At the end of March 2021, Archegos Capital Management collapsed under the weight of bets it had placed using Total Return Swaps (TRS) that went wrong. Their excessive leverage on TRS, accompanied by shortcomings in risk management, meant that when it went down it inflicted billions of dollars in losses on the banks that had lent it the money to trade the TRS.
It had been using TRS to make leveraged bets in the equities market. Using only a small portion of its own money, and getting its bankers to fund the balance, Archegos was able to make huge bets on equities. The key for the banks was collateral. As long as Archegos had pledged collateral to cover its bets, the lending banks felt they were covered. For Archegos, this was easy … they just pledged the shares they had bought with the TRS. If Archegos ran into trouble on the TRS, the banks in theory would just sell off these shares to recover the money they were owed. Clearly most of these derivatives trades don’t go wrong and banks make money on fees and commissions funding them.
The role of prime brokers
Four major banks were acting as prime brokers for Archegos. Prime brokers are more common in the US than they are in the rest of the world. The broker not only executes the derivatives trades but also funds the trade and receives fees for doing so. Most of the funded trades are backed by securities – as was the case with Archegos. They had pledged the equities they bought as collateral. But it seems that as some of the banks’ clients generated more business, they were less stringent on collateral requirements.
In Archegos’ case, it used multiple prime brokers and was able to take advantage of this to increase its funding. The net result was a highly leveraged trading firm whose overall credit risk no one seemed to be monitoring. Archegos used all of this credit to build up huge TRS positions on a variety of corporations. When prices of their shares started to fall, the prime brokers did what they were supposed to do, they sold the collateral, i.e. they sold the shares that Archegos had pledged for the TRS. And as anyone who’s traded with leverage will know, when you’re that highly leveraged, the price falls don’t need to be that big for it to erode your capital. The prime brokers kept selling and Archegos went down.
Risk management failure
Archegos was a failure of risk management. All aspects of it: credit risk, market risk and operational risk. It was lax risk management that allowed the build-up of such leveraged positions by Archegos. The family office model, the lack of oversight by the prime brokers, the fact that notional positions were built up across multiple prime brokers, and the fact that it was the shares underlying the TRS that were being used as collateral; all of this allowed the build-up of highly leveraged positions, apparently without much oversight.
The regulatory framework written after the 2008 financial crisis was designed to prevent such gaps in risk management. In the US, the regulation that should have prevented the build-up of such leverage was the Dodd-Frank Act of 2010. But the implementation of some of its most important parts have been delayed multiple times, with many saying that had the Securities and Exchange Commissions (SEC) fully implemented the rules much of the loss could have been prevented.
The regulatory background post financial crisis:
In March, 2008 the Bank for International Settlements (BIS) hosted the Financial Stability Forum (FSF) to discuss the deepening global financial crisis. This meeting spawned several initiatives:
- The FSF was replaced by the Financial Stability Board
- The Group of Seven (G7) forum became the Group of Twenty (G20)
- Changes to the international banking regulatory regime were initiated which led to the accord known Basel II.5 (or Basel 2.5).
- A major overhaul of banking regulation in the US which became known as The Dodd Frank Act
The Dodd Frank Act
In June 2009, not long after being elected president, Barack Obama proposed a “sweeping overhaul of the United States financial regulatory system, a transformation on a scale not seen since the reforms that followed the Great Depression”. Congressman Barney Frank and Senator Chris Dodd introduced the legislation triggered by Obama’s proposal in 2010. The legislation became known as the Dodd-Frank Act
The Basel Committee for Banking Regulation
Basel II was the global accord on regulation for banks written by the Basel Committee on Banking Supervision (BCBS). It was introduced in 2004 and contained the rules for calculating banking capital, the minimum capital standards for capital and the supervisory review regime for monitoring capital adequacy. The predecessor to Basel II was the 1988 Basel I accord. The Basel accords focus broadly on three types of risk, credit risk, market risk and operational risk. The market risk framework relates to capital calculations and standards for banks that trade in financial markets
Basel II.5, Basel III and FRTB
The Basel II.5 document was focused on market risk capital standards. Its introduction describes how trading in the financial markets was a major source of the build-up of leverage and of the resulting high losses experienced by banks during the crisis. A driver of many of these losses was the fact that the existing Basle II market risk framework did not capture some of main risks that banks were exposed to. In 2012, the first version of the BCBS document “The Fundamental Review of the Trading Book” was published. This contained proposed revisions to the market risk rules that had been published in Basel II.5. The document was much wider in scope than its Basel II.5 predecessor. It contained a prescriptive set of rules, calculation logic and controls that banks who traded in financial markets would need to implement. The document became known as FRTB.
Could the Archegos collapse have been prevented with proper risk management?
Yes. As discussed, the Archegos collapse was a failure of risk management. Readers who are familiar with our data management white paper and blog series on the centrality of data for risk management will be aware of concepts such as:
- A centralized view of counterparty exposures via an entity master. For example, see our posts on client/entity data challenges and integrated customer data management
- The importance of being able to aggregate risk exposure across multiple domains
- The need for accurate and reliable pricing of the inventory within a financial institution. For example, see our post on the SEC Fair Valuation Rule
- Having a data centric view of risk as the bedrock of the firm’s market risk framework
The failure of risk management was central to the Archegos collapse and the lack of enforcement of regulation was central to the risk management failures. At GoldenSource we have consistently been saying that data is central to risk management. A centralized view of legal entity exposures, clean and validated risk and time-series data, and accurate pricing are all critical to effective risk management.
Boards of directors and regulators (in the form of National Competent Authorities, NCA) always learn from the latest event that fell through the cracks of governance, oversight and risk management. While Archegos won’t be the last financial firm to fail, it should be the last to fail because of this particular combination of factors.