- Question ID
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2015_1748
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Market risk
- Article
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285
- Paragraph
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3
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Not applicable
- Article/Paragraph
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Not appliable
- Type of submitter
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Investment firm
- Subject matter
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Application of volatility haircuts adjusted under Article 285(3) (extended margin period of risk)
- Question
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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?
- Background on the question
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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.
- Submission date
- Final publishing date
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- Final answer
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Article 285(3) of Regulation (EU) No 575/2013 (CRR), which defines minimum Margin Period of Risk (MPOR) for the computation of the exposure value for netting sets subject to margin agreements when using the Internal Model Method (IMM), does not specify the liquidation period for the purposes of Article 225(3)(b).
Article 225(3)(b) of the CRR only refers to the liquidation period the institution uses in its day-to-day risk management process, not to the MPOR defined for the purposes of IMM.
Notwithstanding this, the MPOR of at least 20 business days determined in Article 285(3)(b) of the CRR for trades involving illiquid collateral is economically sensible, and should therefore be at least a benchmark for the institution's own risk management processes.
- Status
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Final Q&A
- Answer prepared by
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Answer prepared by the EBA.
- Note to Q&A
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Update 26.03.2021: This Q&A has been reviewed in the light of the changes introduced to Regulation (EU) No 575/2013 (CRR) and continues to be relevant.
Disclaimer
The Q&A refers to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.