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Prudent Valuation Bridging the gap between pricing and risk management Cass Business School London, 4 November 2015 Marco Bianchetti Intesa Sanpaolo, Financial and Market Risk Department In collaboration with Umberto Cherubini Associate Professor of Mathematical Finance, Univ. of Bologna

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Page 1: Interest Rates After the Credit Crunch...Case study of AVA MPU calculation for a security. • Top left: market bid and ask prices. FV is computed as average mid price = 162.25. •

Prudent ValuationBridging the gap between pricing and risk management

Cass Business School

London, 4 November 2015

Marco Bianchetti – Intesa Sanpaolo, Financial and Market Risk Department

In collaboration with Umberto Cherubini – Associate Professor of Mathematical Finance, Univ. of Bologna

Page 2: Interest Rates After the Credit Crunch...Case study of AVA MPU calculation for a security. • Top left: market bid and ask prices. FV is computed as average mid price = 162.25. •

M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 2

Summary

1. Introduction

2. Regulation

3. AVA calculation

4. Conclusions

5. References

Page 3: Interest Rates After the Credit Crunch...Case study of AVA MPU calculation for a security. • Top left: market bid and ask prices. FV is computed as average mid price = 162.25. •

M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 3

1: IntroductionOverview

Traditionally, quantitative finance practitioners are divided into two populations: thosewho seek fair values, i.e. means of price distributions, and those who seek riskmeasures, i.e. quantiles of price distributions. Fair value people and risk people typicallylive in separate lands, and worship different gods: the profit and loss balance sheet, andregulatory capital, respectively.

Prudent Valuation is a rather unexplored midland which has recently emergedsomewhere in between the well known mainlands of Pricing and Risk Management. Infact, the Capital Requirements Regulation (CRR), requires financial institutions to applyprudent valuation to all fair value positions. The difference between the prudent valueand the fair value, called Additional Valuation Adjustment (AVA), is directly deductedfrom the Core Equity Tier 1 (CET1) capital. On March 31st 2014, the European BankingAuthority (EBA) published a draft Regulatory Technical Standards (RTS) for prudentvaluation, to be approved by the EU Commission.

The 90% confidence level required by regulators for prudent valuation links quantiles ofprice distributions (exit prices) to capital, thus bridging the gap between the Pricing andRisk Management mainlands, and forcing the crossbreeding of the fair value and riskpopulations above.

In this seminar, we will explore the Prudent Valuation land.

Page 4: Interest Rates After the Credit Crunch...Case study of AVA MPU calculation for a security. • Top left: market bid and ask prices. FV is computed as average mid price = 162.25. •

M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 4

1: IntroductionOverview

Q-LandQ-measure

Pricing: extrapolate the presentFair value

Profit and loss

P-LandP-measure

Risk: model the future

Risk measuresCapital

Prudent LandPrudent measurePrice distribution90% exit price

Capital

See A. Meucci, “P versus Q: Differences and Commonalities between the Two Areas of Quantitative Finance”, GARP Risk Professional, pp. 47-50, February 2011, http://ssrn.com/abstract=1717163

Page 5: Interest Rates After the Credit Crunch...Case study of AVA MPU calculation for a security. • Top left: market bid and ask prices. FV is computed as average mid price = 162.25. •

M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 5

1: Introduction Prudent valuation history [1]

August 2008

FSA “Dear

CEO letter”

November 2010

FSA “Product Control

Findings and Prudent

Valuation Presentation”

April 2012

FSA “Regulatory Prudent

Valuation Return”, Policy

Statement

2008 2009 2010 2011 20122006 20072004 2005

June 2004

BCBS “International Convergence

of Capital Measurement and

Capital Standards” (Basel 2),

sec. VI (“Trading book issues”),

ch. B (“Prudent valuation

guidance”), par. 690-701.

Page 6: Interest Rates After the Credit Crunch...Case study of AVA MPU calculation for a security. • Top left: market bid and ask prices. FV is computed as average mid price = 162.25. •

M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 6

1: Introduction Prudent valuation history [2]

13 November 2012

EBA Discussion

Paper

(EBA/DP/2012/03)

10 July 2013

EBA Consultation

Paper

(EBA/CP/2013/28)

1 January

2014

CRR

575/2013

31 March 2014

EBA Final Draft RTS and first

application of prudent valuation

Q3 or Q4 2015

Expected final approval

of EBA RTS by the

European Commission

8 November 2013

EBA Quantitative

Impact Study

2012 2013 2014 2015

23 June 2015

EBA Final Draft

RTS amended

Dashed = unofficial

Prudent valuation in

place

Page 7: Interest Rates After the Credit Crunch...Case study of AVA MPU calculation for a security. • Top left: market bid and ask prices. FV is computed as average mid price = 162.25. •

M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 7

2: Regulation CRR 575/2013 [1]

Page 8: Interest Rates After the Credit Crunch...Case study of AVA MPU calculation for a security. • Top left: market bid and ask prices. FV is computed as average mid price = 162.25. •

M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 8

2: Regulation CRR 575/2013 [2]

Art. 34Prudent valuation

scope

Systems and

controls

Valuation

Valuation

adjustments

Art. 105

CRR

575/2013

CRR Prudent Valuation Tree

Prudent valuation

principles

Degree of certainty, art. 105.1

S&C requirements, art. 105.2

Revaluation frequency art. 105.3

Mark to market, art. 105.4-5

Mark to model, art. 105.6-7

IPV, art. 105.8

Valuation adjustments, art. 105.9-10

Illiquid positions, art. 105.11

Other valuation adj., art. 105.12

Complex products, art. 105.13

Page 9: Interest Rates After the Credit Crunch...Case study of AVA MPU calculation for a security. • Top left: market bid and ask prices. FV is computed as average mid price = 162.25. •

M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 9

2: RegulationEBA RTS: overview

General

provisions

Sec. 1

Core

approach

Sec.3

EBA RTS

Final draft

EBA RTS Prudent Valuation Tree

Simplified

approach

Sec.2

Documentation

systems &

controls

Sec.4

Methodology for AVA, art. 1

Definitions, art. 2

Sources of market data, art. 3

Conditions of application, art. 4

AVA calculation, art. 5

AVA aggregation, art. 6

Overview, fall back, art. 7

General provisions, art. 8

AVA calculation, art. 9-17

Documentation, art. 18

Systems & controls, art. 19

Entry into force, art. 20 AVA OpR, art. 17

AVA EaT, art. 16

AVA FAC, art. 15

AVA CoPo, art. 14

AVA FVA, art. 13

AVA CVA, art. 12

AVA MoRi, art. 11

AVA CoCo, art. 10

AVA MPU, art. 9

Page 10: Interest Rates After the Credit Crunch...Case study of AVA MPU calculation for a security. • Top left: market bid and ask prices. FV is computed as average mid price = 162.25. •

M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 10

2: RegulationEBA RTS: prudent valuation scope

Positions subject

to prudential

filters (AFS)

Positions in

hedge

accounting

Positions for which a

change in their

accounting fair value

has only a partial or

zero impact on CET 1

(art. 4.2 and 8.1)

EBA RTS Prudent Valuation scope: exclusions

Positions in

back to back

EU Gov. bonds

Other bonds

Equity

General criteria

for exclusionPositions excluded

% of

exclusion

100%

Partial

Partial

Simplified appr.

Partial, residual exposure

of hedged + hedging items

Core appr.

100%

Partial, residual exposure

to CVA, FVA, CoPo, FAC,

EaT, OpR AVAs

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M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 11

2: RegulationGlobal view of key regulatory concepts

Fair

value

CRR art. 34, 105

EBA RTS

Prudent

value

Scope and exclusions

90% confidence level

Simplified approach

Mark to market

Mark to model

IPV

Systems

and

controls

Core approach

Expert based

Fall back

Diversification

0.1% Formula

9 AVAs

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M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 12

Price distribution, fair value, fair value adjustment, prudent value, AVA

What about realprice distributions...?

Fair value

(mean)Fair value

adjusted

Prudent value

(quantile)

Fair value adjustment

AVA

2: RegulationFair Value Vs Prudent Value [1]

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M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 13

2: Regulation Fair Value Vs Prudent Value [2]

Fair Value

o Regulation: IFRS13

o Application: balance sheet

o Percentile: 50% (expected

value)

o The price that would be received

to sell an asset or paid to

transfer a liability in an orderly

transaction between market

participants at the measurement

date

o Must include all the factors that

a market participants would use,

acting in their economic best

interest.

o Atoms: single trades.

o Fair value adjustments

o Non-entity specific

Prudent value

o Regulation: CRR/EBA

o Application: CET1

o Percentile: 90%

o Must reflect the exit price at which

the institution can trade within the

capital calculation time horizon.

o Atoms: valuation positions subject

to a specific source of price

unertainty

o Entity specific

o Subject to diversification benefit

(50% weight for MPU, CoCo, MoRi

AVAs)

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M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 14

The EBA conducted a QIS to estimate the total impact of the requirements of the RTSincluding 59 banks across 15 jurisdictions, with the following results.

Small banks: < 15 €/bln Medium banks: 15 - 100 €/bln Large banks: > 100 €/bln

Average

227 €/mln

per bank

3: RegulationEBA RTS QIS Nov. 2013

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M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 15

Summary

1. Introduction

2. Regulation

3. AVA calculation

4. Conclusions

5. References

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M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 16

3: AVA calculationAVAs overview

Core approach

Additional Valuation Adjustments

Market

Price

Uncertainty

(MPU)

Art. 9

Close Out

Costs

(CoCo)

Art. 10

Model Risk

(MoRi)

Art. 11

Unearned

Credit

Spread

(CVA)

Art. 12

Investing &

Funding

Cost

(FVA)

Art. 13

Concen-

trated

Positions

(CoPo)

Art. 14

Future

Admin

Costs

(FAC)

Art. 15

Early

Termination

(EaT)

Art. 16

Main

AVAs

CVA/FVA

AVAs

Other

AVAs

Operational

Risk

(OpR)

Art. 17

The AVA hierarchy

Market risk factors

50% weights for diversification

Market risk factors

Split onto main AVAs

Non-market risk factors

100% weights, no diversification

Page 17: Interest Rates After the Credit Crunch...Case study of AVA MPU calculation for a security. • Top left: market bid and ask prices. FV is computed as average mid price = 162.25. •

M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 17

3: AVA calculationDefinitions and basic assumptions

Definitions summary

Item Definition Comments

Fair value 𝐹𝑉 𝑡 =

𝑖=1

𝑁𝑝

𝐹𝑉𝑖 𝑡 i = index for valuation positions

Prudent Value𝑃𝑉𝑖𝑗𝑘 𝑡 ≤ 𝐹𝑉𝑖 𝑡

∀ 𝑖 = 1, … , 𝑁𝑝, 𝑗 = 1, … , 𝑁𝑢, ∀ 𝑘 = 1,… , 𝑁𝐴𝑉𝐴

o j = index for risk factors

o k = index for AVAs

Additional

Valuation

Adjustment

(simplified)

𝐴𝑉𝐴 𝑡 = 0.1%

𝑖=1

𝑁𝐴𝑠𝑠𝑒𝑡𝑠

𝐹𝑉𝑖 𝑡 +

𝑖=1

𝑁𝐿𝑖𝑎𝑏𝑖𝑙𝑖𝑡𝑖𝑒𝑠

𝐹𝑉𝑖 𝑡𝐴𝑉𝐴 𝑡 is the total valuation

adjustment at time t

Additional

Valuation

Adjustment

(core)

𝐴𝑃𝑉𝐴𝑖𝑗𝑘 𝑡 ∶= 𝑤𝑘 𝐹𝑉𝑖 𝑡 − 𝑃𝑉𝑖𝑗𝑘 𝑡 ,

𝐴𝑉𝐴𝑘 𝑡 : =

𝑖=1

𝑁𝑝

𝑗=1

𝑁𝑢

𝐴𝑃𝑉𝐴𝑖𝑗𝑘 𝑡

o 𝐴𝑃𝑉𝐴𝑖𝑗𝑘 𝑡 is the k-th AVA

associated to source of

valuation uncertainty j and

valuation position i at time t,

o 𝐴𝑉𝐴𝑘 𝑡 is the total k-th AVA at t

Prudent

Valuation

Adjustment

𝑃𝑉𝐴 𝑡 ≔

𝐴𝑉𝐴(𝑡) Simplified

𝑘=1

𝑁𝐴𝑉𝐴

𝐴𝑉𝐴𝑘 𝑡 Core

𝑃𝑉𝐴 𝑡 is the total valuation

adjustment at time t

Page 18: Interest Rates After the Credit Crunch...Case study of AVA MPU calculation for a security. • Top left: market bid and ask prices. FV is computed as average mid price = 162.25. •

M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 18

3: AVA calculationAVA Market Price Uncertainty (MPU)

Case study of AVA MPU calculation for a security.

• Top left: market bid and ask prices. FV is computed as average mid price = 162.25.

• Bottom left: ranking and percentiles of mid prices, AVA MPU for long and short positions, equal to 0.14 and 0.12, respectively.

• Top right: distribution chart.

Page 19: Interest Rates After the Credit Crunch...Case study of AVA MPU calculation for a security. • Top left: market bid and ask prices. FV is computed as average mid price = 162.25. •

M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 19

AVA definitionAVA Model Risk (MoRi) refers to the valuation uncertainty of a valuation exposure arising from uncertainty in models and model calibrations used by market participants. In particular, AVA MoRi does not refers to the uncertainty in market risk capital arising from model risk (see FAQ 23.1).

AVA main referenceso EBA RTS, article 11. o EBA FAQs 10, 23.1, 28.

AVA scope of applicationWithin the general prudent valuation scope (see before), AVA MoRi refers in particular to those valuation positions for which the Institution estimates that there is a lack of firm exit price due to model and/or model calibration choices. Of course, instruments which can be replicated by exact static combination of mark-to-market instruments should not contribute to AVA MoRi.

3: AVA calculationAVA Model Risk (MoRi) [1]

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M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 20

Alternative models and calibrationsAVA MoRi is not based on any possible alternative model or model calibration, but on those specific alternative models or model calibrations that may reasonably used by market participants to price the same or similar valuation exposures.

Examples

o alternative but reasonable models, • calibrated to the same calibration basket

• Referred to the same group of financial instruments

o Same model, alternative calibration approaches, e.g. • different calibration baskets

• different calibration weights (e.g. flat, or vega weighted)

• different objective functions

• different optimization algorithm (e.g. global vs local)

• Etc.

o Same model, same calibration, alternative numerical approaches, e.g. • analitycal approximations

• semi-analitycal approximations

• numerical PDE solution

• Monte Carlo simulation

• etc.

3: AVA calculationAVA Model Risk (MoRi) [2]

Inspiration: «There’s

plenty of room at the

bottom»Richard Feynman, 1959

www.its.caltech.edu/~feynm

an/plenty.html

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M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 21

3: AVA calculationAVA MoRi: historical sources of model risk

Historical sources of model risk

Period Main driver Main risk factor Effects1987 Black Monday Volatility Volatility smile

2004 CMS market VolatilitySwaption volatility smile and CMS convexity adjustment

2004 IAS39 Credit Credit Risk Adjustment (CRA)2007 Credit crunch Credit, liquidity Subprime writedown2007 Credit crunch Interest rate basis Multiple yield curves

2009-2010 Credit crunch Interest rate basis CSA discounting2009-2010 Credit crunch Bilateral credit CVA & DVA (IFRS13, 2013)2013-2015 Credit crunch Funding Funding Valuation Adjustment (FVA)

2013-2014 Credit crunch Interest rateNegative interest rates and inflation, negative Floor strikes, Bond floater coupons floored, end of Black’s model.

2014- Credit crunch Capital charges Capital Valuation Adjustment (KVA)2017 Credit crunch Funding Bilateral initial margins

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M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 22

Market Risk Scenarios vs Model Risk Scenarioso Risk measures are typically linked to scenarioso Scenarios are related to the risk factors relevant for a particular risk typology

3: AVA calculationAVA MoRi: model risk scenarios vs traditional scenarios

Risk class Scenarios Risk measures

Market risk Present market data VaR, Expected shortfall, etc.

Counterparty risk Future market data EPE, Effective EPE, etc.

Operational risk Operational loss event frequency

and severity

VaR 99.9%

Model risk Model scenarios

o Alternative models

o Alternative numerical approaches

o Alternative calibrations

K-th percentile of distribution

of model prices (10°

percentile for Prudent

Valuation)

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M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 23

3: AVA calculationAVA MoRi: model risk scenarios for interest rate derivatives

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M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 24

3: AVA calculationAVA Model Risk (MoRi): case study 1 [1]

Case study 1: model risk in interest rate yield curve construction

Interest rate yield curves are used everywhere for discounting and for interest rate derivatives and securities with floating rate coupons. So, this is an important case study.

Yield curve construction is based on recursive application of pricing formulas applied to interest rate market instruments. So, there is a lot of modelling inside.

In particular, the interpolation algorithm is very important, both pre and post bootstrapping:

o Simple but non-smooth linear interpolation algorithms are very simple and robust, but produces irregular forward curves

o Standard spline interpolation is less simple but produces oscillating yield curves

o Monotonic cubic spline interpolation is regular.

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M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 25

3: AVA calculationAVA Model Risk (MoRi): case study 1 [2]

Linear interpolation on zero interest rates

Monotonic cubic spline interpolation on zero interest rates

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M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 26

3: AVA calculationAVA Model Risk (MoRi): case study 1 [3]

Differences in bps between three different interpolation algorithms (linear, natural cubic spline and monotonic cubic spline) for a portfolio of 3 standard IRS on Euribor 1M, 6M, 12M + 3 standard Basis Swaps.

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M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 27

3: AVA calculationAVA Model Risk (MoRi): case study 2 [1]

Case study 2: model risk experiment with Numerix

Sensitivity of prices to modelso Various dimensions of modelling decisionso Example of Bermudan swaption pricing with HW1F, HW2F, CIR, and BK modelso Impact of calibration choiceso AVA MoRi for a Bermudan swaptiono Model implied European swaption smile

Impact of changing market environment on model performanceo Handling of negative rateso Example of floor pricing with very low strikes by using various models

Joint work with Ilja Faerman and Laure Darleguy, Numerix webinar, 12 Nov. 2014, available at www.numerix.com

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M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 28

3: AVA calculationAVA Model Risk (MoRi): case study 2 [2]

Case study 2: model risk experiment with Numerix (cont’d) Global modelling approach

Trade

FX spotBasis

spreadYield Curve Correlation

Model

underlying

Forward

curveSwap rate

Risk factor

Short-rate

Distribution

typeNormalLog-normal Mixture

Chi-

squared

Model type HW1F HW2F

Calibration

instruments Caplets Swaptions

Instruments

configuration

10Y

diagonal

20Y

diagonal10Y column

10Y diag +

10Y column

CIR BK

CMS

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M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 29

3: AVA calculationAVA Model Risk (MoRi): case study 2 [3]

Case study 2: model risk experiment with Numerix (cont’d)

Experiment

#Instruments Models Calibrations

Bermudan

swaption

• Coterminal bermudan payer

swaption

• Euribor 6M

• 10Y maturity

• Annual callability

• Sstrike ATM 10Y swap

• OIS discounting

• Hull-White 1 Factor

(HW1F)

• Black-Karasinski (BK)

• Cox-Ingersoll-Ross 1

Factor (CIR1F)

• Hull-White 2 Factors

(HW2F)

• Cox-Ingersoll-Ross 2

Factors (CIR2F)

• Set 1: 10 Y diagonal

swaption ATM

• Set 2: 10Y diagonal

and 1Y column

swaption ATM

• Set 3: 20Y diagonal

and 1Y column

swaption ATM

Caps/Floors

with negative

rates

• 5Y Floor

• Euribor 6M

• Negative and positive strikes

• Yield curves with negative

rates

• Linear interpolation and flat

extrapolation

• SABR interpolation and flat

extrapolation

• Black (analytic)

• Hull-White 1 Factor

(HW1F)

• Shifted Black-Karasinski

(SBK)

• Set 1: Cap volatility

columns for strikes

ATM and 1%

• Set 2: full Cap volatility

surface, with strikes

from 1% to 10%

Joint work with Ilja Faerman and Laure Darleguy, Numerix webinar, 12 Nov. 2014, www.numerix.com

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3: AVA calculationAVA Model Risk (MoRi): case study 2 [4]

Overview of results

Prices range from 1.45% to 3.91% Normal models produce consistently higher PVs for all calibration sets compared to

non-normal models

HW1FBK

CIR1FHW2F

CIR2F

0.00%

1.00%

2.00%

3.00%

4.00%

Set1

Set2

Set3

Bermudan swaption prices per model and calibration set

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M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 31

3: AVA calculationAVA Model Risk (MoRi): case study 2 [5]

Results by calibration set

Calibration set 1 (10Y diagonal) produces highest distribution of prices Average price is fairly stable across different calibration sets Same model stays consistently below or above the average price for all calibration

sets

1.00%

1.50%

2.00%

2.50%

3.00%

3.50%

4.00%

4.50%

Set1 Set2 Set3

Bermudan swaption prices per calibration set

HW1F BK CIR1F HW2F CIR2F Average

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3: AVA calculationAVA Model Risk (MoRi): case study 2 [6]

Results by model

HW1F and BK models exhibit lowest variations in prices with changing calibration set Prices of 1F and 2F models of the same model type can differ significantly

1.00%

1.50%

2.00%

2.50%

3.00%

3.50%

4.00%

4.50%

HW1F BK CIR1F HW2F CIR2F

Bermudan swaption prices per model

Set1 Set2 Set3

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M. Bianchetti - Prudent Valuation – Cass Business School– London, 4 Nov. 2015 p. 33

3: AVA calculationAVA Model Risk (MoRi): case study 2 [7]

Results

Notional is 10m EUR Assuming Fair Value is the average of all price

Long swaption:o Fair Value: FV = 258k EURo Prudent value is the 10% percentile of all prices: PV = 177k EURo AVA MoRi = 0.5x(FV-PV) = 40.5k EUR

Short swaption:o Fair Value: FV = -258k EURo Prudent value is the 90% percentile of all prices: PV = -317k EURo AVA MoRi = 0.5x(FV-PV) = 29.5k EUR

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3: AVA calculationAVA Model Risk (MoRi): case study 2 [8]

Excluding models

All models All except HW2F All models All except HW2F

Fair Value (1) 258 258 -258 -258

Prudent Value 177 158 -317 -315

Model Risk AVA 40.5 50 29.5 28.5

Long swaption Short swaption

Fair Value (1) is computed as the average of all model prices

Fair Value (2) for “All except HW2F” is computed excluding the price of the HW2F model

All models All except HW2F All models All except HW2F

Fair Value (2) 258 240 -258 -240

Prudent Value 177 158 -317 -315

Model Risk AVA 40.5 41 29.5 37.5

Short swaptionLong swaption

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3: AVA calculationAVA Model Risk (MoRi): case study 2 [9]

Exercise probabilities

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%

70.00%

80.00%

Oct-15 Oct-16 Oct-17 Oct-18 Oct-19 Oct-20 Oct-21 Oct-22 Oct-23

Call probabilities per couponCalibration set 1

HW1F

BK

CIR

HW2F

CIR2F

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%

70.00%

80.00%

Oct-15 Oct-16 Oct-17 Oct-18 Oct-19 Oct-20 Oct-21 Oct-22 Oct-23

Call probabilities per couponCalibration set 2

HW1F

BK

CIR

HW2F

CIR2F

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%

70.00%

80.00%

Oct-15 Oct-16 Oct-17 Oct-18 Oct-19 Oct-20 Oct-21 Oct-22 Oct-23

Call probabilities per couponCalibration set 3

HW1F

BK

CIR

HW2F

CIR2F

Exercise probability per coupon CIR-type models imply a higher

probability of early exercise than HW models

The term structure of exercise probabilities is regular for all models for calibration set 1, humped for calibration sets 2 and 3.

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3: AVA calculationAVA Investing and Funding Costs [1]

AVA definitionAVA Investing and Funding Costs (FVA) refers to the valuation uncertainty in the funding costs used when assessing the exit price of a valuation position, according to the applicable accounting framework. Such valuation uncertainty refers, in particular, to MPU, CoCo and MoRiuncertainties in the calculation of the funding cost. Hence, AVA FVA shall be split into such components, to be aggregated to their corresponding AVAs.

AVA scope of applicationWithin the general prudent valuation scope (see before), AVA FVA refers in particular to those valuation positions subject to a funding valuation adjustment and specifically, to OTC derivatives. Securities are excluded, since funding risk is already included in the security credit spread

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3: AVA calculationAVA Investing and Funding Costs [2]

FVA losses as of end of 2014.

See “The Black Art of FVA, part III: a $4 billion

mistake?“, Risk, 2 Apr. 2015.

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3: AVA calculationAVA Investing and Funding Costs [3]

Joint work with Alexander Antonov, Ion Mihai, to appear in Risk, November 2015.

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4: Conclusions

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5: ReferencesRegulations [1]

1) BCBS, “International Convergence of Capital Measurement and Capital Standards – A

revised framework”, June 2004.

2) Financial Services Authority, “Dear CEO Letter: Valuation and Product Control”, August

2008, http://www.fsa.gov.uk/pubs/ceo/valuation.pdf

3) Financial Services Authority, “Product Control Findings and Prudent Valuation

Presentation”, November 2010, http://www.fsa.gov.uk/pubs/other/pcfindings.pdf

4) Financial Services Authority, “Regulatory Prudent Valuation Return”, Policy Statement

12/7, April 2012, http://www.fsa.gov.uk/library/policy/policy/2012/12-07.shtml

5) International Accounting Standards Board, «International Financial Reporting Standards

13 – Fair Value Measurment», 1° Jan. 2013, www.ifrs.org

6) Regulation EU N.575/2013 of the European Parliament and of the Council on prudential

requirements for credit institutions and investment firms and amending Regulation EU

N.648/2012, 26 June 2013

7) European Banking Authority, “Discussion Paper relating to Draft Regulatory Technical

Standards on prudent valuation under Article 100 of the draft Capital Requirement

Regulation (CRR)” EBA/DP/2012/03, 13 November 2012, http://www.eba.europa.eu/-

/eba-discussion-paper-on-draft-regulatory-standards-on-prudent-valuation.

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5: ReferencesRegulations [2]

8) European Banking Authority, “Consultation Paper Draft Regulatory Technical Standards

on prudent valuation under Article 105(34) of Regulation (EU) 575/2013 (Capital

Requirements Regulation – CRR)”, EBA/CP/2013/28, 10 July 2013,

http://www.eba.europa.eu/regulation-and-policy/market-risk/draft-regulatory-technical-

standards-on-prudent-valuation.

9) European Banking Authority, “Questions and Answers on prudent valuation”, October

2013, http://www.eba.europa.eu/-/revised-faqs-on-prudent-valuation-q-1.

10)European Banking Authority, “Quantitative Impact Study on prudent valuation”,

November 2013, http://www.eba.europa.eu/-/eba-launches-qis-exercise-on-prudent-

valuation.

11)Bank of Italy, Circolare 285, “Disposizioni di vigilanza per le banche”, 17 December

2013, https://www.bancaditalia.it/compiti/vigilanza/normativa/archivio-

norme/circolari/c285/index.html

12)European Banking Authority, “EBA final draft Regulatory Technical Standards

Regulatory Technical Standards on prudent valuation under Article 105(14) of

Regulation (EU) 575/2013 (Capital Requirements Regulation – CRR)”, 31 March 2014,

https://www.eba.europa.eu/regulation-and-policy/market-risk/draft-regulatory-technical-

standards-on-prudent-valuation

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5: ReferencesRegulations [3]

13)European Banking Authority, “EBA final draft Regulatory Technical Standards

Regulatory Technical Standards on prudent valuation under Article 105(14) of

Regulation (EU) 575/2013 (Capital Requirements Regulation – CRR)”, rev1, 23 January

2015, https://www.eba.europa.eu/regulation-and-policy/market-risk/draft-regulatory-

technical-standards-on-prudent-valuation

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5: ReferencesPapers

1) Richard Roll, “A simple implicit measure of the effective bid-ask spread in an efficient

market”, The Journal of Finance, Vol. XXXIX, n. 4, Sept. 1984.

2) E. Derman, "Model Risk", Goldman Sachs Quantitative Strategies Research Notes, Apr.

1996.

3) R. Rebonato, "Theory and Practice of Model Risk Management”, Quantitative Research

Centre (QUARC) of the Royal Bank of Scotland, 2002.

4) R. Cont, "Model uncertainty and its impact on the pricing of derivative instruments",

Mathematical Finance, Vol. 16, No. 3, July 2006, 519–547.

5) R. Brar, “A Regulatory Perspective on Prudent Valuation and Best Practice in Product

Control”, in “Managing Illiquid Assets”, E. Takagawa editor, Risk Books, 2012.

6) Tanguy Dehapiot, “Prudent Value”, Risk Minds presentation, Dec. 2014.

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5: ReferencesOthers

1) Ernst & Young, “Prudent Valuation”, 24 May 2013.

2) Ernst & Young, “BIS III – Prudent Valuation – AVAs Overview and relations to IFRS13”,

July 2013.

3) Deloitte, “Prudent Valuation”, August 2013, http://www.deloitte.com/assets/Dcom-

Belgium/Local%20Assets/Documents/EN/Insights/FSI/be-fsi-

prudentvaluation_ebaconsultationpaper_aug2013.pdf.

4) Financial Machineries, http://www.financial-machineries.com.

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10 Dec. 2014: Risk Minds Conference, joint talk on prudent valuation with T. Dehapiot.

28 May 2014: London Stock Exchange, Milano, prudent valuation course, M.

Bianchetti, U. Cherubini, E&Y.

16 May 2014: ABI conference, Roma, talk “Funding Valuation and Prudent Valuation

Adjustments (PVA & FVA)”, M. Bianchetti, U. Cherubini

24 Sept. 2014: corso ABI, Milano, talk “Prudent valuation“, M. Bianchetti, P. Virgili.

12 Nov. 2014: webinar Numerix, “Prudent Valuation: Bridging the Gap Between

Pricing & Risk Management”, M. Bianchetti (link).

24 Nov. 2014: London Stock Exchange, Milano, prudent valuation course, M.

Bianchetti, U. Cherubini, E&Y.

10 Dec. 2014: Risk Minds, Amsterdam, talk “Prudent Valuation - Bridging Pricing And

Risk Management”, M. Bianchetti (link).

25 Mar. 2015: WBS 4th CVA conference, London, corso “Prudent valuation“, M.

Bianchetti, U. Cherubini (link)

May 2015: Global Derivatives, Amsterdam, talk “Prudent Valuation - Bridging Pricing

And Risk Management”, M. Bianchetti (link).

5: ReferencesEvents

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Disclaimer and acknowledgments

Disclaimer

The views and the opinions expressed here are those of the author and do not

represent the opinions of his employer. They are not responsible for any use that may

be made of these contents. No part of this presentation is intended to influence

investment decisions or promote any product or service.

Acknowledgments

The authors gratefully acknowledges

o E. Maffi, A. Pignataro, S. Vasconi, F. Bertolini, M. Benvenuti, S. Vella from E&Y for

their contribution to develop the prudent valuation framework.

o I. Faerman from Numerix for his contribution for model risk examples.

o T. Dehapiot for sharing information and experties on the subject.

o Members of the AIFIRM committee on market risk for the stimulating discussions on

prudent valuation methodology and applications.

o Many other colleagues in Front Office and Risk Management of Intesa Sanpaolo for

creating a fertile environment to grow the seeds of prudent valuation.