The TRADE 51 | Page 80

[ T H E B I G P I C T U R E | A R E A S S E T The concept of cash-rich buy-side firms lending to each other is gaining momentum.” MARK HIGGINS, MANAGING DIRECTOR FOR EMEA BUSINESS DEVELOPMENT, BNY MELLON MARKETS becoming reliable sources of liquidity. Krol acknowledged market making was happening but on a small scale. “Again, it is the largest managers who are thinking about it rather than the mid-sized organisations,” he said. It is critical that regulators think carefully 80 TheTrade Spring 2017 M A N A G E R S S I F I s ? ] if they choose to impose additional oversight on asset managers. A number of national competent authorities are already review- ing these new practices at asset managers. Securities lending has certainly caught the attention of the US Securities and Exchange Commission (SEC) who have recommended managers report on their securities lending activities. It is possible that if activities like this proliferate at major asset managers, they may be categorised as SIFIs, which could come with it enormous costs. “Asset managers do not take deposits whereas banks do. Their investors expect and do bear full market risk as opposed to depositors and other senior creditors of banks. The level of regulation imposed on asset managers should therefore reflect that,” Krol said. Neither FSOC nor the FSB has decided to designate large asset managers as SIFIs. FSOC has instead opted to scrutinise the activities of asset managers such as liquidity risk – trying to pinpoint whether mass re- demptions would adversely impact financial markets. The FSB – reportedly following pressure from the US and UK regulators – also decided against labelling asset manag- ers as SIFIs. Instead, it is focusing on the risk of liquidity mismatches; fund leverage; operational risk; the porting of investment mandates in stressed markets; and the proliferation of securities lending activities at certain asset managers. While regulators have temporarily absolved fund managers from SIFI designation, it is not a foregone conclusion that this will be assured over the long-term. Proponents of SIFI designation highlight the near market crisis caused by Long Term Capital Management (LTCM), a highly leveraged hedge fund at the turn of the millennium. Again, LTCM was an exceptional circumstance and such leverage today is non-existent. The most reason- able approach is that managers, which do encroach on banking activities, be regulated proportionately. It is crucial that regulators do not adopt a one-size-fits-all approach towards the fund management industry if this happens.