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Deloitte Operations IBOR Transition Forum April 2020 Nomura - Change as a Service – October 2019

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Page 1: Deloitte UK IBOR Transition Operations Forum

Deloitte Operations IBOR Transition Forum

April 2020Nomura - Change as a Service – October 2019

Page 2: Deloitte UK IBOR Transition Operations Forum

2

Agenda – Operations IBOR Transition Forum

1. COVID-19 impact on IBOR Transition

2. IBOR Transition market update

3. Testing impact

4. Our IBOR team

Slides 4-5

Slide 7

Slides 9-12

Slide 14

Page 3: Deloitte UK IBOR Transition Operations Forum

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COVID-19 impact on IBOR Transition

Page 4: Deloitte UK IBOR Transition Operations Forum

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COVID-19 impact on IBOR TransitionHow the recent outbreak may affect the current progress of the IBOR Transition globally

Client impact

Impact on client communications, inbound queries and method of client

outreach

1

Programme governance

How will governance and workstreams continue to operate under current

COVID-19 conditions?

2

Resourcing

How do you continue with planned ramp up and onboarding of team

members to meet workload?

3

Refinancing

How is LIBOR transition being factored into the suitability of refinancing and

restructuring products?

4

Vendors & Infrastructure

How may COVID-19 have an impact on timelines and activity?

5

Programme risk

COVID-19 should be added to your LIBOR risk registers

6

We will discuss the impact of COVID-19 on the IBOR Transition and how changes may need to be considered over the next 6 months. Werecognise the fact that firms need to ensure there is consistent messaging from regulators now that there may be a desire for ‘extensions’.

In addition, there are further considerations which should be factored into future decision making:

Page 5: Deloitte UK IBOR Transition Operations Forum

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COVID-19 impact on IBOR TransitionHow could the market be impacted over the next 6 months if the BoE change the deadlines?

As this whole transition is happening in coordination with other jurisdictions across the globe (e.g. through the work of the Official Sector Steering Group (“OSSG”)), moving targets relevant to GBP LIBOR may inevitably, impact the targets and timelines from other jurisdictions, for other LIBOR currencies.

Whilst there are five LIBOR currencies, and five regulatory convened working groups, each with their own specific considerations on LIBOR transition within their own jurisdictions, transitioning these LIBOR rates requires similar efforts across all jurisdictions (RFR market development, customer outreach, contract re-papering, IT system development etc.). Moving targets in relation to one currency therefore, can impact on the pace of transition in others, including the US, given the extensive use of USD LIBOR across the globe.

How will it affect the international push away from the benchmark, especially in the US?

Caution should be exercised in the use of the word “deadline”. There aren’t “deadlines” – regulators, such as the BoE (in respect of GBP LIBOR), have set transition targets (e.g. the non-issuance of GBP LIBOR cash products by end of Q3 this year).

Amending these target dates further is important:

1. Firms, notably regulated firms, will have developed plans and actions in order to meet the targets as currently stated

2. There are notable external dependencies, which would need to be considered e.g. IT systems and 3rd party vendor infrastructure

3. Should targets move, there could be implications to the depths of liquidity in newly developed RFR markets

If the BOE pushes back Libor transition deadlines, why will this matter?

Page 6: Deloitte UK IBOR Transition Operations Forum

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IBOR Transition market update

Page 7: Deloitte UK IBOR Transition Operations Forum

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IBOR Transition market updateWhat is the latest news in 2020?

NAMEMEA EMEA

FSB letter – February:

o The Financial Stability Board (FSB)

published a letter to the G20, welcoming its

focus on LIBOR transition as a priority for

this year

o The G20 letter was sent to emphasise the

need for progress in 2020

ISDA Documentation – March:

o ISDA published the results of the

Consultation on documentation fallbacks

for Derivatives referencing EUR LIBOR

and EURIBOR

o As per ISDA's prior consultation, the

majority of respondents agreed with an

implementation based on €STR

Swaptions update – February:

o The EUR RFR WG has launched a

consultation on swaptions (legacy and

new)

o This was based on EUR products that

could be affected by the discounting

change for cleared derivatives from the

use of EONIA to €STR effective

BoE & FCA letter – March:

o A joint letter from BoE and FCA was sent to

trade associations on how LIBOR transition

will affect their stakeholders and next steps

o FCA and BoE asked trade associations to

help raise awareness among their networks

HMRC tax impact – March

o The HMRC has issued draft guidance and a

consultation on the tax impacts arising

from LIBOR discontinuation and other

benchmark reform

o The response deadline is 28th May 2020

LIBOR linked collateral – March:

o BoE has announced that from Oct 2020, it

will make newly-issued LIBOR-linked

collateral ineligible and progressively

increase the haircuts on existing LIBOR-

linked collateral it lends against

SOFR publication – March:

o From March 2020, the Federal Reserve

Bank of New York, as administrator of

SOFR, began publication of 30, 90, and

180days SOFR compounded averages

o They also started publishing the SOFR

index

Spread Adjustment – March:

o The ARRC has extended the deadline for

responses to its consultation on Spread

Adjustment Methodologies to 25 March

2020

APAC

JFSA Survey – March:

o The JFSA released the results of its

LIBOR survey showing views of progress

in the region

Singapore key priorities – March:

o The Association of Banks in Singapore

has set out its key priorities to achieve a

smooth transition from SOR to SORA

along with a roadmap for 2020 to 2021

LCH update – March:

o LCH has confirmed they see no reason to

deviate from the timeline they have

previously communicated

o However if members were to advise of

challenges they would consult and consider

adjusting their approach

Page 8: Deloitte UK IBOR Transition Operations Forum

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Testing Impact

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Business Challenges – Making Informed Decisions on IBOR Transition

How can business stakeholders understand the risks to their day to day operations

Business Risk

Mitigation

How can I understand the resource and operational impacts of the IBOR Transition to my Business?

How do I protect my operational services from impact during or after the IBOR Transition?

A change programme such as LIBOR will produce reams of data and information that provides views on how the programme will be executed, when business functions will need to be available and what the impacts on front to back processing will be. But how can this be translated into

a true business view? How can it be used to react to the ever changing nature of the programme with sufficient time to minimise impacts?

Depending on the IBOR transition approach the business engagement will vary, with different demands and considerations based on resource availability, impacts of critical periods in the year and ability of non business stakeholders to be able to articulate ‘what good looks like’.

Defining an interlocking approach to acceptance for a business function and into the IT team are key for an efficient and appropriate approach.

Test Reporting

/ MI

Central Co-

Ordination

AI Driven Insights

Business Process Driven

Coverage

Quality Gating

Processes

UAT Co-Ordination

& Execution

Parallel Run

Live Proving &

Fix Forward

Page 10: Deloitte UK IBOR Transition Operations Forum

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Business confidence will require a pragmatic, efficient and clear approach to validation

Replacing IBOR – Front to Back Testing

IBOR will require banks to update their systems, processes and tools across their F2B business and technology structure. The activities required to provide confidence in the accuracy of such changes across multiple internal and external systems is complex and requires careful planning and communication.

Front

Office

Pre-Trade

Trade Capture

Data

Pro

vid

ers

Matc

hin

g

Pla

tfo

rm

s

Fin

an

ce

Rep

ortin

g

Simulation Views

Risk

Credit Risk

Market Risk

Limits Management

Ops

Trade Validation

Trade Confirmation

Settlement &

Clearing

Finance

Hedge Acc

Finance Accounting

Reg Reporting

Ris

k S

yste

ms

Paym

en

ts

Pric

e F

eed

sT

rad

e R

ep

osito

ry

Exch

an

ge

Testing of FO systems to ensure trade capture and booking systems are able to book trades with new ARR referenced products/configuration changes.

Aim for early testing of the FO systems for new calculations, coupon payments and pricing of new trades by using automation of Pricing Feeds and Simulations.

The risk models, valuation and discount models will need to be validated for the accuracy of curves, trade analytics and trade pricing, along with Fund Transfer pricing

Automate the testing of risk management workflows; use machine learning and AI to predict the generation of new price curves and then use them to test risk and valuation modelling.

Testing of Treasury management and supporting platforms to enable balance sheet funding, hedge accounting and cash-flow forecasting.

Establish a robust test data framework which supports the enablement of fully automated data management by filling gaps in available production data.

Failure to test the existing validation flow can mean trades not being settled and cleared in time, leading to delays in payments and regulatory breaches.

Harness business and SME experience in creating integrated F2B environments and containerized third party interfaces using service virtualization to allow for shorter and quicker test cycles.

Valu

e

Challenges Suggested Approaches

Page 11: Deloitte UK IBOR Transition Operations Forum

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UAT Testing Approach – Approach 1 (Full Front to Back testing by product)

• Front to back testing of high impact products for day 1. Other medium and low impact products in later phases of testing

• System testing and System Integration testing to be executed by IT Test teams with help from BAs. UAT testing by business in a phased approach

• All workstreams need to be involved.in all phases.

• Risk-based approach to testing which results in high quality and minimum impact

• Business users trained and reusable test cases created for next phases of the IBOR programme

• Proven front to back flow testing providing confidence and requirement of minimal testing for later stages.

F2B SIT

Product 1 Product 2 Product 3 Product 4

F2B UAT

Build Build BuildBuild

Design Design DesignDesign

Unit Testing Unit Testing Unit TestingUnit Testing

System Testing

System Testing

System Testing

System Testing

IT T

eam

sIT

Test

Team

s,

BA

Busin

ess

Period 3Period 1 Period 2

Test Data

Approach

Environment

Risks

Time

• Risk to timelines : High

• Risk to test coverage : Medium

• Front to Back environment required with most interfaces integrated and all third party environments aligned

• All batches required to test finance reporting. Testing of month end and EOD reporting

• Test data required for all workstreams front to back, a combination of synthetic and available data from production will likely be used.

• All F2B data feeds and interfaces required for FO, OPS, Risk and Finance

Advantages

• Smaller SIT and UAT test cycles

• More time required for test coordination during the test phases.

F2B SIT

F2B UAT

F2B SIT

F2B UAT

F2B SIT

F2B UAT

Front to Back Testing of individual product flows across the applications stack

Page 12: Deloitte UK IBOR Transition Operations Forum

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UAT Testing Approach – Approach 2 (Front Office to Ops, separate Risk & Finance test)

SIT

Front Office Ops Risk Finance

UAT

Build Build BuildBuild

Design Design DesignDesign

Unit Testing Unit Testing Unit TestingUnit Testing

System

Testing

System

Testing

System

Testing

System

Testing

IT T

eam

sIT

Test

Team

s,

BA

SIT

F2B SIT

UAT

F2B UAT

Period 3Period 1 Period 2

• System changes and testing per workstream. E.g. Changes to front office and Ops systems in phase 1. Risk and finance in later phases based on data feeds from phase 1

• UAT testing by business per workstream

• All workstreams need not to be involved in all phases of testing

• Early testing of the front office functions allows more complex and critical testing to complete first

• Test results from the front office and Ops can be replayed to test other back office and finance reporting tests.

Test Data

Environment

Risks

Time

• Risk to timelines : Low

• Risk to test coverage : High

• Full Front to Back environment is not required allowing asset classes to focus on internal integrations

• The environment when built will be required for a longer duration

• Limited test data required. Reusable test data available from initial phases of testing which can be replayed for next phases

• More up front effort to specify specific data required for Risk and Finance

• Longer SIT and UAT cycles

• Test coordination require less effort in initial phase with increasing requirement of skills and resources in later phases

Busin

esss

Front-to-Middle testing of all the products and events followed by integration into back office functions

Approach

Advantages

Page 13: Deloitte UK IBOR Transition Operations Forum

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Meet the team

Page 14: Deloitte UK IBOR Transition Operations Forum

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Our IBOR Team

Meet the team

Mark Cankett

Audit and Assurance PartnerLondon

[email protected]

+44 7810 657468

Ed Moorby

Risk Advisory PartnerLondon

[email protected]

+44 7803 619121

Stephen Farrell

Audit and Assurance PartnerLondon

[email protected]

+44 7775 798493

Neil Brown

Consulting Partner (Testing)London

[email protected]

+44 7780 712972

Mike Hill

Consulting Director (Testing)London

[email protected]

+44 7760 991374

Page 15: Deloitte UK IBOR Transition Operations Forum

This publication has been written in general terms and we recommend that you obtain professional advice before acting or refraining from action on any of the contents of this publication. Deloitte MCS Limited accepts no liability for any loss occasioned to any person acting or refraining from action as a result of any material in this publication.

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