www.pwc.

com/baseliv

Basel IV & CRR II: Revised

Standardised Approach for
Market Risk
Overview of all
requirements of the revised
Increasing risk sensitivity due to the
Standardised Approach for “Sensitivities-based Approach”
market risk.
Contents

Preface.................................................................................................................. 5
The revisions to the existing regulatory framework are focusing on
determination of risk weighted assets................................................................... 8
The FRTB addresses material weaknesses of the current market risk
framework exposed by the financial crisis … ....................................................... 9
… and aims to replace the existing regulation and harmonises the
treatment of market risk across national jurisdictions........................................ 10
FRTB as part of CRR II – sizing up the trading book............................................ 12
The FRTB introduces several enhancements to the existing framework............. 14

FRTB Framework: Sensitivities-based Approach................................................ 15

The revisions to the standardised approach (Sensitivities-based Approach)
aim to increase risk sensitivity............................................................................ 16
Sensitivities-based Method Definitions that cover the main concepts ................ 18
FRTB framework uses seven risk classes............................................................. 20
Linear risks within the Sensitivities-based Method are captured with
delta and vega risk factors.................................................................................. 24
Non-linear risks within the Sensitivities-based Method are captured
with the curvature risk factor............................................................................. 26
The final risk charge for the Sensitivities-based Method is determined
based on three correlation scenarios.................................................................. 28
The default risk charge is intended to capture the jump-to-default risk.............. 30
The residual risk add-on is introduced to ensure that the model provides
sufficient coverage of the market risks................................................................ 32

FRTB Impacts..................................................................................................... 35
FRTB will have significant impacts on banks in terms of their operational
capability, infrastructure, risk measurement, reporting and other areas........... 36
Typically substantial regulatory changes can be challenging for
institutions......................................................................................................... 38
Banks will experience significant increase in capital charges under the
revised standardised approach........................................................................... 39

Our Services....................................................................................................... 41
PwC has developed an MS-Access-based tool that complies
with the final BCBS 352 and CRR II standards.................................................... 42
With the tool we are able to do the necessary calculations for the
standardised approach....................................................................................... 43
Preface

Revised Standardised Approach for Market Risk 5

 Starting in 2012, the Basel Committee published several consultation
papers on a fundamental review of the trading book (FRTB) to adapt
existing rules for the capitalisation of market risk to the lessons
learned and shortcomings that became evident during the financial
crisis. This fundamental review covers all aspects of minimum
capital requirements for market risk such as the trading book –
banking book boundary, the standardised approach as well as the
use of internal market risk models.

Among the proposed changes, none has more profound impacts than the revised
standardised approach – the so called Sensitivities-based Approach. In fact,
it is less a standardised method than an internal model approach, developed
by the supervisors. It leads to an enormous increase in data requirements and
complexity of calculations compared to the current approaches. And it will
also have a significant impact on risk weighted assets, especially with regard
to positions subject to optionality or credit spread risks.

On 23 November 2016, the EU Commission has proposed amendments to the

capital requirement directive and regulation. The amendments will – beside
others – introduce more risk sensitive measures. The European Commission
has adopted the FRTB framework in the CRR II, that according to the Basel
Committee has a final status since January 2016.

6 Revised Standardised Approach for Market Risk

With regard to the standardised approach for market risk, the European
Commission kept the proposed Sensitivities-based Approach developed by
the BCBS with only minor changes. The most essential change to the FRTB
framework is connected to the principle of proportionality. This means that the
EU acknowledges the contradiction of the new requirements with the risks taken
by institutions with medium sized trading books. Therefore, medium trading
book institutions are allowed to apply a “Simplified Standardised Approach”.
Thus, they can further on determine the capital requirement for market risk
using the existing standardised approach.

This brochure will help you gain an overview over the proposed rules to prepare
for the tasks ahead.

Kind regards,

Martin Neisen Agatha Pontiki

Global Basel IV Leader Global Basel IV Standardised Approach
Workstream Leader

Revised Standardised Approach for Market Risk 7

The revisions to the existing regulatory framework are
focusing on determination of risk weighted assets
The Basel III framework has focused mainly on banks’ own funds requirements. Currently, the Basel Committee
on Banking Supervision (BCBS) is in the process of revising the standardised approaches for calculating
minimum capital requirements. The industry already summarises these revisions under the term “Basel IV”.
While the BCBS has not yet officially recognised this term the outcome is very clear: The revisions will have a
fundamental impact on the calculation of risk weighted assets and capital ratios of all banks regardless of their
size and business model. Beside FRTB, the European Commission has adopted further parts of the Basel IV
package (SA-CCR or CVA) within their proposed amendments to the CRR.

Fig. 1 Areas of revision by the BCBS

Counter­
Securiti­ Market Operational Step-in
Capital­ requirements Credit risk party CVA risk
sation risk risk risk
credit risk

Capital Interest rate SA for Revisions SA counter- Fundamental Revisions to Review of Step-in risk
floors risk in the credit risk to the party credit review of operational the CVA risk
banking securiti­ risk the trading risk framework
book sation book
framework
(BCBS 306,
BCBS 362) (BCBS 368) (BCBS 347) (BCBS 374) (BCBS 279) (BCBS 352) (BCBS 355) (BCBS 325) (BCBS 349)

8 Revised Standardised Approach for Market Risk

The FRTB addresses material weaknesses of the current market
risk framework exposed by the financial crisis …
Fig. 2 The fundamental review of the trading book (FRTB): An Overview

“The financial crisis exposed material weaknesses in the overall design of the framework for
capitalising trading activities.” (Basel Committee on Banking Supervision, October 2013)

Material weaknesses of current approaches … … require fundamental review

1
Trading book – banking Treatment of credit risk • B
 anking book/trading book boundary to be more
book boundary in the trading book objective
• Additional tools for supervision

2
Weaknesses of VaR Hedging and  ew standardised approach increases risk sensitivity
• N
approach diversification of RWA calculation
• Marked increase of complexity

3
• Internal models approach using Expected Shortfall (ES)
Liquidity of trading Transparency and
instead of Value-at-Risk (VaR)
book positions comparability of RWA
• Changes to model approval process
• Floor based on standardised method

Revised Standardised Approach for Market Risk 9

… and aims to replace the existing regulation and harmonises
the treatment of market risk across national jurisdictions
During the financial crisis it turned out that the regulatory capital for market risk
was not adequate. Therefore, the Basel Committee on Banking Supervision
has created with the fundamental review of the trading book (FRTB) a new
framework to replace the old market risk regulation defined under “Basel II.5”.
The intention is “to improve trading book capital requirements and to promote
consistent implementation of the rules so that they produce comparable levels of
capital across jurisdictions”.

Fig. 3 Key objectives of the FRTB

The proposals reflect BCBS’s key objectives

• To develop an effective trading book/banking book boundary condition,

• to achieve a regulatory framework that captures and capitalises all market risks in the trading book,
• to improve risk measurement techniques and
• to achieve comparable levels of capital across internal risk models and the standardised approach.

BCBS’s proposals align with the key objectives of the EU Commission

• To build on the principle of proportionality and strengthen the resilience of EU banks,
• to introduce more risk-sensitive capital requirements as well as
• to further reinforce banks‘ ability to withstand potential shocks

10 Revised Standardised Approach for Market Risk

 The past and future of the trading book regime

1996 Basel I
First methodology laid out by the BCBS to set out
capital requirements for market risks. The amendment 2004 Basel II
to the Basel Capital Accord included a standardised The amendment was further revised in 2005.
approach and an internal models approach. The paper changed the trading book regime.

2009 Basel 2.5

First attempt by the BCBS to address the trading book
issues revealed by the global financial crisis. Revisions
to the Basel II market risk framework. 2012 FRTB
The BCBS issued the fundamental review of the
2012–2015 trading book (FRTB) consultation paper.
Two more consultative papers and four
quantitative impact studies.
2016 Revised standards
In January 2016 the Basel Committee on Banking
Supervision (BCBS) published revised standards
for minimum capital requirements for market risk.
2019
Expected entry into force of CRR II and BCBS’s 2024
deadline for local regulation in January 2019 CRR II: End of phase-in period (three years after date
of application), in which large trading book institutions
are allowed to multiply their capital requirements by a
factor of 65%.
Revised Standardised Approach for Market Risk 11
FRTB as part of CRR II – sizing up the trading book
The CRR II includes the EU implementation of the fundamental review of
the trading book. In terms of methodologies for the own funds calculation
approaches, CRR II broadly follows the Basel framework and adopts the
revised approach proposed by the BCBS. The proposal introduces the new
more risk sensitive standardised approach (SBA) and variations to the internal
model approach (IMA). The new SBA includes the calculation of delta,
vega and curvature risk. During a three year phase-in period, the European
Banking Authority will review and report to the European Commission on the
appropriateness of the FRTB framework.

Although CRR II does not indicate the use of SBA as a floor to the capital
requirements under the IMA, discussions are still ongoing on this topic. While
the capital add-on under the IMA will impact firms with certain exposures, the
new residual risk add-ons under the SBA are also deemed to be capital intensive.
The capital floors and add-ons are key drivers that firms should consider in
adopting the IMA versus SBA for capital requirements calculation.

12 Revised Standardised Approach for Market Risk

A significant change compared to the Basel framework is the derogation for small and medium size trading
businesses, which CRR II introduces to address proportionality. Besides, there is a preferential risk weight
for EU sovereigns and covered bonds for credit spread risk under the Sensitivities-based Method.

Fig. 4 Overview FRTB application according to CRR II

Size of Trading Book On- and off-balance sheet trading book business

No market risk capital

Small Trading Book ≤ 5% of total assets ≤ 50 million requirements, application
of credit risk approaches

Permanent use of existing

Medium Trading Book ≤ 10% of total assets ≤ 300 million market risk standardised
approach possible

FRTB approaches to be
Large Trading Book > 10% of total assets > 300 million applied, multiplier of 65%
during the first three years

Revised Standardised Approach for Market Risk 13

The FRTB introduces several enhancements to the existing
framework
Fig. 5 Overview of the enhancements to the existing market risk framework

• N ew defined list of instruments presumed to be included in the trading book or banking

Regulatory boundary
book. Deviation requires explicit approval from supervisor.
between trading and
• Strict limits on the movement of instruments between the books after initial designation.
banking book
Should a re-designation be approved a capital benefit will not be allowed.
• T he new risk measure for market risk according to FRTB is the Expected Shortfall (ES).
• ES is a coherent risk measure, whereas Value-at-Risk (VaR) is not due to the missing
From VaR to sub-additivity feature.
ES • Banks must calibrate the ES to periods of significant market stress.
• This new metric will help to capture the tail risk and so maintain adequate capital during
periods of significant market stress.

Revised
• S ignificant changes with introduction of Sensitivities-based methodology.
standardised
• The revised standardised approach will act as a floor to the internal models approach.
approach

Inclusion of • V arying liquidity horizons included in the internal models approach.

market illiquidity • Replaces the static 10 day liquidity horizon currently assumed in the VaR framework.

Revised approach
• S upervisors will review the use of internal models at desk level.
to approval for
• More rigorous model approval process using both qualitative and quantitative criteria.
internal models

14 Revised Standardised Approach for Market Risk

FRTB Framework
Sensitivities-based
Approach

Revised Standardised Approach for Market Risk 15

 Default risk Residual risk
Delta risk Vega risk Curvature risk charge add-on
Linear risk Non-linear risk

The revisions to the standardised approach (Sensitivities-based

Approach) aim to increase risk sensitivity
The standardised approach mimimum capital requirement is the sum of
three components: Sensitivities-based Method and default risk charge provide
the main risk factors which are supported by residual risk add-on to sufficiently
cover market risks.

16 Revised Standardised Approach for Market Risk

Fig. 6 Overview of the revised standardised approach

Standardised approach

1. Sensitivities-based Method (Art. 325e – 325l CRR II) 2. Default risk charge 3. Residual risk
add-on
Delta risk Vega risk Curvature risk (Art. 325w CRR II) (Art. 325v CRR II)
Options only
Linear risk Non-linear risk

Delta: A risk measure based on sensitivities of A risk measure A risk measure that A risk measure to
a bank‘s trading book positions to regulatory which captures the captures the jump-to- capture residual
delta risk factors. incremental risk not default risk in three risk, i.e. risk which
Vega: A risk measure that is also based on captured by the delta independent capital is not covered by the
sensitivities to regulatory vega risk factors risk of price changes in charge computations. components 1. or 2.
to be used as inputs to a similar aggregation the value of an option.
formula as for delta risks. CRR II: additional CRR II: RTS on
adjustments i.a. for definition of exotic
covered bonds instruments
• C alculation of three risk charge figures based on three different scenarios on the specified values for the correlation
parameter (cf. slide 27).
• The approach how the total capital charge is aggregated differs between the proposals of BCBS and CRR II
• The bank must determine each delta and vega sensitivity based upon regulatory pre-defined shifts for the
corresponding risk factors.
• Two stress scenarios per risk factor have to be calculated and the worst scenario loss is aggregated in order to
determine curvature risk.

Revised Standardised Approach for Market Risk 17

 Default risk Residual risk
Delta risk Vega risk Curvature risk charge add-on
Linear risk Non-linear risk

Sensitivities-based Method
Definitions that cover the main concepts
The main concepts of the Sensitivities-based Method are given by the supervisor.

Especially the relevant risk classes differ in parts from the risk classes used in
the current approach.

18 Revised Standardised Approach for Market Risk

Fig. 7 Overview of the definitions that cover the main concepts

Definition of seven risk classes for the Sensitivities-based Method:

Risk GIRR Equity Commodity FX
class
CSR (non-SEC) CSR (SEC) CSR (CTP)

• V ariables (e.g. a given vertex of a given interest rate curve or an equity price) within a pricing function
Risk
decomposed from trading book instruments
factor
• Risk factors are mapped to a risk class

• M ain input that enters the risk charge computation

Risk
• Delta and vega risks: sensitivity to a risk factor
position
• Curvature risk: worst loss of two stress scenarios

Bucket Set of risk positions which are grouped together by common characteristics

• A mount of capital that a bank should hold as a consequence of the risks it takes
Risk
• Computed as an aggregation of risk positions first at the bucket level, and then across buckets within a
charge
risk class defined for the Sensitivities-based Method

Revised Standardised Approach for Market Risk 19

 Default risk Residual risk
Delta risk Vega risk Curvature risk charge add-on
Linear risk Non-linear risk

FRTB framework uses seven risk classes (1/2)

GIRR, Equity, Commodity & FX
Fig. 8 O
 verview of risk classes and corresponding risk buckets, risk weights
and correlations (1/2)

Risk buckets

GIRR Each bucket represents an individual currency

(General interest rate risk) exposure to GIRR

• B uckets are depending on market capitalisation,

economy (emerging or advanced) and sector
Equity
• Total of 11 buckets (e.g. consumer goods and
telecommunication)

Eleven buckets are defined for commodity (e.g. energy,

Commodity freight, metals, grains & oilseed, livestock and other
agriculturals)

Foreign Exchange (FX) No specific FX buckets

20 Revised Standardised Approach for Market Risk

 Risk weights Correlations

• R isk weights (RW) depending on vertices ranging

Correlations between two sensitivities are depending
from 0.25 years to 30 years
on equality of buckets, vertices and curves
• Risk weights are ranging from 1.5% to 2.4%

• D ifferentiation between risk weights to equity spot Correlations between two sensitivities for the same
price and equity repo rate bucket (but related to different equity issuer names)
• Risk weights for equity spot price ranges from are depending on market cap and economy and are
55% to 70% ranging between 7.5% and 25%

• T he risk weights depend on the commodity buckets Correlations between two sensitivities (same bucket)
(which group individual commodities by common are defined by a multiplication of factors related to
characteristics) commodity type, vertices and contract grade / delivery
• Risk weights range from 20% to 80% location

A unique relative risk weight equal to 30% applies to A uniform correlation parameter equal to 60% applies
all the FX sensitivities or risk exposures to FX sensitivity or risk exposure pairs

Revised Standardised Approach for Market Risk 21

 Default risk Residual risk
Delta risk Vega risk Curvature risk charge add-on
Linear risk Non-linear risk

FRTB framework uses seven risk classes (2/2)

Credit spread risk (CSR)
Fig. 9 O
 verview of risk classes and corresponding risk buckets,
risk weights and correlations (2/2)

Risk buckets

CSR non-securitisation 18 buckets defined based on credit quality and sector

CSR correlation trading The same bucket structure as for CSR non-
portfolio (CTP) securitisation applies

CSR non-correlation
25 buckets defined based on credit quality and sector
trading portfolios (n-CTP)

22 Revised Standardised Approach for Market Risk

 Risk weights Correlations

• C orrelations between sensitivities within the same

• R isk weights are the same for all vertices within each
bucket are depending on names and vertices of the
bucket
sensitivities, and related curves
• Risk weights range from 0.5% to 12%
• Separate rules for “other sector” bucket

• R isk weights are the same for all vertices within each The risk correlations are derived the same way as for
bucket CSR non-securitisation, but correlations based on
• Risk weights range from 2% to 16% curves differ slightly

• C orrelations between sensitivities within the same

bucket and securitisation tranche are depending on
Risk weights range from 0.8% to 3.5% names and vertices of the sensitivities, and related
curves
• Separate rules for “other sector” bucket

Revised Standardised Approach for Market Risk 23

 Default risk Residual risk
Delta risk Vega risk Curvature risk charge add-on
Linear risk Non-linear risk

Linear risks within the Sensitivities-based Method are captured

with delta and vega risk factors
The computational procedure for linear risks can be divided into the
five calculation steps shown below. Delta and vega risk measures are based
on sensitivities of bank’s trading book positions to regulatory predetermined
delta and vega factors, respectively. These measures are used to calculate the
minimum capital requirements for Sensitivities-based Method.

24 Revised Standardised Approach for Market Risk

Fig. 10 Overview of the computational procedure for the linear risk charge

Calculation Supervisory formulae Details

Assignment of • D elta and vega risks are computed using the same
1

All posi-

Bucket

factor
class
positions to risk aggregation formulae on all relevant risk factors

tions

Risk

Risk
classes, buckets • Separate calculation (no diversification benefit
and risk factors recognised)

Calculation of e.g. for GIRR: • T he sensitivities are defined by the supervisor

2 the risk factor’s • Sensitivities for each risk class are expressed in
sensitivities the reporting currency of the bank

Calculation of The corresponding RW are defined by the supervisor

3 weighted sensitivities
per bucket via given
supervisory RW

Aggregation of The risk position for bucket b, Kb, must be

4 weighted sensitivities determined by aggregating the weighted
per bucket sensitivities to risk factors within the same bucket
using the corresponding prescribed correlation ρ kl

Aggregation of • T he risk charge is determined from risk positions

5 capital charge on risk aggregated between the buckets within each risk
class level class
• Sb and Sc are the sums of the weighted
sensitivities in the corresponding buckets

Revised Standardised Approach for Market Risk 25

 Default risk Residual risk
Delta risk Vega risk Curvature risk charge add-on
Linear risk Non-linear risk

Non-linear risks within the Sensitivities-based Method are

captured with the curvature risk factor
The computational procedure approach for non-linear risks can be divided
into three calculation steps that are shown below. The curvature risk measure
represents the incremental risk not captured by the delta risk of price changes
in the value of an option.

26 Revised Standardised Approach for Market Risk

Fig. 11 Overview of the computational procedure for the non-linear risk charge

Calculation Supervisory formulae Details

Finding a net • O
 nly for risk positions with explicit or
1 curvature risk embedded options
charge CVRk • T
 wo stress scenarios are to be
across computed per risk factor (an upward
instruments to shock and a downward shock)
each curvature • T
 he worse potential loss of the
risk factor k two scenarios, after deduction of the
delta risk positions, is the outcome of
the first scenario

Aggregation of •  (CVRk, CVRl) is a function that takes

2 curvature risk the
exposure within value 0 if CVRk and CVRl both have
each bucket using negative signs
the corresponding • In all other cases, (CVRk, CVRl)
prescribed takes the value of 1
correlation ρ kl

Aggregation of  (Sb, Sc) is a function that takes the

3 curvature risk value 0 if Sb and Sc both have negative
positions across signs. In all other cases, (Sb, Sc) takes
buckets within the value of 1.
each risk class

Revised Standardised Approach for Market Risk 27

 Default risk Residual risk
Delta risk Vega risk Curvature risk charge add-on
Linear risk Non-linear risk

The final risk charge for the Sensitivities-based Method is

determined based on three correlation scenarios
In order to address the risk that correlations increase or decrease in
periods of financial stress, three risk charge figures are to be calculated for
each risk class. This is done by using multipliers for correlation parameters
ρ (correlation between risk factors within a bucket) and γ (correlation across
bucket within a risk class).

28 Revised Standardised Approach for Market Risk

Fig. 12 Overview of the correlation scenarios

The correlation scenarios

Low correlations Medium correlations High correlations

Multiplier Multiplier Multiplier

0.75 1 1.25

Sensitivities-based Method capital charge

According to Art. 325i of CRR II, the calculation of delta, vega and curvature
capital requirements should be performed separately per risk class in all three
correlation scenarios. The aggregation across risk classes is conducted per
scenario and risk type. Thus, three scenario specific capital requirements for
delta, vega and curvature risk are required to be calculated. The final
Sensitivities-based Method capital charge is the sum out of the largest of the
scenario-specific capital charges for delta, vega or curvature risk.

Revised Standardised Approach for Market Risk 29

 Default risk Residual risk
Delta risk Vega risk Curvature risk charge add-on
Linear risk Non-linear risk

The default risk charge is intended to capture the jump-to-

default risk
The default risk charge is independent from the other capital charges for CSR
non-securitisations and securitisations in the standardised approach.

One prime modification of CRR II refers to the calculation of the Default Risk
Charge (DRC). The DRC formula has been extended by an adjustment for
derivative instruments which increases or reduces the full loss on the underlying
instrument.

30 Revised Standardised Approach for Market Risk

Fig. 13 Overview of the computational procedure for the default risk charge

Calculation Supervisory formulae Details

Calculation e.g. for debt instruments: The jump-to-default (JTD) risk is computed
1 of gross JTD for each instrument separately. JTD risk is a
positions function of notional amount (or face value)
and market value of the instruments and
prescribed Loss given Default (LGD) figures.

Calculation e.g. Non-securitisation: long bond position The net JTD risk positions are calculated by
2 of net JTD and short equity position to the same obligor using specified offsetting rules.
positions

Hedge benefit In order to recognise hedging relationship

3 recognition between long and short positions within a
bucket, a hedge benefit ratio is computed
and applied to discount the hedge benefits.

Bucket allocation e.g. for non-securitisation and securitisation • J

 TD positions are allocated to buckets
4 and calculation non-correlation trading portfolio (NCTP) and weighted. For non-securitisation risk
of weighted net weights are prescribed and for securitisation
JTD positions risk weights are to be computed applying
and default the banking book regime.
capital charge • F
 or non-securitisation and securitisation
(DRC) NCTP the overall capital charge is the
simple sum of the bucket level risks. For the
correlation trading portfolio capital charge
is the sum of positive bucket level risks and
half of the negative bucket level risks.
Revised Standardised Approach for Market Risk 31
 Default risk Residual risk
Delta risk Vega risk Curvature risk charge add-on
Linear risk Non-linear risk

The residual risk add-on is introduced to ensure that the model

provides sufficient coverage of the market risks
As not all market risks can be captured with the standardised approach without
necessitating an unduly complex regime, a residual risk add-on was
introduced to the framework. It is to be calculated for all instruments
bearing residual risk separately and in addition to any other capital
requirements within the standardised approach. The scope of instruments that
are subject to the residual risk add-on must not have an impact in terms of
increasing or decreasing the scope of risk factors subject to the other
standardised approach components.

32 Revised Standardised Approach for Market Risk

Fig. 14 Overview of the residual risk charge

Calculation Details

• T he residual risk add-on is the simple sum of gross notional amounts of the instruments
bearing residual risks
Residual risk add-on • RW = 1.0% for instruments with an exotic underlying (e.g. longevity risk, weather or
natural disasters)
• RW = 0.1% for instruments bearing other residual risks

Criteria for instruments bearing other residual risks

Instruments subject to vega or curvature risk capital Instruments which fall under the definition of the
charges in the trading book and with pay-offs that correlation trading portfolio (CTP), except for those
cannot be written or perfectly replicated as a finite linear instruments which are recognised in the market risk
combination of vanilla options with a single underlying framework as eligible hedges of risks within the CTP
equity price, commodity price, exchange rate, bond price,
CDS price or interest rate swap

According to Art. 325v of CRR II, instruments that are listed on a recognised
exchange, that are eligible for central clearing or that perfectly offset the market
risk of another position of the trading book should not be fall in the scope of the
residual risk add-on.

Revised Standardised Approach for Market Risk 33

FRTB Impacts

Revised Standardised Approach for Market Risk 35

FRTB will have significant impacts on banks in terms of their
operational capability, infrastructure, risk measurement,
reporting and other areas
The institutions are faced with a variety of adjustments and changes in the
methodology of calculating the capital charge for market risk. Results of the
quantitative impact studies published by the Basel Committee (BCBS 346)
predict a simple mean increase of 41% and a weighted average
increase of 74% in total market risk capital requirements. Still,
some of this impact can be mitigated by portfolio re-optimisation.

36 Revised Standardised Approach for Market Risk

Fig. 15 Impact of the FRTB

Capital optimisation Desk level review

• Asset classes and trading desks • Desk level review will likely increase the complexity of internal
contributing mainly to the capital charge models, which need to be tailored to each desk
should be identified and their portfolios • Banks need to consider if they need to restructure their desks to
analysed reduce complexity related to models and the capital calculation
• This may lead to the identification of data
issues increasing regulatory capital
• Adapting the asset allocation can Desk level Data availability
review
minimise the capital charge • B anks need to develop and maintain
Capital Data architecture and infrastructure capability
Regulatory reporting
optimisation availability • T he data processes must be checked to
Market
• Business specifications must be in risk
provide the necessary data for correctly
place defining the aggregation & final capital mapping instruments to the trading or the
reporting process charge banking book and capital calculation
Regulatory Methodo-
• Optionality features in the portfolio reporting logy
• Insufficient data on instruments may result
require an appropriate instrument in instruments being mapped to residual
valuation metho­dology for the curvature
Portfolio buckets, thus increasing regulatory
review capital.
risk charge
• Broadened supervisory scope will require
more communication between banks and
the supervisors
Methodology
• Sensitivities-based methodology and expected
Portfolio review shortfall are significant new additions
Banks need to review their trading book to understand • Complexity of the methodology increases which
how the new methodology impacts the capital may cause challenges especially for smaller
consumption institutions

Revised Standardised Approach for Market Risk 37

Typically substantial regulatory changes can be challenging for
institutions
Fig. 16 Overview of selected areas of regulatory change

Special attention must be paid to several aspects of the operations and support framework

Policy frameworks: As part of Infrastructure: As calculation of the

implementation of the revised standards standardised approach capital charge will
banks need to review and revise their internal become mandatory for benchmarking and
policies and related procedures (including the fallback purposes, the need to build,
trading book policy, the market risk policy, maintain and develop risk systems – as
the model management policy, and the model well as data availability and quality within
validation and backtesting policy) the banks – increases

Processes, models and controls: We Resources: We expect that the changes will
expect need for banks to reassess and cause a (temporary) demand for additional
organise their business processes and skilled risk personnel within the banks
controls as a result of the new standards.
The representation of risk may diverge
further between business and regulatory
needs. This is likely to be reflected in the
processes and models needed to fulfil
these needs

38 Revised Standardised Approach for Market Risk

Banks will experience significant increase in capital charges
under the revised standardised approach
Figure 16 shows the increase in capital requirements under the revised
standardised approach compared to the current standardised approach.
According to the FRTB – interim impact analysis from November 2015, capital
requirements will increase for all risk classes. FX risk class faces the most radical
increase. In total, the mean increase in capital charge is 103% and the
median is 83%.

Fig. 17 Overview of the potential impact on capital requirements

Commodity risk 90% 30%

FX risk 115% 88%

Interest rate + Credit spread

112% 37%
+ Equity + Default risk

Total 103% 83%

Increase in capital charge Mean Median

Source: FRTB – interim impact analysis (BCBS346), page 8, Table 3c, November 2015.
Note: Results are not based on the final framework.

Revised Standardised Approach for Market Risk 39

Our Services

Revised Standardised Approach for Market Risk 41

PwC has developed an MS-Access-based tool that complies with
the final BCBS 352 and CRR II standards
Fig. 18 PwC SBA-Tool 2.0: Key facts

PwC Standardised Approach-Tool Implementation potential

Pragmatic test calculations

Calculation of capital requirements for

delta-, vega-, curvature and default risk
as well as additional risk add-on for all
desks

Calculations for all asset classes are

MS Access-based tool for calculating the Standardised possible
 Approach
High adaptability of the tool to client specific needs
 (e.g. report function and analysis function) High adaption flexibility for e.g. scenario
analysis with different correlation
 High performance regardless of portfolio size parameters

42 Revised Standardised Approach for Market Risk

With the tool we are able to do the necessary calculations for
the standardised approach
Fig. 19 Overview of the front-to-back calculation environment

Data extraction
Front office system (Portfolio data)
XML standard for typical front office system supported (Murex,

PwC front-to-back calculation environment

Summit)
Deal data
 FPML format supported for Murex (other possible)

 CSV/Excel
Data extraction & formatting
Sensitivity computation
Adaptiv FinCad F3 Full coverage plain vanilla products (IR, FX, EQ, Credit) & some
Valuation Valuation
 light exotics
& Sensi & Sensi
 Extensions for other exotics possible
Sensitivities  Sensitivities/shifts delta/scenarios calculation

SA-Tool SA-Tool
 SBA methodology implemented (January 2016)

 Sensitivities/shifts delta/scenarios calculation

Revised Standardised Approach for Market Risk 43

 Our Expertise
Whether regarding the Basel Committee, EU-regulation or national legislation –
we use our established know-how of the analysis and implementation of new
supervisory regulation to provide our clients with high-quality services. Embedded
into the international PwC network, we have access to the extensive
knowledge of our experts around the world.

PwC’s Basel IV Initiative was established to support you in all aspects of

getting compliant with the new regulatory requirements to the trading book –
accomplishing a prestudy as a first step, supporting you at quantitative impact
studies (QIS) up to the implementation at all business units and areas of the bank.

PwC can draw on long lasting experience of implementing new regulatory

requirements by supporting a number of banks in completing quantitative impact
studies prior to the implementation of Basel II and Basel III and by the
functional and technical implementation of the final regulations. The PwC-tools
used during the QIS are flexible and will be updated automatically in case of new
consultations by the Basel Committee.

44 Revised Standardised Approach for Market Risk

About us
PwC helps organisations and individuals create the value they’re looking for.
We’re a network of firms in 157 countries with more than 195,000 people who are
committed to delivering quality in assurance, tax and advisory services. Tell us
what matters to you and find out more by visiting us at www.pwc.com. Learn more
about PwC by following us online: @PwC_LLP, YouTube, LinkedIn, Facebook and
Google+.

Revised Standardised Approach for Market Risk 45

Contacts
Global Basel IV Leader Austria
Martin Neisen Andrea Vollmann
Tel: +49 69 9585-3328 Tel: +43 1 501 88-2981
[email protected] [email protected]

Global Basel IV Standardised Australia

Approach Workstream Leader Katherine Martin
Agatha Pontiki Tel: +61 (2) 8266-3303
Tel: +44 77 300-67469 [email protected]
[email protected]
Belgium
Alex Van Tuykom
Tel: +32 2 710-4733
[email protected]

CEE
Jock Nunan
Tel: +381 113302-120
[email protected]

46 Revised Standardised Approach for Market Risk

Cyprus Finland
Elina Christofides Marko Lehto
Tel: +357 22555-718 Tel: +358 20 787-8216
[email protected] [email protected]

Denmark France
Janus Mens Marie-Hélène Sartorius
Tel: +45 3945-9555 Tel: +33 1 56575-646
[email protected] [email protected]

Lars Norup Germany

Tel: +45 3945-9195 Dirk Stemmer
[email protected] Tel: +49 211 981-4264
[email protected]
Estonia
Ago Vilu Stefan Röth
Tel: +372 614-1800 Tel: +49 69 9585-3841
[email protected] [email protected]

Revised Standardised Approach for Market Risk 47

 Greece Italy
Georgios Chormovitis Pietro Penza
Tel: +30 210 6874-787 Tel: +39 6 57083-2158
[email protected] [email protected]

Hong Kong Gabriele Guggiola

Kishore Ramakrishnan Tel: +39 346 507-9317
Tel: +852 2289-1983 [email protected]
[email protected]
Latvia
Hungary Tereze Labzova
Emöke Szántó-Kapornay Tel: +371 67094-400
Tel: +36 1461-9295 [email protected]
[email protected]
Lithuania
Ireland Rimvydas Jogela
Ciaran Cunniningham Tel: +370 5 239-2300
Tel: +353 1 792-5328 [email protected]
[email protected]

48 Revised Standardised Approach for Market Risk

Luxembourg Poland
Jean-Philippe Maes Piotr Bednarski
Tel: +352 49 4848-2874 Tel: +48 22 746-7049
[email protected] [email protected]

Malta Zdzislaw Suchan

Fabio Axisa Tel: +48 22 746-4563
Tel: +356 2564-7214 [email protected]
[email protected]
Portugal
Netherlands Luís Barbosa
Abdellah M’barki Tel: +351 213 599-151
Tel: +31 88 792-5566 [email protected]
[email protected]
Russia
Jan Wille Nikola Stamenic
Tel: +31 88 792-7533 [email protected]
[email protected]

Revised Standardised Approach for Market Risk 49

 Slovenia Switzerland
Pawel Peplinski Reto Brunner
Tel: +386 1 5860-00 Tel: +41 58 792-1419
[email protected] [email protected]

Czech Republik Ukraine

Mike Jennings Lyudmyla Pakhucha
Tel: +420 251 152-024 Tel: +380 44 3540-404
[email protected] [email protected]

Spain/Andorra United Kingdom

Alvaro Gonzalez Nigel Willis
Tel: +34 915 684-155 Tel: +44 20 7212-5920
alvaro.benzo.gonzalez-coloma@ [email protected]
es.pwc.com
Hortense Huez
Sweden Tel: +44 20 721-33869
André Wallenberg [email protected]
Tel: +46 10 212-4856
[email protected]

50 Revised Standardised Approach for Market Risk

This publication has been prepared for general guidance on matters of interest only, and does not constitute
professional advice. You should not act upon the information contained in this publication without obtaining specific
professional advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of
the information contained in this publication, and, to the extent permitted by law, PwC does not accept or assume any
liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance
on the information contained in this publication or for any decision based on it.

© 2017 PwC. All rights reserved.

PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity.
Please see www.pwc.com/structure for further details.

www.pwc.com