Bank One Corporation - Page 240

                                        -80-                                          
               PURPOSE                                                                
               This banking circular provides guidance on risk                        
               management practices to national banks and federal                     
               branches and agencies engaging in financial derivatives                
               activities.  The guidelines in this circular represent                 
               prudent practices that will enable a bank to conduct                   
               financial derivatives activities in a safe and sound                   
               manner.  National banks engaged in financial                           
               derivatives transactions are expected to follow these                  
               guidelines. * * *                                                      
                         *    *    *    *    *    *    *                              
               SCOPE                                                                  
               Financial derivatives transactions currently represent                 
               a relatively small portion of the total credit, market,                
               liquidity, and operational risk to which most banks are                
               routinely exposed.  However, because of their                          
               complexity, many banks involved in financial                           
               derivatives transactions have developed sophisticated                  
               approaches in managing those traditional types of risk.                
               These guidelines reflect such approaches and,                          
               therefore, represent sound procedures for risk                         
               management generally.  Therefore, to the extent                        
               possible, they should be applied to all of a bank’s                    
               risk-taking activities.                                                
          As to the valuation of derivatives, BC-277 stated:                          
               4. Valuation Issues                                                    
               Banks that engage in financial derivatives activities                  
               should ensure that the methods they use to value their                 
               derivatives positions are appropriate and that the                     
               assumptions underlying those methods are reasonable.                   
               Dealers and active position-takers should have systems                 
               that accurately measure the value of their financial                   
               derivative portfolios.  The pricing procedures and                     
               models the bank chooses should be consistently applied                 
               and well-documented.  Models and supporting statistical                
               analyses should be validated prior to use and as market                
               conditions warrant.                                                    
               The best approach is to value derivatives portfolios                   
               based on mid-market levels less adjustments.                           





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Last modified: May 25, 2011