Bank One Corporation - Page 247

                                        -87-                                          
          transactions.  An interval of two standard deviations corresponds           
          to a 95-percent confidence level.                                           
                                   C.  Expected Exposure                              
               Expected exposure is the mean exposure which is used for               
          valuing credit risk.                                                        
                              iii.  OCC’s Position                                    
               BC-277 stated that for risk management purposes every bank             
          should have a system to quantify “current exposure (‘mark-to-               
          market’) as well as potential credit risk due to possible future            
          changes in applicable market rates or prices (‘add-on’).”  BC-277           
          stated further that “This methodology should produce a number               
          representing a reasonable approximation of loan equivalency, that           
          is, the amount of credit exposure inherent in a comparable                  
          extension of credit.”                                                       
                              iv.  Methods Used To Calculate                          
               Complex models were used to measure credit exposure for                
          interest rate swaps.  Initially, some swaps dealers measured                
          potential exposure using a scenario approach.  They would analyze           
          a limited number of future interest rate scenarios and track the            
          value of the swap over time to determine the maximum amount at              
          risk if the counterparty were to default.  Under this approach,             
          the worst case scenario was regarded as the potential exposure.             
          This approach had many deficiencies, and, by the 1990s, most                
          dealers were trying to develop more sophisticated tools.                    






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Last modified: May 25, 2011