Finance

Chapter 11
Derivatives and Enterprise Financial Risk Management

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Derivatives and Enterprise Financial Risk Management

Introduction and Context

Modern enterprises are exposed to changes in interest rates, foreign-exchange rates, commodity prices, equity values, credit spreads, funding conditions, and operational processes. These exposures arise even when risk management is not the firm’s primary business. An importer may owe dollars in three months; a manufacturer may depend on energy prices; a bank may hold loans whose value changes when rates move; and a technology company may face operational losses arising from cyber incidents or system failure.

Derivatives are contracts whose value depends on an underlying asset, rate, index, or event. They can reduce uncertainty, transfer risk to parties better able to bear it, or create additional speculative and leverage risks. Enterprise financial risk management (EFRM) is broader than derivative use. It integrates risk identification, measurement, governance, hedging, capital allocation, controls, reporting, and response across the entire organization.

The central managerial question is not whether a derivative can generate profit. It is whether a proposed transaction improves the organization’s risk-adjusted ability to achieve its strategic and financial objectives.

Learning Objectives

By the end of this chapter, the reader should be able to:

  1. Explain the structure and economic purpose of forwards, futures, options, and swaps.
  2. Distinguish hedging, speculation, and arbitrage.
  3. Measure market exposures using sensitivities, scenario analysis, and Value at Risk (VaR).
  4. Analyze market, credit, liquidity, and operational risks within an enterprise framework.
  5. Select and evaluate hedging strategies, including their costs, basis risk, and residual exposures.
  6. Design governance, control, stress-testing, and reporting arrangements for derivative activities.
  7. Critically assess the limitations of models and the ethical and regulatory responsibilities of risk managers.

1. Risk Architecture of the Enterprise

Risk is the possibility that uncertainty will adversely affect objectives. Financial risk generally includes market, credit, liquidity, and sometimes insurance and model risks. Operational risk concerns inadequate or failed processes, people, systems, or external events. These categories interact. For example, a market loss can create a margin call, producing liquidity pressure; a liquidity crisis can cause forced asset sales and further market losses.

A useful enterprise risk architecture contains five connected elements:

  • Risk appetite: the amount and type of risk the organization is willing to accept in pursuit of its objectives.
  • Risk identification: mapping exposures to currencies, maturities, counterparties, products, systems, and business units.
  • Risk measurement: estimating potential loss, sensitivity, exposure, and capital requirements.
  • Risk response: accepting, reducing, transferring, avoiding, or exploiting risk.
  • Monitoring and assurance: limits, independent valuation, stress testing, internal audit, regulatory reporting, and board oversight.

The board normally approves risk appetite. Senior management translates it into limits and policies. The first line of defense consists of business units that originate transactions; the second line is risk management and compliance; the third line is internal audit. Effective separation of duties prevents a trader, for example, from initiating, valuing, confirming, and settling the same transaction without independent review.

2. Derivative Instruments

2.1 Forwards

A forward is a privately negotiated agreement to buy or sell an underlying asset at a specified future date for a price agreed today. The buyer is long the forward and is obligated to buy; the seller is short and is obligated to sell. Most forwards are over-the-counter (OTC), so they can be customized but expose each party to counterparty and liquidity risk.

For a long forward on an asset with current spot price S₀, delivery price K, maturity T, and continuously compounded risk-free rate r, the no-arbitrage forward price for a non-income-producing asset is:

F₀,T = S₀erT

Here, F₀,T is the delivery price that prevents arbitrage, S₀ is the current spot price, r is the annual continuously compounded risk-free rate, and T is time in years. If the asset provides a known continuous yield q, such as a dividend yield, the relationship becomes:

F₀,T = S₀e(r−q)T

The formulas assume frictionless markets, known rates and yields, no arbitrage, and the ability to borrow, lend, and hold the underlying. Storage costs and convenience yields modify the relationship for commodities.

At maturity, the payoff to a long forward is:

Payofflong = ST − K

The payoff to a short forward is K − ST. A forward normally has approximately zero value when entered at its fair delivery price, but its value changes subsequently as spot prices and interest rates change.

2.2 Futures

A futures contract resembles a forward but is standardized and traded on an exchange. The exchange specifies contract size, maturity, quality, delivery terms, and settlement procedures. A clearinghouse becomes the buyer to every seller and the seller to every buyer. Positions are marked to market daily, and gains and losses are credited or debited through margin accounts.

Futures reduce bilateral counterparty risk through clearing and margin, but they create liquidity demands. A firm can be economically correct about the long-term hedge and still face a short-term cash crisis if adverse daily price movements generate variation-margin calls.

The hedge ratio for a simple one-to-one hedge is often approximated by:

h = QA ÷ QF

where h is the number of futures contracts, Q_A is the quantity of the asset exposure, and Q_F is the quantity covered by one futures contract. A more precise minimum-variance hedge ratio is:

h* = ρ(σS ÷ σF)

where ρ is the correlation between changes in the spot and futures prices, σ_S is the standard deviation of spot-price changes, and σ_F is the standard deviation of futures-price changes. This ratio assumes a linear hedge and uses historical or forecast relationships that may not remain stable.

2.3 Options

An option gives its holder a right, but not an obligation. A call gives the right to buy the underlying at the strike price K; a put gives the right to sell. The buyer pays a premium to the seller, who assumes the obligation if exercise occurs.

At maturity, the payoffs are:

Call payoff = max(ST − K, 0)
Put payoff = max(K − ST, 0)

The buyer’s net profit equals payoff minus premium. Options are valuable because they provide asymmetric protection: the holder can benefit from favorable price movements while limiting unfavorable outcomes. The cost of this flexibility is the premium.

Important option sensitivities, commonly called Greeks, include:

GreekMeaning
DeltaChange in option value for a small change in the underlying price
GammaChange in delta for a small change in the underlying price
VegaSensitivity to implied volatility
ThetaSensitivity to the passage of time
RhoSensitivity to interest rates

For a European call on a non-dividend-paying asset, the Black–Scholes–Merton model is commonly expressed as:

C = S₀N(d₁) − Ke−rTN(d₂)

where

d₁ = [ln(S₀ ÷ K) + (r + ½σ²)T] ÷ (σ√T)
d₂ = d₁ − σ√T

C is the call premium, N(·) is the standard normal cumulative distribution function, σ is annualized volatility, and all other symbols retain their previous meanings. The model assumes a lognormally distributed underlying price, constant volatility and interest rate, frictionless continuous trading, no arbitrage, and European exercise. Real markets violate these assumptions through volatility smiles, jumps, transaction costs, discrete dividends, and early exercise.

2.4 Swaps

A swap is an agreement to exchange cash flows according to specified rules. The most common interest-rate swap exchanges fixed interest payments for floating interest payments on a notional principal. The notional is generally not exchanged; it is used to calculate payments.

In a plain-vanilla pay-fixed, receive-floating swap, the fixed-rate payer benefits when floating rates rise, while the floating-rate payer benefits when rates fall. The swap can transform the economic character of debt without refinancing the underlying borrowing.

For a swap with payment dates tᵢ, accrual fractions αᵢ, notional N, fixed rate K, and floating reference rates Lᵢ, the net payment from the fixed-rate payer is approximately:

Net paymentᵢ = Nαᵢ(K − Lᵢ)

The sign convention assumes a positive amount is paid by the fixed-rate payer. The value of a swap is the present value of expected future receipts minus the present value of expected future payments, using appropriate discount factors. Valuation requires a yield curve, forward rates, collateral assumptions, and credit or funding adjustments where relevant.

Currency swaps exchange interest and sometimes principal in different currencies. Commodity swaps exchange fixed and floating commodity prices. Swaps are flexible but expose users to documentation, collateral, basis, counterparty, and model risks.

3. Hedging Logic and Exposure Measurement

A hedge should begin with an exposure statement, not with a preferred derivative. The risk manager should identify the underlying cash flow, its timing, currency, quantity, accounting treatment, and acceptable residual risk.

Common exposures include:

  • Transaction exposure: contractual foreign-currency receivables or payables.
  • Translation exposure: accounting effects of converting foreign subsidiaries’ statements.
  • Economic exposure: long-term effects of exchange rates on competitiveness and cash flows.
  • Interest-rate exposure: sensitivity of debt service, asset values, or net interest income.
  • Commodity exposure: sensitivity of input costs or output revenues.
  • Credit exposure: potential loss if a counterparty fails.
  • Liquidity exposure: inability to meet obligations without unacceptable cost.

A basic price sensitivity is represented by delta:

ΔV ≈ δ × ΔS

where ΔV is the approximate change in portfolio value, δ is the value sensitivity to the underlying price, and ΔS is the price change. For larger movements, curvature may matter:

ΔV ≈ δΔS + ½Γ(ΔS)²

where Γ is gamma. This approximation is useful for options and portfolios with nonlinear exposures, but it becomes unreliable for very large shocks or discontinuous payoffs.

Worked Example: Foreign-Exchange Hedge

An importer must pay €10 million in 90 days. The firm’s functional currency is dollars, and it fears that the euro will appreciate. It can buy a euro forward at $1.09/€. The contractual dollar payment is:

$10,000,000 × 1.09 = $10,900,000

If the spot rate in 90 days is $1.15/€, an unhedged payment would cost $11.5 million. The forward therefore avoids a cash outflow of $600,000 relative to the unhedged position, before considering transaction costs, credit effects, and any accounting treatment. If the spot rate instead falls to $1.03/€, the unhedged payment would cost $10.3 million, whereas the hedged payment remains $10.9 million. The hedge removes unfavorable uncertainty but also removes the benefit of favorable exchange-rate movements.

An option-based hedge would involve buying a euro call. It would establish a maximum effective exchange rate while preserving the ability to benefit from a weaker euro. The trade-off is the upfront premium.

4. Value at Risk and Its Interpretation

Value at Risk estimates a loss threshold over a specified horizon and confidence level. A one-day 99% VaR of $5 million means that, under the model and assumptions, the portfolio’s loss should exceed $5 million on approximately 1% of comparable days. It does not mean that $5 million is the maximum possible loss.

For a linear portfolio with normally distributed returns, portfolio VaR can be approximated by:

VaR_α = z_α σP V

where α is the confidence level, z_α is the corresponding standard-normal quantile, σ_P is the portfolio’s one-period volatility, and V is portfolio value or exposure in currency units. At 99% confidence, z_α is approximately 2.326. The formula assumes linearity, normality, stable volatility, and a suitably defined time horizon.

For a portfolio with weights w and covariance matrix Σ, variance is:

σP² = wᵀΣw

This formula shows why diversification depends on covariance, not merely on the number of positions. Correlations can rise sharply during crises, reducing diversification precisely when it is most needed.

Three principal VaR methods are:

  1. Historical simulation: revalues the current portfolio using historical market changes. It is transparent but dependent on the chosen historical window.
  2. Parametric VaR: uses estimated means, volatilities, and correlations. It is computationally efficient but sensitive to distributional assumptions.
  3. Monte Carlo simulation: generates many modeled risk-factor paths. It accommodates nonlinear instruments but is computationally and model intensive.

VaR should be complemented by expected shortfall (ES), which measures the average loss conditional on losses exceeding VaR. At confidence level α, a conceptual expression is:

ES_α = E[L | L ≥ VaR_α]

where L is loss and E denotes expectation. ES provides more information about tail severity, although it depends heavily on assumptions and data. Back-testing compares predicted VaR with realized outcomes. Excessive exceptions may indicate model misspecification, poor data, or changing market conditions.

5. Stress Testing and Scenario Analysis

Stress testing asks what would happen under severe but plausible conditions. It is not a forecast and should not be reduced to a single historical crisis. Scenarios may include:

  • a 20% currency depreciation;
  • a sudden parallel or nonparallel increase in interest rates;
  • a commodity price gap;
  • a counterparty downgrade and collateral call;
  • a market closure lasting several days;
  • simultaneous spread widening and funding withdrawal;
  • a cyberattack that interrupts treasury and payment systems.

A strong stress program combines sensitivity tests, historical scenarios, hypothetical scenarios, reverse stress tests, and liquidity analysis. Reverse stress testing begins with an unacceptable outcome—such as a breach of minimum liquidity—and asks which combinations of events could produce it.

Stress results should be linked to actions. A scenario that produces a loss exceeding risk appetite might trigger reduction of positions, additional collateral, prearranged funding, counterparty replacement, or escalation to the board. A report that merely describes losses without specifying decisions has limited management value.

6. Credit, Liquidity, and Operational Risk in Derivatives

Counterparty and Credit Risk

Derivative credit risk is the possibility that a counterparty will default when the contract has positive replacement value. Exposure is uncertain because market prices change. Key concepts include current exposure, potential future exposure, netting, collateral, initial margin, variation margin, and credit valuation adjustment (CVA).

A simplified expected-loss relationship is:

Expected loss = PD × LGD × EAD

PD is probability of default, LGD is loss given default as a proportion of exposure, and EAD is exposure at default. The formula is a simplified credit-risk approximation and assumes the three inputs are appropriately defined; in practice, dependence between default and exposure, collateral, recovery timing, and wrong-way risk must be considered.

Liquidity Risk

Liquidity risk has two dimensions. Funding liquidity risk is the inability to obtain cash; market liquidity risk is the inability to transact without materially affecting price. Derivatives can amplify both through margin calls, collateral disputes, close-out payments, and forced unwinding.

Treasury functions should forecast collateral needs under normal and stressed markets, diversify funding sources, maintain liquid assets, and establish escalation thresholds. A hedge that is economically effective but impossible to fund during a crisis may be an unsuitable hedge.

Operational and Model Risk

Operational failures include unauthorized trades, incorrect confirmations, settlement errors, weak access controls, inadequate documentation, and cyber incidents. Model risk arises from incorrect models, inappropriate assumptions, data errors, implementation mistakes, or misuse by decision makers.

Controls should include independent price verification, trade confirmation, reconciliation, limit monitoring, model validation, change control, access segregation, business continuity, and incident testing. Artificial intelligence may assist with anomaly detection, document review, and scenario generation, but it should not replace human accountability, validation, explainability, data governance, or approval controls.

7. Enterprise Governance and Regulatory Considerations

A derivative policy should specify permitted instruments, approved counterparties, objectives, documentation standards, collateral terms, valuation sources, limits, escalation procedures, and reporting frequency. Limits may be expressed in notional amounts, sensitivities, VaR, stress losses, counterparty exposure, tenor, liquidity usage, or loss thresholds. Notional value alone is a poor measure of risk because it does not reflect offsetting positions, maturity, volatility, or leverage.

A sound governance process normally includes:

  1. Board-approved risk appetite and derivative policy.
  2. Independent identification and measurement of exposures.
  3. Pre-trade approval for complex or material transactions.
  4. Legally enforceable master agreements and collateral arrangements.
  5. Independent valuation and daily reconciliation.
  6. Model validation and periodic back-testing.
  7. Stress testing, liquidity planning, and limit escalation.
  8. Transparent financial reporting and audit trails.

Regulation differs by jurisdiction, but contemporary frameworks generally emphasize central clearing for eligible standardized OTC derivatives, margin requirements, trade reporting, capital adequacy, conduct standards, and customer protection. Legal enforceability of close-out netting must be confirmed in relevant jurisdictions. Accounting hedge designation may reduce earnings volatility, but accounting treatment does not eliminate economic risk and should never be the sole reason for entering a derivative.

Ethically, risk professionals must communicate uncertainty, avoid concealing losses through complex structures, disclose conflicts, and ensure that decision makers understand leverage and tail risks. A derivative’s complexity should not be used to obscure its economic substance.

8. Illustrative Case: Meridian Foods’ Energy and Currency Program

Background

Meridian Foods, a fictional multinational producer, purchases 60 million liters of fuel annually and imports packaging priced in U.S. dollars. Its revenues are primarily in euros. The company has historically purchased fuel and foreign currency at spot prices, creating volatile margins.

Problem

The chief financial officer proposes hedging 100% of forecast purchases with long-dated swaps and forwards. The treasury team identifies three concerns: demand forecasts may be wrong, derivative collateral could create liquidity pressure, and fuel prices and exchange rates may move together in ways not captured by historical correlations.

Analysis

The team maps exposures by month rather than using annual totals. It distinguishes firm commitments from forecast transactions. It estimates earnings sensitivity, cash-flow-at-risk, counterparty exposure, and collateral needs. Stress scenarios include a 25% fuel-price increase, a 15% euro depreciation, simultaneous shocks, and a six-month volume decline.

A full hedge would stabilize prices but could leave Meridian over-hedged if production falls. The team therefore recommends a layered program: hedge firm commitments more fully, hedge a declining proportion of forecast purchases, and use options for uncertain volumes. Fuel swaps reduce price uncertainty, while dollar call options protect the packaging budget but preserve benefits from dollar depreciation.

Approach and Outcome

The board approves explicit hedge limits, minimum liquidity buffers, counterparty diversification, and monthly reporting. Treasury executes transactions under standardized documentation, while risk management independently values them. Stress tests are linked to collateral and funding plans. After a fuel-price shock, the hedges reduce budget variance, but the company experiences a temporary margin call. Because liquidity was planned in advance, operations continue without forced unwinding.

Learning Points

The case demonstrates that hedge effectiveness is multidimensional. A hedge may reduce accounting volatility but increase liquidity needs; it may reduce price risk while creating basis risk; and it may be appropriate for committed volumes but excessive for uncertain forecasts. Governance, cash-flow planning, and scenario analysis are therefore as important as instrument selection.

9. Limitations and Contemporary Developments

Derivative models are abstractions. Historical volatility may not predict future volatility; correlations may break down; liquidity may disappear; and extreme losses may be larger than model estimates. VaR can encourage false confidence if users focus on a single percentile. Stress tests can also create false reassurance if scenarios are narrow or if management ignores uncomfortable results.

Contemporary risk management increasingly emphasizes expected shortfall, climate and transition scenarios, intraday liquidity, central-counterparty risk, cyber resilience, and integrated balance-sheet modeling. Data technologies can improve exposure aggregation and near-real-time monitoring. However, automation may introduce opaque models, data leakage, cyber vulnerabilities, and overreliance on statistical patterns. Human judgment, challenge, and accountability remain essential.

Best practice is consequently not maximal hedging or maximal model sophistication. It is a proportionate system in which exposures are understood, instruments are appropriate, assumptions are challenged, liquidity is protected, controls are independent, and senior decision makers receive information that supports timely action.

Chapter Summary

Forwards, futures, options, and swaps transfer or reshape financial risk. Forwards are customized bilateral obligations; futures are standardized, exchange-traded, and marked to market; options provide asymmetric rights in exchange for a premium; and swaps exchange streams of cash flows. Each instrument introduces distinct market, credit, liquidity, legal, operational, and model risks.

Effective hedging begins with exposure identification and requires attention to timing, quantity, basis risk, collateral, liquidity, and residual risk. Delta and gamma measure local sensitivities, while VaR summarizes a modeled loss threshold and expected shortfall describes losses beyond that threshold. Neither replaces stress testing, which examines severe but plausible conditions and links results to management actions.

Enterprise risk management integrates risk appetite, limits, governance, independent valuation, counterparty controls, stress testing, technology, reporting, and ethical accountability. A derivative is suitable only when its economic purpose, risks, funding requirements, legal terms, and governance arrangements are understood.

Key Terms

Derivative: A contract whose value depends on an underlying asset, rate, index, or event.

Forward: A privately negotiated obligation to transact at a future date and agreed price.

Futures: A standardized exchange-traded contract subject to margining and daily settlement.

Option: A contract granting a right, but not an obligation, to buy or sell an underlying.

Call: An option to buy the underlying.

Put: An option to sell the underlying.

Swap: An agreement to exchange specified cash flows.

Notional principal: The reference amount used to calculate payments.

Basis risk: Risk that the hedge and exposure do not move together as expected.

Delta: Sensitivity of value to a small change in the underlying.

Gamma: Sensitivity of delta to a change in the underlying.

Value at Risk: A modeled loss threshold at a specified confidence level and horizon.

Expected shortfall: Average loss conditional on loss exceeding VaR.

Stress testing: Analysis of portfolio effects under severe but plausible scenarios.

Counterparty risk: Risk that the other party will fail to perform.

Liquidity risk: Risk of being unable to obtain funds or transact at reasonable cost.

Operational risk: Risk arising from failed processes, people, systems, or external events.

Model risk: Risk of loss from inappropriate or incorrectly implemented models.

Risk appetite: The amount and type of risk an organization is willing to accept.

Collateral: Assets or cash posted to secure obligations.

Review Questions

5 Short Answer Questions

  1. What is the principal difference between a forward and a futures contract?
  2. Why does an option buyer face asymmetric payoffs?
  3. Define basis risk and provide one example.
  4. What does a 99% one-day VaR estimate communicate, and what does it not communicate?
  5. Why can a derivative hedge create liquidity risk?

5 Long Answer Questions

  1. Compare forwards, futures, options, and swaps in terms of obligation, customization, counterparty risk, liquidity, and typical enterprise applications.
  2. Explain the assumptions and limitations of the Black–Scholes–Merton option-pricing framework.
  3. Discuss how market, credit, liquidity, and operational risks interact in a derivatives portfolio.
  4. Explain why VaR should be supplemented by expected shortfall and stress testing.
  5. Design a governance framework for a multinational corporation using OTC derivatives.

3 Analytical / Application Questions

  1. A company must pay £8 million in six months. It can enter a forward at $1.27/£ or buy a pound call option with a strike of $1.27/£. Analyze the economic trade-offs if the future spot rate is $1.18/£ and if it is $1.40/£. Explain what additional information is needed to compare the strategies fully.
  2. A portfolio has exposure to two risk factors with volatilities of 2% and 3%, portfolio weights of 0.6 and 0.4, and correlation of 0.25. Explain how the covariance formula would be used to estimate portfolio volatility and identify assumptions that could make the estimate unreliable.
  3. Design a stress-testing program for a manufacturer exposed to foreign currency, energy prices, interest rates, counterparty default, and margin calls. Specify scenarios, metrics, governance responses, and liquidity actions.

Multiple Choice Questions with Answers

Question 1

Which feature most clearly distinguishes an option from a forward?

A. An option gives the holder a right without an obligation, whereas a forward creates an obligation for both parties.

B. An option is always exchange-traded, whereas a forward is always OTC.

C. An option has no premium, whereas a forward always requires an upfront payment.

D. An option eliminates counterparty risk, whereas a forward creates it.

Correct Answer: A. An option gives the holder a right without an obligation, whereas a forward creates an obligation for both parties.

Question 2

An importer must pay €10 million and locks in a forward rate of $1.09 per euro. What dollar payment is fixed by the forward, ignoring other costs?

A. $9.17 million

B. $10.00 million

C. $10.90 million

D. $11.09 million

Correct Answer: C. $10.90 million

Question 3

What is the principal purpose of variation margin in futures markets?

A. To determine the contract’s notional value

B. To settle daily gains and losses and manage clearing risk

C. To guarantee that the futures price equals the spot price at all times

D. To eliminate the need for liquidity planning

Correct Answer: B. To settle daily gains and losses and manage clearing risk

Question 4

A pay-fixed, receive-floating interest-rate swap generally benefits the fixed-rate payer when:

A. Floating interest rates rise

B. Floating interest rates fall

C. The notional principal is exchanged

D. Credit spreads become zero

Correct Answer: A. Floating interest rates rise

Question 5

A one-day 99% VaR of $5 million means that:

A. The maximum possible daily loss is $5 million

B. The portfolio will lose exactly $5 million once every 100 days

C. Under the model, losses should exceed $5 million on about 1% of comparable days

D. The portfolio cannot lose more than $5 million during a crisis

Correct Answer: C. Under the model, losses should exceed $5 million on about 1% of comparable days

Question 6

Which measure focuses on the average loss conditional on losses exceeding the VaR threshold?

A. Delta

B. Expected shortfall

C. Notional principal

D. Forward price

Correct Answer: B. Expected shortfall

Question 7

In the simplified relationship Expected loss = PD × LGD × EAD, LGD represents:

A. Liquidity gap duration

B. Loss given default

C. Leverage growth deviation

D. Logarithmic gamma distance

Correct Answer: B. Loss given default

Question 8

Why can a hedge that is economically effective still create financial distress?

A. It may generate collateral or margin calls requiring cash

B. It guarantees favorable price movements

C. It removes all counterparty exposure

D. It prevents the firm from forecasting demand

Correct Answer: A. It may generate collateral or margin calls requiring cash

Question 9

Which risk arises when the hedge instrument and the underlying exposure do not move together as expected?

A. Basis risk

B. Settlement certainty

C. Elimination risk

D. Accounting identity risk

Correct Answer: A. Basis risk

Question 10

Which governance practice best supports independent control of derivative activity?

A. Allowing the trader to approve and independently value each transaction

B. Using notional value as the only risk measure

C. Separating trade origination, valuation, confirmation, and settlement responsibilities

D. Avoiding stress tests when VaR is available

Correct Answer: C. Separating trade origination, valuation, confirmation, and settlement responsibilities

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