-227-                                         
                    3.  Credit Ratings of Both Counterparties                         
               Petitioner argues that the fair market value of FNBC’s                 
          interest rate swaps does not take into account FNBC’s own credit            
          rating.  Respondent argues that the fair market value of interest           
          rate swaps takes into account both parties’ creditworthiness.  We           
          agree with respondent.  We believe that a determination of the              
          fair market value of interest rate swaps, in that they are                  
          bilateral contracts which by definition require the performance             
          of both parties thereto, must take into account the                         
          creditworthiness of both of those parties.  FNBC’s credit risk              
          methodology ignores the bilateral nature of swaps and the impact            
          that FNBC’s own credit risk has on a swap’s fair market value               
          flowing from the danger that FNBC may not fulfill its obligations           
          under the swap.                                                             
               We agree with Duffie and Parsons that the credit rating of a           
          dealer such as FNBC affects the value of a swap.  We also agree             
          with Duffie and Parsons that the credit adjustment may be either            
          positive or negative when a counterparty has a better credit                
          rating than the dealer, regardless of that higher rating.  As               
          Parsons stated, a dealer such as FNBC may have to make an upward            
          adjustment if a swap becomes significantly off-market to the                
          dealer’s disadvantage, regardless of who has the higher credit              
          rating.  In that case, the counterparty is exposed to credit risk           
          from the dealer, and the dealer is generally not exposed to any             
Page:  Previous   217   218   219   220   221   222   223   224   225   226   227   228   229   230   231   232   233   234   235   236   NextLast modified: May 25, 2011