Question ID:
2020_5419
Legal Act:
Directive 2013/36/EU (CRD)
Topic:
Supervisory review and evaluation (SREP) and Pillar 2
Article:
84
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
EBA/GL/2015/08 - Guidelines on the management of interest rate risk arising from non-trading activities
Article/Paragraph:
115(m)
Disclose name of institution / entity:
Yes
Name of institution / submitter:
Deutsche Bundesbank
Country of incorporation / residence:
Germany
Type of submitter:
Competent authority
Subject Matter:
Weighting of EVE gains of domestic currency by a factor of 50% when calculating the aggregate EVE change for each interest rate shock scenario
Question:

When calculating the aggregate EVE change for each interest rate shock scenario, should EVE gains of the domestic currency (i.e. EUR in most cases) be weighted by a factor of 50% or should such gains be weighted by a factor of 100%?

Background on the question:

Institutions have to aggregate the EVE change for each interest rate shock scenario and translate it into domestic currency.

When doing so “institutions should add together any negative and positive changes to EVE occurring in each currency. Positive changes should be weighted by a factor of 50%” (paragraph 115(m) of the EBA/GL/2018/02 (Guidelines on the management of interest rate risk arising from non-trading book activities).

The treatment of domestic currency positions is not specified and the text is open to two interpretations:

1. Positive changes of currencies other than EUR should be weighted by a factor of 50%;

2. All positive changes should always be weighted by a factor of 50%.

A third possible interpretation would be that all positive changes should only be weighted by a factor of 50%, when EVE changes from other currencies are considered, i.e. if material currency positions other than the domestic currency exist. However, we conclude this cannot be the aim of the paragraph due to the different treatment of EVE gains resulting from the existence of currency positions with material IRRBB. That is, a bank without material foreign currency positions would profit more from a positive interest rate shock than a bank with those material foreign currency positions.

We have exemplified in the table below the effects of the two interpretations: Depending on the share of foreign currency positions and the respective exposures, the reported value of the standardised outlier test and even the relevant scenario may differ. To see this, change the share of USD in cell C3. It shows that there may be circumstances under which the interpretation of 115(m) may become relevant. Currently, the interpretation of this para seems to differ across (N)CAs.

 

Interpretation

Share of USD

50%

1

2

bank is exposed to an increase of EUR rates

EUR ΔEVE in EUR

Parallel up

-200

-200

 

Parallel down

100

100

 

 

bank is exposed to a decrease of USD rates

USD ΔEVE in EUR

Parallel up

100

100

 

Parallel down

-200

-200

 

 

 

Aggregated ΔEVE

Parallel up

-75

-75

 

 

Parallel down

-50

-75

 

Interpretations:
1. Positive changes of currencies other than EUR should be weighted by a factor of 50%.
2. All positive changes should always be weighted by a factor of 50%.

* Parity of EUR and USD is assumed

Date of submission:
07/08/2020
Published as Final Q&A:
11/02/2022
Final Answer:

Following paragraph 115 (m) of the EBA/GL/2018/02 (Guidelines on the management of interest rate risk arising from non-trading book activities), when calculating the aggregate Economic Value of Equity (EVE) change for each interest rate shock scenario, institutions should add together any negative and positive changes to EVE occurring in each material currency. Positive changes should be weighted by a factor of 50%.

The GL do not set any exception here and a 50% factor should apply to all positive changes irrespective of whether or not it is referring to items denominated in the reporting currency or if all positions are denominated in only one currency. Before proceeding to computing the aggregate EVE change for each interest rate shock scenario, changes in the EVE for each interest rate shock scenario for material currencies other than the reporting currency should be converted to the reporting currency at the prevailing spot FX rate on the reference date.

Status:
Final Q&A
Answer prepared by:
Answer prepared by the EBA.
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