Chapter 6 Market Risk
A. Market Risk Management Policy
1. Market Risk refers to the risk of incurring losses on positions held by a Bank with trading intent (usually in its Trading Book), caused by adverse movements in market prices or in underlying value drivers. Market risk may result from on-balance-sheet and off-balance-sheet exposures arising from investments, inter-bank lending, derivative transactions, securities financing transactions and trading activities. It primarily arises from a Bank’s Trading Book while the foreign exchange risk component of the Market risk can arise in its Banking Book.
2. A Bank’s Market risk management policy is expected to address the following key elements:
(a) effective systems for the accurate and timely identification, measurement, evaluation, management and control or mitigation of Market risk, and reporting to the Bank’s governing body and senior management;
(b) prudent and appropriate Market risk limits that are consistent with the Bank’s risk tolerance, risk profile and capital, and with the management’s ability to manage;
(c) who is responsible for identifying, measuring and reporting Market risk;
(d) procedures for tracking and reporting exceptions to, and deviations from, limits or policies; and
(e) procedures for including positions and exposures in the Trading Book.
3. The policy must ensure that all of the Bank’s transactions are identified and recorded in a timely way and that their valuations are consistent and prudent. The Bank must use reliable market data that have been verified by a function that is independent of the function that assumed or incurred the risk.
B. Trading Book
4. In cases where a Bank acts as principal (even in the course of an activity normally described as ‘broking’ or ‘customer business’), the resulting positions should be included in its Trading Book. This applies even if the nature of the business means that the only risks being incurred by the Bank are counterparty risks where no Market risk capital requirements apply.
5. In respect of BBR Rule 6.3, the AFSA will grant approval for a switching of positions between the Trading Book and the Banking Book of the bank only in extraordinary cases. When such approval is granted, the AFSA is likely to mandate public disclosure of the approved switch.
6. A Bank’s Trading Book policy is expected to address the following key elements:
(a) positions to be included, or not to be included, in the Trading Book;
(b) managing and reporting trading positions;
(c) valuing positions, including:
(i) clearly defined responsibilities of staff involved in the valuation;
(ii) sources of market information, and review of their reliability;
(iii) frequency of independent valuations;
(iv) timing of closing prices;
(v) procedures for adjusting valuations between periods;
(vi) ad-hoc verification procedures; and
(vii) reporting lines for the valuation function that are independent of that function that gave rise to the position.
(d) distinguishing consistently between trading activities and banking activities
(e) monitoring the size of its Trading Book.
C. Valuation of positions
7. In relation to the requirements set out in the BBR Rule 6.4 on valuation of positions, a Bank must mark-to-market all the positions in its Trading Book, except for cases where it is not possible to do so (for example, unlisted securities, illiquid securities or positions). The AFSA expects a Bank to mark-to- market listed securities since there is a market with observable and reliable prices for such securities. It should use the prudent side of bid or offer unless the Bank is a significant market maker that can close at mid-market.
8. When estimating fair value, the Bank should maximise the use of relevant observable inputs and avoid the use of unobservable inputs. The Bank should be extra conservative when using the marking-to-model method. The AFSA will take into account the following in deciding if the Bank’s model is prudent:
(a) whether senior management is aware of the positions and exposures that are marked to model and whether it understands the uncertainty this might create in reporting the risk or performance of the business;
(b) the extent to which market inputs are sourced from market prices;
(c) the appropriateness of the assumptions used by the Bank;
(d) the availability of generally accepted valuation methods for particular products
(e) who developed the model;
(f) whether the Bank holds a secure copy of the model;
(g) the existence of formal control procedures for changing the model;
(h) how often the model is used to check valuations;
(i) how aware is the Bank’s risk management function of the weaknesses of the model and how those weaknesses are reflected in the valuation output;
(j) the results of comparisons between actual close out values and model outputs;
(k) the Bank’s procedures for reviewing the model.
9. Independent price verification is different from daily mark-to-market. The object of the verification is to regularly check the accuracy of market prices or model inputs and, thereby, eliminate inaccurate daily marks. The verification should be carried out by a unit independent of whoever marked the positions or exposures.
10. The independent marking in the verification process should reveal any error or bias in pricing. It 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. The Bank must consider the following valuation adjustments:
(a) unearned profit;
(b) close-out costs;
(c) Operational Risks;
(d) early termination;
(e) investing and funding costs;
(f) future administrative costs;
(g) model risk, if relevant;
(h) any other adjustment that the Bank considers appropriate
D. Use of Internal Models
11. This section sets out the conditions under which a Bank is permitted to use an internal model to calculate its Market Risk Capital Requirement or any component of its Market Risk Capital Requirement. A Bank that wishes to use an internal model to calculate any part of this requirement is required to apply to the AFSA. Internal models will commonly permit more extensive netting of long and short positions and have greater risk sensitivity.
12. In assessing whether to give approval, the AFSA will consider the effectiveness and coverage of the Bank’s risk management framework, governance of its model development and implementation processes, the stress-testing and back-testing standards and the process surrounding the calculation of capital requirements.
13. The AFSA will usually approve the use of an internal model if:
(a) the use of the model to calculate the Market Risk Capital Requirement has been approved by another appropriate regulator or the Bank has provided opinions from independent experts on the ability of the model to calculate Market Risk capital requirements, to the satisfaction of the AFSA;
(b) use of the methodology is integrated into the governance and risk management framework of the Bank. Specifically, the Governing Body and senior management of the Bank receives and reviews appropriate reports in respect of the model and its use;
(c) it is satisfied with the overall soundness and integrity of the Bank's enterprise-wide risk management system;
(d) the Bank has sufficient numbers of staff skilled in the use of sophisticated models specifically in the risk management, audit, and back office areas;
(e) the Bank's models have a proven track record of reasonable accuracy in measuring risk; and
(f) the Bank has a robust stress testing programme.
14. In determining whether an internal value at risk (VaR) model meets the standard for approval, the AFSA will apply the criteria set out in the section below, which are based on the Basel Market Risk Capital Amendment 1996 and Basel Revisions to the Basel II Market Risk framework 2009 and which can be grouped under the following headings:
(a) qualitative standards;
(b) specification of Market Risk factors;
(c) quantitative standards;
(d) adjustments to Market Risk Capital Requirements;
(e) stress testing; and
(f) combination of internally developed models and the Standardised Methodology.
15. In addition to VaR models, the AFSA is open to considering the use of option risk aggregation models and interest rate ‘pre-processing’ or sensitivity models, Option risk aggregation models analyse and aggregate options risks for interest rate, equity, foreign exchange and commodity options. Interest rate pre-processing models are used to calculate weighted positions for inclusion in a Bank’s interest rate Market Risk Capital Requirement calculation under the Duration Method.
16. Any internal model used for purposes of Chapter 6 of BBR should be conceptually sound and implemented with integrity and, in particular, all of the following qualitative requirements should be met:
(a) any internal model used to calculate Market Risk Capital Requirements for equity risk, interest rate risk, foreign exchange risk or commodities risk should be closely integrated into the daily risk management process and serve as the basis for reporting risk Exposures to senior management;
(b) the Bank should have a risk control unit that is independent from business trading units and reports directly to senior management. The unit should be responsible for designing and implementing any internal model used for purposes of Chapter 6 of BBR. The unit should conduct the initial and on-going validation of any such internal models. The unit should produce and analyse daily reports on the output of any internal model used for calculating Capital Requirements for position risk, foreign exchange risk and commodities risk, and on the appropriate measures to be taken in terms of trading limits;
(c) the Bank's Governing body and senior management should be actively involved in the risk control process and the daily reports produced by the risk control unit are reviewed by a level of management with sufficient authority to enforce both reductions of positions taken by individual traders as well as in the Bank's overall risk Exposure;
(d) the Bank should have established procedures for monitoring and ensuring compliance with a documented set of internal policies and controls concerning the overall operation of its internal models;
(e) the Bank should frequently conduct a rigorous programme of stress testing, including reverse stress tests, which encompasses any internal model used for purposes of Chapter 6 of BBR and the results of these stress tests should be reviewed by senior management and reflected in the policies and limits it sets. This process should particularly address illiquidity of markets in stressed market conditions, concentration, one way markets, event and jump-to-default risks, non-linearity of products, deep out-of-the-money positions, positions subject to the gapping of prices and other risks that may not be captured appropriately in the internal models. The shocks applied should reflect the nature of the portfolios and the time it could take to hedge out or manage risks under severe market conditions; and
(f) the Bank should conduct, as part of its regular internal auditing process, an independent review of its internal models.
17. The independent review of the internal models used by a Bank, must include the activities of both the business trading units and of the independent risk-control unit. At least once a year, the Bank should conduct a review of its overall risk management process. The review should consider the following:
(a) the adequacy of the documentation of the risk-management system and process and the organisation of the risk-control unit;
(b) the integration of risk measures into daily risk management and the integrity of the management information system;
(c) the process the Bank employs for approving risk-pricing models and valuation systems that are used by front and back-office personnel;
(d) the scope of risks captured by the risk-measurement model and the validation of any significant changes in the risk-measurement process;
(e) the accuracy and completeness of position data, the appropriateness of volatility and correlation assumptions, and the accuracy of valuation and risk sensitivity calculations;
(f) the verification process used to evaluate the consistency, timeliness and reliability of data sources used to run internal models, including the independence of such data sources; and
(g) the verification process used to evaluate back-testing for the internal models' accuracy.
18. As techniques and best practices evolve, Banks are expected to apply those new techniques and practices in any internal model used for purposes of Chapter 6 of BBR.
19. Any internal model used to calculate Capital Requirements for equity position risk, interest rate risk, foreign exchange risk, commodities risk and any internal model for correlation trading should meet all of the following requirements:
(a) the model must capture accurately reflect, on a continuous basis, all material price risks, including General Market Risks and, where approval has been granted in relation to specific Risk, specific risks arising on the underlying portfolio, and should ensure that sufficient risk factors are properly specified; and
(b) the model should capture a sufficient number of risk factors, depending on the level of activity of the Bank in the respective markets. The risk factors in the model should be sufficient to capture the risks inherent in the Bank’s portfolio of on and off-balance sheet trading positions. The Bank should at least incorporate those risk factors in its model that are incorporated into its pricing model.
(c) The risk-measurement model should capture nonlinearities for options and other products as well as correlation risk and basis risk. Where proxies for risk factors are used they should show a good track record for the actual position held. Although a Bank will have some discretion in specifying the risk factors for its internal models, the AFSA expects that such models will meet the criteria specified in this guideline.
20. Any internal model used to calculate Capital Requirements for position risk, foreign exchange risk or commodities risk should meet all of the following requirements:
(a) the model should incorporate a set of risk factors corresponding to the interest rates in each currency in which the Bank has interest rate sensitive on or off balance sheet positions. The Bank should model the yield curves using one of a number of generally accepted approaches, for example, by estimating forward rates of zero-coupon yields;
(b) for material Exposures to interest-rate risk in the major currencies and markets, the yield curve should be divided into a minimum of six maturity segments, to capture the variations of volatility of rates along the yield curve. The model should also capture the risk of less than perfectly correlated movements between different yield curves. The risk measurement system should incorporate separate risk factors to capture spread risk, for example, between bonds and swaps;
(c) the model should incorporate risk factors corresponding to gold and to the individual foreign currencies in which the Bank's positions are denominated.
(d) for Collective Investment Funds the actual foreign exchange positions of the Fund should be taken into account. Banks may rely on third party reporting of the foreign exchange position of the Fund, where the correctness of this report is adequately ensured. If a Bank is not aware of the foreign exchange positions of a Fund, this position should be carved out of the model and treated separately;
(e) the model should use a separate risk factor at least for each of the equity markets in which the Bank holds significant positions. At a minimum, this will include a risk factor that is designed to capture market-wide movements in equity prices, for example, a market index. Positions in individual securities or in sector indices could be expressed in “beta-equivalents” relative to this market-wide index. A relatively 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. The most extensive approach would be to have risk factors corresponding to the volatility of individual equity issues;
(f) the model should use a separate risk factor at least for each commodity in which the Bank holds significant positions. The model must also capture the risk of less than perfectly correlated movements between similar, but not identical, commodities and the Exposure to changes in forward prices arising from maturity mismatches. It should also take account of market characteristics, notably delivery dates and the scope provided to traders to close out positions; For more actively traded portfolios, the model should also take account of variation in the “convenience yield” between derivative positions such as forwards and swaps and cash positions in the commodity; and
(g) the Bank's internal model should conservatively assess the risk arising from less liquid positions and positions with limited price transparency under realistic market scenarios. In addition, the internal model should meet minimum data standards. Proxies should be appropriately conservative and should be used only where available data is insufficient or is not reflective of the true volatility of a position or portfolio.
21. Banks may use empirical correlations within risk categories and across risk categories only if the Bank's approach for measuring correlations is sound and implemented with integrity.
22. The AFSA will usually approve an internal Value-at-Risk (VaR) model, for the purposes of Chapter 6 of the BBR only when that VaR model meets the following quantitative criteria:
(a) VaR should be computed at least 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 VaR, an instantaneous price shock equivalent to a 10 day movement in prices is to be used, i.e., the minimum "holding period" will be 10 trading days;
(d) an effective historical observation period of at least one year except where a shorter observation period is justified by a significant upsurge in price volatility; and
(e) its data set is updated by the Bank no less frequently than once every month and is reassessed whenever market prices are subject to material changes.
23. A bank may use VaR numbers calculated according to shorter holding periods than 10 days scaled up to 10 days by an appropriate methodology.
24. The AFSA prescribes no particular type of model so long as the model used captures all the material exposures of the Bank. The Bank will be free to use models based, for example, on variance- covariance matrices, historical simulations, or Monte Carlo simulations. Banks have discretion to recognise empirical correlations within broad risk categories, for example, interest rates, exchange rates, equity prices and commodity prices, including related options volatilities in each risk factor category.
25. A Bank's internal models should accurately capture the unique risks associated with options within each of the broad risk categories. A Bank should calculate, on a daily basis, its Market Risk Capital Requirement or any component for which an internal model is used, expressed as the higher of (a)
its previous day's VaR number measured according to the parameters specified in this section and
(b) an average of the daily VaR measures on each of the preceding sixty business days, multiplied by a multiplication factor.
26. The AFSA will usually set a multiplication factor of 3 that must be used by the Bank where all the qualitative and quantitative criteria are satisfied. This will be imposed as a condition on the approval and may be varied by the AFSA should circumstances require.
27. A Bank using internal VaR models is expected to calculate a ‘Stressed VaR' of the current portfolio, at least on a weekly basis, in addition to the calculation of VaR in accordance with the requirements set out in this section. The VaR model inputs for calculation of Stressed VaR should ideally be calibrated to historical data from a continuous 12-month period of significant financial stress relevant to the Bank's portfolio. The choice of such historical data should be subject to review by the Bank, at least on an annual basis and the outcome of such a review must be notified to the AFSA promptly.
28. A Bank using an internal model should calculate Capital Requirement for the relevant risk categories, as the sum of points (a) and (b):
(a) the higher of:
i) its previous day's VaR number calculated in accordance with the guidance in this section; or
ii) an average of the daily VaR numbers calculated in accordance with the guidance in this section, on each of the preceding sixty business days (AvgVaR), multiplied by the multiplication factor referred in paragraph 26 above; plus
(b) the higher of:
i) its latest available stressed VaR number calculated in accordance with guidance in this section (sVaRt-1); or
ii) an average of the stressed VaR numbers calculated in accordance with the guidance in this section, over the preceding sixty business days (Avg sVaR), multiplied by the multiplication factor referred in Guidance note 16 above.
Regulatory back-testing and multiplication factors
29. The results of the Stressed VaR calculations referred in this section must be scaled up by the multiplication factors given below. The multiplication factor referred above is defined as the sum of 3 and an addend between 0 and 1. That addend should depend on the number of violations for the most recent 250 business days as evidenced by the Bank’s back-testing of the VaR as set out in the guidance in this section.
Number of violations | addend |
Fewer than 5 | 0.00 |
5 | 0.40 |
6 | 0.50 |
7 | 0.65 |
8 | 0.75 |
9 | 0.85 |
10 or more | 1.00 |
For example, if the number of violations (as defined in the following paragraph) observed on the back- testing results of a Bank over the most recent 250 business days is 6, then the multiplication factor to scale the Stressed VaR result would be 3.5. This is determined by adding 3 with the addend from the table for 6 violations, which is 0.5. So, if the calculated stressed VaR for the Bank is USD 300 million, then it must be scaled up to a stressed VaR of USD 1050 million (3.5*300 million). This clearly points to the penalizing impact of the scaling factor for models which perform poorly in back testing. The minimum scaling factor is 3, even if the number of violations observed over the most recent 250 business days happens to be 0.
… Please provide an example of application the above table.
30. A Bank should count daily violations on the basis of back-testing on hypothetical and actual changes in the portfolio's value. A violation for this purpose is defined as a one-day change in the portfolio's value that exceeds the related one-day VaR number generated by the Bank's model. For the purpose of determining the addend the number of violations should be assessed at least on a quarterly basis and should be equal to the higher of the number of violations under hypothetical and actual changes in the value of the portfolio.
31. Back-testing on hypothetical changes in the portfolio's value should be based on a comparison between the portfolio's end-of-day value and, assuming unchanged positions, its value at the end of the subsequent day. Back-testing on actual changes in the portfolio's value should be based on a comparison between the portfolio's end-of-day value and its actual value at the end of the subsequent day excluding fees, commissions, and net interest income.
32. The AFSA may in individual cases limit the addend to that resulting from violations under hypothetical changes, where the number of violations under actual changes does not result from deficiencies in the internal model. In order to enable the AFSA to monitor the appropriateness of the multiplication factors on an ongoing basis, the Bank should notify any violations that result from its back-testing programme promptly, and in any case no later than five working days from the date of its identification.
33. Banks should have processes in place to ensure that all their internal models have been adequately validated by suitably qualified parties independent of the development process to ensure that they are sound and adequately capture all material risks. The validation should be conducted when the internal model is initially developed and when any significant changes are made to the internal model.
34. The validation should also be conducted on a periodic basis, especially where there have been significant structural changes in the market or changes to the composition of the portfolio which might result in the internal model being no longer adequate. As techniques and best practices for internal validation evolve, Banks are expected to apply such improvements. Internal model validation should not be limited to back-testing, 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 or overestimate the risk;
(b) Banks should carry out their own internal model validation tests, including back-testing, in relation to the risks and structures of their portfolios; and
(c) the use of hypothetical portfolios to ensure that the internal model is able to account for particular structural features that may arise, for example material basis risks and concentration.
35. The Bank should perform back-testing on both actual and hypothetical changes in the portfolio's value. An internal model used for calculating Capital Requirements for specific risk and an internal model for correlation trading should meet the following additional requirements:
(a) it explains the historical price variation in the portfolio;
(b) it captures concentration in terms of magnitude and changes of composition of the portfolio;
(c) it is robust to an adverse environment;
(d) it is validated through back-testing aimed at assessing whether specific risk is being accurately captured. If the Bank performs such back-testing on the basis of relevant sub- portfolios, these must be chosen in a consistent manner;
(e) it captures name-related basis risk and should in particular be sensitive to material idiosyncratic differences between similar, but not identical, positions; and
(f) it captures event risk.
36. A Bank may choose to exclude from the use of its internal model for calculation of its specific risk Capital Requirement, those positions for which it calculates the Capital Requirement for specific Risk in accordance with relevant sections of Chapter 6 of BBR. A Bank may choose not to capture default and migration risks for debt instruments in its internal model where it is capturing those risks through internal models for incremental default and migration risk.
E. Incremental risk charge (IRC) model
37. A Bank that uses an internal model for calculating Capital Requirements for specific risk of interest rate risk Exposures should also have an internal incremental default and migration risk (incremental risk charge, or IRC) model in place to capture the default and migration risks of its Trading Book positions that are incremental to the risks captured by the VaR measure as specified in paragraph 22 above.
38. A Bank is expected to demonstrate that its internal model meets soundness standards comparable to that expected under the Basel III standard for the Internal Ratings Based (IRB) approach for Credit Risk under the assumption of a constant level of risk, and adjusted where appropriate to reflect the impact of liquidity, concentrations, hedging and optionality.
39. The internal IRC model should cover all positions subject to a Capital Requirement for specific interest rate risk, including those subject to a 0% specific Risk capital charge using the Standard method, but should not cover securitisation positions and n-th-to-default Credit Derivatives.
40. A Bank may, subject to approval by the AFSA, choose to include consistently all listed equity positions and derivatives positions based on listed equities. The permission will be granted only if such inclusion is consistent with how the Bank internally measures and manages risk.
41. Banks should use the internal model to calculate a number which measures losses due to default and internal or external ratings migration at the 99.9 % confidence interval over a time horizon of one year. Banks should calculate this number at least weekly. Correlation assumptions should be supported by analysis of objective data in a conceptually sound framework. The internal model should appropriately reflect issuer concentrations including those that can arise within and across product classes under stressed conditions.
42. The internal IRC model should reflect the impact of correlations between default and migration events. The impact of diversification between, on the one hand, default and migration events and, on the other hand, other risk factors should not be reflected.
43. The internal model should be based on the assumption of a constant level of risk over the one- year time horizon, implying that given individual Trading Book positions or sets of positions that have experienced default or migration over their liquidity horizon are re-balanced at the end of their liquidity horizon to attain the initial level of risk. Alternatively, a Bank may choose to consistently use a one-year constant position assumption.
44. The liquidity horizons should be set according to the time required to sell the position or to hedge all material relevant price risks in a stressed market, having particular regard to the size of the position. Liquidity horizons should reflect actual practice and experience during periods of both systematic and idiosyncratic stresses. The liquidity horizon should be measured under conservative assumptions and should be sufficiently long that the act of selling or hedging, in itself, would not materially affect the price at which the selling or hedging would be executed.
45. The appropriate liquidity horizon for a position or set of positions is subject to a floor of three months. The determination of the appropriate liquidity horizon for a position or set of positions should take into account a Bank's internal policies relating to valuation adjustments and the management of stale positions. When a Bank determines liquidity horizons for sets of positions rather than for individual positions, the criteria for defining sets of positions should be defined in a way that meaningfully reflects differences in liquidity. The liquidity horizons should be greater for positions that are concentrated, reflecting the longer period needed to liquidate such positions. The liquidity horizon for a securitisation warehouse should reflect the time to build, sell and securitise the assets, or to hedge the material risk factors, under stressed market conditions.
46. Hedges may be incorporated into a Bank's internal model to capture the incremental default and migration risks. Positions may be netted when long and short positions refer to the same financial instrument. Hedging or diversification effects associated with long and short positions involving different instruments or different securities of the same obligor, as well as long and short positions in different issuers, may only be recognised by explicitly modelling gross long and short positions in the different instruments. Banks should reflect the impact of material risks that could occur during the interval between the hedge's maturity and the liquidity horizon as well as the potential for significant basis risks in hedging strategies by product, seniority in the capital structure, internal or external rating, maturity, vintage and other differences in the instruments. A Bank should reflect a hedge only to the extent that it can be maintained even as the obligor approaches a credit or other event.
47. For positions that are hedged via dynamic hedging strategies, a rebalancing of the hedge within the liquidity horizon of the hedged position may be recognised, provided that the Bank:
(a) chooses to model rebalancing of the hedge consistently over the relevant set of Trading Book positions;
(b) demonstrates that the inclusion of rebalancing results in a better risk measurement; and
(c) demonstrates that the markets for the instruments serving as hedges are liquid enough to allow for such rebalancing even during periods of stress. Any residual risks resulting from dynamic hedging strategies must be reflected in the Capital Requirement.
48. The internal model to capture the incremental default and migration risks should reflect the nonlinear impact of options, structured credit derivatives and other positions with material nonlinear behaviour with respect to price changes. The Bank should also have due regard to the amount of model risk inherent in the valuation and estimation of price risks associated with such products.
49. The internal model should be based on data that are objective and up-to-date. As part of the independent review and validation of their internal models used for purposes of this Chapter, a bank should in particular do all of the following:
(a) validate that its modelling approach for correlations and price changes is appropriate for its portfolio, including the choice and weights of its systematic risk factors;
(b) perform a variety of stress tests, including sensitivity analysis and scenario analysis, to assess the qualitative and quantitative reasonableness of the internal model, particularly with regard to the treatment of concentrations. Such tests should not be limited to the range of events experienced historically; and
(c) apply appropriate quantitative validation, including relevant internal modelling benchmarks.
50. The internal model should be consistent with the Bank's internal risk management methodologies for identifying, measuring, and managing trading risks. The Bank should document its internal models so that their correlation and other modelling assumptions are transparent to the AFSA.
51. The internal model should conservatively assess the risk arising from less liquid positions and positions with limited price transparency under realistic market scenarios. In addition, the internal model should meet minimum data standards. Proxies should be appropriately conservative and may be used only where available data is insufficient or is not reflective of the true volatility of a position or portfolio.
52. If a Bank uses an internal model to capture incremental default and migration risks that does not comply with all requirements specified in this Guideline, but that is consistent with the Bank's internal methodologies for identifying, measuring and managing incremental default and migration risks, it should be able to demonstrate that its internal model results in a Capital Requirement that is at least as high as if it were based on a model in full compliance with the requirements of the Guidance notes referred above. The AFSA will review compliance with the previous sentence at least annually.
53. The AFSA will grant permission to use an internal model for calculating the Capital Requirement for a correlation trading portfolio only to Banks that have obtained the AFSA’s approval to use an internal model for specific risk of interest rate risk t Rate Risk Exposures and that meet the requirements for internal models specified earlier in this section.
54. Banks should use this internal model to calculate a number which adequately measures all price risks at the 99.9 % confidence interval over a time horizon of one year under the assumption of a constant level of risk, and adjusted where appropriate to reflect the impact of liquidity, concentrations, hedging and optionality. Banks should calculate this number at least weekly. The following risks should be adequately captured by the internal model for correlation trading:
(a) the cumulative risk arising from multiple defaults, including different ordering of defaults, in tranched products;
(b) credit spread risk, including the gamma and cross-gamma effects;
(c) volatility of implied correlations, including the cross effect between spreads and correlations;
(d) basis risk, including both of the following:
i) the basis between the spread of an index and those of its constituent single names; and
ii) the basis between the implied correlation of an index and that of bespoke portfolios;
(e) recovery rate volatility, as it relates to the propensity for recovery rates to affect tranche prices;
(f) to the extent the comprehensive risk measure incorporated benefits from dynamic hedging, the risk of hedge slippage and the potential costs of rebalancing such hedges; and
(g) any other material price risks of positions in the correlation trading portfolio.
55. A Bank should use sufficient market data within their internal model for correlation trading, in order to ensure that it fully captures the salient risks of those Exposures in its internal approach in accordance with the requirements set out in this guidance. The Bank should be able to demonstrate to the AFSA through back testing or other appropriate means that its model can appropriately explain the historical price variation of those products.
56. The Bank should have appropriate policies and procedures in place in order to separate the positions for which it holds permission to incorporate them in the Capital Requirement in accordance with this Guideline from other positions for which it does not hold such permission.
57. With regard to the portfolio of all the positions incorporated in the internal model for correlation trading, the Bank should regularly apply a set of specific, predetermined stress scenarios. Such stress scenarios should examine the effects of stress to default rates, recovery rates, credit spreads, basis risk, correlations and other relevant risk factors on the correlation trading portfolio. The Bank should apply stress scenarios at least weekly and report at least quarterly to the AFSA the results, including comparisons with the Bank's Capital Requirement in accordance with this point. Any instances where the stress test results materially exceed the Capital Requirement for the correlation trading portfolio should be reported to the AFSA in a timely manner.
58. The internal model should conservatively assess the risk arising from less liquid positions and positions with limited price transparency under realistic market scenarios. In addition, the internal model should meet minimum data standards. Proxies should be appropriately conservative and may be used only where available data is insufficient or is not reflective of the true volatility of a position or portfolio.
F. Stress testing
59. For the purposes of BBR Rule 6.7 (4), the AFSA will expect a Bank’s internal model to meet the following criteria:
(a) the Bank's stress scenarios must 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;
(b) the Bank's stress tests must be both of a quantitative and qualitative nature, incorporating both Market Risk and liquidity aspects of market disturbances. Quantitative criteria must identify plausible stress scenarios to which the Bank could be exposed. Qualitative criteria must 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; and
(c) the Bank must combine the use of supervisory stress scenarios with stress tests developed by the Bank itself to reflect their specific Risk characteristics. Information is required in three broad areas:
(i) supervisory scenarios requiring no simulations by the Bank - the Bank must have information on the largest losses experienced during the reporting period available for supervisory review. This loss information must be compared to the level of capital that results from a bank's internal measurement system;
(ii) supervisory scenarios requiring a simulation by the Bank – the Bank must subject its portfolio to a series of simulated stress scenarios and provide the AFSA with the results (e.g., the sensitivity of the Bank’s Market Risk Exposure to changes in the assumptions about volatilities and correlations); and
(iii) scenarios developed by the Bank itself to capture the specific characteristics of its portfolio.
60. In addition to the scenarios prescribed under 52(c) above, a Bank must also develop its own stress tests which it identifies as most adverse, based on the characteristics of its portfolio, for example, problems arising in a key region of the world combined with a sharp move in oil prices. The Bank must also provide the AFSA 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.
G. Calculation of Foreign Exchange Risk Capital Requirement
61. This section of the BPG sets out the standards, methodology, formulae and parameters to be employed by a Bank in calculating the Foreign Exchange risk capital requirements, specified in BBR Rule 6.5 (1) (C). These elements constitute the framework which the AFSA would use to assess compliance with BBR Rules requiring a Bank to maintain adequate capital to support its foreign exchange risk exposures. In order to ensure compliance with the requirement under this Rule and to demonstrate adequacy of capital to address foreign exchange risk exposures, the AFSA expects a Bank to follow the methodology specified in this section.
62. In measuring its Market risk, a Bank must include the risk of holding or taking positions in foreign currencies and gold (foreign exchange risk). Foreign exchange risk may arise from the Bank’s trading in the foreign exchange market and other markets; it may also arise from non-trading activities that are denominated in a foreign currency.
63. If a Bank is exposed to interest rate risk on positions in foreign currencies and gold, the Bank must include the relevant interest rate positions in the calculation of interest rate risk. Gold is dealt with as a foreign exchange position (rather than as a commodity position) because the volatility of its prices is similar to that of a currency. If foreign currency is to be received or delivered under a forward contract, the Bank must report any interest rate exposure from the other leg of the contract in accordance with the section on traded interest rate risk in this BPG. If gold is to be received or delivered under a forward contract, the Bank must report any foreign currency or interest rate exposure from the other leg of the contract in accordance with this section or the section on traded interest rate risk in this BPG, respectively.
64. In calculating the capital charge for foreign exchange risk, a Bank must include in its exposure to each foreign currency:
(a) the net spot position (that is, all assets minus all liabilities denominated in the currency, including accrued interest and other accrued income and accrued expenses);
(b) the net forward position (that is, all amounts to be received less all amounts to be paid under forward foreign exchange transactions denominated in the currency, including currency futures and the principal on currency swaps not included in the spot position);
Examples of amounts to be received or paid
● payments under currency futures
● the principal on currency swaps not included in the spot position
● interest from futures, swaps and other interest rate transactions.
(c) irrevocable guarantees (and similar instruments) that are certain to be called and likely to be irrecoverable;
(d) net future income/expenses not yet accrued but already fully hedged, at the discretion of the Bank; and
(e) any other items representing a profit or loss in foreign currencies or an exposure to risk in foreign currencies (for example, a specific provision held in the currency in question where the underlying asset is held in a different currency).
65. The Bank may also include in its currency exposure any net future income or expenses that are not yet accrued but already fully hedged. If the Bank includes such income or expenses, it must do so consistently and must not select only expected future flows that reduce its position.
66. If the Bank has deliberately taken a position to partly or totally protect itself against the adverse effect of a change in an exchange rate on its capital adequacy ratio, it may exclude the position from its currency exposure insofar as it relates to that hedge, if:
(a) the position is of a structural and non-trading nature;
(b) the structural position does no more than protect the Bank’s capital adequacy ratio;
(c) the position cannot be traded for speculative or profit-making purposes; and
(d) the exclusion of the position is done consistently, with the treatment of the hedge remaining the same for the life of the assets or other items.
67. A structural position includes:
(a) a position arising from an instrument that satisfies the criteria for inclusion as capital under Chapter 4 of BBR;
(b) a position in relation to a net investment in a self-sustaining subsidiary, the accounting consequence of which is to reduce or eliminate what would otherwise be a movement in the foreign currency translation reserve; and
(c) an investment in an overseas subsidiary or other entity in the same corporate group as the Bank that, under these Rules, is deducted from the Bank’s capital for capital adequacy purposes.
68. A Bank must include any currency exposures arising from equity, commodity and interest positions as well as interest accrued and accrued expenses as positions. If a Bank includes future income/expenses it must do so on a consistent basis and not include only those expected future flows that reduce its position.
69. A Bank may exclude any positions which it has deliberately taken in order to hedge partially or totally against the adverse effect of the exchange rate on its Capital Resources, from the calculation of net open currency positions, if each of the following conditions is met:
(a) the positions are of a structure that is of a non-dealing nature;
(b) the Bank has notified the AFSA in writing of its intention to rely upon this Rule; and
(c) any exclusion of the position must be applied consistently, with the treatment of the hedge remaining the same for the life of the assets or other items.
70. A Bank need not include positions related to items which are deducted from its capital when calculating its Capital Resources, including investments in non-consolidated subsidiaries; or other long-term participations denominated in Foreign Currencies which are reported in the published accounts at historic cost.
71. If a Bank is assessing its foreign exchange risk on a consolidated basis, and the inclusion of the currency positions of a marginal operation of the Bank is technically impractical, the Bank may use, as a proxy for those positions, the internal limit in each currency that the Bank applies to the operation. Marginal operation, in relation to a Bank, is an operation that accounts for less than 5% of the Bank’s total currency positions. The absolute values of the limits must be added to the net open position in each currency, but only if the actual positions are adequately monitored against those internal limits.
72. For a Bank that does not write options, net open position in a foreign currency is the sum of:
(a) the Bank’s currency exposures as specified in Section E of this BPG for the currency; and
(b) the value of the options and their associated underlying assets measured using the simplified approach for options risk capital requirement specified in this BPG.
73. For a Bank that writes options, net open position in a foreign currency is the sum of:
(a) the Bank’s currency exposures as specified in Section E of this BPG for the currency; and
(b) either:
(i) the net delta-based equivalent of the Bank’s total book of foreign currency options (with separately calculated capital charges for gamma risk and vega risk under Division 6.3.C); or
(ii) the value of the options and their associated underlying assets under the delta-plus method in Division 6.3.C.
74. A Bank must calculate its overall foreign currency net open position by:
(a) calculating the net open position in each foreign currency;
(b) converting the nominal amount (or net present value) of each such net position into the reporting currency at the current spot market exchange rate;
(c) adding all short net positions and adding all long net positions calculated under paragraphs
(a) and (b); and
(d) selecting the greater of the absolute values of the two sums (total of all net short positions and total of all net long positions) referred in (c) above of this paragraph.
75. The Bank must then calculate its net position in gold by:
(a) valuing all gold positions using the reporting currency at current spot price (regardless of maturity); and
(b) offsetting long and short positions
76. A Bank must value forward currency and gold positions at the current spot market exchange rates and report positions in a currency pair separately as if each were a currency on its own.
77. The capital charge for foreign exchange risk of a Bank is the sum of:
(a) 8% of the Bank’s overall foreign currency net open position in each of the foreign currencies it holds; and
(b) 8% of its net position in gold.
H. Calculation of Interest Rate Risk Capital Requirement
78. This section of the BPG sets out the standards, methodology, formulae and parameters to be employed by a Bank in calculating the Interest Rate risk capital requirements, specified in BBR Rule
6.5 (1) (a). These elements constitute the framework which the AFSA would use to assess compliance with BBR Rules requiring a Bank to maintain adequate capital to support its traded interest rate risk exposures. In order to ensure compliance with the requirement under this Rule and to demonstrate adequacy of capital to address foreign exchange risk exposures, the AFSA expects a Bank to follow the methodology specified in this section. In measuring its Market risk, a banking business Bank must include the risk of holding or taking positions in debt securities and other interest- rate-related instruments that are held in the Trading Book (interest rate risk).
79. The measurement of interest rate risk in the Trading Book applies to all fixed-rate and floating-rate debt securities and other interest-rate-related instruments that exhibit market behaviour similar to debt securities. Examples of such instruments would include non-convertible preference shares and convertible bonds that trade like debt securities. A debt security that is the subject of a repurchase or securities lending agreement is taken to be owned by the lender of the security.
80. In calculating the capital charge for interest rate risk, a banking business Bank must include interest rate exposures arising from forward foreign exchange transactions and forward sales and purchases of commodities and equities. The Bank must also include any interest rate exposures arising from foreign exchange, equity and commodity positions.
Capital charge—interest rate risk
81. The capital charge for general risk is for the risk of loss arising from changes in market interest rates. The capital charge for interest rate risk is calculated as the sum of 2 separate charges:
(a) a charge for the specific risk of holding a long or short position in an individual instrument; and
(b) a charge for the general risk of holding a long or short position in the market as a whole.
Specific risk capital charge—interest rate risk
82. The capital charge for specific risk arising from an on-balance-sheet or off-balance-sheet interest- rate position held in a banking business Bank’s Trading Book is calculated by multiplying the market value of the debt security by the applicable charge set out in column 5 of table F1 for the category and residual maturity of the instrument.
83. The Bank may offset matched long and short positions (including positions in derivatives) in identical instruments with exactly the same issuer, coupon, currency and maturity.
Table F1 specific risk capital charges
column 1 item | column 2 category | column 3 external credit rating | column 4 residual maturity | column 5 specific risk capital charge (%) |
1 | government | AAA to AA- | 0.00 | |
A+ to BBB- | 6 months or less more than 6 months and up to and including 24 months more than 24 months | 0.25 1.00 1.60 | ||
BB+ to B- or unrated | 8.00 | |||
Below B- | 12.00 | |||
2 | qualifying | 6 months or less more than 6 months and up to and including 24 months more than 24 months | 0.25 1.00 1.60 | |
3 | other | BB+ to BB- or unrated Below BB- | 8.00 12.00 |
84. In column 2 of table F1:
government, as a category, includes all forms of government paper such as bonds, treasury bills and other short-term instruments.
qualifying, as a category, includes:
(a) securities issued by public sector enterprises and multilateral development banks;
(b) instruments rated investment grade by at least 2 ECRAs;
(c) instruments rated investment grade by 1 ECRA and 1 other credit rating agency that is not an ECRA; and
(d) unrated instruments, but only if:
(i) the banking business Bank has no reason to suspect that the particular instrument would have a rating less than investment grade if it were rated; and
(ii) the issuer of the instrument is rated investment grade and is regulated in its home jurisdiction in a way comparable to banks in the AIFC.
85. In deciding whether an issuer is regulated in a comparable way, the bank must look, in particular, at the home jurisdiction’s risk-based capital requirements and consolidated supervision.
other, as a category, includes:
(a) instruments issued or fully guaranteed by the central government or central bank of a state that is a member of the OECD;
(b) instruments fully collateralised by instruments described in paragraph (a); and
(c) instruments issued or fully guaranteed by the central government or central bank of a state that is not a member of the OECD, but only if:
(i) the instruments have a residual maturity of 1 year or less;
(ii) the instruments are denominated in the local currency of the issuer; and
(iii) the banking business Bank’s holdings in such instruments are funded by
liabilities in the same currency.
(d) In column 3 of table F 1, external credit rating means a long-term rating issued by an ECRA for the purpose of risk-weighting claims on rated counterparties and exposures.
86. Interest rate swaps, cross-currency swaps, forward rate agreements, forward foreign exchange transactions, interest rate futures and futures on an interest rate index are exempt from charges for specific risk. However, a specific risk capital charge must be calculated if the underlying is a debt security or an index representing a basket of debt securities. Futures and forward contracts, other than those mentioned in this paragraph are exempt from specific risk capital charge if:
(a) the Bank has a right to substitute cash settlement for physical delivery under the contract; and
(b) the price on settlement is calculated with reference to a general market price indicator.
Such contracts exempt from specific risk capital charge must not be offset against specific securities (including those securities that make up a market index).
General Risk Capital charge—interest rate risk
87. General risk is measured using the maturity method. In that method, positions are allocated to a maturity ladder before the capital charge is calculated. The Bank must add the absolute values of the individual net positions within each time band, whether long or short. The sum of the absolute values is the Bank’s gross position.
Maturity method
88. In the maturity method, long or short positions in debt securities (and in other sources of interest rate exposures such as derivative instruments) are allocated to the time bands in table F 2 (and then to the zones in table F 3) based on the residual maturity of the instrument and the interest rate of coupon payments. A Bank must allocate:
(a) positions in fixed-rate instruments according to their residual term to maturity; and
(b) positions in floating-rate instruments according to the residual term to the next re-pricing date.
89. The Bank may offset:
(a) long and short positions (whether actual or notional) in identical instruments with exactly the same issuer, coupon, currency and maturity; and
(b) matched swaps, forward contracts, futures and forward rate agreements that satisfy the criteria for matching derivative positions detailed later in this section F.
90. The steps to calculate the general risk capital charge are:
Step 1: Weight the positions in each time band by the risk factor corresponding to those positions in table F2.
Table F2 Time Bands and risk factors
column 1 item | column 2 time band | column 3 risk factor % | column 4 assumed changes in yield % |
1 | 1 month or less | 0.00 | 1.00 |
2 | more than 1 and up to 3 months | 0.20 | 1.00 |
3 | more than 3 and up to 6 months | 0.40 | 1.00 |
4 | more than 6 and up to 12 months | 0.70 | 1.00 |
5 | more than 1 and up to 2 years | 1.25 | 0.90 |
6 | more than 2 and up to 3 years | 1.75 | 0.80 |
7 | more than 3 and up to 4 years | 2.25 | 0.75 |
8 | more than 4 and up to 5 years | 2.75 | 0.75 |
9 | more than 5 and up to 7 years | 3.25 | 0.70 |
10 | more than 7 and up to 10 years | 3.75 | 0.65 |
11 | more than 10 and up to 15 years | 4.50 | 0.60 |
12 | more than 15 years and up to 20 years | 5.25 | 0.60 |
13 | more than 20 years | 6.00 | 0.60 |
Step2: Offset the weighted long and short positions within each time band.
Example: If the sum of the weighted long positions in a time band is USD 100 million and the sum of the weighted short positions in the band is USD 90 million, you offset the positions to come up with a matched position of USD 90 million and unmatched position of USD 10 million.
Step 3: For each time band, apply a 10% capital charge (vertical disallowance) on the matched position calculated in step 2.
Example: Continuing on from the example in step 2, apply the 10% on the QR90 million matched position to come up with a QR9 million vertical disallowance for the time band.
Step 4: For the unmatched positions calculated in step 2, carry out 2 further rounds of offsetting using the zones (made up of time bands) in table F3 and apply the appropriate capital charge, as follows:
(a)first between the remaining unmatched positions within each of 3 zones and subject to a charge (expressed as a percentage) as follows:
(i)matched weighted positions within zone 1 x 40%;
(ii)matched weighted positions within zone 2 x 30%;
(iii)matched weighted positions within zone 3 x 30%;
(b)subsequently between the remaining unmatched positions across the three different zones (in the order set out below) and subject to a capital charge as follows:
(i)matched weighted positions between zones 1 and 2 x 40%;
(ii)matched weighted positions between zones 2 and 3 x 40%;
(iii)matched weighted positions between zones 1 and 3 x 100%.
Step 5: The absolute value of the net amount remaining is the net position.
Table F 3 Zones for coupons
column 1 item | column 2 zone | column 3 time bands |
1 | zone 1 | 1– 1 month 2– 3 months 3 – 6 months 6 – 12 months |
2 | zone 2 | 1– 2 years 2– 3 years 3– 4 years |
3 | zone 3 | 4 – 5 years 5 – 7 years 7 – 10 years |
10 – 15 years 15 – 20 years more than 20 years |
Step 6: Calculate the horizontal allowance by adding the charges from paragraphs (a) and (b) of step 4.
Step 7: Calculate the general risk capital charge as the sum of:
(a) the net position calculated from steps 1 to 4;
(b) the vertical disallowance from step 3;
(c) the horizontal disallowance from steps 4 and 5; and
(d) the net charge for positions in options, where appropriate, calculated in accordance with the guidelines on options risk in this BPG.
Positions in currencies
91. A Bank must use separate maturity ladders for positions in each currency, with capital charges calculated separately for each currency and then summed. Positions in different currencies are not to be offset. If the Bank’s position in a currency is less than 5% of the value of the Bank’s banking book assets, that currency is taken to be a residual currency and the Bank may use a single maturity ladder for all residual currencies (instead of having to use separate maturity ladders for each currency). The Bank must enter, into each appropriate time band, the net long or short position for residual currencies. The Bank must apply, with no further offsets, the risk factor in column 3 of table 6.6.8A to the position in each time band for residual currencies.
Futures and forward contracts
92. A Bank must treat futures and forward contracts on bank or corporate debt (including forward rate agreements) as a combination of a long and a short position in the underlying debt security. Futures and forward contracts not on bank or corporate debt must be treated as a combination of a long and a short position in a notional government security.
93. The maturity of a futures contract or a forward rate agreement is the period until delivery or exercise of the contract, plus the life of the underlying (or notional underlying) instrument. The Bank must report the long and short positions at the market value of the underlying (or notional underlying) security or portfolio of securities. If a range of instruments may be delivered to fulfil a contract, the Bank may choose the deliverable security to be allocated to the maturity ladder. The Bank must, however, take account of any conversion factor specified by the exchange where the instrument must be delivered.
Swaps
94. A Bank must treat a swap as two notional positions in government securities with maturities. Both legs of the swap must be reported at their market values. For swaps that pay or receive a fixed or floating interest rate against some other reference price (for example, a stock index), the Bank must:
(a) enter the interest rate component into the appropriate maturity category; and
(b) include any equity component in the measurement of equity risk.
95. Each leg of a cross-currency swap must be reported in the maturity ladder for the currency concerned. The capital charge for any foreign exchange risk arising from the swaps must be calculated in accordance with the provisions of Section E of this Chapter.
Derivatives
96. In the measurement of interest rate risk, a Bank must include interest rate derivatives and off- balance-sheet instruments in the Trading Book if those instruments react to changes in interest rates. The Bank must convert derivatives into positions in the relevant underlying to enable the Bank to calculate specific and general risk capital charges. To determine the capital charges, the value of the positions must be the market value of the underlying or notional underlying.
97. Positions in derivatives are subject to charges for general risk in the same way as cash positions. However, matched positions are exempt from the charges if the positions satisfy the criteria specified in the rest of this section. Positions in derivatives must be allocated to a maturity ladder and treated in accordance with this Rule and the maturity method.
Criteria for matching derivative positions
98. A Bank may offset a matched position in derivatives if the positions relate to the same underlying instruments, have the same nominal value and are denominated in the same currency. For futures, the positions in the underlying (or notional underlying) instruments must be for identical products and must mature within 7 days of each other.
99. For swaps, forward rate agreements and forward contracts:
(a) the reference rate (for floating-rate positions) must be identical and the coupons must differ by no more than 15 basis points; and
(b) the next interest-fixing date (or, for fixed-coupon positions or forward contracts, the residual maturity) must comply with the following requirements:
(i) if either instrument has an interest-fixing date or residual maturity up to and including 1 month in the future, the dates or residual maturities must be the same for both instruments;
(ii) if either instrument has an interest-fixing date or residual maturity more than 1 month, but no more than 1 year, in the future, the dates or residual maturities must be within 7 days of each other;
(iii) if either instrument has an interest-fixing date or residual maturity more than 1 year in the future, the dates or residual maturities must be within 30 days of each other.
100. A Bank that writes options may offset the delta- equivalent values of options (including the delta- equivalent value of legs arising out of the treatment of caps and floors in accordance with the provisions on options risk in this Chapter. However, for offsetting between a matched position in a futures or forward contract and its underlying, the provisions of the following paragraphs apply.
101. A Bank may offset long and short positions (whether actual or notional) in identical instruments with exactly the same issuer, coupon, currency and maturity and may offset a matched position in a futures or forward contract and its corresponding underlying. The net position must be reported. The Bank may offset positions in a futures or forward contract with a range of deliverable instruments and the corresponding underlying only if:
(a) there is a readily identifiable underlying security; and
(b) the price of that security and the price of the futures or forward contract move in close alignment.
102. The Bank must treat each leg of a cross-currency swap or forward foreign exchange transaction as a notional position in the relevant instrument, and must include the position in the calculation for each currency.
I. Calculation of Equity Risk Capital Requirement
103. This section of the BPG sets out the standards, methodology, formulae and parameters to be employed by a Bank in calculating the Equity risk capital requirements, specified in BBR Rule 6.5
(1) (b). These elements constitute the framework which the AFSA would use to assess compliance with BBR Rules requiring a Bank to maintain adequate capital to support its equity risk exposures. In order to ensure compliance with the requirement under this Rule and to demonstrate adequacy of capital to address equity risk exposures, the AFSA expects a Bank to follow the methodology specified in this section.
104. In measuring its Market risk, a Bank must include the risk of holding or taking positions in equities (equity position risk). In respect of options with equities as the underlying, Section I of this Chapter should be followed. If equities are to be received or delivered under a forward contract, the Bank must report any foreign currency or interest rate exposure from the other leg of the contract in accordance with the relevant section of this Chapter 6 of BPG dealing with Foreign exchange risk capital requirement or interest rate risk capital requirement. If a Bank is exposed to interest rate risk on equity positions, it must include the relevant interest rate positions in the calculation of interest rate risk according to the methodology specified in the section on interest rate risk capital requirement.
105. The measurement of equity position risk in the Trading Book applies to short and long positions in all instruments that exhibit market behaviour similar to equities.
Examples of instruments with equity-like behaviour
(a) common shares (whether voting or non-voting)
(b) convertible securities and commitments to buy or sell equity securities
(c) convertible bonds that trade like equities.
106. A Bank may report short and long positions in instruments relating to the same issuer on a net basis. The Bank must calculate the long or short position in the equity market on a market-by- market basis. That is, the Bank must make a separate capital calculation for each exchange in which it holds equities, irrespective of whether it is a recognised exchange or not.
107. In calculating the capital charge for equity position risk, a Bank must include equity derivatives and off-balance-sheet positions that are affected by changes in equity prices (such as futures and swaps on individual equities and stock indices). To calculate the charges for equity position risk for equity derivatives and other off-balance-sheet positions, the Bank must convert positions into notional equity positions, such that:
(a) equity derivatives and off-balance-sheet positions relating to individual equities are reported at current market prices;
(b) equity derivatives and off-balance-sheet positions relating to stock indices are reported as the mark-to-market value of the notional underlying equity portfolio; and
(c) equity swaps are treated as two notional positions.
Capital Charge for equity risk
108. The capital charge for equity position risk consists of 2 separately calculated charges:
(a) a charge for the specific risk of holding a long or short position in an individual equity; and
(b) a charge for the general risk of holding a long or short position in the market as a whole.
109. The capital charge for specific risk is 8% of the gross position of a Bank in equities listed on a recognised exchange and 12% of the gross position of the Bank in other equities. Gross position, of a Bank in an equity market, is the sum of the absolute values of all short equity positions and all long equity positions of the Bank.
110. The capital charge for general risk is 8% of the net position of a Bank. Net position, of a Bank in an equity market, is the difference between long equity positions and short equity positions of the Bank.
111. Equity position is the net of short and long exposures to an individual company or stock or unit. It is measured on the gross position across the company rather than individual transactions. If a Bank takes a position in depository receipts against an opposite position in the underlying equity, irrespective of whether it is listed in the same country where the receipts were issued or not, it may offset the positions only if any costs on conversion are taken into account in full.
112. The Bank may offset matched positions in an identical equity or stock index in each market, resulting in a single net long or short position to which the specific and general risk capital charges are to be applied. For this purpose, a future in an equity may be offset against an opposite physical position in the same equity.
Charges for index contracts
113. In the case of an index contract on an index considered by the Bank as a diversified index, the Bank must apply a general risk capital charge of 8%, and a specific risk capital charge of 2%, to the net long or short position in the contract. For any other index contract, the Bank must apply a general risk capital charge of 8%, and a specific risk capital charge of 4%, to the net long or short position in the contract.
114. If required to do so by the AFSA, the Bank must demonstrate how the Bank arrived at the assessment that the index is a diversified one and be able to explain the rationale behind that assessment. The index must have a minimum number of equities. There must be an absolute threshold below which the index cannot be considered sufficiently diversified to ignore the specific risk completely. None of the equities must significantly influence the volatility of the index. Equities must not represent more than a certain percentage of the total index value. The index must have equities diversified from a geographical perspective. The index must represent equities that are diversified from an economic perspective. Different ‘industries’ must be represented in the index.
115. If a Bank uses a futures-related arbitrage strategy under which the Bank takes an opposite position in exactly the same index at different dates or in different markets, the Bank:
(a) may apply the 2% specific risk capital charge in paragraph 12 above of this section to only 1 position; and
(b) may exempt the opposite position from any capital charge for specific and general risks.
116. The Bank may also apply the 2% specific risk capital charge if:
(a) the Bank has opposite positions in contracts at the same date in 2 similar indices; and
(b) the AFSA has notified the Bank in writing that the 2 indices have sufficient common components to allow offsetting.
117. If the Bank engages in an arbitrage strategy under which a futures contract on a broadly-based index matches a basket of shares, the Bank:
(a) may decompose the index position into notional positions in each of the constituent stocks; and
(b) may include the notional positions and the disaggregated physical basket in the country portfolio, netting the physical positions against the index equivalent positions in each stock.
118. If the values of the physical and futures positions are matched, the capital charge is 4% (that is, 2% of the gross value of the positions on each side). The Bank may use this provision to apply the 4% capital charge to a position that is part of the arbitrage strategy only if:
(a) a minimum correlation of 0.9 between the basket of shares and the index can be clearly established over at least the preceding year, and the Bank has satisfied the AFSA that the method the Bank has chosen is accurate; or
(b) the composition of the basket of shares represents at least 90% of the index.
119. The Bank must treat any excess value of the shares comprising the basket over the value of the futures contract, or excess value of the futures contract over the value of the basket, as an open long or short position, and must use the approach for index contracts specified above, as appropriate. If an arbitrage does not satisfy the conditions in paragraph 114 above of this Section, the Bank must treat the index position using the approach for index contracts.
When basket of shares is 90% of index
120. To determine whether a basket of shares represents at least 90% of an index, the relative weight of each stock in the basket must be compared to the weight of that stock in the index to calculate a percentage slippage from its weight in the index. Stocks that are included in the index but are not held in the basket have a slippage equal to their percentage weight in the index. The sum of the slippages across all stocks in the index represents the total slippage from the index. The absolute values of the percentage slippages must be summed. Deducting the total slippage from 100 gives the percentage coverage of the index to be compared to the required minimum of 90%.
J. Calculation of Option Risk Capital Requirement
121. This section of the BPG sets out the standards, methodology, formulae and parameters to be employed by a Bank in calculating the Option risk capital requirements, specified in BBR Rule 6.5
(1) (e). These elements constitute the framework which the AFSA would use to assess compliance with BBR Rules requiring a Bank to maintain adequate capital to support its option risk exposures. In order to ensure compliance with the requirement under this Rule and to demonstrate adequacy of capital to address equity risk exposures, the AFSA expects a Bank to follow the methodology specified in this section.
122. In measuring its Market risk, a Bank must include the risk of holding or taking positions in options contracts (options risk). If all the written option positions are hedged by perfectly matched long positions in exactly the same options, no capital charge for options risk is required. A Bank that does not write options must use the simplified approach. A Bank that writes options must use the delta-plus method.
Simplified approach
123. A Bank that does not write options must calculate capital charges in accordance with the provisions of :
(a) The paragraph 26 of this section H for a position that is a ‘long cash and long put’ or ‘short cash and long call’ position; or
(b) The paragraph 26 of this section H for a position that is a ‘long put’ or ‘long call’ position.
124. In the simplified approach, the position in the option and the associated underlying asset (cash or forward) is not subject to the standard method. Instead, each position is carved-out and subject to a separately calculated capital charge for specific risk and general risk.
Capital charges—‘long cash and long put’ or ‘short cash and long call’
125. For a position that is ‘long cash and long put’ or ‘short cash and long call’, the capital charge is calculated by multiplying the market value of the underlying security by the sum of the specific and general risk capital charges for the underlying, and then subtracting the amount by which the option is in-the-money (bounded at zero).
126. In cases (such as foreign exchange transactions) where it is unclear which side is the underlying security, the underlying should be taken to be the asset that would be received if the option were exercised. In addition, the nominal value should be used for items if the market value of the underlying instrument could be zero (such as in caps, floors and swaptions). Some options have no specific risk (such as those having an interest rate, currency or commodity as the underlying security); other options on interest-rate-related instruments and options on equities and stock indices, however, would have specific risk.
127. In the simplified approach, the capital charge is:
(a) 8% for options on currency; and
(b) 15% for options on commodities.
128. For options with a residual maturity of less than 6 months, a Bank must use the forward price (instead of the spot price) if it is able to do so. For options with a residual maturity of more than 6 months, the firm must compare the strike price with the forward price (instead of the current price). If the firm is unable to do this, it must take the in-the- money amount to be zero.
Capital charges—‘long put’ or ‘long call’
129. For a position that is ‘long put’ or ‘long call’, the capital charge is the lesser of:
(a) the market value of the underlying security multiplied by the sum of the specific and general risk capital charges for the underlying; and
(b) the market value of the option.
130. The book value of the option may be used instead of the market value if the position is not included in the Trading Book (for example, options on particular foreign exchange or commodities positions).
Delta-plus method
131. A Bank that writes options must calculate specific risk capital charges separately by multiplying the delta-equivalent value of each option by the risk-weight applicable under the sections relating to equity position risk and traded interest rate risk.
132. In calculating general risk capital charge, the firm must enter delta- weighted positions with a debt security or interest rate as the underlying into the interest rate time bands in table F1 by using a two-legged approach. Under this approach, there is one entry at the time the underlying contract takes effect and a second entry at the time the underlying contract matures. For an option with a debt security as the underlying, the Bank must apply a specific risk capital charge to the delta- weighted position based on the issuer’s rating and in accordance with Section F of this Chapter.
133. A Bank that writes options must include delta-weighted option positions in measuring its Market risk. The Bank must report such an option as a position equal to the sum of the market values of the underlying multiplied by the sum of the absolute values of the deltas. Because delta does not cover all risks associated with option positions, the Bank must calculate gamma and vega in calculating the regulatory capital charge. The firm must calculate delta, gamma and vega using the pricing model used by a recognized exchange, or a proprietary options pricing model approved, in writing, by the AFSA.
Capital charges—options
134. The capital charge for an option with equities as the underlying must be based on the delta-weighted positions included in the measurement of specific and general risks in accordance with Section G of this Chapter on equity position risk.
135. A Bank that writes options must calculate the capital charge for options on foreign exchange and gold positions in accordance with Section E of this Chapter on foreign exchange risk. For delta risk, the net delta-based equivalent of the foreign currency and gold options must be included in the measurement of the exposure for the respective currency (or gold) position.
136. The capital charge for an option on commodities must be based on the charge calculated using the simplified approach specified in Section I of this Chapter on Commodities risk capital requirement.
Gamma capital charges
137. A Bank that writes options must calculate the capital charge for gamma risk (gamma capital charge) for each option position separately. To calculate gamma capital charge, calculate the gamma impact of each option in accordance with the following formula:
Gammaimpact = 1 / 2 * gamma * VU2 where:
VU is:
(a) for an interest rate option:
i. if the option has a bond as the underlying—the market value of the underlying multiplied by the risk factor applicable under column 3 of table F1 in this Chapter; or
ii. if the option has an interest rate as the underlying—the market value of the underlying multiplied by the assumed changes in yield in column 4 of table F1 in this Chapter;
(b) for options on equities and stock indices—the market value of the underlying multiplied by 8%;
(c) for options on foreign exchange and gold—the market value of the underlying multiplied by 8%; or
(d) for an option on commodities—the market value of the underlying multiplied by 15%.
138. For the purpose of calculating the gamma impact for an option, the following positions must be treated as the same underlying instrument or asset:
(a) for interest rates—each time band in column 2 of table F1 (with each position allocated to separate maturity ladders);
(b) for equities and stock indices—each recognised exchange;
(c) for foreign currencies and gold—each currency pair and gold; and
(d) for commodities—that are deliverable against each other or those that are close substitutes for each other with a minimum price correlation of 0.9 over the previous 12 months.
139. An Authorised Firm must calculate its Capital Requirement for Gamma risk by:
(a) calculating the net Gamma impact in respect of each underlying financial instrument or commodity by aggregating the individual Gamma impacts for each option position in respect of that underlying financial instrument or commodity (which may be either positive or negative); and
(b) aggregating the absolute value of the net Gamma impacts that are negative.
140. The underlying financial instrument or commodity should be taken to be the asset which would be received if the option were exercised. In addition, the notional value should be used for items where the market value of the underlying financial instrument or commodity could be zero (e.g. caps and floors, swaptions). Certain notional positions in zero-specific-risk securities do not attract specific Risk, e.g. interest rate and currency swaps, Forward Rate Agreement (FRA), forward foreign exchange contracts, interest rate futures and futures on an interest rate index. Similarly, options on such zero-specific-risk securities also bear no specific Risk. For the purposes of this paragraph:
(a) the specific and general risk weights in respect of options on interest rate-related instruments are determined in accordance with section F of this Chapter;
(b) the specific and general risk weights in respect of options on equities and equity indices are determined in accordance with section G of this Chapter;
(c) the risk weight in respect of foreign currency and gold options is 8%; and
(d) the risk weight in respect of options on commodities is 15%.
(e) For options with a residual maturity of more than 6 months, the strike price should be compared with the forward, and not current, price. Where an Authorised Firm is unable to do this, the in-the-money amount would be zero.
141. A Bank which trades in exotic options (e.g. barriers, digitals) would use either the scenario approach or the Internal Models Approach (IMA) to calculate its Option Risk Capital Requirement for such options, unless it is able to demonstrate to the AFSA that the Delta-plus method is appropriate. In the case of options on futures or forwards, the relevant underlying is that on which the future or forward is based (e.g. for a bought call option on a June 3-month bill future, the relevant underlying is the 3-month bill).
Vega capital charges
142. A Bank must calculate the capital charge for vega risk (vega capital charge) by:
(a) multiplying the sum of the vegas for all option positions in respect of the same underlying financial instrument or commodity, defined in paragraph 39 of this section H, by a proportional shift in the option’s current volatility of 25%; and
(b) aggregating the absolute value of the individual capital requirements which have been calculated for vega risk.
K. Calculation of Commodities Risk Capital Requirement
143. This section of the BPG sets out the standards, methodology, formulae and parameters to be employed by a Bank in calculating the Commodities risk capital requirements, specified in BBR Rule 6.5 (1) (d). These elements constitute the framework which the AFSA would use to assess compliance with BBR Rules requiring a Bank to maintain adequate capital to support its commodities risk exposures. In order to ensure compliance with the requirement under this Rule and to demonstrate adequacy of capital to address equity risk exposures, the AFSA expects a Bank to follow the methodology specified in this section.
144. In measuring its Market risk, a Bank must include the risk of holding or taking positions in commodities and commodities options (commodities risk). Commodities means physical or energy products that may be traded. Commodities include precious metals (other than gold), base metals, agricultural products, minerals, oil, gas and electricity. A Bank must also include commodity derivatives and off-balance sheet positions that are affected by changes in commodity prices, having derived notional commodity positions; and other positions against which no other Market or Credit Risk Capital Requirement has been applied.
145. If a Bank is exposed to foreign exchange or interest rate risk from funding commodities positions, it must include the relevant positions in the measurement of interest rate or foreign exchange risk. Gold is dealt with as a foreign exchange position (rather than as a commodity position) because the volatility of its prices is similar to that of a currency. If a commodity is to be received or delivered under a forward contract, the Bank must report any foreign currency, equity or interest rate exposure from the other leg of the contract in accordance with the relevant section of this Chapter.
146. In calculating the capital charge for commodities risk, a Bank must include commodity derivatives and off-balance- sheet positions that are affected by changes in commodity prices (such as commodity futures and commodity swaps). Options on commodities for which the options risk is measured using the delta-plus method must also be included (with their underlying assets). Options for which the options risk is measured using the simplified approach must be excluded.
147. Commodity derivatives need to be converted into notional commodities positions and assigned to maturities. Futures and forward contracts relating to a particular commodity must be included in the measurement of commodities risk as notional amounts in terms of the standard unit of measurement multiplied by the spot price of the commodity.
148. A Bank must first state each commodity position (spot plus forward) in terms of the standard unit of measurement for the commodity (such as barrels, kilos or grams). The firm must then convert the net position in each commodity into the reporting currency at the current spot market exchange rates.
Measuring commodities risk
149. A Bank must use the simplified approach to measure commodities risk. To calculate open positions using this approach, the firm may report short and long positions in each commodity on a net basis. Positions are reported on a net basis by offsetting them against each other if they are in the same commodity. Positions in different commodities must not be offset unless:
(a) the commodities are deliverable against each other; or
(b) the commodities are close substitutes for each other and a minimum correlation between price movements of 0.9 can be clearly established over at least the preceding year.
Correlation-based offsetting mentioned in (b) above may not be used unless the AFSA has approved its use in writing.
150. Gross position in a commodity, is the sum of the absolute values of all short positions and all long positions of the firm, regardless of maturity. A Bank must use the current spot price to calculate its gross position in commodity derivatives.
Capital charges—simplified approach
151. The capital charge for commodities risk of a Bank is the sum of:
(a) 15% of the firm’s overall net position, long or short, in each commodity; and
(b) 3% of the firm’s gross position in each commodity.