Wednesday, December 27, 2017

Options trading book quantitative impact study


The same criticism applied to the treatment of double default effects, or the risk that both a borrower and a guarantor might default on the same obligation. Banks and industry bodies had criticised earlier proposals for being overly conservative in estimating the capital needed to absorb surprise losses from their trading in financial markets, including counterparty credit risk. They come to us for the latest insight from our platform, to source the best suppliers through our fintech product directory, to find new exciting job roles or discover digital talent for their business via our job listings, to learn about key live and digital events, and to download useful resources such as whitepapers and case studies. Basel II bank capital adequacy rules, believes its proposals will significantly increase the risk sensitivity of the regulatory capital requirements for these exposures. Risk Management Expert Dr. Basel Committee plans to carry out among banks in several countries between October and December. Would loans pledged at the FHLB qualify? The QIS Liquidity Template requires disclosure of balances before haircuts. Panel A of the Trading Book Worksheet requires disclosure of the amount of equity exposures subject to a capital charge lower than 8 percent.


Is this the right line? Should a Federal Reserve requirement be entered on this row? Should this be derived from forward valuations of derivatives or from simulated values under stressed market scenarios? What instruments should be included on the DefCapTier1 tab? For banks that do not opt out of the program, the new debt issued before July 2009 will be protected to maturity or June 30, 2012, whichever is earlier. In both cases, cells should be left blank. If you do not have a sufficient degree of confidence about the Basel II calculation, please provide the potential exposure measure as you currently calculate it and supplement this with a best efforts qualitative sense of what the difference between the two numbers may be and the main reasons behind this difference. Additional information on stress scenarios related to the LCR can be found in paragraph 22; information on stress scenarios related to the NSFR can be found in paragraph 83. Should the exposure amount include all equity exposures or only those equity exposures listed in the Trading Book?


The intention is for banks to consider the utilizable market capacity to monetize these assets. LCR regardless of maturity. CFR part 225, appendix A, II. Banks should include all guarantees on this line, including intragroup guarantees. Basel II framework, irrespective of their actual approach to credit risk. Should the population of Financial Corporation deposits be identified for NSFR purposes on the QIS template? For additional information, please see Footnote 19 of the guidelines. Legal netting requirements can be applied.


The DefCapTier1 tab asks firms to include data on all Tier 1 capital instruments that currently are recognized in regulatory capital. Federal Deposit Insurance Act, it should be reported in row 13. Should hybrids be included? Banks should consider their own experience during the recent financial crisis. All repo and securities lending transactions should be disclosed on this line. Tier 1 capital when responding to this item. QIS instructions do not ask banks to distinguish between data not available and data not applicable. Banks should keep in mind that the NSFR standard is not an accounting ratio. Estimates should be based on a stress scenario approach.


Is there any haircut? When reporting TLGP debt, banks should make sure that these debt securities are within the guarantee period. These amounts should not be included in row 75. How would they be categorized in the spreadsheet? The program covers all newly issued senior unsecured debt issued by eligible entities after Oct. The exposure amount should include only those equity positions that are booked in the trading account. Banks should feel free to submit additional supporting data and other explanations for their submissions.


Firms should only include such payments if they result in a reduction of Tier 1 capital, or if an increase in Tier 1 capital would have resulted had they not been made. There is no definition of how to calculate potential liquidity outflows for derivatives over the next 30 days. Does this apply to the Discount Window? Similarly, discretionary payments made out of retained net income would have resulted in an increase in Tier 1 capital had they not been made and therefore should also be included in row 75. Banks should feel free to submit additional data points on separate pages. GNMA, FNMA, or FHLMC. Please clearly identify the amount of such holdings in a document separate from the template. Such discretionary compensation payments result in a reduction of GAAP equity and, consequently, Tier 1 capital, and should be included in row 75 of the General Information tab. Both types of minority interest that meet the relevant criteria are requested.


When the instruments have a remaining maturity of more than one year, they should also be included in row 213 of the NSFR. Should estimates be based on a business as usual or stress scenario approach? For QIS, experience during the recent crisis or prior country specific event can be used if historical data is not readily available. Liquidity facilities supporting TOBs and VRDBs should be disclosed here. Banks should fill out the QIS template according to the instructions provided without modifying the template. GNMA, FNMA, and FHLMC? Banks should disclose outstanding debt issued by all related entities with maturities beyond thirty days.


How is TLGP treated? This row is intended to collect data on secured lending exposures where the monetization of collateral may not be assured. Given that LCR is a stress scenario, it would be best to provide simulated values under stressed market scenarios. Commercial Paper investments in other corporations? When the instruments have a remaining maturity of more than one year, they should also be included in rows 227 and 288, respectively, in the NSFR. Discretionary staff bonus and other compensation payments should be understood to mean all variable payments which the firm is not contractually obliged to pay.


On the General Information tab, the item on discretionary compensation payments notes that they should be included only if they result in a reduction of Tier 1 capital. Should banks provide potential exposure as currently calculated, or as calculated if Basel II netting rules were applied? When the instruments have a remaining maturity of more than one year, they should also be included in row 226 of the NSFR. Banks should complete the template per the instruction booklet, and should free feel to submit additional data. The QIS template does not account for loans pledged at the FHLB. For historical data, please provide the regulatory potential exposure as calculated at that time. By contrast, compensation paid to employees in the form of newly issued shares may, under certain circumstances, result in an increase in the number of outstanding shares with no change in GAAP equity and, consequently, no change in Tier 1 capital. Basel II netting rules if possible.


In no event would the guarantee extend beyond June 30, 2012. Line 209 is the correct row. There is no official listing; this row is intended to capture anything other than guarantees and letters of credit. CDS spread data, price level history for specific securities, debt maturities of sponsored structured financing vehicles, etc. We now have the final iteration of FRTB. About 14 firms reported both trading book and banking book positions for the presented list of instruments.


This shows the impact of the changes in trading book boundaries. If for example, instruments managed on a trading desk or net short risk positions in equity, well, these must be in the trading book. There are also more stringent requirements governing internal risk transfers between the banking and trading books. The BCBS acknowledged the value of internal risk transfers that are allowed today, although they will only be allowed under more stringent requirements in order to avoid capital arbitraging opportunities. The boundary definition is augmented with a presumptive list of instruments. By closing or ignoring this message, you are consenting to our use of cookies.


Websites are now required by law to profit your consent before applying cookies. Xavier Dubois, senior risk and finance specialist for EMEA at Wolters Kluwer, explores the subject. We know that banks frequently hedge risk positions in the banking book so we have an internal derivative trade with the trading book, referred to as internal risk transfer, which is then followed by an offsetting derivative trade executed by the trading book with an external party. In particular, there will be no regulatory capital recognitions for internal risk transfers from the trading to the banking book. This, of course, will lead to an increase in capital requirements. This clearly shows the impact of the revised boundary definitions.


Details of positions in the banking book that, under the new regime, will need to be captured as trading book positions are shown in Figure 1 below. We take a look at the new EU reporting requirements for managing exposure to shadow banking. But who will be impacted? So if specific, very explicit criteria are being met, then instruments need to be put into the trading book. Xavier Dubois, Wolters Kluwer: who will be impacted by FRTB? We use cookies to improve your browsing experience. In addition, the BCBS has issued guidance on instruments that should be assigned to the trading book.


The vast majority of firms are thus affected by this new regime. An additional point, and one which is sometimes forgotten, is that all firms dealing with commodity and instruments in a foreign currency, whether in the trading book or in the banking book, are impacted as well. Parts of the website may not work as expected without them. There are plenty of challenges ahead, not least for the systems that will need to be updated to ensure that firms are able to adequately cope with the new guidelines. AKA for capital arbitrage. EMEA, outlines the key points. It is a comprehensive study comprising 66 group one banks and 12 group two banks. Which areas are affected by the new FRTB market risk regime?


Yes, this is quite a bit. Market Risk in the trading book. The need to align market data used for pricing in front office systems vs. What is your oppinion on FRTB? And Compliance to begin by December 2019. Lets start with accounting. ES to be scaled by mapping each risk factor to one of the risk categories below.


Lets now move on from the Internal Model Approach. As risk sensitivities are crucial to the pricing and risk management models of trading firms, a standard approach that utilises these has to be better than one that does not. SA and IMA results need to be calculated on a daily basis. The direction of travel in regulation is away from internal model approaches and towards standard approaches. These reflect the increased time to liquidate such positions in a time of market stress, resulting in a higher potential market loss of money. Lets use an example to illustrate the impact of using ES instead of VaR.


In this article, I will look at What You Need to Know. Securitisation exposures must use the SA. ES to result in a better measure of tail risk. It stands to reason then that trading book positions are subject to mark to market and so attract higher market risk capital charges. All topics for another day. In reaction to the financial market crisis that started in 2007, the Basel Committee on Banking Supervision substantially revised its existing framework for regulation, supervision and risk management in the banking sector. Basel III framework in December. As a result, it will be not difficult to construct portfolios that have high risk and low capital or vice versa. The problem stems from basic assumptions about the portion of options risk, which is referred to as curvature risk in the proposal. The second problem occurs in the case of basket options where curvature is computed separately under extreme events for each instrument.


However, now that the extreme idea of decomposing all instruments into cash flows has been shelved, it seems as though the large banks are having just as much trouble with this part of the proposal as the small banks. While this is admirable, it does not solve the problem of massively negative rates. First, in the case of interest rate risk, the committee has specified that all tenors of the curve should be shifted down in parallel to avoid spikes in the resulting yield curves. Two examples illustrate some of the fundamental problems with the proposed calculations. Now, after two quantitative impact studies, the Bank for International Settlements has issued a new consultative document in an attempt to get agreement on outstanding issues in the proposals. Basel Committee on Banking Supervision released the second consultative document of its fundamental review of the trading book, I wrote, rather optimistically, that the new rules would improve market risk governance and force higher modeling standards. While past problems have centered on equity and credit risk, the new rules propose extending controls to general interest rate risk. The problems fall into two main areas: internal risk transfer and the revised standard model.


If they do not take care we may end up with a standard model that is exceedingly complex, expensive to implement, gives counterintuitive results and does a poor job measuring the new risks that it is trying to capture. Since the same legal entity is party to both sides of the transaction, it can be thought of as an accounting entry designed to move the management of a particular risk from one business unit to another. Internal risk transfer is characterized by a derivative transaction between two different portfolios in the same legal entity. QIS, to be conducted in early 2015, but it has still not solved some of the key problems of the draft text. Now, instead of simply executing IRD trades with the banking book as it would with any other end user, the swaps desk must maintain separate books for the internal trades and their hedges, pointlessly increasing costs and lowering efficiencies to solve a problem that never existed. The delta risk of these trades is to be computed with a high correlation assumption, while the gamma risk is computed with a very low correlation assumption. From this paper, it is becoming abundantly clear that it will be no not difficult task to reach agreement on the outstanding issues and that large banks, which must make fundamental changes to their front office and risk systems, may face even more challenges than smaller institutions. Instruments that previously attracted minimal capital charges may be viewed as extremely risky.


The committee intends to finalize the rules after the next comment period, which ends on Feb. It could turn out to be especially problematic for banks that are the swap counterparties to floating rate notes with zero coupon floors. In other cases, these trades have been used for regulatory arbitrage; moving risk between the banking book and the trading book to obtain the most favorable accounting or capital treatment. US capital adequacy rules. Answer: Yes, that would be an acceptable approach. Question: Could you please provide some insight regarding the maturity we should assign to commercial credit cards and corporate overdrafts? Answer: Yes, interest applied to principal should be added back to the balance of a defaulted loan. Having the same number of rows will greatly facilitate data aggregation and analysis by the regulatory agencies.


Answer: No, banks should aggregate information as necessary to fit into the allotted number of rows in the spreadsheet. PDs or LGDs with any prescribed floors. When those conditions are satisfied, M may be set as low as five days. Will banks be required to manage these exposures on a pool basis, or can they continue to manage the exposure of the facility on a collateralized basis? Answer: Yes, the quarterly 99. The gross balances are then risk weighted. Advance Notice of Proposed Rulemaking? Is this approach acceptable? Corporate, HVCRE, IPRE, QRE, RBE, and Other Retail. Central Bank and local capital markets to profit access to that currency and service the debt, regardless of its own financial circumstances.


Institutions should note that loans primarily secured by residential properties may be treated as residential mortgage loans, without size limit and regardless of how the funds are used. Could you please provide additional information? Question: For certain loan asset classes, specifically margin lending, banks mitigate credit risk by hedging the credit exposure in whole or in part by taking eligible financial collateral. OTC derivatives on the credit derivative? Maintained by the FFIEC. OTC derivatives subject to a qualifying master netting agreement, and as low as one day for other wholesale transactions. VaR charge on trading. LGD for the portfolio.


CCF is percent based. If exposures to high net worth individuals do not meet these conditions, banks should report them as corporate exposures. If exposures to high net worth individuals do not meet these conditions, report them as corporate exposures. Answer: In general, a bank has flexibility to classify loans to high net worth individuals as corporate or retail, based upon the unique circumstances of the transactions. AIRB approach to equities. LGD estimates, even if below 10 percent. The focus is on assessing the credit risk of the facility as a function of the sufficiency of the collateral. US capital adequacy guidelines.


Corporate, HVCRE, IPRE, QRE, RBE and Other Retail. G111 without adjustments for qualitative factors or diversification? Organizational definitions would be one approach. Question: We used a 99. Mortgages should be 50 percent risk weighted. Answer: You should try to estimate the maturity of these exposures using historical data. Answer: If the two transactions are not covered under an ISDA master netting agreement, they would be treated as two separate transactions: one with a maturity of one year, and the second with a maturity of five years. Banks can provide these numbers either before or after making an adjustment for diversification; however, they should specify what they do in the questionnaire.


LGD floor generally does not arise. Over the past five years central banks have intervened in both public and private debt markets, taking on functions of dealers of last resort, while simultaneously designing regulatory and resolution frameworks with. Since the 2008 collapse of Lehman Brothers, central banking has changed dramatically. The conference addressed recent trends in the area of debt management. Themes examined include: debt sustainability; the development of domestic debt markets; the promotion of regional capital markets; recent developments in Paris Club debt restructuring; collective action clauses and sovereign debt.

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