Bank One Corporation - Page 258

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          the basis of supply and demand.  They gauged the market by                  
          looking at various sources (e.g., yields on Treasury securities,            
          broker quotes of swap spreads over relevant Treasury instruments,           
          and Eurodollar futures prices) to determine points on the                   
          interest rate yield curve.  Some of the requisite information               
          underlying these sources was reflected in FNBC’s Devon system.              
          FNBC’s traders often used the information provided by the Devon             
          system as a starting point in pricing.                                      
                         d.  Risk Management Responsibility                           
               Each FNBC trader was responsible for maintaining his or her            
          aggregate positions within various market risk parameters.  The             
          traders risk-managed their portfolios subject to the trading                
          limits set by those market risk parameters.  In risk-managing               
          their portfolios, the traders used daily risk profiles and                  
          Devon-system-generated daily profit and loss statements for                 
          swaps.  These profiles and statements listed midmarket values and           
          did not include administrative costs adjustments or credit                  
          adjustments.  FNBC’s traders were limited on the amount of                  
          interest rate exposure that they could assume on behalf of FNBC             
          by a risk point system.  That risk point system was based upon              
          the profit/loss estimates that FNBC’s Devon system provided given           
          a certain basis point movement in interest rates.                           
               Whenever FNBC and a counterparty reached agreement on the              
          price of a new swap, the trader would begin the process of                  






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Last modified: May 25, 2011