Modelling Incremental Risk Charge. Capital Allocation and Management London 13-Sep-2010
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1 Capital Allocation and Management London 13-Sep-2010
2 Content Regulatory requirements and definitions Modelling approach Implementation 2
3 Evolution of Regulatory Decrees for the Trading Book Application of Basel II to Trading Activities and Treatment of Double Default Effects Changes in June 2010 (postponed to 2012) Proposed Principles for Modelling Incremental Default Risk in the Trading Book 2005 Amendment to the Capital Accord to incorporate market risks (Update) July 2009 Revisions to the Basel II market risk framework 2007 Guidelines for Computing Capital for Incremental Default Risk in the Trading Book 2006 Basel II Framework - Comprehensive Version July 2009 Enhancements to the Basel II framework July 2009 Guidelines for Computing Capital for Incremental Risk in the Trading Book 2006 EU: Capital Requirements Directive (CRD) October 2009 EU: Proposed Amendments to Capital Big News July 2009 Requirements Directive 3
4 Incremental and Comprehensive Risk Charge Internal Market Risk Models Value-at-Risk, 10 day risk horizon, fiscal year parameterization, 99% confidence level, factor 3+x+y Stressed Value-at-Risk, as above, but parameterized by stress period (e. g. 2007/08), factor 3+z General Market Risk Specific Market Risk EQ, EQ vol FX, FX vol IR*, IR vol * IR = base curve + sector-by-rating spreads + Incremental Risks 1 year risk horizon and 1 year liquidity horizon (*), 99,9% confidence level, factor 1, Default and migration risk (at least specific IR) (*) Assumption: constant level of risk Residual Risk Event Risk Issuer spreads, Equities Equities Comprehensive Risk All relevant price risks: Correlation Trading Portfolio Sufficient liquidity, factor 1 Floor: 8% (standardised charge) x (0,1) supervisory additional charge dependent on quality of market risk model 2010 d-fine All rights reserved. y additional capital charge from back-testing results 4
5 Price dynamics of a bond Market price development of a long term corporate bond 7,50 Incremental Risk Issuer Event Tecnost: downgrade Downgrading d A von A auf % Yield* Rendite [%] in 7, ,50 6,00 Specific interest rate risk (issuer specific residual spread risk) spezifisches Spreadrisiko von Tecnost 09 Corporate issuer specific curve allgemeines Spreadrisiko für Corporate A-Bonds General market risk (sector rating spread risk) Corporate A 10Y T Corp EU 5,50 allgemeines Marktpreisrisiko General für alle Finanzinstumente market risk (base curve interest rate risk) EUR IRS 10Y 5, Handelstage Trading days *Yield calculated from quoted bond price 5
6 Incremental Risk in some Detail Risk Driver Dynamics Parametrisation Mapping Initial Data Type of Simulation Risk Measure Risk Indicators Modelling Nature Default, Migration Discrete Probability of Occurrence Probabilities, Correlations Monte-Carlo, Portfolio Models Value-at-Risk (99,9% 9% 1y) Risk Contributions Selected Regulatory Requirements: securitisations as defined in the Basel II framework can not be included no N-th-to-Default credit derivatives equities may be modelled (e.g. for reasons of consistency) constant level of risk assumption liquidity horizons (floor: 3 months) (systematic) correlations, concentrations reflect basis risks (product, seniority, rating, maturity, differences between offsetting positions) validation (good quality of market data entering the model, stress tests, etc.) 6
7 Comprehensive Risks (Market & Credit Risk) Correlation Trading Portfolio actively traded d single-name reference entities (liquid underlyings) no re-securitisations, R/CMBS, Retail-Securities credit derivatives, (other) securitisations, hedges Hedge relations fully covered Fallback: CTP-specific standardised di d charge (restricted hedging possibilities) Selected Regulatory Requirements multiple (ordered) defaults in tranches credit spread risk volatility of implied correlations volatility of recovery rate (stochastic recovery rates) hedge-slippage, g rebalancing costs CRC stress tests Back-testing (historical explanation) all requirements for incremental risks minimum capital 8% of standard charge (current EU Capital Requirements Directive) 7
8 Incremental Risk Charge Validation Model Validation No back-testing as required for 1 day market risk, however, all results should be validated quantitatively (as for Basel II) What? Model assumptions, e.g. liquidity horizon Parameter estimation e.g. migration matrix, correlation matrix, spread shifts Numerical stability Resulting uncertainty of risk measures How? Stress Tests and scenario analyses Sensitivity analysis Statistical Bootstrapping Use Test Application as steering instrument within the bank Use within economic capital calculation 8
9 Content The IRC regulatory framework Modelling Approach Implementation 9
10 Incremental Risk Charge Implementation Choices System architecture Market risk model credit portfolio model stand-alone alone system Rating Migrations Jump Diffusion Merton Model Valuation Migration default (deterministic or stochastic Recovery) Ratings Liquidity horizon Constant Level of Risk external vs. internal Ratings grading Definition of criteria Calculation of Short-term PDs One Period Model Multi-Period Model Determination of Point-in-time vs. Inclusion of CRC Risk factors Through-the-cycle Systematic Idiosyncratic Correlation model other product types additional requirements 10
11 Model: Market risk like + jump processes Problems Modelling of different liquidity horizons (possibly via multi-period i simulations, but difficult to calibrate) Calibration of jumps to actual migration or default probabilities Correlation between jumps Spread changes do not cover migration and default risk only. Calculated risk might be fluctuating with changing spread volatility. 11
12 Integrated Market and Credit Risk Model Problems Need of scenario generator simulating relevant risk factors Choice of risk factors Correlations between credit risk and market risk factors Inclusion of stochastic volatility, recovery and base correlation, jump events Model validation IT infrastructure 12
13 IRC Modelling Framework Spread Curve Construction Building sets of sector/rating credit spread curves (extra- and interpolation between tenors and rating classes) Spread curves Revaluation Model Revaluation of positions after migration with FO pricing engines PVs for different ratings Model for short term migration probabilities Structural Merton Model Simulation of migration & default (multi step extension for constant level of risk) Stochastic LGD Model Parameterization Models (Correlation, R 2 ) Loss Distribution (Percentiles) IRC contribution of positions 13
14 Structural Merton Model: Simulating migration P&L Model firm s normalized asset log return process at risk horizon Firm s as sset log retu urn Default Threshold Scenario 1 Scenario 2 0 AAA AA A BB B CCC ΔPV=PV(R 0 ) PV(AAA) ΔPV=PV(R 0 ) PV(AA) ΔPV=PV(R( 0 ) PV(A) ΔPV=PV(R 0 ) PV() ΔPV=PV(R 0 ) PV(BB) ΔPV=PV(R 0 ) PV(B) ΔPV=PV(R 0 ) PV(CCC) Scenario 2 Risk Horizon (12 months) Default ΔPV=PV(RPV(R 0 ) N x Rec Scenario 1 t 0 T Initial rating R 0 at t 0 Initial value PV=PV(R 0 ) at t 0 Scenario rating R scenario at T Scenario value PV=PV(R scenario ) at T Key modelling issues: 1. Specification of firm s (normalized) asset log return process in factor model 2. Rating class dependent revaluation of position at risk horizon 14
15 Structural Merton Model: Specification & Assumptions Asset value log return process driven by multivariate i t factor model Asset return of obligor i at risk horizon assumed to be normally distributed: Position r i R X i 1 R 2 i R Sector Issuer 2 w Y w Y 1 R ~ N 0,1 1i 1 2i 2 i Normalised asset value log return at risk horizon Systematic risk (e.g. country & industry) Idiosyncratic risk Correlation of migration and default events induced by correlated systematic risk factors Y j (e.g. MSCI country or industry indices): Y Y Y ~ N 0, where Σ is the covariance matrix of systematic factors 1, 2 Assume conditional independence of obligors asset returns upon systematic risk: 0,1 ; cov, 0 & cov, Y 0 ~ N i i j Impact of systematic and idiosyncratic risk term steered by parameter R 2 Default and migration thresholdsh are obtained from migration probabilities: biliti d def i N -1 PD i i j 15
16 Structural Merton Model: Special Features for IRC Extension of Merton model to satisfy regulatory requirements Treatment of hedges (short and long CDS positions) Issuer concentration ti (same idiosyncratic risk for different bonds of same issuer) Constant level of risk assumption: After a so called liquidity horizon a positions can be replaced by another position having its original risk profile. Reflects that buy-and-hold is not appropriate for trading book. Implementation by a multi-step version of the Merton-Model in which the position s asset return process is reset at its liquidity horizon. Multi-step model requires modelling of short term migration matrices (generator matrix approach; thresholds) Double default Optional: Stochastic LGD (recovery) e.g. Beta distribution, generalised logit function Dependent or independent of PD 16
17 Specific topic: Constant Level of Risk Rollover and replacement of positions Replace assets with changed credit quality with similar asset at liquidity horizon Same name? Same industry/country? Buy and Hold Distribute the exposure to other similar names? What if no other or only few other names of same characteristic exist? 1 month B 1 month B D Constant Level of Risk:= Same loss distribution Consider sub-portfolio assigned to one month liquidity horizon Calculate one month loss distribution using one month default probabilities For second month assume same loss distribution again One year constant tlevel lof fikl risk loss ditibti distribution is convolution of 12 copies of one month loss distribution In Monte Carlo context, sum 12 independent draws from one month loss distribution, repeat many times to derive one year loss distribution Multi-period Credit Risk Model Constant Level of Risk 1 month B 1 month B D B D D B Same asset? Same correlation? Same concentration risk? 17
18 Structural Merton Model: Constant Level of Risk Multi-step t extension for replacement of positions within risk horizon Bond 1 (LH 6m) Firm s as sset log retu urn t 0 Bond 2 (LH 12m) 1st step: 6 months Restart AVP Lock 2nd in ΔPV(D) step: 6 months 0 Lock in ΔPV(BB)* Lock in ΔPV(CCC) 1. Simulate first 6-months section of asset value process (AVP): 2. Assess 6-months rating & lock in ΔPV(D) ( ) 3. Constant-level-of-risk reset AVP to zero 4. Simulate second 6- months section of AVP 5. Asses 12-months rating & lock in ΔPV(CCC) for Bond 1 & for Bond 2 ΔPV(BB) 6. Scenario loss Bond 1: ΔPV(D)+ ΔPV(CCC) (over entire risk horizon) 18
19 Revaluation Model: Bond Valuation Standard Model Present value (PV) of bond computed with instrument specific spot curve Components of an instrument specific curve for a bond Residual spread s residual Ra ate [bp] Spot Curve r bond General spread s general Spot curve r bond (R 0 ) Base curve r base Time to maturity T PV is the sum of cash flows discounted Base curve: e.g. swap curve with the spot curve r bond : General spread represented by PV c( t ) sector/rating/currency spread curve n i bond ( t ) (1 t t i i r ( 1 bond t, t ; i R )) Residual spread obtained according to 0 market price of the bond 19
20 Revaluation: Bond Valuation After Rating Migration PV after simulated rating migration computed with adjusted spot curve Components of an instrument specific curve for a bond s residual Ra ate [bp] s general Original spot curve New spot curve r base r bond (R 0 ) r bond (R scenario ) Time to maturity T New PV is the sum of cash flows Shift according to differences in discounted with the new spot curve sector/rating curves of R 0 and R scenario r bond (R scenario ): PV c ( t ) (tenor-wise) n i bond ( t) Construction of sector/rating curves a ti t i1 (1 rbond ( t, ti; Rscenario)) major ingredient 20
21 Net Short Position in Sample Portfolio Causes Unfamiliar Results from a Credit Risk Point of View Loss distribution differs from typical banking book results Net long Net short IRC=99.9%- percentile IRC s sensitivity to parameters is not intuitive 21
22 Content The IRC regulatory framework Modelling Approach Implementation 22
23 d-fine s IRC engine IRC engine is a modified version of d-fine s EC-engine with the following features: Multi-Factor Merton Model Full Migration mode Interface to PV-vectors for each instrument at each different rating grade Constant level of risk Multi step model Stochastic recovery Treatment of different liquidity horizons of different instruments of fthe same issuer 23
24 IRC Calculation Process d-fine s IRC engine & calibration suite Spread curve generation Spread curves Market risk reporting infrastructure t Test portfolio FO-pricing engines IRC-engine ΔPV vectors Migration matrices Correlation model R 2 parameterization suite 24
25 IRC Infrastructure: Flexible Modularised Architecture IRC calculations require interaction of various models, systems and data entities Load transaction-, issuer- & market data Setup IRC portfolio & QA of input data Calibration of model and pre-processing IRC calculation kernel, GUI, reporting & validation 25
26 IRC Calculation Kernel: Data Process control Merton engine incl. pre-/postprocessing EC engine: internal data setup Merton engine kernel Facility table generator: Data validation Missing data imputation Reasonability checks Portfolio reports EC calculation module EC input DB EC output DB EC temp. DB e.g. Country/Product to RiskgroupID mapping, CovarianceMatrix, FactorWeights, R² parameters e.g. FacilityCEC results FacilityESF PortfolioEC PortfolioESF Process s Control eg e.g. PD, EAD, recovery, country, product, etc. Data interface Archive portfolio data, capital allocation control Clients Source Systems reports 26
27 IRC Infrastructure: IRC Engine Calculation Kernel Each component consists of various sub components and modules This is the heart of the IRC system where the MC simulation is performed and related calculations are done. 27
28 d-fine s Approach to IRC Definition of liquidity horizon for trading book positions Determination of PV vectors in different migration states and exposure at default (EAD), jump to default values, recovery rates of trading book positions at liquidity horizon (depending on horizon, possible inclusion of EPE/PFE for derivatives e.g. hedge abort of CDS, Mtm + Add-on etc.) Incorporation of netting effects and hedge positions (short vs. long positions, offsetting positions with same party, hedges) Incorporating double default risk of issuer and hedge position Determination of recovery value (LGD) of trading book positions (recovery at different seniority classes for bonds) Stochastic recovery Calibration of short term PDs by usage of migration generator matrices Usage of multi-step portfolio model Parameterization of IRC engine (mapping of parties to industry and country factors, calibration of correlation model, calibration of idiosyncratic risk weights, PD term structures, rating migration matrices etc.) Calculation of incremental capital charge and design of reporting 28
29 Implementation ti Phases and Elements Phase 1 Phase 2 Phase 3 Phase 4 Current situation Gap analysis Model selection Setup of portfolio and parameterization Calculation and reporting design Documentation phase Ele ements Investigation of current situation and developments Availability of transaction data (PD, LGD, Exposure) Methods to calculate short term PD, EAD and LGD Gap analysis Suitable framework and further proceeding Missing data Test calculation Documentation of replacement phase of IRC methodology and Setup of portfolio Benchmarking business Selection of factors results specifications appropriate for IRC calculation at Documentation of counterparty risk different levels of pre-requisites, data profile portfolio capture and Estimation of aggregation database requirements, test correlation matrix Conception and results, reports, IT Mapping of parties to draft design of environment, systematic factors reports (internal resources, and regulatory) Estimation of R² maintenance and further standards etc. Resul lts Documentation of gap analysis and workshop presentation Parameterised portfolio, correlation model and other parameters Test results of IRC calculations l and prototype reports Business concept, methodological l concept, report guidelines 29
30 Your Contact at d-fine: Dr Christian Oehler Senior Manager mobile phone [email protected] d-fine GmbH Opernplatz Frankfurt am Main +49 (0) Dr Bernd Appasamy Managing Director mobile phone [email protected] Dr Georg Stapper Director mobile phone [email protected] d-fine Ltd 28 King St London, EC2V 8EH +44 (0) d-fine (HK) Ltd 32 Hollywood Road Hong Kong, Central
31 2010 d-fine All rights reserved. 31
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