What matters is that the system as a whole has the right level of liquidity to cope with volatility in derivatives markets in a stress and that liquidity is in the right place  We need to understand which market participants were caught flat-footed and why. Thanks to post- 2008 liquidity reforms, banks seemed able to handle the liquidity pressures they faced in March, including from margin calls. But non-banks such insurers, pension funds, hedge funds and asset managers have grown in importance over the past decade - we need to examine how well prepared they were to face the liquidity demands around margins. It’s too early to reach policy conclusions. But to preview the options in front of us: It’s possible we’ll want to explore solutions that could reduce the need for CCP margin to rise as much in stress by pre-positioning more liquidity at CCPs during quiet periods. It’s possible we could accomplish this by spreading existing good practices in CCP model design. It’s equally possible we’ll want to focus on better liquidity risk management, particularly for non-banks. This could make sure market participants self-insure against margin calls on their own balance sheets – rather than pre-positioning initial margin at the CCP. Improving transparency around potential margin calls could help support this. It’s possible that we’ll want to do some of both. 10  All speeches are available online at www.bankofengland.co.uk/news/speeches and @BoE_PressOffice  10  The right balance of policy responses will depend on what evidence we find.
To be clear, the question here is not about whether CCP margin is to “blame” for the dash-for-cash. The question is did the system have enough liquidity ready in the right places to respond to derivative market volatility without adverse consequences for financial stability. Whatever we conclude, our policy response will need to take into account the whole story- including the essential role that margin played in preventing panic. We don’t want to return to the pre-Lehman world of a spaghetti bowl of counterparty credit risk. 4. Conclusion  So going back to my original questions. First, what has the experience of March and April told us about the reforms we put in place post-2008 to make the global financial system simpler? A: The headline answer is: It worked. When it comes to the crucial goal of preventing panic fuelled by a spaghetti bowl of bilateral derivatives exposures, the new system held up despite unprecedented stress. Second, where do we go from here? A: I have two recommendations:  First, we need global regulatory cooperation in order to avoid reverting to fragmentation and spaghetti. Trust based on proportionate, informed reliance. Second, if we want the simpler system to keep working, global regulators need to stay ahead of the curve and keep the system under review. We cannot ignore the fire the financial system experienced in March and April last year just because central banks did a good job putting it out. We need to look behind the walls and address any faults in the wiring.