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Risk, Treasury & Financial Control
1Risk Foundations
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5Market Risk
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Market Risk: The Exposures a Balance Sheet Carries to Prices

Market risk is what a balance sheet loses when a price moves against it. Vindhya Commercial Bank Limited, invented, carries a Rs 3,600 crore trading book measured at Rs 15.6 crore of value at risk a day, and Rs 84,000 crore of rate sensitive positions whose value falls Rs 840 crore under its own 200 basis point scenario. Two books, two measures, and both figures are the bank's own.

Hold on to the shape of that answer. A great deal of what goes wrong in this subject goes wrong in the gap between its two halves. One measure is small, precise, produced every morning and looked at by six people once a month. The other is large, coarse, produced against a single made-up rate move, and settled once a period by a different committee. The two are measuring one institution against one interest rate, and they disagree by a factor of more than fifty. Neither is a mistake. The two measures are answers to questions that were never the same question.

What is market risk actually asking, and what is it not asking?

Market riskThe loss a position takes when a market price or rate moves against it, whether or not any counterparty fails. asks one question and refuses another. The question it asks is: what is this position worth now that the price has moved? The question it refuses is: will the other side pay? Whether the other side will pay is a real question, it is measured with great care, and it belongs under credit risk. Market risk asks what a position is worth when a price moves, and it asks that even when every counterparty is perfectly good for the money.

The separation is easier to feel in a household than on a balance sheet, so start there. Suppose a lender has advanced Rs 2,00,000/- to a cousin who has never missed a repayment in his life. Repayment is settled, and settled well. Now suppose the loan runs at a fixed rate for five years and rates in the market rise sharply next month. Nothing about the cousin has changed. The holder is now locked into receiving less than the going rate for another four and a half years, so the loan the lender holds is worth less than it was. Not a rupee of repayment has been lost. Value has been lost, and it was lost to a price rather than to a person.

The household case is the whole of it in miniature. A bank is doing the same thing in Rs 96,000 crore rather than Rs 2,00,000/-, and across thousands of positions at once rather than one. The counterparties are fine. The prices moved. Something is worth less. The moment a loss no longer requires somebody to fail, the subject is market risk.

Which market variables actually reach a balance sheet?

Four of them, and only one of the four goes anywhere near a dealing room, so it is worth being precise about which part of the bank each one touches. The first is the interest rate, and it is by a wide margin the largest of the four in this invented bank. The loan book, the deposit book and the investment book are each a promise to pay or receive an amount of money at a date, and the worth of such a promise moves when rates move, so the interest rate reaches all three at once.

The second is the exchange rate. At Vindhya Commercial Bank Limited, invented, it reaches five currency positions numbered FX1 to FX5, and one net investment of Rs 480 crore in a single overseas branch. The third is the price of a traded instrument itself, and this is the one that reaches the Rs 3,600 crore of securities the bank holds in order to trade them. The fourth is the least obvious, and it is the one that produced this bank's only value at risk limit breach of the year: the spread between two things that were expected to move together, and then did not. Three of the four variables reach parts of the balance sheet nobody would describe as trading, and market risk is mostly what happens in those three.

The fourth deserves a sentence of its own. An experienced reader is caught there more often than anywhere else. In month 3 of this invented bank's year, two government bond maturities that the bank's model had been treating as offsetting each other widened apart. Nothing defaulted. No single price collapsed. The two prices simply stopped moving in step, and a position that had been reported as nearly flat turned out not to be. The widening apart is breach B5, and the point to carry away is that a hedge is a claim about a relationship, and relationships are themselves a market variable.

FOUR MARKET VARIABLES, AND WHERE EACH ONE LANDS Vindhya Commercial Bank Limited, invented. Every balance and position named below belongs to that invented bank. VARIABLE ONE The interest rate Reaches the loan book, the deposit book and the investment book at the same moment. Rs 84,000 crore of rate sensitive positions. VARIABLE TWO The exchange rate Reaches five currency positions, FX1 to FX5, and one net investment in an overseas branch. Rs 192 crore aggregated, Rs 480 crore abroad. VARIABLE THREE The price of a security Reaches the securities held in order to trade them, and reaches nothing else on this sheet. Rs 3,600 crore, held for trading. VARIABLE FOUR The spread between two Reaches wherever one position was assumed to offset another, and then stopped doing so. Breach B5, month 3, and it is the only one. Only variable three reaches a dealing room. The other three reach the ordinary business of taking deposits and making loans.
Interest rates, exchange rates, security prices and the spread between two positions expected to offset each other all reach this invented bank, and three of the four land nowhere near the securities it holds in order to trade.
Try it out

A loan book reprices in one year and the deposits funding it reprice in one month. Neither the loans nor the deposits are traded. Is this market risk?

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Why does one bank carry this exposure in two places at once?

Because a bank does two different things with securities and rates, and it does them for different reasons. The bank holds a small book in order to trade it, buying and selling to make a margin on the movement. And it runs a very large book in order to be a bank at all: taking deposits, making loans, and holding investments it intends to keep. Both books move when rates move. Only one of them is anybody's idea of trading.

The trading bookThe positions an institution holds in order to trade them, marked to market and measured daily. At this invented bank it is the held for trading book of Rs 3,600 crore and nothing else. at Vindhya Commercial Bank Limited, invented, is Rs 3,600 crore, being 3.75 per cent of total assets of Rs 96,000 crore. The trading book carries a measured figure every morning, a cap in the form of limit L5 at Rs 18.0 crore, a formal test of the measure against what actually happened, and a monthly seat at committee G7. The banking bookEverything else the institution holds to run its business, including the loan book and the investments it does not intend to trade. carries Rs 84,000 crore of rate sensitive positions. The banking book gets one measure against one internal scenario, and it depends on a behavioural assumption set by a different committee. The present value it predicts is not observable day by day, so the banking book measure cannot be tested against realised outcomes at all. The book that gets a number every morning is one twenty-third the size of the book that does not.

The everyday version is a household with a small share portfolio and a large home loan. The number is there and it moves, so the portfolio is checked on a phone most evenings. The home loan is a far larger exposure to the same interest rate, it is checked roughly never, and when it does move it moves by a multiple of anything the portfolio does. Attention follows the number that is easy to see, and the number that is easy to see is rarely the one carrying the exposure.

ONE RATE MOVE, TWO BOOKS, TWO COMPLETELY DIFFERENT SETS OF MACHINERY Vindhya Commercial Bank Limited, invented. Both caps are the bank's own and neither is a requirement from anywhere. One parallel move in the interest rate HELD IN ORDER TO TRADE IT Rs 3,600 crore 3.75 per cent of total assets A measured figure every morning Cap: limit L5, Rs 18.0 crore Reading: Rs 15.6 crore, 86.7 per cent Committee G7 receives it monthly Formally tested against outcomes Seven exceptions this year, X1 to X7 HELD IN ORDER TO RUN THE BANK Rs 84,000 crore rate sensitive positions One measure, one internal scenario Cap: limit L8, Rs 990 crore Reading: minus Rs 840 crore, 84.8 per cent Committee G4 sets the assumptions No test against outcomes is possible The outcome is not observable daily THE SMALLER BOOK CARRIES THE LARGER APPARATUS Rs 3,600 crore gets a daily number and a test. Rs 84,000 crore gets one scenario and an assumption.
One interest rate move reaches both books of this invented bank at once, and the Rs 3,600 crore held in order to trade carries a daily measure, a cap, a test and a monthly committee while Rs 84,000 crore of rate sensitive positions carry a single scenario and a behavioural assumption.
Try it out

The measured value at risk is Rs 15.6 crore and the measured economic value change is Rs 840 crore. Which book is bigger, and which one gets measured more often?

Long Short Mechanics teaches you to construct a long short book and say what exposure remains after the hedge.

What is in the trading book, and what is deliberately kept out of it?

This is where most readers acquire their first wrong idea, and it is worth being blunt about it. The investment book at Vindhya Commercial Bank Limited, invented, is Rs 26,400 crore. The investment book splits three ways: held for trading Rs 3,600 crore, available for sale Rs 8,400 crore, and held to maturity Rs 14,400 crore, and those three add to Rs 26,400 crore exactly. The trading book for market risk measurement in this invented case is the held for trading book of Rs 3,600 crore and nothing else. The remaining Rs 22,800 crore, being 86.4 per cent of the investment book, sits in the banking book alongside the loans and is measured by the rate measures instead.

Notice what that sentence is and is not. The classification is not a fact about a bond. The same security, bought on the same day at the same price, sits in one book or the other depending on what the bank intends to do with it and how it has classified it. The classification is a decision, recorded, with consequences that run all the way through to which limit the position consumes and which committee argues about it. A reader who assumes that classification follows automatically from the instrument has missed the one place where a bank's own judgement enters the arithmetic before any arithmetic happens.

THE INVESTMENT BOOK AS AN EXTRACT: THREE ROWS, AND ONLY ONE IS THE TRADING BOOK Vindhya Commercial Bank Limited, invented, at month 12. Rs crore. Every balance below belongs to that invented bank. CLASSIFICATION BALANCE WHICH BOOK WHICH MEASURE Held for trading Rs 3,600 the trading book value at risk, daily Available for sale Rs 8,400 the banking book the rate measures Held to maturity Rs 14,400 the banking book the rate measures Investment book, total Rs 26,400 two books two sets of limits Rs 22,800 crore, being 86.4 per cent of the investment book, is outside the trading book entirely. Which row a position lands in is a recorded decision, not a property of the security itself.
Read as an extract with a classification column, this invented bank's Rs 26,400 crore investment book shows the Rs 3,600 crore held for trading row carrying the daily measure while Rs 22,800 crore of it sits in the banking book under an entirely different set of limits.
Try it out

This bank's investment book is Rs 26,400 crore. How much of it is the trading book for market risk measurement?

What does each market risk measure claim, and what can it not see?

There are four kinds of measure in ordinary use, and the fastest way to stop confusing them is to write down what each one claims in a single line. Not how it is built, but what it claims. Each measure has a treatment of its own under its own name, so the table below is a map rather than a lesson in any one of them.

The first is the open positionThe exposure itself, unhedged, to a market variable. It exists whether or not anybody measures it. itself, and it is not a model at all. The open position is a statement of how much exposure is there. The five currency positions of this invented bank aggregate to Rs 192 crore against limit L7. The second is the sensitivity measureA number produced by moving one market variable and reporting what the position is then worth., and it moves one variable to report the new worth of the position. A sensitivity measure is the workhorse, and it says nothing about how likely the move is. The third is the distributional pair, being value at riskA loss figure a book is not expected to exceed on a stated share of days over a stated horizon, and it says nothing about the days it is exceeded. and expected shortfallThe average of the losses beyond a stated cut-off, which is a different question from where the cut-off sits., and both put a rupee figure on a bad day. The fourth is the pair used on the banking book, one asking what a rate move does to twelve months of income and one asking what it does to the value of everything held.

MeasureWhat it claimsWhat it cannot see
The open positionHow much exposure exists, before anybody models anythingWhether the price is likely to move, and by how much
A sensitivity measureThe worth of a position after one variable is moved by a stated amountHow probable that move was, or what two variables do together
Value at riskA loss a stated book is not expected to pass on a stated share of daysAnything at all about the days it is passed
Expected shortfallThe average size of the losses beyond a stated cut-offWhere the cut-off itself should sit, which is a separate choice
The income measureWhat a rate move does to twelve months of net interest incomeAnything past the twelve months, including value already locked in
The value measureWhat a rate move does to the present value of both sides at onceWhen any of it shows up in reported earnings

Read down the third column and the shape of the subject appears: every measure on the list is defined as much by its blind spot as by its claim. A bank therefore runs several measures rather than picking a favourite, and a committee shown one number has been shown one answer to one question.

Where did the habit of one number for traded risk come from?

The habit of one number for traded risk is so settled that it now looks inevitable, and it is not. Before a single figure was workable, each desk described its own exposure in its own units: so many bonds of such a maturity, so much of one currency, so many contracts. Every description was accurate and none of them added up. A senior person asking how much traded risk the institution as a whole was carrying got a stack of papers rather than a number.

The RiskMetrics technical document of 1994 changed that by publishing two things together: a method for turning positions into one loss figure, and a data set to run the method on. The idea of a percentile was old. The difference came from publishing a workable method alongside the data needed to use it. Within a few years the single firm-wide figure was the ordinary way traded risk was reported. Peter Bernstein tells the longer story of how measuring risk became possible at all in Against the Gods, 1996, and it is worth reading for how recent all of this is.

HOW ONE FIGURE FOR TRADED RISK BECAME THE ORDINARY WAY TO REPORT IT A published document of 1994 is the object named here. BEFORE A stack of papers Each desk described its own exposure in its own units. All accurate. None of it added up across the floor. THE DOCUMENT, 1994 A method and data The RiskMetrics technical document set out a way to produce the figure, and the data needed to run it. AFTER One figure A single number could stand for a whole institution, and reporting settled around it within a very few years. The artefact is what did the work, so the artefact is what gets named. The published document of 1994 is what travelled, and the document is what gets named.
Traded risk reporting settled on a single institution-wide figure because one published document of 1994 supplied a workable method together with the data to run it, which is why the document rather than any bank is what gets named.
Try it out

What is named here as the reason value at risk became the ordinary way to report traded risk?

What does this bank's market risk limit set actually look like?

Four limits out of the twelve this invented bank runs, and each of the four is measured on a different kind of object. The difference between the four objects is easy to skate past, and it matters more than the numbers. Limit L5 caps a distributional measure. Limit L6 caps a realised loss accumulated through a month. Limit L7 caps an aggregated position. Limit L8 caps a change in value under a scenario. Four caps, four different objects, and the only thing they have in common is that the board risk management committee G2 set every one of them.

LimitWhat runs against itCapRunningUtilisation
L5Trading book value at risk, one day, on the bank's own methodRs 18.0 croreRs 15.6 crore86.7 per cent
L6Trading book loss accumulated through the month to dateRs 30.0 croreRs 8.4 crore28.0 per cent
L7Net overnight open currency position, five positions aggregatedRs 240 croreRs 192 crore80.0 per cent
L8Change in the value of equity under the bank's own 200 basis point scenarioRs 990 croreRs 840 crore84.8 per cent

Every one of those caps is this invented bank's own decision, recorded in its own policy and set by its own board committee. None of them is a requirement from anywhere. The cap and the utilisation are printed together throughout: a percentage on its own invites a reader to treat the denominator as a standard, and it is not one.

FOUR MARKET RISK LIMITS AT MONTH 12, ON ONE SCALE Vindhya Commercial Bank Limited, invented. Every cap is the bank's own and none is a requirement from anywhere. the cap, 100 per cent 86.7 per cent L5 trading book value at risk running Rs 15.6 crore cap Rs 18.0 crore 28.0 per cent L6 stop loss, month to date running Rs 8.4 crore cap Rs 30.0 crore 80.0 per cent L7 open currency position running Rs 192 crore cap Rs 240 crore 84.8 per cent L8 economic value sensitivity running Rs 840 crore cap Rs 990 crore FOUR CAPS, FOUR DIFFERENT KINDS OF OBJECT A distributional measure, a month to date loss, an aggregated position, and a change in value.
On one scale the four market risk limits of this invented bank read 86.7, 28.0, 80.0 and 84.8 per cent of caps the bank set for itself, and the tightest of the four is the daily trading measure rather than the far larger banking book exposure.
Try it out

Which of this bank's four market risk limits is running closest to its cap at month 12?

Who sees these numbers, and how often do they see them?

Two committees carry the market risk load at this invented bank, and they carry different halves of it. The market risk committee G7 has six members, meets monthly, and receives the value at risk position, the test of that measure against realised outcomes, and the open currency position. The asset liability management committee G4 has nine members, meets monthly, is chaired by the chief executive, and sets the behavioural assumptions on which the banking book measure depends. The board risk management committee G2 sets every one of the twelve limits and decides what happens when one is passed.

BodyWhat reaches it on market riskHow often
Committee G7, market riskThe value at risk position, the test of the measure against realised outcomes, and the open currency positionMonthly
Committee G4, asset and liability managementThe behavioural assumptions the banking book measure depends onMonthly
Committee G2, board risk managementEvery one of the twelve limits, and the decision on any that is passedSix times a year

Notice that the assumption and the limit it decides the answer to are set by two different bodies, so no single paper in this invented bank carries both. Who should see what, and what a governance structure does about a gap like it, is covered under risk governance.

What did the twelve months actually look like at this bank?

Compressed into one paragraph, the year reads like this. On the trading book the measure was passed by a realised loss on seven days, numbered X1 to X7, against roughly two and a half such days expected across two hundred and fifty. The measured figure itself went over the Rs 18.0 crore cap of limit L5 on two days in month 3, breach B5, and positions were reduced. The currency position went over the Rs 240 crore cap of limit L7 for one day in month 9 after a customer deal was booked after the cut-off, breach B2, and it was squared the next morning. Both of those breaches are closed. On the banking book the headline reading finished the year at Rs 840 crore, being 84.8 per cent of the Rs 990 crore cap of limit L8, and it was never passed.

A limit breach and a backtesting exception look similar in a summary and they are not the same thing at all. A limit breach is a measured number going over a cap the bank set. A backtesting exception is a realised loss going over the number the measure produced that morning. One is the control failing, the other is the measure failing, and this invented bank had both in month 3 on different days. Breach B5 was days 21 and 22. Exceptions X2 and X3 were days 14 and 15. A week apart, same month, and merging them would hide two separate faults behind one story.

Try it out

This bank had seven backtesting exceptions and one value at risk limit breach in the same year. Are those the same events counted twice?

What happens to income and to value when the same rate moves?

Here is the part of this subject that surprises careful readers, and it is worth slowing down for. The banking book at this invented bank produces two answers to one rate move, and the two answers have opposite signs. Both are correct. The two answers are not two attempts at the same calculation.

The income answer comes from the repricing gapThe difference between assets and liabilities repricing inside one time bucket, which is what makes income move when rates do.. More of this bank's assets reprice inside a year than its liabilities do, so the one year cumulative gap is plus Rs 15,600 crore. When rates rise, those assets start earning more before the funding starts costing more, and twelve months of net interest income go up. On the bank's own 200 basis pointOne hundredth of one percentage point, and the unit every interest rate move in this case is stated in. scenario, applied to that gap for an average of half a year remaining, income rises by Rs 156 crore.

The value answer comes from duration. The assets have a longer modified durationA locked input in this case, used as a number and never derived here, that turns a rate move into a value change. than the liabilities funding them, 3.00 years against 2.50 years, so the gap is 0.50 years on Rs 84,000 crore. When rates rise, the present value of the assets falls further than the present value of the liabilities, and the difference lands on the economic value of equityWhat a rate move does to the present value of everything on both sides of the balance sheet, expressed as a change in the value of equity.. The same 200 basis point rise takes Rs 840 crore off it, which is 84.8 per cent of the Rs 990 crore cap of limit L8.

The same shock adds Rs 156 crore of income and removes Rs 840 crore of value, and a committee shown only one of the two has been shown half the position. The everyday version is a household that switches from a fixed rate deposit to a floating one just before rates rise. Next year's interest income goes up, and the gain is real. The value of what the household holds, if it had to sell today, went the other way, and that loss is equally real. Two true statements about one decision.

Try it out

A 200 basis point rise adds Rs 156 crore to this invented bank's net interest income over twelve months. What does the same rise do to the value of its equity?

Play with it

One parallel rate rise, two answers of opposite sign

Move the shock and watch both lines at once. The income line rises at 0.78 per basis point and the value line falls at 4.2 per basis point, so the two answers separate from the very first step. The point where the value answer reaches the Rs 990 crore cap of limit L8 is located by stepping the shock one basis point at a time rather than being asserted.

parallel rise: 200 basis points
ONE SHOCK, TWO ANSWERS, OPPOSITE SIGNS income, plus Rs 156 crore value of equity, minus Rs 840 crore 200 basis points +400 0 -400 -800 -1,200 -1,600 Rs CRORE income effect plus 0.78 a basis point limit L8 cap Rs 990 crore value of equity minus 4.2 a basis point 0 100 200 300 400 PARALLEL RATE RISE, BASIS POINTS Stepping one basis point at a time, the Rs 990 crore cap of limit L8 is first passed at 236 basis points.
Income, twelve months
plus Rs 156 crore
Value of equity
minus Rs 840 crore
Limit L8 utilisation
84.8 per cent
Value against income
5.38 times
At a parallel rise of 200 basis points, income over twelve months moves by plus Rs 156 crore and the value of equity by minus Rs 840 crore, being 84.8 per cent of the Rs 990 crore cap of limit L8, on this invented bank's own locked position.
Educational illustration. The 200 basis points is this invented bank's own internal scenario and is not a requirement from anywhere. Both lines are straight because each is a balance multiplied by a rate multiplied by a time, and the ratio between the two answers therefore stays at 5.38 times at every shock size. The downward direction is deliberately not drawn: a 200 basis point fall gives one locked point, minus Rs 336 crore of income, and it rests on a behavioural assumption the bank does not publish, so a single unpublished point is not stretched into a line.
Parallel riseIncome, twelve monthsValue of equityLimit L8 utilisation
50 basis pointsplus Rs 39 croreminus Rs 210 crore21.2 per cent
100 basis pointsplus Rs 78 croreminus Rs 420 crore42.4 per cent
200 basis pointsplus Rs 156 croreminus Rs 840 crore84.8 per cent
about 236 basis pointsplus Rs 184 croreminus Rs 991 crore100.1 per cent
300 basis pointsplus Rs 234 croreminus Rs 1,260 crore127.3 per cent
400 basis pointsplus Rs 312 croreminus Rs 1,680 crore169.7 per cent

Two notes on that table. The Rs 990 crore cap is reached exactly at 235.7 basis points, and because the control moves in whole basis points, 236 is the first step past it, and the row therefore reads Rs 991 crore rather than Rs 990 crore. And the ratio between the two answers never changes: 4.2 divided by 0.78 is 5.38, at fifty basis points, at two hundred and at four hundred. Both are straight lines through the same origin, so the value answer is 5.38 times the income answer everywhere on this table.

ONE 200 BASIS POINT RISE, DRAWN TO SCALE, BOTH ANSWERS AT ONCE Vindhya Commercial Bank Limited, invented. The 200 basis points is the bank's own internal scenario, not a requirement. plus Rs 156 crore THE VALUE OF EQUITY 0 TWELVE MONTHS OF INCOME minus Rs 840 crore limit L8 cap, Rs 990 crore The value answer is 5.38 times the income answer, at every shock size. 4.2 a basis point against 0.78 a basis point, and both lines run straight through the origin.
Drawn to one scale, the income gain of Rs 156 crore and the value loss of Rs 840 crore from a single 200 basis point rise at this invented bank sit on opposite sides of zero, and the loss reaches most of the way to the Rs 990 crore cap the bank set itself.
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Where do these standards come from, and what actually binds an Indian bank?

Think about how a building gets put up in an Indian city. There is a model code, written carefully by people who study structures for a living, and there is the municipal rule that decides whether a plan is sanctioned. The model code is where the thinking came from. The municipal rule is what stops the concrete. Somebody who quotes the model code at the sanctioning desk has named the right ideas and answered the wrong question, and will be sent away to read the rule that actually applies.

Market risk works exactly that way, and this is the one habit worth building at the start of a sequence of eighteen. Naming where a standard came from and naming what actually binds are two separate acts, and performing only the first is the confident and common error. The Bank for International Settlements, at bis.org, publishes the Basel market risk framework, the interest rate risk in the banking book standard, the standardised interest rate shocks, the outlier test, the shorthand method for aggregating an open currency position, and the traffic light approach for counting realised losses against a measure. The Basel documents are the origin, the place where the reasoning was worked out and where to look to understand why any of it is shaped the way it is.

The Reserve Bank of India, at rbi.org.in, sets what an Indian bank must actually do. Which book a position is allowed to sit in. Which measurement approach may be used. Which figures must be computed, and how often. Which of them must be reported, and to whom. How much capital must be held against the result. And from what date each of those applies. Vindhya Commercial Bank Limited is an Indian bank, invented, so the second list is the one that governs it and the first is the one that explains it. A reader who can only recite the first has learned the subject and not the job.

Every figure used here belongs to one invented bank and was recorded in that bank's own policy by its own committees. The 200 basis point move used throughout is this invented bank's own internal scenario and is not a requirement from anywhere. So is the Rs 18.0 crore cap of limit L5, so is the Rs 990 crore cap of limit L8, and so is the choice to measure value at risk over one day at 99 per cent. The binding numbers move, so they are read at the two sites named above.

TWO SEPARATE ACTS, AND ONLY ONE OF THEM BINDS Name the origin, then name what binds. Performing only the first is the confident and common error. THE ORIGIN: BANK FOR INTERNATIONAL SETTLEMENTS bis.org the Basel market risk framework the interest rate risk in the banking book standard the standardised interest rate shocks the outlier test the shorthand method for currency positions the traffic light for counting exceptions WHAT BINDS: RESERVE BANK OF INDIA rbi.org.in which book a position is allowed to sit in which measurement approach may be used what must be computed, and how often what must be reported, and to whom what must be held against the result from what date each of those applies No shock size, outlier threshold, zone boundary, multiplier or effective date is stated as fact here. The 200 basis point move used here is this invented bank's own internal scenario.
The origin of a market risk standard and the rule that actually binds an Indian bank are two different lists held by two different bodies, and a reader who can recite only the left panel has learned the subject without learning the job.
Jurisdiction

Where to confirm the binding numbers

The Bank for International Settlements at bis.org is the origin of the Basel market risk framework, the interest rate risk in the banking book standard, the standardised interest rate shocks, the outlier test, the shorthand method for aggregating a currency position and the traffic light for counting exceptions. The Reserve Bank of India at rbi.org.in sets what an Indian bank must compute, report and hold against, which book a position sits in, and from what date. The Indian Banks Association at iba.org.in carries banking operational convention in India. Every shock size, outlier threshold, zone boundary, multiplier, behavioural cap and effective date must be confirmed at source before it is used for anything.

Try it out

Which body sets what an Indian bank must actually compute and report for interest rate risk in its banking book?

Who actually reads these numbers, and what does each reader want from them?

One pack leaves the risk function every month at this invented bank. The pack carries a small number of figures, and four quite different people open it looking for four quite different things. A measure only means something once it is clear who is going to act on it.

Start with the person closest to the position. Devendra Achar, an invented head of treasury at this bank, reads the pack the way a driver reads the fuel gauge before a long drive: not to admire the number but to work out what he can still do. The trading book measure sits at Rs 15.6 crore against the Rs 18.0 crore cap of limit L5, so there is Rs 2.4 crore of measured headroom before a cap the bank set itself is reached. The aggregated currency position sits at Rs 192 crore against limit L7's Rs 240 crore, leaving Rs 48 crore. A limit reader is not asking how large the risk is, but how much more of it a decision this morning is allowed to add. Headroom is a different reading of the same numbers, and it is the reading that governs behaviour.

Second, somebody lending money to this bank, or placing a large wholesale deposit with it. A wholesale lender does not care about the headroom at all. Such a lender wants to know how much of the result comes from one desk and one currency, and whether the figure on the paper is measured on the part of the balance sheet that could actually hurt them. Reading Rs 15.6 crore and stopping there tells them about Rs 3,600 crore of a Rs 96,000 crore institution. A lender who takes the trading measure as the market risk of the bank has been shown 3.75 per cent of the balance sheet and told it was the whole of it. The figure they actually need is the one on the other Rs 84,000 crore, and that figure is minus Rs 840 crore of value under this bank's own 200 basis point rise, being 84.8 per cent of the Rs 990 crore cap of limit L8.

Third, a board member. The job from that seat is not arithmetic, it is noticing what is missing. The same 200 basis point rise produces two answers here, plus Rs 156 crore of income over twelve months and minus Rs 840 crore of value, and they point in opposite directions. A board member who is handed only one of them has been shown half the position, and the half they were shown was chosen by somebody. The right question from a board seat is not what is this number, it is what is the other number and who decided I would not see it.

Fourth, and this is the reader nobody puts on the distribution list, the depositor. A schoolteacher with Rs 4 lakh in a term deposit at this invented bank reads none of these figures, receives none of these packs, and is exposed to every one of them through the institution holding her money. Nirjhar Industries Limited, invented, the bank's largest single-name borrower at counterparty C1, is a rupee borrower, so market risk reaches this bank through the rate on that loan and the rate on the deposits funding it rather than through anything that name does. The exposure does not require anybody to be watching it. The control apparatus exists precisely for that reason, and a limit nobody reads is not a control.

ONE PACK, FOUR READERS, FOUR DIFFERENT QUESTIONS THE MONTHLY MARKET RISK PACK TRADING BOOK, ONE DAY, 99 PER CENT Rs 15.6 crore AGGREGATE CURRENCY POSITION Rs 192 crore VALUE OF EQUITY, 200 BASIS POINTS minus Rs 840 crore NET INTEREST INCOME, SAME RISE plus Rs 156 crore The treasurer of this bank how much more may I add before a cap is reached? A lender to this bank how much of the balance sheet is that figure measured on? A board member what is the other answer, and who decided I would not see it? A depositor asks nothing, reads nothing, and is exposed to all four. One pack, four readers, and no two of them are reaching for the same figure.
The same four figures leave the risk function once a month and are read four different ways, and the reader most exposed to all of them is the one who never sees the pack at all.
Try it out

An outside analyst is handed exactly one figure from this bank's pack and told it is the market risk number. Which single figure would leave them most misled about the size of the exposure?

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What is the commonest way this subject goes wrong on a first reading?

Believing that market risk lives in the dealing room

Almost everybody arrives at this subject with a picture already installed: screens, a desk, somebody watching a price. The picture is vivid, and it is where the word market sends the mind. The trouble is that following the money at this invented bank shows the picture wrong by an order of magnitude, and wrong in a way that makes a reader feel informed at exactly the moment they have stopped being informed.

Follow it. The held for trading book is Rs 3,600 crore. The book gets a measured figure every morning. It has a cap of its own, limit L5 at Rs 18.0 crore. A formal count of realised losses runs against that measure. The book goes to committee G7 once a month, and this year its escalation policy fired twice, once at five exceptions and again at seven. Every one of those is a real control and none of them is wasted. And the entire book those controls sit on is 3.75 per cent of a Rs 96,000 crore balance sheet.

Now look at the other side. Rs 84,000 crore of rate sensitive positions on both sides of the sheet get one measure against one scenario the bank made up itself. The banking book measure cannot be counted against realised outcomes at all. The present value of everything the bank holds and owes is not observed day by day the way a traded price is. The measure depends on a behavioural assumption about Rs 36,000 crore of current and savings balances, and that assumption is set by a different committee from the one that sets the cap it runs against. The traded measure says Rs 15.6 crore. The banking book measure says minus Rs 840 crore. The second is 53.8 times the first, on the same institution, on the same evening, against the same interest rate.

A second failure sits underneath the first. Because it survives the correction, the second one is worse. Suppose a reader takes the point, drops the dealing room picture and settles on minus Rs 840 crore as the real market risk of this bank. The same 200 basis point rise adds Rs 156 crore to net interest income over twelve months, so that reader is still only half right. Both answers are correct. Neither is a rounding of the other. The two answers have opposite signs. One asks what the book earns while rates are what they are, and the other asks what the book will be worth once rates have changed.

The whole mistake costs attention, the scarcest thing in any risk function. Attention flows to the number that arrives most often, is easiest to compute, and has the cleanest test attached to it. In this bank the attention does not go where the exposure is, and correcting that is what the rest of market risk measurement is for.

THE ATTENTION AND THE EXPOSURE POINT OPPOSITE WAYS Both bars are drawn on one scale, the Rs 96,000 crore balance sheet of this invented bank. SIZE OF THE EXPOSURE Held for trading book Rs 3,600 crore, 3.75 per cent of total assets Rate sensitive positions, both sides Rs 84,000 crore, 87.5 per cent of total assets CONTROLS ATTACHED TO IT Held for trading a figure daily a cap, L5 a backtest a committee, G7 Rate sensitive no daily figure a cap, L8 no backtest a committee, G4 The 3.75 per cent book carries four of those controls. The 87.5 per cent book carries two. Filled means present at this invented bank, dashed means absent, and every cap named is the bank's own.
Drawn on one scale, the book that carries four separate controls is 3.75 per cent of this invented bank and the book that carries two is 87.5 per cent of it, which is where the controls and the exposure part company.
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What has been established, and what comes next?

The subject began as a word and ends as a map. Market risk is the loss a position takes when a price moves against it. Market risk asks that question even when every counterparty is perfectly good for the money, and one sentence is all that separates it from the credit question. Four market variables reach a balance sheet: interest rates, exchange rates, the price of a traded instrument, and the spread between two things that were expected to move together. Only one of those four stops at a dealing room, and even that one does not stay there.

The classification decision matters more than it looks. The investment book of this invented bank, Rs 26,400 crore, splits into held for trading Rs 3,600 crore, available for sale Rs 8,400 crore and held to maturity Rs 14,400 crore, and only the first row is the trading book for measurement. The other Rs 22,800 crore sits in the banking book alongside the loans, and the interest rate block therefore reaches much further than the daily measure does. Which book a position sits in is a decision made about the position and not a fact about the asset, and that decision is what determines which measure ever sees it.

The four caps this bank set itself have also appeared. Limit L5 caps a distributional measure at Rs 18.0 crore and runs at 86.7 per cent. Limit L6 caps a month to date stop loss at Rs 30.0 crore and runs at 28.0 per cent. Limit L7 caps an aggregated currency position at Rs 240 crore and runs at 80.0 per cent. Limit L8 caps a change in value at Rs 990 crore and runs at 84.8 per cent, that utilisation being the Rs 840 crore value effect measured against that cap. Four caps, four different objects measured, and every one of the four is the invented bank's own number rather than anybody's requirement.

And there is the year. Seven exceptions X1 to X7 against about 2.5 expected in 250 days, and that count triggered this bank's own escalation at five and its own model review at seven. One closed limit breach on the traded measure, B5, in month 3. One closed currency limit breach, B2, in month 9. A headline banking book number sitting at 84.8 per cent of its cap and never breached all year. Nothing on that list is a scandal, and all of it together is a picture of an institution whose largest market exposure is the one with the fewest controls on it.

Market risk as covered here runs from what it is, through the four market variables and which part of a balance sheet each one reaches, the split between a trading book and a banking book as a classification decision, the four kinds of measure at a glance, the four limits L5 to L8 with what runs against each, the two reporting routes into committees G7 and G4, and where the standards come from against what binds in India. Each measure named here is taught on its own: the open position as an object, sensitivity measures, value at risk and its three methods, expected shortfall, the count of realised losses against a measure, economic value of equity, earnings at risk and the hedging policy all have a treatment of their own. Liquidity risk is a different exposure and a different sequence, and the one place the two touch is that the same Rs 36,000 crore of current and savings balances is slotted differently in the two ladders, a difference worked under liquidity risk. Model validation and the model inventory belong to the risk reporting, data and model risk sequence, and the governance of the unvalidated behavioural model is handed there. Wrong way risk belongs to the credit sequence and has been published there as counterparty C7. Asset liability management as a function belongs to the treasury sequence, and stress and scenario analysis as methods belong to the risk foundations sequence. A swap, a forward, an option, a bond and a government security are named here and taught under fixed income and derivatives.

Sources

SourceDocumentSite
Reserve Bank of IndiaWhat actually binds a bank in India on market risk: which book a position sits in, which measurement approach may be used, what must be computed and reported, and what must be held against the resultrbi.org.in
Bank for International SettlementsThe Basel market risk framework, the interest rate risk in the banking book standard, the standardised interest rate shocks, the outlier test, the shorthand method for a currency position and the traffic light for counting exceptionsbis.org
Indian Banks AssociationBanking operational convention in Indiaiba.org.in
RiskMetrics technical document, 1994The method that turned a set of positions into one loss figure, published together with the data set needed to run itPublished document

Vindhya Commercial Bank Limited, Nirjhar Industries Limited and Devendra Achar are invented.
Educational material. Not advice on any investment, tax, budget or market position.

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