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Improve the Effectiveness of your Product Control Function
Effective Product Control is a detailed how-to guide covering everything you need to know about the function. Considered essential reading for:
Encompassing both a technical skills primer and key insights into core controls used to mitigate major risks emanating from trading desks, you will get expert advice on practical topics such as:
Complete with a wealth of insightful graphs, illustrations and real-world examples to enliven the covered material, the dependable answers you need are in Effective Product Control.
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Veröffentlichungsjahr: 2017
Founded in 1807, John Wiley & Sons is the oldest independent publishing company in the United States. With offices in North America, Europe, Australia and Asia, Wiley is globally committed to developing and marketing print and electronic products and services for our customers' professional and personal knowledge and understanding.
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PETER NASH
This edition first published 2018© 2018 Peter Nash
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Library of Congress Cataloging-in-Publication Data
Names: Nash, Peter, author.Title: Effective product control : controlling for trading desks / by Peter Nash.Description: Chichester, West Sussex, United Kingdom : John Wiley & Sons, 2018. | Includes index. |Identifiers: LCCN 2017029434 (print) | LCCN 2017040992 (ebook) | ISBN 9781118939796 (Pdf) | ISBN 9781118939802 (epub) | ISBN 9781118939819 (cloth)Subjects: LCSH: Financial institutions—Risk management. | Financial services industry— Risk management. | Portfolio management. | Stocks. | Investments.Classification: LCC HG173 (ebook) | LCC HG173 .N27 2018 (print) | DDC 332.1068/1—dc23LC record available at https://lccn.loc.gov/2017029434
A catalogue record for this book is available from the British Library.
ISBN 978-1-118-93981-9 (hardback)
ISBN 978-1-118-93979-6 (ePDF)
ISBN 978-1-118-93980-2 (ePub)
ISBN 978-1-118-93978-9 (obk)
Cover design: Wiley
Cover image: Top: ©Shai_Halud/Shutterstock, Bottom: ©Inozemtsev Konstantin/Shutterstock
I dedicate this book to my family, especially my children, who haveforgone a great deal of Dad time for this book to come to life.To Phoebe, Xani and Matilda.Thank you.
In memory of Patrick Spratt, a product controller and friendwho was larger than life.
Preface
Acknowledgements
About the Author
Part 1 Working in Product Control
CHAPTER 1 An Introduction to Product Control
The Emergence of Product Control
The Purpose of Product Control
Different Types of Product Control
Skills, Qualifications and Experience
Organizational Structure
The Desk
CHAPTER 2 Changing Landscape of Product Control
Offshoring
XVA
Greater Levels of Capital
Greater Focus on Liquidity
Notes
CHAPTER 3 Key Stakeholders
Front Office: Sales and Trading Desk
Chief Operating Officers (COOs)
Operations
Middle Office
Market Risk
Financial Reporting
Management Reporting
Finance Change
IT
Operational Risk
Regulatory Reporting
Accounting Policy
Tax
Audit
Finance Shared Service
Summary
Notes
Part 2 Technical Skills
CHAPTER 4 Accounting Standards: Recognition and Measurement
IAS 39 Financial Instruments: Recognition and Measurement
IFRS 9: Financial Instruments
IFRS 13: Fair Value Measurement
Notes
CHAPTER 5 Market Risk
What Is Market Risk and How Is It Generated?
How Is Market Risk Measured by a Bank?
Notes
CHAPTER 6 Pricing Financial Instruments
How to Approach the Pricing of a Financial Instrument
Pricing examples
Notes
CHAPTER 7 Internal Control
What is Internal Control?
Establishing an Internal Control Framework
Example of Front to Back Internal Controls
Notes
Part 3 Profit and Loss Controls
CHAPTER 8 System Feeds, End of Day Rates and Profit and Loss Estimates
System Feeds
End of Day
End of Day Rates
P&L Estimate
Notes
CHAPTER 9 Review of New and Amended Trades
New Trades
Amended Trades
Notes
CHAPTER 10 Review of Mark-to-Market P&L
Defining Mark-to-Market P&L
Attributing MTM P&L
Risk-Based P&L estimates
Changes in the End of Day Prices
When to Validate the MTM P&L
CHAPTER 11 Funding, Fees and Charges
Funding
Fees and Charges
Notes
CHAPTER 12 Profit and Loss Adjustments
The Need for P&L Adjustments
Controlling P&L Adjustments
Notes
CHAPTER 13 Profit and Loss Commentary
Who Is the Reader?
When Is P&L Commentary Required?
CHAPTER 14 Profit and Loss Reconciliations and Sign-Offs
Flash vs. Actual
Desk P&L Sign-off
P&L Reconciliation
Part 4 Valuations
CHAPTER 15 Independent Price Verification
Components to IPV Process
Notes
CHAPTER 16 Valuation Adjustments
Why Valuation Adjustments Are Required
Bid–Offer
Day 1 Reserves
Model Valuation Adjustment
XVA and Collateral Agreements
Recording and Reporting of VAs
Notes
Part 5 Balance Sheet Controls
CHAPTER 17 Balance Sheet Substantiation and Analysis
Substantiating the Balance Sheet
Frequency of the Balance Sheet Substantiation
Evidencing the Balance Sheet Substantiation
Unsupported Balances
Lines of Responsibility
CHAPTER 18 Dividending of Profit and Loss and FX Selldown
CHAPTER 19 Controlling Nostros
Introduction to Nostros
Controlling Nostros – Cash Breaks
Risk-Weighting Cash and AVE breaks
Provisioning for Nostro and AVE Breaks
Notes
Part 6 Financial Accounting and Reporting
CHAPTER 20 Financial Accounting Entries
Financial Accounting Entries
Chart of Accounts
Accounting Rules Engine
Notes
CHAPTER 21 Financial Reporting and Note Disclosures
Context of Financial Reporting
Profit and Loss
Balance Sheet
Netting
Fair Value Hierarchy
Notes
Part 7 Supplementary Controls
CHAPTER 22 New Product Proposals
Starting Line
The Review
The Sign-Off
CHAPTER 23 Rogue Trading
The Forefathers of Rogue Trading
The Fallout from Rogue Trading – The Bank
The Fallout from Rogue Trading – The Industry
Going Rogue
UBS Rogue Trading Incident, 2011
Notes
Index
EULA
Chapter 1
Table 1.1
Chapter 3
Table 3.1
Table 3.2
Chapter 4
Table 4.1
Table 4.2
Table 4.3
Table 4.4
Table 4.5
Table 4.6
Table 4.7
Table 4.8
Table 4.9
Table 4.10
Table 4.11
Table 4.12
Table 4.13
Table 4.14
Chapter 5
Table 5.1
Table 5.2
Table 5.3
Table 5.4
Table 5.5
Table 5.6
Table 5.7
Table 5.8
Chapter 6
Table 6.1
Table 6.2
Table 6.3
Table 6.4
Table 6.5
Table 6.6
Table 6.7
Table 6.8
Table 6.9
Table 6.10
Table 6.11
Chapter 7
Table 7.1
Table 7.2
Table 7.3
Table 7.4
Chapter 8
Table 8.1
Table 8.2
Chapter 9
Table 9.1
Table 9.2
Table 9.3
Table 9.4
Table 9.5
Table 9.6
Table 9.7
Table 9.8
Table 9.9
Table 9.10
Table 9.11
Table 9.12
Table 9.13
Table 9.14
Table 9.15
Table 9.16
Table 9.17
Table 9.18
Chapter 10
Table 10.1
Table 10.2
Table 10.3
Table 10.4
Chapter 11
Table 11.1
Table 11.2
Table 11.3
Table 11.4
Table 11.5
Table 11.6
Chapter 12
Table 12.1
Table 12.2
Table 12.3
Chapter 13
Table 13.1
Table 13.2
Table 13.3
Table 13.4
Chapter 14
Table 14.1
Table 14.2
Table 14.3
Table 14.4
Chapter 15
Table 15.1
Table 15.2
Table 15.3
Table 15.4
Table 15.5
Table 15.6
Table 15.7
Table 15.8
Chapter 16
Table 16.1
Table 16.2
Table 16.3
Table 16.4
Table 16.5
Table 16.6
Table 16.7
Table 16.8
Table 16.9
Table 16.10
Chapter 17
Table 17.1
Table 17.2
Table 17.3
Table 17.4
Table 17.5
Table 17.6
Table 17.7
Table 17.8
Table 17.9
Chapter 18
Table 18.1
Table 18.2
Chapter 19
Table 19.1
Table 19.2
Table 19.3
Table 19.4
Chapter 20
Table 20.1
Table 20.2
Table 20.3
Table 20.4
Table 20.5
Table 20.6
Table 20.7
Table 20.8
Table 20.9
Table 20.10
Table 20.11
Table 20.12
Table 20.13
Table 20.14
Table 20.15
Table 20.16
Table 20.17
Table 20.18
Table 20.19
Table 20.20
Table 20.21
Table 20.22
Table 20.23
Table 20.24
Chapter 21
Table 21.1
Table 21.2
Table 21.3
Table 21.4
Table 21.5
Table 21.6
Table 21.7
Table 21.8
Table 21.9
Table 21.10
Table 21.11
Table 21.12
Table 21.13
Table 21.14
Table 21.15
Table 21.16
Table 21.17
Table 21.18
Table 21.19
Chapter 22
Table 22.1
Table 22.2
Table 22.3
Chapter 23
Table 23.1
Table 23.2
Chapter 1
Figure 1.1
The purpose of product control
Figure 1.2
The P&L
Figure 1.3
Finance and product control organizational structure
Figure 1.4
Remit of valuation control
Figure 1.5
The foreign exchange market operating hours
Figure 1.6
World stock market operating hours
Figure 1.7
Sir Alex Ferguson brokering trades for charity in London
Chapter 2
Figure 2.1
Changes in product control
Figure 2.2
Offshoring models
Figure 2.3
The impact of increased capital
Chapter 3
Figure 3.1
Stakeholder interaction with product control
Figure 3.2
The role of operations
Figure 3.3
Sparta Bank FX One Name Trading (Single book)
Chapter 4
Figure 4.1
Overview of IAS 39
Figure 4.2
Derecognizing an asset
Figure 4.3
Repurchase agreement
Figure 4.4
Aspects of control within a transfer
Figure 4.5
IAS 39's classification and measurement of financial assets
Figure 4.6
Classification and measurement of financial liabilities under IAS 39
Figure 4.7
U.S. GAAP classification and measurement
Figure 4.8
U.S. GAAP classification and measurement
Figure 4.9
Recording the impairment of AFS and held to maturity assets
Figure 4.10
IFRS 9: classification and measurement for financial assets
Figure 4.11
Establishing the type of business model
Figure 4.12
IFRS 9: interest components
Figure 4.13
IFRS 9 – Fair value through P&L
Figure 4.14
IFRS 9: Impairment
Figure 4.15
Bid and Ask quotes for spot FX rates
Figure 4.16
IFRS 13: Determining fair value
Chapter 5
Figure 5.1
Generating and laying off market risk
Figure 5.2
Pricing, market risk and P&L
Figure 5.3
Consolidating interest rate risk
Figure 5.4
Market risk arising from a FRA
Figure 5.5
Interest rate risk for an interest rate swap
Figure 5.6
The standard deviation of P&L scores
Chapter 6
Figure 6.1
Approach to pricing a financial instrument
Figure 6.2
Spot FX trade
Figure 6.3
Spot FX quotes in the market
Figure 6.4
FX forward trade
Figure 6.5
GBP/USD FX forward rate
Figure 6.6
Bond cash flows
Figure 6.7
Interest rate swap
Figure 6.8
U.S. swaps curve
Figure 6.9
AUD/USD FX volatility
Figure 6.10
The payoff for a long AUD/USD call option
Chapter 7
Figure 7.1
COSO Integrated Control Framework
Figure 7.2
Objectives and internal control
Figure 7.3
Establishing a risk culture and risk management framework
Figure 7.4
Lines of defence
Figure 7.5
Four lines of defence
Figure 7.6
Front to back controls
Chapter 8
Figure 8.1
Optimal controls over the P&L
Figure 8.2
Decomposing or attributing the P&L
Figure 8.3
Alternative P&L reporting feeds
Figure 8.4
Supply of data and checks to product control
Figure 8.5
Sourcing end of day rates
Figure 8.6
SuperDerivatives pricing service
Figure 8.7
External rate checks
Figure 8.8
Checking trader marks
Chapter 9
Figure 9.1
Drivers of new trades
Figure 9.2
Drivers of new trades
Figure 9.3
Steps in the new trade process
Figure 9.4
New trade threshold criteria
Figure 9.5
New trade threshold criteria
Figure 9.6
Intraday GBP/USD Spot FX prices
Figure 9.7
Considerations in a new trade review
Figure 9.8
Client transaction
Figure 9.9
Crossing the bid–offer to hedge risk
Figure 9.10
Transaction price now incorporates the cost of crossing the bid–offer
Figure 9.11
Transaction price now incorporates bid–offer, margin and CVA
Figure 9.12
Transaction price now incorporates bid–offer, margin, CVA and FVA
Figure 9.13
Selling CDS protection to a client
Figure 9.14
P&L from amended trades
Figure 9.15
HSBC Share price
Figure 9.16
P&L reporting of a close out
Figure 9.17
Novation of an interest rate swap
Figure 9.18
CME Group acting as a central clearing counterparty
Figure 9.19
Overview of MarkitServ's process
Figure 9.20
Avoidable amendments
Chapter 10
Figure 10.1
Defining MTM P&L
Figure 10.2
Validating MTM P&L
Figure 10.3
Driver of MTM P&L
Figure 10.4
Using the waterfall method to sub-attribute an FX option's MTM P&L
Figure 10.5
Using the restored method to attribute an FX option's MTM P&L
Figure 10.6
Quantifying a risk-based P&L estimate
Figure 10.7
Fixings vs risk based P&L estimate
Figure 10.8
U.S. markets in Bloomberg
Figure 10.9
AUD/USD price changes
Chapter 11
Figure 11.1
Drivers of funding
Figure 11.2
Sourcing funding
Figure 11.3
Funding a bond purchase
Figure 11.4
Funding P&L
Figure 11.5
Above and below the line expenses
Chapter 13
Figure 13.1
P&L commentary segments
Figure 13.2
Intraday MTM P&L
Chapter 14
Figure 14.1
P&L sign off
Figure 14.2
Approaches to P&L reporting and the impact on reconciliations
Figure 14.3
Establishing P&L variance thresholds
Chapter 15
Figure 15.1
P&L smoothing
Figure 15.2
IPV process
Figure 15.3
Price discovery hierarchy
Figure 15.4
Cross currency basis
Figure 15.5
Stock prices
Figure 15.6
World corporate bond prices
Figure 15.7
Outright GBP volatilities by delta
Figure 15.8
Spot FX rates
Figure 15.9
GBPUSD FX forward points
Figure 15.10
Transocean 5-yr Senior CDS quote
Chapter 16
Figure 16.1
Aligning valuations to their exit price
Figure 16.2
Crossing the bid–offer spread
Figure 16.3
Differences in bid–offer spreads by tenor
Figure 16.4
Volatile market
Figure 16.5
Stable market
Figure 16.6
Rates desk risk aggregation
Figure 16.7
Back-to-back interest rate swap
Figure 16.8
FCA on a back-to-back interest rate swap
Chapter 17
Figure 17.1
Substantiating the GL
Chapter 18
Figure 18.1
Overview of dividending, FX selldown and repatriation of P&L
Figure 18.2
In non-selldown centres, foreign currency P&L is transferred to the FX position accounts
Chapter 19
Figure 19.1
Nostro record keeping
Figure 19.2
Ledger and statement entries
Figure 19.3
TLM reconciliation workflow
Figure 19.4
TLM cash reconciliation dashboard
Figure 19.5
Cash break identification
Figure 19.6
Cash break transfer to the credit desk
Chapter 20
Figure 20.1
A trial balance report
Figure 20.2
Loan agreement
Figure 20.3
Cash flows for $1m Muster Inc. 10% S/A bond
Figure 20.4
Accounting for an interest rate swap
Figure 20.5
Accounting for an FX forward
Figure 20.6
Accounting rules engine flows
Chapter 21
Figure 21.1
Different paradigms
Figure 21.2
Netting – a summary of IAS 32’s criteria
Figure 21.3
Fair value hierarchy
Figure 21.4
FVH decision tree
Chapter 23
Figure 23.1
Rogue trading events
Figure 23.2
Repercussions of rogue trading
Figure 23.3
NAB capital increase post rogue trading
Figure 23.4
Control weakness at UBS not remediated post rogue trading review in 2008
Figure 23.5
UBS Organizational structure
Figure 23.6
EURO STOXX 50 and S&P 500 price history
Figure 23.7
Concealment mechanisms used by the rogue trader
Figure 23.8
SCP alerts
Figure 23.9
Late trades
Figure 23.10
Deferred settlements
Figure 23.11
P&L smoothing using fee tickets
Figure 23.12
Summary of control weaknesses
Figure 23.13
Consolidated lens
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In 2003 I was working in a Dutch bank in a high rise overlooking the picturesque Sydney Harbour, when another junior external auditor sat beside me to review my work. This was the third new auditor in as many years and as they struggled to grasp what it was I did as a job, their lack of understanding generated in me mixed feelings of frustration and empathy for the person.
Their lack of knowledge wasn't their fault; product control is difficult to understand for an outsider and sending junior staff in to test controls is the model many audit firms use to carry out their audit assignments. Nevertheless, that exchange generated an idea to help close the gap between new auditors and product controllers and their more experienced colleagues.
Over the past 14 years I continued to work in product control in both Sydney and London, developing more experience, skills and friendships, which together have finally made possible the writing and publication of this book.
Due to the large numbers of sales and trading teams within banks, they remain the largest employer of product controllers. We will, therefore, aim the narrative of the book towards banks, but the content can also be applied to other contexts in which product control operates, such as hedge funds and corporate treasuries.
Whether you are embarking on your career or have years of experience in the field, this book will equip you with the building blocks necessary to be an effective product controller or effective in your review of product control. These building blocks cover both the core technical skills required in product control and the primary controls which product control are responsible for.
My hope is that through reading this book, your career is enhanced and more opportunities are afforded to you and your family.
Peter Nash
Special thanks to Robert Phillips who encouraged me and helped develop the manuscript from its infancy.
Thank you also to the following people and organisations who have contributed to the content of this book:
Dooshyant Beekarry, Nico Botha, Paul Bradley, Paul Buchanan, Clive Budd, Matthew Burbedge, James Campbell, Lisa Chuilon (nee Able), James Clarke, CME, Brighton Cohen, COSO, Christine Cossor, Brent Davies, Delphi Derivatives, Kane Erickson, FCA, FINMA, Fitzgerald Jenkins Recruitment, Chad Foyn, Paul Galpin, Darren Gordois, Chris Harvell, James Hayden, Michael Hoppe, ICE, Sanjiv Ingle, Investing.com, Tim Jenkins, Steve Kelley, Thusitha Liyanage, Markit, Harkil Maru, Ruairi McHale, Denley Mirabueno, Mondrian Alpha Recruitment, Grant Moscowitz, Richard O'Flynn, Daniel Pass, Mark Proctor, SmartStream, Ben Tallentire, Thomson Reuters, TriOptima, TOM Recruitment, Treasury Services, Darren Wadhera, Peter Walsh, Ben Weekes, Matthew Wiles, Mark Williams and Keith Young.
Finally, thank you to my past managers who have shared their knowledge and experience throughout my career:
Scott Rissman, Ben Weekes, Geoff Simmonds, Callum Winchester, Craig Townsend, Sandy Coxon, Peter Roberts, Robert Phillips, Ron Antonelli, Diana Neo, Prash Patel, Pascal Loup, James Howard, Stephen Chippendale, Chad Foyn, Oliver Gee, Rob Jones, James Campbell, Ryan Evans, Nathan Harris and Kane Erickson.
Peter Nash is a qualified accountant who has spent almost two decades working in Product Control, controlling a wide range of sales and trading desks in Investment and Commercial banks. He is currently a director of FINSED (www.finsed.com), a financial services training and consulting firm specialising in Product Control.
The opening part of this book provides an introduction to what it's like to work in product control, beginning with a review of product control's emergence as a significant control function, before considering its purpose and the environment within which it operates. The book will then go on to explore the skills and experience required and consider what changes have impacted the function over the past decade.
