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.
Requirements
Calculations
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%.
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.
Changes & sources
| Before | Now |
|---|---|
| CEM / Standardised Method | SA-CCR only (below thresholds: simplified/OEM) |
| UCC CCF 0% | 10% (phased) |
| Own-estimate haircuts | Abolished — 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.