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SCI Special ReportTall orderThe advent of Basel 3 significantly changes the way in which financialinstitutions address counterparty credit risk (CCR) and credit valueadjustment (CVA). While a small number of banks are geared up for theregulatory changes and are actively managing CVA, the complexity andcost of implementing the necessary infrastructure remains a dauntingtask for the majority. Anna Carlisle reportsL arge losses resulting from CVA volatility during the According to Dan Travers, product manager, risk solutions global financial crisis led banks and regulators to scru- at SunGard, three big challenges are associated with CVA: the tinise CVA and CVA charges more closely. Around policy challenge, the data challenge and the calculation itself. two-thirds of CCR losses during the crisis were attrib- “Banks need to decide whether CVA will be charged on some uted to CVA losses and only one-third to actual defaults. or all transactions,” he says. “They then need to get the go-aheadAs a result, Basel 3 will introduce revised rules for calculating and investment to implement a CVA function across the bank,CVA, as well as new capital charges based on the stressed which can take a considerable amount of time.”VaR adjustment. He adds: “Many of the Tier 1 US and European banks have It is estimated that most financial institutions are at relatively started to insist that all deals are subject to a CVA charge, whichearly stages of implementing up-to-date CVA systems, aside comes out of the P&L of a deal, and will be actively managed byfrom the top-20 dealing banks. The majority are understood to a centralised CVA desk. Getting an agreement from board levelhave an informal CCR solution in place or may just be in the as to what the bank is going to do, however, is a big challenge.”planning stages of an enterprise solution. Some may not even A huge amount of data needs to be collected in order to makehave started planning at all. a CVA calculation possible, including CDS spread data, recovery “Moving from Basel 2 to Basel 3 means quite a change in the rates, netting set collateral information, transaction data – for alllevel of counterparty risk analysis,” says Rohan Douglas, ceo at asset classes – and market data. “All those pieces of informationQuantifi. “For most banks that may nothave been doing anything particularly Figure 1sophisticated in that space, it’s a huge Data and Technology Challengesstep up in terms of where they wereto where they need to get to.” IR/FX Credit Commodities Equities CVA cuts across many areas of a Trading System(s)bank: there are trading aspects, acorporate risk management aspectand regulatory and accountingaspects. It affects both the front and • Transactionback office of a bank. • Market data Clearing Systems & Trade Repos • Reference data “Many institutions are workingagainst the clock,” adds Douglas. Hedges“The Basel 3 framework is loomingand, in many cases, existing infra- Marginal CVA Pricing Tool Counterparty Exposure Collateral Managementstructure for risk management in CVA Risk Management Simulation Engine Systembanks is geared towards separate Systemmarket and credit risk management.The requirements for counterpartyrisk are completely different: we’re Reportingtalking about a very large, very • Counterpartiescomplex infrastructure that has to be • Legal agreementsimplemented across all divisions ofthe bank [see charts].” Source: Quantifi1 www.structuredcreditinvestor.com October 2011

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SCI Special ReportFigure 2 Technologies. “However, it must be calculated separately at the counter-Counterparty Risk Workflow party portfolio level because there are Corporate Treasury portfolio effects beyond the valuation of each instrument; for example, Derivative netting and collateral agreements.” Transaction If a trader brings in a new transac- Bank Derivatives Sales tion, the CVA desk needs to under- stand how it interacts with existing Derivative Pricing deals with that counterparty and work Bank Treasury (funding) Derivatives Trading Desk Exchanges (hedges) out the incremental CVA charge to the new transaction. The trader may be Marginal able to give the counterparty a cheaper CVA Price CVA price if the transaction’s contribution CVA Desk Hedging is small or even negative, if it cancels out some other exposure, for example. Exposure Limits “At the same time, counterparties Collateral Management Collateral Risk Control can shop around with different Risk dealers to see who is the cheapest, Regulatory Capital based on what has been traded with and Reporting them before,” notes Rosen. Bank Regulator Cost may be one deciding factorSource: Quantifi as to the type of CCR and CVA solu- tions banks are able to implement. Travers explains that while there arecome from different areas in the bank, so that’s a challenge that some variable infrastructure costs that are related to the sizeshouldn’t be underestimated,” notes Travers. and number of transactions, there are also some fixed costs, Finally, there’s the actual CVA calculation itself, which not such as gathering the data and putting processes in place toonly requires a Monte Carlo simulation of around 5000 sce- manage collateral data, transaction data and market data.narios, but also needs to take into account the path- dependent “Some of those fixed costs may preclude the smaller banksnature of relevant derivatives and the netting and collateral in from entering into CVA for at least the next couple of years,”order to get an expected exposure and calculate the CVA. “Once he says. “There are also staff costs to think about. For a medium-you’ve got the data assembled, it’s a huge computational chal- sized bank, it is going to cost in the region of €10m to implementlenge. Then when you put sensitivities on top of that, it’s another a system. There’s been a huge amount of interest in CVAorder of magnitude of complexity,” says Travers. recently, but it will be interesting to see whether cost pressures He continues: “We are seeing a lot of banks talk to vendors will hamper progress.”about CVA solutions because they are realising it’s a problemthat they are unable or do not want to take on themselves. They Hedging strategieswant to be live on CVA trading in 12 months.” A number of banks have – or are in the process of – setting up Basel 3 requires a CVA capital risk charge in January 2013. centralised CVA desks to manage CCR exposure. CommonlyWhile banks will be expected to have solutions in place by then, staffed by traders and structurers previously involved in struc-it will be possible to take a more basic standardised approach. tured credit or exotics, the desk has two main roles.Many banks are understood to be taking this option. The first is to provide counterparty credit insurance to the At the same time, however, banks need to remain competitive derivatives dealers. For simple products such as interest ratein terms of CVA pricing and need systems that not only accurately swaps, this should be fairly straight forward. However, whetherprice CVA, but also price it correctly from the bank’s perspective. it is a physical cash amount or rate that is provided to the dealer, This needs to be done in the CVA desk needs the infrastructure to be able to provide this. a real-time, almost sub- The larger banks will typically have a large CCR solution in second environment. place with an automated system that calculates CCR exposures “CVA is an integral across all different desks and positions overnight. Saved infor- component of the value of mation from those calculations allows the CVA desk to calculate derivatives and ideally it incremental pricing of a new trade very quickly and also will be should be part of the valu- able to produce all the sensitivities that a CVA desk needs to ation models for each hedge and manage those exposures. instrument,” says Dan At the same time, the CVA desk proactively monitors the Rosen, ceo of R2 Financial state of the market. New events during the day affecting the “Some fixed costs may preclude the smaller banks from entering into CVADan Travers, SunGard for at least the next couple of years”October 2011 www.structuredcreditinvestor.com 2

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SCI Special Reportstate of a particular counterparty will not have been priced in These deals haveby the automated system. Therefore the CVA desk is required involved the CVA deskto update in real-time restrictions on certain trades: they need pooling CVA exposure andto proactively manage the credit risk of the bank to make sure selling tranches of risk tonew trades are not put on when news comes in. investors. The Amstel and “From a pricing perspective, CVA is the most complex instrument Alpine transactions, forthat we have ever priced, by a long way,” says Rosen. “In practice, example (SCI passim),CVA cannot be captured to a decimal place. There is no perfect issued by ABN AMRO andquote. We are really pushing our limits on how well we can do it.” UBS respectively tranched The second role of the CVA desk is to actively hedge posi- a pool of risk and sold thetions. “CVA desks need to preserve the figure that they quote equity portion, therebyto traders,” says Neil Dodgson, vp business development & reducing the risk-weightingcustomer solutions at Algorithmics. “This can be done via rela- of the exposure.tively simple FX, CDS, IRS, equity and commodity hedges.” One structured credit However, a significant concern for CVA desks is cross-gamma manager confirms that hishedging. “Instead of putting on a static first order hedge, the CVA firm has been talking todesk needs to look down further at hedging its second order. For four or five differentexample, if you have a FX and interest rate movement at the same houses about CVA trades Neil Dodgson, Algorithmicstime, how do you hedge that? At the same time, they also need over a long period of time,to think about credit risk,” continues Dodgson. with one particular deal close to completion. “People are at dif- He points out that some desks are looking at contingent CDS, ferent stages in terms of completing these transactions,” he says.which could encapsulate both of those risks into one transaction. “There’s one bank that has done several trades already and we’dHowever, that market is very small and highly illiquid at present expect we could trade with them if we can agree terms.”(see box below). The manager adds: “There are other banks that have done There was some initial controversy and discussion as to what CVA trades in the past, such as Deutsche Bank, ABN/RBS andqualified as a hedge for CVA under Basel 3. But, following market UBS. These firms have got specific systems in place and couldfeedback, the rules were modified so that currently single name do further trades if they want to. Most banks do not have a systemCDS, single name contingent CDS and CDS indices (jurisdiction- in place, but several are looking to set something up.”dependant) are eligible hedge securities for CVA. The trade in question would consist of a bank taking its Tranche securities and nth-to-default swaps are not eligible. exposure to around 400-500 counterparties; for example,Often interest rate and FX risk for CVA is hedged using interest US$10m in exposure to one manufacturer and US$20m expo-rate swaps and FX products, but these currently would not get sure to a bank, and so on. The bank would buy protection fortreatment as hedge securities for CVA and would be measured the portfolio from the structured credit manager, with the manageras adding to the overall risk under Basel 3. selling the bank protection on a first-loss portion of the portfo- lio; in other words, the first 8% of losses.The next traded risk? “From a regulatory perspective, I think this market has theThe growing number of CVA desks has also given rise to the potential to grow,” says the manager. “The capital charge arisingconcept of CVA becoming a viable traded risk. To date, a small from CVA under Basel 3, which is based on the stressed VaRnumber of CVA securitisations have been issued. adjustment, is much larger than the capital charges under Basel 2. Supply issues C ontingent CDS (CCDS) has been touted as an effec- risk to other investors.” tive hedge for incremental regulatory capital charges He adds: “If one trading desk sells CCDS protection to for CVA volatility outlined in Basel 3. Indeed, regulators another, what do they do with that risk? Do they warehouse have tacitly approved CCDS as a possible hedge. However, it? If they don’t warehouse it, they need to show that they can the likelihood that this product will gain traction looks unlikely distribute that risk to an investor, and this is not currently in the current environment due to the lack of sellers. possible.” “CCDS is not being widely used to hedge CVA books due Mukherjee explains that in the absence of CCDS, it comes to the lack of adequate supply,” confirms Shankar Mukherjee, down to banks managing their CVA volatility by essentially co-founder of Novarum. “What banks want is a suitably-rated replicating a CCDS strategy internally. However, one problem counterparty to sell the CCDS, but these simply do not exist.” with this strategy is that often the idiosyncratic CDS hedges While there has been a limited interbank market for CCDS, are not available. volumes have been low and, in order to make an impact, a “To my mind, instead of going for more active portfolio meaningful supply of the product is necessary. Regulators have management on a name-by-name basis, I think people are also stipulated that the supply of CCDS should come from stepping back and looking at the bigger picture,” he notes. outside the banking industry – that is, they do not want to see “Before Basel 3 specifics were announced, many banks had a reciprocal trade between banks, where one bank hedges no idea what their counterparty exposure looked like. The another and vice versa. However, non-bank suppliers – such new regulations are forcing people to think more about it.” as the monolines – are no longer in a position to sell protection. Mukherjee continues: “It has certainly brought people up “I struggle to see how a meaningful supply of CCDS will to scratch in capturing all of their derivative trades: they are emerge,” says Mukherjee. “The difference between vanilla putting in risk exposure clarification programmes and captur- CDS and CCDS is that a bank using CDS can distribute that ing the data properly. This is the first step.”3 www.structuredcreditinvestor.com October 2011

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SCI Special Report Wrong-way risk W rong-way risk – when the exposure to a counterparty and calculating it for a portfolio is a computationally-intensive is adversely correlated with the credit quality of that task. First, the correlations (co-dependence) between expo- counterparty – occurs in two forms. sures and default probabilities are generally very difficult to The first – and most commonly referred to – is ‘general’ estimate in practice. wrong-way risk. In this case, exposure to a counterparty may Given the complexity of wrong-way risk, the methodology be related to the likelihood of default through non-specific must be simple, robust and easy to understand. More impor- microeconomic factors, such as interest rates or general tantly, stress-testing and model-risk must be built into the market indices. Although general wrong-way risk is something core of the methodology. that can in principle be amenable to statistical analysis, in “One problem that arises is that counterparty exposure practice it may be difficult to estimate with a high degree of calculations are computationally expensive to begin with, requir- accuracy. ing the simulation of thousands of derivatives positions, over The second type of wrong-way risk is ‘specific wrong-way thousands of market scenarios and a hundred time-steps,” risk’. In this case, an exposure to a specific counterparty is Rosen notes. “In addition, systems in place at banks often very highly correlated to default. handle exposures and default simulations separately. A brute- “This generally arises from badly-structured transactions,” force Monte Carlo simulation is straightforward but not really explains Dan Rosen, ceo of R2 Financial Technologies. “For feasible, given the time and computer constraints and complex- example, a counterparty might be a company that writes put ity of the calculation. An effective methodology to calculate options on its own stock or that is collateralised with its own CVA and capital with wrong-way risk must necessarily leverage shares or shares of a subsidiary. If they go into default, what existing exposure simulation engines.” you think is collateralised isn’t actually collateralised and is CVA and economic capital calculations will be affected by worth nothing. That is true wrong-way risk and is something market-credit correlations. “It is more than just the pricing that can be avoided by structuring deals properly.” that is impacted, however,” adds Rosen. “If you are trying to Rosen explains that wrong-way risk is difficult to model hedge CVA, the hedges may not be effective.”Therefore banks have the incentive to carry out these transactions nological capabilities and models to compute CVA and counter-because capital charges in this space are increasing so much.” party credit risk are improving dramatically. Just because we Not everyone agrees that this market has a future, however, can do it, it does not mean we should do it,” continues Rosen.with questions over the investor base and the complexity of He remains concerned that another “monster” could besuch deals. “While it is good to push the boundaries of financial created, bringing a whole new set of problems. “As an industry,engineering with talk of securitising CVA, at the same time we we need to look for solutions for how to manage the CVA risk,also have to understand our own limitations,” notes Rosen. “I given that it is now embedded in accounting, P&L and in thethink that CVA securitisation is probably a bad idea. I do not regulations. But we need to find the right tools to do this.”see the idea of CVA securitisation developing and capturing Shankar Mukherjee, co-founder of Novarum, notes that itthe interest of sufficient investors and the approval of regulators.” would be difficult to see CVA becoming a serious traded risk He adds: “If done correctly, securitisation itself has proven to unless banks figure out a way to distribute the risk. “There havebe a powerful tool, which can bring funding and distribute risks been very few securitisations of CVA risk done and, consideringthrough the capital markets. We’ve also seen through the crisis the amount of risk on banks’ books, this shows that there isn’tthat, done wrongly, it can result in a financial disaster. I think the an effective mechanism at the moment to securitise,” he says.industry trend is towards simplicity and transparency.” He adds: “It comes back to the fact that CVA is a very difficult It is questionable whether investors will be able to understand risk to understand. Added to which is the fact that the risk profileand model the underlying risks of a structure based on the CCR changes over time and there’s no upper bound to what that exposureof complex underlying portfolios of derivatives, which are also might be. That makes it difficult for end investors to buy that risk.”changing continuously. “I think we will look for better solutions, Many banks may therefore reduce CVA risk by more simplebut I don’t think securitisation is the solution to managing coun- methods, such as restructuring transactions with various coun-terparty credit risk. Sure, our creativity as financial engineers terparties. This includes breaking transactions, mark-to-marketallow us to design vehicles to securitise any risk. Also our tech- resets, re-couponing or employing various techniques to restruc- ture the transaction that reduces the CVA number. Another option“While it is good to push is to sign a credit support annex (CSA) if a bank has a large amount of CVA with one particular counterparty. Industry participants also point out that putting credit hedgesthe boundaries of financial in place is expensive and there remains a large basis risk for names without liquid CDS markets. This means that creditengineering with talk of hedging of CVA on the market is usually the last resort after market hedging and restructuring. “One of the issues with actively trading CVA is there are trans-securitising CVA, we also action costs involved,” concludes Mukherjee. “Every time you buy a CDS, you pay a bid/offer spread to whoever you buy from. Everyhave to understand our time that position is re-hedged, again a bid/offer spread needs to be paid. If you look at how much it costs you over the life of theown limitations” deal, it can be quite significant, so you need to work out if it’s worth going out and spending all that money.”October 2011 www.structuredcreditinvestor.com 4