February  2006  Market  Clearing  in  the  Energy  Industry  5-38  ©  Copyright  2006,  CCRO.  All  rights  reserved.  participants  supplying  greater  numbers  of  bids  and  offers.  Increased  market  participation  and  numbers  of  bids  and  offers  should  drive  market  liquidity  and  transparency.  However,  market  clearing  of  power  markets  may  also  include  fees  and  brokerage  costs  that  a  participant  does  not  currently  incur  and  typically  employ  risk  management  practices  that  correlate  collateral  requirements  to  market  risk.  Additionally,  risk  management  practices  employed  by  clearing  vendors  employ  daily  cash  settlements  of  mark-to-market  positions  to  mitigate  default  risk  and  limit  the  extent  of  collateral  that  is  required  to  be  posted  by  a  participant  however,  the  accelerated  cash  settlement  required  by  clearing  may  introduce  additional  cash  demands  on  a  participant.  All  of  these  costs  may  cause  some  participants  to  be  unable  to  participate,  or  limit  their  participation  in  cleared  markets.  In  this  regard,  it  is  critical  for  potential  participants  to  measure  accurately  and  completely  the  costs  associated  with  non-cleared  transactions.  Often  exposures  that  are  unfunded  involve  costs  that  are  less  obvious  than  settling  marks  but  just  as  real.  Comparing  costs  must  also  take  into  consideration  the  benefits  of  netting,  which  is  far  less  available  in  non-cleared  transactions.  5.6.1.  Benefits  of  clearing  The  most  commonly  cited  benefits  of  market  clearing  for  the  energy  markets  relate  to  capital  efficiency  and  risk  reduction,  both  systemically  and  for  individual  market  participants.  The  concentration  of  transactions  with  a  single  central  counterparty  provides  for  the  netting  of  long  and  short  positions  in  correlated  products  and  across  correlated  time  periods  within  the  same  product,  as  well  as  inter  and  intra  commodity  spread  credits.  This  netting  of  positions  leads  to  the  calculation  of  a  single  initial  margin  for  a  market  participant  within  a  clearing  platform.  This  single  initial  margin  amount  may  be  significantly  less  than  the  amount  of  collateral  required  for  the  same  position  if  the  transactions  are  spread  amongst  bilateral  counterparties  through  transactions  that  are  not  cleared.  Initial  margin  covers  a  very  real  risk:  typically  the  worst  case  of  loss  of  the  customers  portfolio  at  a  certain  confidence  interval  (often  99%),  over  a  specified  holding  period,  modeled  under  different  scenarios  accounting  for  price  change  and  the  risk  of  loss  above  marks.  While  a  participant  must  collateralize  this  risk,  it  is  also  relieved  from  a  similar  risk  exposure  to  its  counterparty  through  clearing.  This  reduction  in  exposure  mitigates  or  completely  offsets  the  cost  of  initial  margin,  depending  upon  the  measurement  of  the  cost  of  the  counterparty  risk  exposure.  However,  a  market  participant’s  initial  margin  may  actually  be  greater  than  its  required  margin  with  a  group  of  counterparties  for  the  same  consolidated  position.  This  may  occur  because  of  the  spread  of  transactions  among  counterparties,  due  to  large  credit  limits  reflecting  strong  credit  quality,  or  because  bilateral  counterparties  generally  do  not  capture  a  volatility  of  exposure  in  their  margin  requirements  as  is  common  practice  in  cleared  markets.  The  application  of  SPAN  parameters  (Standardized  Portfolio  Analysis  of  risk)  to  products  such  as  physically  settled  power  might  indeed  drive  very  high  margin  requirements  that  exceed  those  from  bilateral  counterparties.  Market  clearing,  including  the  use  of  margin,  most  often  with  an  accelerated  settlement  cycle,  and  netting,  provide  for  the  capital  efficiency  and  risk  reduction  benefits  illustrated  above.  ISO-NE  provides  a  prime  example  of  this  systemic  benefit,  where  it  
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