Fundamental Review of the Trading Book (FRTB) | Accenture
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FROM THEORY TO ACTION In January 2016, the Basel Committee on Banking Supervision (BCBS) published final rules for the market risk framework for capital requirements. The BCBS proposed the end of 2019 as a compliance deadline for banks with a significant presence in capital markets.1 The new rules – known as Fundamental FTRB encompasses a revised internal Review of the Trading Book or FRTB – are model approach characterized by a shift designed to address Basel 2.5 issues from Value-at-Risk (VAR) to the Expected such as the under-capitalization of the Shortfall (ES) measure of risk, for a better trading book, capital arbitrage between reflection of “tail risk” and capital adequacy banking and trading books, and internal during periods of significant financial risk transfers. Through the FRTB rules, market stress.3 BCBS is seeking, for example, to establish a more objective boundary between the trading book and the banking book, and to eliminate capital arbitrage between the regulatory banking and trading books.2 2 FUNDAMENTAL REVIEW OF THE TRADING BOOK (FRTB) CHALLENGES TO FRTB IMPLEMENTATION Accenture believes that adoption of the FRTB • Additional investment in technology rules presents banks with major challenges infrastructure for risk calculation. in areas related to business operations and infrastructure provisioning. According FRTB rules require banks to strengthen to our analysis and estimates we expect: their existing market risk infrastructure and overall technology capabilities, with • Significant increases (as much as additional computational capacity to 40 percent) in market risk capital support calculations as required under new requirements; capital requirements. Banks should also plan for additional complexity in operations and • Higher costs for rules implementation processes due to changed desk structures programs – ranging from $100 million and should undertake the standardization to $250 million for large banks; of data sources to support these changes. • Large increases in Business as Usual (BAU) costs due to desk level requirements; and Figure 1. Expected FRTB Timeline Q2Q3 2019 Supervisor approvals Q4 2017 Advanced implementation DEC 2019 of standardized approach Compliance and internal model deadline approach components to be completed Q4 2016 Q2Q3 2018 Project plan, gap analysis Production parallel and program funding run of FRTB to begin to be completed Q2 2017 Foundational components of strategic market risk infrastructure under implementation Note: Industry participants are in discussion with national supervisors and the BCBS around the compliance timeline for FRTB. This may lead to the compliance deadline moving beyond December 2019. Source: Minimum capital requirements for market risk, BCBS, January 2016 and Accenture estimates. 3 FUNDAMENTAL REVIEW OF THE TRADING BOOK (FRTB) The BCBS recommended deadline of Data requirements and risk December 31, 2019 may not seem imminent, measures at desk level but the journey to compliance is not easy. Banks should begin to address their FRTB FRTB rules are explicit in proposing implementation strategy immediately and the reporting structure of market risk plan for implementation issues going forward. to management and regulators would be checking this at the trading desk New rules affect these key areas: level.6 As we see it, banks would also need to obtain the data and run their P&L (profit and loss) attribution test risk calculations at a trading desk level and to adjust their data sourcing and P&L attribution test helps evaluate the calculation strategies accordingly. efficiency of the internal models and their ability to capture all the relevant For banks, major areas of focus include risks impacting the portfolio. This is strengthening existing market risk a new requirement and each trading infrastructure and technology capabilities; desk must independently pass this test. positioning additional computational If a desk experiences breaches four capacity to support FRTB calculations; or more times, then it will be put on and planning for additional complexity standardized approach methodology.4 in operations and processes due to changes in their desk structures (although Risk factor eligibility (modelable we believe that some banks may seek vs non-modelable) to incorporate this into ongoing Volcker Rule implementation activities) and Each of the risk factors which banks model the standardization of data sources. will need to undergo an eligibility check, meaning that the banks will need to obtain As shown in Figure 2, a majority of FRTB real prices for them.5 With this measure, rules have a direct or indirect impact we believe that BCBS aims to strengthen on banks’ data management strategies. the internal models to include only those Solving for data challenges would be risk factors which would have consistent a top priority as banks mobilize their interpretation by the banks. This will also resources in their efforts to comply. eliminate any ad-hoc risk factor inclusion to help reduce the capital impact. 4 FUNDAMENTAL REVIEW OF THE TRADING BOOK (FRTB) Figure 2. FRTB Impact Analysis Framework 1. TRADING BOOK BOUNDARY 2. STANDARDIZED APPROACH 3. INTERNAL MODEL AND RISK POLICY APPROACH 2.1 Sensitivity 2.4 Delta, Vega 3.4 Default 1.1 Trade and Bank 1.4 Covered 3.1 Risk Based Method and Curvature Risk Charge Book Boundaries Instruments Factor Analysis (SBM) Calculation (DRC) – IMA 3.2 Expected 3.5 Non-Modelable: 1.2 Trading 1.5 Risk 2.2 Establish 2.5 Default Risk Shortfall Capital Add-Ons Desk Identiication Management Risk Classes Charge (DRC) - SA Policies Calculation (SES) 1.3 Internal 1.6 Reporting 2.3 Securitization 2.6 Residual 3.3 Trading 3.6 Multi Liquidity Risk Transfers Requirements Risk Add-On Desk Eligibility Horizons 2.7 SA Capital 3.7 Calibration 3.8 IMA Capital Calculation to Stress Period Calculation Methodology Methodology 1, 2, 3. FUNCTIONAL FUNCTIONAL 3. 2, 1, REQUIREMENTS 4.1 Trading 4.3 Instrument 4.4 Residual Risk 4.6 SBM 4.8 IMA 4.10 P&L Book Boundary Redesignation Add-On Approval Calculator Risk Factors Attribution 4.2 Exception 4.5 Internal Risk 4.7 Model 4.9 Backtesting 4.11 Changes for Covered Transfers Controls Validation to IMA Model Instruments 4. SUPERVISORY SUPERVISORY 4. APPROVALS 5.1 Asset 5.3 Instrument 5.3 Risk 5.5 Capital 5.6 Risk Factor 5.8 Full Classiication Master Sensitivities Aggregation Pricing Data Revaluation Data Sourcing 5.2 Security 5.4 Data 5.7 Stress 5.9 P&L Attribution Reference Data Taxonomy Calculations and Backtesting 5. DATA & DATA 5. TECHNOLOGY High Impact Activities Source: Accenture Analysis 5 FUNDAMENTAL REVIEW OF THE TRADING BOOK (FRTB) DATA ISSUES FOR BANKS We see three data issues as fundamental to an effective implementation of the FRTB framework 6 FUNDAMENTAL REVIEW OF THE TRADING BOOK (FRTB) 1 RISK SENSITIVITIES Under the revised rules, a bank would SOURCING need to compute at least 79 different calculation inputs for each sensitivity The rules for standardized approach (SA) and class for risk computation under SA. The internal models approach (IMA) advocate new prescribed risk factors and liquidity both: the use of risk sensitivities and computation may lead to as many as consistency in their calculation which, for 12,000 calculations per trade, compared the first time, should be the same as those to the current 250 to 500 calculations per used for the pricing models or instrument trade under earlier Basel 2.5 regulations. prices in the P&L statement that management receives.7 Unlike previous standardized The SA has introduced the concept of models, the SA under FRTB rules makes use curvature risk to capture nonlinear risk of risk sensitivities to capture both linear which is not captured by the delta of the and nonlinear risk in the trading desk. instruments with optionality. Curvature risk is Banks are also required to calculate risk not a second order approximation, but rather charges using SA, identifying Delta, Vega and a full revaluation needed for every instrument Curvature sensitivities across all risk classes. affected. This means, we believe, that The rules specify the maturity buckets for banks would need to update infrastructure, each risk class and sensitivity combination to data availability, and IT capacity to run the arrive at a final sensitivity value per bucket, revaluation for all products with optionality. using netting rules. This should lead to a The new rules also specify that the comprehensive calculation of risk using SA, sensitivities should be calculated on the adding to the complexity of computation. prices of instruments or on pricing models Figure 3 below shows the number of buckets which are used for P&L reporting or market for each sensitivity and risk class combination risk management within the bank. This calls under a sensitivities-based method for SA. for consistency between the calculations used for computing sensitivities and the valuation models used by the front office for trading purposes. Figure 3. Number of Buckets for Sensitivities Calculation RISK CLASSES GIRR CSR – CSR – CSR – Equity Commodity FX Non-Securitization Securitization Securitization (CTP) (Non-CTP) Delta Individual 16 16 25 11 11 Individual currency currency Vega Individual 16 16 25 11 11 Individual currency currency SENSITIVITY Curvature Individual 16 16 25 11 11 Individual currency currency LEGEND: CSR: Credit Spread Risk CTP: Correlation Trading Portfolio GIRR: General Interest Rate Risk Source: Minimum capital requirements for market risk. Basel Committee on Banking Supervision,