ABN AMRO Bank NV
Question 1. The EBA believes that an understanding of where the accounting fair value sits within the notional range of plausible values at an aggregate level is essential context for assessing that the downside of this range, and therefore the AVA, is appropriately reported. Do you agree with this statement? If not please explain your reasoning? [Annex 2, page 1]
Yes, the understanding of accounting value within the range is an indicator for assessing the down side uncertainty.
Question 2: Would the ‘upside uncertainty’ measure defined above and used in column 120 be suitable as a definition of the upside uncertainty? If not please provide reasons and any alternative suggestions for how such an upside measure could be defined. [Annex 2, page 1]
The definition of upside uncertainty appears to be suitable, but further clarification (including an example) would be good.
Question 3: Is the above approach to splitting out fair valued assets and liabilities and fair-value adjustments on the one hand between the different types of AVAs and on the other hand between asset classes and product categories practical to implement? If not please describe the practical obstacles. Please suggest any alternative approaches (particularly if an alternative approach has been found useful for internal reporting purposes). [Annex 2, page 5]
The split is practical. Question 4: Is the above portfolio-based approach to splitting out AVAs and other attributes between ‘Exotic’ and ‘Vanilla’ practical to implement? If not please describe the practical obstacles. Please suggest any alternative approaches (particularly if an alternative approach has been found useful for internal reporting purposes). [Annex 2, page 12]
Exotic should be defined in more detail. Further, there could be an intermediate category, such as flow exotics". This category would for instance include digital IR caps or FX barrier options. Arguably, the model risk residing in flow exotics is lower than in exotics, and institutions might want to reflect this in their treatments of the model risk AVAs."
Question 5: Do you think such mismatches between the portfolio-level AVAs and the institution-level AVAs would be significant? Please give examples. [Annex 2, page 12]
Not currently significant.
Question 6: Where the difference is significant what additional practical difficulties would arise from calculating AVAs for each of the portfolio categories in rows 050-170? [Annex 2, page 13]
Not applicable. Question 7: What are stakeholders’ views on the ability to usefully summarise in a few key words the models and products concerned, as well as on the associated reporting burden or IT issues? [Annex 2, page 15]
60 characters is too limited for a meaningful description. These columns should be removed from the framework.
Question 8: Do you find the proposed instructions on prudent valuation clear? Are there specific parts where definitions or instructions should be clarified?
Instructions are clear.
Question 9: Do respondents have any comments on the structure and content of the proposed templates on prudent valuation?
Edwin van Heusden