
DMIST, the Derivatives Market Institute for Standards, published the Final Standard designed to improve the processing of position transfers in the exchange-traded derivatives markets. This is the third final standard published by DMIST, an independent organization formed by FIA in July 2022, to promote greater efficiency across the trading and clearing workflow.
The Position Transfer Standard covers the movement of open positions between accounts—whether within a single clearing member firm or across different firms. Position transfers play a critical role in managing risk, optimizing margin, correcting allocations, balancing portfolios, changing clearing relationships and handling ownership changes due to mergers or acquisitions.
Currently, the position transfer process is largely manual. By introducing a standardized approach, DMIST aims to strengthen operational efficiency and resiliency, lower regulatory and operational risk by reducing manual intervention, and improve communication between clearing members and clients. This new standard lays the groundwork for greater automation of the process going forward.
Samina Anwar, senior director of global derivatives operations at Cargill and chair of the DMIST Sponsor Board, said: “Position transfers are crucial for clients to manage risk and optimize margins efficiently. A standardized approach ensures a more streamlined, consistent process for clients and fewer errors. Clearing members, clients, clearinghouses, and service providers collaborated to create this standard, which demonstrates the value of bringing together a diverse range of industry participants to discuss and shape solutions that benefit everyone.”
Tim Hoopes, executive director, Morgan Stanley and leader of the DMIST Position Transfer Working Group: “This standard introduces a new level of consistency and structure to the position transfer process. It harmonizes and streamlines two critical steps in the process: communication from the client to the clearing member, and from the clearing member to the central counterparty (CCP)—while also drawing a distinction between simple and complex transfers.”
Don Byron, executive director, DMIST: “This is a real success story for both the industry and DMIST. The Position Transfer Standard will drive meaningful change. The clearing members, clients, CCPs and service providers who collaborated during the standard development process can be proud of what they have achieved.”
Final Standard
The Position Transfer Final Standard establishes 1) a template clients can use to submit a position transfer request to its clearing member(s) and a standard template for clearing members to more easily upload position transfer data to CCPs; and (2) a corresponding standard template for CCPs to adopt for receiving data from clearing members.
The standard is accompanied by a guidebook, which provides detailed information about each field in the client request form. DMIST will continually update the client request form and guidebook based on feedback from market participants.
The standard also defines timing for simple and complex position transfers. It recommends that:
- Simple position transfers requested five hours ahead of the market clearing close be completed the same day after receiving the completed client request form,
- Complex transfers be completed within 48 hours or sooner of receiving the completed client request form, and
- Complex transfers that require exchange approval be completed within 72 hours or sooner of receiving the completed client request form.
The standard also recommends that the client send the client request form simultaneously to both the originating and receiving clearing members.
The Position Transfer Implementation Working Group will continue meeting to encourage adoption of the standard. An API Focus Group will publish guidance for a standard API, using the fields identified in the CCP upload functionality table. The working group also will create an implementation guide to provide additional guidance to CCPs and service providers that are implementing the standard.