COMMODITY RISK MANAGEMENT & SURVEILLANCE POLICY

OBJECTIVE

• Risk Management & Surveillance is a must for safe & smooth trading operations of any organization.
• The main object of Risk Management & Surveillance is to mitigate the losses/debits of clients and safeguard the organization

CLIENT ID ACTIVATION & MAPPING

• RMS will activate the New Clients and map the same to concerned Branch or Authorized Person CTCL ID.
• Branches should login CTCL ID in a Dedicated System to avoid issues in client mapping like “client is not mapped” and pending order issues like order status will be shown as pending though the order is already executed and trade confirmation will also not be shown.

SPAN MARGIN

• Span Margin Report will be uploaded by IT team in co-ordination with RMS in the company’s website before start of market. Span Margin Report will help Branches and clients to check the commodity wise Span Margin

CLIENT MARGIN SHORTFALL

• Back Office sends Ledger Balance Confirmation and Long Short Position Report to all the clients by SMS.
• Branches need to collect client margin shortfalls of the previous trade date by 3p.m. of T+2 day for MTM loss.
• If the same is not collected within the specified time, then RMS will square off client positions at 11 p.m. after informing the concerned Branch and Authorized Person over telephone and subsequently will send a mail.
• Cheques of only those Banks, which are registered in our Back Office, will be accepted and no third party payment will be entertained.
• Cheques banked and cheques received after banking hours would be considered for MTM shortfall purposes only when the required scan images are sent to Funds & RMS Department.
• Demand Drafts are not accepted unless accompanied by client letter in specified format.

MARKED TO MARKET (MTM)

• Branches need to monitor closely the MTM loss of their clients and inform to the concerned client from time to time via SMS alerts and delivery depends upon the operator.
• RMS will sent Marked to Market (MTM) alert message at 50%, 60% & 70% through sms to the respective clients and delivery depends upon the operator. .
• MTM shortfall needs to be collected and updated before 70% MTM loss to hold the client positions.
• If the MTM shortfall is not collected and updated before 70% MTM Loss, the client positions will be squared off by RMS through Auto Square off at 70% MTM Loss and will inform the same to Branches overtelephone.
• If the MTM Loss of a client reaches 70% at the close of agri market or non-agri market all the open positions will be closed by RMS.
• But in case of heavy position in client account using exposure company has the right to· square off trade or can ask to reduce position and keep position as per margin available in ledger else RMS will square off the position at any point before reaching 70% it can be 50% MTM loss also.

POSITION LIMITS (CLIENT LEVEL)

• Client Level Position Limit in any commodity will be allowed as specified by the exchange.
• Branch or Authorized Person should have information about Client Level Position Limit before allowing huge positions to any client.
• If client exceeds the Client Level Position Limit in any commodity of the exchange, then RMS will inform the same to the concerned Branch or Authorized Person to square off excess positions immediately. If any Branch or Authorized Person is unable to square off, then RMS will square off the same so as to avoid any penalty by exchange

POSITION LIMITS (MEMBER LEVEL)

• Member Level Position Limit in any commodity should be maintained as specified by the exchange i.e. Fixed Limit or 15% of the market-wide open position, whichever is higher.
• If, Member Level Position Limit exceeds in any commodity, exchange will inform to the Member, then Member need to square off the positions immediately “last in last out basis” else Member will put in square off mode in that commodity.

COMPULSORY DELIVERY

• Long Positions & short position in Compulsory Delivery contracts like Gold, Gold Mini, Silver, should be closed before one day of Tender Period starting date by 8.00 p.m. Copper, Lead, Lead Mini, Aluminum, Aluminum Mini, Zinc, Zinc Mini and Nickel should be closed before one day of Tender Period starting date by 8:00 p.m

Note:

Delivery logic – Compulsory Delivery

Tender Period – Last 5 working days of the contract Expiry and 1st working day after expiry of the contract

• If Tender Period starts date falls on Monday-Friday to avoid Delivery Allocation or Delivery Penalty by Exchange.
• Long Positions or Short Positions in Compulsory Delivery commodities viz., Gold Petal, Gold Guinea, Agri Commodities can be held till the last day of contract Expiry but should be closed before one hour of close of Expiry period.