Response to consultation Paper on draft RTS on the treatment of non-trading book positions subject to foreign-exchange risk or commodity risk
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Accounting values are updated at least monthly. Fair Value calculation of banking book positions de-pends on the type of instrument. For traded instruments like bonds, the fair values are generally updated daily, but at least monthly. For non-traded instrument like loans and deposits, a fair value calculation is following the quarterly IFRS reporting frequency.
The foreign exchange component is updated on a daily basis.
In addition, the Delta 1 approach is in contradiction to the proposed treatment under the internal model approach where the risk of impairment due to FX should be modelled by the bank, see also Question 9.
Inclusion of items at historic cost is directly connected to the EBA Draft Guidelines on the treatment of structural FX under 352 (2) of the CRR. Regulatory approval for exclusion of items at historic costs generate an overly complex, resource and time consuming process.
Additionally, we see a possible overlap between inclusion of subsidiaries at historic costs and systemic risk buffer and O-SII buffer that would lead to double coverage of the same risks.
Finally, we would recommend allowing the full exclusion of items at historic costs or to establish criteria for reduced risk weights depending on probability for FX induced impairment.
Q1. Do you agree with the approach in relation to the use of the accounting value and alternatively the fair value as a basis for computing the own funds requirements for foreign exchange risk, or do you think that institutions should be requested to use e.g. only the accounting value? Please elaborate.
We agree with the proposal (To use either accounting value or fair value) but some of our members prefer to use the accounting value (see also answer to Question 3).Q2. Do you agree that institutions should be requested to update on a daily basis only the foreignexchange risk component of banking book instruments? Please elaborate.
We agree with the proposal.Q3. Could you please describe the current risk-management practices that institutions use for managing the foreign-exchange risk stemming from banking book positions, e.g. whether the accounting or the fair-value is used as a basis for determining the exposure in a currency, the frequency at which banking book positions are fully revalued, the frequency at which the foreignexchange component is updated?
In general, the accounting values are used for determination of the exposures of banking book positions. Although in some special cases fair values for certain type of instruments (e.g. bonds) are taken into account in Pillar 2 framework (even if treated at amortized costs) we think that the accounting value is the best common basis for the Pillar 1 framework of banking book positions.Accounting values are updated at least monthly. Fair Value calculation of banking book positions de-pends on the type of instrument. For traded instruments like bonds, the fair values are generally updated daily, but at least monthly. For non-traded instrument like loans and deposits, a fair value calculation is following the quarterly IFRS reporting frequency.
The foreign exchange component is updated on a daily basis.
Q4. Do you agree with the proposed methodology for capturing the foreign-exchange risk stemming from non-monetary items at historical cost under the standardised approach? Do you have any other proposal for capturing the foreign-exchange risk stemming from non-monetary items at historical cost that would be prudentially sound while fitting within the standardised approach framework? Please elaborate.
ESBG thinks that the inclusion of items at historic costs as a Delta 1 positions is in general overly con-servative. As these positions do not revalue with FX-movements, an efficient hedge for risk weighted assets (RWAs) generated from historic costs item is impossible. Impairments due to FX movements depend on many parameters and the risk of impairment due to FX movements may be remote.In addition, the Delta 1 approach is in contradiction to the proposed treatment under the internal model approach where the risk of impairment due to FX should be modelled by the bank, see also Question 9.
Inclusion of items at historic cost is directly connected to the EBA Draft Guidelines on the treatment of structural FX under 352 (2) of the CRR. Regulatory approval for exclusion of items at historic costs generate an overly complex, resource and time consuming process.
Additionally, we see a possible overlap between inclusion of subsidiaries at historic costs and systemic risk buffer and O-SII buffer that would lead to double coverage of the same risks.
Finally, we would recommend allowing the full exclusion of items at historic costs or to establish criteria for reduced risk weights depending on probability for FX induced impairment.