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Interest rate benchmark reform
6 Months Ended
Jun. 30, 2021
Disclosure Of Interest Rate Benchmark Reform [Line Items]  
Disclosure of how entity is managing transition to alternative benchmark rates, its progress at reporting date and risks to which it is exposed arising from financial instruments because of transition [text block]
Note 13
 
Interest rate benchmark reform
Background
A
 
market-wide
 
reform
 
of
 
major
 
interest
 
rate
 
benchmarks
 
is
being undertaken globally,
 
with the Financial
 
Conduct Authority
(the
 
FCA)
 
announcing
 
in
 
March
 
2021
 
that
 
the
 
publication
 
of
London
 
Interbank Offered
 
Rates (LIBORs)
 
will
 
cease for
 
all
 
non-
US dollar
 
LIBORs, as
 
well as
 
for one-week
 
and two-month
 
USD
LIBOR,
 
after
 
31 December
 
2021.
 
Publication
 
of
 
the
 
remaining
USD LIBOR tenors will cease immediately after 30 June 2023.
The majority of
 
UBS’s Interbank Offered
 
Rate (IBOR) exposure
is
 
to
 
CHF
 
LIBOR
 
and
 
USD
 
LIBOR.
 
The
 
alternative
 
reference
 
rate
(
ARR
)
 
for
 
CHF
 
LIBOR
 
is
 
the
 
Swiss
 
Average
 
Rate
 
Overnight
(SARON).
 
Th
e
ARR
for
 
USD
 
LIBOR
 
is
 
the
 
Secured
 
Overnight
Financing Rate (SOFR); in addition, there are recommended
 
ARRs
for GBP LIBOR, JPY LIBOR and EUR LIBOR. For certain
 
products in
the US,
 
UBS is
 
considering the use
 
of credit-sensitive
 
rates as an
alternative to SOFR.
As
 
of
 
30 June
 
2021,
 
transition
 
uncertainty
 
with
 
respect
 
to
significant interest
 
rate benchmarks
 
remains, with
 
the exception
of
the
Euro
 
Interbank
 
O
ffered
 
Rate
(
Euribor
).
The
 
reform
 
of
 
Euribor
 
is
 
now
 
complete
 
and
 
consisted
 
of
 
a
 
change
 
in
 
the
underlying calculation method.
 
The transition
 
to ARRs includes
 
a number
 
of active
 
steps that
will
 
also
 
benefit
 
from
 
the
 
support
 
of
 
associated
 
regulatory
activities. There may be some contracts, known as “tough legacy
contracts,”
 
that
 
cannot
 
be
 
practically
 
transitioned
 
or
 
amended
from
 
IBORs
 
to
 
ARRs
.
The
 
FCA
 
continues
 
to
 
consult
 
market
 
participants
 
about
 
requiring
 
the
 
ICE
 
Benchmark
 
Administration
to
 
continue
 
publishing
 
certain
 
LIBOR
 
settings
 
(i.e.,
 
one-,
 
three-
and
 
six-month
 
settings
 
for
 
the GBP,
 
JPY
 
and
 
USD
 
LIBORs)
 
on
 
a
“synthetic”
 
basis, which are not representative
 
of the underlying
financial
 
markets,
 
for
a
 
certain
 
duration
after
3
1
 
December
2021.
 
However, these
 
synthetic LIBORs
 
will
 
not be
 
available for
use
 
in
 
new
 
contracts,
 
given
 
that
 
they
 
are
 
non-representative,
and
 
are
 
instead
 
intended
 
to
 
help
 
reduce
 
disruption
where
resolution
 
has
 
not
 
been
 
agreed
for
 
certain
 
tough
 
legacy
contracts.
 
Furthermore,
 
in
 
February
 
2021,
 
the
 
EU
 
Benchmarks
Regulation
 
was
 
amended
 
to
 
enable
 
the
 
European
 
Commission
to designate a statutory replacement rate for tough legacy LIBOR
contracts
 
that
 
are
 
governed
 
by
 
the
 
laws
 
of
 
EU
 
Member
 
States
and remain
 
outstanding after
 
LIBOR cessation.
 
On 6 April
 
2021,
New York State LIBOR
 
legislation was enacted with
 
the intention
of
 
minimizing
 
legal
 
uncertainty
 
and
 
adverse
 
economic
 
effects
associated with
 
USD LIBOR
 
transition for
 
tough legacy
 
contracts
governed
 
by
 
New
 
York
 
law.
 
For
 
USD
 
LIBOR
 
contracts
 
not
governed
 
by
 
New
 
York
 
law,
 
a
bill
 
has
 
been
 
introduced
 
in
Congress with similar objectives.
In
 
October
 
2020,
 
the
 
International
 
Swaps
 
and
 
Derivatives
Association
 
(ISDA)
 
released
 
the
 
IBOR
 
Fallbacks
 
Supplement
 
and
IBOR Fallbacks
 
Protocol, amending
 
ISDA standard
 
definitions for
interest-rate
 
derivatives
 
to
 
incorporate
 
fallbacks
 
for
 
derivatives
linked
 
to
 
certain
 
IBORs.
 
The
 
changes
 
came
 
into
 
effect
 
on
25 January 2021 and, from that date, all
 
newly cleared and non-
cleared derivatives between adhering
 
parties that reference ISDA
standard definitions now include these fallbacks. UBS adhered to
the protocol in November 2020.
UBS is focused on transitioning existing contracts via
 
bi-lateral
and multi-lateral
 
agreements, leveraging industry
 
solutions (e.g.,
the
 
use
 
of
 
fallback
 
provisions)
 
and
 
through
 
third-party
 
actions
(clearing
 
houses,
 
agents
,
 
etc
.
).
Furthermore,
 
in
 
line
 
with
regulatory guidance
 
UBS has
 
implemented a
 
framework to
 
limit
entry into new contracts referencing IBORs.
Governance over the transition to alternative benchmark rates
UBS
 
has
 
established
 
a
 
global
 
cross-divisional,
 
cross-functional
governance structure
 
and change
 
program
 
to address
 
the scale
and
 
complexity
 
of
 
the
 
transition.
 
This
 
global
 
program
 
is
sponsored
 
by the
 
Group
 
CFO and
 
led by
 
senior
 
representatives
from
 
the
 
business
 
divisions
 
and
UBS’s
control
 
and
 
support
functions.
 
The
 
program
 
includes
 
governance
 
and
 
execution
structures
 
within
 
each
 
business
 
division,
 
together
 
with
 
cross-
divisional
 
teams
 
from
 
each
 
control
 
and
 
support
 
function.
Progress is overseen centrally
 
via a monthly operating committee
and a
 
monthly steering
 
committee, as
 
well as
 
quarterly updates
to the joint Audit and Risk committees.
Risks
A
 
core
 
part
 
of
 
UBS’s
 
change
 
program
 
is
 
the
identification,
management
 
and
 
monitoring
 
of
 
the
 
risks
 
associated
 
with
 
IBOR
reform and transition. These
 
risks include,
 
but are not limited
 
to,
the following:
 
economic risks to UBS and its
 
clients, through the repricing of
existing
 
contracts,
 
reduced
 
transparency
 
and
 
/
 
or
 
liquidity
 
of
pricing information, market uncertainty or disruption;
 
accounting
 
risks, where
 
the transition
 
affects the
 
accounting
treatment,
 
including
 
hedge
 
accounting
 
and
 
consequential
income statement volatility;
 
valuation risks arising from the variation between benchmarks
that will cease
 
and ARRs, affecting
 
the risk profile of
 
financial
instruments;
 
operational risks
 
arising from
 
changes to
 
UBS’s front-to-back
processes and systems to accommodate the transition, as well
as
 
the
 
revision
 
of
 
operational
 
controls related
 
to
 
the
 
reform;
and
 
legal
 
and
 
conduct
 
risks
 
relating
 
to
 
UBS’s
 
engagement
 
with
clients
 
and
 
market
 
counterparties
 
around
 
new
 
benchmark
products
 
and
 
amendments
 
required
 
for
 
existing
 
contracts
referencing benchmarks that will cease.
In
 
some
 
cases,
 
contracts may
 
contain
 
provisions intended
 
to
provide a fallback interest
 
rate in the event of a brief unavailability
of the relevant
 
IBOR. These provisions
 
may not be effective
 
or may
produce arbitrary results
 
in the event of a permanent cessation of
the
 
relevant
 
IBOR.
 
While
 
efforts
 
to
 
transition
 
outstanding
transactions from IBORs to ARRs have
 
made substantial progress,
including through industry-wide
 
protocols,
 
such as the ISDA IBOR
Fallbacks Supplement and
 
IBOR Fallbacks
 
Protocol, there
 
are
 
still
substantial volumes
 
of
 
transactions that
 
require
 
modification to
effectively
 
transition
 
to ARRs.
UBS remains
 
confident that
 
it has
 
the transparency,
 
oversight
and
 
operational
 
preparedness
to
 
progress
 
with
 
the
 
IBOR
transition consistent with
 
market timelines. UBS
 
does not expect
changes
 
to
 
its
 
risk
 
management
 
approach
 
and
 
strategy
 
as
 
a
result of interest rate benchmark reform.
 
Progress made during 2020 and the first half of 2021
Approaches to transition vary by product type. During 2020, UBS
transitioned
 
most
 
of
 
its
 
CHF
 
LIBOR-linked
 
deposits
 
to
 
SARON
and
launched
 
SARON
-
based
 
mortgages
 
and
 
corporate
 
loans
based
 
on
 
all
 
major
 
ARRs
 
in
 
the
 
Swiss
 
market,
 
as
 
well as
 
SOFR-
based
 
mortgages
 
in
 
the
 
US
 
market.
 
By
 
the
 
end
 
of
 
the
 
second
quarter
 
of
 
2021,
 
UBS
 
ha
d
 
successfully
 
transitioned
 
its
 
GBP
LIBOR- and
 
EUR LIBOR-based
 
private and
 
commercial real
 
estate
mortgages
 
in
 
the
 
UK
 
and
 
Monaco
 
to
 
the
 
Sterling
 
Overnight
Index
 
Average
 
(
SONIA
)
 
and
 
Euribor
,
 
respectively.
 
UBS
 
has
detailed
 
plans
 
in
 
place
 
to
 
deliver
 
the
 
required
 
changes
 
for
 
all
other IBOR exposures, predominantly during 2021.
Financial instruments yet to transition to alternative benchmarks
The
 
amounts
 
included
 
in
 
the
 
table
 
below
 
relate
 
to
 
financial
instrument
 
contracts across
 
UBS’s business
 
divisions
 
where
 
UBS
has material
 
exposures subject
 
to IBOR
 
reform that
 
have not
 
yet
transitioned to ARRs, and that:
contractually
 
reference
 
an
 
interest
 
rate
 
benchmark
 
that
 
will
transition to an alternative benchmark; and
 
have
 
a
 
contractual
 
maturity
 
date
 
(including
 
open-ended
contracts) after the agreed cessation dates.
 
 
Contracts
 
where
penalty
 
terms
reference
 
IBORs
,
 
or
 
where
exposure to
 
an IBOR
 
is not
 
the primary
 
purpose of
 
the contract,
have
 
not
 
been
 
included,
 
as
 
these
 
contracts
 
do
 
not
 
have
 
a
material impact
 
on the
 
transition process.
 
In addition,
 
contracts
that have been
 
changed to incorporate
 
ARR-based interest rates
before the
 
relevant cessation
 
date have
 
been excluded
 
from the
table below,
 
because UBS
 
expects no
 
further transition
 
work to
implement the reform.
In
 
line
 
with
 
information
 
provided
 
to
 
management
 
and
external
 
parties
 
monitoring
 
UBS’s
 
transition
 
progress,
 
the
 
table
below
 
includes
 
the
 
following
 
financial
 
metrics
 
for
 
instruments
subject to interest rate benchmark reform:
 
gross
 
carrying
 
value
 
/
 
exposure
 
for
 
non-derivative
 
financial
instruments;
 
and
 
 
total trade count for derivative financial instruments.
 
The
 
exposure
s
 
included
 
in
 
the
 
table
 
below
 
represent
 
the
maximum
 
IBOR
 
exposure,
 
with
 
the
 
actual
 
IBOR
 
exposure
 
being
dependent
 
upon
 
client
 
preferences
 
and
 
investment
 
decisions.
Overall,
 
the
 
effort
 
required
 
to
 
transition
 
is
 
affected
 
by
 
multiple
factors, including
 
whether negotiations
 
need to
 
take place
 
with
multiple
 
stakeholders
 
(as
 
is
 
the
 
case
 
for
 
syndicated
 
loans
 
or
certain
 
listed
 
securities),
 
market
 
readiness
 
 
such
 
as
 
liquidity
 
in
ARR
 
equivalent
 
products
 
 
and
 
a
 
client’s
 
technical
 
readiness
 
to
handle ARR market conventions.
As significant IBOR exposures
 
transition to ARRs during
 
2021,
the values and trade count disclosed are expected to decrease.
30.6.21
LIBOR benchmark rates
1
Measure
CHF
USD
GBP
EUR
2
JPY
XCCY
Carrying value of non-derivative financial instruments
Total non-derivative financial assets
 
USD million
31,423
77,502
1,829
6,587
3,070
3,796
3
Total non-derivative financial liabilities
 
USD million
2,029
9,834
566
1,919
1,060
0
Trade count of derivative financial instruments
Total derivative financial instruments
Trade count
9,519
42,566
12,513
9,626
4,247
5,948
4
Off-balance sheet exposures
Total irrevocable loan commitments
USD million
1
4,433
0
0
0
15,767
5
31.3.21
LIBOR benchmark rates
1
Measure
CHF
USD
GBP
EUR
2
JPY
XCCY
Carrying value of non-derivative financial instruments
Total non-derivative financial assets
 
USD million
36,046
72,185
5,399
8,253
3,060
4,469
3
Total non-derivative financial liabilities
 
USD million
2,612
13,142
1,429
2,252
1,460
0
Trade count of derivative financial instruments
Total derivative financial instruments
Trade count
9,749
40,080
13,006
9,613
3,961
5,206
4
Off-balance sheet exposures
Total irrevocable loan commitments
USD million
106
4,656
167
0
0
15,188
5
1 Contracts have been disclosed without
 
regard to early termination rights.
 
Instead, it is assumed that such
 
contracts will transition away
 
from IBORs without such rights being
 
exercised.
 
2 Includes primarily EUR
LIBOR positions.
 
3 Includes loans related to revolving multi-currency credit lines.
 
4 Includes cross-currency swaps where either leg or both legs are indexed to an IBOR.
 
5 Includes loan commitments that can be
drawn in different currencies at the client‘s discretion.
Non-derivative instruments
UBS’s
 
significant
 
non-derivative
 
IBOR
 
exposures
 
primarily
 
relate
to
 
brokerage
 
receivable
 
and
 
payable
 
balances,
 
corporate
 
and
private loans, and mortgages, linked to CHF and USD LIBORs.
In
 
March
 
2021,
 
following
 
the FCA
 
announcement
 
regarding
the
 
cessation
 
timelines
 
for
 
IBORs,
 
UBS
 
started
 
a
 
centralized
communication
 
initiative
 
for
 
private
 
mortgages
 
linked
 
to
 
CHF
LIBOR, with
 
the objective
 
of transitioning
 
these exposures
 
either
through the activation of existing fallbacks
 
or the amendment of
contractual terms,
 
where such fallbacks
 
do not exist.
 
During the
second
 
quarter
 
of
 
2021,
 
mortgages
 
that
 
were
 
linked
 
to
 
CHF
LIBOR
 
have
 
been
 
reduced
 
by
 
approximately
 
USD
2
 
billion
 
and
the
 
remaining
 
USD
3
 
billion
 
of
 
mortgages
 
linked
 
to
 
GBP
 
LIBOR
as
 
of
 
31
 
March
 
2021
have
successfully
 
transitioned
.
 
US
 
mortgages
 
linked
 
to
 
USD
 
LIBOR
 
are
 
planned
 
to
 
transition
 
to
SOFR from 2022–2023.
 
US securities-based lending increased
 
by
approximately USD
4
 
billion in the
 
second quarter of
 
2021, with
agreements
expected
to
 
switch
 
to
 
an
alternative
 
benchmark
 
from the fourth quarter of 2021.
UBS is
 
also proactively
 
discussing transition
 
mechanisms with
many of its brokerage and corporate clients in
 
order to transition
their
 
exposures
 
throughout
 
2021
 
from
 
CHF
 
LIBOR,
 
EUR
 
LIBOR
and
 
GBP
 
LIBOR.
 
During
 
the
 
second
 
quarter
 
of
 
2021,
 
the
 
gross
carrying amount
 
of IBOR-indexed
 
non-derivative financial
 
assets
and
 
liabilities
 
r
elated
 
to
 
brokerage
 
accounts
,
predominantly
 
linked
 
to
 
GBP
 
and
 
USD
 
LIBOR,
 
was
 
reduced
 
by
 
approximately
USD
8
 
billion in aggregate as a result of successful transitions.
For
 
certain
 
non-derivative
 
financial
 
assets
 
and
 
financial
liabilities,
 
in
 
particular
 
bonds
 
issued
 
by
 
third
 
parties,
 
UBS
 
is
dependent
 
on
 
the
 
participation
 
and
 
engagement
 
of
 
others
 
in
effecting
 
the
 
transition
 
from
 
IBORs.
 
UBS
 
is
 
actively
 
monitoring
such exposures and is in discussions with clients.
As
 
presented
 
in
 
the
 
table
 
on
 
the
 
previous
 
page,
 
UBS
 
had
approximately USD
16
 
billion (31 March 2021, USD
15
 
billion) of
irrevocable commitments as
 
of 30 June
 
2021 that can
 
be drawn
down
 
in
 
different
 
currencies
 
with
 
IBOR-based
 
interest
 
rates,
primarily
 
USD
 
LIBOR
and
 
Euribor,
 
and
 
that
expire
 
after
 
the
relevant
benchmark
cessation
 
dates
.
 
Related
 
drawn
-
down
amounts
 
under
 
these
 
commitments
were
USD
 
4
 
billion
 
(31 March 2021, USD
4
 
billion).
In addition,
 
UBS had
 
approximately USD
10
 
billion (31 March
2021
,
USD
 
16
 
billion
)
 
of
 
committed
 
revocable
 
credit
 
lines
outstanding that
 
allow clients
 
to draw down
 
a number of
 
IBOR-
linked products. UBS is in
 
discussions with impacted clients, with
plans
 
in
 
place
 
to
 
have
 
all
 
contracts
 
amended
 
by
 
the
 
relevant
cessation dates.
Derivative instruments
 
UBS
 
holds
 
derivatives
 
for
 
trading
 
and
 
hedging
 
purposes,
including those
 
designated in
 
hedge accounting
 
relationships. A
significant
 
number
 
of
 
interest
 
rate
 
and
 
cross-currency
 
swaps
have
 
floating
 
legs
 
that
 
reference
 
various
 
benchmarks
 
that
 
will
cease.
The
 
majority
 
of
 
derivatives
 
are
 
transacted
 
with
 
clearing
houses
where
 
UBS
 
is
 
dependent
 
upon
 
industry
-
wide
compression
 
activities
 
to
 
reduce
 
exposure
 
and
 
clearing
 
house
actions to convert any
 
remaining derivatives nearer the
 
cessation
dates. London Clearing House (LCH), which is
 
the clearing house
for a
 
significant number
 
of UBS’s
 
IRS derivatives,
 
has confirmed
that
 
a
 
standardized
 
transition
 
will
 
be
 
undertaken
 
in
 
December
2021
 
to
 
transition
 
IBOR-based
 
derivatives
 
to
 
respective
 
ARRs.
UBS expects derivative
 
volumes to fluctuate
 
in line with
 
business
activity until such clearing house actions are taken.
For
 
derivatives
 
not
 
transacted
 
with
 
clearing
 
houses,
 
as
previously
noted,
 
UBS
 
adhered
 
to
 
the
 
ISDA
 
IBOR
 
Fallback
Protocol in
 
November 2020,
 
although its
 
preferred approach,
 
in
line
 
with
 
regulatory
 
expectations,
 
is
 
to
 
actively
 
switch
 
to
 
ARRs
before
 
the
 
relevant
 
cessation
 
dates
 
or
 
to
 
bilaterally
 
compress
where feasible.
 
UBS has
 
begun a
 
series of
 
outreach activities
 
to
understand
 
counterparties’
 
intentions
 
regarding
 
whether
 
they
seek to adhere to the protocol or will actively switch.
In
 
order
 
to
 
minimize
 
the
 
operational
 
risk
 
of
 
converting
 
high
volumes of
 
transactions at
 
the time
 
of cessation,
 
UBS is
 
making
progress
 
with
 
its
 
preparations
 
to
 
convert
 
derivative
 
instruments
in bulk to ARR equivalents.