Elderlake Partners

03 · Exposure value, CRM & counterparty risk

Art 111 · 166 · 192–241 · 271–285 CRR

Purpose & history

Before the weight comes the amount

Risk weights get the attention; the exposure value quietly decides half the answer. For balance-sheet items EAD is carrying value net of provisions; for commitments it is a credit-conversion question — how much of the undrawn line will be drawn by the time trouble arrives (empirically: most of it, which is why the unconditionally-cancellable 0% became 10%); for derivatives it is a distribution question — what could this be worth when the counterparty fails.

The derivatives answer has its own history. The Current Exposure Method (1988) — MtM plus a notional add-on — survived twenty-five years because it was simple, and misfired throughout because the add-ons knew nothing of netting quality, margining or moneyness. SA-CCR (BCBS 2014, EU since 2021) rebuilt it: replacement cost that respects margin terms, PFE add-ons per asset class with supervisory factors, a multiplier rewarding over-collateralisation, and the α = 1.4 scalar carried over from IMM as a conservatism buffer — much criticised, still standing.

CRM philosophy: collateral and guarantees reduce loss only if legally enforceable, valued with haircuts for market and FX risk, and monitored. CRR3's notable turn: own-estimate haircuts abolished — one more model surface closed.

1988
CEM: MtM + crude add-on.
1995–
ISDA netting opinions make close-out netting the industry's real mitigant.
2008
Bilateral uncollateralised books blow through CEM numbers; margining migrates to CCPs (09: clearing mandates).
2014
SA-CCR published; UMR phases begin for bilateral IM.
2021
SA-CCR live in the EU (CRR2); CEM and SM repealed.
2025
CRR3: CCF ladder tightened (UCC 10% phased), own-estimate haircuts gone; SA-CCR feeds the floor for IMM banks.

Requirements

Netting enforceabilityJurisdiction-by-jurisdiction legal opinions, refreshed; netting sets defined by agreement, not by system convenience.
Margin dataTH, MTA, NICA per CSA feeding RC; MPOR classification; disputes tracked (they extend MPOR).
Collateral operationsEligibility screening, daily valuation, haircut application (incl. FX mismatch), concentration and wrong-way monitoring, segregation for IM.
Guarantee filesDirect, explicit, irrevocable, unconditional — evidenced per guarantee; substitution logic in the engine, not the spreadsheet.
CCF classificationEvery off-balance item mapped to the Annex I bucket ladder; UCC status defensible against the "in practice cancellable?" test.
Maturity & currency mismatchHaircut adjustments computed, not waived; residual maturity tracked per protection item.

Calculations

SA-CCR — unmargined vs margined, same trade 7y IRS, N = €100m, V = +€2m
Unmargined: RC = €2.0m · AddOn = €2.95m → EAD = 1.4 × 4.95 = €6.93m
Margined (daily VM, TH €0, MTA €0.5m, MPOR 10d): RC = max(V−C, TH+MTA−NICA, 0) = €0.5m · MF = 1.5×√(10/250) = 0.3 → AddOn = 2.95 × 0.3 = €0.89m
EAD = 1.4 × (0.5 + 0.89) = €1.94m — margining cuts the exposure 72%.
Multiplier — over-collateralisation pays Same netting set, IM held so that C − V = €3m: mult = min(1, 0.05 + 0.95·e^(−(3)/(2×0.95×2.95))) ≈ 0.62 → PFE shrinks accordingly. The exponential rewards real over-collateralisation, floored at 5%.
Financial collateral comprehensive method Loan €10m · collateral: corporate bond €8m, Hc = 8%, no FX mismatch
E* = max(0, 10 − 8×(1−0.08)) = 10 − 7.36 = €2.64m → weight the residual at the obligor's RW. Volatility, not value, is what the haircut prices.
Guarantee substitution €10m to an unrated corporate (100%), guaranteed €6m by a CQS1 bank (20%): RWA = 6×20% + 4×100% = 1.2 + 4.0 = €5.2m vs €10m — substitution, not reduction: you now hold bank risk.

Changes & sources

BeforeNow
CEM / Standardised MethodSA-CCR only (below thresholds: simplified/OEM)
UCC CCF 0%10% (phased)
Own-estimate haircutsAbolished — supervisory haircuts only
  • Sources: Art 271–285 (SA-CCR), 192–241 (CRM), EBA SA-CCR RTS (delta, material risk driver), EMIR/UMR for the margin substrate.
  • Watch: α = 1.4 review pressure — the industry's longest-running calibration complaint.

Independent analysis by Elderlake Partners, as at August 2026. Not legal, accounting or supervisory advice.