High Line Advisors LLC

management ideas for banks and broker-dealers

Rules of Prime Brokerage Risk Management

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We’ve assembled a list of guiding principals for managing risk in a prime brokerage business, covering the areas where prime brokers are most likely to get into trouble. We encourage the community to contribute to or debate this list. Anonymous contributions may be emailed to feedback@highlineadvisors.com.

  1. Margin Lending: Don’t finance what you don’t trade. If you don’t have price discovery or can’t orchestrate a liquidation of the collateral, don’t make the loan.
  2. Margin Lending: Lend against assets, not credit. The ability to value collateral should be a core competency of any prime broker or repo desk, while expertise in credit extension (unsecured lending) is not. Be aware of the boundary between secured and unsecured risk, as lower margin buffers increase credit exposure in extreme (multi-sigma) market events. If you don’t have possession (custody) of the asset, don’t finance it.
  3. Margin Lending: Finance portfolios, not positions. Diversification of collateral is a significant risk mitigator.
  4. Margin Lending: Accept everything as collateral, but don’t necessarily lend against it. Cover your tail risk with a lien on anything you can get, but don’t add to the problem by lending against less liquid positions.
  5. Margin Lending: Be aware (beware) of crowded trades. The liquidity assumptions used to determine margins may be insufficient when like-minded hedge funds simultaneously become sellers of the stock. This goes beyond positions in custody, but those held by other prime brokers as well. Ownership representations are reasonably required.
  6. Secured Funding: Eliminate arbitrage among similar products. Maintain consistent pricing and contractual terms when borrowing securities or entering into swaps, repos, margin loans, or OTC option combinations with customers.
  7. Customer Collateral: Accept only cash collateral for derivatives. If non-cash collateral is offered, convert it to cash (via repo), apply only the cash value against the requirement, and charge for the cost of the conversion. Cash debits and credits are the best way to manage margin/collateral requirements across multiple products and legal entities.
  8. Contractual Terms: Treat clients that do not permit cross-default or cross-collateralization among accounts as if they were as many distinct clients. If you can’t net or offset client obligations, don’t give margin relief for diversification.
  9. Derivatives Intermediation: Do not provide credit intermediation unless you understand credit risk (again, most prime brokers do not) and charge accordingly. When intermediating derivatives operations, do not inadvertently insulate customers from the credit of their chosen counterparties.
  10. Funding Sources: Raise cash from collateral, not corporate Treasury. Strive to be self-funding, raising cash lent to customers from securities pledged by customers. Practice “agency” lending (from cash raised from customer collateral) over “principal” lending (from unsecured sources of cash, like commercial paper).
  11. Term Funding Commitments: Don’t be the lender of last resort unless you understand what it means, want to do it, and get paid properly for it. Only the largest banks with substantial cash positions under the most dire circumstances may be in a position to offer unconditional term funding commitments. Does any broker-dealer qualify?
  12. Sponsored Access: Have robust controls for high-frequency direct market access, including gateways to enforce trading limits.
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