Derivatives Primer Analyst: Michele Wong
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Section 1256 and Foreign Currency Derivatives
Section 1256 and Foreign Currency Derivatives Viva Hammer1 Mark-to-market taxation was considered “a fundamental departure from the concept of income realization in the U.S. tax law”2 when it was introduced in 1981. Congress was only game to propose the concept because of rampant “straddle” shelters that were undermining the U.S. tax system and commodities derivatives markets. Early in tax history, the Supreme Court articulated the realization principle as a Constitutional limitation on Congress’ taxing power. But in 1981, lawmakers makers felt confident imposing mark-to-market on exchange traded futures contracts because of the exchanges’ system of variation margin. However, when in 1982 non-exchange foreign currency traders asked to come within the ambit of mark-to-market taxation, Congress acceded to their demands even though this market had no equivalent to variation margin. This opportunistic rather than policy-driven history has spawned a great debate amongst tax practitioners as to the scope of the mark-to-market rule governing foreign currency contracts. Several recent cases have added fuel to the debate. The Straddle Shelters of the 1970s Straddle shelters were developed to exploit several structural flaws in the U.S. tax system: (1) the vast gulf between ordinary income tax rate (maximum 70%) and long term capital gain rate (28%), (2) the arbitrary distinction between capital gain and ordinary income, making it relatively easy to convert one to the other, and (3) the non- economic tax treatment of derivative contracts. Straddle shelters were so pervasive that in 1978 it was estimated that more than 75% of the open interest in silver futures were entered into to accommodate tax straddles and demand for U.S. -
Interest Rate Options
Interest Rate Options Saurav Sen April 2001 Contents 1. Caps and Floors 2 1.1. Defintions . 2 1.2. Plain Vanilla Caps . 2 1.2.1. Caplets . 3 1.2.2. Caps . 4 1.2.3. Bootstrapping the Forward Volatility Curve . 4 1.2.4. Caplet as a Put Option on a Zero-Coupon Bond . 5 1.2.5. Hedging Caps . 6 1.3. Floors . 7 1.3.1. Pricing and Hedging . 7 1.3.2. Put-Call Parity . 7 1.3.3. At-the-money (ATM) Caps and Floors . 7 1.4. Digital Caps . 8 1.4.1. Pricing . 8 1.4.2. Hedging . 8 1.5. Other Exotic Caps and Floors . 9 1.5.1. Knock-In Caps . 9 1.5.2. LIBOR Reset Caps . 9 1.5.3. Auto Caps . 9 1.5.4. Chooser Caps . 9 1.5.5. CMS Caps and Floors . 9 2. Swap Options 10 2.1. Swaps: A Brief Review of Essentials . 10 2.2. Swaptions . 11 2.2.1. Definitions . 11 2.2.2. Payoff Structure . 11 2.2.3. Pricing . 12 2.2.4. Put-Call Parity and Moneyness for Swaptions . 13 2.2.5. Hedging . 13 2.3. Constant Maturity Swaps . 13 2.3.1. Definition . 13 2.3.2. Pricing . 14 1 2.3.3. Approximate CMS Convexity Correction . 14 2.3.4. Pricing (continued) . 15 2.3.5. CMS Summary . 15 2.4. Other Swap Options . 16 2.4.1. LIBOR in Arrears Swaps . 16 2.4.2. Bermudan Swaptions . 16 2.4.3. Hybrid Structures . 17 Appendix: The Black Model 17 A.1. -
Margin Requirements Across Equity-Related Instruments: How Level Is the Playing Field?
Fortune pgs 31-50 1/6/04 8:21 PM Page 31 Margin Requirements Across Equity-Related Instruments: How Level Is the Playing Field? hen interest rates rose sharply in 1994, a number of derivatives- related failures occurred, prominent among them the bankrupt- cy of Orange County, California, which had invested heavily in W 1 structured notes called “inverse floaters.” These events led to vigorous public discussion about the links between derivative securities and finan- cial stability, as well as about the potential role of new regulation. In an effort to clarify the issues, the Federal Reserve Bank of Boston sponsored an educational forum in which the risks and risk management of deriva- tive securities were discussed by a range of interested parties: academics; lawmakers and regulators; experts from nonfinancial corporations, investment and commercial banks, and pension funds; and issuers of securities. The Bank published a summary of the presentations in Minehan and Simons (1995). In the keynote address, Harvard Business School Professor Jay Light noted that there are at least 11 ways that investors can participate in the returns on the Standard and Poor’s 500 composite index (see Box 1). Professor Light pointed out that these alternatives exist because they dif- Peter Fortune fer in a variety of important respects: Some carry higher transaction costs; others might have higher margin requirements; still others might differ in tax treatment or in regulatory restraints. The author is Senior Economist and The purpose of the present study is to assess one dimension of those Advisor to the Director of Research at differences—margin requirements. -
Buying Options on Futures Contracts. a Guide to Uses
NATIONAL FUTURES ASSOCIATION Buying Options on Futures Contracts A Guide to Uses and Risks Table of Contents 4 Introduction 6 Part One: The Vocabulary of Options Trading 10 Part Two: The Arithmetic of Option Premiums 10 Intrinsic Value 10 Time Value 12 Part Three: The Mechanics of Buying and Writing Options 12 Commission Charges 13 Leverage 13 The First Step: Calculate the Break-Even Price 15 Factors Affecting the Choice of an Option 18 After You Buy an Option: What Then? 21 Who Writes Options and Why 22 Risk Caution 23 Part Four: A Pre-Investment Checklist 25 NFA Information and Resources Buying Options on Futures Contracts: A Guide to Uses and Risks National Futures Association is a Congressionally authorized self- regulatory organization of the United States futures industry. Its mission is to provide innovative regulatory pro- grams and services that ensure futures industry integrity, protect market par- ticipants and help NFA Members meet their regulatory responsibilities. This booklet has been prepared as a part of NFA’s continuing public educa- tion efforts to provide information about the futures industry to potential investors. Disclaimer: This brochure only discusses the most common type of commodity options traded in the U.S.—options on futures contracts traded on a regulated exchange and exercisable at any time before they expire. If you are considering trading options on the underlying commodity itself or options that can only be exercised at or near their expiration date, ask your broker for more information. 3 Introduction Although futures contracts have been traded on U.S. exchanges since 1865, options on futures contracts were not introduced until 1982. -
Tax Treatment of Derivatives
United States Viva Hammer* Tax Treatment of Derivatives 1. Introduction instruments, as well as principles of general applicability. Often, the nature of the derivative instrument will dictate The US federal income taxation of derivative instruments whether it is taxed as a capital asset or an ordinary asset is determined under numerous tax rules set forth in the US (see discussion of section 1256 contracts, below). In other tax code, the regulations thereunder (and supplemented instances, the nature of the taxpayer will dictate whether it by various forms of published and unpublished guidance is taxed as a capital asset or an ordinary asset (see discus- from the US tax authorities and by the case law).1 These tax sion of dealers versus traders, below). rules dictate the US federal income taxation of derivative instruments without regard to applicable accounting rules. Generally, the starting point will be to determine whether the instrument is a “capital asset” or an “ordinary asset” The tax rules applicable to derivative instruments have in the hands of the taxpayer. Section 1221 defines “capital developed over time in piecemeal fashion. There are no assets” by exclusion – unless an asset falls within one of general principles governing the taxation of derivatives eight enumerated exceptions, it is viewed as a capital asset. in the United States. Every transaction must be examined Exceptions to capital asset treatment relevant to taxpayers in light of these piecemeal rules. Key considerations for transacting in derivative instruments include the excep- issuers and holders of derivative instruments under US tions for (1) hedging transactions3 and (2) “commodities tax principles will include the character of income, gain, derivative financial instruments” held by a “commodities loss and deduction related to the instrument (ordinary derivatives dealer”.4 vs. -
An Analysis of OTC Interest Rate Derivatives Transactions: Implications for Public Reporting
Federal Reserve Bank of New York Staff Reports An Analysis of OTC Interest Rate Derivatives Transactions: Implications for Public Reporting Michael Fleming John Jackson Ada Li Asani Sarkar Patricia Zobel Staff Report No. 557 March 2012 Revised October 2012 FRBNY Staff REPORTS This paper presents preliminary fi ndings and is being distributed to economists and other interested readers solely to stimulate discussion and elicit comments. The views expressed in this paper are those of the authors and are not necessarily refl ective of views at the Federal Reserve Bank of New York or the Federal Reserve System. Any errors or omissions are the responsibility of the authors. An Analysis of OTC Interest Rate Derivatives Transactions: Implications for Public Reporting Michael Fleming, John Jackson, Ada Li, Asani Sarkar, and Patricia Zobel Federal Reserve Bank of New York Staff Reports, no. 557 March 2012; revised October 2012 JEL classifi cation: G12, G13, G18 Abstract This paper examines the over-the-counter (OTC) interest rate derivatives (IRD) market in order to inform the design of post-trade price reporting. Our analysis uses a novel transaction-level data set to examine trading activity, the composition of market participants, levels of product standardization, and market-making behavior. We fi nd that trading activity in the IRD market is dispersed across a broad array of product types, currency denominations, and maturities, leading to more than 10,500 observed unique product combinations. While a select group of standard instruments trade with relative frequency and may provide timely and pertinent price information for market partici- pants, many other IRD instruments trade infrequently and with diverse contract terms, limiting the impact on price formation from the reporting of those transactions. -
Black-Scholes Equations
Chapter 8 Black-Scholes Equations 1 The Black-Scholes Model Up to now, we only consider hedgings that are done upfront. For example, if we write a naked call (see Example 5.2), we are exposed to unlimited risk if the stock price rises steeply. We can hedge it by buying a share of the underlying asset. This is done at the initial time when the call is sold. We are then protected against any steep rise in the asset price. However, if we hold the asset until expiry, we are not protected against any steep dive in the asset price. So is there a hedging that is really riskless? The answer was given by Black and Scholes, and also by Merton in their seminal papers on the theory of option pricing published in 1973. The idea is that a writer of a naked call can protect his short position of the option by buying a certain amount of the stock so that the loss in the short call can be exactly offset by the long position in the stock. This is standard in hedging. The question is how many stocks should he buy to minimize the risk? By adjusting the proportion of the stock and option continuously in the portfolio during the life of the option, Black and Scholes demonstrated that investors can create a riskless hedging portfolio where all market risks are eliminated. In an efficient market with no riskless arbitrage opportunity, any portfolio with a zero market risk must have an expected rate of return equal to the riskless interest rate. -
Panagora Global Diversified Risk Portfolio General Information Portfolio Allocation
March 31, 2021 PanAgora Global Diversified Risk Portfolio General Information Portfolio Allocation Inception Date April 15, 2014 Total Assets $254 Million (as of 3/31/2021) Adviser Brighthouse Investment Advisers, LLC SubAdviser PanAgora Asset Management, Inc. Portfolio Managers Bryan Belton, CFA, Director, Multi Asset Edward Qian, Ph.D., CFA, Chief Investment Officer and Head of Multi Asset Research Jonathon Beaulieu, CFA Investment Strategy The PanAgora Global Diversified Risk Portfolio investment philosophy is centered on the belief that risk diversification is the key to generating better risk-adjusted returns and avoiding risk concentration within a portfolio is the best way to achieve true diversification. They look to accomplish this by evaluating risk across and within asset classes using proprietary risk assessment and management techniques, including an approach to active risk management called Dynamic Risk Allocation. The portfolio targets a risk allocation of 40% equities, 40% fixed income and 20% inflation protection. Portfolio Statistics Portfolio Composition 1 Yr 3 Yr Inception 1.88 0.62 Sharpe Ratio 0.6 Positioning as of Positioning as of 0.83 0.75 Beta* 0.78 December 31, 2020 March 31, 2021 Correlation* 0.87 0.86 0.79 42.4% 10.04 10.6 Global Equity 43.4% Std. Deviation 9.15 24.9% U.S. Stocks 23.6% Weighted Portfolio Duration (Month End) 9.0% 8.03 Developed non-U.S. Stocks 9.8% 8.5% *Statistic is measured against the Dow Jones Moderate Index Emerging Markets Equity 10.0% 106.8% Portfolio Benchmark: Nominal Fixed Income 142.6% 42.0% The Dow Jones Moderate Index is a composite index with U.S. -
Interest Rate Swap Contracts the Company Has Two Interest Rate Swap Contracts That Hedge the Base Interest Rate Risk on Its Two Term Loans
$400.0 million. However, the $100.0 million expansion feature may or may not be available to the Company depending upon prevailing credit market conditions. To date the Company has not sought to borrow under the expansion feature. Borrowings under the Credit Agreement carry interest rates that are either prime-based or Libor-based. Interest rates under these borrowings include a base rate plus a margin between 0.00% and 0.75% on Prime-based borrowings and between 0.625% and 1.75% on Libor-based borrowings. Generally, the Company’s borrowings are Libor-based. The revolving loans may be borrowed, repaid and reborrowed until January 31, 2012, at which time all amounts borrowed must be repaid. The revolver borrowing capacity is reduced for both amounts outstanding under the revolver and for letters of credit. The original term loan will be repaid in 18 consecutive quarterly installments which commenced on September 30, 2007, with the final payment due on January 31, 2012, and may be prepaid at any time without penalty or premium at the option of the Company. The 2008 term loan is co-terminus with the original 2007 term loan under the Credit Agreement and will be repaid in 16 consecutive quarterly installments which commenced June 30, 2008, plus a final payment due on January 31, 2012, and may be prepaid at any time without penalty or premium at the option of Gartner. The Credit Agreement contains certain customary restrictive loan covenants, including, among others, financial covenants requiring a maximum leverage ratio, a minimum fixed charge coverage ratio, and a minimum annualized contract value ratio and covenants limiting Gartner’s ability to incur indebtedness, grant liens, make acquisitions, be acquired, dispose of assets, pay dividends, repurchase stock, make capital expenditures, and make investments. -
Options Strategy Guide for Metals Products As the World’S Largest and Most Diverse Derivatives Marketplace, CME Group Is Where the World Comes to Manage Risk
metals products Options Strategy Guide for Metals Products As the world’s largest and most diverse derivatives marketplace, CME Group is where the world comes to manage risk. CME Group exchanges – CME, CBOT, NYMEX and COMEX – offer the widest range of global benchmark products across all major asset classes, including futures and options based on interest rates, equity indexes, foreign exchange, energy, agricultural commodities, metals, weather and real estate. CME Group brings buyers and sellers together through its CME Globex electronic trading platform and its trading facilities in New York and Chicago. CME Group also operates CME Clearing, one of the largest central counterparty clearing services in the world, which provides clearing and settlement services for exchange-traded contracts, as well as for over-the-counter derivatives transactions through CME ClearPort. These products and services ensure that businesses everywhere can substantially mitigate counterparty credit risk in both listed and over-the-counter derivatives markets. Options Strategy Guide for Metals Products The Metals Risk Management Marketplace Because metals markets are highly responsive to overarching global economic The hypothetical trades that follow look at market position, market objective, and geopolitical influences, they present a unique risk management tool profit/loss potential, deltas and other information associated with the 12 for commercial and institutional firms as well as a unique, exciting and strategies. The trading examples use our Gold, Silver -
Bankruptcy Futures: Hedging Against Credit Card Default
CONSUMER LENDING Bankruptcy Futures: Hedging Against Credit Card Default by Russ Ray his article discusses the new bankruptcy futures contract to be launched by the Chicago Mercantile Exchange and examines the mechanics and contract specifications of this innovation, illus- trating its hedging potential in the process. ometime during the latter half of 1999 or early Credit-card debt is becoming particularly burden- 2000, the Chicago Mercantile Exchange intends some. The average credit-card balance is approximately to launch an innovative new futures contract that $2,500, with typical households having at least three dif- will offer consumer-lending institutions, particularly ferent bank cards. The average card holder also uses six credit-card issuers, a hedge against the bankruptcies additional cards at service stations, department stores, filed by their borrowers. Bankruptcy futures—contracts specialty stores, and other vendors issuing their own cred- to buy or sell a cash-valued index based upon the cur- it cards. rent number of actual bankruptcies—will enable con- Commensurate with such increases in consumer sumer lenders to transfer default risk to other lenders debt is an ever-growing rise in consumer bankruptcies, and/or speculators holding opposite expectations. which, in turn, represent an ever-increasing proportion Significantly, this new contract also constitutes a proxy of total bankruptcies. In 1998, 96.9% of all bankruptcy variable for banks' confidence in the value and liquidity filings were personal—not business—bankruptcies. (In of their own loan portfolios, just as other proxy vari- terms of dollar volume, however, businesses continue to ables now measure consumer and investor confidence. -
Derivative Securities
2. DERIVATIVE SECURITIES Objectives: After reading this chapter, you will 1. Understand the reason for trading options. 2. Know the basic terminology of options. 2.1 Derivative Securities A derivative security is a financial instrument whose value depends upon the value of another asset. The main types of derivatives are futures, forwards, options, and swaps. An example of a derivative security is a convertible bond. Such a bond, at the discretion of the bondholder, may be converted into a fixed number of shares of the stock of the issuing corporation. The value of a convertible bond depends upon the value of the underlying stock, and thus, it is a derivative security. An investor would like to buy such a bond because he can make money if the stock market rises. The stock price, and hence the bond value, will rise. If the stock market falls, he can still make money by earning interest on the convertible bond. Another derivative security is a forward contract. Suppose you have decided to buy an ounce of gold for investment purposes. The price of gold for immediate delivery is, say, $345 an ounce. You would like to hold this gold for a year and then sell it at the prevailing rates. One possibility is to pay $345 to a seller and get immediate physical possession of the gold, hold it for a year, and then sell it. If the price of gold a year from now is $370 an ounce, you have clearly made a profit of $25. That is not the only way to invest in gold.