Counterparty Credit Risk Measurement Under Basel II. A presentation by ISDA Asia 2007



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Counterparty Credit Risk Measurement Under Basel II A presentation by ISDA Asia 2007 1

Outline 1- Definition of counterparty credit risk (CCR) 2- Basel I treatment 3- Basel II treatment : Regulatory approved methods for measuring counterparty exposures 4- Simple approaches 5- Internal Model Method a- EPE b- Corrections brought to the pure EPE concept c- Short term maturity transactions 2 ISDA

Definition of counterparty credit risk the risk that the counterparty to a transaction could default before the final settlement of the transaction s cash flows. An economic loss would occur if the transactions or portfolio of transactions with the counterparty has a positive economic value at the time of default [Excerpt from The Application of Basel II to Trading Activities and the Treatment of Double Default Effects, July 2005, BIS] 3 ISDA

The nature of counterparty credit risk Counterparty risks are an inevitable by-product of privatelynegotiated derivatives transactions Counterparty risks create a chain of dependencies among derivatives counterparties Counterparty risks lead to exposures that must be measured and managed End -user Dealer Dealer End -user 4 ISDA

The nature of counterparty credit risk CCR exposure is the potential exposure at the time of default. Because it is a future exposure it is not known with certainty, but depends on the value, at the time of default, of the market factors driving the valuation of the instrument or portfolio under consideration. Instruments concerned include Securities Financing Transactions (SFTs) and OTC derivatives A horizon for calculating this value is necessary; in the regulatory framework, this is set at ONE YEAR. 5 ISDA

6 ISDA Example of CCR exposure Example of expected exposure simulation 250,000 200,000 Expected Exposure 150,000 100,000 50,000 0-50,000-100,000 1 8 15 22 29 36 43 50 57 64 71 78 85 92 99 % of 1 year

Counterparty risk milestones 7 ISDA 1988 Basel Capital Accord first set of derivative add-ons 1994 Basel Committee recognises netting 1995 Market Risk Amendment to the Accord, expanded add-ons matrix 2001 Basel Models Task Force defers reform of counterparty risk treatment 2003 SEC Capital Proposals for SIBC and CSE 2004 Basel Committee and IOSCO announce plans to consider counterparty risk and other trading book issues July 2005 Basel Committee and IOSCO publish The Application of Basel II to Trading Activities and the Treatment of Double Default Effects, otherwise known as the Trading Book review document September 2005 EU Commission incorporates the Trading Book review in the Capital Requirements Directive October 2006 FSA publishes its rulebook Sept 06-June07 US agencies consult on a Notice of Policy Rulemaking implementing Basel II

8 Basel I treatment

9 ISDA Basel I treatment of CCR risk OTC derivatives Capital= EAD x Counterparty RW x 8% SFTs in the trading book If documented properly, no charge applies EAD= Current exposure + Add-on x Notional principal Potential future exposure (PFE) Add-on : fixed percentage, function of underlying and maturity. Low for interest rate, high for commodities. Netting of add-ons is permitted: Potential future exposure is reduced to : 0.4 x PFEgross+ 0.6 x net to gross ratio x PFE gross PFEgross= sum of all add-on terms for contracts included in a netting set. net to gross ratio: net CE/gross CE Counterparty risk weight function of nature of counterparty

Criticism of Basel I treatment Not risk sensitive: PFE is in reality not proportional to notional; Should be adjusted to reflect changing volatilities of underlying; Netting of add-ons is a rule of thumb; RW is reflective of the nature of the counterparty, not its risk quality Not consistent: SFTs and OTC derivatives should be treated consistently, as they pose similar risks [an SFT is a combination of a spot position and a forward] 10 ISDA

11 Basel II treatment

12 ISDA In a nutshell: Basel II treatment broadly consistent between SFTs and OTC derivatives. Cross product netting is recognised between product types, provided that the bank obtains a legal opinion that concludes that relevant courts would find the firm s exposure to be the cross product net amount under the laws of the relevant jurisdictions. Greater risk sensitivity is included in measurement of EAD [exposure] and counterparty RW Capital charge= EAD x Counterparty RW x 8%

Counterparty RW 2 approaches: Standardised approach simply links the RW with the external rating of the counterparty. Non-rated counterparty attracts a 100% risk weight Internal Ratings Based approach: RW=f(PD,LGD, maturity); PD is determined by the firm; LGD, maturity can be determined by the regulators or by the firm. 13 ISDA

14 ISDA IRB versus Standardised capital charges Comparison of Standardised RW with IRB RW 300 250 IRB RW RW (%) 200 150 100 50 0 Standardised RW 0.03% 0.04% 0.06% 0.22% 0.98% 5.30% 21.94% Probability of default of counterparty (corporate)

15 ISDA Our primary focus today: measurement of CCR EAD under Basel II SFTs OTC derivatives Internal Model Method IMM VaR Comprehensive haircut collateral Standardised Method Simple risk weight substitution Current Exposure Method

16 Product specific approaches to measuring CCR EAD

SFTs- simple approaches Simple method : RW substitution [only available in the banking book] Claims collateralised receive the risk weight of the collateral issuer, subject to a floor of 20%; Broader definition of collateral than under Basel I [IG debt, government debt rated above BB-, listed equity] 17 ISDA

SFTs- simple approaches Comprehensive approach: EAD= max (0, E(1-He)-C(1-Hc-Hfx)), Where: E is the exposure being collateralised; He is the haircut applicable to E; C is the collateral available Hc is the haircut applicable to C Hfx is the haircut for currency mismatch between E and C Haircuts can be supervisory or calculated by firms to a (99 th, 5 or 10 day) standard 18 ISDA

SFTs - IMM VaR approach EAD on a portfolio of repos with a counterparty calculated using VaR (99 th, 5 days) Correlation /diversification effects taken into account Same qualitative requirements as for market risk VaR models Backtesting on sample of 20 counterparties Backtesting multipliers apply 19 ISDA

OTC derivatives: simple approaches CEM approach: -EAD defined as per Basel I; -Collateral captured under the simple or the comprehensive approach outlined before. Under simple approach, floor is brought down to 0% for daily cash margined positions where no FX mismatch occurs -New add-ons for credit derivatives: 5% for IG underlyings; 10% otherwise. 20 ISDA

OTC derivatives: Standardised Method Standardised Method: - Intermediate approach between IMM and CEM, useful for firms which are not equipped to use the IMM. - The standardized formula for the credit equivalent exposure (EAD) under discussion is: EAD = β max( E C; RPE RPC xccf j ) j where the conversion factors CCF are intended to convert a net risk position RPE-RPC into a potential exposure add-on which is compared to the net current value MtM. The result is multiplied by a corrective factor β. RPE is the risk position attributable to a transaction assigned to a particular hedging set; RPC is the risk position attributable to collateral assigned against this transaction. RP= dv/dp [delta of the position] The CCF are conversion factors imposed by the regulators, corresponding to the EPE attributable to a position of 0 current value in the hedging set. 21 ISDA

22 ISDA Example of use of the standardised method Commodity forward delta 2 CCF 10% beta 1.4 MTM EAD 0 0.28 1 1.4 2 2.8 3 4.2 4 5.6 5 7

23 The Internal Model Method: EPE Corrections to pure EPE concept Short term maturity adjustment

24 Expected Positive Exposure (EPE)

25 ISDA EPE Capital = EAD. RW. 8% RW is the Risk Weight, a function of the credit quality of the counterparty, expected recovery rate and tenor of the credit risk (Effective Maturity M) EAD is the Exposure At Default What is EAD for the market-driven OTC derivatives counterparty exposures? PFE(99%,1-year) Expected Positive Exposure Something else?

Exposure Profile Single Transaction Initial CMTM = 0. Exposure Profile of 5 Yr. Swap EPE 4.00 Exposure Profile Portfolio of Many Transactions Initial Portfolio Net CMTM > 0. Portfolio Exposure Profiles Potential Replacement Cost Expected Positive Exposure 0 12 24 36 48 60 72 Time (Months) 99%CL Exposure Potential Replacement Cost 3.50 3.00 2.50 2.00 1.50 1.00 0.50 Expected Positive Exposure 99%CL Exposure 0.00 0 12 24 36 48 60 72 84 96 108 120 Time (months) For illustration only EXPOSURE PROFILE Potential replacement cost of portfolio of contracts, over time, calculated at some confidence level, assuming: - No Additional Transactions - Netting And Margin Taken Into Account Exposure Profile for credit line limits is typically calculated at a very high CL (e.g. 97.7%). Exposure profile can be calculated at other CL, including expected positive profile or even a negative profile how much one s firm may owe counterparty in the future. 26 ISDA

EPE Initial Industry Proposal: Loan equivalent = EPE for SFTs and OTC Derivatives. EPE = Average of expected positive profile over one year horizon. 150 COUNTERPARTY EXPOSURE PROFILE POTENTIAL REPLACEMENT COST ($mm) 125 100 75 50 25 0 0 6 12 18 24 30 36 42 48 54 60 TIME (months) Calculate the expected positive value of the counterparty s exposure profile over the life of the portfolio EPE = Average of expected profile over one year horizon. 27 ISDA

Calculation of EPE- Process steps Forecast future values of market factors; distribution of values at future points in time. Value each position under each market scenario at each point in time; Aggregate positions to netting set level, taking collateral into account An exposure profile is obtained enabling the calculation of the expected positive exposure 28 ISDA

29 Corrections to pure EPE concept

Corrections to EPE : Rollover risk Most short term exposures are rolled over If this effect is ignored, EPE <CE for many counterparties: 30 ISDA

Rollover risk Solution : regulators propose to use Effective EPE, defined as: Eff EPEt =Max(Eff EPEt-1, EPE) Effective EPE EPE value 35 30 25 20 15 10 5 0 Effective EPE Average 1 year EPE 1 2 3 4 Time buckets 31 ISDA

Rollover risk Remaining issues: Industry would like to be able to calculate Effective EPE at the level of the counterparty, rather than the netting set; Some would also like to ignore roll-over risk where portfolios are rapidly changing [either very short term, or entered into with counterparties who will assign or novate trades quickly] 32 ISDA

Correction: Effective maturity 150 A Counterparty's Exposure Profile Lifetime area under discounted curve Potential Exposure ($MM) 125 100 75 50 25 0 0 6 12 18 24 30 36 42 48 54 60 Time (Months) ==> Full Life of k = 1y Portfolio EPE k 1 year t EEPE k df k k tk df = k + k = 1 140.7 150 A Counterparty's Exposure Profile One year area under discounted curve Potential Exposure ($MM) 125 100 75 50 25 0 0 6 12 18 24 30 36 42 48 54 60 Time (Months) ==> M is simply the ratio of: The area under the full-lifetime EPE curve, corrected for EEPE divided by the area EEPE 1-year. 1Year EEPEk t k df = k k = 1 33 ISDA 75.9 Therefore M = (140.7/75.9) yrs = 1.85 yrs = 22.2 months

34 ISDA Correction : imperfect diversification (alpha factor) Tom Wilde (2001) showed that if the portfolio of counterparty exposures is perfectly diversified, EPE is the correct measure of EAD under the Basel II model But real portfolios are not perfectly diversified they have market and credit risk granularities. The graph below shows the distribution of correlation between pairs of counterparties in a typical derivatives portfolio. 0.025 0.02 0.015 0.01 0.005 0-1 -0.9-0.8-0.7-0.6-0.6-0.5-0.4-0.3-0.2-0.1-0 0.08 0.17 0.26 0.35 0.44 0.53 0.62 0.71 0.8 0.89 0.98 Evan Picoult (2002) defined and proposed α as the gross-up factor for EPE necessary to account

35 ISDA Alpha factor Evan Picoult (2002) defined and proposed α as the gross-up factor for EPE necessary to account for the risk granularities in the portfolio: Economic capital under market and credit uncertainty α = Economic capital under credit uncertainty only But What is the value of α? How does α vary with the characteristics of the portfolio of exposures? Eduardo Canabarro (2002) developed a quantitative model to represent a portfolio of market-driven counterparty exposures with parameters defining various characteristics of the portfolio. With that model, Eduardo calculated α s via Monte Carlo simulations. Tom Wilde (2002) derived the analytical expressions for α for the model.

36 ISDA Example Portfolio Specification Intended to be a realistic model of a large derivatives portfolio. Portfolio parameters were as shown for base portfolio. PORTFOLIO PARAMETERS Percentile q 99.90% Credit information Number of counterparties N 200 Default probability p 0.30% Asset correlation l 22.00% Exposure information Number of market factors K 3 Spot values ± u ±1. 36 Market volatilities s 1 unit Within IRB range (12% to 24%) K = 3 chosen based on the empirical correlation structure discussed above

Asset corr'n The value of alpha Spot value+/- No factor s No. of cpties PD Conf level Systematic risk Actual Portfolio A Reference Portfolio B ISDA worked with example portfolios to quantify α: Actual portfolio A This is the portfolio with full stochastic exposures and correlations as per the settings described above. Reference portfolio B This portfolio is as A but with each exposure fixed = EPE of the corresponding portfolio A counterparty. α = A q / B q alpha measures the extra risk arising from the fact that exposures are variable and correlated. Comments Analytic and Monte-Carlo results agree on α = 1.09 for the base portfolio Importantly, α is not very sensitive to most parameters; don t need tailored values of α 22% 1.36 3 200 0.3% 99.5% 5.85 7.90 7.90 7.18 7.23 1.10 1.09 37 ISDA α = Α/Β λ u K N p q Analytic M-Carlo Analytic M-Carlo Analytic M-CarloAnalytic Base case Percentile Percentile Percentile 22% 1.36 3 200 0.3% 99.9% 10.19 13.14 12.96 12.06 12.02 1.09 1.08 Sensitivity to asset correlation 0% 1.36 3 200 0.3% 99.9% 0.51 6.09 NA 4.26 NA 1.43 1.46 12% 1.36 3 200 0.3% 99.9% 5.31 8.99 8.91 7.43 7.73 1.21 1.15 24% 1.36 3 200 0.3% 99.9% 11.30 14.08 13.96 13.04 13.05 1.08 1.07 50% 1.36 3 200 0.3% 99.9% 30.69 32.70 32.50 32.06 31.82 1.02 1.02 Sensitivity to current market values 22% 0 3 200 0.3% 99.9% 5.65 8.42 8.23 6.24 6.18 1.35 1.33 22% 1 3 200 0.3% 99.9% 8.26 10.96 10.81 9.61 9.61 1.14 1.12 22% 2 3 200 0.3% 99.9% 14.28 17.80 17.64 16.95 16.96 1.05 1.04 22% 3 3 200 0.3% 99.9% 21.24 25.95 25.73 25.19 25.26 1.03 1.02 Sensitivity to the number of market risk factors 22% 1.36 1 200 0.3% 99.9% 10.19 13.22 13.11 12.02 12.02 1.10 1.09 22% 1.36 5 200 0.3% 99.9% 10.19 13.07 12.93 12.10 12.02 1.08 1.08 22% 1.36 10 200 0.3% 99.9% 10.19 12.97 12.91 12.01 12.02 1.08 1.07 22% 1.36 50 200 0.3% 99.9% 10.19 12.96 12.89 12.00 12.02 1.08 1.07 Sensitivity to number of counterparties 22% 1.36 3 20 0.3% 99.9% 1.02 3.54 3.72 2.81 2.85 1.26 1.31 22% 1.36 3 50 0.3% 99.9% 2.55 5.21 5.26 4.27 4.37 1.22 1.20 22% 1.36 3 100 0.3% 99.9% 5.10 7.79 7.83 7.08 6.92 1.10 1.13 22% 1.36 3 500 0.3% 99.9% 25.48 28.92 28.36 27.81 27.31 1.04 1.04 Sensitivity to probability of default 22% 1.36 3 200 0.1% 99.9% 4.55 7.03 6.93 6.01 6.16 1.17 1.12 22% 1.36 3 200 0.5% 99.9% 14.56 17.59 17.56 16.44 16.50 1.07 1.06 22% 1.36 3 200 1.0% 99.9% 23.10 26.60 26.50 25.09 25.20 1.06 1.05 22% 1.36 3 200 5.0% 99.9% 59.40 65.00 64.55 61.90 61.84 1.05 1.04 Sensitivity to confidence level 22% 1.36 3 200 0.3% 99.0% 4.37 6.08 6.11 5.68 5.56 1.07 1.10

Regulatory value of alpha Firms can, subject to operational risk requirements, calculate own alphas, subject to a floor of 1.2 Basel Committee will re-examine the floor in the light of further advances made by firms in modelling economic capital. 38 ISDA

Other risks not captured There are further possible risks with a counterparty portfolio Wrong way risk and systematic LGD risk These risks are not part of the simulations that produced α. They are not accounted for by simply using the α multiplier, and must be considered separately. Wrong way risk This is risk where the exposure is adversely correlated with counterparty credit quality A classic example is the own shares financing, where the transaction is essentially a loan collateralised by equity related to the borrower. ISDA advocates prudent treatment (e.g. treat as unsecured). Not appropriate to incorporate into α, as requires tailored transaction by transaction treatment. Systematic LGD risk Accepted that capital requirements should reflect LGD appropriate to bad years. Principally an issue for loans. However, is there an effect on counterparty LGD s as well? Evidence likely to be sparse, but prudence needed. It can be shown that effect on α is a slight decrease, which can therefore be ignored. 39 ISDA

40 Short term maturity

Short term maturity issues Some portfolios are principally comprised of short term transactions [repos are often overnight, FX derivatives tend to be short term]. For those portfolios, industry has argued that it should be feasible to adjust maturity below one year [a one year floor otherwise applies in the IRB framework] Regulators have accepted the argument and applied the maturity adjustment below one year. 41 ISDA

Maturity effect on the IRB capital charge 300% 250% 200% Below one year Scope - National discretion (Basel, para 321). - Guidance / examples given (para 322). Slope - Same as for > 1 year. AAA BBB B 150% 100% 50% 0% Above one year - generally available (or use 2.5 years) - slope based on quantitative work 0.0 0.5 1.0 1.5 2.0 2.5 3.0 3.5 4.0 4.5 5.0 42 ISDA

Problems with Basel s treatment Slope: Same as > 1 year The treatment of short dated products borrows the > 1 year formula. This formula was not developed for short dated products. Industry and regulators agree the technicalities are different for < 1 and >1 year. -> Can we develop a tailored approach to short dated products? -> Principles for inclusion within scope : -availability of information concerning credit quality of counterparty -ability to hedge or terminate the exposure 43 ISDA

- ANNEX - Extract from Citigroup Presentation ECONOMIC CAPITAL 44 ISDA

DEFINITION OF ECONOMIC CAPITAL THE TERM CAPITAL HAS SEVERAL MEANINGS: SOME MEASURE OF AVAILABLE FINANCIAL RESOURCES: BOOK CAPITAL = ASSETS LIABILITIES MARKET CAPITALIZATION = NUMBER OF SHARES * PRICE PER SHARE = IMPL. MKT. VALUE OF ASSETS LIABILITIES (Implied Market Value of Assets) A MEASURE OF ECONOMIC RISK (solvency, i.e. debt holders, perspective): ECONOMIC CAPITAL = MEASURE OF UNEXPECTED LOSS AT HIGH C.L. Probability of Credit Loss 3.0% 2.5% 2.0% 1.5% 1.0% 0.5% Probability Distribution of Potential Credit Loss for a Portfolio of Many Obligors Loss at high CL Economic Capital Exp Loss 0.0% -160-140 -120-100 -80-60 -40-20 0 Potential Credit Loss ($mm) 45 ISDA

46 ISDA ECONOMIC CAPITAL BASICS EC should always be defined on a portfolio basis for all obligors in the portfolio. EC is defined by width of potential loss distribution. The width depends on the characteristics of the entire portfolio of obligor exposure. There are two levels of portfolio diversification that needs to be taken into account when measuring ec for counterparty credit risk: Diversification / portfolio effects with regard to the potential exposure across all transactions with a particular counterparty. Diversification/portfolio effects across all counterparties.

DEFINITION OF ECONOMIC CAPITAL EXAMPLE: EC FOR CREDIT RISK Economic Capital For Credit Risk = A measure of risk: The unexpected loss, at a high confidence level, in excess of the expected loss. Probability Distribution of Potential Credit Loss for a Portfolio of Many Obligors 3.0% Probability of Credit Loss 2.5% 2.0% 1.5% 1.0% 0.5% Loss at a very high CL (e.g. 99.9%) Economic Capital for Credit Risk to cover Unexpected Loss (UL) Expected Loss (EL) 0.0% -160-140 -120-100 -80-60 -40-20 0 Potential Credit Loss ($mm) The probability distribution of potential credit loss, and the ratio UL/EL, depends on the composition of the portfolio and the definition of credit loss. 47 ISDA

48 ISDA ECONOMIC LOSS - LOAN PORTFOLIO - DEFAULT ONLY ANALYSIS SIMULATING LOSS DISTRIBUTION OF LOAN PORTFOLIO: Default only Perspective ASSUME SOURCE OF CREDIT RISK IS DEFAULT AND RECOVERY ONLY. FACTORS NEEDED TO SIMULATE LOSS DISTRIBUTION: - Credit exposure per obligor - Probability distribution of exposure at default, for contingent credit. - Probability of default (i.e. by obligor risk rating) and correlations of probability of default - Probability distribution of loss given default (LGD) (i.e. 1 recovery%). THERE ARE SEVERAL VERY DIFFERENT WAYS OF MODELING THE POTENTIAL LOSS DISTRIBUTION DUE TO DEFAULT AND RECOVERY.

FACTORS EFFECTING ECONOMIC CAPITAL FOR LOANS: DEFAULT ONLY Even if had certainty about PD and LGD: Uncertainty in how many obligors default. Uncertainty in which obligors default (particularly important for inhomogeneous portfolio) Uncertainty in recovery after default In addition have uncertainty about future state of economy and therefore uncertainty in PD. 49 ISDA

50 ISDA ECONOMIC CAPITAL FOR COUNTERPARTY RISK DEFAULT ONLY PERSPECTIVE

ECONOMIC LOSS - COUNTERPARTY RISK - DEFAULT ONLY ANALYSIS SIMULATING POTENTIAL LOSS DISTRIBUTION OF DERIVATIVE PORTFOLIO: DEFAULT ONLY ANALYSIS FACTORS NEEDED TO SIMULATE LOSS DISTRIBUTION: Probability distribution of Credit Exposure per obligor Probability of Default (by risk rating, industry, etc.) and correlations of probability of default. Probability distribution of Loss Given Default (LGD) Correlation of Potential Exposure and Default MATERIAL DIFFERENCES WITH SIMULATION OF LOAN PORTFOLIO LOSS DISTRIBUTION. Variability of Exposure per obligor - All else held constant, increases risk relative to a fixed exposure. Not all obligors have exposure at same time - All else held constant, decrease risk relative to a fixed exposure. Need a method of measurement of economic capital for counterparty credit risk, taking into account the potential volatility of counterparty exposure over time. 51 ISDA

TWO METHODS FOR SIMULATING POTENTIAL LOSS DISTRIBUTION DUE TO COUNTERPARTY RISK FULL SIMULATION: Simulate a path the market could take over time. For each path the cash flows of each counterparty are fixed and the exposure of each counterparty is determined. Hence, for each potential path of the market, one can simulate thousands of potential default and recovery scenarios over time just as for a loan portfolio. Repeat by simulating thousands of potential paths market rates could take over time. Derive EC from the distribution of potential loss. This has virtual of coherent simulation. The consequence of default and recovery take into account the particularly exposure given the particular simulated state of the market. SIMULATION WITH FIXED EXPOSURE PROFILE Assume the potential exposure of each counterpart can be represented by a fixed exposure profile over time equal to the expected exposure profile. Simulate thousands of defaults and recoveries over time, just as if this were a loan portfolio. Derive EC from the distribution of potential loss. 52 ISDA

ECONOMIC LOSS - COUNTERPARTY RISK - DEFAULT ONLY ANALYSIS EC BY FULL SIMULATION: GENERAL METHOD, FIVE STEPS 1) SIMULATE A PATH, P, OF MARKET RATES OVER TIME M(t) P Same as for Exposure Profile. ths P. Loop over thousands of pa 2) FOR SIMULATED PATH P, MEASURE THE POTENTIAL MARKET VALUE OVER TIME OF EACH TRANSACTION WITH FOR COUNTERPARTY K. Same as for Exposure Profile. 3) FOR SIMLUATED PATH P, DERIVE COUNTERPARTY K S POTENTIAL EXPOSURE OVER TIME. i.e. For each counterparty K, for path M(t) P derive Exposure(t) K,P Same as for Exposure Profile. 4) USING THE SET OF EXPOSURE PROFILES {Exposure(t) K,P } FOR ALL COUNTERPARTIES K, GENERATED BY MARKET PATH P: CALCULATE THE POTENTIAL LOSS DISTRIBUTION BY SIMULATING THOUSANDS OF SCENARIOS OF DEFAULT AND RECOVERY FOR THE SET OF COUNTERPARTIES K. 5) AFTER SIMULATING THOUSANDS OF POTENTIAL PATHS OF MARKET RATES, M(t) P CALCULATE FULL LOSS DISTRIBUTION AND DERIVE THE FULL SIMULATION ECONOMIC CAPITAL FOR COUNTERPARTY RISK. 53 ISDA Loop over thousands of scenarios of default and recove ry.

IS IT POSSIBLE TO DEFINE A LOAN EQUIVALENT FOR COUNTERPARTY EXPOSURE? A Loan Equivalent is the fixed exposure profile, per counterparty, that would generate the same economic capital as calculated with full simulation. Note: The use of a fixed exposure profile per counterparty to calculate total EC for the credit risk of all counterparties entails the incoherent summation of each counterparty s potential exposure and has the same potential error as the simple, incoherent summation of the potential exposure of each transaction with a counterparty to get the counterparty s total potential exposure. In other words, for any state of the market, some counterparties will have positive exposure, some negative. There will be no state of the market in which every counterparty has its average positive expected exposure. HOW GOOD AN APPROXIMATION OF A LOAN EQUIVALENT IS THE EXPECTED EXPOSURE PROFILE? IN WHAT CONTEXT, IF ANY, IS IT A GOOD APPROXIMATION? 54 ISDA

ECONOMIC LOSS - COUNTERPARTY RISK - DEFAULT ONLY ANALYSIS EC USING EXPECTED EXPOSURE EXPOSURE PROFILE AS A LOAN EQUIVALENT: 1) CALCULATE THE EXPECTED POSITIVE EXPOSURE PROFILE, EPE(t) K, OF EACH COUNTERPARTY K Loop over thousands of paths P. a) Simulate a path, P, of market rates over time M(t) P b) For simulated path, P, measure the simulated market value over time of each transaction with counterparty K. c) For simulated path, P, derive counterparty exposure over time. i.e. For the counterparty K, for path M(t) P, derive Exposure(t) K,P LOOP OVER THOUSANDS OF SIMULATED PATHS M d) Derive each counterparty s expected positive exposure profile EPE(t) K Loop over thousands of default scenarios.t 2) USING THE SET OF EXPECTED POSITIVE EXPOSURE PROFILES {EPE(t) K } FOR EVERY COUNTERPARTY K Calculate the potential loss distribution by simulating thousands of scenarios of default and recovery for the set of counterparties K. 3) CALCULATE THE ECONOMIC CAPITAL FROM THE LOSS DISTRIBUTION DERIVED FROM EACH COUNTERPARTY S EXPECTED EXPOSURE PROFILE. 55 ISDA

DEFINING THE LOAN EQUIVALENT FOR ECONOMIC CAPITAL a.k.a. The Credit Equivalent Amount (CEA) - From a default only perspective Define a as the ratio of a) EC calculated by full simulation to b) EC calculated by simulation where each counterparty s exposure is represented as a fixed expected positive exposure profile: α ( P; CL,T ) = Econ Cap (P; CL, T) Econ Cap (P; CL, T) FULL_SIM; DEFAULT ONLY FIXED_EPE_ SIM; DEFAULT ONLY Where: P = Particular portfolio of counterparties with transactions and assumptions about portfolio, e.g. PDs, Correlations, etc. CL = Confidence Level that EC is measured at. T = Time Horizon over which EC measured. Therefore: CEA(t) K = α(p;cl,t) * EPE(t) K for counterparty K Questions: - How will α vary with the characteristics of the entire portfolio of counterparty risk? - What characteristics of the portfolio does α depend on? 56 ISDA

57 ISDA ISDA TESTS CREATE TEST PORTFOLIOS AND CALCULATE a AS A FUNCTION OF THE CHARACTERISTICS OF THE PORTFOLIO: NUMBER OF EFFECTIVE COUNTERPARTIES NUMBER OF EFFECTIVE MARKET FACTORS PROBABILITY OF DEFAULT OF COUNTERPARTIES CORRELATION OF DEFAULT. INITIAL MTM OF COUNTERPARTIE S PORTFOLIO OTHER FACTORS. INITIAL PROPOSAL: Evan Picoult, Citigroup SIMULATIONS OF STYLIZED PORTFOLIOS: Eduardo Canabarro, Lehman ANALYTICAL CALCULATIONS: Tom Wilde, CSFB MEASUREMENT OF a FOR REAL PORTFOLIOS: Several Firms SUMMARY CONCLUSION: For Large Market Makers a 1.10 See: - ISDA web site. Papers on Counterparty Risk to Basel Committee, June 2003 - Risk Magazine, September, 2003

ISDA Contact Details Emmanuelle Sebton Co-Head European Office & Policy One New Change London EC4M 9QQ England Phone: 44(0)20 7330-3571 Fax: 44 (0)20 7330-3555 esebton@isda-eur.org ISDA Website www.isda.org Go To: Committees/Risk Management for more detail on ISDA s activities in the field of prudential regulation. 58 ISDA