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LVA, FVA, CVA, DVA impacts on derivatives management Christophe MICHEL Head of RCCAD Quantitative Research AFGAP-PRMIA April 5th 2012
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Contents 02 Introduction to LVA 13 Introduction to CVA
19 Impact of CSA on CVA 26 A New Pricing Framework 31 Centralized Risk Management
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Introduction to LVA
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Pricing principle Discounting Forecasted Flows Collateral Impact
To make a long story short, pricing is a question of forecasting future fixed, floating or conditional flows in a given currency and discounting them consistently with a funding level in this currency (in order to avoid arbitrage opportunities). For a single flow we can formally write: Collateral Impact In case of collateral agreement, additional flows are to be taken into account in the valuation process. Indeed, to be posted a collateral has to be funded and remunerated with the funding rate, on the other hand, the collateral posted is remunerated with a given collateral rate described within the collateral agreement. The additional flows are all differentials of interest generated by the difference between funding and collateral rates applied to the collateral amount posted. These additional flows have to be funded and their price is straightforward as soon as we know their forecasted value. Time t forecasted value of the future flow in the given currency Time t value of the future flow in a given currency Time t value of a unit of currency paid at T According to a funding level
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Valuation of Collateral Impact
Collateral Impact Value: an Implicit Problem Coming back on the case of a single flow, additional flows linked to a collateral agreement depend upon the collateral amount paid at each period: In general, the collateral amount to be posted is directly deduced from the value of the collateralized derivative i.e. including additional interest flows, say Vc, which is different from the value of the unsecured derivative (Vf). Hence, the value of a collateralized derivative depends upon this value: we’re facing an implicit problem. t3 t4 t0 t1 t2 t5 t6 Collateral-linked flow paid at t4 equal to the differential of interest of collateral Remuneration posted at t3 : Future derivative value
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Valuation of Collateral Impact: the Standard Case
Collateral Impact Value: the Special Case of Bilateral Contracts In case of bilateral collateral agreement, we have: In this special case, under model assumptions, one can show that the price of a collateralised contract is obtained by discounting with the collateral remuneration rate instead of the funding rate. For a single flow, we can formally write: Note that in this case, the value of the collateralized contract doesn’t depend any more upon the funding rate. Note also that if a given derivative pays flows in a given currency but is collateralized in another currency then its collateralized value will depend upon FX-Term Changes. Time t value of the future flow in a given Currency including collateral additionaml flows Time t forecasted value of the future flow in the given currency Time t value of a unit of currency paid at T according to the collateral remuneration rate
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Valuation of Collateral Impact: the General Case
General Collateral Many other possibilities exist in practice. For instance the unilateral collateral agreement can be written as follows: In this case, the collateral impact remains implicit but cannot be explicitly solved like in the standard case. Pricing Method To treat the general case, one has to solve a high dimensional optimal control problem. This is generally not do-able in practice but it is well approximated by Monte Carlo simulation method Market data are diffused on simulated paths On each node of the simulation the Mark-to-Market of each product included in the collateral agreement are approximated The collateral amount to be posted on each node can then be deduced Additional flows resulting from collateral agreement can then be evaluated on each node The average of their present value approximate the LVA impact Note that the collateral impact crucially depends upon the global portfolio within the collateral contract and cannot be treated on a stand alone basis. A contribution to the global adjustment can be computed.
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The IR pricing framework was a SINGLE CURVE one based on -Bor.
Before the crisis . Pre-crisis Bor rates were market convention for discounting all trades, independently on the counterparty, CSA, etc… Implicit assumptions If the counterparty was uncollateralised, CA-CIB could lend/borrow Bor flat If the counterparty was collateralised, it meant the interest paid on the collateral posted/received was Bor (which is consistent with interest - mainly OIS as defined in the CSA) Historically Access to liquidity was taken as granted Basis were tight EONIA, 3m Euribor 6m Euribor: historical values* These assumptions were verified Source: Bloomberg The IR pricing framework was a SINGLE CURVE one based on -Bor.
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During and post crisis During and post crisis Liquidity crisis
. During and post crisis Liquidity crisis Drying up of lending/borrowing between banks Creditworthiness of banks questioned Pre-crisis funding assumptions no longer hold Unsecured funding much more expensive Interest paid on collateral (usually OIS) significantly diverged from Bor rates 3M EONIA/Euribor spread (LHS) 5Y 3m EONIA/Euribor basis (LHS) 5Y 3m/6m Euribor basis (RHS) EONIA, 3m Euribor 6m Euribor: historical values*
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Growing importance of Credit Support Annex (CSA)
Liquidity & credit risk issues are more and more actively managed by banks. The main trend is a clear shift towards growing use of CSA as collateralization remains among the most widely used methods to mitigate counterparty credit risk in the OTC derivatives market. Growth of value of total collateral (USD billions) Growth of collateral agreements Source: ISDA Margin Survey 2011
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Credit Support Annex (1/3)
Each CSA determines the collateralization terms between counterparties: bilateral or unilateral, type of collateral, currency, haircut, threshold, minimum transfer amount and all other details are stipulated in the CSA. The amount of margin posted and the margin interest – and consequently the valuation of the structure – will depend on the CSA terms. CSA determines the range of assets that may be posted as a collateral – cash in different currencies, government bonds or corporate or mortgage backed securities The choice of collateral currency will alter the expected return as the cash funding terms are tied to the corresponding currency’s overnight rate (need of cross currency swap if the collateral currency is not the same as the deal currency) For cash-only CSA’s, the funding curve corresponds to the specified collateral interest rate The threshold level will determine how much of the exposure is collateralized. Margin transfers will be made only if the minimum transfer amount is exceeded. Bilateral CSA collateral profile Counterparty posts collateral and receives interest PV - + Bank posts collateral and receives interest
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Credit Support Annex (2/3)
Description of the CSA Margin transfer form Unilateral – only one way transfers – CA CIB posts a collateral but the counterparty dos not (required by some supranational entities ) Bilateral – symmetric transfer terms Margin call frequency Daily margin call is frequency required (becoming a market standard). Longer than daily margin call frequency can be practical for markets and assets that are not volatile Threshold This is the exposure amount below which collateral is not required (the threshold represents an amount of uncollateralized exposure). A threshold of zero implies that any exposure is collateralized Minimum transfer amount The smallest amount of collateral that can be transferred. It is used to avoid the workload associated with a frequent transfer of insignificant amounts of collateral
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Credit Support Annex (3/3)
What is a standard CSA ? Pay attention to the detail when negotiating CSA terms Standard CSA terms Non standard agreements Bilateral margin transfer form: symmetric transfer terms for both parties Daily margin call frequency (weekly can be also accepted as standard) No threshold – up to 5M threshold is considered as reasonable Cash and G7 bonds (haircuts – 0%-2% on short term maturities and 5-10% on longer term maturities) In EUR or in USD, remunerated at EONIA FLAT or Fed Funds FLAT No CSA Unilateral CSA (can be unilateral in our favour; often supranational institutions require an unilateral CSA in their favour) CSA with very high threshold – M threshold will impact pricing CSA with rating triggers (example: CA-CIB needed to post an independent amount to EIB due to the S&P rating action) Sub-optimal CSAs – negative spreads on cash collateral, securities received that can’t be re-hypothecated
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Introduction to CVA
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CVA Basics – Definition
To be or not to be paid ? The Credit Value Adjustment appears in the pricing framework when a credit risk is taken into account. Formally, one can explicit this risk by multiplying each payment flow by the following function: In case of a counterparty default at time T, the key question is to measure the exposure. A priori, the exposure is the sum of all positive mark to market of each transaction remaining at time T with this counterparty. In case of netting agreement with the counterparty, the exposure becomes the sum of all netted positive mark to market of each set of transactions within each netting agreement contract. A classical formula A classical CVA formula can be expressed as the amount of discounted future Expected Losses Loss Given Default Default Probability Exposure at Default (Discounted)
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CVA Basics – Key Ingredients
Expected Positive Exposure (EPE) Calculated via simulations process (Monte Carlo…) Computation including netting and collateral agreements Involves only the Positive Exposures in case of Counterparty Default Definition of Exposure linked to the mark to market of transaction Evaluated Contingent on the default of the counterparty including right way / wrong way risks CSA or break clause have a huge impact on EPE Default Probability Implied from CDS spreads (market-implied) or, Historical default probabilities Loss Given Default / Recovery Rate Market Implied (where possible) : LGDMarket Internal Recovery measure : LGDInternal Market CDS Curve
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CVA Basics – Key Ingredients
Risk parameters: Peak Exposure: Maximum of the MtM of the transaction over its lifespan, given a high confidence level (VaR 95%) Loan Equivalent: Average EPE over time (measure to determine risk equivalent in terms of loan for economic capital calculation) Tail Credit Risk (CVaR): average of 5% maximum potential losses 10y EUR IRS CA-CIB Receives Fixed 2.3%
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CVA Basics – Interpretation
CVA as an Accounting Provision Measure of Expected Loss Use of Historical Default Probabilities Inactive Risk Management (Acceptance to ‘carry’ the Credit Risk) No Market Hedges in Place (IR, FX or Credit) Credit Risk remains in the individual traders books CVA as a Mark to Market Adjustment Market Cost of Dynamically Hedging Counterparty Risk Use of Market Implied Default Probabilities (implied from CDS) Active Risk Management Strategy in place Local Sensitivities Jump to Default Risks Concentrations / Wrong Way risks Market Hedges in place (IR, FX and Credit) Credit Risk transferred to a centralised CVA desk
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CVA Basics – Summary CVA is a fair market adjustment to the derivatives portfolio CVA charges are there to offset losses in the global CVA portfolio due to new trades Incremental impact on the portfolio CVA P&L is flat provided the cash transfers take place CVA hedges are initiated in order to offset future CVA P&L volatility for CA-CIB Due to portfolio MTM movements (IR, FX, Credit Hedges) Due to counterparty CDS Spread Changes (Credit Hedges) At inception: CVA P&L is flat, Hedge P&L is flat: CDS spreads increase: CVA increases (Loss) versus Hedge P&L (Gain) CDS spreads decrease: CVA decrease (Gain) versus Hedge P&L (Loss) CDS spreads stay static: Negative carry on Hedge (Loss) is offset against positive carry of CVA (Gain) CVA Credit Hedges also provide Jump to default risk management Basel III capital reductions Debit Value Adjustment (DVA) is the CVA seen from the counterparty. To take it into account allows symmetrical views on the shared portfolio.
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Impact of CSA on CVA
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CVA impact of collateral on stand alone transaction (IRS)
The Credit Support Annex is a key tool for credit risk mitigation EPE computation includes netting and collateral agreements EPE is calculated up to the threshold Above threshold, mark to market drift is calculated on margin call period + collateral lag period (10days) CSA features are built into EPE simulations and consequently have an impact on CVA Trade description Collateral features Unilateral vs Bilateral Threshold Frequency Currency Minimum Transfer Amount (MTA) Start date: 10 Apr 2012 Maturity: 10Y Notional: EUR 100M CA-CIB receives: 2.30% (SA, act/360) CA-CIB pays: 6M Euribor (SA, 30/360 Counterpart: XXX 5Y cds: 143bps Internal rating: B
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CVA impact of collateral on stand alone transaction (IRS)
No collateral agreement in place Risk exposure is maximal for CA-CIB Peak exposure: Market CVA: (1.49 bps p.a) Historical CVA: (0.11 bps p.a) Market CVA ~ hedging cost of loan lquivalent on cds market CSA agreement in place Sharp decrease of risk profile due to CSA risk mitigation CSA in place Bilateral Frequency: daily Threshold: 0 MTA: 0 Currency: EUR Peak exposure: Market CVA: (0.30 bps p.a) Historical CVA: (0.02 bps p.a)
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CVA impact of collateral on stand alone transaction (IRS)
CSA agreement in place Weekly frequency: drift is computed on one week + 10 days collateral lag CSA in place Bilateral Frequency: weekly Threshold: 0 MTA: 0 Currency: EUR Peak exposure: Market CVA: (0.37 bps p.a) Historical CVA: (0.02 bps p.a) CSA agreement in place CSA in place Bilateral Frequency: daily Threshold: 0 MTA: 0 Currency: EUR Peak exposure: Market CVA: (0.30 bps p.a) Historical CVA: (0.02 bps p.a)
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CVA impact of collateral on stand alone transaction (IRS)
CSA agreement in place CSA in place Bilateral Frequency: daily Threshold: 500K MTA: 0 Currency: EUR Peak exposure: Market CVA: (0.47 bps p.a) Historical CVA: (0.024 bps p.a) CSA agreement in place CSA in place Bilateral Frequency: daily Threshold: 0 MTA: 0 Currency: EUR Peak exposure: Market CVA: (0.30 bps p.a) Historical CVA: (0.020 bps p.a)
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CVA impact of collateral on stand alone transaction (CRS)
Trade description Collateral features Start date: 10 Apr 2012 Maturity: 10Y Notional: EUR 100M EURUSD: CA-CIB pays: 6M Euribor (SA, act/360) CA-CIB receives: USD 2.25% (SA, act/360) Notional exchange: Beg and end Unilateral vs Bilateral Threshold Frequency Currency Minimum Transfer Amount (MTA) Counterparty Name: XXX 5Y cds: 143bps Internal rating: B
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CVA impact of collateral on stand alone transaction (CRS)
No collateral agreement in place Risk exposure is maximal for CA-CIB Peak exposure: Market CVA: (18bps p.a) Historical CVA: (2 bps p.a) CSA agreement in place CSA in place Bilateral Frequency: daily Threshold: 0 MTA: 0 Currency: EUR CSA drastically minimizes risk exposure on cross-currency Peak exposure: Market CVA: (2.40 bps p.a) Historical CVA: (0.24 bps p.a)
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A new pricing framework
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Collecting Information
Market Information In the new pricing framework, market prices remain of course a central source of information but one has to interpret them consistently. A price is at least dependent with the CSA of the product priced and when one observe the price of an OTC product on a screen the question of the implicit CSA of this price has to be solved. To fix this problem, a standardization of market practice arise Standard swap are assumed cleared with a collateral in the currency of the swap with a collateral remuneration at OIS rate. Multi-currency products are often assumed collateralized in USD with a collateral remuneration at USDOIS rate. Physical settlement swaption quotation often assumes the underlying swap to be a standard swap and quotes a forward premium in order to avoid the LVA impact on the discounted premium. Once the implicit CSA question is answered, it becomes possible to strip from market prices cleaned market data (IR curves per tenor, FX forward, default probabilities, inflation forward, liquid volatilities, etc) Additional Observable Information Our own funding level will also intervene in the new pricing framework even if its monetisation isn’t straightforward. From the CVA point of view, some new deal information are to be taken into account like break clause. Lastly, the main new information type to input and which will impact all quotations is all information related to the client (CSA, netting agreement, rating, …)
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Forecasting Data Diffusion Data Missing Credit Data
In addition to market data and client data, we have seen that most of xVA are linked to global portfolio measures based on Monte Carlo simulations. Once the diffusion model is defined, its calibration can partly be implicit (calibration on a set of market prices) but will mainly linked to historical market behaviour. Like for any diffusion model design for structured derivatives pricing, the calibration process is dependent with the sophistication of the diffusion process (from a theoretical point of view) and availability of implicit and historical information. A key point to focus on is the joint behaviour between all class of market risks (let’s say correlation to simplify) implicitly defined in the diffusion process. It is indeed well known that this point will drive market risk netting from the global portfolio point of view. Missing Credit Data For a great number of counterparties there is no quoted CDS. The CVA needs information on default probabilities and LGD for any counterparty. This information is to be forecasted. Based on all internal works on counterparty risk management (sector classification, internal ratings, historical recovery rates, …), it becomes possible to map any counterparty on market information.
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“Stand alone Price” + “Portfolio-Linked Adjustment”
The new pricing workflow can be summarized as follows: By definition, the “stand alone” price of a product is its value independent with the portfolio of deals Calculation Engines Stripping under CSA assumptions Data Forecasting Engine Raw Market Data Cleaned Market Data Global Simulation Engine Portfolio adjustment (CVA, DVA, FVA, non standard LVA) Internal Client Portfolio Internal Client Data Bilateral CSA Input + t0 t1 t2 t3 t4 t5 t6 Product Description (Termsheet) Client Stand-Alone Pricing Engine Stand alone Price
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About Portfolio-Linked Adjustments
A Non Linear Adjustment Generally speaking, portfolio-linked adjustments aren’t linear i.e. the value adjustment of a given deal depends upon the portfolio (and market data) at the moment the valuation. Same trade with two counterparties, with different credit profiles or portfolio vis-à-vis the bank, will have different market prices. Example: Client receives Fixed on 10y Swap Mid Market 10y Swap Rate = 2.31% Client 1: Rated A- receives 2.27% 4bp CVA charge Client 2: Rated B+ receives 2.23% 8bp CVA charge In practice, an incremental portfolio value adjustment relating to the new trade is used. It corresponds to the differential of portfolio value adjustment with and without the deal. This incremental value can either be positive or negative and a pricing policy is to be defined. Adjustment Breakdown The global portfolio value adjustment is made with several sources of risks (credit, liquidity, funding) and with several market data qualities (pure market data versus forecasted data). To look into these, it is meaningful to evaluate the global portfolio value adjustment breakdown based on those different sources of risk and data qualities. Similarly, this breakdown can be computed for incremental portfolio value adjustments at the deal level.
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Centralized Risk Management
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Hedging Risks Stand-alone Value Risk Management Funding Risk
A priori, the stand-alone product value can be hedged trading desk per trading desk without particular need of centralisation. Nevertheless, the multiplicity of CSA may induce “not so material” additional sources of risks for trading desks (like cross-currency basis swap margin risks) which can pollute trading desk risk management and which could be centralised. We have to keep in mind that any transaction has, from valuation and risk management point of view, a stand-alone part and a portfolio part. The implicit CSA of the stand-alone part of the deal isn’t necessarily the actual CSA of the deal. Funding Risk Funding risk could in theory be managed on a stand-alone basis since this risk isn’t explicitly linked to the portfolio view. But this risk can’t be directly risk managed in the market. Hence, this risk has to be risk managed jointly with ALM. Indeed, the stake is the remuneration or the charge of this adjustment. This has to be made consistently with the way these remuneration/charge are monetised by ALM. Global simulation tools can of course be very used to obtain a complete view of the distribution of funding needs at any future maturity (expectation, standard deviations, … of funding needs including collateral simulation).
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Hedging Risks Portfolio Adjustment Value Risk Management
By definition, this adjustment has to be centrally risk-managed. Indeed: The value to risk manage make sense at the portfolio level only. Global metrics to evaluate (EPE) are time consuming and depend upon a wide range of market data then standard complete local management is just numerically impossible and alternative risk management strategies has to be developed. Some adjustments are based on forecasted/mapped data which as to be specifically risk managed At the centralized level, impacts of global events like defaults, CSA changes, Funding changes can be anticipated, studied and quantified. Conversely, a centralized desk can be pro-active on all portfolio-linked risks: CSA change Waives/Further discounted counterparties (to take into account liquidity providers or to be aligned with the Banks business strategy. Wrong way / Right way risk. RWA management A centralised desk ensure a unique and consistent FO view internally and externally.
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Capital requirements for Counterparty Credit Risk (CCR)
Capital CCR only covers default risk: MtM + standardized add-on based on issuer type, underlying and maturity No capital requirement for MTM loss due to change in counterparty credit spread Capital CCR only covers default risk Internal Ratings-Based approach: Internal assessment of default risk via internal probability of default and LGD EPE: counterparty exposure estimated using non-stressed market data, on a 1Y horizon Basel III Capital CCR = Capital Default (Basel II) + Capital CVA Capital CVA: additional Capital requirement for MtM loss due to change in counterparty credit spread Capital CVA: Market Risk capital charge estimated using stressed VaR on credit instruments EPE: counterparty exposure estimated under stressed parameters on the full maturity CVA VaR is calculated Net of Eligible Hedges Other adjustments: Assuming a higher correlation between financial institutions in the supervisory formula Extending the collateral lag period from 10 days to 20 days Basel I Basel II Basel III
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Regulatory impact on capital requirements
Changing Landscape CVA VaR now a key component in Return on Capital calculations for New Trades DVA not an allowable offset under Basel III, so competitors using DVA for pricing must consider capital usage Active CDS Hedging encouraged Influences CDS pricing and volatility Innovation needed to help reduce RWA costs Cost of Novations / Intermediations now closely scrutinised Need for CVA Pricing Tools to consider Basel III impacts CVA Capital Methodology linked more closely to Market Dynamics Regulatory Methodology is entirely Market Based --> No reliance on Historical Default Measures Basel III extends maturity of Exposure at Default to the Full EPE Profile (previously 1y EPE under Basel II) Capital Relief provided by Eligible Hedges Includes Single name CDS, CDS index, CCDS and other hedges that directly reference the Counterparty Hedging a CVA portfolio releases Capital Challenge: focus on regulatory influence vs focus on competitive pricing
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Central Desk Mandate Centralise and risk manage FO derivatives counterparty and portfolio-linked risk Minimise xVA P&L impact for FO through: Systematic Macro hedging of the overall xVA P&L impact Single Name default hedging (where practical) Active participation in RWA management Target business model is to incentivise Sales Force not only on revenue generation but also on RWA and liquidity consumption Sales recognition methodology has to be consistently defined Establish a Pricing Policy aligned with the internal xVA methodology Educate and train sales and support functions in xVA related issues Involvement in Regulatory Discussions / Decisions affecting xVA Involvement in ISDA / CSA discussions affecting xVA. Need to remain Competitive in Pricing … Must remain business-focused and incentivise the right types of trades: Waiver / Exemption for Target Clients / Businesses Additional Charge for Wrong Way trades Benefits for Right Way Trades / Unwinds / Portfolio Diversifications Need for feedback from clients relating to current market practices Encourage risk mitigation (eg negotiation of Credit Support Annex (CSA) with counterparties)
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Interaction with other FO teams
Central Desk is there to Support the Business: In accurately pricing Credit and Liquidity into new trades, and To manage the credit risk of derivatives portfolio through dynamic CVA hedging To achieve this Central Desk needs: Active Dialogue with Trading / Sales / Structuring on new trades, and existing portfolio (risk reduction opportunities) Involvement in Complex Trades, especially where replacement costs in default are hard to define Clear Understanding of all key components of the trades Identification of potential risk mitigants - break clauses, legal details (CSA, netting), etc Feedback from Clients ! ... and on problem names To ‘wall cross’ the CVA team in case non-public information needs to be shared. To check PV details in front/back office systems. Involve Legal team to ensure appropriate modus operandi is followed Goal is to streamline process Revised guidelines for involvement of Central desk in trade analysis (e.g. where CVA > 50k EUR, ... thresholds to be discussed/revised) Improvement of CVA / LVA pricing tools (including capital costs/usage) Clear communication is critical ... and to Adapt to Change Methodology is dynamic and intended to support business initiatives
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Disclaimer © 2012, CRÉDIT AGRICOLE CORPORATE AND INVESTMENT BANK All rights reserved. The information in this document (the “Information”) has been prepared by Crédit Agricole Corporate and Investment Bank or one of its affiliates (“Crédit Agricole CIB”) for informational purposes only. Nothing in this document is to be construed as an offer for services or products or as an offer or solicitation for the purchase or sale of securities or any other financial product. The Information has no regard to the specific investment objectives, financial situations or particular needs of any recipient. While the Information is based on sources believed to be reliable, no guarantee, representation or warranty, express or implied, is made as to its accuracy, correctness or completeness. Crédit Agricole CIB is under no obligation to update the Information. Crédit Agricole CIB does not act as an advisor to any recipient of this document, nor owe any recipient any fiduciary duty and the Information should not be construed as financial, legal, regulatory, tax or accounting advice. Recipients should make their own independent appraisal of the Information and obtain independent professional advice from appropriate professional advisers before embarking on any course of action. In no event shall Crédit Agricole CIB or any of its directors, officers or employees have any liability or responsibility to any person or entity for any direct or consequential loss, damage, cost, charge, expense or other liability whatsoever, arising out of or in connection with the use of, or reliance upon, the Information. Furthermore, under no circumstance shall Crédit Agricole CIB have any liability to any person or entity for any loss or damage, in whole or in part, caused by, resulting from, or relating to, any error (negligent or otherwise), omission, condition or other circumstances within or outside the control of Crédit Agricole CIB or any of its directors, officers or employees in connection with the procurement, collection, compilation, analysis, interpretation, communication or delivery of the Information. This document and the Information are confidential and may not be copied, reproduced, redistributed, passed on, published, reproduced, transmitted, communicated or disclosed, directly or indirectly, in whole or part, to any other person without Crédit Agricole CIB’s prior written consent. Recipients of this document in jurisdictions outside the United Kingdom should inform themselves about and observe any applicable legal or regulatory requirements in relation to the distribution or possession of this document to or in that jurisdiction. In this respect, Crédit Agricole CIB does not accept any liability to any person in relation to the distribution or possession of this document to or in any jurisdiction. This document is not directed at, or intended for distribution or use by, any person or entity who is a citizen or resident of any jurisdiction where such distribution, publication, availability or use would be contrary to applicable laws or regulations of such jurisdictions. United Kingdom: Crédit Agricole Corporate and Investment Bank is authorised by the Comité des Etablissements de Crédit et des Entreprises d’Investissement (CECEI) and supervised by the Commission Bancaire in France and subject to limited regulation by the Financial Services Authority. Details about the extent of our regulation by the Financial Services Authority are available from us on request. Crédit Agricole Corporate and Investment Bank is incorporated in France and registered in England & Wales. Registered number: FC Registered office: Broadwalk House, 5 Appold Street, London, EC2A 2DA.
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