Bank One Corporation - Page 35

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          the last day of the quarter in which the swap was considered                
          initiated; e.g., if the swap was actually initiated on a day that           
          fell between March 1 and May 31, the initial credit adjustment              
          was calculated on June 30.38  Second, FNBC assigned the swap                
          counterparty to one of its credit risk rating classes (discussed            
          infra p. 133) and ascertained the corresponding CRESCO39 loss               
          reserve factor from the credit rating that FNBC had assigned to             
          that CRESCO loss reserve factor.40  Third, FNBC multiplied the              
          swap’s CEM amount by the counterparty’s CRESCO loss reserve                 
          factor to arrive at the swap’s initial credit adjustment.41                 
               For the period beginning in the fourth quarter of 1992, FNBC           
          accounted for its credit adjustment as follows.  First, on the              
          quarterly basis, FNBC reduced income by the credit adjustment for           
          the group of swaps originating in the quarter (with the 1-month             




          38 The CEM determined how much of the credit limit was                      
          consumed by each swap.                                                      
          39 The acronym “CRESCO” refers to the Credit Strategy                       
          Committee, a committee consisting of the most senior officers of            
          FNBC, including the chairman, the president, the chief financial            
          officer, the chief credit officer, and the chief economist.                 
          40 FNBC also referred to the CRESCO loss reserve factor as                  
          the loan loss reserve factor.                                               
          41 For example, if the counterparty had a credit rating of                  
          2, the corresponding CRESCO loss reserve factor during most of              
          1993 was .05 percent.  Therefore, if a swap with this                       
          counterparty had a CEM of $1 million, the swap’s initial credit             
          adjustment would be $500 (0.05% x $1 million).                              




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