We have endeavored in this Ghostly little post, to raise the Ghost of an Idea, which we hope shall not put our readers out of humour with themselves, with each other, with the season, or with us.

Enduser Scrooge sat busy in his counting-house. It was cold, bleak, biting weather, but Enduser Scrooge would not put more coals upon the fire, for the price of coal had abruptly risen and he had not hedged his exposure with Newcastle Index swaps. “Bah! Humbug!” he muttered as he poured over the details of his risk management portfolio. At length the hour of shutting up the counting-house arrived, and with an ill will he dismounted from his stool and locked up the office with a growl. After taking his usual melancholy dinner in his usual melancholy tavern, Enduser Scrooge beguiled the rest of the evening with his ledger-book, and then went home to bed.

He awoke with a start to find a phantom standing before him. “Who are you?” he whispered.

“In life I was your partner, Unhedged Barley. You know that I untowardly managed all my agricultural price exposures in life. And now I’m come to tell you that three spirits will visit you; without their visits, you cannot hope to shun the path I tread. Expect the first tomorrow, when the bell tolls one.”

The Ghost of Derivatives Past

When Enduser Scrooge awoke, the clock chimed midnight and then three quarters more. He resolved to lie awake until the hour was past, and at length it broke his listening ear with a deep, dull, hollow One. The curtains of his bed were drawn aside by an unearthly visitor. “Are you the Spirit, sir, whose coming was foretold to me?” asked Scrooge.

“I am!” came the soft and gentle voice, as if from a distance. “I am the Ghost of Derivatives Past. Rise and walk with me! I am to show you the well-remembered time when you used derivatives without regard for diversifying counterparty risk.”

As the words were spoken, they passed through the wall and stood within the treasury department of the firm in which Scrooge and Barley had labored before the crisis. It was a large room, but one of broken fortunes, for the spacious offices were little used, and there was a lonely man talking on the telephone. Enduser Scrooge wept as he heard himself speak.

“Sure, let’s buy those options with Leanman Brothers. No, don’t worry about their risk of default! Every bank is much too big to fail. We can finance the purchases by selling CDS on a large diversified financial institution and insurer. Do I think the paper has any risk? Certainly not – if enough mortgages are packaged together, in the aggregate they lose all risk of default, no matter which tranche you own.”

The Ghost looked at him sagely. “So you see, do you not, that your choosing to disregard counterparty risk of default led you and many others to great sorrow?”

“Remove me from this place, Spirit!” said Enduser Scrooge in a broken voice. “I cannot bear it!” He was suddenly conscious of being exhausted and overcome by an irresistible drowsiness.

The Ghost of Derivatives Present

Awaking in the middle of a prodigious snore, and sitting up in bed to get his thoughts together, Enduser Scrooge had no occasion to be told that the bell was again upon the stroke of two. When no shape immediately appeared, he was taken with a violent fit of trembling, but then a strange voice called his name. He glanced up to see a jolly Giant, glorious to see, bearing a glowing torch not unlike Plenty’s horn, who held it high up to shed its light on Enduser Scrooge.

“Come forth!” exclaimed the Ghost. “Come forth, and know me better! I am the Ghost of Derivatives Present. Come forth, and let me show you the fruits of your current procrastination. Touch my robe!”

Scrooge did as he was told and held it fast. All the room vanished instantly, and they stood in the great hallway of the counting-house. It was a remarkable quality of the Ghost that notwithstanding his gigantic size, he could accommodate himself to any place with ease, and so they came inside the company’s file room to a huge stack of documents. One by one the Ghost lifted them up for Enduser Scrooge to behold.

“Observe,” said he, “no sign that you have prepared in any way for compliance with the Dodd-Frank Act. If you are a financial entity, where is the evidence that you have evaluated any potential FCMs, negotiated and signed Clearing Agreements or OTC Addenda with them, or obtained Cleared Derivative Execution Agreements with your dealers? Even if you are a non-financial entity qualifying for the end-user exception, I see no indication that you have amended your ISDAs to comply with Dodd-Frank, or gathered the fact pattern to demonstrate that you are an eligible contract participant.”

“No more, Spirit, no more!” Enduser Scrooge wailed. “I am woefully unprepared for the new regulatory regime; show me no more!” Just then the Ghost vanished, and the bell struck three.

The Ghost of Derivatives Future

The third Phantom slowly, gravely, silently approached. When it came, Scrooge bent down upon his knee; for in the very air through which this Spirit moved it seemed to scatter gloom and mystery. It was shrouded in a deep black garment, which concealed its head, its face, its form, and left nothing of it visible save one outstretched hand.

“Am I in the presence of the Ghost of Derivatives Yet to Come?” asked Enduser Scrooge.

The Spirit answered not, but pointed onward with his hand. They scarcely seemed to enter Scrooge’s office; for rather the office seemed to spring up about them, and encompass them of its own act. They passed through the walls into the executive boardroom, where Scrooge could see the two divisions of his company in desperate straits to justify their respective financial positions to the board.

One division head said: “Why are our earnings so volatile when they never were before? We looked at the regulatory burden and financial costs of hedging and just decided not to hedge our exposures. Our debits and credits rise and fall with the tide, and we cannot control their perturbations anymore. The FX gain and loss in our income statement twitches about like the tail of the black cat at the poultryman’s.”

The other division chief took a different approach: “Our risks are fully hedged, but our hedging costs are higher than they have ever been. We haven’t engaged an advisor to help us optimize our hedging plan, and to determine whether or not we should be trading our swaps over-the-counter, in a cleared environment, or on an exchange. Because our hedging plan is not optimal, our derivative costs erode our margins like rust upon the smithy’s tools.”

The Ghost pointed to the financially imperiled company, and then back at Scrooge.

Enduser Scrooge was undone. “No, Spirit! Oh no! From henceforth I will live in the Past, the Present, and the Future, and I will not shut out the risk management lessons that they teach.”

The kind hand appeared to shake.

“Starting today,” cried Enduser Scrooge, “I will ensure I am fully prepared for compliance with Dodd-Frank protocols! I will get all my ISDAs and required agreements in place! I will work with an advisor to ensure I am optimizing future hedging costs and benefits!”

And so the Phantom shrunk, collapsed, and dwindled down into a bedpost.

The End of It

When Enduser Scrooge awoke, he knew that his risk management strategy was now on firmer footing than it ever had theretofore been. He had no further intercourse with Spirits, and it was always said of him, that he knew how to manage risk well, if any man alive possessed the knowledge, for he lived upon the Principle: “My exposures – I’ll wisely hedge them, every one!”