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The Basel III/IV framework contains a number of new and updated
measures to increase bank liquidity, decrease bank leverage, and to
strengthen risk management and regulation in the banking and
financial sector. The latest amendments were just finalized in
December 2017, and all features are expected to be implemented or
phased in by 2022. The framework increases capital charges
substantially and makes banking activities more capital intensive.
The cost of holding regulatory capital over the lifetime of a
portfolio to buffer and control counterparty losses therefore is
finding its way into derivatives pricing in the form of the capital
valuation adjustment (KVA). It supplements other upfront
adjustments such as credit, debit, funding, and collateral/margin
valuation adjustments (CVA, DVA, FVA, and ColVA/MVA,
respectively).
Estimating the lifetime cost of capital, or KVA, is a non-trivial
task. The capitalization of counterparty credit risk under Basel
III/IV builds on frameworks for counterparty default (CCR) risk and
credit valuation adjustment (CVA) risk and is reinforced by the
leverage ratio and the (risk-weighted) capital floor as backstops.
But even without considering the impact of these backstops, pricing
capital requirements can be challenging, as it requires fast and
accurate numerical estimation of exposures over potentially long
time horizons and high-dimensional risk factor spaces.
Both CCR and CVA capital use as one of the inputs the exposure-at-
default (EAD), whose non-internal model method (non-IMM)
alternatives were updated in Basel III/IV to the standardized
approach for measuring counterparty credit risk (SA-CCR). With the
new SA-CCR methodology, EADs are more risk-sensitive generally, but
also tend to be more conservatively calibrated than the previous
non-IMM methods, in particular in the absence of collateral. The
Basel III/ IV CCR capital framework, however, opens the door to
adjusting the EAD for incurred CVA as a capitallowering measure.
This follows from the fact that the upfront CVA already realizes
the expected cost of counterparty credit default. Its impact
therefore is recognized in Basel III/IV by the introduction of the
outstanding EAD, i.e. the maximum of zero and the EAD less the
incurred CVA, in lieu of solely the EAD (this applies to CCR
capital calculations only).
Under SA-CCR, estimating the EAD over the lifetime of a
transaction or portfolio is relatively straightforward. The SA-CCR
formulae can be embedded within a single Monte Carlo pass and
evaluated for each path and time step. Factoring in the incurred
CVA on the other hand is computationally more elaborate and, taking
the brute force route, requires lengthy nested Monte Carlo
simulations. To avoid this bottleneck, one may resort to least
squares Monte Carlo where the incurred (or forward evaluated) CVA
is approximated efficiently over the entire time horizon by
regressionbased proxies (see Figure 1).
Figure 1: One-path incurred/forward CVA projections for (a)
a 30-year USD interest rate swap and (b) a 30-year EUR/USD
cross-currency basis swap, based on nested Monte Carlo (NMC) and
two types of least squares Monte Carlo (LS1 and LS2). In the
present case, approach LS2 utilizes more explanatory variables than
LS1 and tends to agree better with the nested Monte Carlo
benchmark.
The success and accuracy of the regression approach, of course,
depends on a number of different factors, chiefly among them the
choice of regression basis functions and explanatory variables, but
also, to equally important extent, the way the regressionbased
proxies are used in subsequent computations. For CCR capital and
CCR KVA calculations, the incurred/forward CVA enters the
outstanding EAD, which in turn makes up part of the risk-weighted
asset (RWA) that the CCR risk framework relies on. The outstanding
EAD thus has to be manipulated accordingly to keep estimator bias
at bay. This is akin to the Longstaff-Schwartz approach to Bermudan
option pricing1. Hence, as with the Bermudan option exercise
boundary, the overall accuracy for CCR KVA computations therefore
ultimately comes down to accurately approximating the trigger
boundary of the max-operator of the outstanding EAD.
Some questions that arise naturally in this context are the
following: What is the actual impact of the incurred CVA on CCR
capital and/or CCR KVA? How accurate is the regression approach
typically? And, under what circumstances do the approximations
become increasingly challenging for CCR capital and CCR KVA? These
questions are hard to answer in general terms as portfolios and
netting sets can have complicated exposures and the time structure
of the CCR KVA integrand (partially determined, for example, by the
counterparty survival probability and/or the dynamics of the
internal ratings based (IRB) CCR risk weights) can sensitively
impact the final CCR KVA result.
The regression approach obviously also becomes more challenging the
larger the number of underlying risk factors. Simple instruments,
however, such as an interest rate swap or a cross-currency basis
swap (both without collateral) indicate that the SA-CCR EAD tends
to outsize the incurred/forward CVA, typically by up to a few
multiples. The reduction of CCR KVA due to upfront CVA therefore is
tangible, and even rough incurred/forward CVA proxies can lead to
good results.
In very rare circumstances, SA-CCR EAD and incurred CVA can be made
of roughly equal size, giving rise to relatively small CCR KVA. In
these cases, higher accuracy of the forward CVA estimate may be
desirable and can be achieved through further refinement of the
regression approach. Compared with other valuation adjustments, CCR
KVA appears to be smaller overall than the corresponding CVA KVA
(excluding CVA hedging) or the upfront CVA.
In a nutshell, even though the updates for counterparty credit risk
put in place by the Basel III/IV regulation have made counterparty
credit risk capital and the cost of capital more severe - to
encourage collateralization, hedging, and central clearing -
upfront CVA has a real, mitigating impact on CCR capital and CCR
KVA. The impact can be computed efficiently with exposure
simulations, and the accuracy can be reasonably well controlled by
utilizing a regression based proxy for incurred/forward CVA.
1 Longstaff, F. A. and Schwartz, E. S. (2001) Valuing
American Options by Simulation: A Simple Least-Squares Approach.
The Review of Financial Studies, 14, 113
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May 12
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