is only a small portion of the many varied
categories found within these pages. It
is a book with a focus on the understanding
of currency pairs yet it is a book for all traders
in all markets, in all traded instruments.
Fair value for example is calculated as an
example to factor the S&P’s. Fair value is
defined as futures priced to cash yet theoretical
value is also calculated as an example.
Theoretical value is defined as a long
or short in one index or a long or short in a
stock that comprises the index.
A reader will have a full understanding
of not only the international
system but a firm comprehension
of each nation’s market in
order to trade and understand the
purpose, functions and trade of
currency pairs.
16 17
Europe vs the United States
Brian Twomey
The Federal Reserve Board established in
2008 what it calls maintenance periods.
These are weekly periods during which
banks must maintain required reserves.
Maintenance periods cover 14 consecutive
days. Required reserves began as Reg D
that appeared first in the Federal Reserve
Act of 1978 then carried forward to the
1980 Monetary Control Act that imposed
mandatory reserve requirements. All governments
then imposed reserve laws and
this gave rise to the need for the British
Bankers Association as reserves had to be
priced and balanced in line with central
bank target rates.
Fig. 6.8
Fig. 6.9
To pay interest on reserves was scheduled
for 2011 with passage of the Financial
Services Regulatory Relief Act of 2006
but moved forward by Congress to 2008
with passage of the Emergency Economic
Stabilization Act of 2008 (Federal Reserve
2010).
In conclusion, maintenance period
is an important time between the US
and Europe because lend and borrow
rates, bids and offers, yield curves and
direction of financial market instruments
are established for a particular
day’s trade not only in the US and Europe
but between the US and Europe
in terms of a Euro/USD exchange rate.
The most important aspect of maintenance
periods is the determination in
the demand and supply of Euros vs US
Dollars. It is an indicator and a valued
market tool that should be a regular
focus for those involved in the markets.
Brian Twomey is an
independent trader
and a prolific writer
on trading,
having authored over sixty articles in
Technical Analysis of Stocks & Commodities
and Investopedia. His article
on Welles Wilder is one of the most
heavily accessed pieces in Technical
Analysis of Stocks & Commodities in
recent years. Through his writings,
Twomey has established a strong following
among traders and market analysts.
He is an Adjunct Professor of
Politics at Gardner-Webb University.
Twomey has a BA in journalism and a
master’s in political science and public
administration from the University of
Central Florida.
15
Money Market Funds:
2012 presents great uncertainties for money
market funds (MMFs). Indeed, the Financial
Stability Board (FSB) has asked IOSCO to undertake
“a review of potential regulatory reforms
of MMFs that would mitigate their susceptibility
to runs and other systemic risks.”
IOSCO is to propose policy recommendations
by July 2012, with particular emphasis on the
following reforms: (i) encouraging or requiring
shifts to variable net asset value arrangements
and (ii) imposing capital and liquidity
requirements on MMFs which continue to
promise investors constant net asset value.
Regulators’ concerns about MMFs are directly
linked with the difficulties of the Reserve Primary
Fund shareholders, following the failure
of Lehman Brothers. This event led the U.S.
authorities to take government-supported
measures to alleviate the pressure on MMFs.
They also adopted new rules to reduce risks
associated with MMFs. The U.S. authorities
characterized these measures as “a first step”
and noted that additional possible reforms
would be considered to make MMFs less vulnerable
to “runs”. Clearly, there is a risk that
this process will lead to the adoption of new
requirements that are neither necessary nor
helpful to MMFs in Europe.
It is true that the financial instability arising
from the Lehman Brothers’ bankruptcy, and
the meltdown of credit and money markets,
created pressures for MMFs in Europe. Ultimately,
however, the pressures faced by
MMFs started to recede in November 2008,
without any government guarantees. The
financial crisis also caused strains among
MMFs in Europe in 2007 after the outbreak of
the subprime crisis. However, investors’ concerns
about the quality of MMFs reflected the
fact that a small number of “cash-enhanced”
funds had purchased asset-backed securities
to boost their returns. These funds were in
fact not classified as MMFs.
89
State of EU banking integration in times
of crisis
Economic globalisation led by the business sector around the world is now being echoed by
regulatory globalisation orchestrated by the G20. Despite the fact that the G20 proposals are
not binding, the EU leaders follow in their footsteps and transform into legislation almost to the
letter the outcome of G20 discussions. This gives rise to a new dawn of regulatory environment
around the world, especially if all countries (G20 and beyond) follow suit.
It is in this context that the integration of the EU financial services markets has been taking
shape till now. Over a decade up till 2008, a number of important structural barriers to integration
had been removed . However, it took a serious crisis to address a number of big stumbling
blocks such as pan-European banking supervision, and EU Crisis Management and Resolution
Framework. One could argue that these fundamental elements should have been put in place
much earlier, in order to help sustain the process of integration of financial services from the
outset, and help facilitate stability of the industry and, consequently, the entire economy.
IMPACT OF THE CRISIS ON EUROPEAN BANKS’ BUSINESS AND THEIR INTEGRATION
Over the past three years, Europe’s banking sector has been affected by the financial, economic
and sovereign debt crises in various ways.
With the economic situation rapidly deteriorating,
the ECB moved from the variable minimum
rate of 4.25% in late 2008 to a fixed rate of 1%
in May 2009.
European inter-bank money market dried up
early on in the crisis due to plummeted confidence
and poor transparency of risks between
the inter-bank lenders and borrowers.
In Q3-2011, cross-border inter-bank loans and
deposits are both down by around 9% compared
with Q4-2008; also the nature of inter-bank
lending had changed: shifting from unsecured
lending to almost exclusively secured lending.
Figure 1: Total euro area MFI lending to households, € million (ECB)
5.400.000
5.300.000
5.200.000
5.100.000
5.000.000
4.900.000
4.800.000
4.700.000
4.600.000
4.500.000
4.400.000
In response, the ECB undertook a number of
non-standard liquidity operations.
Figure 2: Total Euro area MFI lending to non-financial corporations, € million
(ECB)
5.000.000
A number of banks have had to rely on the ECB’s
main refinancing operations for access to liquidity
at low cost (only in 2011, the amount of the
ECB’s main refinancing operations has more
than doubled.)
Encouragingly, cross-border MFI lending to non-
MFIs is growing.
Still, bank lending to households in the euro area
plunged in 2009, recovering somewhat thereafter
(in November 2011 it stood at € 5.1 trillion).
2007Jan
2007Mar
2007May
2007Jul
2007Sep
2007Nov
2008Jan
2008Mar
2008May
2008Jul
2008Sep
2008Nov
2009Jan
2009Mar
2009May
2009Jul
2009Sep
2009Nov
2010Jan
2010Mar
2010May
2010Jul
2010Sep
2010Nov
2011Jan
2011Mar
2011May
2011Jul
2011Sep
2011Nov
4.800.000
4.600.000
4.400.000
4.200.000
4.000.000
3.800.000
10 11
Regulatory Outlook for 2012
Bernard DELBECQUE
These strains led EFAMA and the Institutional
Money Market Funds Association to develop
a pan-European definition of MMFs to clarify
what the “MMF” label should include. Their
joint work persuaded the Committee of European
Securities Regulators (CESR) to issue
guidelines which created the first common
regulatory definition of the European MMF.
The guidelines include restrictions on exposure
to interest rate and credit risks, and also
require that MMFs draw investor attention
to the difference between the money market
fund and investment in a bank deposit.
The implementation of the CESR definition
will enhance investor awareness about the
exact nature of MMFs as well as strengthen
the quality of their assets, thereby enhancing
their resilience in crises.
Against this background, the European MMF
industry is highly concerned about the impact
that additional regulatory measures could
have on MMFs. MMFs are already highly regulated
investment products, which invest only
in very short-term, high quality, marketable
debt instruments, and do not use any leverage.
The cost that new regulatory rules would impose
on MMFs and their sponsors would cause
significant shifts of assets into bank deposits
and/or other less regulated vehicles. Imposing
capital requirements would reduce
or eliminate their attractiveness as a cash
management vehicle. In addition, the new
rules would hamper the role played by MMF
in providing funding to corporate and government
borrowers in the money markets.
Consequently, banks would have to play an
even greater role in the European economy,
which would run counter to the view that a
mix of market and bank financing increases
the economy’s resilience to crises.
The European Fund and Asset
Management Association (EFA-
MA) in figures
26 countries (EU Members,
Lichtenstein, Norway, Switzerland
and Turkey).
57 Corporate Members.
20 Associate Members.
Total Assets under Management
(in Europe) = around
EUR 13 trillion, of which
EUR 7,7 trillion through over
54.000 investment funds
(end September 2011).
Money Market Fund Assets
= EUR 1,1 trillion (end September
2011).
Bernard Delbecque,
Director of Economics and Research
We therefore hope that the policy options
will be reviewed by IOSCO taking into account
the potential impact of additional
costs and burdens on the availability of
funding to the European economy, and
the lack of evidence that MMFs pose risks
to the European financial system.
9
Table of contents
The Repo Market: there has to be some funding alternatives
for European Banks
Developments in the STEP MARKET
Money Market Funds:
Regulatory Outlook for 2012
State of EU banking
integration in times of crisis
Overview of the proposed FTT
Directive
Short News
Maintenance Periods and the Money Supply:
Europe vs the United States
Inside the Currency MarketMarket
€
EUROPEAN BANKING FEDERATION URIBOR
E B F
5
Roger KAISER
Technically, the tax chargeable event is defined as the execution of a financial transaction
involving an EU financial institution. The latter will be liable for the payment of the FTT to
the local tax authorities. Each Member State will be required to adopt domestic measures
to ensure that the FTT is paid immediately if the transaction is carried out electronically
and within three working days in all other cases. There is in addition a joint liability of each
party to the transaction, resulting in significant practical issues and costs associated with
enforcing collection and compliance, as well as legal uncertainty for presumed collectors
of the tax.
The wide scope of the FTT legislation will include transactions in all kinds of financial instruments,
i.e. equities, bonds, foreign currency (excluding spot contracts) and derivatives.
The scope will cover all kinds of transactions, whether conducted on regulated markets or
on an OTC basis, including purchase and sale, repos (sale and repurchase) and securities
lending transactions. The FTT will apply both to transactions between third parties and
intra-group transactions. This broad based approach is the most difficult aspect of the
legislation. Indeed, as acknowledged by the Commission in its impact assessment, this
will have a huge impact on the volumes of transactions. Therefore, by including repos, the
FTT will seriously impact the liquidity of markets. By including derivatives, it will impact
the major risk management tool used by banks. In a nutshell, the FTT is likely to create a
“structural break” of financial markets.
In the case of financial transactions other than derivatives, the taxable amount will be
the consideration payable between the parties for the transfer of the financial instruments
under the transaction. However, if this is lower than the market price, than the tax base
will consist in the market price. The taxable amount in relation to derivative transactions
will be the notional principal amount specified in the contract at the time the derivative is
entered into.
The tax rate of the FTT will be fixed by each Member State subject to a minimum rate of
0.1% for financial transactions other than derivatives and 0.01% for derivatives.
The implementation of the FTT legislation, the adoption of which requires unanimity at
Council level, is tabled for the 1st of January 2014. When fixing this date, the Commission
has ignored the necessary lead-time for financial institutions to adapt their systems and
procedures, a process which can only start when they know the details of the legislation.
But this is not the only flaw in this initiative. The worse is that policy-makers seem to ignore
that the financial sector operates on a global basis with capital able to move freely
and easily and trading carried out electronically and in many jurisdictions. Consequently
a real risk of the imposition of an EU wide FTT is that the tax base would be immediately
eroded through the migration of transactions outside the scope of the legislation.
Roger Kaiser, Senior Adviser
13
Giuseppina BOREA - Sandrine CORVOISIER
In order to investigate further whether the discontinuation of the temporary measure of the
ECB had a negative impact on STEP-labelled programmes issued by credit institutions, the developments
of those securities relative to the overall issuance of STEP securities were assessed
until the end of December 2011 for outstanding amounts (Chart 2) as well as for the number
of programmes (Chart 3).
At the end of December 2011, 79% of the total outstanding amount of STEP securities was
issued by MFIs and 15% by the general government sector. The MFIs’ share has decreased
since April 2011 almost back to the level in December 2010, while it was expected that the
discontinuation of this exceptional measure at the end of 2010 might have a negative impact
on securities issued by MFIs. The evolution of the share of the MFIs sector was mirrored by the
evolution of the share of the general government sector. Indeed the share of the issuance by
the general government sector increased from 5.8% in April 2011 to 15.1% in December 2011.
The distribution among the sectors is thereby almost the same as that in December 2010, i.e.
before the discontinuation of the ECB’s temporary measure.
Chart 3 reinforces the fact that the sectoral distribution did not differ significantly from the
figures at the end of 2010. Indeed 19 STEP labels were withdrawn by end December 2011 , of
which 13 were MFIs but this was almost offset by new STEP labels granted during this period.
Out of twelve new STEP labels, eight programmes refer to MFIs. The withdrawal of STEP programmes
issued by MFIs does not seem to have had a negative impact on the volume of the
STEP market, especially for the MFIs.
Chart 2. Outstanding amounts of STEP securities issuance by sector
Chart 3. Number of STEP programmes by sector
MFIs
non-financial corporations
supranationals
other financial intermediaries
general government
insurance corporations and pension funds
MFIs
non-financial corporations
supranationals
other financial intermediaries
general government
insurance corporations and pension funds
percentages
100
2,8
3,9
90
80
70
60
50
40
30
2,2 3,0
3.1 0,1 0,2
5,8
3,3 1,2
2,4 1,6 12,2
2,1
3,0
1,4
4,0
4,2
1,3
1,3
3,5
91,1
89,1
89,8
88,8
82,2
0,1
15,1
2,2
79,1
percentages
100
90
80
70
60
50
40
30
20
2,4
20,5
6,3
68,5
2,4
66,9
3,7
19,6
6,1
1,84
1,8
3,6
67,1
20,4
5,4
1,80
1,78
1,8
4,1
2,4
20,1
5,3
66.3
20
10
10
0
Sep.-08
Dec.-08
Jan.-09
Dec.-10
Apr.-11
Dec.-11
0
Dec.-09 (127
programmes) Dec.-10 (163
programmes) Apr.-11 (167
programmes) Dec.-11 (169
programmes)
The STEP statistics show that the development of the STEP market until the end of December
2011 supports the view that STEP securities have continued to develop robustly.
On 20 September 2011 the ECB’s Governing Council approved a new version of “The implementation
of monetary policy in the euro area – general documentation on Eurosystem monetary
policy instruments and procedures” 3 and adopted Guideline ECB/2011/14 on monetary policy
instruments and procedures of the Eurosystem. This means that STEP-labelled securities issued
by credit institutions will be again eligible as collateral for the ECB’s monetary policy operations
as of 1 January 2012.
Giuseppina Borea - Sandrine Corvoisier, European Central Bank
1
For more details, please refer to Corvoisier, S. and Petit, V., “Further signs of the robustness of the STEP market”, Euribor EBF
Newsletter, June 2011.
2
http://www.ecb.europa.eu/stats/money/step/html/index.en.html.
3
For more details, please refer to the Sections 6.2.1.5 and 6.2.1.6 of the General Documentation http://www.ecb.int/ecb/legal/
pdf/en_ecb_2011_14_f_sign.pdf.
7