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Counterparty Exposure: Measuring What Is Actually at Risk

A counterparty exposure calculator takes one counterparty and turns four facilities into one number. The calculator asks for the funded balance, the undrawn committed line with a drawdown assumption, the current exposure of any contracts and the add-on that goes with them, then reports both bases: the reported total a limit is usually measured on, and the exposure at default a loss computation needs. On C1 those are Rs 2,496 crore and Rs 2,160 crore.

A counterparty is never one facility. The habit of thinking in single facilities is the whole reason the measurement needs a method, and people find that hardest to believe until they have watched a single name produce two correct answers on the same afternoon. Money lent, money promised and not yet taken, contracts worth something today and contracts that could be worth more tomorrow all sit under one name, and every one of them is a different kind of claim. Adding them takes a decision at each step. A tool that hides those decisions inside one printed figure is not saving anybody time; it is producing a number nobody can take apart when it matters.

What does this working tool compute?

Start with the shape of the thing rather than the arithmetic. Four items go in and four items come out, and the four inputs are not equally solid. Exactly one of them is a fact that can be read off a system, and the other three are judgements the bank made, wrote down and now applies every month without reopening. The reason this tool shows its inputs rather than only its answer is that three quarters of the answer is assumption.

The mechanism is identical at every scale. Here is the household version before the bank version. Suppose a lender has lent a cousin Rs 40,000/- and it is fully drawn. The same lender has told a neighbour who runs a tiffin service that Rs 20,000/- is there whenever she needs it, and she has not touched it. And there is an arrangement with a scrap dealer under which he owes for one delivery and is owed for another. How much is at risk with those three people cannot be answered without first deciding three things: how much of the tiffin line she is likely to take, whether the two scrap deliveries can be set against each other, and how much bigger the scrap position could get before it settles. The drawdown share, the set-off and the future movement are exactly the three decisions the tool asks a bank to make.

THE FORM: FOUR THINGS IN, FOUR THINGS OUT, ONE COUNTERPARTY Counterparty C1 at the invented Vindhya Commercial Bank Limited, Rs crore, and every figure the bank's own. FOUR INPUTS FOUR OUTPUTS INPUT 1 the funded balance Rs 1,680 crore drawn and outstanding A FACT, READ OFF THE LOAN ACCOUNT INPUT 2 the undrawn committed line Rs 720 crore promised and not taken A CHOICE: HOW MUCH OF IT GETS DRAWN INPUT 3 the value of the contracts plus Rs 132 crore and minus Rs 36 crore A CHOICE: DO THEY NET, AND CAN THEY INPUT 4 the size of the contracts a notional of Rs 1,600 crore A CHOICE: WHAT ADD-ON FACTOR APPLIES OUTPUT 1 the reported total Rs 2,496 crore, the published basis 94.5 PER CENT OF LIMIT L1 OUTPUT 2 the exposure at default Rs 2,160 crore, the loss basis 81.8 PER CENT OF LIMIT L1 OUTPUT 3 loss given default 40.0 per cent falls to 22.67 per cent COLLATERAL ACTS HERE, NOT ON EXPOSURE OUTPUT 4 expected loss Rs 2.20 crore, down from Rs 3.89 crore THE FALL IS 43.3 PER CENT Limit L1 of Rs 2,640 crore is the invented bank's own single name cap and is not a regulatory figure of any kind.
The tool takes four inputs and returns four outputs, and only the funded balance is a fact rather than a decision this bank made and wrote down.
Try it out

C1 shows a reported total of Rs 2,496 crore and an exposure at default of Rs 2,160 crore. Before going any further: which of the two is the published limit utilisation of 94.5 per cent measured on?

What has to be entered before a counterparty exposure figure means anything?

Input one, the funded balance, which is the only input that is a fact

Rs 1,680 crore is drawn and outstanding to Nirjhar Industries Limited, the invented steel and alloys maker that is counterparty C1 and the largest single name in this bank's book. Nobody has to estimate that. The drawn balance sits on a loan account, and it will be the same figure whoever pulls it, on whatever day, into whatever report. Two people working independently are certain to agree on the funded balance, and on no other input in this tool. Everything downstream of it involves a view. A reader handed only a final exposure figure should always ask what share of it came from a system and what share came from a policy.

Try it out

Which of the tool's four inputs is a fact rather than a choice?

Input two, the undrawn line and the assumption applied to it

C1 has a committed line of Rs 720 crore that it has not drawn. A committed line is a promise the bank cannot walk away from because the customer is having a bad year, and a customer having a bad year is precisely when a line gets drawn. So the tool cannot treat the undrawn line as nothing, and it cannot sensibly treat it as certain either. The tool applies a drawdown assumptionThe share of an undrawn line assumed to be taken before a default, here this bank's own 50.0 per cent., and at this bank that assumption is 50.0 per cent, set internally rather than imposed from outside. Half of Rs 720 crore is Rs 360 crore.

The drawdown assumption carries a full Rs 720 crore of range behind it. No other input in this tool comes close, so no other input matters as much. Set at zero, it says a distressed borrower draws nothing. Set at a hundred, it says every promise gets called. A bank only sees the drawdown behaviour of the borrowers who actually defaulted, and that is a small and unrepresentative set. The truth is somewhere in between, and no system observes it. The simulation further down shows exactly how far the answer moves across that range, and the size of the movement is the argument for showing the assumption on the face of the report rather than burying it.

Input three, what the contracts are worth today

C1 has two contracts with the bank. One is worth plus Rs 132 crore to the bank and one is worth minus Rs 36 crore. The tool needs a single netted current exposureThe positive and negative values of contracts under one enforceable agreement collapsed into a single figure., and whether it is allowed to produce one is a legal question rather than an arithmetic one. Without an enforceable agreement covering both contracts, the losing one gives the bank no credit at all in a default: the bank still owes its Rs 36 crore and simply joins the queue for its Rs 132 crore. With such an agreement, the two collapse. Rs 132 crore less Rs 36 crore is Rs 96 crore.

The two contracts on C1 are covered by one netting agreement, so the tool reports Rs 96 crore, a fall of Rs 36 crore against the gross figure and a reduction of 27.3 per cent. A signed document produces the difference between Rs 132 crore and Rs 96 crore, and nothing else does. So the tool asks whether the agreement exists before it asks what the contracts are worth. Note also what Rs 96 crore is not: it is the netted current exposure and it is not the exposure at default, and those two figures appear separately in the counterparty table for exactly that reason.

WHAT THE TOOL REPORTS AS CURRENT EXPOSURE, AND WHY A DOCUMENT DECIDES IT Counterparty C1 at the invented Vindhya Commercial Bank Limited, Rs crore. Bars drawn to one scale. THE TWO CONTRACTS UNDER ONE NAME contract one in the bank's favour Rs 132 crore contract two against the bank minus Rs 36 crore WHAT THE TOOL THEN REPORTS no enforceable agreement the losing one counts nothing Rs 132 crore one netting agreement the two collapse into one Rs 96 crore Rs 36 crore 27.3 per cent The reduction is produced by an enforceable agreement, not by an arithmetic step, and the tool asks for the agreement first. Rs 96 crore is the netted current exposure of C1. It is not the exposure at default, which adds the potential future exposure.
Without an enforceable agreement the tool reports Rs 132 crore and with one it reports Rs 96 crore, a fall of 27.3 per cent produced by a document rather than by arithmetic.
Try it out

A counterparty has two contracts, one worth plus Rs 40 crore and one worth minus Rs 15 crore, and no netting agreement covers them. What current exposure does the tool report?

Input four, how big the contracts are

The fourth input has nothing to do with what the contracts are worth today. The fourth input asks how big they are. A contract worth almost nothing this morning can be worth a great deal by the time a default is actually worked through. C1's contracts carry a notional of Rs 1,600 crore, and the bank applies its own add-on factor of 1.5 per cent to that notional to get Rs 24 crore. The Rs 24 crore is the allowance for movement between today and the day the position is closed out.

The add-on is taken on notional and never on value. People building this calculation for themselves get that convention wrong more often than any other. Take a percentage of a contract's current value instead, and a contract sitting exactly at zero today would carry no allowance for future movement at all. A contract at zero can move as far as any other, so an allowance of nothing is plainly wrong. Size is what drives movement, so size is what the add-on is taken on.

Derivatives Foundation Bootcamp — Fin Maverick Hedging a Real Exposure — free micro-course from Fin Maverick

How is the funded, undrawn and derivative exposure of one name brought into a single figure?

With the four inputs together, an attempt to add them runs into trouble immediately. The four cannot be added, at least not once. There are two defensible ways to combine them and they answer two different questions, so the tool produces both rather than choosing between them. The first is the reported totalFunded exposure plus the undrawn line in full plus current exposure, which is the basis a single name limit is usually measured on here., built from the funded balance, the whole undrawn line and the current exposure of the contracts. The second is the exposure at defaultFunded exposure plus the drawn share of the line plus current exposure plus the add-on, which is the basis a loss computation needs., built from the funded balance, the drawn share of the line, the current exposure and the add-on on top.

Try it out

The drawdown assumption on C1's Rs 720 crore line moves from zero all the way to one hundred per cent. Before the figures: by how much does the exposure at default move?

Counterparty C1 worked end to end

Every figure below belongs to Vindhya Commercial Bank Limited, an invented lender, and to Nirjhar Industries Limited, and every factor in it is this bank's own. Read the two right-hand columns as two different questions being asked of one set of facilities on one day.

Input, and what the tool was givenReported total basisExposure at default basis
Funded balance, Rs 1,680 crore drawn1,6801,680
Undrawn committed line, Rs 720 crore promised720360
Netted current exposure, plus 132 less 369696
Add-on, 1.5 per cent of a Rs 1,600 crore notional024
The figure the tool reports, Rs crore2,4962,160
Measured against limit L1 of Rs 2,640 crore94.5 per cent81.8 per cent

A tool nobody checks is a tool nobody trusts. Check the two totals yourself. On the first basis, 1,680 plus 720 plus 96 is 2,496. On the second, 1,680 plus 360 plus 96 plus 24 is 2,160. One counterparty, one day, one set of facilities, and two figures Rs 336 crore apart, both of them correct. The two bases differ on exactly two rows, and they differ in opposite directions. The net gap is therefore smaller than either move that produced it.

ONE SET OF FACILITIES, TWO TREATMENTS, TWO ANSWERS The two bases agree on two rows and differ on two, and they differ in opposite directions. THE FACILITY WHAT THE REPORTED TOTAL DOES WHAT THE EXPOSURE AT DEFAULT DOES Funded balance Rs 1,680 crore drawn taken in full Rs 1,680 crore taken in full Rs 1,680 crore Undrawn committed line Rs 720 crore promised taken in full, no assumption applied Rs 720 crore taken at the 50.0 per cent assumption Rs 360 crore Netted current exposure plus 132 less 36 taken in full Rs 96 crore taken in full Rs 96 crore Potential future exposure add-on on Rs 1,600 crore left out of this basis entirely Rs 0 added at 1.5 per cent of notional Rs 24 crore THE TOTAL Rs 2,496 crore Rs 2,160 crore Every factor here is the invented bank's own and none of them is taken from any published standard.
The same four facilities are treated differently by the two bases, which is why one counterparty on one day produces Rs 2,496 crore and Rs 2,160 crore at once.
Credit Exposure and How It Is Reduced teaches you to measure counterparty exposure and to know what netting and collateral actually do to it.

Which basis is the figure on, and why does one counterparty produce two different utilisations?

A figure on its own is not yet a measurement. A figure becomes one when it is laid against something, and here that something is limit L1A cap on exposure to one counterparty. Here it is 40.0 per cent of tier 1 capital, this bank's own figure rather than a regulatory cap., the bank's own single name cap, set at 40.0 per cent of tier 1 capitalThe capital measure this bank sets its single name and group caps as a percentage of, being Rs 6,600 crore here. of Rs 6,600 crore. Forty per cent of Rs 6,600 crore is Rs 2,640 crore. Divide each of the two figures by that cap, and one counterparty on one day yields two utilisationWhat is running against a cap, expressed as a percentage of it, which means nothing until the basis is named. readings. 2,496 over 2,640 is 94.5 per cent, and 2,160 over 2,640 is 81.8 per cent.

Twelve point seven percentage points separate two correct answers about the same counterparty, and the only thing that decides which one appears is a convention nobody wrote at the top of the report. The bank publishes the reported total, so 94.5 per cent is the figure that binds internally and the figure Manjari Sondhi, who runs wholesale banking and carries C1 as a risk owner, is held to. A loss computation cannot use it. The reported total counts a whole undrawn line that will not be wholly drawn, and it leaves out an add-on that will actually be there. Each basis is right for its own job and wrong for the other one.

ONE COUNTERPARTY, ONE LIMIT, TWO UTILISATIONS Both bars are drawn against the same track, which runs from zero to limit L1 of Rs 2,640 crore. LIMIT L1, Rs 2,640 CRORE THE REPORTED TOTAL Rs 2,496 crore 94.5 per cent THE EXPOSURE AT DEFAULT Rs 2,160 crore 81.8 per cent Rs 336 crore apart 12.7 percentage points This bank publishes the reported total basis, so 94.5 per cent is the figure that binds inside it. Limit L1 is the invented bank's own cap at 40.0 per cent of tier 1 capital of Rs 6,600 crore, and is not a regulatory figure.
One counterparty measured against one limit runs at 94.5 per cent on one basis and 81.8 per cent on the other, and neither figure is wrong.

The Rs 336 crore between the two is not a mystery and it should never be presented as one. The gap is two moves in opposite directions. The exposure at default takes half the undrawn line rather than all of it, and half of Rs 720 crore removes Rs 360 crore. Then it adds the potential future exposure the reported total leaves out entirely. The derivative measure rises from Rs 96 crore to Rs 120 crore, putting Rs 24 crore back. Rs 360 crore off and Rs 24 crore on is Rs 336 crore net, and 2,496 less 336 is 2,160. A gap that decomposes exactly into two named moves is an explanation; a gap presented as a single net figure is an invitation to guess.

FROM Rs 2,496 CRORE TO Rs 2,160 CRORE IN TWO NAMED MOVES The two bases differ on exactly two rows and the two rows pull in opposite directions. Counterparty C1 at the invented Vindhya Commercial Bank Limited. 2,100 2,200 2,300 2,400 2,500 Rs 2,496 crore minus Rs 360 crore plus Rs 24 crore Rs 2,160 crore THE REPORTED TOTAL the whole line counted HALF THE LINE, NOT ALL 720 taken at 50.0 per cent THE ADD-ON, PUT BACK 1.5 per cent of 1,600 EXPOSURE AT DEFAULT the loss computation basis The vertical scale is in Rs crore and starts at Rs 2,100 crore rather than at zero, so the two moves are readable against each other.
The Rs 336 crore between the two bases decomposes exactly into Rs 360 crore removed and Rs 24 crore added back, so the gap is explainable rather than mysterious.
Try it out

The gap between the two bases on C1 is Rs 336 crore. What is the gap made of?

What does the tool do with collateral, and what does it deliberately not do?

C1 has given a charge over inventory and receivables valued at Rs 1,440 crore. The bank cuts that valuation by its own haircut of 35.0 per cent, leaving eligible collateralCollateral value after the haircut, being what the lender is willing to count on. of Rs 936 crore. Against the exposure at default of Rs 2,160 crore that covers 43.3 per cent. The instinct almost everybody has here is wrong. Now watch where the Rs 936 crore actually goes.

The collateral does not come off the exposure. Neither reported total nor exposure at default moves by a single rupee. The collateral cuts the severity instead. Loss given default falls from this bank's assumed 40.0 per cent to 40.0 times one less 0.4333, or 22.67 per cent. The expected loss on C1 falls from Rs 2,160 crore times 0.45 per cent times 40.0 per cent, being Rs 3.89 crore, to Rs 2,160 crore times 0.45 per cent times 22.67 per cent, being Rs 2.20 crore. The fall is 43.3 per cent, exactly the share of exposure the collateral covers.

Collateral belongs in severity because a limit is measured on exposure, and collateral does not reduce what the counterparty owes. If the tool deducted it, C1 would report an exposure of Rs 1,224 crore against a cap that was set on gross terms, and a name at 46.4 per cent of its limit invites no question at all. Deducting collateral is the arithmetic by which an institution talks itself under a cap it is actually running close to. The rule to hold is simple: the exposure line answers how much is at stake, and the collateral line answers how much of it comes back.

WHERE THE Rs 936 CRORE OF COLLATERAL ACTUALLY GOES Counterparty C1. Every valuation, haircut and severity assumption here is the invented bank's own. ELIGIBLE COLLATERAL, Rs 936 CRORE Rs 1,440 crore of inventory and receivables, less this bank's own haircut of 35.0 per cent. WHAT COLLATERAL DOES NOT TOUCH The reported total Rs 2,496 crore, before and after The exposure at default Rs 2,160 crore, before and after NEITHER FIGURE MOVES BY ONE RUPEE WHAT COLLATERAL DOES CHANGE Loss given default 40.0 per cent 22.67 per cent Expected loss on the year Rs 3.89 crore Rs 2.20 crore BOTH FALL BY 43.3 PER CENT, THE COVERAGE The 43.3 per cent is Rs 936 crore over the exposure at default of Rs 2,160 crore, and the fall in expected loss is the same 43.3 per cent. A tool that deducted collateral from exposure would report C1 at Rs 1,224 crore against a cap that was set on gross terms.
The Rs 936 crore of eligible collateral appears in neither exposure figure and shows up entirely as severity, cutting loss given default and expected loss by the same 43.3 per cent.
Try it out

Why does the Rs 936 crore of eligible collateral not appear in either exposure figure?

What the tool will not do, and why each refusal matters

A calculator that always produces a figure is more comfortable to use and much worse to rely on. The tool refuses three things, and each refusal marks a place where a real exposure report quietly invents something. With no notional entered, it computes no add-on. With no enforceable agreement recorded, it does not net two contracts. And an empty security field is never read as an absence of security. Every one of those three shortcuts produces a figure that looks right, reconciles to nothing and cannot be traced back to anybody's decision.

THE THREE THINGS THE TOOL REFUSES TO DO Each refusal marks a place where an exposure report can produce a figure nobody can trace back. R1 it will not compute an add-on with no notional An add-on is a percentage of contract size. With no size entered there is nothing to take the percentage of, so the tool prints nothing and says why. A BLANK FIELD IS NOT A ZERO R2 it will not net without an enforceable agreement Netting is a legal fact and not an arithmetic step. With no agreement the losing contract is worth nothing in a default, so the gross figure stands. Rs 132 CRORE, NOT Rs 96 CRORE R3 it will not read a blank as an absence of security An empty security field means nobody has entered one yet. Reading it as no security held reports a severity the bank may not actually be carrying. UNKNOWN IS NOT THE SAME AS NONE A tool that always returns a figure is easier to use and far harder to rely on, and the three refusals above are the price of tracing. All three are conventions of the invented Vindhya Commercial Bank Limited and none of them is a requirement of any kind.
The tool refuses three shortcuts on purpose, and each refusal marks a place where a real exposure report quietly invents a figure nobody can trace.
Try it out

A user enters four contracts with values but leaves the notional field empty on all of them. What should the tool report for potential future exposure?

How does the answer move when the drawdown assumption moves?

Everything above is arithmetic on figures somebody chose. Here is the one that matters most. Hold every other input still and move only the drawdown assumption from zero to a hundred per cent, and the exposure at default runs from Rs 1,800 crore to Rs 2,520 crore. The whole undrawn line of Rs 720 crore is the range, and that is six times the entire derivative position of Rs 120 crore. The single input nobody observes moves the answer further than every input anybody measures put together.

The assumption enters the arithmetic once and multiplies one fixed quantity. The shape is therefore a straight line. Five points on it are worth memorising: at zero the exposure at default is Rs 1,800 crore, being 68.2 per cent of limit L1. At 25 per cent it is Rs 1,980 crore, being 75.0 per cent. At 50 per cent, this bank's own assumption, it is Rs 2,160 crore, being 81.8 per cent. At 75 per cent it is Rs 2,340 crore, being 88.6 per cent. At 100 per cent it is Rs 2,520 crore, being 95.5 per cent.

Two crossings are worth naming before the control is touched. The exposure at default equals the reported total of Rs 2,496 crore at a drawdown assumption of 96.7 per cent, very nearly the whole line. Past that point the exposure at default becomes the larger of the two figures. The limit itself is never reached. Rs 2,640 crore would need a drawdown assumption of 116.7 per cent, and that is more of the line than exists. On the exposure at default basis this counterparty cannot breach its single name cap at any assumption a bank could set, and saying that plainly is better than leaving a reader hunting for a crossing that is not there.

THE SHAPE: A STRAIGHT LINE, ONE CROSSING, AND ONE THAT NEVER HAPPENS Exposure at default in Rs crore against the drawdown assumption, counterparty C1, everything else held still. 1,800 2,000 2,200 2,400 2,600 limit L1, Rs 2,640 crore reported total, Rs 2,496 crore the two bases meet at a drawdown assumption of 96.7 per cent this bank's own assumption, 50.0 per cent, gives an exposure at default of Rs 2,160 crore MORE OF THE LINE THAN EXISTS 0 25 50 75 100 120 THE DRAWDOWN ASSUMPTION, PER CENT OF THE Rs 720 CRORE UNDRAWN LINE Reaching limit L1 on this basis needs a drawdown assumption of 116.7 per cent, marked with a cross, which is more of the line than exists. The vertical scale is in Rs crore and starts at Rs 1,700 crore. Every figure belongs to the invented Vindhya Commercial Bank Limited.
The exposure at default rises in a straight line with the drawdown assumption, meets the reported total at 96.7 per cent and never reaches the limit at all.
Play with it

Move the one input nobody observes and watch three answers move with it

One control: the drawdown assumption applied to C1's Rs 720 crore undrawn committed line, from zero to a hundred per cent. Three consequences redraw together: the exposure at default against limit L1, the expected loss with and without collateral, and the collateral coverage. The reported total of Rs 2,496 crore and the limit of Rs 2,640 crore stay where they are. The control opens at 50.0 per cent, this bank's own assumption, and reproduces the worked example exactly.

0 PER CENT DRAWN50 PER CENT DRAWN100 PER CENT DRAWN
THE EXPOSURE AT DEFAULT AGAINST LIMIT L1, AND WHAT MOVES WITH IT LIMIT L1, Rs 2,640 CRORE REPORTED TOTAL, Rs 2,496 CRORE, FIXED EXPOSURE AT DEFAULT against the limit track 81.8 per cent EXPECTED LOSS, ON A TRACK OF Rs 0 TO Rs 5.00 CRORE without collateral Rs 3.89 crore with collateral Rs 2.20 crore COLLATERAL COVERAGE OF THE EXPOSURE AT DEFAULT, 0 TO 60 PER CENT 43.3 per cent 0 20 40 60 per cent Coverage is Rs 936 crore of eligible collateral over the exposure at default, so it falls as the assumed drawdown rises. Every factor here belongs to the invented Vindhya Commercial Bank Limited and none of them is a requirement.
Exposure at default
Rs 2,160 crore
Utilisation of limit L1
81.8 per cent
Collateral coverage
43.3 per cent
Loss given default
22.67 per cent
Expected loss
Rs 2.20 crore

At a drawdown assumption of 50 per cent, the exposure at default is Rs 2,160 crore, being 81.8 per cent of limit L1, against a reported total of Rs 2,496 crore at 94.5 per cent.

Educational illustration. Invented figures throughout. Vindhya Commercial Bank Limited and Nirjhar Industries Limited are both invented, and so are the 50.0 per cent drawdown assumption, the 1.5 per cent add-on factor, the Rs 1,600 crore notional, the 35.0 per cent haircut, the 40.0 per cent loss given default, the 0.45 per cent grade 4 probability of default and the Rs 2,640 crore limit L1. None of them is a requirement of any body. The netting agreement is assumed enforceable. Enforceability is a legal question this tool names and does not settle. Solved points: 0 per cent gives Rs 1,800 crore at 68.2 per cent of limit L1, 25 per cent gives Rs 1,980 crore at 75.0 per cent, 50 per cent gives Rs 2,160 crore at 81.8 per cent, 75 per cent gives Rs 2,340 crore at 88.6 per cent and 100 per cent gives Rs 2,520 crore at 95.5 per cent. The exposure at default equals the reported total of Rs 2,496 crore at 96.7 per cent, and reaching limit L1 of Rs 2,640 crore would need 116.7 per cent, more of the line than exists.
Try it out

At what drawdown assumption would C1's exposure at default reach the Rs 2,640 crore single name limit?

Private Equity Analyst Bootcamp — Fin Maverick

What can this tool not tell an analyst about a counterparty?

The tool cannot say which of its two answers belongs in a paper, and that is where the damage actually happens. Both figures reproduce perfectly from the same inputs. Nothing about either is arithmetically wrong. So a limits pack quoting 94.5 per cent and a counterparty review quoting 81.8 per cent both survive every check anybody runs on them, and a committee holding one of each has two numbers about one name with no line anywhere telling it why they differ.

The failure that survives review, because there is nothing wrong with the arithmetic

A paper that says C1 is running at 94.5 per cent of its single name limit is correct. A paper that says 81.8 per cent is also correct. A reviewer checking the sums finds nothing to object to. The failure is not an arithmetic one, and that is exactly why it survives review.

The report is missing one line, the line naming the basis the utilisation is measured on. The cost of that missing line is not academic. A name at 94.5 per cent of a cap needs watching this month, and Sunanda Ravikumar as chief risk officer would ask what is being done about it. The same name at 81.8 per cent looks like a name with room, and nobody asks anything. The difference between those two meetings is a convention that fitted on one line and was not written.

Vindhya Commercial Bank Limited publishes the reported total, so 94.5 per cent is the figure that binds here. The tool still prints both, with the basis named beside each, and refuses to pick for the reader. The refusal is the point. A calculator that silently chooses a convention has made a governance decision on somebody else's behalf and left no trace of having made it.

TWO PAPERS, ONE COUNTERPARTY, AND NOTHING WRONG WITH EITHER SUM Both figures reproduce exactly from the same four inputs on the same day. PAPER A: THE MONTHLY LIMITS PACK 94.5 per cent of the single name limit for counterparty C1 checks out: Rs 2,496 crore over Rs 2,640 crore NO BASIS NAMED ANYWHERE IN THE PAPER PAPER B: THE COUNTERPARTY REVIEW 81.8 per cent of the single name limit for counterparty C1 checks out: Rs 2,160 crore over Rs 2,640 crore NO BASIS NAMED ANYWHERE IN THE PAPER BOTH ARE CORRECT. THE ONE MISSING LINE IS THE BASIS. Measured on the reported total, 94.5 per cent. Measured on the exposure at default, 81.8 per cent. Twelve point seven points apart. Both papers are invented, as are the counterparty, the limit and every figure on them.
Two papers carrying two correct utilisations of one counterparty pass every arithmetic check, because the missing thing is a line naming the basis rather than a number.

There are other things this tool cannot do. The tool measures size rather than quality, and whether C1 is a good counterparty is a question about quality. A haircut is an estimate, and inventory sold under pressure is a different asset from inventory sitting in a shed. Whether the Rs 936 crore of collateral would actually realise that much in a distressed sale is beyond the arithmetic. And it says nothing at all about the other nine names in the book: it takes one counterparty at a time, and what happens when several names move together is a separate question with a separate treatment.

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Who actually picks up a two basis exposure figure, and what do they do with it?

Four people read this output, and they read it for four different things. Printing both bases therefore costs nothing and saves a great deal.

The relationship person who covers Nirjhar Industries Limited reads the reported total. Only the reported total tells her whether she can write more business. At Rs 2,496 crore against a Rs 2,640 crore cap she has Rs 144 crore of headroom on paper, and a single new facility of any size would take her past it. The cap is measured on the reported total. The reported total is therefore the figure that governs behaviour. The exposure at default of Rs 2,160 crore is genuinely irrelevant to that question, and quoting it to her would be worse than useless.

A loss computation needs a figure that reflects what will actually be owed rather than what could theoretically be owed. The credit risk analyst preparing the loss provision therefore reads the exposure at default. Rs 2,160 crore multiplied by the grade 4 probability of default of 0.45 per cent and by a severity of 22.67 per cent gives Rs 2.20 crore of expected loss on this name for the year. The reported total fed into the same computation overstates that number by Rs 336 crore of exposure. Overstating it is not conservative but simply wrong.

The independent director on the board risk management committee reads neither figure on its own; she reads the gap. A committee that is shown 94.5 per cent one month and 81.8 per cent the next, without being told the basis changed, has been given a false sense of movement in a position that did not move. A convention that stays put is what makes two months comparable. A governance reader needs the stated convention from an exposure tool, not the tightest number. Whether that convention is right is a separate argument and one worth having; whether it is stated is not negotiable.

And a credit analyst at another institution, looking at Vindhya Commercial Bank Limited itself as a counterparty rather than as a lender, reads it for something different again. The single largest name is 94.5 per cent of a self-set cap on the bank's own published basis. The 94.5 per cent says a great deal about how much room this bank has left before its own arrangements start binding, and nothing at all about whether the name is sound. The household version is the same shape: knowing that Rs 60,000/- rides on one cousin is a different question from knowing whether the cousin will pay, and the honest answer is that both are needed and they come from different places.

Where do the measurement conventions actually come from?

The measurement itself is jurisdiction free: four facilities, two bases, one cap. But the conventions the tool applies did not appear from nowhere, and a reader who needs the binding version should know where to go and read it. The methods are international and what actually binds an Indian bank is not, and mixing the two up is the most common error in this whole subject.

India

What is named here, and where the binding version lives

Every figure, factor, assumption and cap above is Vindhya Commercial Bank Limited's own, set internally rather than taken from a published standard. Limit L1 of Rs 2,640 crore is the bank's own single name cap, set at 40.0 per cent of its own tier 1 capital, and a regulatory large exposure cap is a different thing set by a different body.

The idea of measuring a counterparty exposure as a current exposure plus an add-on on notional, and the standard that governs how a large exposure to a single counterparty is defined and capped, come from the Basel Committee on Banking Supervision, published by the Bank for International Settlements at bis.org. The Basel framework is the origin of the method and the place to read it.

The Reserve Bank of India at rbi.org.in sets what an Indian bank must actually compute, report and observe on exposure to a single counterparty and to a connected borrower group, and that is what binds. Conversion factors, add-on factors, haircuts, large exposure limits and effective dates all come from that source, and a figure needed for real work is read there. Banking operational convention on how such exposures are recorded and exchanged in India is a separate matter and sits with the Indian Banks Association at iba.org.in.

Try it out

Which body decides what an Indian bank must actually report as its exposure to a single counterparty?

How collateral works as a technique and why the fall in expected loss equals the coverage are covered separately, and so is netting. How a probability of default is estimated is covered separately, and the grade 4 figure of 0.45 per cent is used here as given. The definitions of current exposure, potential future exposure and exposure at default are covered separately and are used here without being re-derived. Concentration across names, groups and sectors is a separate subject, and this tool measures one name against one cap and stops. The Rs 3,168 crore of exposure to the Nirjhar group appears only when C1 and Nirjhar Alloys Private Limited are connected, and it belongs to concentration. Wrong way risk is covered separately, and it sits on counterparty C7 rather than C1. Who sets limit L1, who accepts a breach of it and how an escalation runs belong to risk governance and are named here only. A swap, a forward or an option belongs to the instruments themselves, and this tool asks only what a contract is worth and how big it is.
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Sources

SourceDocumentSite
Reserve Bank of IndiaWhat actually binds a bank in India on exposure to a single counterparty and to a connected borrower group, on credit risk mitigation and on capitalrbi.org.in
Bank for International SettlementsThe Basel Committee standards behind the current exposure method, the treatment of netting and collateral, and the large exposure standardbis.org
Indian Banks AssociationBanking operational convention on how counterparty exposures are recorded and exchanged between lenders in Indiaiba.org.in

Vindhya Commercial Bank Limited, Nirjhar Industries Limited, Nirjhar Alloys Private Limited, counterparties C1 to C10, Manjari Sondhi and Sunanda Ravikumar are invented.
Educational material. Not advice on any investment, tax, budget or market position.

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