- Question ID
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2022_6571
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Credit risk
- Article
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274
- Paragraph
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3
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Not applicable
- Article/Paragraph
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-
- Type of submitter
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Individual
- Subject matter
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SA-CCR cap margin agreement
- Question
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How do you calculate the cap for netting sets subject to a contractual margin agreement mentioned in Article 274(3) CRR?
- Background on the question
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I would like to use the following example. There is a netting set that is subject to a contractual margin agreement containing only interest derivatives and cash collateral, applying the Articles literally.
For the calculation of the replacement cost in Article 275, CMV = -30, VM = -35, TH = MTA = NICA = 0.
If you plug this into the formulas, you get
RC_nomargin = 0 (as in Article 275 1.)
RC_margin = 5 (as in Article 275 2.)
For the potential future exposure (PFE) in Article 278, we use
Addon_nomargin = 10
Addon_margin = 3
To calculate the multiplier in Article 278 3. we have to use CMV and VM again, resulting in
Multiplier_nomargin = min(1, 0.05 + (1-0.05)*exp(-30/(2*(1-0.05)*10)))=0.246
Multiplier_margin = 1
Resulting in
PFE_nomargin = 2.46
PFE_margin = 3
Going back to Article 274, the resulting exposure value is
Exposure_nomargin = 1.4*(0+2.46)= 3.64
Exposure_margin = 1.4*(5+3) = 11.2
According to this calculation, we would have to use the non-margined exposure (3.64), which is smaller than the net exposure of the netting set (CMV - VM = 5). This is a result which is troubling from a credit risk perspective, since the exposure for a netting set should always be larger than the net exposure due to the volatile nature of derivatives.
- Submission date
- Rejected publishing date
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- Rationale for rejection
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This question has been rejected because the issue it deals with is already explained or addressed in Article 272(12a) and 274(3) of Regulation (EU) No 575/2013 as amended by Regulation (EU) 2019/876 (Capital Requirements Regulation or CRR). For further information on the purpose of this tool and on how to submit questions, please see 'Additional background and guidance for asking questions'.
- Status
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Rejected question