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TO ACTION
In January 2016, the Basel Committee on Banking Supervision
(BCBS) published final rules for the market risk framework for capital
requirements. The BCBS proposed the end of 2019 as a compliance
deadline for banks with a significant presence in capital markets.1
Q4 2017
Advanced implementation DEC 2019
of standardized approach Compliance
and internal model deadline
approach components
to be completed
Note: Industry participants are in discussion with national supervisors and the BCBS around the compliance
timeline for FRTB. This may lead to the compliance deadline moving beyond December 2019.
Source: Minimum capital requirements for market risk, BCBS, January 2016 and Accenture estimates.
1.1 Trade and Bank 2.1 Sensitivity 2.4 Delta, Vega 3.4 Default
1.4 Covered 3.1 Risk
Book Boundaries Based Method and Curvature Risk Charge
Instruments Factor Analysis
(SBM) Calculation (DRC) – IMA
1.3 Internal 1.6 Reporting 2.3 Securitization 2.6 Residual 3.3 Trading 3.6 Multi Liquidity
Risk Transfers Requirements Risk Add-On Desk Eligibility Horizons
4.1 Trading 4.3 Instrument 4.4 Residual Risk 4.6 SBM 4.8 IMA 4.10 P&L
Book Boundary Redesignation Add-On Approval Calculator Risk Factors Attribution
APPROVALS
5.3 Risk
5.1 Asset 5.3 Instrument 5.5 Capital 5.6 Risk Factor 5.8 Full
Sensitivities
TECHNOLOGY
LEGEND:
CSR: Credit Spread Risk CTP: Correlation Trading Portfolio GIRR: General Interest Rate Risk
Source: Minimum capital requirements for market risk. Basel Committee on Banking Supervision, January 2016.
Maturity mismatch
The FRTB rules framework defines the
risk factors and vertices in a way designed
to calculate sensitivities. These risk factors
and vertices have maturities which may
differ from the existing risk computation
systems within banks.
Assumptions
FRTB rules detail the process for P&L
attribution for the internal models, which
requires full revaluation methods rather
than the approximation methods banks
currently use. To use full revaluation
methods, banks would need to use data
for full sets of positions; they would
need to create systemic assumptions
to fill in the missing data. This may not
sit well with regulators, who may insist
on the SA calculation in the absence of
hard data to back the internal models.
Calculate Delta, Calculate portfolio “Greeks” for each of the risk factors,
Vega and Curvature which can be done using internal models, vendor supplied
for each risk class models or counterparty provided “Greeks.”
IMx=DeltaMarginx+VegaMarginx+CurvatureMarginx
The total market risk Aggregate the margins for each asset class calculated
charge is an aggregate using the above formula.
of the risk charge SIMM=SIMMRatesFX+SIMMCredit+SIMMEquity+SIMMCommodity
for Delta, Vega and
Curvature across
risk classes
Source: Accenture analysis of the International Swaps and Derivatives Association (ISDA) Standard Initial Margin
Model (SIMM) version 3.15
2. Developing a target state Once the first three steps have been taken,
operating model the bank can create a detailed roadmap
and direct different workstreams aimed
The bank should finalize the target state at reaching the desired target state.
technology and business operation
capabilities, and identify strategic platforms As we have seen, challenges related to
and solutions to be leveraged in a target FRTB implementation are significant. While
state environment. In addition, the bank banks still have enough time to meet the
should also define the organizational 2019 deadline, they have no time to lose in
structure for compliance and participate organizing and planning what amounts to a
in industry forums to identify the current comprehensive reordering of their market
level of industry practice. risk processes. The needed talent is in short
supply and banks that move quickly to
develop and execute a plan would have an
advantage over competitors who are slower
to respond to this major regulatory initiative.
Disclaimer
This document is intended for general
informational purposes only and does not
take into account the reader’s specific
circumstances, and may not reflect the most
current developments. Accenture disclaims,
to the fullest extent permitted by applicable
law, any and all liability for the accuracy
and completeness of the information in this
document and for any acts or omissions
made based on such information. Accenture
does not provide legal, regulatory, audit,
or tax advice. Readers are responsible for
obtaining such advice from their own legal
counsel or other licensed professionals.