Application of volatility haircuts adjusted under Article 285(3) (extended margin period of risk)

Is the ‘use test’ set out in Article 225(3)(a)/(b) of the CRR intended to be sufficiently strong to invoke the use of haircuts adjusted under Art 285(3) in the non-model exposure calculation for a netting set containing a single SFT?

The question relates to the application of own estimate volatility adjustments in the calculation of exposures on securities lending/borrowing transactions, repurchase transactions etc (‘SFTs’) using the ‘Own Estimates Volatility Adjustments Approach for Master Netting Agreements’, in the specific case of a netting set containing a single SFT. The formula for a netting set is set out in Article 220, with Article 225 describing the use of own estimates of volatility adjustments. When applied to a single SFT (eg outside a netting set), the formula simplifies to {exposure – collateral} with volatility adjustments applied in the normal way. Article 285(3), within Section 6 ‘Internal Model Method’, requires an extended margin period of risk (‘MPOR’) to be used in determining volatility haircuts in the case of large netting sets (Art 285(3)(a)); netting sets containing illiquid collateral (Article 285(3)(b)); or netting sets containing hard-to-replace trades (Article 285(3)(b)). Article 225 contains no cross-reference to Article 285(3), and hence there is no explicit requirement to use the extended MPOR in the exposure calculation on SFTs under Article 220 and Article 225. However, Article 225(3)(a) and (b) set out a ‘use test’ relevant for the calculation of own estimate haircuts.