Bank One Corporation - Page 235

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                    3.  Risk Management                                               
               Swaps dealers needed to value financial derivatives to                 
          measure the performance of their financial derivatives trading              
          operations and to measure and to ascertain how to hedge the                 
          market risks in their portfolios.  Traders were responsible for             
          maintaining the portfolios they managed within various risk                 
          limits.  The traders needed to know their exposure to long-term             
          and short-term interest rate movement positions in order to                 
          assure that they did not take on unacceptable levels of risk.               
               Swaps dealers such as FNBC used midmarket values for daily             
          risk management purposes.  The purpose of these valuations was to           
          measure the day-to-day change in the value of the portfolio and             
          to quantify the impact that particular interest rate movements              
          would have on the value of the portfolio.  These calculations               
          were used to monitor risk positions (i.e., how much unhedged                
          market risk a trader could assume) and to identify where hedging            
          was needed.  Swaps dealers such as FNBC did not rely upon their             
          credit adjustments to risk-manage their swaps and did not use               
          their administrative costs adjustments for risk management.                 
                    4.  Management Reporting                                          
               Each month, swaps dealers such as FNBC prepared a management           
          report for the financial derivatives profit center that included            
          interest rate swaps.  The monthly management reports contained a            
          profit-and-loss statement and a balance sheet.  On its balance              






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