《金融时报》：事实驳斥了关于信用衍生品的诊断
伦敦金融城刚刚发布的场外衍生品市场报告读来令人警醒——前提是你和我一样，认为政治家和监管者应对金融危机的方式应当像医学界对待病人那样：先诊断病情，再开处方。
The report* that has just been published by the City of London on over-the-counter (OTC) derivatives makes for alarming reading if, like me, you believe that politicians and regulators should approach the financial crisis as the medical profession would approach a sick patient: by diagnosing the illness and then prescribing treatment.
场外市场有几个特点值得认识。
There are a couple of characteristics of the OTC markets that are important to recognise.
第一，它们的规模远大于交易所市场。报告显示，场外衍生品合约的市场价值是交易所挂牌衍生品的 8 倍，而交易所挂牌衍生品的交易量又是现货股票交易量的 25 倍。这多少能让人感受到这些市场的相对规模和重要性。
First, they are much bigger than the markets that are conducted on exchanges. The report shows that the market value of OTC derivatives contracts is eight times larger than exchange-listed derivatives, and that turnover in exchange-listed derivatives is in turn 25 times the turnover in traded cash equities, This gives some sense of the relative size and importance of these markets.
第二，伦敦是场外市场的中心。据估计，2007 年全球 43% 的衍生品交易在伦敦进行，纽约占 24%，而法国、德国和日本加起来不到 15%。场外市场对广义上的伦敦金融城（包括金丝雀码头和梅菲尔的衍生机构）至关重要。
Second, London is the most important centre for the OTC markets. It is estimated that 43 per cent of worldwide derivatives trading in 2007 was conducted in London, whereas 24 per cent was conducted in New York, and less than 15 per cent in France, Germany and Japan combined. OTC markets are important to the City of London in its widest sense, including the offshoots in Canary Wharf and Mayfair.
正因如此，针对场外市场开出的药方竟公然无视事实，还掺杂着政治家和部分从业者的私利盘算，这更让人担忧。
This makes it all the more worrying that the prescriptions put forward for the OTC markets show a blatant disregard for the facts, and the cultivation of self-interest by politicians and some operators.
先从那个似乎被普遍接受的简单论断说起：信用衍生品场外市场是危机的主因之一。伦敦金融城的报告彻底驳斥了这一说法。信用违约互换市场并未引发任何重大问题。事实上，该市场经历了雷曼兄弟倒闭的严峻考验，毫发无损。
Let’s start with the simple proposition, which seems to be almost universally accepted, that the OTC markets in credit derivatives were one of the main causes of the crisis. The City of London report utterly refutes this claim. There have been no significant problems caused by the markets in credit default swaps. In fact, the market survived a severe test with the failure of Lehman Brothers without any ill effect.
尽管没有任何证据表明信用违约互换的场外市场造成过问题，仍有人鼓噪着要设立中央对手方来为信用违约互换市场的交易提供担保，甚至要求信用违约互换交易搬到交易所进行。我们看到蒂姆·盖特纳（时任纽约联储主席）表示，场外信用违约互换市场应由美国监管——这实在令人惊讶，因为全球四分之三的信用违约互换交易发生在美国以外。
Despite this absence of any evidence that the OTC markets in credit default swaps have caused any problem, there is a clamour for a central counterparty to guarantee trades in the CDS market and even for CDS trading to be conducted on exchanges. We have seen Tim Geithner (when he was president of the New York Federal Reserve) indicate that the OTC CDS market should be regulated by the US, which is amazing since three-quarters of the world’s CDS trading takes place outside the US.
欧盟委员会不甘落后，威胁要立法实施严格的新管制，除非信用违约互换的主要做市银行在年中之前建立欧盟境内的中央对手方。至于这一目标是否可行，当然没人考虑过，更不用说是否可取。
Not to be outdone, the European Commission has threatened legislation imposing stringent new controls unless the banks that are the main dealers in CDS establish the use of an EU-based central counterparty for CDS by the middle of the year. The practicality of achieving this has, of course, not been considered, let alone the desirability.
还有一点同样重要：法国央行提议为欧元区建立中央对手方——换句话说，就是不设在伦敦的中央对手方，因为英国不在欧元区。
Last but by no means least, the Banque de France has proposed that a central counterparty needs to be established for the eurozone – in other words, one that is not located in London, since the UK is not in the euro.
在这场混战中，还有欧洲证券交易所联合会在提交的意见书中建议，信用违约互换（及其他场外产品）交易只有放到交易所进行，才能实现透明、流动性和有效监管。这一论断同样没有任何证据支持，推动它的是那些试图借助立法或监管力量把场外业务赶到自己平台上的交易所。
Added to this mêlée is the suggestion, for example in a submission from the Federation of European Securities Exchanges, that CDS (and other OTC) trading can be transparent, liquid and well regulated only if it is conducted on exchanges. This assertion, which is equally unsupported by any evidence, is promoted by those exchanges that are seeking legislative or regulatory help to drive OTC business on to their platforms.
它们的举动并不令人意外，因为它们在打入场外市场方面几乎毫无建树。失败的原因很多，但最大的一条是：场外市场的产品本质上就是定制化的工具和合约，在专业参与者之间大额交易；因此，它们与交易所交易产品截然相反。如果把场外业务强行赶到这些不合适的场所，市场效率只会更低——这是我们应当避免的结果。
Their action is not surprising since they have almost universally failed to make any inroads into the OTC markets. There are many reasons they have failed, but the largest one is that OTC market products are of necessity bespoke instruments and contracts, traded in large amounts between professional participants; and as such, they are the antithesis of an exchange-traded product. If OTC business is driven to these unsuitable venues, markets will become less efficient, which is an outcome we should seek to avoid.
鉴于场外市场对伦敦以及对整体金融市场健康的重要性，英国政府理应游说支持伦敦金融城报告的结论。但正如我们上周所见，它的优先事项似乎另有所在。
Given the importance of OTC markets to London and to the health of the financial markets in general, the British government should surely be lobbying to support the City of London report’s conclusions. But as we saw last week, its priorities would seem to lie elsewhere.
*《影响场外衍生品市场的当前问题及其对伦敦的重要性》，作者：Bourse Consult 的林顿·琼斯。
- Current Issues Affecting the OTC Derivatives Market and its Importance to London by Lynton Jones of Bourse Consult
Terry Smith
Terry Smith
Financial Times
Financial Times