10: ICE Clear Credit Treasury Clearing Offering

Welcome to Tonic Boom, a specialist capital market podcast series brought to you by Tonic, the expert he has led consultancy dedicated to giving firms more. Join our host, our resident Tonic Ninjas, and industry experts, as we drop the mic on the hot market topics across high profile domains such as margin, post-trade, treasury, risk, digital, legal, sustainability, and more. More expertise, more trust, more achieved. Ready for your dose of Tonic? Hello, hello, and welcome to Tonic Boom. For those tuning in for the first time, Boom is Tonic's expertise led podcast series where we dive into the hottest topics across capital markets and beyond. I'm Chris Watts, Tonic CEO and co-founder and your host for today's episode, and we are really excited about this one, with today's Tonic Boom titled "US Treasury Clearing Ice Insights". Now, unless you've been living under a rock recently, you'll know that treasury clearing represents one of the biggest reg developments to hit the markets in recent years. We all know central clearing has long been the cornerstone of safe and resilient markets. By managing counterparty risk and enhancing transparency, clearing has already hugely strengthened the derives and repo ecosystems. But now, clearing attention has turned to US Treasuries, the largest governance bond market in the world. We're super psyched to introduce our special guest with us here today who's right at the heart of the treasury clearing changes playing out. A true industry leader, please welcome Helen Furmore, COO of IceClearUS. Helen, do you mind introducing yourself? My name is Helen Furmore. I am the COO at IceClearUS. I've been with ice probably about 15 years now, so very much been in the clearing world for some time. And I would say for about 10 years of that, I was involved in us launching our credit default swap clearing house here. IceClear credit. So I'm hoping I can bring some of my insight and knowledge to this discussion today. You absolutely will. Thank you. And not forgetting from the Tonic side, we're joined by our resident clearing ninja and firm fan favorite, Philip Forkin. Philip, do you want to provide a quick intro? Absolutely. So yes, Philip Forkin here, and I lead the catcher management practice at Tonic. I've been with Tonic for about five years where we help clients navigate complex regulatory and business challenges. So US Treasuries clearing is one of those key ones for us at the moment. Awesome. Thank you, Philip. On to today's chat. I think we're going to break this into a few key themes. US Treasuries is a water clearly. Treasuries clearing no doubt has become one of the most talked about topics across global markets. And for good reason, in response to market conditions in recent years, including increased volatility, liquidity pressures, tightening reg expectations, the SEC's mandate marks a major shift in how the world's largest and most liquid government bond market will operate. Ultimate goals, we all know that I think reduce systemic risk, impose market transparency for treasury clearing, all reasonable and all with the vast majority of support from the market. But I guess this is the clincher for many market participants, this is forcing a huge amount of change and transformation. So in terms of how we got here, and a little recap, Philip, do you want to give us just a brief reset on where the industry currently sits with regards to the treasury clearing mandate, including any key updates you want to provide? Yeah, so it seems like February when the SEC announced intention to extend the deadline, that seems like an eternity ago, because so much has actually happened in the last year, which is a good thing because I sort of mentioned, Chris, it's a significant change to the financial market and so many different actors involved will have to make these changes. So we do anticipate a huge amount of challenges and issues that need to be addressed. But I think if you look back over that year and if we look from now until when the mandates go live, so 14 months before the cash mandate goes live, less than 20 months before the repo mandate goes live, these compliance dates seem a long time in the future, but firms aren't waiting until the last drop dead date. They want to be sort of doing things sooner rather than later, making sure they avoid any bottlenecks, making sure they get access to liquidity and the benefits of clear liquidity as well. So the accounting treatment on agent clear transactions that are now recognisers off-ballot sheet, that's a real win for the industry. The exclusion of mixed q-sips from clearing is really positive as well because that would have sort of grandfathered in a lot of US treasury transactions that didn't really need to be cleared and also the double margin challenge as well. That's associated with regulated money market funds. Again, there's an industry solution out there as well. So real positive direction from the industry there. In terms of ongoing challenges that still need to be addressed, but I think the key thing is, whilst they need to be addressed, folks aren't standing still, they're still moving forward. Extrateraity scope in terms of entities outside of the US, how they actually clear, and the inter-filiate exemption as well. So the industry's seeking a broader application of what is considered an inter-affiliate, so including for instance holding companies, and also looking really for that inter-affiliate exemption to apply to liquidity and collateral management affected transactions. Lots and lots of happening on the regulatory front making sure that there's clarity from the regulators, but also I think there's been a movement from am I compliant and am I impacted to, I now need to build. Thanks so much Phil. We all know, ISIS got a huge history of operating systemically important clearinghouse across a large number of asset classes, with its entry into US treasury clearing bringing a new string to its bow. We also know that ISIS capability brings the known CCP offerings for treasury clearing to three, providing direct competition to the existing FIC product offering as well as the CME offering that's coming to market. So as the clearing ecosystem matures, it's going to be fascinating to see and hear how ISIS model fits into that landscape. Helen, hoping you might be able to help us a little bit there. Do you mind sharing a bit more about ISIS treasury clearing offering? Yeah, absolutely. So you've actually gave me a good intro there by just kind of giving that background on ice in our history. I mean we have six global clearinghouses where obviously big in the future is not option space, but we've also been pretty kind of big in terms of rolling out new clearing solutions. So ISIS clear credit is our OTC credit default swap clearinghouse. It very much built out a lot of clearing workflows in response to Dodd Frank and the CDS clearing mandate. So that's been going for about 15 years. And when the SEC came out with the Treasury mandate, ISIS very much looked at this as an opportunity for us to also kind of step into that arena with our own offering. And one of the biggest things there is we're really stepping forth with a traditional clearing model that this market could utilize. And while we're using ISIS credit, it's dual regulated. So it's already a CFTC recognized DCO and it's an SEC registered CCA. So we're quite unique in the position that we have that dual regulation in a single clearinghouse. And as Phil kind of mentioned there, all this like great work that's been happening in industry this year, I would say our ice, we've made some really good progress to really get our reg approvals for treasury clearing. So we both regulators, we've been looking to extend our ice period credit recognition so that we can support both cash and repote. And so where are we at with that? We have filed our application with SEC that went into the federal register in August. There was a public comment period that was due to close early October with a government shutdown. We're obviously waiting for that to official close. But we have directly received copies of comment letters from several industry bodies. So FIA is the SIFMA aimer, etc. All positive, right? So there's comments in there recognizing the need for multiple CCAs in the space and even kind of a request for the SEC to approve our solution as soon as possible. So that's great for us. We're making good progress on those reg approvals and we're hopeful that when the government reopens, they can complete some of those governance steps themselves that will get the required approvals. And then the other kind of aspect that's worth highlighting is yes, the mandate was pushed back 12 months industry needed more time. We completely supported that delay as well. But we internally have been really working towards the end of this year to be ready for cash treasuries. So from a technology perspective, we very much are going to be operationally ready in December. And that's important for us. We recognise there's an existing clearinghouse. We're coming in to give kind of an alternate option. And we want to be up and running, showing the firms, the market participants, that there is a viable alternative. And so we will be operation ready at the end of the year. As soon as we get the reg approvals, we'll be looking to on ball clearing participants. And that will give people the opportunity to come in testing clear with us before the mandates kick in. Lovely. Thank you, Helen. That's a really helpful opener. Have you got just that of interest in equivalent target date for the repo side? That will be introduced next year. So in terms of all the tech bill that we've done for cash, a lot of that infrastructure does apply to repo. So that's great. When we talk about how you get your trades in, some of that reporting, a lot of our risk management framework, but there are some other aspects to the repo transactions and we'll phase that in. We're targeting more kind of QTQ3 next year to start kind of supporting the repo products as well. In advance of the repo mandate for sure. It gives you a nice runway still until that repo go live in June 20th, 20th. That's more. And here you as well on the reuse of the ice clear credit application, which has obviously been accelerated for you guys to bring this new offering to markets. I think that's good context for all of us. I guess maybe going down one baby level, what makes ice as approach to treasury clearing different from maybe some of the other CCP's that we mentioned are in or due to be in this space? I think clearing in this space has obviously been happening for decades. But when you do look at how some of those flows are really being processed today, it's not what we refer to as a traditional clearing model. And when I say traditional, we're very much looking at all the clearing houses you have doing features and options, credit default swaps, interest rate swaps, etc. And that's very much an agency style model. And there's certain aspects that ice can kind of bring into this market. So when I say agency style, let me kind of talk about how you even access kind of ice tip credit for clearing. Okay. So I think that is important. There's a lot of different models in the space today. So when we talk about ice tip credit and how we will give access to the market, you can either be a direct participant. So you'll be a clearing participant that can come in clear prop business and you could offer services to customers. And then for customers, you're actually coming through a direct clearing participant. And that's very much what we refer to as the agency style ice tip credit as a clearing house is going to have that relationship with clearing participants. And then any end customer is essentially coming through the relationship they have with a clearing participant. What that means is that clients are then documenting with a clearing broker relationship to get their trades into ice tip credit. They're not actually setting up a direct relationship with us for clearing. And I would say from from ice tip credit perspective, having that kind of agency style setup, we have full segregation between customer and house. That's something historically we've always had at CDS. We will extend some of those customer access models. So there is flexibility in clearing today, but we will also give customers that flexibility. Do they want to clear into what we call the gross initial margin account? Or do they want to come into a net initial margin account? So we give them that option. And there is also flexibility in terms of who's funding their margin, okay? We know in the treasury space, big market, there's a lot of relationships there where maybe clearing participants are funding for clients. We will be offering that flexibility. And I think that's important for customers to look at commercial terms with their clearing brokers and also how we risk manage their positions. So we very much will allow customer to choose whether they're funding their margin requirement or whether their clearing participant is funding it for them. And then I think another key aspect that we kind of are bringing to the conversation is how you get your trades into clearing, okay? And that might seem like, well, that's just operation, that's an API, that's integration. But actually, it has a bigger kind of impact. I think it really kind of gets into the execution layer, okay? So today, there's a lot of discussion and industry around done with and done away relationships. And predominantly in treasury clearing space, it's done with. People are executing and clearing through the same entity. When you look at ICE and our kind of agency style model, in fact, done with and done away isn't even terms that we use in our current clearing models. We very much have models where you execute on an exchange or an OTC execution venue. You can execute with anyone on that platform. And then you clear through your chosen clearing broker relationship. And that might be one, two, if you're a large asset manager, it may be four or five clearing brokers. But it really allows you to execute with a large number of counterparties without requiring bilateral documentation. I think that's a really key thing when we talk about kind of access to market liquidity, some of the onboarding efforts that happen, and then have a relationship with just a couple of clearing breakers. And that's what you see in futures, CDS rates. And we think that is a strong model for treasury clearing. And why? This mandate is going to pick up more firms. And when those firms, like let's talk about principle trading firms, having to start clearing, it's important to them that they can execute with as many counterparties as possible. It's very large fee to be putting documentation in place with all these entities for execution and clearing. So if you break that requirement, yeah, you kind of break out that you can execute with a large number of entities and you clear with your chosen clearing brokers, just opens up that whole execution layer. So that's really a big thing that we're introducing here. And it's something we do day in day out, right? It's not saying there's a model here that we support and you could do it in the future. It's very much a model understood by a lot of dealers, by size, kind of clearing breakers today that we're also going to introduce into this space. That helps us understand where you guys sit, I think. Mr. Forkin, having any questions for Helen, just on the ISIS treasury clearing setup. What Helen mentioned, how ice will address some of the key challenges in the industry, the time to document is significant. Organizations want broad access to liquidity. This ultimately will change how organizations access liquidity. So they want to have as broad network of firms to provide them liquidity. We talk about clearing why, how does it manage in a stress scenario? You want to have access to as many liquidity providers as possible and then get the benefits of then netting down those trades and exposies into two or three clearing brokers. So it's a really powerful proposition. And I think you're mentioning the different types of margin sort of capabilities in terms of, I'm pretty sure there's option to either take 100%, 70% or zero initial margins, that right in terms of your model. If you look at the amount of margin that may need to be posted, it runs into the trillions of dollars. So having flexibility about how margin will be funded, either the clients do it themselves and post directly to the CCP. All leverage their clearing brokers to do that for them. I think having flexibility around margin as well, is really really important. The impact of this reg is significant in terms of the amount of liquidity and margin requirements. So any new capabilities and solutions around that to give clients more and more options, I think is really important. It's such a broad, when you look at the buy side, such a broad list of participants there, all have their own nuances. And therefore having a broad set of solutions is really, really helpful. I would say on the back of that, when you look at Dodd-Frank regulations under the CFTC and what was built out for CDS, the only customer kind of account we could offer was legally segregated operation in Co-mingle. That's a great, so many of us account. And the client had to fund that margin. So that's kind of what we do in the CDS world today. When you go and look at SEC regs, there's a lot more flexibility. I mean, it was only until recently that the incumbent was actually co-mingling House and customer funds. That's something that very much in traditional clearing, we don't do. We always segregate house and customer funds. There's obviously a new requirement now under the SEC to segregate, customer and house funds at a clearing house, but there is still this flexibility on a customer can clear and have their positions netted with us at other customers in the omnibus account, all they could choose to clear growth. And from our perspective, and we've kind of heard this kind of going out there and talking to the market, we originally suggested that we would support growth style accounts only. And when we went out, had those conversations, we were giving flexibility, as Phil said, it can be funded 100% by the client, 70% or 0. That's really to give that flexibility because we appreciate the funding kind of side of things, but actually there was still feedback from some of the clients in the Quimbrake community to offer that net account. So we are going to support that. The one thing we'll always say is that when a customer is reviewing the models, how they want to clear their trades, you've got to then look at the level of protection you're going to get, right? You clear into a net omnibus account, you've got mutualized risk with other clients in that account, okay? If you clear into a growth style, then the margin that we collect at your client league entity, it cannot be used for another client in that omnibus account. And so there's just things like that for people to review. But as you said, there's very different participant types in this market. So absolutely, some clients are going to want a net model. We will support that. There will be other clients, probably more the asset managers that will say, I want a growth style and I'll fund it. So it opens up a choice. And that's also one of the key things for customers when they're reviewing what's out there, what they want to support for a mandate is very much what kind of account do you want to clear into? What's the commercial terms with your clearing broker? What's the funding arrangement? It's probably one of the biggest things that people need very much consider when they get ready for this mandate. I think that flexibility is going to be a powerful benefit to any potential folk coming in for treasury clearing that haven't locked down their CCP decisions as yet. And for years to come, of course, this is also a long game, right? The compliance date is just day one. This is a new business model that is embedded now for the long term. Just one point of clarification, Helen, I know you talked about ice, don't use so much to done with, done away terminology, but here you as well on the flexibility of the service offering that's been brought to market. I guess in industry speak, does that model account for both sponsored and agent model variations? I think it does based on what you shared around. You could execute where you like and clear through a single broker, but just to confirm for our listeners. Yeah, of course. And when I say we don't raise done with done away, that kind of in our future space and our CDS space. And that's because there isn't really this kind of restriction that you execute and clear of the same entity. It's just very much kind of open access. You execute across many count parties and then you clear with your chosen clearing breakers. But then in the treasury space, of course, done with done away, it's the terms, it's what everyone knows. They, as you said, they talk about kind of sponsored relationships and agency style is something that is, I guess, less utilized in today's treasury clearing space, but also becoming a big discussion point in regards to the mandate. From ice perspective, agency style essentially covers dealer and client clearing. So we don't use the terms sponsored in our ice model, but essentially a customer is setting up a clearing relationship with a clearing discipline and they will come through and clear with us. So the difference between the models there is a client is not contracting directly with ice declared. You're not going to have a relationship with us. You have a relationship with your clearing broker and you clear through your clearing broker. Okay. So the access that you have into clearing is you very much set up as a customer account and you come through a clearing discipline. I actually think that simplifies things. That simplifies it in terms of documentation as well that yes, you've got your clearing broker relationship, but you're not contracting with us directly with clearing house. So that's kind of equivalent and absolutely for institutions that have done with relationships that works under our model. Done with done away doesn't really change how you get a trade into us because we have that full trade capture workflows for venue off venue. So we already have that kind of operational piping that if you execute a completely different entities, we can support that. We have a way to get those trades in. So I think that's a key thing. We absolutely support done with and done away. They just come through the same trade capture workflows and then it really in terms of which account you'll clear into that's into house, into customer. That's easy for us to manage. So done with will exist in our world as well, but I think we make done away far easier than the offerings that are there today. Thank you, Helen. I guess just to wrap that one up, is there anything else at all you wanted to share with our audience around ISIS Treasury offering? Yeah, look, I think talked a little bit about agency style, how you get trades in and everything like that. One of the key things that we support is immediacy of clearing. Okay, so if you execute on a platform like Bloomberg market access trade web, they're going to be able to submit that trade directly into ice clear credit. That is important. If you are principal trading firm, you're executing on these venues, you want to know when you execute that you're cleared. So we're talking about within a second, not five, ten minutes later, my current broker is consented to the trade. So again, that's activity. That's workflows we see day in day out. We do think that's going to be very important here in the Treasury space to be able to support that for principal trading firms as an example. And that's important. And I would say another thing, we get this in the clearing space in general. Okay, there's been a lot of focus on transparency in the last year, kind of 18 months. And I would say ice to credit. One of the great things is our transparency out to the end customer. So when the customers are clearing with us, they can connect to our API or interface. They're going to see their clear activity. They get access to all our end-of-day reports. They can see ice to credit's minimum margin requirement. We give them access to margin analysis tools for simulation, GUI API connections. And that might sound standard, but actually not all clearing houses provide that level of transparency down to the end customer. So if that's just something that absolutely our CDS customers know that, they like that feature that we have, that all of that will be extended into Treasury. And then look, another topic, which I think for many clearing houses is the biggest thing is risk management. And almost in this Treasury space, a lot of the focus has been very much on trade capture done with done away all the workflows. How can we clear the trades? And maybe because Treasury is a more kind of trade date T+1, there's less focus on risk. But I will say the main reason ice to credit has been so successful for CDS is our risk management framework. Okay, we have portfolio based risk model. We have very much a standard risk waterfall. So we are collecting initial margin. We calculate variation margin. We have a guarantee fund, which our clearing participants contribute to. And that's a cover too. So that's pre-funded financial resources that we manage and have access to the clearing house. We also then from ice is perspective, we contribute up to 100 million skin in the game. So it's kind of this risk waterfall process that we have very robust default management. And with that as well, we support customer reporting. We have lots of liquidation tools. So there's a lot of tools that we have, which are very common across our ice clearing houses. And absolutely, I think is pretty key to out offering filtration today. Great stuff. Thank you, Helen. Certainly helps us understand ISIS offering and no doubt any of the folk listening at home. Much appreciated. And I think that look from the market's perspective, good to see less concentration in terms of the CCP's sitting in and around Treasury clearing, right? I think that's been a theme that certainly has come out of recent industry forums and panels that we've been part of, is folk are looking for optionality and choice. I would say with that Chris, 12, 18 months ago, a lot of the response was why. We have a solution. We don't need another clearing house. But when you start really walking through what alternate offerings are, it is competition, it's innovation. We're seeing that already. And I would say fast forward 12 months later, some of the points that we've always been raising about our model are now absolutely industry conversations. There are standards being put out there because all CCAs make sure that they can support some of these kind of processes. So in that respect, we've the work we've done has definitely got it to a point now that across the industry, there is a recognition. This is a large space. It will be a good thing to have multiple CCAs. So there's a lot of work for us to do. But I think there's now a lot more recognition that there'll be more CCAs offering solutions. The thing, Mr Forkin was talking about the months that we have remaining, which is few, especially for cash, but certainly for repo as well. We know from experience that firms that start preparing now or have already will be rewarded in terms of, I guess, the ease of their compliance and the optimization of the solutions and the operating model that they're ready with the day one. I guess let's start to think a little bit about what's next. How do you expect adoption to roll out across the industry in coming months? Are there any immediate focus areas that firms should be conscious of? So I think to answer that question, you've got to look at it from a direct member and an indirect member, really, looking at the indirect members. So that's going to be thousands of funds needing to get access to liquidity in a short space of time, having to understand the different CCP offerings now, which is great. So there's more optionality, but there's more education that they need to do. So understanding the risk profiles, the account access models, etc. So there's still a big education that these organisations need to do. And then once they've got to gripped with the risk that these CCPs and the different models have, how do then start to onboard, how they start to test, how do then start to transform their own margin and collateral systems so that they can adhere to the new timings, the new marginal requirements, etc. So one angle that needs to be performed by the indirect members. The direct members, naturally, for a lot of them, they're already members of clearing houses. This is just another sort of product that they need to clear, but we may want to offer agent models and essentially client clearing models. How do they roll that out? How do they show their clients? The new capabilities, new sort of what if analysis, software, etc. that clients can use, there's quite a lot to be done. So whilst clearing is a sort of trial and tested space and we've all trodden its path, there's lots to get done to ensure that the significant amount of risk and sort of funds that need to be cleared have access to clearing in sufficient time. Very good. Thank you, sir. And is there a certain degree here of I think we've all been stunned by previous regulations that like people talk about the parallels between you and my own treasury clearing? And yeah, I can personally attest for how painful that legal and operational readiness and onboarding lift can be for firms that aren't already members today. It was a certain value to firms really beating the group, beating the curve and making those selection decisions, especially as indirect members, ASAP to give them themselves the best, the best chance of getting onboard and getting operationally ready in time for compliance. The key thing is that there are going to be liquidity benefits and capital efficiency benefits of moving to the cleared model. So firms who want to realise those benefits quickly will probably want to adopt sooner rather later. So it's well expected that liquidity and pricing will be better cleared and currently bilateral. So firms will want to take advantage of that and make sure that access these clearing capabilities sooner rather later. You want to obviously avoid any sort of last minute rush of the world. You want to have a well tested capability that's flawless rather than waiting say June 27 to move your portfolio to cleared. Absolutely, but you raise a really important point though. You raise the financial benefits which sometimes lost on folk right as well as the regulatory obligations. Helen, anything that you wanted to share just around focus areas for the street as we approach the home stretch for treasury clearing? Yeah, I think with the man that again pushed back this past year, some people did step back a little bit and part of that is also having more time to work through some of the more kind of legal reg kind of issues that feel kind of listed off in the intro. And then also to really see what these other offerings are. I can say them from my side's perspective. Until you really have a final walker, you're getting kind of close to that reg approval, it's difficult for people to really commit and say I'm going to come on board with you. So I think what we're going to see is we get our reg approvals, we're up and running kind of early next year that if you are a firm, you may be clearing already today, you may want to look and have a second option as well. If you are not clearing today and you've got to come in and be compliant with the mandate, you're going to make that decision. Are you a customer? Are you going to come in direct? And I think there's more information out there now about the different models. So I think that important education step is really happening right now. So firms can truly look at what their options are and then make that decision where are you onboarding? What model do you want access? And with everything, the integration to come in from a tech perspective is normally the longest lead time. So if you're looking to be a direct participant, that's something that really needs to kick off probably three to six months before a mandate. And we very much been trying to give flexible options. If you use a big vendor like Broadridge today, they're going to be hooked in with us. So it makes that kind of easier to come on board. But there's aspects there from a technology perspective that you've really got to start looking at in Q1. If you want to be there for a cash mandate into the year. And then I would say for those customers that are more repo-focused, a lot of discussions that are happening in the market now, even around cash, are relevant to repo. So definitely being engaged with the discussions in the industry, all the information that we're putting out there. And yeah, you've got a bit longer, but you can make it educated, informed decision as to which models you want to use. Well said, don't think we can dispute any of that from either of you. So conscious that we're coming to the end of this tonic boom, chance for me just to ask you guys whether any final thoughts, predictions before we sign off. I'll just reiterate the educational piece is really important. There's a lot out there to digest for both direct members and indirect members. I think Helen touched upon a really important factor, technology. That typically sometimes is the longest part to get implemented and how it impacts your operating models, etc. So understanding what sort of technology requirements you have for needed for clearing. And then finally, looking at the impact to your margin and your collateral teams, because we feel that there's going to be a significant change required to support that in terms of number of calls and size of calls. So preparing those departments is going to be really important. And I think for me, at the moment, there's a lot of market participants probably concerned about the mandate. There's a lot still being discussed. There's lots of decisions being made. But actually, I think, and we know this from our experience, looking at past reg mandates or huge industry implementations, it does take a reg mandate to really get market participants to look at how things are working and to then maybe look at it and say, what can we do better? So I actually think at the moment, yeah, there's a lot of work for participants, whether your execution venues, CCPs, clearing breakers dealers, but it is an opportunity to look at how things are done today. How can they be done better? And I do think then in three, five years time, you're going to look back and go, okay, we've got master process saying we've opened up some liquidity, more liquidity, I should say, on execution. There's opportunities with innovation across the industry. So I think with all the hard work that everyone's going to do to be compliant to these mandates, I think you're going to see through execution layer, clearing layer, operational tech, all these processes that actually, you're going to come out in a better place, okay. You're going to have greater efficiencies, reduce operational risk, better risk management. So that's really the positive thing that you'll see once we get through these mandates. Very good. Helen, Philip, thank you both so much for joining some awesome insights from you both. Helen, thank you especially just for bringing to life ISIS service offering really nice for us to act as a sort of platform for you guys to speak more about what you're bringing to the street. It's evident that treasury cleaning is going to bring a huge amount of change to the market, not just in the run-up to compliance with post-compliance as well. We're really reshaping the market at the moment leveraging some of the strong foundations that the CCP's and other players have laid previously. Really good to unpack some of the key opportunities actually ahead, which you guys have done nicely, including, I guess, ISIS flexible service model, as well as some of the key implementation challenges that firms and our clients will need to bypass as best as they can. Thanks as always to our listeners, here at Tonic Boom, you can find far more on the website in the way of insights, more Tonic Boom episodes, thought leadership, etc. Until next time, we'll see you again soon. You've been listening to Tonic Boom. Don't forget to like and subscribe to stay up to date on the latest developments and industry opinion for cross capital markets. Visit thetonicconsultancy.com to see more of our expertise-led insights and enter-end solutions. Tonic, more expertise, more trust, more achieved.