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If SNB made a crisis on January 15, 2015, then Saxo Bank made itself (and its clients) a bigger crisis on the day.
From another page:
http://www.garp.org/risk-news-and-resources/risk-headlines/story.aspx?newsId=129462
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Ada Reynolds 3/2/2015 9:17:13 PM
Fellow GARPs, this Saxo Bank crisis should be well documented as a case study. From risk management prospective, Saxo Bank committed a big mistake.
1. In its FX business, Saxo Bank makes prices to clients on FX spot, forward and options. That means Saxo Bank is having a principal-to-principal relationship with clients. On their trading platform, the prices are all tradable, and it forms an "offer". Once the trade is executed on the trading platform, via clients' action, or orders triggered, that constitutes an "acceptance". With "offer" and "acceptance", that is a contract sealed. For whatever reason that one side manipulate the details of the transaction (here it is price), it is a breach of contract. The new price of the contract has no legal power to be enforced because the content is not mutually agreed.
2. In its letter explaining the methodology of the “re-pricing”, Saxo Bank is confusing itself as an agent. In this business, Saxo Bank is actually the sole market maker from clients’ perspective. There are no other markets. If Saxo Bank explains its methodology with reference to EBS, the client agreements have to be re-written that Saxo Bank acts as an agent and all trade flows (spot and forward) goes to EBS (and Saxo Bank bears no responsibility on the fills), and each and every trade confirmation with EBS has to be sent to clients. However, it still cannot solve Saxo Bank’s problems in options because it cannot find a sizable marketplace for options similar to EBS.
3. The key problem of Saxo Bank is its risk control on pricing. As a market maker, Saxo Bank has full discretion to quote a price on its trading platform. The bid price it quote to clients is the price Saxo Bank willing to buy from clients, and the ask price it quote to clients is the price Saxo Bank willing to sell to clients. Therefore, always, Saxo Bank should display a price that it is willing to do buy and sell (for this part the Trading department takes the blame, then the Risk Management department). It cannot first quote clients a price and then twelve hours later tell clients that, sorry, we are going to change your transacted price to another price blah blah blah.
4. Another highlight of the incidence, from a risk management perspective, is how Saxo Bank manages its FX exposure. If clients are selling CHF, to avoid depreciation of the CHF, Saxo Bank should have shorted a certain amount of CHF with its own trading counterparties. Did Saxo Bank get out of its hedge positions before it cut clients’ margin positions? Would it be possible that Saxo Bank got hit by betting bigger than clients and then transferred the losses to clients by manipulating clients’ positions?
Ada Reynolds 3/2/2015 9:35:14 PM
Another key study in the Saxo Bank crisis is how we look at Counterparty risk. Saxo Bank does trade with another entity in order to hedge its exposure from clients. Is Saxo Bank evaluating its trading counterparties sufficiently? Would anyone of them dishonored trades with them (same way as they do to clients)? Is the contract terms able to protect Saxo Bank from being dishonored on trades which they can profit from? Besides counterparty risk, how about liquidity risk? Did Saxo Bank has a too big concentration exposure on CHF (compare to the potential liquidity that is available) such that it cannot hedge its own exposure in good prices? With Saxo Bank claiming low liquidity in the EURCHF pair, do they have a plan to trade USDCHF and EURUSD separately?
From another page:
http://www.garp.org/risk-news-and-resources/risk-headlines/story.aspx?newsId=129462
There are 2 comments.
Click here to view.
Ada Reynolds 3/2/2015 9:17:13 PM
Fellow GARPs, this Saxo Bank crisis should be well documented as a case study. From risk management prospective, Saxo Bank committed a big mistake.
1. In its FX business, Saxo Bank makes prices to clients on FX spot, forward and options. That means Saxo Bank is having a principal-to-principal relationship with clients. On their trading platform, the prices are all tradable, and it forms an "offer". Once the trade is executed on the trading platform, via clients' action, or orders triggered, that constitutes an "acceptance". With "offer" and "acceptance", that is a contract sealed. For whatever reason that one side manipulate the details of the transaction (here it is price), it is a breach of contract. The new price of the contract has no legal power to be enforced because the content is not mutually agreed.
2. In its letter explaining the methodology of the “re-pricing”, Saxo Bank is confusing itself as an agent. In this business, Saxo Bank is actually the sole market maker from clients’ perspective. There are no other markets. If Saxo Bank explains its methodology with reference to EBS, the client agreements have to be re-written that Saxo Bank acts as an agent and all trade flows (spot and forward) goes to EBS (and Saxo Bank bears no responsibility on the fills), and each and every trade confirmation with EBS has to be sent to clients. However, it still cannot solve Saxo Bank’s problems in options because it cannot find a sizable marketplace for options similar to EBS.
3. The key problem of Saxo Bank is its risk control on pricing. As a market maker, Saxo Bank has full discretion to quote a price on its trading platform. The bid price it quote to clients is the price Saxo Bank willing to buy from clients, and the ask price it quote to clients is the price Saxo Bank willing to sell to clients. Therefore, always, Saxo Bank should display a price that it is willing to do buy and sell (for this part the Trading department takes the blame, then the Risk Management department). It cannot first quote clients a price and then twelve hours later tell clients that, sorry, we are going to change your transacted price to another price blah blah blah.
4. Another highlight of the incidence, from a risk management perspective, is how Saxo Bank manages its FX exposure. If clients are selling CHF, to avoid depreciation of the CHF, Saxo Bank should have shorted a certain amount of CHF with its own trading counterparties. Did Saxo Bank get out of its hedge positions before it cut clients’ margin positions? Would it be possible that Saxo Bank got hit by betting bigger than clients and then transferred the losses to clients by manipulating clients’ positions?
Ada Reynolds 3/2/2015 9:35:14 PM
Another key study in the Saxo Bank crisis is how we look at Counterparty risk. Saxo Bank does trade with another entity in order to hedge its exposure from clients. Is Saxo Bank evaluating its trading counterparties sufficiently? Would anyone of them dishonored trades with them (same way as they do to clients)? Is the contract terms able to protect Saxo Bank from being dishonored on trades which they can profit from? Besides counterparty risk, how about liquidity risk? Did Saxo Bank has a too big concentration exposure on CHF (compare to the potential liquidity that is available) such that it cannot hedge its own exposure in good prices? With Saxo Bank claiming low liquidity in the EURCHF pair, do they have a plan to trade USDCHF and EURUSD separately?