fundamental review of trading book: new rules for market risk
TRANSCRIPT
Fundamental Review of Trading Book: new rules for Market Risk
Arturo Labanda
Risk Unit Director. Market Risk Models
Methodology and Models Construction
Banco Santader
Global Association of Risk Professionals
June, 2016
2
The views expressed in the following material are the
author’s and do not necessarily represent the views of
the Global Association of Risk Professionals (GARP),
its Membership or its Management.
2 | © 2012 Global Association of Risk Professionals. All rights reserved.
Why a fundamental revision?. Timeline
• Recent financial crisis showed debilities in Regulatory Capital
calculation for Market Risk
Financial crisis 2007
BIS 2.5 (julio-09)
First consultive
doc. FRTB
(may-12)
Second consultive
doc. FRTB
(oct-13)
QIS impact
(sep-14)
Third consultive
doc. FRTB
(dic-14)
Final doc. FRTB
(ene-16)
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Why a fundamental revision?
• Deficiencies in BIS II para Market Risk
• Insufficicency of Capital for absorve losses
• Models fails: tail risk, basis risk,…2007
• SVaR calculation
• Incremental Risk Charge (IRC): rating migration and default
• Correlation trading portfolio (CRM)BIS 2.5
• Models and standard aproximations
• Fundamental review of market risk standards. BIS 2.5 is not enought
consultive
period
• Reform plan and details for BIS 2.5
• Standard Model Approach (SA)
• Internal Model Approach (IMA)FRTB
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Why a fundamental revision?
• Review of boundary between banking book and trading book
• Inadequate capital for credit products (ie. bonds) in the crisis period
• Insufficiency of capital during the stress period. Problems of VaR in tail risk
scenarios
• No liquidity factors in the model
• Standard model fails in complex derivatives
• High dependency of internal models for calculate regulatory capital:
internal models of banks give their own view of risk
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Milestones: probably increase of capital requirements
• Review of boundary between banking book and trading book
• Review of trading desk structure and eligibility: PL test for IMA approval
needs a minimal differential between Front office models and Risk models:
models and risk factors
• Definition of Trading Desk with quantitative criteria
• Risk Theoretical PL vs Hypothetical PL:
• Risk PL: engines and risk factors from risk data base
• Hypothetical PL: engines and risk factors from FO data base
• Backtesting
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Milestones: probably increase of capital requirements
• Capital consumption for Standard Approach (SA):
• Capital at Trading Desk Level
• Input: sensitivities
• RWA, correlations, scenarios, etc., given by regulators
• New Metrics:
• Curvature
• Jump to Default for EQ
• Sticky delta approach
• IMA has a floor at SA. To be determined by BIS
• > 90%: no incentives for IMA. No R+D
• 50%-80%: incentives for IMA
• < 50%: low probability of success. Very difficult for calculate for all TDs
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Milestones: probably increase of capital requirements
• Impact in capital requirements for Internal Model Approach (IMA)
• Non-Modellable Risk Factors (NMRF). What is a “real price”?
• It is a price at which the institution has conducted a transaction
• It is a verifiable price for an actual transaction between other arms-length parties
• The price is obtained from a committed quote
• The price is obtained from a third-party vendor, where: (i) the transaction has
been processed through the vendor; (ii) the vendor agrees to provide evidence of
the transaction to supervisors upon request; and (iii) the price meets the three
criteria immediately listed above, then it is considered to be real for the purposes
of the modellable classification.
• Risk factor must have at least 24 observable “real” prices per year with a
maximum period of one month between two consecutive observations.
• Use of proxies
• Impacts driven by Expected Shortfall calculations
• Impacts driven by Default Risk Charge calculations (DRC)
• Impacts driven by Stressed capital add-on for NMRF (SES)
8 | © 2012 Global Association of Risk Professionals. All rights reserved.
Milestones: methodology and models
• Enhance of actuals models for ES, DRC,... Or development of new
models?
• Alignment of FO models and Risk Models?
• Expected Shortfall calculation: no formula provided by BIS
• High number of calculations: optimization process
• New IRC Default Risk Charge
• EQ and Credit deals
• “Only” default (migration is excluded)
• DRC internal approach: 2 factors model
• Look through approach for index and baskets: intensive in calculations
9 | © 2012 Global Association of Risk Professionals. All rights reserved.
Milestones: methodology and models
• Non-modelable risk factors definitions: in-house development or third party
vendors?
• Risk Theoretical PL vs Hypothetical PL
• Risk Theo. PL: PL calculated only with risk models and risk factors
included in the risk models.
• Risk Hyp. PL: PL based on MtM with all risk factors
• Align risk and front models?
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Milestones: methodology and models
• Risk Theoretical PL vs Hypothetical PL (cont.)
• PL attribution test: use to determinate IMA model for the TDs
Risk Theoretical PL
PL diario producido por los modelos de valoración,
usando sólo los RF utilizados en el modelo de riesgos
Hypothetical PL
PL producido por los modelos de valoración, usando
todos los RF utilizados en el modelo de riesgos
Unexplained PL
Diferencia entre Theoretical e Hypothetical PL
Metrics
Mean Ratio:
Mean Unexplained PL
Standard Desviation (Hypo. PL)
Variance Ratio
Variance Unexplained PL
Variance (Hypo. PL)
Test
11 | © 2012 Global Association of Risk Professionals. All rights reserved.
Milestones: methodology and models
• PL attribution test: use to determinate IMA model for the TDs
Mean Ratio:
Mean Unexplained PL
Standard Desviation (Hypo. PL)
Variance Ratio
Variance Unexplained PL
Variance (Hypo. PL)
Test
Ratio > +/-10%
Ratio > 20%
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Milestones: IT architecture and infrastructure
• To be development: Expected Shortfall, DRC, SES, capital agregation,…
• Data base for PL attribution
• Calculator for SA
• Market data information:
• Risk weights, capitalization for EQ, modelable/non-modelable risk
factors,..
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Standard Approach in a glance
General Interest Rate Risk (GIRR)
Credit Spread Risk
Credit Spread Risk non Secur (CSR)
Securitizaciones (CSR Sec)
Correlation Trading Portfolio (CSR CTP)
Foreing Exchange Risk (FX)
Equity Risk (EQ)
Commodity Risk (CM)
Default Risk
Default Risk non Secur (CSR)
Securitizaciones (CSR Sec)
Correlation Trading Portfolio (CSR CTP)
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Standard Approach in a glance
SA = Sensitivities
(Delta + Vega +Curvatura)
GIRR + CSR + EQ + FX + CM
DRC
Residual Risk
Add on
1% o 0.1% of
the notional
+
Debt & EQ
+
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Internal Model Approach in a glance
TD por IMA TD por SA
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Internal Model Approach in a glance
3 “times”
Max number of “runs”: 3 x 21 = 63!!!
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Default Risk Charge (DRC)
Risk “objetc”
Default and migration
Products in scope
Credit no-securitizations
Incremental Risk Charge (IRC) Default Risk Charge (DRC)
Model
1y @ 99.9%
Risk “object”
Default
Products in scope
Credit no-securitizations and equities
Model
1y @ 99.9%
Liquidity Horizon
Floor @ 3M
Liquidity Horizon
Floor @ 3M for EQ and 1y for Credit
Others
Historical correlations in a 10y time window and
with a stress period. PD floor @ 3pb
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BIS 2.5 vs FRTB
C r e a t i n g a c u l t u r e o f r i s k a w a r e n e s s ®
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