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The scale of investments held by collective investment   default. Today, it may be argued that the proliferation   Another key by-product of this coalescence of
 vehicles (including UCITS) and their actual participation   of central clearing across many markets, combined with   several markets around the theme of collateral, is a
 in the lending markets (See Figs 3 & 4), continues to   the progressive rollout of the Uncleared Margin Rules   greater willingness to collaborate on joint initiatives,
 look unbalanced (with collective investment vehicles   (UMR) regulation in the derivatives world, is pushing   particularly in the technology space. ISLA has
 representing 44% of all lendable assets in lending   traditionally disparate markets ever closer.    already committed to work with other associations   The future of the CMU
 programmes whilst the latter is only 22%). In our   This manifests itself in a number of ways.   including ISDA on the development of a Common   and Brexit are somewhat
 manifesto that was published in December 2019   Domain Model (CDM), that will create cross-market
 (Securities Lending to Support More Autonomous EU   In a short paper published by the BoE on 10 June,   standards for the description of trading assets   intertwined, as the biggest
 Capital Markets: Priorities for the Next 5 Years), we   they observed that ‘Initial margin required by UK   and life cycle events. This will allow our collective   capital markets centre
 argued the need for policy makers and regulators to   CCPs increased in March, with the overall increase   members to develop products and solutions that are
 look closely at the link between the provision of market   peaking at 31% compared to the average requirement   underpinned by the agreed standards and protocols,   within Europe takes up
 liquidity and the long term success of the EU’s CMU   earlier in 2020’. They also noted that the provision   that in turn will drive efficiencies and cost savings   a new offshore status in
 project. We again highlighted the need to think actively   of margin helped ensure that derivatives markets   across the industry.
 about how the EU 27 can effectively mobilise liquidity   remained resilient throughout the recent market   the coming months. We
 across Europe, in our response to the report from the   shocks. However, they did caution that these large   As we turn towards the second half of this year and   have already seen the
 CMU High Level Forum published in June. Much of   movements of liquidity around the financial system   what 2021 might bring, it feels that many things we
 that shortfall continues to be assumed by Sovereign   contributed to a ‘dash for cash’, as some market   took to be the norm in January and February have   UK is unlikely to adopt
 Wealth Funds (SWFs), who today represent some 16%   participants had insufficient cash-like assets to   changed out of all recognition. Working from home   key elements of the
 of available securities and circa 29% of all loans globally.   meet actual or anticipated margin calls. This ‘dash   for instance, had mixed support and buy-in before the
 Their participation in the global securities lending markets   for cash’ and ‘cash like assets’ was seen in securities   pandemic. Today, this has become the mainstay of how   settlement discipline
 is a well understood feature of our markets, where   lending markets, as the demand to borrow HQLA   many firms and institutions function on a daily basis.   regimes within CSDR,
 liquidity provided (especially in fixed income markets) is   spiked significantly in March. The following volumes-
 an important source of trading and market liquidity.  based graph looks at the US Treasury markets, and   More broadly as regulators and policy makers begin   and is implementing the
 highlights how integral securities lending markets   to think about the longer term implications of the   SRD II through changes
 Collateral has always played an integral part in our   were to the continued provision of collateral assets   pandemic, we will see changes to policy and focus.
 markets, primarily as a risk mitigant against counterpart   within the system.  In Europe, we can already see how the sustainable   to existing UK legislation
        finance agenda is being increasingly seen as the   rather than the wholesale
        vehicle that the European Commission will use to
 Fig 5: US Treasury Bonds On-Loan    Source: DataLend  deliver COVID changes. From an ISLA perspective,   adoption of the Directive.
        our decision to create the ISLA Council for
        Sustainable Finance now seems increasingly timely,
 700B
        and will provide a strong platform for ISLA to engage   inconsistent regulation whilst offering opportunities for
        in this debate.                           some, also creates logistical and operational headaches
 US Treasury Loan Balance (Quantity)  600B  Europe takes up a new offshore status in the coming   Split jurisdictional and differing regulatory regimes are of
                                                  for firms that have significant footprints in both
        The future of the CMU and Brexit are somewhat
                                                   jurisdictional regimes.
        intertwined, as the biggest capital markets centre within
        months. We have already seen the UK is unlikely to
                                                  course nothing new, but it should be remembered that
                                                   less harmonisation tends to lead to one thing, additional
        adopt key elements of the settlement discipline regimes
        within CSDR, and is impementing the SRD II through
                                                  the form of charges we pay for everything, from cross-
        changes to existing UK legislation rather than the
                                                   border mobile phone roaming charges, to management
        wholesale adoption of the Directive.. This of course   costs. Ultimately, these will filter down to all of us in
 500B
 Jan 20  Feb 20  Mar 20  Apr 20  May 20  Jun 20  Jul 20  was not necessarily unexpected, but fragmented and   fees on our investment and pension portfolios.
 14  * See Data Methodologies for full details on page 50                               15
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