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US Government Debt Different - Finance Department - University of ...

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Richard SquireSo far, there is little evidence that such “correlation-seeking” activityis occurring in the market for CDS on <strong>US</strong>A. But regulators shouldbe aware <strong>of</strong> the hazard and monitor protection sellers accordingly,rather than proceeding under a mistaken assumption that a tightlink between the solvency <strong>of</strong> the <strong>US</strong> Treasury and the solvency <strong>of</strong>protection sellers means that demand for CDS on <strong>US</strong>A will alwaysbe negligible.71The Size and Function <strong>of</strong> Markets for CDS on <strong>Government</strong> <strong>Debt</strong>At the end <strong>of</strong> 2011, the gross notional value <strong>of</strong> outstanding CDScontracts worldwide was $28.6 trillion. 1 Of this amount, only $3.0trillion, or 10.5%, referenced government debt. 2 If, however, we lookat the market in terms <strong>of</strong> reference entities (that is, the borrowerswhose debts are referenced in the contracts), sovereign debt becomesmore important: in weekly lists <strong>of</strong> the ten largest reference entitiesby notional amounts, sovereign borrowers consistently represent alarge majority. 3 Protection sellers, in turn, tend to be large financialinstitutions, with just over half <strong>of</strong> all government-debt CDS writtenby five firms: Deutsche Bank, Goldman Sachs, Barclays, Citigroupand Bank <strong>of</strong> America. 4<strong>Government</strong>-debt CDS serves several potential functions for protectionbuyers, including the following:• Regulatory capital compliance: Banks that operate under minimumcapital regulations may be required to hold more capitalif, instead <strong>of</strong> investing in assets deemed safe, they invest in sovereigndebt with a low credit rating. This regulatory penalty canbe avoided, however, if the bank “covers” the debt by purchasingCDS from a highly rated protection seller. 5 By definition, this1 Bank for International Settlements, Credit default swaps, by sector (2011), http://www.bis.org/statistics/otcder/dt25.pdf. The “gross notional” amount is the total facevalue <strong>of</strong> outstanding CDS contracts without accounting for <strong>of</strong>fsetting positions.2 Id.3 Depository Trust & Clearing Corporation (DTCC), Trade Information WarehouseData (Section IV), http://www.dtcc.com/products/derivserv/data_table_iv.php (last visited Oct. 25. 2012).4 Creditflux, CDS League Tables (2011), http://www.creditflux.com/Data/.5 D. Andrew Austin & Rena S. Miller, Treasury Securities and the <strong>US</strong> SovereignCredit Default Swap Market, Congressional Research Service Report for Congress(Aug. 15, 2011), http://www.fas.org/sgp/crs/misc/R41932.pdf.

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