EBA · 2022_6571 Rejected question

SA-CCR cap margin agreement

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
274, para. 3
Topic
Credit risk
Submitted by
Individual
Submitted
2022-08-25

Question

How do you calculate the cap for netting sets subject to a contractual margin agreement mentioned in Article 274(3) CRR?

Background

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.
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Original source: European Banking Authority, Q&A ID 2022_6571

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