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by kridsdale1 1962 days ago
Vlad said live on air (in Clubhouse) in conversation with Elon Musk on Sunday that the clearinghouse increased their requirements from (IIRC) 30% to 100%, and that the formula for calculating that was "not transparent" and had a component that was "a multiplier based on their opinion".

RH negotiated with them all Thursday last week and reduced the required payment from $3B to ~$0.7B. So it sure seems like the DTCC made an arbitrary decision to jack up systemic safety cushion that resulted in the RH clients turning very sour.

2 comments

DTCC has higher requirements for concentrated positions than for other uncleared CNS positions. Couple this with Robinhood laying out its own capital to fund margin trades and Robinhood Instant trades, and you've got some pretty aggressive capital commitments.

  (PROCEDURE XV)
  288
  II. if the absolute value of the largest non-index position in the portfolio
  represents more than 30 percent of the value of the entire portfolio (the
  “concentration threshold”), an amount determined by multiplying the gross
  market value of such position by a percentage designated by the
  Corporation, which percentage shall be not less than 10 percent. Such
  percentage shall be determined by selecting the largest of the 1st and
  99th percentiles of three-day returns of a composite set of equities, using
  a look-back period of not less than 10 years that includes a one-year
  stress period,2 and then rounding the result up to the nearest whole
  percentage.
  The concentration threshold would be no more than 30 percent, and would
  be determined by the Corporation from time to time and calibrated based
  on the portfolio’s backtesting results during a time period of not less than
  the previous 12 months.
Also, the fact that the man running Robinhood gave out material nonpublic information on a a private podcast with a billionaire says a lot about his judgment, in my opinion.
> had a component that was "a multiplier based on their opinion"

I'll chalk this up to colloquialism. The DTCC has very little discretion in what they do. That's why they're trusted to do it.

The "opinion" component could be a reference to their line of credit banks, who adjust the rates they charge the DTCC based on their varied risk models. There is a valid argument that there isn't as much transparency in that layer as there could be. But that isn't relevant to this case.

Any off-the-shelf collateral cost estimation tool should have told you, given GME's realized volatility in the week prior to the fiasco, that it was a high clearing risk. If the CEO is getting blindsided by the DTCC at 3AM, it's a oversight of internal controls.

> RH negotiated with them all Thursday last week and reduced the required payment from $3B to ~$0.7B

Negotiating collateral requirements involves netting out trades and delaying settlement on some trades and accelerating settlement on others. It does not involve recomputing collateral rules. (The DTCC can't recompute collateral rules for one member over another.)

To add to your comment:

In his chat with Elon Musk, the RH CEO said that Robinhood was given the $3B bill at 3am in the morning, and got it down to $0.7B after saying they would only allow closing out of positions for "meme stocks".

By his own words, RH took the first step to "change the game", which I am not really seeing discussion of anywhere. The DTCC certainly did not change any rules for them, but this still feels unprecedented.

No, the multiplier is from the "Margin Liquidity Adjustment Charge". It was raised so the brokers had to front 100% of purchase prices for 2 days.

People keep referring to a super transparent formula, yet nobody has actually been able to point me to what this formula actually is.

Seems quite opaque to me, actually.