SMA, CCAR and structured notes

The week on, June 3–9, 2016


SMA brings more losers than winners, study says

CCAR and the Big Four consultancies

STRUCTURED NOTES saved from TLAC limits


COMMENTARY: Headwinds for the SMA

Opposition is gathering to the Basel Committee's proposed Standardised Measurement Approach, which would sweep away current methods of calculating operational risk capital – including the internal model-based Advanced Measurement Approach – in favour of a single simple method combining a business indicator representing the size of the institution with historical internal loss data. Ditching other AMA inputs – external loss data in particular – and completely abandoning internal models has attracted criticism, but this week we've looked at research that implies some of the complexity of AMA models could be unnecessary: dimensional analysis shows that, scale aside, most types of operational risk loss behave almost exactly the same way.

But there are more serious problems with SMA. An ORX study of 54 banks found that implementing the new rules last year would have meant the banks raising an additional €115 billion ($129 billion) in capital, with the impact most severe among the largest banks.

Defenders of SMA can argue this shows how larger banks – especially AMA banks – were exploiting the flexibility of the older methods to bring capital levels down below where they should be, but whether it is justified or not, this sort of capital increase will be a hard blow for many institutions, especially systemically important ones already facing higher capital demands from other sources.



"The LCR is ill-conceived and it's not necessary. Even if you think there is some reason to get the banks to hold more liquidity, the LCR is about as destructive a regulation as you can imagine, especially given the Fed's power in the US to pay interest on reserves." Marvin Goodfriend, professor of economics at Carnegie Mellon University



75% of banks sampled by ORX would have seen a capital increase in 2015 if the Standardised Measurement Approach had been in force, with aggregate Pillar 1 capital rising by €115 billion ($129 billion)



LCH-JSCC basis to boost XVA acceptance in Japan
Prices now "can't be explained without reference to XVAs", says Nomura credit head

Futurisation facing headwinds as cleared swaps evolve
Panellists at FIA conference say cleared OTC market is holding off futures challenge

Three months left: dealers fret over slow start to Simm tests
Banks "still working like mad" in race to implement standard margin model

Basel liquidity ratios ‘destructive' US Senate told
Fed's analysis of NSFR costs "dubious at best", says AEI scholar Paul Kupiec

Esma changes to position limits seen as 'sensible'
Regulator allows higher limits for less-liquid commodity derivatives contracts

Banks fear early rollout of EU margin rules for forex forwards
Industry groups call on European Commission to clarify when forex forwards will be subject to a variation margin requirement

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