-231- significantly off-market to the advantage of the dealer. Duffie stated similarly to Parsons that there should be no credit adjustment at the inception of a swap with a counterparty rated AA, but that a downward credit adjustment would subsequently be warranted if changes in interest rates caused the value of the swap to become positive. We agree with the testimony of Duffie and Parsons. Given that FNBC discounted at an AA rate, the midmarket values being reduced by credit adjustments already were discounted by a factor reflecting the risk of nonpayment by an AA-rated counterparty. The impact of the AA discount rate coupled with the claimed credit adjustments is that FNBC is taking two adjustments for the risk of default by AA-rated counterparties. FNBC did not increase the value of swaps with A and above A-rated counterparties to take into account the impact of FNBC’s credit rating of A-.77 5. Credit Enhancements Whereas many of FNBC’s swaps were supported by credit enhancements such as credit triggers, guarantees, collateral, and credit agreements, FNBC did not take those enhancements into account in computing its credit adjustments. We believe that collateral and other types of credit enhancements must be 77 Duffie testified that it would be unusual to see a difference in prices between counterparties rated AAA and AA.Page: Previous 221 222 223 224 225 226 227 228 229 230 231 232 233 234 235 236 237 238 239 240 Next
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