AFTAs 2017: Best Risk Management Initiative—TD Securities

CMOS was built to allow TD to comply with new variation margin (VM) rules for non-centrally cleared OTC derivatives that went into effect on March 1, 2017. It will also help the bank to adhere to initial margin (IM) requirements that will come into force at the beginning of September 2018. 

“It was a massive undertaking in the industry. The platform that we had, Century, wasn’t compliant with the regulations,” says Stephen Neal, a director at TD Securities. “Looking at it strategically, what are the other roles that we’re going to see being plagued by collateral management and margining going forward? You start looking at things like cheapest-to-deliver, cheapest-to-post, optimization, and the cost of funding. When we started seeing all of these other requirements and areas of concern, we realized that we had to build a strategic system to not only meet the regulation, but to really enable us to move forward.”

The collateral risk management platform was built with Lombard Risk’s Colline solution at the heart of the system with proprietarily-built microservices feeding into the hub and out to other platforms within the business. CMOS extends beyond over-the-counter (OTC) derivatives and is now live with US mortgage-backed securities (MBS), while securities lending and repos support will be added in the near future, Neal says. 

The platform supports real-time updates for intra-day margining and better management of risk limits. Collateral can be valued either on an intra-day or end-of-day basis, using pricing hierarchies. Built in are straight-through processes to support low-touch, exception-based business processes, which, according to Neal, has helped the firm to grow its client base as the onboarding process has been streamlined. It also provides the ability to calculate margin based on either market-standard or posted-collateral valuations. And, importantly, it is fully integrated with other internal downstream risk and reporting systems and external vendors, such as AcadiaSoft and Nex Group’s TriResolve. 

Coming next September are the IM requirements for uncleared swaps. Neal says that without this system, “there is no way we would have been able to be flexible enough to be able to support things [that] we’re having to do for initial margin [calculations].”