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Welcome to Introduction to Derivatives & Securities Financing Transactions (DSFT)

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Lesson Learning Objectives

This lesson will provide you with an understanding of DSFT.

After completing this lesson, you will be able to:

  • Define DSFT
  • List products that are in-scope for DSFT
  • Understand the governance structure of DSFT
  • Describe the risks associated with DSFT
  • Explain how Citi manages and constrains DSFT risk

Completion Criteria

This lesson contains a final assessment. You must score 80% or higher on the assessment to complete this lesson.

This lesson also includes an optional test-out. If you pass, you can bypass the lesson content and final assessment and exit the lesson.

If you prefer, you can skip the test-out and go straight to the content.

What are DSFT?

Who Seeks & Who Provides Financing for DSFTs?

Within Citi, we conduct DSFT activity globally across the firm, including Markets, Services and Wealth. However, the majority of DSFT activity takes place in Markets & Services – notably the Finance desk, the Securities Borrowing/Lending business, Prime Finance/Prime Brokerage, and in Treasury areas.

To proceed, select each market player to learn more.

Market Players Seeking Financing

Market Players Seeking Financing

Market players seeking financing include:

  • Hedge funds
  • Private equity funds
  • Broker/dealers
  • REITs
  • High net worth individuals

Market Players Providing Financing

Market Players Providing Financing

Market players providing financing include:

  • Asset managers/investors
  • Sovereign wealth funds
  • Insurance companies
  • Agent custodians

Principles for Inclusion

The way Citi defines DSFT transactions is through these three principles for inclusion.

To proceed, select each principle to learn more.

Extension of Credit
 

DSFT are transactions that provide an extension of credit to counterparties, including exposures reported and capitalized on a net basis under the Basel III capital framework.

They include Securities Financing Transactions (SFT) and margin finance transactions where the exposure is reported and capitalized under Basel III and includes both asset-side and liability-side activity as both sides require Citi to calculate exposures and hold capital.

In Return for Financing
or Borrowing
 

DSFT comprise transactions where Citi receives or provides securities, traded loans, or physical commodities, in return for financing or borrowing.

Total Return Swaps
 

DSFT encompasses Total Return Swaps or certain similar derivative transactions where there is implicit financing to the counterparty or Citi, of the reference asset.

In-scope Transactions

At Citi, certain types of transactions qualify as DSFT. You will explore what specific products are considered DSFT, as well as those that are out of scope from this framework.

To proceed, select each transaction to learn more.

 

Margin Financing

All margin type financing (e.g., reverse repo / stock borrow / buy-sell / margin loans and repo / stock lending / sell-buy / margin borrows), with collateral that is marked-to-market to reflect changes in the fair value of such collateral, where collateral is comprised of securities, traded loans, physical commodities, or baskets thereof, such as:

  • SFT and Margin Lending Transactions (long & short positions) under the Basel definition, whether eligible or not for netting
  • Collateralized loans that do not meet the Basel SFT and Margin Lending Transaction definition
  • SFTs where Citi acts as agent and its credit exposure is via indemnification (excludes non-indemnified)

Total Return Swaps

All Total Return Swaps (TRS), and structures with embedded TRS (“pay return” and “receive return”), that directly or indirectly reference securities, traded loans, physical commodities, or baskets thereof

Other Derivatives Financing

All other Derivative transactions or structures where Citi’s principal intent is to replicate the economic characteristics (from either a credit or funding standpoint) of an SFT or Margin Lending transaction (long & short positions) collateralized by securities, traded loans, physical commodities, or baskets thereof (e.g., Funded Collars, Prepaid Swaps), with principality of intent to be assessed by the DSFT Governance Committee

Committed Facilities

Committed Facilities providing the right to enter into a DSFT, as described above, which include:

  • Committed Repo Facilities
  • Committed Margin Lending Facilities (e.g., typically offered by Prime Finance and SES)

Variation Margin

Variation Margin received and delivered in the form of securities associated with derivative transactions.

Certain Forward Transactions

Forward Purchases and Forward Sales of securities, traded loans, physical commodities

Out of Scope Transactions

Now that you are familiar with what products are in-scope, let’s review the out of scope products for DSFT.

The following products and activities are out of scope:

  • Outright purchase and outright sale transactions (e.g., long or short Citi trading inventory)
  • The extension of credit in the form of a traditional secured loan (e.g., residential mortgages) or securitization
  • In general, Exchanged Traded Derivatives, Credit Default Swaps, and To Be Announced (TBA) Mortgages
  • Any Initial Margin associated with derivative transactions

However, similar to all other derivative activity, these activities will be reviewed to determine whether the principal intent of the trading strategy is to replicate the economics of an SFT or Margin Loan.

The DSFT Interpretive Group decides whether a transaction should be considered a DSFT. Any inquiries around interpretation of the definition should be emailed to *Citigroup GLOBAL DSFT Interpretation Group.

Key Businesses Transacting DSFT

View a snapshot of Key business in DSFT here.

New product types might be added subject to DIG approval.

DSFT Examples

Let’s look at some examples of DSFT to help your understanding.

To proceed, select the forward arrow to see some examples.

 

Example 1: Reverse Repo

A 1-month term reverse repo is a DSFT product.

On trade start date, Client pledges $100mm worth of US Treasury Bonds and Citi lends out $99mm US cash.

 

Example 1: Reverse Repo

Transaction is marked-to-market daily throughout the life.

On trade maturity date, Client will return US cash to Citi and Citi will return the US Treasury Bonds to the Client.

In this example, a reverse repo transaction facilitates client activity through funding their long inventory. Let’s take a look at another example.

 

Example 2: 1-Month Total Return Swap

A 1-month Total Return Swap (TRS) referencing the S&P 500 is a DSFT product.

On trade start date, there is no exchange of cash flows. The client agrees to pay SOFR in exchange for the return of the S&P 500.

 

Example 2: 1-Month Total Return Swap

Transaction is marked-to-market daily throughout the life.

On trade maturity date, the final settlement of cash flows occurs.

In this example, the client receives a return on S&P 500 without having to put up any initial capital.

A TRS is economically similar to a repo/reverse repo.

 
 

DSFT Key Risks

Now that you are familiar with what types of products are considered DSFT, let’s highlight the key risks.

In Citi, the DSFT portfolio is very large and diverse, comparable in size with Citi’s Banking Book portfolio. All regions engage in this activity across Citi’s Institutional Clients Group, Private Bank, Consumer Bank, and across various legal entities.

The size and breadth of this portfolio may create risks to Citi, especially in maintaining funding sources and the ability to quickly monetize collateral at times of stress.

To proceed, select each risk to learn more.

Maintaining funding sources
Ability to quickly monetize collateral at times of stress

Maintaining funding sources

The majority of DSFT activity is funded in the market through repos and, where Citi has legal right to do so, through re-hypothecation of financial instruments received as collateral or held as market risk hedges.

The risk:
An inability to maintain third party financing may require Citi to replace funding through alternative sources. Given the size of this portfolio, losing access to such funding sources is a key risk to Citi.

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Ability to quickly monetize collateral at times of stress

These extensions of credit are backed by collateral. Idiosyncratic counterparty defaults and systemic market failures could expose Citi to the risk of holding illiquid and/or concentrated collateral. In certain jurisdictions, the legal landscape may cause a delay in taking control of the collateral.

The risk:
Idiosyncratic counterparty defaults, collateral value depreciation and systemic market failures could expose Citi to the risk of holding illiquid and/or concentrated collateral. In certain jurisdictions, the legal landscape may impede our ability to take control of the collateral in a timely fashion. Such events may create challenges to Citi’s risk and funding profile, especially under stressed market conditions.

Coming Next

You’ve seen an overview of the main functions of Derivatives and Securities Financing Transactions (DSFT).

In the next section, you will learn about the framework that Citi uses to govern DSFT activity.

The DSFT Framework

Who Comprises DSFT Governance?

First, we will describe the governance that help Citi manage and control DSFT activity.

Access the DSFT Governance diagram here.

To proceed, select each group to learn more about their roles and responsibilities.

 

DSFT Oversight Group

The DSFT Oversight Group provides a senior management forum for governance, oversight, and challenge of DSFT activity, including reviewing the risk profile of DSFT activity, discussing pertinent risk issues across Citi concerning DSFT, and ensuring Citi’s DSFT strategic decisions are consistent with established risk appetite.

Liquid & Readily Marketable – Liquidity Oversight Council

The Liquid & Readily Marketable – Liquidity Oversight Council (LRM-LOC) is composed of related subject-matter experts who manage matters related to the design, use or implementation of the DSFT LRM (Liquid and Readily Marketable) and MPOR (Margin Period of Risk) decision trees. The LRM-LOC is also responsible for reviewing, approving and tracking all exceptions to these decision trees.

DSFT Interpretive Group

The DSFT Interpretive Group Group is composed of subject-matter experts from Business and Global Functions, tasked with adjudicating on the scope of the DSFT definition as it applies to new and existing products and transactions across the Markets, Services, US Personal Banking and Wealth (email: *CitiGroup GLOBAL DSFT Interpretation Group)

DSFT Identification Forum

The DSFT Identification Forum is composed of subject-matter experts from Technology, Business and Global Functions. It is tasked with maintaining the DSFT population by overseeing data controls, data quality, and DSFT population change control for new products.

1st LoD DSFT Governance Forum

The 1st Line of Defense (LoD) DSFT Governance Forum is composed of representatives from each of the DSFT business areas and an aggregate 1st LoD lead. The Forum’s purpose is to ensure that key responsibilities relating to the oversight of risks associated with DSFT activities are being met, including monitoring and escalating of DSFT risk-taking and proposing actions to the DSFT Oversight Group for approval where required.

How Does Citi Manage the Risk?

Now that you are familiar with the groups that oversee the risks that arise from DSFT, let’s explore how Citi constrains the scope and scale of this activity.

At the highest level, Citi’s risk management approach to the control and oversight of DSFT activity is the establishment of an overall portfolio risk appetite structure that all businesses transacting in DSFT activity must adhere to. These limits, which also have associated Management Action Triggers (MAT), consist of the following:

To proceed, select each limit to learn more.

DSFT Notional Limits
 

DSFT notional limits restrict the notional amount of cash and securities delivered or synthetically financed against DSFT collateral.

DSFT Risk Capital Limits
 

DSFT aggregate Risk Capital limits apply to the aggregate (long and short) DSFT portfolio and complement the notional limits with a risk-sensitive measure that captures key risk drivers and potential losses in extreme market conditions (at 99.97% confidence interval).

Setting Limits

DSFT Limits and Management Action Triggers (MAT) are set at least at the Citigroup, CBNA, CGMI and CGML levels. Consistent with Citi’s Risk Limit & Trigger Breach Procedure, DSFT limits and their associated MATs are designated a specific Category that dictates their respective breach and escalation protocol, which is detailed in the DSFT Governance & Oversight Framework.

In addition, the DSFT portfolio is included as part of the CCR Risk Pool under the Enterprise Concentration Risk Management Policy, with a series of sub-portfolio thresholds established to identify potential portfolio concentrations.

DSFT limits also exist within other Risk stripes, documented in their respective policies. For more information around Citi’s risk appetite approach around DSFT, including concentration risks, see the DSFT Governance & Oversight Framework.

Measuring Risk in DSFT

Review the Measures section in the diagram here.

Risks in DSFT activity are quantified across a number of different measures, such as notional size, potential future exposure, internal risk capital, Basel Regulatory capital, value-at-risk and stress testing, among others.

One of the most salient aspects of DSFT is Citi’s ability to net the exposure against the collateral. By doing so, we receive favorable regulatory capital treatment and reduce our credit exposure. There are a number of criteria that impact our ability to net. Two important ones are the absence of wrong-way risk and the ability to liquidate collateral under normal market conditions, both of which you’ll review next.

Wrong-Way Risk

Wrong-way risk arises when an exposure to a particular counterparty is positively correlated with the probability of default of that counterparty.

To proceed, select each risk to learn more.

Specific Wrong-Way Risk (SWWR)
General Wrong-Way Risk (GWWR)

Specific Wrong-Way Risk (SWWR)

Specific Wrong-Way Risk (SWWR) refers to wrong-way risk that arises when either the counterparty and issuer of the collateral supporting the transaction, or the counterparty and the reference asset of the transaction, are the same entity or have an equity ownership relationship of >25%.

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General Wrong-Way Risk (GWWR)

General Wrong-Way Risk (GWWR) arises when the probability of default of counterparties is positively correlated with general market risk factors (e.g., same industry sector, same country, same exposure to commodities).

Transactions Subject to Specific Wrong-Way Risk (SWWR)

For transactions subject to SWWR, obligor recovery is currently considered zero for both internal and Basel Risk Capital. When netting is eligible, collateral recovery is recognized.

General Wrong-Way Risk (GWWR) transactions are subject to conservative stress tests, but do not impact Basel Capital. Wrong-way risk transactions are subject to separate limits and escalation.

Liquid & Readily Marketable (LRM) Framework

If a security in a standard lot size can be liquidated under normal market conditions without “moving the market” (i.e., at given bid-offer levels), it is considered Liquid and Readily Marketable (LRM).

Citi has developed a firmwide decision tree-based LRM framework to:

  • Determine whether securities held as DSFT collateral, or that are the reference assets in a derivative in the DSFT scope, can be considered LRM, and if so,
  • Assign appropriate liquidation horizon (i.e., margin period of risk (MPOR)).

The LRM determination is relevant when measuring Counterparty Credit Risk (CCR), allocating Internal Risk and Basel Regulatory Capital because it impacts:

  • the ability to net the exposure against the collateral
  • how conservative the period of risk is in the exposure calculation.

The testing framework sequentially first determines whether a security is LRM, and then assigns that security an appropriate (MPOR) reflecting anticipated impact of stressed market conditions and position concentration on the product’s time to liquidation.

LRM Governance

To proceed, select each governance group to learn more.

Development (LRM WG)
Approval (LRM LOC)
Validation (Model Risk Management (MRM))
Maintenance (LRM LOC)

Development (LRM WG)

The LRM Working Group was established to draft and develop the LRM decision trees. This group includes key stakeholders from Finance (Capital Planning), FICC, & Market Risk, as well as the Business.

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Approval (LRM LOC)

The LRM Liquidity Oversight Council (LOC) is responsible for formally approving the LRM Decision Trees.

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Validation (Model Risk Management (MRM))

All LRM decision trees developed by the LRM Working Group are subject to model validation, per the model Risk Management Policy.

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Maintenance (LRM LOC)

The LRM-LOC is comprised of key stakeholders. The group was established to affirm approaches for LRM and MPOR determination and is also responsible for ongoing monitoring of the appropriateness of various thresholds and metrics related to the LRM framework.

The LRM-LOC reviews decision trees at least annually and escalates to the DSFT Oversight Group any matters requiring senior awareness, attention and/or decision with regard to the LRM framework.

Fixed Income & Equity Decision Trees

To conclude our review of the LRM framework, access the fixed income decision tree here.

The LRM framework first decides if a standard lot size amount of securities is Liquid & Readily Marketable and, if it is, then performs a concentration test to assign an appropriate margin period of risk. Any exceptions are raised in the LRM-LOC forum.

The detailed framework can be found here.

Stress Testing & Risk Capital for DSFT

Citi has developed DSFT-specific stress testing and risk capital models to capture downside risk in the portfolio.

To proceed, select the arrow to learn more about the approaches.

 

Methodology

Citi’s stress testing methodology captures:

  • Counterparty exposure stress (stress of the value of collateral and reference assets)
  • Counterparty risk stress (counterparty default/rating migration) and
  • Associated wrong-way risks

 

Scenarios

  • For stress testing, scenarios can be defined at varying degrees of granularity to meet more precise and tailored requirements. Scenario details can be accessed through a centralized scenario repository which contains current and historical scenarios.
  • For risk capital, standardized severe scenarios are used at the 99.97% confidence level.
 

Quick Reminder

The Three Lines of Defense include:

  • First Line of Defense is the business
  • Second Line of Defense is enterprise risk management
  • Third Line of Defense is Citi’s internal audit group

 
 

Coming Next

You’ve explored the DSFT framework in detail. In the next topic, you’ll examine the Lines of Defense, beginning with the First Line of Defense (LoD).

Managing DSFT Risk – First Line of Defense

First Line of Defense Control Framework Responsibilities

In managing DSFT, both Business and In-Business Risk have responsibility within the First LoD.

First Line of Defense Control Framework Responsibilities

  • The Business is responsible for the identification, measurement, control, monitoring, reporting, and management of risks relating to DSFT activities, and
  • Setting an effective control framework at both business and aggregate levels.

Where Are You in the DSFT LoD Structure?

Take a minute to review the First Line of Defense DSFT structure here and see where your role fits in.

Collateral Substitutability and Materiality

Adequate and proportionate controls are applied using a matrix to categorize the businesses into four categories, based on collateral substitutability and materiality:

  • Business materiality necessitates the need for more active and formalized in-business risk management
  • Collateral substitutability provides a client with optionality on the securities that are posted to secure a financing facility. Material optionality increases the inherent risk associated with collateral concentration and collateral liquidity, necessitating additional controls to mitigate against this risk.

What is the DSFT’s Role in the First LoD?

This categorization determines a set of standard business controls, which are supplemented by additional product-level and aggregate-level firmwide controls.

A quarterly attestation process is in place to ensure that these controls are implemented and applied comprehensively to the DSFT activities performed within the business.

To proceed, select each control factor to learn more about the First Line of Defense responsibilities.

Responsibilities
Identifying DSFT at inception

Responsibilities

The First Line of Defense responsibilities are:

  • Monitoring and managing aggregate-level DSFT activity against thresholds established by the Second line of Defense
  • Adhering to the Limit & Trigger Breach Protocol when thresholds are exceeded by:
    • Performing a deep dive analysis of the breach and confirming its validity
    • Creating and implementing a remediation plan with necessary approvals
  • Monitoring utilization against any First Line of Defense DSFT thresholds where relevant
  • Keeping the Second Line of Defense informed of material issues and potential risks

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Identifying DSFT at inception

The First line of Defense is responsible for identifying new DSFT activity and reporting it to the DSFT Oversight Group. The New Activity Policy and the Group New Activity (GNAC) processes include an assessment as to whether the new activity meets the definition of DSFT.

Any inquiries around interpretation of the DSFT definition should be directed to the DSFT Interpretive Group (DIG). The DIG is tasked with providing review and interpretation of PACs when there is ambiguity as to whether the activity should be considered a DSFT.

It is a key responsibility of the individuals designated as DSFT Risk Leads to liaise with the DIG on interpretations.

Controlling and Managing DSFT Risks

As you can see, the First Line of Defense has a number of key responsibilities in controlling and managing DSFT risks, since they are the group that executes these transactions.

Treasury’s Role in Managing DSFT

Citi has a comprehensive liquidity management framework, with metrics to measure, monitor, and manage liquidity risk. Liquidity management is governed by the Liquidity Risk Management Policy, which includes roles and responsibilities for Board-level and senior management committees such as the Asset & Liability Committees (ALCO), as well as two primary liquidity forums: The Funding & Liquidity Risk Committee (FLRC) and the Liquidity Model Review Committee (LMRC). Treasury, as the First Line of Defense, is responsible for developing, monitoring, and ensuring adherence to the liquidity management framework.

To proceed, select the forward arrow to learn about the key risks that Treasury considers.

 

Client Driven

Cash and collateral flows driven by client action outside the control of Citi that adversely impact our funding profile.

 

Counterparty Driven

Counterparties may take action which adversely affects Citi, such as refusing to roll funding trades or rolling at a higher haircut.

 

Market Driven

Cash and collateral flows driven by market movements or volatility, such as increases in variation margin or initial margin requirements.

 
 

How Does Treasury Control These Risks?

Treasury actively monitors and controls these risks by:

To proceed, select each control factor to learn more.

Creating Risk Frameworks

Creating Risk Frameworks

Creating risk frameworks to measure, model, and monitor DSFT risks and available mitigants

Calibrating Risk Appetite

Calibrating Risk Appetite

Calibrating Citi’s risk appetite for DSFT activity

Evaluating Potential New Activity

Evaluating Potential New Activity

Evaluating potential new DSFT business activity for risks

Mitigating and Remediating Exceptions

Mitigating and Remediating Exceptions

Mitigating and remediating exceptions to risk appetite, with partners in Liquidity Risk and the Businesses

Coming Next

Now that you are familiar with the role of the First Line of Defense in managing DSFT activity, you’ll learn about the role the Second Line of Defense plays in the next topic.

Managing DSFT Risk – Second Line of Defense

Credit Risk

Let’s look at the roles of Credit officers and Credit Risk.

To proceed, select the forward arrow to learn more.

 

Initial, interim and annual counterparty review templates

Credit officers are required to fill out a DSFT-specific section within the counterparty review template to attest to the DSFT exposure that relates to the specific counterparty.

Credit officers are also required to escalate, as necessary, any material DSFT-specific risks that pertain to that counterparty.

They have tools to drill down into DSFT data, perform ad-hoc analysis and monitor concentration risks.

 

Credit Risk

Credit Risk monitors DSFT activity across various measures, such as notional, PFE and risk capital for DSFT portfolios. DSFT specific limits are established on DSFT Notional. DSFT Risk Capital, Less Liquid collateral. DSFT is also monitored for liquidity and credit hotspots. LRM and MPOR, and output of DSFT Framework, is consumed in PFE and NSE calculations. Higher illiquid/Non-LRM collateral and higher MPOR increases the usage of these metrics. Additionally, Credit officers have to complete a DSFT section in credit memo for annual review.

Credit Risk also monitors collateral metrics such as specific and general wrong-way exposures, illiquid collateral (non-LRM), collateral margin period of risk, collateral issuer concentration and legal netting.

 
 

DSFT in Citi Private Bank (CPB)

CPB Risk Management has an extensive and comprehensive framework to manage credit risk that arises from extensions of credit to DSFT CPB clients under the Margin Lending (ML) and Global Capital Markets (GCM) product programs. The framework is governed by the Citi Private Bank Credit Policy Product Programs.

To proceed, select each program element to learn more.

Product Programs
Funding
Monitoring DSFT Activity

Product Programs

Product programs are subject to limits. Collateral haircuts (1 – loanable value) are approved based on volatility, liquidity, credit rating, and country risk. The haircut is in line with or more conservative than the supervisory haircut. Any exception requires the approval of independent risk.

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Funding

CPB does not re-hypothecate received collateral. Funding is obtained via Citi Treasury.

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Monitoring DSFT Activity

CPB monitors DSFT activity (ML & GCM) through portfolio reviews, concentration reports, CCAR stress testing reports, CitiRisk product stress testing, margin call reports, and margin shortfall, among others.

DSFT in Personal Banking & Wealth Management

DSFT activity in Retail is conducted under the Business GML (Global Margin Lending) RSR (Retail Credit Lending) policy, which sets specific margin lending risk appetite constraints and governance around this activity, such as monitoring GML program usage against limits, GML cross border usage against consumer limits, GML relationship and credit approval facility limit above business-designated thresholds (loan basis) and GML program/business risk appetite thresholds and limits.

The Retail GML program is subject to the Retail Credit Risk Policies/Standard that governs credit extension to Citigold and CPC clients. IBR (In Business Risk) monitors DSFT (GML) activity through portfolio quality reviews, global margin call reports, CCAR stress testing reports and aggregate GML reports, among others.

Collateral Risk in DSFT

Collateral risk is defined as risk of concentration and loss arising from the decline in value or inability to liquidate in timely manner the collateral securing or referenced in a DSFT transaction.

Inability or delay in liquidating the collateral upon a default of a DSFT transaction can result in potential exposure against the collateral issuer in the form of holding the collateral securities if the borrower also defaults and cannot honor its obligations.

To proceed, select each risk category to learn more.

Collateral Management
Contingent Collateral Exposure

Collateral Management

The Global Collateral Management Policy sets out the framework for the management of collateral, including DSFT, which considers:

  • Concentration risk
  • Growth in concentrations
  • Material correlations between collateral and counterparty
  • Collateral Rating Scorecards – which rate collateral strength based on Basel eligibility and adherence to the four core pillars of collateral risk management: valuation approach/independence, documentation strength criteria, legal enforceability in the applicable legal jurisdictions, and collateral control criteria

The Collateral Advisory Group (CAG) has a quarterly review process whereby it distributes a broad-ranging collateral reporting package to senior management and convenes a meeting for its review, with a view to providing guidance and strategic direction for the management of collateral and overseeing its execution.

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Contingent Collateral Exposure

Contingent collateral exposure is the potential amount of collateral Citi would need to liquidate if a borrower defaults. The collateral exposure is weighted by the probability of default of the borrower. It is captured in the Company Specific Citi Limit (CSCL) that measures and controls exposure across Citi to a single relationship under the Single Name Concentration framework.

Single name concentrations are monitored and managed by the Portfolio Management Group (PMG).

Market Risk in the context of DSFT

Market risk is broadly defined as the risk of loss arising from changes in market factors to which a party has a direct exposure.

Market liquidation risk is defined as the risk of loss arising from the inability to readily close out a position or market risk exposure without substantially affecting the asset’s price, thus resulting in unhedged market exposure which can result in losses caused by market fluctuations.

Risk has developed, updated, and implemented an enhanced risk management framework to manage DSFT activity. The Market Risk Limits Framework includes:

To proceed, select each framework component to learn more.

Enhanced LCI Pre-trade
Approval Process

Enhanced LCI Pre-trade Approval Process

Large, Complex or Illiquid (LCI) Pre-Trade

Market Liquidation Dashboard

Market Liquidation Dashboard

Market and credit risk

Enhanced Market Risk Reporting

Enhanced Market Risk Reporting

Market risk managers monitor enhanced MTM Right Desk and Issuer Risk reports to highlight DSFT

Legal Risk in DSFT

Citi Legal reviews legal agreements that relate to DSFT activity to determine whether the Well-Founded Basis (WFB) requirements are met. The WFB legal review process includes analyzing the enforceability of the agreement, close out netting provisions, existence of any stay risk upon counterparty bankruptcy, as well as walk-away clauses.

To proceed, select each WFB requirement to learn more.

Framework
Checklist
Reporting

Framework

A framework for determining WFB for certain agreements provides consistent standards and processes for meeting the WFB standard.

  • Basel III requires that a bank determine, with a well-founded basis, that it has the enforceable right to promptly exercise remedies/netting rights free from delay upon the default, including the insolvency of the bank’s counterparty.
  • The WFB review includes a jurisdictional analysis to determine whether Citi’s ability to exercise its rights would be delayed or restricted counterparty’s insolvency.

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Checklist

A WFB checklist for DSFT agreements should reflect the WFB analysis.

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Reporting

Reporting capabilities in Master Agreement Central (MAC) system capture data from the checklist for use in enhanced risk reporting.

Well-Founded Basis Process

Let’s look at the WFB process in more detail.

To proceed, select each process component to learn more.

Well-Founded Basis at a Glance
Well-Founded Basis Framework and Checklist Scope

Well-Founded Basis at a Glance

The Well-Founded Basis Standard or WFB Standard is a legal standard based on requirements set out in the Basel III regulatory capital rules that are designed to ascertain the risk that Citi’s netting rights and its rights as a secured creditor with respect to Covered Agreements (derivative contracts, repurchase agreements, reverse repurchase agreements, securities borrowing transactions, securities lending transactions, and margin loan agreements, whether documented under industry standard documentation or otherwise, including any related security or collateral agreements that are uploaded to MAC, as well as any Agreements outside of MAC that are identified to Legal by the DSFT Identification Forum) could be found to be ineffective under certain scenarios, including after the counterparty becomes subject to a bankruptcy, insolvency, liquidation or similar proceeding.

The WFB Standard is affected by and based on:

  • the terms and governing law of the relevant contractual agreements
  • the type and jurisdiction of the counterparty
  • Citi’s rights with respect to any collateral securing the transaction
  • the type of secured transaction
  • the applicable bankruptcy and other laws of the relevant bankruptcy jurisdiction(s)

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Well-Founded Basis Framework and Checklist Scope

The WFB Framework and checklist applies to Covered Agreements, where Citi is seeking:

  • Recognition of collateral for either reducing its exposure by the amount of collateral, and/or
  • Treating a set of transactions with a single counterparty that are subject to a Covered Agreement as a single “netting set” for purposes of determining the exposure amount for counterparty credit risk on the transactions (collectively, “E-C Treatment”)

Funding Liquidity Risk

Funding liquidity risk is the risk that the firm will not be able to efficiently meet both expected and unexpected current and future cash flow and collateral needs without adversely affecting either daily operations or financial conditions of the firm.

Liquidity Risk Process

In this situation, what process should be followed?

Risks embedded in and driven by DSFT transactions are captured via Citi’s liquidity risk management framework, which entails:

Liquidity Risk Management Policy

Risk appetite

Concentration analyses

Internal liquidity stress test (ILST) scenarios and metrics

Liquidity Risk Management Responsibilities

The responsibilities of Liquidity Risk Management, as Second Line of Defense, as it pertains to DSFT activity include:

  • Providing Second Line of Defense oversight of liquidity risk management processes, performed at the entity level through monitoring and escalation of liquidity risks, and liquidity risk management practices
  • Approving liquidity test assumptions and limits/triggers for liquidity risk metrics
  • Providing independent assessments of liquidity risk management processes
  • Approving relevant entity’s forecasts of liquidity metrics to ensure risk associated with planned funding or other Treasury actions are identified, and limits/triggers are set an appropriate level

Operational Risk Management’s (ORM) Role in Managing DSFT

Operational risk is defined as the risk of loss resulting from inadequate or failed internal processes, people and systems, or from external events. This definition of operational risk includes legal risk – which is the risk of loss (including litigation costs, settlements, and regulatory fines) resulting from the failure of the bank to comply with laws, regulations, prudent ethical standards, and contractual obligations in any aspect of the bank’s business – but excludes strategic and reputation risks. Citi also recognizes the impact of Operational Risk on the reputation risk associated with Citi’s business activities.

Operational Risk Management

Operational Risk Management (ORM) has two primary responsibilities in managing DSFT:

  1. Provide review and challenge of first and second line MCA content, which may include DSFT-related controls
  2. Report on operational risk events related to DSFT activities, as described in the Data Quality Standards

To proceed, select each ORM Reporting component to learn more.

 

Loss Capture System (LCS)

ORM has created functionality in the Loss Capture System (LCS) that allows users to classify operational risk events that are DSFT-related.

  • Users identify specific events as DSFT-related by using the ‘Event Channel’ functionality in LCS, which is a required field for each event entered into LCS.
  • The DSFT Flag is active in LCS.

DSFT Activity

DSFT activity should not result in “new” operational risks, as the underlying activity already occurs and any event (loss/gain) would be captured based on existing operational risk criteria.

  • An example would be a booking error in Delta-1 business that results in a loss of $1MM. Prior to DSFT, the event would have been captured and reported as a failure in the trade booking process. That same event now continues to be classified as a trade booking error and DSFT is an additional attribute of the event.
  • DSFT is an attribute of an operational risk event which is included in standard monthly reporting that ORM distributes; however, ORM also generates DSFT-specific reporting.

ORM: DSFT Reporting Approaches by In-Scope Business Areas

For each of the main business lines that are in-scope for DSFT activity, customized approaches are developed to account for current processes for identifying operational risk events. As would be expected, Markets & Services experiences the greatest number of DSFT-related operational risk events.

To proceed, select each reporting approach to learn more.

Markets
Services
Wealth

Markets

DSFT identification relies on the person inputting the event to correctly classify it as DSFT. The person may leverage in-business SMEs (e.g. Business Managers, Traders, In-Business Risk and Controls), or they may leverage a DSFT questionnaire that product areas use to assess DSFT applicability to New Product Activity.

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Services

The Private Bank process leverages In-Business Risk teams for investment finance and investment products to inform inputters when an event is DSFT.

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Wealth

DSFT identification leverages a detailed checklist based on event type (Basel designations) and the referral of events to a DSFT SME.

Coming Next

Now that you’re familiar with the roles of the First and Second Lines of Defense in managing DSFT activity, you’ll learn about the role the Third Line of Defense plays in the final topic.

Managing DSFT Risk – Third Line of Defense

Internal Audit

The Internal Audit function has designated Chief Auditors responsible for assessing the design and effectiveness of controls within the various business units, functions, geographies, and legal entities in which Citi operates, including specific Chief Auditors for Risk Management, Finance, and ICRM.

The purpose of Internal Audit’s attendance in the various committee meetings is to:

  • Act as an independent observer.
  • Allow Internal Audit to keep abreast of DSFT-related issues and of developments and communications with the regulators.
  • Provide analysis utilizing various audit techniques including audit reviews pertinent to compliance with the DSFT Governance & Oversight Framework.

In addition, Internal Audit is responsible for coverage of DSFT governance and activity as outlined within the DSFT Internal Audit assurance strategy.

Coming Next

You’ve learned all about the three Lines of Defense. Now please review the key takeaways in the conclusion that follows.

Key Takeaways

Recap of What You Learned

In this lesson you learned:

  • The definition of Derivatives & Securities Financing Transactions (DSFT)
  • The products that are in-scope for DSFT
  • The governance and oversight framework for DSFT
  • The key risks associated with DSFT activity
  • How Citi manages and constrains DSFT risks

If you would like to know more about this activity and to further explore the policies, processes, and frameworks that are impacting DSFT, as well as the roles and responsibilities the various functions across the three lines of defense play, select the Resources button in the top right corner of your screen.

Coming Next

Now it’s time to check your understanding of the content by completing a short assessment. Good luck!

Which group or forum decides whether a transaction is a DSFT?

Select the best response from the four options and then select Submit.

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Which of the following products are considered DSFT?

Select the best response from the three options and then select Submit.

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The most important key risks of DSFT include:

Select the best response from the four options and then select Submit.

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How many Lines of Defense does Citi have?

Select the best response from the four options and then select Submit.

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Which is the senior management forum for governance oversight and challenge of DSFT activity, including reviewing the risk profile of DSFT activity, discussing pertinent risk issues across Citi concerning DSFT, and ensuring Citi’s DSFT strategic decisions are consistent with established risk appetite?

Select the best response from the four options and then select Submit.

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The boundaries Citi has set to constrain DSFT include Limits and Management Action Triggers (MAT) for which of the following entities?

Select the best response from the five options and then select Submit.

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Which one of the following does the LRM Framework NOT develop criteria in the form of decision trees?

Select the best response from the four options and then select Submit.

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1st LoD uses a matrix to categorize the businesses transacting DSFT into:

Select the best response from the four options and then select Submit.

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What is the business responsible for within the First Line of Defense?

Select the best response from the five options and then select Submit.

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The Second Line of Defense includes Credit Risk, Collateral Risk, Market Risk, Market Liquidation Risk, Legal Risk, Funding Liquidity Risk and ___________________________________.

Select the best response from the four options and then select Submit.

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Home

Welcome
What are DSFT?
The DSFT Framework
Managing DSFT Risk – First Line of Defense
Managing DSFT Risk – Second Line of Defense
Managing DSFT Risk – Third Line of Defense
Key Takeaways
Assessment

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