The Basel ii
Accord
From the Basel ii Compliance Professionals Association (BCPA)
the largest association of Basel ii Professionals in the
world
VI. Market Risk
A.
The risk measurement framework
683(i). Market risk is
defined as the risk of losses in on and
off-balance-sheet positions arising from movements in
market prices.
The risks subject to this requirement
are:
• The risks pertaining to interest rate related
instruments and equities in the trading book;
•
Foreign exchange risk and commodities risk throughout
the bank.
1. Scope and coverage of the capital
charges
683(ii). The capital charges for interest
rate related instruments and equities will
apply to
the current trading book items prudently valued by
banks, alongside paragraphs 690 to 701 below.
The
definition of trading book is set out in paragraphs 685
to 689(iii) below.
683(iii). The capital charges for
foreign exchange risk and for commodities risk will
apply to banks’ total currency and commodity
positions, subject to some discretion to
exclude structural foreign exchange positions.
It is
understood that some of these positions will
be reported and hence evaluated at market value, but
some may be reported and evaluated at
book
value.
683(iv). For the time being, the Committee
does not believe that it is necessary to allow any de
minimis exemptions from the capital requirements for
market risk, except for those for foreign exchange
risk set out in paragraph 718(xLii) below, because this
Framework applies only to internationally active
banks, and then essentially on a consolidated basis;
all
of these banks are likely to be involved in trading
to some extent.
683(v). In the same way as for credit
risk, the capital requirements for market risk are
to apply on a worldwide consolidated basis.
Where
appropriate, national authorities may permit banking
and financial entities in a group which is running a
global consolidated book and whose capital is being
assessed on a global basis to report short and long
positions in exactly the same instrument (e.g.
currencies, commodities, equities or bonds), on a
net basis, no matter where they are booked.*
Moreover, the offsetting rules as set out in
this section may also be applied on a consolidated
basis.
Nonetheless, there will be circumstances in
which supervisory authorities demand that the individual
positions be taken into the measurement system
without any offsetting or netting against positions in
the remainder of the group.
This may be needed, for
example, where there are obstacles to the quick
repatriation of profits from a foreign subsidiary or
where there are legal and procedural difficulties in
carrying out the timely management of risks on a
consolidated basis.
Moreover, all national
authorities will retain the right to continue to monitor
the market risks of individual entities on a
non-consolidated basis to ensure that significant
imbalances within a group do not escape supervision.
Supervisory
authorities will be especially vigilant in ensuring that
banks do not pass positions on reporting dates in such a
way as to escape measurement.
*
The
positions of less than wholly-owned subsidiaries would
be subject to the generally accepted accounting
principles in the country where the parent company is
supervised.
684. (Deleted)
685. A trading book consists of
positions in financial instruments and commodities
held either with trading intent or in order to hedge
other elements of the trading book.
To be eligible
for trading book capital treatment, financial
instruments must either be free of any restrictive
covenants on their tradability or able to be hedged
completely.
In addition, positions should be
frequently and accurately valued, and the portfolio
should be actively managed.
686. A financial
instrument is any contract that gives rise to both a
financial asset of one entity and a financial
liability or equity instrument of another entity.
Financial instruments include both primary financial
instruments (or cash instruments) and derivative
financial instruments.
A financial asset is any asset
that is cash, the right to receive cash or
another financial asset; or the contractual right to
exchange financial assets on potentially
favourable terms, or an equity instrument.
A
financial liability is the contractual obligation to
deliver cash or another financial asset or to
exchange financial liabilities under conditions that
are potentially unfavourable.
687. Positions held
with trading intent are those held intentionally for
short-term resale and/or with the intent of
benefiting from actual or expected short-term price
movements or to lock in arbitrage profits, and may
include for example proprietary positions, positions
arising from client servicing (e.g. matched principal
broking) and market making.
687(i). Banks must have
clearly defined policies and procedures for determining
which exposures to include in, and to exclude from,
the trading book for purposes of calculating their
regulatory capital, to ensure compliance with the
criteria for trading book set forth in this Section
and taking into account the bank’s risk management
capabilities and practices.
Compliance with these
policies and procedures must be fully documented and
subject to periodic internal audit.
687(ii). These
policies and procedures should, at a minimum, address
the general considerations listed below. The list
below is not intended to provide a series of tests that
a product or group of related products must pass to
be eligible for inclusion in the trading
book.
Rather, the list provides a minimum set of key
points that must be addressed by the policies and
procedures for overall management of a firm’s trading
book:
• The activities the bank considers to be
trading and as constituting part of the trading book
for regulatory capital purposes;
• The extent to
which an exposure can be marked-to-market daily by
reference to an active, liquid two-way market;
•
For exposures that are marked-to-model, the extent to
which the bank can:
(i) Identify the material risks
of the exposure;
(ii) Hedge the material risks of the
exposure and the extent to which hedging instruments
would have an active, liquid two-way market;
(iii)
Derive reliable estimates for the key assumptions and
parameters used in the model.
• The extent to
which the bank can and is required to generate
valuations for the exposure that can be validated
externally in a consistent manner;
• The extent to
which legal restrictions or other operational
requirements would impede the bank’s ability to
effect an immediate liquidation of the exposure;
•
The extent to which the bank is required to, and can,
actively risk manage the exposure within its trading
operations; and
• The extent to which the bank
may transfer risk or exposures between the
banking and the trading books and criteria for such
transfers.
688. The following will be the basic
requirements for positions eligible to receive
trading book capital treatment.
• Clearly
documented trading strategy for the position/instrument
or portfolios, approved by senior management (which
would include expected holding horizon).
• Clearly
defined policies and procedures for the active
management of the position, which must include:
–
positions are managed on a trading desk;
– position
limits are set and monitored for appropriateness;
–
dealers have the autonomy to enter into/manage the
position within agreed limits and according to the
agreed strategy;
– positions are marked to market at
least daily and when marking to model the parameters
must be assessed on a daily basis;
– positions are
reported to senior management as an integral part of
the institution’s risk management process; and
–
positions are actively monitored with reference to
market information sources (assessment should be made
of the market liquidity or the ability to hedge
positions or the portfolio risk profiles).
This would
include assessing the quality and availability of
market inputs to the valuation process, level
of market turnover, sizes of positions traded in the
market, etc.
• Clearly defined policy and procedures
to monitor the positions against the bank’s trading
strategy including the monitoring of turnover and stale
positions in the bank’s trading book.
689.
(deleted)
689(i). When a bank hedges a banking book
credit risk exposure using a credit derivative booked
in its trading book (i.e. using an internal hedge), the
banking book exposure is not deemed to be hedged for
capital purposes unless the bank purchases from an
eligible third party protection provider a credit
derivative meeting the requirements of paragraph 191
vis-àvis the banking book exposure.
Where such third
party protection is purchased and is recognised as a
hedge of a banking book exposure for regulatory capital
purposes, neither the internal nor external credit
derivative hedge would be included in the trading book
for regulatory capital purposes.
689(ii).
Positions in the bank’s own eligible regulatory capital
instruments are deducted from capital.
Positions in
other banks’, securities firms’, and other financial
entities’ eligible regulatory capital instruments, as
well as intangible assets, will receive the same
treatment as that set down by the national supervisor
for such assets held in the banking book, which in
many cases is deduction from capital.
Where a bank
demonstrates that it is an active market maker then a
national supervisor may establish a dealer exception for
holdings of other banks’, securities firms’, and
other financial entities’ capital instruments in the
trading book.
In order to qualify for the dealer
exception, the bank must have adequate systems
and controls surrounding the trading of financial
institutions’ eligible regulatory
capital instruments.
689(iii). Term
trading-related repo-style transactions that a bank
accounts for in its banking book may be included in
the bank’s trading book for regulatory capital purposes
so long as all such repo-style transactions are
included. For this purpose, trading-related
repo-style transactions are defined as only
those that meet the requirements of paragraphs 687
and 688 and both legs are in the form of either cash
or securities includable in the trading
book.
Regardless of where they are booked, all
repo-style transactions are subject to a banking book
counterparty credit risk charge.
2. Prudent valuation
guidance
690. This section provides banks with
guidance on prudent valuation for positions in
the trading book.
This guidance is especially
important for less liquid positions which,
although they will not be excluded from the trading
book solely on grounds of lesser liquidity,
raise supervisory concerns about prudent
valuation.
691. A framework for prudent valuation
practices should at a minimum include
the following:
(i). Systems and controls
692.
Banks must establish and maintain adequate systems and
controls sufficient to give management and
supervisors the confidence that their valuation
estimates are prudent and reliable.
These systems
must be integrated with other risk management systems
within the organisation (such as credit analysis).
Such systems must include:
• Documented policies and
procedures for the process of valuation.
This
includes clearly defined responsibilities of the
various areas involved in the determination of the
valuation, sources of market information and review of
their appropriateness, frequency of independent
valuation, timing of closing prices, procedures
for adjusting valuations, end of the month and ad-hoc
verification procedures; and
• Clear and independent
(i.e. independent of front office) reporting lines for
the department accountable for the valuation process.
The reporting line should ultimately be to a main
board executive director.
(ii). Valuation
methodologies
Marking to market
693.
Marking-to-market is at least the daily valuation of
positions at readily available close out prices that
are sourced independently.
Examples of readily available
close out prices include exchange prices, screen
prices, or quotes from several independent
reputable brokers.
694. Banks must mark-to-market
as much as possible.
The more prudent side of
bid/offer must be used unless the institution is a
significant market maker in a particular position
type and it can close out at mid-market.
Marking
to model
695. Where marking-to-market is not
possible, banks may mark-to-model, where this can be
demonstrated to be prudent.
Marking-to-model is defined
as any valuation which has to be benchmarked,
extrapolated or otherwise calculated from a market
input.
When marking to model, an extra degree of
conservatism is appropriate. Supervisory authorities
will consider the following in assessing whether a
mark-to-model valuation is prudent:
• Senior
management should be aware of the elements of the
trading book which are subject to mark to model and
should understand the materiality of the
uncertainty this creates in the reporting of the
risk/performance of the business.
• Market inputs
should be sourced, to the extent possible, in line with
market prices (as discussed above).
The
appropriateness of the market inputs for the
particular position being valued should be reviewed
regularly.
• Where available, generally accepted
valuation methodologies for particular
products should be used as far as possible.
•
Where the model is developed by the institution itself,
it should be based on appropriate assumptions, which
have been assessed and challenged by
suitably qualified parties independent of the
development process.
The model should be developed or
approved independently of the front office.
It should be
independently tested.
This includes validating the
mathematics, the assumptions and the
software implementation.
• There should be formal
change control procedures in place and a secure copy of
the model should be held and periodically used to
check valuations.
• Risk management should be aware
of the weaknesses of the models used and how best to
reflect those in the valuation output.
• The model
should be subject to periodic review to determine the
accuracy of its performance (e.g. assessing continued
appropriateness of the assumptions, analysis of
P&L versus risk factors, comparison of actual close
out values to model outputs).
• Valuation
adjustments should be made as appropriate, for example,
to cover the uncertainty of the model valuation (see
also valuation adjustments in 698 to
701).
Independent price verification
696.
Independent price verification is distinct from daily
mark-to-market.
It is the process by which market
prices or model inputs are regularly verified for
accuracy.
While daily marking-to-market may be
performed by dealers, verification of market prices or
model inputs should be performed by a unit
independent of the dealing room, at least monthly
(or, depending on the nature of the market/trading
activity, more frequently).
It need not be performed
as frequently as daily mark-to-market, since the
objective, i.e. independent, marking of positions,
should reveal any error or bias in pricing, which should
result in the elimination of inaccurate daily
marks.
697. Independent price verification entails a
higher standard of accuracy in that the market prices
or model inputs are used to determine profit and loss
figures, whereas daily marks are used primarily for
management reporting in between reporting dates.
For independent price verification, where pricing
sources are more subjective, e.g. only one available
broker quote, prudent measures such as valuation
adjustments may be appropriate.
(iii). Valuation
adjustments or reserves
698. Banks must establish and
maintain procedures for considering
valuation adjustments/reserves. Supervisory
authorities expect banks using third-party valuations
to consider whether valuation adjustments are
necessary.
Such considerations are also necessary
when marking to model.
699. Supervisory
authorities expect the following valuation
adjustments/reserves to be formally considered at a
minimum: unearned credit spreads, close-out costs,
operational risks, early termination, investing and
funding costs, and future administrative costs
and, where appropriate, model risk.
700. Bearing
in mind that the underlying 10-day assumption in
paragraph 718 (Lxxvi) (c) may not be consistent with
the bank’s ability to sell or hedge out positions under
normal market conditions, banks must make downward
valuation adjustments/reserves for these less liquid
positions, and to review their continued appropriateness
on an on-going basis.
Reduced liquidity could arise
from market events.
Additionally, close-out prices
for concentrated positions and/or stale positions
should be considered in establishing those valuation
adjustments/reserves.
Banks must consider all relevant
factors when determining the appropriateness of
valuation adjustments/reserves for less liquid
positions.
These factors may include, but are not
limited to, the amount of time it would take to hedge
out the position/risks within the position, the
average volatility of bid/offer spreads, the
availability of independent market quotes (number and
identity of market makers), the average
and volatility of trading volumes, market
concentrations, the aging of positions, the extent
to which valuation relies on marking-to-model, and
the impact of other model risks.
701. Valuation
adjustments/reserves made under paragraph 700 must
impact Tier 1 regulatory capital and may exceed those
made under financial accounting standards.
3. Methods
of measuring market risks
701(i). In measuring their
market risks, a choice between two broad
methodologies (described in paragraphs 709 to
718(Lxix) and 718(Lxx) to 718(XCix), respectively) will
be permitted, subject to the approval of the national
authorities.
One alternative will be to measure the
risks in a standardised manner, using the measurement
frameworks described in paragraphs 709 to 718(Lxix)
below.
Paragraphs 709 to 718(Lv) deal with the four
risks addressed in this section, i.e. interest rate,
equity position, foreign exchange and commodities
risk.
Paragraphs 718(Lvi) to 718(Lxix) set out a number
of possible methods for measuring the price risk in
options of all kinds.
The capital charge under the standardised measurement method will be the measures
of risk obtained from paragraphs 709 to 718(Lxix),
summed arithmetically.
701(ii). The alternative
methodology, which is subject to the fulfilment of
certain conditions and the use of which is therefore
conditional upon the explicit approval of the
bank’s supervisory authority, is set out in 718(Lxx)
to 718(XCix).
This method allows banks to use risk
measures derived from their own internal risk management
models, subject to seven sets of conditions,
namely:
• certain general criteria concerning the
adequacy of the risk management system;
• qualitative
standards for internal oversight of the use of models,
notably by management;
• guidelines for specifying
an appropriate set of market risk factors (i.e. the
market rates and prices that affect the value of
banks’ positions);
• quantitative standards setting
out the use of common minimum statisticalparameters
for measuring risk;
• guidelines for stress
testing;
• validation procedures for external
oversight of the use of models;
• rules for banks
which use a mixture of models and the standardised
approach.
701(iii). The standardised
methodology uses a “building-block” approach in which
specific risk and the general market risk arising
from debt and equity positions are
calculated separately.
The focus of most internal
models is a bank’s general market risk
exposure, typically leaving specific risk (i.e.
exposures to specific issuers of debt securities
or equities*) to be measured largely through
separate credit risk measurement systems.
Banks using
models should be subject to capital charges for the
specific risk not captured by their models.
Accordingly, a separate capital charge for specific risk
will apply to each bank using a model to the extent
that the model does not capture specific risk.
The
capital charge for banks which are modelling specific
risk is set out in paragraphs 718(Lxxxvii) to
718(XCviii) of this Framework. **
*
Specific risk includes the risk that an individual debt
or equity security moves by more or less than the
general market in day-to-day trading (including periods
when the whole market is volatile) and event risk (where
the price of an individual debt or equity security moves
precipitously relative to the general market, e.g. on a
takeover bid or some other shock event; such events
would also include the risk of “default”).
**
Banks that already have received specific risk model
recognition for particular portfolios or lines of
business according to the original version of the 1996
Market Risk Amendment should agree a timetable with
their supervisors to bring their model in line with the
new standards in a timely manner as is practicable, with
an end date of 1 January 2010.
Following that transition period, banks that have been
unable to develop an acceptable methodology will have to
use the standardised rules for specific risk.
701(iv). In
measuring the price risk in options under the
standardised approach, where a number of alternatives
with varying degrees of sophistication are provided (see
paragraphs 718(Lvi) to 718(Lxix)), supervisory
authorities will apply the rule that the more a bank
is engaged in writing options, the more sophisticated
its measurement method needs to be.
In the longer
term, banks which are significant traders in options
will be expected to move to comprehensive
value-at-risk models and become subject to the full
range of quantitative and qualitative standards set
out in paragraphs 718(Lxx) to 718(XCIX).
701(v). Each
bank subject to capital charges for market risk will be
expected to monitor and report the level of risk
against which a capital requirement is to be applied.
The bank’s overall minimum capital requirement will
be:
(a) the credit risk requirements laid down in
this Framework, excluding debt and equity securities
in the trading book and all positions in commodities,
but including the credit counterparty risk on all
over-the-counter derivatives whether in the trading
or the banking books; plus
(b) the capital charges
for operational risk described in paragraphs 644 to 683
of this Framework; plus
(c) either the capital
charges for market risks described in paragraphs 709 to
718(Lxix), summed arithmetically; or
(d) the
measure of market risk derived from the models approach
set out in paragraphs 718(Lxx) to 718(XCix);
or
(e) a mixture of (c) and (d) summed
arithmetically.
701(vi). All transactions, including
forward sales and purchases, shall be included in
the calculation of capital requirements as from the
date on which they were entered into.
Although
regular reporting will in principle take place only at
intervals (in most countries quarterly), banks are
expected to manage the market risk in their trading book
in such a way that the capital requirements
are being met on a continuous basis, i.e. at the close
of each business day.
Supervisory authorities have at
their disposal a number of effective measures to
ensure that banks do not “window-dress” by showing
significantly lower market risk positions on
reporting dates. Banks will also, of course, be expected
to maintain strict risk management systems to ensure
that intra-day exposures are not excessive.
If a bank
fails to meet the capital requirements, the national
authority shall ensure that the bank takes immediate
measures to rectify the situation.
4. Treatment of
counterparty credit risk in the trading book
Banks will be required to calculate the counterparty
credit risk charge for OTC derivatives, repo-style
and other transactions booked in the trading book,
separate from the capital charge for general market
risk and specific risk. *
The risk weights to be used
in this calculation must be consistent with those
used for calculating the capital requirements in
the banking book.
Thus, banks using the standardised
approach in the banking book will use
the standardised approach risk weights in the trading
book and banks using the IRB approach in the banking
book will use the IRB risk weights in the trading book
in a manner consistent with the IRB roll out
situation in the banking book as described in paragraphs
256 to 262.
For counterparties included in portfolios
where the IRB approach is being used the IRB
risk weights will have to be applied.
*
The treatment for unsettled foreign exchange and
securities trades is set forth in paragraph 88.
703. In the
trading book, for repo-style transactions, all
instruments, which are included in the trading book,
may be used as eligible collateral.
Those instruments
which fall outside the banking book definition of
eligible collateral shall be subject to a haircut at the
level applicable to non-main index equities listed on
recognised exchanges (as noted in paragraph 151).
However, where banks are using the own estimates
approach to haircutting they may also apply it in the
trading book in accordance with paragraphs 154 and
155.
Consequently, for instruments that count as
eligible collateral in the trading book, but not
in the banking book, the haircuts must be calculated
for each individual security.
Where banks are using a
VaR approach to measuring exposure for repo-style
transactions, they also may apply this approach in
the trading book in accordance with paragraphs 178 to
181 (i) and Annex 4.
704. The calculation of the
counterparty credit risk charge for collateralised
OTC derivative transactions is the same as the rules
prescribed for such transactions booked in the
banking book.
705. The calculation of the
counterparty charge for repo-style transactions will
be conducted using the rules in paragraphs 147 to 181
(i) and Annex 4 spelt out for such transactions
booked in the banking book.
The firm-size adjustment for SMEs as set out in paragraph 273 shall also be
applicable in the trading book.
Credit
derivatives 706. (deleted)
707. The counterparty
credit risk charge for single name credit derivative
transactions in the trading book will be calculated
using the following potential future exposure
add-on factors:

708.
Where the credit derivative is a first to default
transaction, the add-on will be determined by the
lowest credit quality underlying in the basket, i.e. if
there are any non qualifying items in the basket, the
non-qualifying reference obligation add-on should be
used.
For second and subsequent to default
transactions, underlying assets should continue to
be allocated according to the credit quality, i.e.
the second lowest credit quality will determine the
add-on for a second to default transaction etc.
5.
Transitional arrangements
708(i). Banks will on a
transitional basis be free to use a combination of the
standardised measurement method and the internal
models approach to measure their market risks.
As
a general rule, any such “partial” models should
cover a complete risk category (e.g. interest rate
risk or foreign exchange risk), i.e. a combination of
the two methods will not be permitted within the same
risk category. *
*
This does not, however, apply to pre-processing
techniques which are used to simplify the calculation
and whose results become subject to the standardised
methodology
However, as most banks are at present
still implementing or further improving their risk
management models, the Committee believes that the
banks should be given – even within risk categories –
some flexibility in including all their operations on
a worldwide basis; this flexibility will be subject to
approval by the national authority and reviewed by
the Committee in the future (supervisory authorities
will take precautions against “cherry-picking”
between the standardised approach and the models
approach within a risk factor category).
Banks which
adopt the modelling alternative for any single risk
category will be expected over time to include all
their operations, subject to the exceptions
mentioned below, and to move towards a comprehensive
model (i.e. one which captures all market
risk categories).
Banks which adopt a model will not
be permitted, save in exceptional circumstances, to
revert to the standardised approach.
Notwithstanding
these general principles, even banks using
comprehensive models to measure their market risk may
still incur risks in positions which are not captured
by their internal trading risk management models, for
example, in remote locations, in minor currencies or in
negligible business
areas.*
Any
such risks that are not included in a model should be
separately measured and reported using the methodologies
described in paragraphs 709 to 718(xviii) below.
*
For example, if a bank is hardly at all engaged in
commodities it would not necessarily be expected to
model its commodities risk.
B. The capital requirement
1. Definition of
capital
708(ii). The definition of capital to be used
for market risk purposes is set out in
paragraphs 49(xiii) and 49(xiv) of this
Framework.
708(iii). In calculating eligible capital,
it will be necessary first to calculate the
bank’s minimum capital requirement for credit and
operational risks, and only afterwards its
market risk requirement, to establish how much Tier 1
and Tier 2 capital is available to support market
risk.
Eligible capital will be the sum of the whole of
the bank’s Tier 1 capital, plus all of its Tier 2
capital under the limits imposed in paragraph 49(iii) of
this Framework.
Tier 3 capital will be regarded as
eligible only if it can be used to support market risks
under the conditions set out in paragraphs 49(xxi)
and 49(xxii) above.
The quoted capital ratio will
thus represent capital that is available to meet
credit risk, operational risk, and market risk.
Where a bank has Tier 3 capital, within the limits
set out in paragraph 49(xxi), which is not at
present supporting market risks, it may report that
excess as unused but eligible Tier 3 alongside
its standard ratio.
C. Market risk – The
standardised measurement method
1. Interest rate
risk
709. (Deleted)
709(i). This section describes
the standard framework for measuring the risk of holding
or taking positions in debt securities and other
interest rate related instruments in the
trading book.
The instruments covered include all
fixed-rate and floating-rate debt securities
and instruments that behave like them, including
non-convertible preference shares.117
Convertible
bonds, i.e. debt issues or preference shares that are
convertible, at a stated price, into common shares of
the issuer, will be treated as debt securities if they
trade like debt securities and as equities if they
trade like equities.
The basis for dealing with
derivative products is considered in paragraphs
718(ix) to 718(xviii) below.
709(ii). The minimum
capital requirement is expressed in terms of two
separately calculated charges, one applying to the
“specific risk” of each security, whether it is a short
or a long position, and the other to the interest
rate risk in the portfolio (termed “general market
risk”) where long and short positions in different
securities or instruments can be offset.
(i) Specific risk
709(iii). The
capital charge for specific risk is designed to protect
against an adverse movement in the price of an
individual security owing to factors related to the
individual issuer.
In measuring the risk, offsetting
will be restricted to matched positions in the
identical issue (including positions in derivatives).
Even if the issuer is the same, no offsetting will
be permitted between different issues since
differences in coupon rates, liquidity, call
features, etc. mean that prices may diverge in the
short run.
Specific risk capital charges for issuer
risk
710. The new capital charges for “government”
and “other” categories will be as follows.

710(i). The category
“government” will include all forms of government *
paper including bonds, Treasury bills and other
short-term instruments, but national authorities reserve
the right to apply a specific risk weight to
securities issued by certain foreign
governments, especially to securities denominated in
a currency other than that of the issuing
government.
*
Including, at national discretion, local and regional
governments subject to a zero credit risk weight in this
Framework.
711. When the government paper is
denominated in the domestic currency and funded by
the bank in the same currency, at national discretion a
lower specific risk charge may be applied.
711(i). The “qualifying”
category includes securities issued by public sector
entities and multilateral development banks, plus
other securities that are:
• rated
investment-grade * by at least two credit rating
agencies specified by the national authority; or
•
rated investment-grade by one rating agency and not less
than investment-grade by any other rating agency
specified by the national authority (subject to
supervisory oversight); or
• subject to
supervisory approval, unrated, but deemed to be of
comparable investment quality by the reporting bank,
and the issuer has securities listed on a
recognised stock exchange.
Each supervisory
authority will be responsible for monitoring the
application of these qualifying criteria,
particularly in relation to the last criterion where the
initial classification is essentially left to the
reporting banks.
National authorities will also have
discretion to include within the qualifying category
debt securities issued by banks in countries which
have implemented this Framework, subject to the
express understanding that supervisory authorities in
such countries undertake prompt remedial action if a
bank fails to meet the capital standards set forth in
this Framework.
Similarly, national authorities will
have discretion to include within the qualifying
category debt securities issued by securities
firms that are subject to equivalent
rules.
*
E.g. rated Baa or higher by
Moody’s and BBB or higher by Standard and Poor’s.
711(ii). Furthermore, the “qualifying”
category shall include securities issued by
institutions that are deemed to be equivalent to
investment grade quality and subject to supervisory
and regulatory arrangements comparable to those under
this Framework.
Specific risk rules for unrated debt
securities
712. Unrated securities may be included in
the “qualifying” category when they are subject to
supervisory approval, unrated, but deemed to be of
comparable investment quality by the reporting bank,
and the issuer has securities listed on a recognised
stock exchange.
This will remain unchanged for banks
using the standardised approach.
For banks using
the IRB approach for a portfolio, unrated securities
can be included in the “qualifying” category if both
of the following conditions are met:
• the securities
are rated equivalent * to investment grade under the
reporting bank’s internal rating system, which the
national supervisor has confirmed complies with the
requirements for an IRB approach; and
• the issuer
has securities listed on a recognised stock
exchange.
*
Equivalent means the debt security has a one-year PD
equal to or less than the one year PD implied by the
long-run average one-year PD of a security rated
investment grade or better by a qualifying rating
agency.
Specific risk rules for non-qualifying
issuers
712(i). Instruments issued by a
non-qualifying issuer will receive the same specific
risk charge as a non-investment grade corporate
borrower under the standardised approach for credit
risk under this Framework.
712(ii). However,
since this may in certain cases considerably
underestimate the specific risk for debt instruments
which have a high yield to redemption relative to
government debt securities, each national supervisor
will have the discretion:
• To apply a higher
specific risk charge to such instruments; and/or
• To
disallow offsetting for the purposes of defining the
extent of general market risk between such
instruments and any other debt instruments.
In that
respect, securitisation exposures that would be subject
to a deduction treatment under the securitisation
framework set forth in this Framework (e.g. equity
tranches that absorb first loss), as well as
securitisation exposures that are unrated liquidity
lines or letters of credit should be subject to a
capital charge that is no less than the charge set forth
in the securitisation framework.
Specific risk
capital charges for positions hedged by credit
derivatives
713. Full allowance will be recognised
when the values of two legs (i.e. long and
short) always move in the opposite direction and
broadly to the same extent.
This would be the case in
the following situations:
(a) the two legs consist of
completely identical instruments, or
(b) a long cash
position is hedged by a total rate of return swap (or
vice versa) and there is an exact match between the
reference obligation and the underlying exposure
(i.e. the cash position). *
In these cases, no
specific risk capital requirement applies to both sides
of the position.
*
The maturity of the swap itself may be different from
that of the underlying exposure.
714. An 80% offset will be
recognised when the value of two legs (i.e. long and
short) always moves in the opposite direction but not
broadly to the same extent.
This would be the case
when a long cash position is hedged by a credit default
swap or a credit linked note (or vice versa) and
there is an exact match in terms of the reference
obligation, the maturity of both the reference
obligation and the credit derivative, and the currency
of the underlying exposure.
In addition, key features
of the credit derivative contract (e.g. credit
event definitions, settlement mechanisms) should not
cause the price movement of the credit derivative to
materially deviate from the price movements of the cash
position.
To the extent that the transaction
transfers risk (i.e. taking account of restrictive
payout provisions such as fixed payouts and
materiality thresholds), an 80% specific risk offset
will be applied to the side of the transaction with
the higher capital charge, while the specific risk
requirement on the other side will be zero.
715.
Partial allowance will be recognised when the value of
the two legs (i.e. long and short) usually moves in
the opposite direction. This would be the case in the
following situations:
(a) the position is captured
in paragraph 713 under (b), but there is an asset
mismatch between the reference obligation and the
underlying exposure. Nonetheless, the position meets
the requirements in paragraph 191 (g).
(b) The position
is captured in paragraph 713 under (a) or 714 but there
is a currency or maturity mismatch * between the
credit protection and the underlying asset.
(c) The
position is captured in paragraph 714 but there is an
asset mismatch between the cash position and the
credit derivative.
However, the underlying asset
is included in the (deliverable) obligations in the
credit derivative documentation.
*
Currency mismatches should feed into the normal
reporting of foreign exchange risk.
716. In each of
these cases in paragraphs 713 to 715, the following rule
applies.
Rather than adding the specific risk capital
requirements for each side of the transaction (i.e.
the credit protection and the underlying asset) only
the higher of the two capital requirements
will apply.
717. In cases not captured in
paragraphs 713 to 715, a specific risk capital charge
will be assessed against both sides of the
position.
718. With regard to banks’ first-to-default
and second-to-default products in the trading book,
the basic concepts developed for the banking book will
also apply.
Banks holding long positions in these
products (e.g. buyers of basket credit linked notes)
would be treated as if they were protection sellers
and would be required to add the specific risk charges
or use the external rating if available.
Issuers of
these notes would be treated as if they were
protection buyers and are therefore allowed to
off-set specific risk for one of the underlyings, i.e.
theasset with the lowest specific risk
charge.
(ii) General market risk
718(i). The
capital requirements for general market risk are
designed to capture the risk of loss arising from
changes in market interest rates. A choice between two
principal methods of measuring the risk is permitted,
a “maturity” method and a “duration” method.
In each
method, the capital charge is the sum of four
components:
• The net short or long position in the
whole trading book;
• A small proportion of the
matched positions in each time-band (the
“vertical disallowance”); • A larger proportion of
the matched positions across different time-bands
(the “horizontal disallowance”);
• A net charge
for positions in options, where appropriate (see
paragraphs 718(Lxvi) to 718(Lxix)).
718(ii).
Separate maturity ladders should be used for each
currency and capital charges should be calculated for
each currency separately and then summed with no
offsetting between positions of opposite sign. In the
case of those currencies in which business
is insignificant, separate maturity ladders for each
currency are not required.
Rather, the bank may
construct a single maturity ladder and slot, within each
appropriate time-band, the net long or short position
for each currency.
However, these individual net
positions are to be summed within each time-band,
irrespective of whether they are long or short
positions, to produce a gross position figure.
718(iii).
In the maturity method (see paragraph 718(vii) for the
duration method), long or short positions in debt
securities and other sources of interest rate exposures
including derivative instruments are slotted into a
maturity ladder comprising thirteen time-bands
(or fifteen time-bands in case of low coupon
instruments).
Fixed rate instruments should
be allocated according to the residual term to
maturity and floating-rate instruments according
to the residual term to the next repricing date.
Opposite positions of the same amount in the same
issues (but not different issues by the same issuer),
whether actual or notional, can be omitted from the
interest rate maturity framework, as well as closely
matched swaps, forwards, futures and FRAs which meet
the conditions set out in paragraphs 718(xiii)
and 718(xiv) below.
718(iv). The first step in the
calculation is to weight the positions in each time-band
by a factor designed to reflect the price sensitivity
of those positions to assumed changes in interest
rates.
The weights for each time-band are set out in the
table below.
Zero-coupon bonds and deep-discount
bonds (defined as bonds with a coupon of less than 3%)
should be slotted according to the time-bands set out
in the second column of the table.

718(v). The next
step in the calculation is to offset the weighted longs
and shorts in each time-band, resulting in a single
short or long position for each band.
Since, however,
each band would include different instruments and
different maturities, a 10% capital charge to reflect
basis risk and gap risk will be levied on the smaller of
the offsetting positions, be it long or short.
Thus,
if the sum of the weighted longs in a time-band is $100
million and the sum of the weighted shorts $90
million, the so-called “vertical disallowance” for that
timeband would be 10% of $90 million (i.e. $9.0
million).
718(vi). The result of the above
calculations is to produce two sets of weighted
positions, the net long or short positions in each
time-band ($10 million long in the example above) and
the vertical disallowances, which have no sign.
In
addition, however, banks will be allowed to conduct
two rounds of “horizontal offsetting”, first between the
net positions in each of three zones (zero to one
year, one year to four years and four years and
over), * and subsequently between the net positions
in the three different zones.
The offsetting will
be subject to a scale of disallowances expressed as a
fraction of the matched positions, as set out in the
table below.
The weighted long and short positions in
each of three zones may be offset, subject to the
matched portion attracting a disallowance factor that is
part of the capital charge.
The residual net position
in each zone may be carried over and offset
againstopposite positions in other zones, subject to
a second set of disallowance factors.

*
The zones for coupons less than 3% are 0 to 1 year, 1 to
3.6 years, and 3.6 years and over.
124 The zones for coupons less than 3% are 0 to 1 year,
1 to 3.6 years, and 3.6 years and over.
718(vii). Under the alternative duration
method, banks with the necessary capability may, with
their supervisors’ consent, use a more accurate method
of measuring all of their general market risk by
calculating the price sensitivity of each position
separately.
Banks must elect and use the method on a
continuous basis (unless a change in method is approved
by the national authority) and will be subject to
supervisory monitoring of the systems used.
The mechanics of this method are as follows:
•
First calculate the price sensitivity of each instrument
in terms of a change in interest rates of between 0.6
and 1.0 percentage points depending on the maturity of
the instrument (see the table below);
• Slot the
resulting sensitivity measures into a duration-based
ladder with the fifteen time-bands set out in the
table below;
• Subject long and short positions in
each time-band to a 5% vertical disallowance designed
to capture basis risk;
• Carry forward the net
positions in each time-band for horizontal offsetting
subject to the disallowances set out in table
paragraph 718(vi) above.

718(viii). In the case of residual
currencies (see paragraph 718(ii) above) the
gross positions in each time-band will be subject to
either the risk weightings set out in
paragraph 718(iv), if positions are reported using
the maturity method, or the assumed change in
yield set out in paragraph 718(vii), if positions are
reported using the duration method, with no further
offsets.
(iii) Interest rate derivatives
718(ix).
The measurement system should include all interest rate
derivatives and off balance- sheet instruments in the
trading book which react to changes in interest rates,
(e.g. forward rate agreements (FRAs), other forward
contracts, bond futures, interest rate
and cross-currency swaps and forward foreign exchange
positions).
Options can be treated in a variety of
ways as described in paragraphs 718(Lvi) to 718(Lxix)
below.
A summary of the rules for dealing with
interest rate derivatives is set out in paragraph
718(xviii) below.
Calculation of positions
718(x).
The derivatives should be converted into positions in
the relevant underlying and become subject to
specific and general market risk charges as described
above.
In order to calculate the standard formula
described above, the amounts reported should be the
market value of the principal amount of the
underlying or of the notional underlying resulting from
the prudent valuation guidance set out in paragraphs
690 to 701 above. *
*
For
instruments where the apparent notional amount differs
from the effective notional amount, banks must use the
effective notional amount.
Futures and forward contracts,
including forward rate agreements
718(xi). These
instruments are treated as a combination of a long and a
short position in a notional government security.
The
maturity of a future or a FRA will be the period
until delivery or exercise of the contract, plus -
where applicable - the life of the underlying instrument.
For
example, a long position in a June three month interest
rate future (taken in April) is to be reported as a
long position in a government security with a maturity
of five months and a short position in a government
security with a maturity of two months.
Where a range
of deliverable instruments may be delivered to fulfil
the contract, the bank has flexibility to elect which
deliverable security goes into the maturity or duration
ladder but should take account of any conversion
factor defined by the exchange.
In the case of a future
on a corporate bond index, positions will be included
at the market value of the notional
underlying portfolio of
securities.
Swaps
718(xii). Swaps will be treated
as two notional positions in government securities
with relevant maturities.
For example, an interest
rate swap under which a bank is receiving floating
rate interest and paying fixed will be treated as a long
position in a floating rate instrument of maturity
equivalent to the period until the next interest fixing
and a short position in a fixed-rate instrument of
maturity equivalent to the residual life of the swap.
For swaps that pay or receive a fixed or floating
interest rate against some other reference
price, e.g. a stock index, the interest rate
component should be slotted into the
appropriate repricing maturity category, with the
equity component being included in the
equity framework.
The separate legs of cross-currency
swaps are to be reported in the relevant maturity
ladders for the currencies concerned.
Calculation of
capital charges for derivatives under the standardised
methodology
Allowable offsetting of matched
positions
718(xiii). Banks may exclude from the
interest rate maturity framework altogether (for
both specific and general market risk) long and short
positions (both actual and notional) in identical
instruments with exactly the same issuer, coupon,
currency and maturity.
A matched position in a future
or forward and its corresponding underlying may also be
fully offset, * and thus excluded from the
calculation.
When the future or the forward comprises
a range of deliverable instruments offsetting of
positions in the future or forward contract and its
underlying is only permissible in cases where there is a
readily identifiable underlying security which is
most profitable for the trader with a short position to
deliver.
The price of this security, sometimes called
the “cheapest-to-deliver”, and the price of the future
or forward contract should in such cases move in
close alignment.
No offsetting will be
allowed between positions in different currencies;
the separate legs of cross-currency swaps or forward
foreign exchange deals are to be treated as notional
positions in the relevant instruments and included in
the appropriate calculation for each
currency.
*
The leg representing the time to expiry of the future
should, however, be reported.
718(xiv). In addition, opposite positions
in the same category of instruments* can in
certain circumstances be regarded as matched and
allowed to offset fully.
To qualify for
this treatment the positions must relate to the same
underlying instruments, be of the same nominal value
and be denominated in the same currency.**
* This
includes the delta-equivalent value of options. The
delta equivalent of the legs arising out of the
treatment of caps and floors as set out in paragraph
718(Lx) can also be offset against each other under the
rules laid down in this paragraph. ** The
separate legs of different swaps may also be “matched”
subject to the same conditions.
In
addition:
(i) for
futures: offsetting positions in the notional or
underlying instruments to which the futures contract
relates must be for identical products and mature within
seven days of each other;
(ii) for swaps and FRAs:
the reference rate (for floating rate positions) must
be identical and the coupon closely matched (i.e.
within 15 basis points); and
(iii) for swaps, FRAs
and forwards: the next interest fixing date or, for
fixed coupon positions or forwards, the residual
maturity must correspond within the
following limits:
• less than one month hence:
same day;
• between one month and one year hence:
within seven days;
• over one year hence: within
thirty days.
718(xv). Banks with large swap books may
use alternative formulae for these swaps to calculate
the positions to be included in the maturity or duration
ladder.
One method would be to first convert the
payments required by the swap into their present values.
For that purpose, each payment should be discounted
using zero coupon yields, and a single net figure for
the present value of the cash flows entered into the
appropriate time-band using procedures that apply to
zero (or low) coupon bonds; these figures should be
slotted into the general market risk framework as set
out above.
An alternative method would be to
calculate the sensitivity of the net present value
implied by the change in yield used in the maturity
or duration method and allocate these sensitivities
into the time-bands set out in paragraph 718(iv) or
paragraph 718(vii).
Other methods which produce similar
results could also be used.
Such alternative
treatments will, however, only be allowed if:
• the
supervisory authority is fully satisfied with the
accuracy of the systems being used;
• the
positions calculated fully reflect the sensitivity of
the cash flows to interest rate changes and are
entered into the appropriate time-bands;
• the
positions are denominated in the same
currency.
Specific risk
718(xvi). Interest rate
and currency swaps, FRAs, forward foreign exchange
contracts and interest rate futures will not be
subject to a specific risk charge.
This exemption also
applies to futures on an interest rate index (e.g.
LIBOR).
However, in the case of futures
contracts where the underlying is a debt security, or
an index representing a basket of debt securities, a
specific risk charge will apply according to the credit
risk of the issuer as set out in paragraphs 709(iii)
to 718 above.
General market risk
718(xvii).
General market risk applies to positions in all
derivative products in the same manner as for cash
positions, subject only to an exemption for fully or
very closely matched positions in identical
instruments as defined in paragraphs 718(xiii) and
718(xiv).
The various categories of instruments
should be slotted into the maturity ladder and treated
according to the rules identified
earlier.
718(xviii). The table below presents a
summary of the regulatory treatment for interest
rate derivatives, for market risk
purposes.

129
This is the specific risk charge relating to the issuer
of the instrument. Under the existing credit risk rules,
there remains a separate capital charge for the
counterparty risk.
130
The specific risk capital charge only applies to
government debt securities that are rated below AA- (see
paragraphs 710 and 710 (i)).
2. Equity
position risk
718(xix). This
section sets out a minimum capital standard to cover the
risk of holding or taking positions in equities in
the trading book.
It applies to long and short positions
in all instruments that exhibit market behaviour
similar to equities, but not to
non-convertible preference shares (which are covered
by the interest rate risk requirements described
in paragraphs 709 to 718(xviii)).
Long and short
positions in the same issue may be reported on net
basis.
The instruments covered include common stocks,
whether voting or non-voting, convertible securities
that behave like equities, and commitments to buy or
sell equity securities.
The treatment of derivative
products, stock indices and index arbitrage
is described in paragraphs 718(xxii) to 718(xxix)
below.
(i). Specific and general
market risk
718(xx). As with debt securities, the
minimum capital standard for equities is expressed
in terms of two separately calculated charges for the
“specific risk” of holding a long or short position
in an individual equity and for the “general market
risk” of holding a long or short position in the
market as a whole.
Specific risk is defined as the
bank’s gross equity positions (i.e. the sum of all
long equity positions and of all short equity positions)
and general market risk as the difference between the
sum of the longs and the sum of the shorts (i.e. the
overall net position in an equity market).
The long or
short position in the market must be calculated on a
market-by-market basis, i.e. a separate calculation has
to be carried out for each national market in which
the bank holds equities.
718(xxi). The capital charge
for specific risk will be 8%, unless the portfolio is
both liquid and well-diversified, in which case the
charge will be 4%. Given the different characteristics
of national markets in terms of marketability and
concentration, national authorities will
have discretion to determine the criteria for liquid
and diversified portfolios.
The general market risk
charge will be 8%.
(ii). Equity
derivatives
718(xxii). Except for options, which are
dealt with in paragraphs 718(Lvi) to 718(Lxix),
equity derivatives and off-balance-sheet positions
which are affected by changes in equity prices should
be included in the measurement system.*
This includes
futures and swaps on both individual equities and on
stock indices.
The derivatives are to be converted into
positions in the relevant underlying.
The treatment
of equity derivatives is summarised in
paragraph
718(xxix) below.
*
Where equities are part of a forward contract, a future
or an option (quantity of equities to be received or to
be delivered), any interest rate or foreign currency
exposure from the other leg of the contract should be
reported as set out in paragraphs 709 to 718(xviii) and
718(xxx) to 718(xLii).
718(xxiii). In order to calculate the
standard formula for specific and general market
risk, positions in derivatives should be converted
into notional equity positions:
• Futures and forward
contracts relating to individual equities should in
principle be reported at current market prices;
•
Futures relating to stock indices should be reported as
the marked-to-market value of the notional underlying
equity portfolio;
• Equity swaps are to be treated as
two notional positions;*
• Equity options and stock
index options should be either “carved out” together
with the associated underlyings or be incorporated in
the measure of general market risk described in this
section according to the delta-plus method.
*
For example, an equity swap in which a bank is receiving
an amount based on the change in value of one particular
equity or stock index and paying a different index will
be treated as a long position in the former and a short
position in the latter. Where one of the legs involves
receiving/paying a fixed or floating interest rate, that
exposure should be slotted into the appropriate
repricing time-band for interest rate related
instruments as set out in paragraphs 709 to 718(xviii).
The
stock index should be covered by the equity treatment.
Calculation of capital
charges
Measurement of specific and general market
risk
718(xxiv). Matched positions in each identical
equity or stock index in each market may be fully
offset, resulting in a single net short or long position
to which the specific and general market risk charges
will apply. For example, a future in a given equity may
be offset against an opposite cash position in the
same equity. *
*
The
interest rate risk arising out of the future, however,
should be reported as set out in paragraphs 709 to
718(xviii).
Risk in relation to an
index
718(xxv). Besides general market risk, a
further capital charge of 2% will apply to the
net long or short position in an index contract
comprising a diversified portfolio of equities.
This capital charge is intended to cover factors such
as execution risk.
National supervisory authorities
will take care to ensure that this 2% risk weight
applies only to well-diversified indices and not, for
example, to sectoral indices.
Arbitrage
718(xxvi).
In the case of the futures-related arbitrage strategies
described below, the additional 2% capital charge
described above may be applied to only one index with
the opposite position exempt from a capital charge.
The strategies are:
• When the bank takes an opposite
position in exactly the same index at different dates
or in different market centres;
• When the bank has
an opposite position in contracts at the same date in
different but similar indices, subject to supervisory
oversight that the two indices contain sufficient
common components to justify offsetting.
718(xxvii).
Where a bank engages in a deliberate arbitrage strategy,
in which a futures contract on a broadly-based index
matches a basket of stocks, it will be allowed to carve
out both positions from the standardised methodology
on condition that:
• The trade has been deliberately
entered into and separately controlled;
• The
composition of the basket of stocks represents at least
90% of the index when broken down into its notional
components.
In such a case the minimum capital
requirement will be 4% (i.e. 2% of the gross value of
the positions on each side) to reflect divergence and
execution risks.
This applies even if all of the
stocks comprising the index are held in identical
proportions. Any excess value of the stocks
comprising the basket over the value of the futures
contract or excess value of the futures contract over
the value of the basket is to be treated as an open long
or short position.
718(xxviii). If a bank takes a
position in depository receipts against an opposite
position in the underlying equity or identical
equities in different markets, it may offset the
position (i.e. bear no
capital charge) but only on condition that any costs on
conversion are fully taken
into account. *
*
Any foreign exchange risk arising out of these positions
has to be reported as set out in paragraphs 718(xxx) to
718(xLvii).
718(xxix). The table below
summarises the regulatory treatment of equity
derivatives for market risk purposes.

135
This is the specific risk charge relating to the issuer
of the instrument. Under the existing credit risk rules,
there remains a separate capital charge for the
counterparty risk.
3. Foreign exchange risk
718(xxx). This
section sets out a minimum capital standard to cover the
risk of holding or taking positions in foreign
currencies, including gold. *
*
Gold is to be dealt with as a foreign exchange position
rather than a commodity because its volatility is more
in line with foreign currencies and banks manage it in a
similar manner to foreign currencies.
718(xxxi). Two
processes are needed to calculate the capital
requirement for foreign exchange risk. The first is
to measure the exposure in a single currency position.
The second is to measure the risks inherent in a
bank’s mix of long and short positions in
different currencies.
(i). Measuring the exposure
in a single currency
718(xxxii). The bank’s net open
position in each currency should be calculated by
summing:
• The net spot position
(i.e. all asset items less all liability items,
including accrued interest, denominated in the
currency in question);
• The net forward position
(i.e. all amounts to be received less all amounts to be
paid under forward foreign exchange transactions,
including currency futures and the principal on
currency swaps not included in the spot position);
•
Guarantees (and similar instruments) that are certain to
be called and are likely to be irrecoverable;
•
Net future income/expenses not yet accrued but already
fully hedged (at the discretion of the reporting
bank);
• Depending on particular accounting
conventions in different countries, any other item
representing a profit or loss in foreign
currencies;
• The net delta-based equivalent of the
total book of foreign currency
options. *
*
Subject to a separately calculated capital charge for
gamma and vega as described in paragraphs 718(Lix) to
718(Lxii); alternatively, options and their associated
underlyings are subject to one of the other methods
described in paragraphs 718(Lvi) to 718(Lxix).
718(xxxiii). Positions in composite
currencies need to be separately reported but,
for measuring banks’ open positions, may be either
treated as a currency in their own right or split
into their component parts on a consistent basis.
Positions in gold should be measured in the same
manner as described in paragraph
718(xLix). *
*
Where gold is part of a forward contract (quantity of
gold to be received or to be delivered), any interest
rate or foreign currency exposure from the other leg of
the contract should be reported as set out in paragraphs
709 to 718(xviii) and 718(xxxii) above.
718(xxxiv). Three aspects call for more
specific comment: the treatment of interest,
other income and expenses; the measurement of forward
currency positions and gold; and the treatment of
“structural” positions.
The treatment of interest,
other income and expenses
718(xxxv). Interest accrued
(i.e. earned but not yet received) should be included as
a position.
Accrued expenses should also be included.
Unearned but expected future interest and anticipated
expenses may be excluded unless the amounts are certain
and banks have taken the opportunity to hedge them.
If banks include future income/expenses they should
do so on a consistent basis, and not be permitted to
select only those expected future flows which reduce
their position.
The measurement of forward currency
and gold positions
718(xxxvi). Forward currency and
gold positions will normally be valued at current
spot market exchange rates. Using forward exchange
rates would be inappropriate since it would result in
the measured positions reflecting current interest rate
differentials to some extent.
However, banks which
base their normal management accounting on net present
values are expected to use the net present values of
each position, discounted using current
interest rates and valued at current spot rates, for
measuring their forward currency and
gold positions.
The
treatment of structural positions
718(xxxvii). A
matched currency position will protect a bank against
loss from movements in exchange rates, but will not
necessarily protect its capital adequacy ratio.
If a
bank has its capital denominated in its domestic
currency and has a portfolio of foreign currency
assets and liabilities that is completely matched,
its capital/asset ratio will fall if the
domestic currency depreciates.
By running a short
position in the domestic currency the bank
can protect its capital adequacy ratio, although the
position would lead to a loss if the
domestic currency were to
appreciate.
718(xxxviii). Supervisory authorities are
free to allow banks to protect their capital
adequacy ratio in this way. Thus, any positions which
a bank has deliberately taken in order to
hedge partially or totally against the adverse effect
of the exchange rate on its capital ratio may
be excluded from the calculation of net open currency
positions, subject to each of the
following conditions being met:
• Such positions
need to be of a “structural”, i.e. of a non-dealing,
nature (the precise definition to be set by national
authorities according to national
accounting standards and practices);
• The
national authority needs to be satisfied that the
“structural” position excluded does no more than
protect the bank’s capital adequacy ratio;
• Any
exclusion of the position needs to be applied
consistently, with the treatment of the hedge
remaining the same for the life of the assets or other
items.
718(xxxix). No capital charge need apply to
positions related to items that are deducted from a
bank’s capital when calculating its capital base, such
as investments in non-consolidated subsidiaries, nor
to other long-term participations denominated in foreign
currencies which are reported in the published
accounts at historic cost.
These may also be treated
as structural positions.
(ii). Measuring the
foreign exchange risk in a portfolio of foreign currency
positions and gold
718(xL). Banks will have a
choice between two alternative measures at
supervisory discretion; a “shorthand” method which
treats all currencies equally; and the use of
internal models which takes account of the actual
degree of risk dependent on the composition of
the bank’s portfolio.
The conditions for the use of
internal models are set out in paragraphs 718(Lxx) to
718(xcix) below.
718(xLi). Under the shorthand
method, the nominal amount (or net present value) of the
net position in each foreign currency and in gold is
converted at spot rates into the
reporting currency.*
*
Where the bank is assessing its foreign exchange risk on
a consolidated basis, it may be technically impractical
in the case of some marginal operations to include the
currency positions of a foreign branch or subsidiary of
the bank. In such cases the internal limit in each
currency may be used as a proxy for the positions.
Provided there is adequate ex post monitoring of actual
positions against such limits, the limits should be
added, without regard to sign, to the net open position
in each currency.
The overall net open position
is measured by aggregating:
• The sum of the net
short positions or the sum of the net long positions,
whichever is the greater; ** plus
• The net position (short or
long) in gold, regardless of sign.
**
An alternative calculation, which produces an identical
result, is to include the reporting currency as a
residual and to take the sum of all the short (or long)
positions.
The capital charge
will be 8% of the overall net open position (see example
below).

The capital
charge would be 8% of the higher of either the net long
currency positions or the net short currency
positions (i.e. 300) and of the net position in gold
(35) = 335 x 8% = 26.8.
718(xLii). A bank doing
negligible business in foreign currency and which does
not take foreign exchange positions for its own
account may, at the discretion of its national
authority, be exempted from capital requirements on
these positions provided that:
• Its foreign currency
business, defined as the greater of the sum of its gross
long positions and the sum of its gross short
positions in all foreign currencies, does not exceed
100% of eligible capital as defined in paragraphs
49(xxi) and 49(xxii); and
• Its overall net open
position as defined in the paragraph above does not
exceed 2% of its eligible capital as defined in
paragraphs 49(xxi) and 49(xxii)
4. Commodities
risk
718(xLiii). This section establishes a minimum
capital standard to cover the risk of holding
or taking positions in commodities, including
precious metals, but excluding gold (which is treated
as a foreign currency according to the methodology set
out in paragraphs 718(xxx) to 718(xLii) above).
A
commodity is defined as a physical product which is or
can be traded on a secondary market, e.g.
agricultural products, minerals (including oil) and
precious metals.
718(xLiv). The price risk in
commodities is often more complex and volatile than
that associated with currencies and interest rates.
Commodity markets may also be less liquid than those
for interest rates and currencies and, as a result,
changes in supply and demand can have a more dramatic
effect on price and volatility. *
These market
characteristics can make price transparency and the
effective hedging of commodities risk more
difficult.
*
Banks need also to guard against the risk that arises
when the short position falls due before the long
position. Owing to a shortage of liquidity in some
markets it might be difficult to close the short
position and the bank might be squeezed by the market.
718(xLv). For spot or physical trading,
the directional risk arising from a change in the
spot price is the most important risk. However, banks
using portfolio strategies involving forward and
derivative contracts are exposed to a variety of
additional risks, which may well be larger than the
risk of a change in spot prices.
These include:
•
Basis risk (the risk that the relationship between the
prices of similar commodities alters through
time);
•
Interest rate risk (the risk of a change in the cost of
carry for forward positions and options);
•
Forward gap risk (the risk that the forward price may
change for reasons other than a change in interest
rates);
In addition banks may face credit
counterparty risk on over-the-counter derivatives, but
this is captured by one of the methods set out in
Annex 4 of this Framework.
The funding of commodities
positions may well open a bank to interest rate or
foreign exchange exposure and if that is so the
relevant positions should be included in the measures of
interest rate and foreign exchange risk described in
paragraphs 709 to 718(xviii) and paragraphs 718(xxx)
to 718(xLii), respectively. *
*
Where a commodity is part of a
forward contract (quantity of commodities to be received
or to be delivered), any interest rate or foreign
currency exposure from the other leg of the contract
should be reported as set out in paragraphs 709 to
718(xviii) and paragraphs 718(xxx) to 718(xLii).
Positions which are purely stock financing (i.e. a
physical stock has been sold forward and the cost of
funding has been locked in until the date of the
forward sale) may be omitted from the commodities risk
calculation although they will be subject to interest
rate and counterparty risk requirements.
718(xLvi). There
are three alternatives for measuring commodities
position risk which are described in paragraphs
718(xLviii) to 718(Lv) below.
As with other categories
of market risk, banks may use models subject to the
conditions set out in paragraphs 718(Lxx) to
718(xcix).
Commodities risk can also be measured in a
standardised manner, using either a verysimple
framework (paragraphs 718(Liv) and 718(Lv) below) or a
measurement system which captures forward gap and
interest rate risk separately by basing the methodology
on seven time-bands (paragraphs 718(xLix) to
718(Liii) below).
Both the simplified approach and
the maturity ladder approach are appropriate only for
banks which, in relative terms, conduct only a
limited amount of commodities business.
Major traders
would be expected over time to adopt a models
approach subject to the safeguards set out in paragraphs
718(Lxx) to 718(xcix).
718(xLvii). For the
maturity ladder approach and the simplified approach,
long and short positions in each commodity may be
reported on a net basis for the purposes of
calculating open positions.
However, positions in
different commodities will as a general rule not
be offsettable in this fashion. Nevertheless,
national authorities will have discretion to
permit netting between different sub-categories * of
the same commodity in cases where the
subcategories are deliverable against each other.
They can also be considered as offsettable if they
are close substitutes against each other and a minimum
correlation of 0.9 between the price movements can be
clearly established over a minimum period of one year.
However, a bank wishing to base its calculation of
capital charges for commodities on correlations
would have to satisfy the relevant supervisory
authority of the accuracy of the method which
has been chosen and obtain its prior approval.
Where
banks use the models approach they can offset long
and short positions in different commodities to a degree
which is determined by empirical correlations, in the
same way as a limited degree of offsetting is allowed,
for instance, between interest rates in different
currencies.
* Commodities can be grouped into
clans, families, sub-groups and individual commodities.
For example, a clan might be Energy Commodities, within which
Hydro-Carbons are a family with Crude Oil being a
sub-group and West Texas Intermediate, Arabian Light
and Brent being individual commodities.
(i)
Models for measuring commodities risk
718(xLviii).
Banks may choose to adopt the models approach as set out
in paragraphs 718(Lxx) to 718(xcix). It is essential
that the methodology used encompasses:
• Directional
risk, to capture the exposure from changes in spot
prices arising from net open positions;
• Forward
gap and interest rate risk, to capture the exposure to
changes in forward prices arising from maturity
mismatches; and
• Basis risk, to capture the exposure
to changes in the price relationships between two
similar, but not identical, commodities.
It is also
particularly important that models take proper account
of market characteristics - notably delivery dates
and the scope provided to traders to close out
positions.
(ii) Maturity ladder
approach
718(xLix). In calculating the capital
charges under this approach banks will first have
to express each commodity position (spot plus
forward) in terms of the standard unit of measurement
(barrels, kilos, grams etc.).
The net position in each
commodity will then be converted at current spot
rates into the national currency.
718(L). Secondly,
in order to capture forward gap and interest rate risk
within a time-band (which, together, are sometimes
referred to as curvature/spread risk), matched long
and short positions in each time-band will carry a
capital charge.
The methodology will be
rather similar to that used for interest rate related
instruments as set out in paragraphs 709
to 718(xviii).
Positions in the separate commodities
(expressed in terms of the standard unit
of measurement) will first be entered into a maturity
ladder while physical stocks should be allocated to
the first time-band.
A separate maturity ladder will be
used for each commodity as defined in paragraph
718(xLvii) above. *
For each time-band, the sum of
short and long positions which are matched will be
multiplied first by the spot price for the commodity,
and then by the appropriate spread rate for that band
(as set out in the table below).
* For markets
which have daily delivery dates, any contracts maturing
within ten days of one another may
be offset.

718(Li). The residual net positions from
nearer time-bands may then be carried forward
tooffset exposures in time-bands that are further
out.
However, recognising that such hedging of
positions among different time-bands is imprecise, a
surcharge equal to 0.6% of the net position carried
forward will be added in respect of each time-band that
the net position is carried forward.
The capital
charge for each matched amount created by carrying
net positions forward will be calculated as in
paragraph 718(L) above.
At the end of this process a
bank will have either only long or only short positions,
to which a capital charge of 15%
will apply.
718(Lii). Even though the Committee is
aware that there are differences in volatility
between different commodities, it has decided in the
interest of simplicity, and given the fact that banks
normally run rather small open positions in commodities,
that one uniform capital charge for open positions in
all commodities should apply.
Those banks which desire
to be more precise in this area may choose to adopt
the models approach.
718(Liii). All commodity
derivatives and off-balance-sheet positions which are
affected by changes in commodity prices should be
included in this measurement framework.
This includes
commodity futures, commodity swaps, and options where
the “delta plus” method145 is used (see paragraphs
718(Lix) to 718(Lxii) below). In order to calculate the
risk, commodity derivatives should be converted into
notional commodities positions and assigned
to maturities as follows:
• Futures and forward
contracts relating to individual commodities should
be incorporated in the measurement system as notional
amounts of barrels, kilos etc. and should be assigned
a maturity with reference to expiry date;
• Commodity
swaps where one leg is a fixed price and the other the
current market price should be incorporated as a
series of positions equal to the notional amount
of the contract, with one position corresponding with
each payment on the swap and slotted into the
maturity ladder accordingly.
The positions would be long
positions if the bank is paying fixed and
receiving floating, and short positions if the bank
is receiving fixed and paying floating; *
•
Commodity swaps where the legs are in different
commodities are to be incorporated in the relevant
maturity ladder.
No offsetting will be allowed in
this regard except where the commodities belong to
the same sub-category as defined in paragraph
718(xLvii) above.
*
If one of the legs involves receiving/paying a fixed or
floating interest rate, that exposure should be slotted
intothe appropriate repricing maturity band in the
maturity ladder covering interest rate related
instruments.
(iii) Simplified
approach
718(Liv). In calculating the capital charge
for directional risk, the same procedure will
be adopted as in the maturity ladder approach above
(see paragraphs 718(xLix) and 718(Liii)).
Once again,
all commodity derivatives and off-balance-sheet
positions which are affected by changes in commodity
prices should be included. The capital charge will equal
15% of the net position, long or short, in each
commodity.
718(Lv). In order to protect the bank
against basis risk, interest rate risk and forward gap
risk, the capital charge for each commodity as
described in paragraphs 718(xLix) and 718(Liii) above
will be subject to an additional capital charge
equivalent to 3% of the bank’s gross positions, long
plus short, in that particular commodity.
In valuing the
gross positions in commodity derivatives for this
purpose, banks should use the current spot price.
5.
Treatment of options
718(Lvi). In recognition of the
wide diversity of banks’ activities in options and the
difficulties of measuring price risk for options,
several alternative approaches will be permissible at
the discretion of the national authority:
• Those
banks which solely use purchased options * will be free
to use the simplifiedapproach described in paragraph
718(Lviii) below;
• Those banks which also write
options will be expected to use one of
the intermediate approaches as set out in paragraphs
718(Lix) to 718(Lxix) or a comprehensive risk
management model under the terms of paragraphs 718(Lxx)
to 718(xcix) of this Framework.
The more significant
its trading, the more the bank will be expected to
use a sophisticated approach.
*
Unless all their written option positions are hedged by
perfectly matched long positions in exactly the same
options, in which case no capital charge for market risk
is required.
718(Lvii). In the
simplified approach, the positions for the options and
the associated underlying, cash or forward, are not
subject to the standardised methodology but rather
are “carved-out” and subject to separately calculated
capital charges that incorporate both general market
risk and specific risk.
The risk numbers thus generated
are then added to the capital charges for the
relevant category, i.e. interest rate related
instruments, equities, foreign exchange and
commodities as described in paragraphs 709 to 718(Lv).
The deltaplus method uses the sensitivity parameters
or “Greek letters” associated with options to measure
their market risk and capital requirements.
Under this
method, the delta-equivalent position of each option
becomes part of the standardised methodology set out in
paragraphs 709 to 718(Lv) with the delta-equivalent
amount subject to the applicable general market
risk charges.
Separate capital charges
are then applied to the gamma and vega risks of
the option positions.
The scenario approach uses
simulation techniques to calculate changes in the
value of an options portfolio for changes in the level
and volatility of its associated underlyings.
Under
this approach, the general market risk charge is
determined by the scenario “grid” (i.e. the specified
combination of underlying and volatility changes)
that produces the largest loss. For the delta-plus
method and the scenario approach the specific risk
capital charges are determined separately by multiplying
the delta-equivalent of each option by the specific
risk weights set out in paragraphs 709 to
718(xxix).
(i) Simplified approach
718(Lviii).
Banks which handle a limited range of purchased options
only will be free to use the simplified approach set
out in the table below for particular trades.
As an
example of how the calculation would work, if a
holder of 100 shares currently valued at $10 each holds
an equivalent put option with a strike price of $11,
the capital charge would be: $1,000 x 16% (i.e. 8%
specific plus 8% general market risk) = $160, less the
amount the option is in the money ($11 - $10) x 100 =
$100, i.e. the capital charge would be $60.
A similar
methodology applies for options whose underlying is a
foreign currency, an interest rate related
instrument or a commodity.

148 In some cases such as
foreign exchange, it may be unclear which side is the
“underlying security”; this should be taken to be the
asset which would be received if the option were
exercised. In addition the nominal value should be
used for items where the market value of the underlying
instrument could be zero, e.g. caps and floors,
swaptions etc.
149 Some options (e.g. where the
underlying is an interest rate, a currency or a
commodity) bear no specific risk but specific risk
will be present in the case of options on certain
interest rate related instruments (e.g. options on a
corporate debt security or corporate bond index; see
paragraphs 709 to 718(xviii) for the relevant
capital charges) and for options on equities and
stock indices (see paragraphs 718(xix) to 718(xxix)).
The charge under this measure for currency options
will be 8% and for options on commodities 15%.
150
For options with a residual maturity of more than six
months the strike price should be compared with
the forward, not current, price. A bank unable to do
this must take the in the money amount to be
zero.
151 Where the position does not fall within the
trading book (i.e. options on certain foreign exchange
or commodities positions not belonging to the trading
book), it may be acceptable to use the book value
instead.
(ii) Intermediate
approaches
Delta-plus method
718(Lix). Banks which
write options will be allowed to include delta-weighted
options positions within the standardised methodology
set out in paragraphs 709 to 718(Lv).
Such
options should be reported as a position equal to the
market value of the underlying multiplied by
the delta.
However, since delta does not sufficiently
cover the risks associated with options positions,
banks will also be required to measure gamma (which
measures the rate of change of delta) and vega (which
measures the sensitivity of the value of an option
with respect to a change in volatility) sensitivities
in order to calculate the total capital charge.
These
sensitivities will be calculated according to an
approved exchange model or to the bank’s proprietary
options pricing model subject to oversight by the
national authority. *
*National
authorities may wish to require banks doing business in
certain classes of exotic options (e.g. barriers,
digitals) or in options at the money that are close to
expiry to use either the scenario approach or the
internal models alternative, both of which can
accommodate more detailed revaluation approaches.
718(Lx). Delta-weighted
positions with debt securities or interest rates as the
underlying will be slotted into the interest rate
time-bands, as set out in paragraphs 709 to 718(xviii),
under the following procedure.
A two-legged approach
should be used as for other derivatives, requiring
one entry at the time the underlying contract takes
effect and a second at the time the underlying
contract matures.
For instance, a bought call option on
a June three-month interest-rate future will in April
be considered, on the basis of its delta-equivalent
value, to be a long position with a maturity of five
months and a short position with a maturity of
two months. *
The written option will be similarly
slotted as a long position with a maturity of
two months and a short position with a maturity of
five months.
Floating rate instruments with caps or
floors will be treated as a combination of floating rate
securities and a series of European-style options.
For example, the holder of a three-year floating rate
bond indexed to six month LIBOR with a cap of 15%
will treat it as:
(i) A debt security that reprices
in six months; and
(ii) A series of five written call
options on a FRA with a reference rate of 15%,
each with a negative sign at the time the underlying
FRA takes effect and a positive sign at the time the
underlying FRA matures.**
*
A
two months call option on a bond future where delivery
of the bond takes place in September would be considered
in April as being long the bond and short a five months
deposit, both positions being deltaweighted.
**
The rules applying to closely matched positions set out
in paragraph 718(xiv) will also apply in this respect.
718(Lxi). The capital
charge for options with equities as the underlying will
also be based on the delta-weighted positions which
will be incorporated in the measure of market
risk described in paragraphs 718(xix) to 718(xxix).
For purposes of this calculation each national market
is to be treated as a separate underlying.
The capital
charge for options on foreign exchange and gold
positions will be based on the method set out in
paragraphs 718(xxx) to 718(xLii).
For delta risk, the
net delta-based equivalent of the foreign currency and
gold options will be incorporated into the
measurement of the exposure for the
respective currency (or gold) position.
The capital
charge for options on commodities will be based
on the simplified or the maturity ladder approach set
out in paragraphs 718(xLiii) to 718(Lv).
The delta-weighted positions will be incorporated in
one of the measures described in that section.
718(Lxii). In
addition to the above capital charges arising from delta
risk, there will be further capital charges for gamma
and for vega risk. Banks using the delta-plus method
will be required to calculate the gamma and vega for
each option position (including hedge positions)
separately. The capital charges should be calculated in
the following way:
(i) for each individual option a
“gamma impact” should be calculated according to
a Taylor series expansion as:
Gamma impact = ½ x
Gamma x VU²
where VU = Variation of the underlying of
the option.
(ii) VU will be calculated as
follows:
• For interest rate options if the
underlying is a bond, the market value of
the underlying should be multiplied by the risk
weights set out in paragraph
718(iv). An equivalent
calculation should be carried out where
the underlying is an interest rate, again based on
the assumed changes in the corresponding yield in
paragraph 718(iv);
• For options on equities and
equity indices: the market value of the underlying
should be multiplied by 8%;
[The
basic rules set out here for interest rate and equity
options do not attempt to capture specific risk when
calculating gamma capital charges. However, national
authorities may wish to require specific banks to do
so.]
• For foreign exchange
and gold options: the market value of the
underlying should be multiplied by 8%;
• For
options on commodities: the market value of the
underlying should be multiplied by 15%.
(iii) For
the purpose of this calculation the following positions
should be treated as the same underlying:
• for
interest rates, [Positions
have to be slotted into separate maturity ladders by
currency]
each time-band as set out in
paragraph
718(iv);[Banks using the duration method
should use the time-bands as set out in paragraph
718(vii).]
• for equities and stock
indices, each national market;
• for foreign
currencies and gold, each currency pair and gold;
•
for commodities, each individual commodity as defined
in paragraph 718(xLvii).
(iv) Each option on the
same underlying will have a gamma impact that is either
positive or negative.
These individual gamma impacts
will be summed, resulting in a net gamma impact for
each underlying that is either positive or negative.
Only those net gamma impacts that are negative will
be included in the capital calculation.
(v) The total
gamma capital charge will be the sum of the absolute
value of the net negative gamma impacts as calculated
above.
(vi) For volatility risk, banks will be
required to calculate the capital charges
by multiplying the sum of the vegas for all options
on the same underlying, as defined above, by a
proportional shift in volatility of ± 25%.
(vii) The
total capital charge for vega risk will be the sum of
the absolute value of the individual capital charges
that have been calculated for vega risk.
Scenario
approach
718(Lxiii). More sophisticated banks will
also have the right to base the market risk
capital charge for options portfolios and associated
hedging positions on scenario matrix analysis.
This
will be accomplished by specifying a fixed range of
changes in the option portfolio’s risk factors and
calculating changes in the value of the option portfolio
at various points along this “grid”.
For the purpose
of calculating the capital charge, the bank will revalue
the option portfolio using matrices for simultaneous
changes in the option’s underlying rate or price
and in the volatility of that rate or price.
A
different matrix will be set up for each
individual underlying as defined in paragraph
718(Lxii) above.
As an alternative, at the discretion
of each national authority, banks which are
significant traders in options will for interest
rate options be permitted to base the calculation on
a minimum of six sets of time-bands.
When using this
method, not more than three of the time-bands as defined
in paragraphs 718(iv) and 718(vii) should be combined
into any one set.
718(Lxiv). The options and related
hedging positions will be evaluated over a specified
range above and below the current value of the
underlying.
The range for interest rates
is consistent with the assumed changes in yield in
paragraph 718(iv).
Those banks using the alternative
method for interest rate options set out in paragraph
718(Lxiii) above should use, for each set of
time-bands, the highest of the assumed changes in yield
applicable to the group to which the time-bands
belong. *
The other ranges are ± 8% for equities155, ±
8% for foreign exchange and gold, and ± 15% for
commodities.
For all risk categories, at least seven
observations (including the current observation) should
be used to divide the range into equally spaced
intervals.
*
If, for example, the time-bands 3 to 4 years, 4 to 5
years and 5 to 7 years are combined the highest assumed
change in yield of these three bands would be 0.75.
718(Lxv). The second dimension of the
matrix entails a change in the volatility of
the underlying rate or price.
A single change in the
volatility of the underlying rate or price equal to a
shift in volatility of + 25% and - 25% is expected to be
sufficient in most cases.
As circumstances warrant,
however, the supervisory authority may choose to require
that a different change in volatility be used and/or
that intermediate points on the grid be
calculated.
718(Lxvi). After calculating the matrix
each cell contains the net profit or loss of the
option and the underlying hedge instrument. The
capital charge for each underlying will then
be calculated as the largest loss contained in the
matrix.
718(Lxvii). The application of the scenario
analysis by any specific bank will be subject
to supervisory consent, particularly as regards the
precise way that the analysis is constructed.
Banks’
use of scenario analysis as part of the standardised
methodology will also be subject to validation by the
national authority, and to those of the qualitative
standards listed in paragraphs 718(Lxxiv) and
718(Lxxv) which are appropriate given the nature of the
business.
718(Lxviii). In drawing up
these intermediate approaches the Committee has sought
to cover the major risks associated with options. In
doing so, it is conscious that so far as specific
risk is concerned, only the delta-related elements
are captured; to capture other risks
would necessitate a much more complex regime.
On the
other hand, in other areas the
simplifying assumptions used have resulted in a
relatively conservative treatment of certain
options positions.
For these reasons, the Committee
intends to keep this area under close
review.
718(Lxix). Besides the options risks
mentioned above, the Committee is conscious of
the other risks also associated with options, e.g.
rho (rate of change of the value of the option with
respect to the interest rate) and theta (rate of change
of the value of the option with respect to time).
While not proposing a measurement system for those risks
at present, it expects banks undertaking significant
options business at the very least to monitor such
risks closely.
Additionally, banks will be permitted
to incorporate rho into their capital
calculations for interest rate risk, if they wish to
do so.
D. Market Risk – The Internal Models
Approach
1. General criteria
718(Lxx). The use of
an internal model will be conditional upon the explicit
approval of the bank’s supervisory authority. Home
and host country supervisory authorities of banks
that carry out material trading activities in
multiple jurisdictions intend to work co-operatively
to ensure an efficient approval
process.
718(Lxxi). The supervisory authority will
only give its approval if at a minimum:
• It is
satisfied that the bank’s risk management system is
conceptually sound and is implemented with
integrity;
• The bank has in the supervisory
authority’s view sufficient numbers of staff skilled
in the use of sophisticated models not only in the
trading area but also in the risk control, audit, and
if necessary, back office areas;
• The bank’s models
have in the supervisory authority’s judgement a proven
track record of reasonable accuracy in measuring
risk;
• The bank regularly conducts stress tests
along the lines discussed in paragraphs 718(Lxxvii)
to 718(Lxxxiv) below.
718(Lxxii). Supervisory
authorities will have the right to insist on a period of
initial monitoring and live testing of a bank’s
internal model before it is used for supervisory capital
purposes.
718(Lxxiii). In addition to these general
criteria, banks using internal models for
capital purposes will be subject to the requirements
detailed in paragraphs 718(Lxxiv) to 718(xcix).
2.
Qualitative standards
718(Lxxiv). It is important
that supervisory authorities are able to assure
themselves that banks using models have market risk
management systems that are conceptually sound
and implemented with integrity. Accordingly, the
supervisory authority will specify a number
of qualitative criteria that banks would have to meet
before they are permitted to use a
models based approach.
The extent to which banks meet
the qualitative criteria may influence the level at
which supervisory authorities will set the
multiplication factor referred to in
paragraph 718(Lxxvi) (j) below. Only those banks
whose models are in full compliance with
the qualitative criteria will be eligible for
application of the minimum multiplication factor.
The qualitative criteria include:
(a) The bank
should have an independent risk control unit that is
responsible for the design and implementation of the
bank’s risk management system.
The unit
should produce and analyse daily reports on the
output of the bank’s risk measurement model,
including an evaluation of the relationship between
measures of risk exposure and trading limits.
This
unit must be independent from business trading units
and should report directly to senior management of the
bank.
(b) The unit should conduct a regular
back-testing programme, i.e. an ex-post comparison of
the risk measure generated by the model against actual
daily changes in portfolio value over longer periods
of time, as well as hypothetical changes based on
static positions.
(c) The unit should also conduct
the initial and on-going validation of the
internal model. [Further guidance regarding the
standards that supervisory authorities will expect can
be found in paragraph 718(xcix).]
(d) Board of directors and
senior management should be actively involved in the
risk control process and must regard risk control as
an essential aspect of the business to which
significant resources need to be devoted. [The report, Risk management
guidelines for derivatives, issued by the Basel
Committee in July 1994 further discusses the
responsibilities of the board of directors and senior
management.]
In this
regard, the daily reports prepared by the independent
risk control unit must be reviewed by a level
of management with sufficient seniority and authority
to enforce both reductions of positions taken by
individual traders and reductions in the bank’s overall
risk exposure.
(e) The bank’s internal risk
measurement model must be closely integrated into the
day to day risk management process of the bank. Its
output should accordingly be an integral part of the
process of planning, monitoring and controlling the
bank’s market risk profile.
(f) The risk
measurement system should be used in conjunction with
internal trading and exposure limits.
In this regard,
trading limits should be related to the bank’s
risk measurement model in a manner that is consistent
over time and that is well understood by both traders
and senior management.
(g) A routine and rigorous
programme of stress testing [Though banks will have some
discretion as to how they conduct stress tests, their
supervisory authorities will wish to see that they
follow the general lines set out in paragraphs
718(Lxxvii) to 718(Lxxxiiii)] should be in place as
a supplement to the risk analysis based on the
day-to-day output of the bank’s risk measurement
model.
The results of stress testing should be reviewed
periodically by senior management, used in the
internal assessment of capital adequacy,
and reflected in the policies and limits set by
management and the board of directors.
Where stress
tests reveal particular vulnerability to a given set of
circumstances, prompt steps should be taken to manage
those risks appropriately (e.g. by hedging against
that outcome or reducing the size of the bank’s
exposures, or increasing capital).
(h) Banks should
have a routine in place for ensuring compliance with a
documented set of internal policies, controls and
procedures concerning the operation of the
risk measurement system.
The bank’s risk measurement
system must be well documented, for example, through
a risk management manual that describes the basic
principles of the risk management system and that
provides an explanation of the empirical techniques
used to measure market risk.
(i) An independent
review of the risk measurement system should be carried
out regularly in the bank’s own internal auditing
process.
This review should include both the
activities of the business trading units and of the
independent risk control unit. A review of the
overall risk management process should take place at
regular intervals (ideally not less than once a year)
and should specifically address, at a minimum:
•
The adequacy of the documentation of the risk management
system and process;
• The organisation of the risk
control unit;
• The integration of market risk
measures into daily risk management;
• The approval
process for risk pricing models and valuation systems
used by front and back-office personnel;
• The
validation of any significant change in the risk
measurement process;
• The scope of market risks
captured by the risk measurement model;
• The
integrity of the management information system;
• The
accuracy and completeness of position data;
• The
verification of the consistency, timeliness and
reliability of data sources used to run internal
models, including the independence of such
data sources;
• The accuracy and appropriateness
of volatility and correlation assumptions;
• The
accuracy of valuation and risk transformation
calculations;
• The verification of the model’s
accuracy through frequent back-testing as described
in 718(Lxxiv) (b) above and in the accompanying
document:
Supervisory framework for the use of
backtesting in conjunction with the internal models
approach to market risk capital requirements.
3.
Specification of market risk factors
718(Lxxv). An
important part of a bank’s internal market risk
measurement system is the specification of an
appropriate set of market risk factors, i.e. the market
rates and prices that affect the value of the bank’s
trading positions.
The risk factors contained in a
market risk measurement system should be sufficient
to capture the risks inherent in the bank’s
portfolio of on- and off-balance sheet trading
positions.
Although banks will have some discretion
in specifying the risk factors for their internal
models, the following guidelines should be
fulfilled.
(a) For interest rates, there must
be a set of risk factors corresponding to interest
rates in each currency in which the bank has
interest-rate-sensitive on- or off balance sheet
positions.
• The risk measurement system should model
the yield curve using one of a number of generally
accepted approaches, for example, by
estimating forward rates of zero coupon yields.
The
yield curve should be divided into various maturity
segments in order to capture variation in the volatility
of rates along the yield curve; there will typically
be one risk factor corresponding to each maturity
segment.
For material exposures to interest rate
movements in the major currencies and markets, banks
must model the yield curve using a minimum of six
risk factors.
However, the number of risk factors
used should ultimately be driven by the nature of the
bank’s trading strategies.
For instance, a bank with
a portfolio of various types of securities across
many points of the yield curve and that engages
in complex arbitrage strategies would require a
greater number of risk factors to capture interest
rate risk accurately.
• The risk measurement system
must incorporate separate risk factors to capture
spread risk (e.g. between bonds and swaps).
A variety
of approaches may be used to capture the spread risk
arising from less than perfectly correlated movements
between government and other fixed income interest
rates, such as specifying a completely separate yield
curve for non-government fixed-income instruments
(for instance, swaps or municipal securities) or
estimating the spread over government rates
at various points along the yield curve.
(b) For
exchange rates (which may include gold), the risk
measurement system should incorporate risk factors
corresponding to the individual foreign currencies in
which the bank’s positions are denominated. Since the
value-at-risk figure calculated by the risk
measurement system will be expressed in the bank’s
domestic currency, any net position denominated in a
foreign currency will introduce a foreign
exchange risk.
Thus, there must be risk factors
corresponding to the exchange rate between the
domestic currency and each foreign currency in which the
bank has a significant exposure.
(c) For equity
prices, there should be risk factors corresponding to
each of the equitymarkets in which the bank holds
significant positions:
• At a minimum, there should
be a risk factor that is designed to
capture market-wide movements in equity prices (e.g.
a market index).
Positions in individual securities
or in sector indices could be expressed in
“betaequivalents”* relative to this market-wide index;
* A “beta-equivalent” position would
be calculated from a market model of equity price
returns (such as the CAPM model) by regressing the
return on the individual stock or sector index on the
risk-free rate of return and the return on the market
index.
• A somewhat more detailed approach would be
to have risk factors corresponding to various sectors
of the overall equity market (for instance, industry
sectors or cyclical and non-cyclical sectors).
As above,
positions in individual stocks within each sector
could be expressed in betaequivalents49 relative to
the sector index;
• The most extensive approach would
be to have risk factors corresponding e
volatility of individual equity issues.
• The
sophistication and nature of the modelling technique for
a given market should correspond to the bank’s
exposure to the overall market as well as its
concentration in individual equity issues in that
market.
(d) For commodity prices, there should be
risk factors corresponding to each of the commodity
markets in which the bank holds significant positions
(also see paragraph 718(xLvii) above):
• For banks
with relatively limited positions in commodity-based
instruments, a straightforward specification of risk
factors would be acceptable.
Such a specification
would likely entail one risk factor for each commodity
price to which the bank is exposed.
In cases where
the aggregate positions are quite small, it might be
acceptable to use a single risk factor for a
relatively broad sub-category of commodities (for
instance, a single risk factor for all types of
oil);
• For more active trading, the model must also
take account of variation in the “convenience
yield”163 between derivatives positions such as
forwards and swaps and cash positions in the
commodity.
4. Quantitative standards
718(Lxxvi).
Banks will have flexibility in devising the precise
nature of their models, but the following minimum
standards will apply for the purpose of calculating
their capital charge.
Individual banks or their
supervisory authorities will have discretion to apply
stricter standards.
(a) “Value-at-risk” must be
computed on a daily basis.
(b) In calculating the
value-at-risk, a 99th percentile, one-tailed confidence
interval is to be used.
(c) In calculating
value-at-risk, an instantaneous price shock equivalent
to a 10 day movement in prices is to be used, i.e.
the minimum “holding period” will be ten trading
days.
Banks may use value-at-risk numbers calculated
according to shorter holding periods scaled up to ten
days by the square root of time (for the treatment
of options, also see 718(Lxxvi) (h) below).
(d) The choice of historical
observation period (sample period) for calculating value
at risk will be
constrained to a minimum length of one year.
For banks
that use a weighting scheme or other methods for the
historical observation period, the “effective” observation period must be
at least one year (that is, the weighted average time
lag of the individual observations cannot be less than 6
months).
(e) Banks should update their data sets no
less frequently than once every three months and
should also reassess them whenever market prices are
subject to material changes.
The supervisory
authority may also require a bank to calculate
its value-at-risk using a shorter observation period
if, in the supervisor’s judgement, this is justified
by a significant upsurge in price volatility.
(f) No
particular type of model is prescribed. So long as each
model used captures allthe material risks run by the
bank, as set out in paragraph 718(Lxxv), banks will
be free to use models based, for example, on
variance-covariance matrices, historical simulations,
or Monte Carlo simulations.
(g) Banks will have
discretion to recognise empirical correlations within
broad risk categories (e.g. interest rates, exchange
rates, equity prices and commodity prices, including
related options volatilities in each risk factor
category).
The supervisory authority may also
recognise empirical correlations across broad risk
factor categories, provided that the supervisory
authority is satisfied that the bank’s system for
measuring correlations is sound and implemented with
integrity.
(h) Banks’ models must accurately capture
the unique risks associated with options within each
of the broad risk categories.
The following criteria
apply to the measurement of options risk:
• Banks’
models must capture the non-linear price characteristics
of options positions;
• Banks are expected to
ultimately move towards the application of a full
10 day price shock to options positions or positions
that display option-like characteristics.
In the
interim, national authorities may require banks
to adjust their capital measure for options risk
through other methods, e.g. periodic simulations or
stress testing;
• Each bank’s risk measurement system
must have a set of risk factors that captures the
volatilities of the rates and prices underlying option
positions, i.e. vega risk.
Banks with relatively
large and/or complex options portfolios should have
detailed specifications of the relevant volatilities.
This means that banks should measure the volatilities
of options positions broken down by different
maturities.
(i) Each bank must meet, on a daily
basis, a capital requirement expressed as the higher
of
(i) its previous day’s value-at-risk number measured
according to the parameters specified in this section
and
(ii) an average of the daily
value-at-risk measures on each of the preceding sixty
business days, multiplied by a multiplication
factor.
(j) The multiplication factor will be set by
individual supervisory authorities on the basis of
their assessment of the quality of the bank’s risk
management system, subject to an absolute minimum of
3.
Banks will be required to add to this factor a
“plus” directly related to the ex-post performance of
the model, thereby introducing a built in positive
incentive to maintain the predictive quality of the
model.
The plus will range from 0 to 1 based on the
outcome of so-called “backtesting.”
If the backtesting results are satisfactory and the bank
meets all of the qualitative standards set out
in paragraph 718(Lxxiv) above, the plus factor could
be zero.
The Annex 10a of this Framework
presents in detail the approach to be applied for
backtesting and the plus factor. Supervisors will
have national discretion to require banks to
perform backtesting on either hypothetical (i.e.
using changes in portfolio value that would occur
were end-of-day positions to remain unchanged), or
actual trading (i.e. excluding fees, commissions, and
net interest income) outcomes, or both.
(k) Banks
using models will also be subject to a capital charge to
cover specific risk (as defined under the
standardised approach for market risk) of interest rate
related instruments and equity securities.
The manner
in which the specific risk capital charge is to be
calculated is set out in paragraphs 718(Lxxxvii) to
718(xcviii).
5. Stress testing
718(Lxxvii). Banks
that use the internal models approach for meeting market
risk capital requirements must have in place a
rigorous and comprehensive stress testing
program.
Stress testing to identify events or
influences that could greatly impact banks is a
key component of a bank’s assessment of its capital
position.
718(Lxxviii). Banks’ stress scenarios need
to cover a range of factors that can
create extraordinary losses or gains in trading
portfolios, or make the control of risk in
those portfolios very difficult.
These factors
include low-probability events in all major types of
risks, including the various components of market,
credit, and operational risks.
Stress scenarios need
to shed light on the impact of such events on positions
that display both linear and nonlinear price
characteristics (i.e. options and instruments that have
options-like characteristics).
718(Lxxix). Banks’
stress tests should be both of a quantitative and
qualitative nature, incorporating both market risk
and liquidity aspects of market disturbances.
Quantitative criteria should identify plausible
stress scenarios to which banks could be
exposed.
Qualitative criteria should emphasise that
two major goals of stress testing are to evaluate the
capacity of the bank’s capital to absorb potential large
losses and to identify steps the bank can take to
reduce its risk and conserve capital.
This assessment is
integral to setting and evaluating the bank’s
management strategy and the results of stress testing
should be routinely communicated to senior management
and, periodically, to the bank’s board
of directors.
718(Lxxx). Banks should combine the
use of supervisory stress scenarios with stress
tests developed by banks themselves to reflect their
specific risk characteristics.
Specifically, supervisory authorities may ask banks
to provide information on stress testing in three
broad areas, which are discussed in turn
below.
(i) Supervisory scenarios requiring no
simulations by the bank
718(Lxxxi). Banks should have
information on the largest losses experienced during
the reporting period available for supervisory
review.
This loss information could be compared
to the level of capital that results from a bank’s
internal measurement system.
For example, it could
provide supervisory authorities with a picture of how
many days of peak day losses would have been covered
by a given value-at-risk estimate.
(ii) Scenarios
requiring a simulation by the bank
718(Lxxxii). Banks
should subject their portfolios to a series of simulated
stress scenarios and provide supervisory authorities
with the results.
These scenarios could include
testing the current portfolio against past periods of
significant disturbance, for example, the 1987 equity
crash, the ERM crises of 1992 and 1993 or the fall in
bond markets in the first quarter of 1994,
incorporating both the large price movements and the
sharp reduction in liquidity associated with these
events.
A second type of scenario would evaluate the
sensitivity of the bank’s market risk exposure to
changes in the assumptions about volatilities
and correlations.
Applying this test would require an
evaluation of the historical range of variation for
volatilities and correlations and evaluation of the
bank’s current positions against the extreme values
of the historical range.
Due consideration should be
given to the sharp variation that at times has
occurred in a matter of days in periods of significant
market disturbance.
The 1987 equity crash, the
suspension of the ERM, or the fall in bond markets in
the first quarter of 1994, for example, all involved
correlations within risk factors approaching the
extreme values of 1 or -1 for several days at the height
of the disturbance.
(iii) Scenarios developed by the
bank itself to capture the specific characteristics of
its portfolio.
718(Lxxxiii). In addition to the
scenarios prescribed by supervisory authorities
under ragraphs 718(Lxxxi) and 718(Lxxxii) above, a
bank should also develop its own stress tests which
it identifies as most adverse based on the
characteristics of its portfolio (e.g. problems in a
key region of the world combined with a sharp move in
oil prices).
Banks should provide supervisory
authorities with a description of the methodology used
to identify and carry out the scenarios as well as
with a description of the results derived from these
scenarios.
718(Lxxxiv). The results should be
reviewed periodically by senior management and
should be reflected in the policies and limits set by
management and the board of directors.
Moreover, if
the testing reveals particular vulnerability to a given
set of circumstances, thenational authorities would
expect the bank to take prompt steps to manage those
risks appropriately (e.g. by hedging against that
outcome or reducing the size of its exposures).
6.
External validation
718(Lxxxv). The validation of
models’ accuracy by external auditors and/or
supervisory authorities should at a minimum include
the following steps:
(a) Verifying that the internal
validation processes described in paragraph 718(Lxxiv)
(i) are operating in a satisfactory manner;
(b)
Ensuring that the formulae used in the calculation
process as well as for the pricing of options and
other complex instruments are validated by a qualified
unit, which in all cases should be independent from
the trading area;
(c) Checking that the structure of
internal models is adequate with respect to the
bank’s activities and geographical coverage;
(d)
Checking the results of the banks’ back-testing of its
internal measurement system (i.e. comparing
value-at-risk estimates with actual profits and losses)
to ensure that the model provides a reliable measure
of potential losses over time.
This means that banks
should make the results as well as the underlying inputs
to their value-at-risk calculations available to
their supervisory authorities and/or external auditors
on request;
(e) Making sure that data flows and
processes associated with the risk measurement system
are transparent and accessible.
In particular, it is
necessary that auditors or supervisory authorities
are in a position to have easy access, whenever they
judge it necessary and under appropriate procedures,
to the models’ specifications
and parameters.
7. Combination of internal
models and the standardised methodology
718(Lxxxvi).
Unless a bank’s exposure to a particular risk factor,
such as commodity prices, is insignificant, the
internal models approach will in principle require banks
to have an integrated risk measurement system that
captures the broad risk factor categories
(i.e. interest rates, exchange rates (which may
include gold), equity prices and commodity
prices, with related options volatilities being
included in each risk factor category).
Thus,
banks which start to use models for one or more risk
factor categories will, over time, be expected to
extend the models to all their market risks.
A bank
which has developed one or moremodels will no longer
be able to revert to measuring the risk measured by
those models according to the standardised
methodology (unless the supervisory authority
withdraws approval for that model).
However, pending
further experience regarding the process of changing
to a models-based approach, no specific time limit will
be set for banks which use a combination of internal
models and the standardised methodology to move to
a comprehensive model.
The following conditions will
apply to banks using such combinations:
(a) Each
broad risk factor category must be assessed using a
single approach (either internal models or the
standardised approach), i.e. no combination of the
two methods will in principle be permitted within a
risk category or across banks’ different entities for
the same type of risk (but see paragraph 708(i)
above);164
(b) All the criteria laid down in
paragraphs 718(Lxx) to 718(xcix) of this Framework
will apply to the models being used;
(c) Banks may
not modify the combination of the two approaches they
use without justifying to their supervisory authority
that they have a good reason for doing so;
(d) No
element of market risk may escape measurement, i.e. the
exposure for all the various risk factors, whether
calculated according to the standardised approach
or internal models, would have to be captured;
(e)
The capital charges assessed under the standardised
approach and under the models approach are to be
aggregated according to the simple sum method.
8.
Treatment of specific risk
718(Lxxxvii). Where a bank
has a VaR measure that incorporates specific risk and
that meets all the qualitative and quantitative
requirements for general risk models, it may base
its charge on modelled estimates, provided the
measure is based on models that meet the additional
criteria and requirements set out below.
Banks which are
unable to meet these additional criteria and
requirements will be required to base their specific
risk capital charge on the full amount of the
specific risk charge calculated under the standardised
method.
718(Lxxxviii). The criteria for supervisory
recognition of banks’ modelling of specific
risk require that a bank’s model must capture all
material components of price risk and be responsive
to changes in market conditions and compositions of
portfolios.
In particular, the model must:
• explain the historical price
variation in the portfolio;* • capture
concentrations (magnitude and changes in
composition);** • be robust to an adverse
environment;*** • capture name-related basis
risk;**** • capture event risk;***** • be validated
through backtesting.*******
* The key ex ante measures of
model quality are “goodness-of-fit” measures which
address the question of how much of the historical
variation in price value is explained by the risk
factors included within the model. One measure of
this type which can often be used is an R-squared
measure from regression methodology.
If this measure
is to be used, the risk factors included in the bank’s
model would be expected to be able to explain a high
percentage, such as 90%, of the historical price
variation or the model should explicitly include
estimates of the residual variability not captured in
the factors included in this regression.
For some types
of models, it may not be feasible to calculate a
goodness-of-fit measure. In such instance, a bank is
expected to work with its national supervisor to
define an acceptable alternative measure which would
meet this regulatory objective.
** The bank would be
expected to demonstrate that the model is sensitive to
changes in portfolio construction and that higher
capital charges are attracted for portfolios that have
increasing concentrations in particular names or
sectors.
*** The bank should be able to demonstrate
that the model will signal rising risk in an adverse
environment. This could be achieved by incorporating
in the historical estimation period of the model at
least one full credit cycle and ensuring that the
model would not have been inaccurate in the downward
portion of the cycle. Another approach for
demonstrating this is through simulation of historical
or plausible worst-case environments.
**** Banks
should be able to demonstrate that the model is
sensitive to material idiosyncratic differences
between similar but not identical positions, for
example debt positions with different levels of
subordination, maturity mismatches, or credit
derivatives with different default events.
*****For
debt positions, this should include migration risk. For
equity positions, events that are reflected in
large changes or jumps in prices must be captured,
e.g. merger break-ups/takeovers. In particular, firms
must consider issues related to survivorship
bias.
******Aimed at assessing whether
specific risk, as well as general market risk, is being
captured adequately.
718(Lxxxix). Where a bank is
subject to event risk that is not reflected in its VaR
measure, because it is beyond the 10-day holding
period and 99 percent confidence interval (i.e.
low probability and high severity events), banks must
ensure that the impact of such events is factored in
to its internal capital assessment, for example through
its stress testing.
718(xc). The bank's model must
conservatively assess the risk arising from less
liquid positions and/or positions with limited price
transparency under realistic market scenarios.
In addition, the model must meet minimum data
standards.
Proxies may be used only where available
data is insufficient or is not reflective of the true
volatility of a position or portfolio, and only where
they are appropriately conservative.
718(Xci).
Further, as techniques and best practices evolve, banks
should avail themselves of these
advances.
718(XCii). In addition, the bank must have
an approach in place to capture in its
regulatory capital default risk of its trading book
positions that is incremental to the risk captured by
the VaR-based calculation as specified in paragraph
718(Lxxxviii) above.
To avoid double counting a bank
may, when calculating its incremental default charge,
take into account the extent to which default risk has
already been incorporated into the VaR
calculation, especially for risk positions that could
and would be closed within 10 days in the event
of adverse market conditions or other indications of
deterioration in the credit environment.
No specific
approach for capturing the incremental default risk is
prescribed; it may be part of the bank's internal
model or a surcharge from a separate calculation.
Where
a bank captures its incremental risk through a
surcharge, the surcharge will not be subject to a
multiplier or regulatory backtesting, although the
bank should be able to demonstrate that the
surcharge meets its aim.
718(XCiii). Whichever
approach is used, the bank must demonstrate that it
meets a soundness standard comparable to that of the
internal-ratings based approach for credit risk as
set forth in this Framework, under the assumption of a
constant level of risk, and adjusted where
appropriate to reflect the impact of liquidity,
concentrations, hedging, and optionality.
A bank that
does not capture the incremental default risk through an
internally developed approach must use the fallback
of calculating the surcharge through an approach
consistent with that for credit risk as set forth in
this Framework.
718(XCiv). Whichever approach is
used, cash or synthetic exposures that would be subject
to a deduction treatment under the securitisation
framework set forth in this Framework (e.g. equity
tranches that absorb first losses),171 as well as
securitisation exposures that are unrated liquidity
lines or letters of credit, would be subject to a
capital charge that is no less than that set forth in
the securitisation framework.
718(XCv). An exception
to this treatment could be afforded to banks that are
dealers in the above exposures where they can
demonstrate, in addition to trading intent, that a
liquid two way market exists for the securitisation
exposures or, in the case of synthetic
securitisations that rely solely on credit
derivatives, for the securitisation exposures themselves
or all their constituent risk components.
For
purposes of this section, a two-way market is deemed
to exist where there are independent bona fide offers
to buy and sell so that a price reasonably related to
the last sales price or current bona fide competitive
bid and offer quotations can be determined within one
day and settled at such price within a relatively short
time conforming to trade custom.
In addition, for a
bank to apply this exception, it must have sufficient
market data to ensure that it fully captures the
concentrated default risk of these exposures in
its internal approach for measuring the incremental
default risk in accordance with the standards set
forth above.
718(XCvi). Banks that already have
received specific risk model recognition for
particular portfolios or lines of business should
agree a timetable with their supervisors to bring
their model in line with the new standards in a
timely manner as is practicable.
718(XCvii). Banks
which apply modelled estimates of specific risk are
required to conduct backtesting aimed at assessing
whether specific risk is being accurately captured.
The methodology a bank should use for validating its
specific risk estimates is to perform separate
backtests on sub-portfolios using daily data on
sub-portfolios subject to specific risk.
The key
sub-portfolios for this purpose are traded-debt and
equity positions.
However, if a bank itself
decomposes its trading portfolio into finer categories
(e.g. emerging markets, traded corporate debt, etc.),
it is appropriate to keep these distinctions for
sub-portfolio backtesting purposes. Banks are
required to commit to a sub-portfolio structure and
stick to it unless it can be demonstrated to
the supervisor that it would make sense to change
the structure.
718(XCviii). Banks are required to
have in place a process to analyse exceptions
identified through the backtesting of specific risk.
This process is intended to serve as the
fundamental way in which banks correct their models
of specific risk in the event they become
inaccurate.
There will be a presumption that models
that incorporate specific risk are “unacceptable”
if the results at the sub-portfolio level produce a
number of exceptions commensurate with the Red Zone
as defined in Annex 10a of this Framework.
Banks with
“unacceptable” specific risk models are expected to
take immediate action to correct the problem in the
model and to ensure that there is a sufficient
capital buffer to absorb the risk that the backtest
showed had not been adequately captured.
9. Model
validation standards
718(XCix). It is important that
banks have processes in place to ensure that their
internal models have been adequately validated by
suitably qualified parties independent of
the development process to ensure that they are
conceptually sound and adequately capture
all material risks.
This validation should be
conducted when the model is initially developed
and when any significant changes are made to the
model.
The validation should also be conducted on a
periodic basis but especially where there have been any
significant structural changes in the market or
changes to the composition of the portfolio which might
lead to the model no longer being adequate.
More
extensive model validation is particularly
important where specific risk is also modelled and is
required to meet the further specific risk
criteria.
As techniques and best practices evolve,
banks should avail themselves of these
advances.
Model validation should not be limited to
backtesting, but should, at a minimum, also
include the following:
(a) Tests to demonstrate
that any assumptions made within the internal model
are appropriate and do not underestimate risk.
This
may include the assumption of the normal
distribution, the use of the square root of time to
scale from a one day holding period to a 10 day
holding period or where extrapolation or
interpolation techniques are used, or pricing
models;
(b) Further to the regulatory backtesting
programmes, testing for model validation should be
carried out using additional tests, which may include,
for instance:
• Testing carried out using
hypothetical changes in portfolio value that
would occur were end-of-day positions to remain
unchanged.
It therefore excludes fees, commissions,
bid-ask spreads, net interest income and
intra-day trading;
• Testing carried out for
longer periods than required for the
regular backtesting programme (e.g. 3 years).
The
longer time period generally improves the power of
the back testing.
A longer time period may not
be desirable if the VaR model or market conditions
have changed to the extent that historical data is no
longer relevant;
• Testing carried out using
confidence intervals other than the 99
percent interval required under the quantitative
standards;
• Testing of portfolios below the overall
bank level;
(c) The use of hypothetical portfolios to
ensure that the model is able to account
for particular structural features that may arise,
for example:
• Where data histories for a
particular instrument do not meet the
quantitative standards in paragraph 718(Lxxvi) and
where the bank has to map these positions to proxies,
then the bank must ensure that the proxies
produce conservative results under relevant market
scenarios;
• Ensuring that material basis risks are
adequately captured.
This may include mismatches
between long and short positions by maturity or
by issuer;
• Ensuring that the model captures
concentration risk that may arise in an undiversified
portfolio.
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