Creadit risk management

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    Chapter 1: Introduction

    Introduction

    Credit risk arises from the possibility of default by

    counterparty. Credit risk lay at the heart of the sub prime

    crisis. The most important point to note about credit risk is

    that it is more difficult to model and measure compared to

    market risk. Unlike market risk, where a lot of data is

    available in the public domain, data is scanty and sometimes

    non existent in case of credit risk. Moreover, credit risk is

    far more contextual, i.e., firm specific compared to market

    risk. Despite these challenges, there has been significant

    progress in credit risk modeling in recent years. In this

    chapter, we will examine the three building blocks of credit

    risk management probability of default, exposure at default

    and recovery rate. We will also discuss briefly some of the

    commonly used credit risk modeling techniques. These

    techniques can help us to estimate the potential loss in a

    portfolio of credit exposures over a given time horizon at a

    specified confidence level. The aim of this chapter is to

    provide a high level understanding of credit risk

    management.

    Credit risk is an investor's risk of loss arising from a

    borrower who does not make payments as promised. Such an

    event is called a default. Another term for credit risk is

    default risk.

    Investor losses include lost principal and interest, decreased

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    cash flow, and increased collection costs, which arise in a

    number of circumstances:

    A consumer does not make a payment due on a mortgage

    loan, credit card, line of credit, or other loan

    A business does not make a payment due on a mortgage ,

    credit card, line of credit, or other loan

    A business or consumer does not pay a trade invoice when

    due

    A business does not pay an employee's earned wages when

    due

    A business or government bond issuer does not make a

    payment on a coupon or principal payment when due

    An insolvent insurance company does not pay a policy

    obligation

    An insolvent bank won't return funds to a depositor

    A government grants bankruptcy protection to an insolvent

    consumer or business

    Credit risk is an investor's risk of loss arising from a

    borrower who does not make payments as promised. Such an

    event is called a default. Another term for credit risk is

    default risk.

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    Chapter 2 : Credit Risk Management in Banks

    2.1 Principles for the Management of Credit Risk

    1. While financial institutions have faced difficulties over

    the years for a multitude of reasons, the major cause of

    serious banking problems continues to be directly related to

    lax credit standards for borrowers and counterparties,

    poor portfolio risk management, or a lack of attention to

    changes in economic or other circumstances that can lead to

    a deterioration in the credit standing of a bank's

    counterparties. This experience is common in both G-10 and

    non-G-10 countries.

    2. Credit risk is most simply defined as the potential that a

    bank borrower or counterparty will fail to meet its

    obligations in accordance with agreed terms. The goal of

    credit risk management is to maximise a bank's risk-adjustedrate of return by maintaining credit risk exposure within

    acceptable parameters. Banks need to manage the credit risk

    inherent in the entire portfolio as well as the risk in

    individual credits or transactions. Banks should al so consider

    the relationships between credit risk and other risks. The

    effective management of credit risk is a critical component

    of a comprehensive approach to risk management and

    essential to the long-term success of any banking

    organisation.

    3. For most banks, loans are the largest and most obvious

    source of credit risk; however, other sources of credit risk

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    exist throughout the activities of a bank, including in the

    banking book and in the trading book, and both on and off

    the balance sheet. Banks are increasingly facing credit risk

    (or counterparty risk) in various financial instruments other

    than loans, including acceptances, interbank transactions,

    trade financing, foreign exchange transactions, financial

    futures, swaps, bonds, equities, options, and in the extension

    of commitments and guarantees, and the settlement of

    transactions.

    4. Since exposure to credit risk continues to be the leading

    source of problems in banks world-wide, banks and their

    supervisors should be able to draw useful lessons from past

    experiences. Banks should now have a keen awareness of the

    need to identify, measure, monitor and control credit risk as

    well as to determine that they hold adequate capital against

    these risks and that they are adequately compensated for

    risks incurred. The Basel Committee is issuing this

    document in order to encourage banking supervisors

    globally to promote sound practices for managing credit risk.

    Although the principles contained in this paper are most

    clearly applicable to the business of lending, they should be

    applied to all activities where credit risk is present.

    5. The sound practices set out in this document specifically

    address the following areas: (i) establishing an appropriate

    credit risk environment; (ii) operating under a sound credit-

    granting process; (iii) maintaining an appropriate credit

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    administration, measurement and monitoring process; and

    (iv) ensuring adequate controls over credit risk. Although

    specific credit risk management practices may differ among

    banks depending upon the nature and complexity of their

    credit activities, a comprehensive credit risk management

    program will address these four areas. These practices

    should also be applied in conjunction with sound practices

    related to the assessment of asset quality, the adequacy of

    provisions and reserves, and the disclosure of credit risk, all

    of which have been addressed in other recent Basel

    Committee documents.

    6. While the exact approach chosen by individual

    supervisors will depend on a host of factors, including their

    on-site and off-site supervisory techniques and the degree to

    which external auditors are also used in the supervisory

    function, all members of the Basel Committee agree that the

    principles set out in this paper should be used in evaluating a

    bank's credit risk management system. Supervisory

    expectations for the credit risk management approach used

    by individual banks should be commensurate with the scope

    and sophistication of the bank's activities. For smaller or less

    sophisticated banks, supervisors need to determine that the

    credit risk management approach used is sufficient for their

    activities and that they have instilled sufficient risk -return

    discipline in their credit risk management processes.

    7. The Committee stipulates in Sections II through VI of the

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    paper, principles for banking supervisory authorities to apply

    in assessing bank's credit risk management systems. In

    addition, the appendix provides an overview of credit

    problems commonly seen by supervisors.

    8. A further particular instance of credit risk relates to the

    process of settling financial transactions. If one side of a

    transaction is settled but the other fails, a loss may be

    incurred that is equal to the principal amount of the

    transaction. Even if one party is simply late in settling, thenthe other party may incur a loss relating to missed

    investment opportunities. Settlement risk (i.e. the risk that

    the completion or settlement of a financial transaction will

    fail to take place as expected) thus includes elements of

    liquidity, market, operational and reputational risk as well as

    credit risk. The level of risk is determined by the particular

    arrangements for settlement. Factors in such arrangements

    that have a bearing on credit risk include: the timing of the

    exchange of value; payment/settlement finality; and the role

    of intermediaries and clearing houses.

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    Chapter 3: Settlement Risk

    3.1 Presettlement vs. Settlement Risk

    Counterparty credit risk consists of both presettlement and

    settlement risk. Preset- tlement risk is the risk of loss due to

    the counterpartys failure to perform on an obligation during

    the life of the transaction. This includes default on a loan or

    bond or failure to make the required payment on a

    derivative transaction. Presettlement risk can exist over long

    periods, often years, starting from the time it is contracted

    until settlement.

    In contrast, settlement risk is due to the exchange of cash

    flows and is of a much shorter-term nature. This risk arises as

    soon as an institution makes the required payment until the

    offsetting payment is received. This risk is greatest when

    payments occur in different time zones, especially forforeign exchange transactions where nationals are exchanged

    in different currencies. Failure to perform on settlement can

    be caused by counterparty default, liquidity constraints, or

    operational problems.

    Most of the time, settlement failure due to operational

    problems leads to minor economic losses, such as additional

    interest payments. In some cases, however, the loss can be

    quite large, extending to the full amount of the transferred

    payment. An example of major settlement risk is the 1974

    failure of Herstatt Bank. The day it went bankrupt, it had

    received payments from a number of counterparties but

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    defaulted

    before payments were made on the other legs of the

    transactions.

    3.2 Handling Settlement Risk

    In March 1996, the Bank for International Settlements (BIS)

    issued a report warning that the private sector should find

    ways to reduce settlement risk in the $1.2 trillion-a- day global

    foreign exchange market.1

    The report noted that central bankshad signifi- cant concerns regarding the risk stemming from

    the current arrangements for settling FX trades. It explained

    that the amount at risk to even a single counterparty could

    exceed a banks capital, which creates systemic risk. The

    threat of regulatory The action led to reexamination of

    settlement risk status of a trade can be classified into five

    categories:

    Revocable: when the institution can still cancel the transfer

    without the consent of the counterparty

    Irrevocable: after the payment has been sent and before

    payment from the otherparty is due Uncertain: after the

    payment from the other party is due but before it is actually

    received

    Settled: after the counterparty payment has been received

    Failed: after it has been established that the counterparty has

    not made the pay- ment

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    Settlement risk occurs during the periods of irrevocable

    and uncertain status, which can take from one to three days.

    While this type of credit risk can lead to substantial

    economic losses, the short nature of settlement risk makes it

    fundamentally different from presettlement risk. Managing

    settlement risk requires unique tools, such as real-time gross

    settlement (RTGS) systems. These systems aim at reducing

    the time interval between the time an institution can no

    longer stop a payment and the receipt of the funds from thecounterparty.Settlement risk can be further managed with

    netting agreements. One such form is bilateral netting, which

    involves two banks. Instead of making payments of gross

    amounts to each other, the banks would tot up the balance

    and settle only the net balance outstanding in each currency.

    At the level of instruments, netting also occurs with contracts

    for differences (CFD). Instead of exchanging principals in

    different currencies, the contracts are settled in dollars at the

    end of the contract term.2

    The next step up is a multilateral netting system, also called

    continuous-linked settlements, where payments are netted

    for a group of banks that belong to the sys- tem. This idea

    became reality when the CLS Bank, established in 1998

    with 60 bank participants, became operational on September

    9, 2002. Every evening, CLS Bank pro- vides a schedule of

    payments for the member banks to follow during the next

    day.

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    Chapter4 : Overview of Credit Risk

    4.1 Drivers of Credit Risk

    We now examine the drivers of credit risk, traditionally

    defined as presettlement risk. Credit risk measurement

    systems attempts to quantify the risk of losses due to coun-

    terparty default. The distribution of credit risk can be viewed

    as a compound process

    driven by these variables

    Default, which is a discrete state for the counterpartyeither

    the counterparty is in default or not. This occurs with some

    probability of default (PD).

    Credit exposure (CE), also known as exposure at default

    (EAD), which is the eco- nomic value of the claim on the

    counterparty at the time of default.

    Loss given default (LGD), which represents the fractional

    loss due to default. As an example, take a situation where

    default results in a fractional recovery rate of

    30% only. LGD is then 70% of the exposure.

    Traditionally, credit risk has been measured in the context of

    loans or bonds for which the exposure, or economic value,

    of the asset is close to its notional, or face value. This is an

    acceptable approximation for bonds but certainly not for

    derivatives, which can have positive or negative value.

    Credit exposure is defined as the positive

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    value of the asset:

    Credit Exposuret = Max(Vt, 0)

    This is so because if the counterparty defaults with money

    owed to it, the full amount has to be paid.3 In contrast, if it

    owes money, only a fraction may be recovered. Thus,

    presettlement risk only arises when the contracts

    replacement cost has a positive value to the institution (i.e.,

    is in-the-money).

    Measurement of Credit Risk

    The evolution of credit risk management tools has gone

    through these steps:

    Notional amounts

    Risk-weighted amounts External/internal credit ratings

    Internal portfolio credit models

    Initially, risk was measured by the total notional amount. A

    multiplier, say 8 per- cent, was applied to this amount to

    establish the amount of required capital to hold as a reserve

    against credit risk.

    The problem with this approach is that it ignores variations

    in the probability of default. In 1988, the Basel Committee

    instituted a very rough categorization of credit risk by risk-

    class, providing risk weights to scale each notional amount.

    This was the first attempt to force banks to carry enough

    capital in relation to the risks they were taking.

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    These risk weights proved to be too simplistic, however,

    creating incentives for banks to alter their portfolio in order

    to maximize their shareholder returns subject to the Basel

    capital requirements. This had the perverse effect of creating

    more risk into the balance sheets of commercial banks,

    which was certainly not the intended purpose of the 1988

    rules. As an example, there was no difference between AAA rated

    and c rated credits. Since loans to C-credits are more profitable

    than those to AAA-credits, given the same amount of

    regulatory capital, the banking sector responded by shifting

    its loan mix toward lower-rated credits.

    This led to the 2001 proposal by the Basel Committee to

    allow banks to use their own internal or external credit

    ratings. These credit ratings provide a better represen- tation

    of credit risk, where betteris defined as more in line with

    economic measures. The new proposals will be described in

    more detail in a following chapter.

    Even with these improvements, credit risk is still measured on

    a stand-alone basis. This harks back to the ages of finance

    before the benefits of diversification were for- malized by

    Markowitz. One would have to hope that eventually the

    banking system

    will be given proper incentives to diversify its credit risk.

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    4.2 Credit Risk vs. Market Risk

    The tools recently developed to measure market risk have

    proved invaluable to assess credit risk. Even so, there are a

    number of major differences between market and

    credit risks .As mentioned previously, credit risk results from

    a compound process with three sources of risk. The nature of

    this risk creates a distribution that is strongly skewed to the

    left, unlike most market risk factors. This is because credit

    risk is akin to short positions in options. At best, the

    counterparty makes the required payment and there is no loss.

    At worst, the entire amount due is lost.

    The time horizon is also different. Whereas the time required

    for corrective action is relatively short in the case of market

    risk, it is much longer for credit risk. Positions

    also turn over much more slowly for credit risk than for

    market risk, although the advent of credit derivatives now

    makes it easier to hedge credit risk.

    Finally, the level of aggregation is different. Limits on

    market risk may apply at the level of a trading desk, business

    units, and eventually the whole firm. In contrast, limits on

    credit risk must be defined at the counterparty level, for all

    positions taken by the institution.

    Credit risk can also mix with market risk. Movements in

    corporate bond prices indeed reflect changing expectations

    of credit losses. In this case, it is not so clear

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    whether this volatility should be classified into market risk

    or credit risk.

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    Chapter 5: Credit Risk Management by Stock

    Exchange.

    5.1 Settlement Process at NSCCL

    The settlement process begins as soon as members'

    obligations are determined through the clearing process. The

    settlement process revolves around the clearing corporation,

    which with the help of clearing banks and depositories, with

    clearing corporation providing a major link between clearing

    banks and depositories ensures actual movement of funds as

    well as securities on the prescribed pay-in and pay-out day.

    This requires members to bring in their funds/securities to

    the clearing corporation. The CMs make the securities

    available in designated accounts with the two dep ositories

    (CM pool account in the case of NSDL and designated

    settlement accounts in the case of CDSL). The depositories

    move

    the securities available in the pool accounts to

    pool account of the clearing corporation. Likewise C Ms

    with funds obligations make funds available in the

    designated accounts with clearing banks. The clearing

    corporation sends electronic instructions to the clearing

    banks to debit designated CMs' accounts to the extent of

    payment obligations. The banks process these instructions,

    debit accounts of CMs and credit accounts of the clearing

    corporation. This constitutes pay-in of funds and of

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    securities.

    After processing for shortages of funds/securities and

    arranging for movement of funds from surplus banks t o

    deficit banks through RBI clearing, the clearing corporation

    sends electronic instructions to the depositories/clearing

    banks to release pay-out of securities/funds. The depositories

    and clearing banks debit accounts of the Clearing

    Corporation and credit accounts of CMs. This constitutes

    pay out of funds and securities.

    Settlement is deemed to be complete upon declaration and

    release of pay-out of funds and securities. The settlement is

    performed by NSCCL as per well-defined settlement cycle.

    5.2 Settlement Guarantee Mechanism

    NSCCL has adopted the principle of novation for

    settlement of all trades. It is the legal counter-party to the

    settlement obligations of every member. NSCCL carries out

    the clearing and settlement of the trades executed in the

    Equities and Derivatives segments and operates Subsidiary

    General Ledger (SGL) for settlement of trades in

    government securities. It assumes the counter-party risk of

    each member and guarantees financial settlement. It also

    undertakes settlement of transactions on other stock

    exchanges like, the Over the Counter Exchange of India.

    NSCCL meets all settlement obligations, regardless of

    member complying with his obligations, without any

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    discretion. Once a member fails on any obligations, NSCCL

    immediately initiates measures to reduce exposure limits,

    withhold pay out of securities, square up open positions,

    disable trading terminal until members obligations are fully

    discharged.

    NSCCL assumes the counter party risk of each member and

    guarantees financial settlement. Counter party risk is

    guaranteed through a fine tuned risk management system

    and an innovative method of on -line position monitoring andautomatic disablement. A large Settlement Guarantee Fund

    provides the cushion for any residual risk. In the event of

    failure of a trading member to meet settlement obligations or

    committing default, the Fund is utilized to the extent

    required for successful completion of the settlement. This

    has eliminated counter party risk of trading on the Exchange.

    The market has now full confidence that settlements will

    take place in time and will be completed irrespective of

    possible default by isolated trading members. The

    5.3 Equities Segment

    Members are required to provide liquid assets which

    adequately cover various margins & base minimum capital

    requirements. Liquid assets of the member include their

    Initial membership deposits including the security deposits.

    Members may provide additional collateral deposit towards

    liquid assets, over and above their minimum membership

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    NSCCL at all points of time, after activation.

    Every CM is required to maintain BMC of Rs.50 lakh with

    NSCCL in the following manner:

    Rs. 25 lakh in the form of cash.

    Rs.25 lakh in any one form or combination of the following

    forms: (a) cash (b) fixed deposit receipts with approved

    custodians ban Guarantee from approved banks (d) approved

    securities in demat form deposited with approved custodians

    In addition to the above minimum base capital requirements,

    every CM is required to maintain BMC of Rs.10 lakh, in

    respect of every trading member(TM) whose deals such CM

    undertakes to clear and settle, in the following manner:

    Rs. 2 lakh in the form of cash.

    Rs.8 lakh in a one form or combination of the following: (a)

    cash (b) fixed deposit receipts with approved custodians (c)

    Bank Guarantee from approved banks (d) approved

    securities in demat form deposited with approved custodians

    Any failure on the part of a CM to meet with the BMC

    requirements at any point of time, will be treated as a

    violation of the Rules, Bye-Laws and Regulations ofNSCCL and would attract disciplinary action inter-alia

    including, withdrawal of trading facility and/or clearing

    facility, closing out of outstanding positions etc.Additional

    Base Capital

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    Clearing members may provide additional margin/collateral

    deposit (additional base capital) to NSCCL and/or may wish

    to retain deposits and/or such amounts which are receivable

    from NSCCL, over and above their minimum deposit

    requirements, towards initial margin and/or other

    obligations.

    Clearing members may submit such deposits in any one

    form or combination of the following forms: (i) Cash (ii)

    Fixed Deposit Receipts with approved custodians (iii) BankGuarantee from approved banks (iv) approved securities in

    demat form deposited with approved custodians.

    5.5 Effective Deposits / Liquid Networth

    Effective deposits

    All collateral deposits made by CMs are segregated into cash

    component and non-cash component.

    For Additional Base Capital, cash component means cash,

    bank guarantee, fixed deposit receipts, T-bills and dated

    government securities. Non-cash component shall mean all

    forms of collateral deposits like deposit of approved demand

    securities.

    At least 50% of the Effective Deposits should

    in the form of cash.

    Liquid Networth

    Liquid Networth is computed by reducing the initial margin

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    payable at any point in time from the effective deposits.

    The Liquid Networth maintained by CMs at any point in

    time should not be less than Rs.50 lakh (referred to as

    Minimum Liquid Net Worth).

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    Chapter6 :Margins

    6.1Equities Segment

    As per SEBI directives, the stocks are categorized as follows

    for imposition of margins:

    The Stocks which have traded atleast 80% of the days for the

    previous six months shall constitute the Group I (Liquid

    Securities) and Group II (Less Liquid Securities).

    Out of the scrips identified above, the scrips having mean

    impact cost of less than or equal to 1% shall be categorized

    under Group I and the scrips where the impact cost is more

    than 1, shall be categorized under Group II.

    The remaining stocks shall be classified into Group III

    (Illiquid Securities).

    The impact cost shall be calculated on the 15th of each

    month on a rolling basis considering the order book

    snapshots of the previous six months. On the basis of the

    impact cost so calculated, the scrips shall

    move from one group to another group from the 1st of the

    next month.

    For securities that have been listed for less than six months,

    the trading frequency and the impact cost shall be computed

    using the entire trading history of the security.

    For the first month and till the time of monthly review a

    newly listed security shall be categorised in that Group

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    where the market capitalization of the newly listed security

    exceeds or equals the market capitalization of 80% of the

    securities in that particular group. Subsequently, after one

    month, whenever the next monthly review is

    carried out, the actual trading frequency and impact cost of

    the security shall be computed, to determine the liquidity

    categorization of the security.

    In case any corporate action results in a change in ISIN, then

    the securities bearing the new ISIN shall be treated as newly

    listed security for group categorization

    6.2 Margin requirement

    yValue at Risk MarginyExtreme Loss MarginyMark-To-Market Margin

    Daily margin, comprising of the sum of VaR margin,

    Extreme Loss Margin and mark to market margin is payable.

    Value at Risk Margin

    VaR Margin is a margin intended to cover the largest loss

    that can be encountered on 99% of the days (99% Value at

    Risk). For liquid securities, the margin covers one-day losses

    while for illiquid securities, it covers three-day losses so as

    to allow the clearing corporation to liquidate the position

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    over three days. This leads to a scaling factor of square root

    of three for illiquid securities.

    For liquid securities, the VaR margins are based only on the

    volatility of the security while for other securities, the

    volatility of the market index is also used in the

    computation.

    Computation of VaR Rate:

    VaR is a single number, which encapsulates whole

    information about the risk in a portfolio. It measures

    potential loss from an unlikely adverse event in a normal

    market environment. It involves using historical data on

    market prices and rates, the current portfolio positions, and

    models (e.g., option models, bond models) for pricing those

    positions. These inputs are then combined in different ways,

    depending on the method, to derive an estimate of aparticular percentile of the loss distribution, typically the

    99th percentile loss.

    The return is defined as the logarithmic return: rt = ln(It/It -

    1 ) where It is the index futures price at time t.

    Security sigma means the volatility of the security computed

    as at the end of the previous trading day. The volatility is

    computed as mentioned above

    Security VaRmeans the higher of 7.5% or 3.5 security

    sigmas.

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    Index sigma means the daily volatility of the market index

    (S&P CNX Nifty or BSE Sensex) computed as at the end of

    the previous trading day.

    Index VaR means the higher of 5% or 3 index sigmas. The

    higher of the Sensex VaR or Nifty VaR would be used for

    this purpose.

    The VaR Margins are specified as follows for different

    groups of securities:

    Liquidity One-Day VaR Scaling factor for VaR Margin

    Categorization illiquidity

    Liquid Securities Security VaR 1.00 Security VaR

    (Group I)

    Less Liquid Higher of Security 1.73 Higher of 1.73

    Securities VaR and three (square root of times Security

    (Group II) times Index VaR 3.00) VaR and 5.20

    times Index VaR

    Illiquid Securities Five times Index 1.73 8.66 times Index

    (Group III) VaR (square root of VaR

    3.00)

    In case of securities in Trade for Trade segment (TFT

    segment) the VaR rate applicable is 100%.

    VaR margin rate for a security constitutes the

    following:

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    Value at Risk (VaR) based margin, which is arrived at, based

    on the methods stated above. The index VaR, for the

    purpose, would be the higher of the daily Index VaR based

    on S&P CNX NIFTY or BSE SENSEX. The index VaR

    would be subject to a minimum of 5%.

    Security specific Margin: NSCCL may stipulate security

    specific margins for the securities from time to time.

    The VaR margin rate computed as mentioned above will be

    charged on the net outstanding position (buy value-sell

    value) of the respective clients on the respective securities

    across all open settlements. There would be no netting off of

    positions across different settlements. The net position at a

    client level

    for a member are arrived at and thereafter, it is grossed

    across all the clients including proprietary position to arriveat the gross open position.

    For example, in case of a member, if client A has a buy

    position of 1000 in a security and client B has a sell position

    of 1000 in the same security, the net position of the member

    in the security would be taken as 2000. The buy position of

    client A and sell position of client B in the same security

    would not be netted. It would be summed up to arrive at the

    members open position for the purpose of margin

    calculation.

    The VaR margin shall be collected on an upfront basis by

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    adjusting against the total liquid assets of the member at the

    time of trade.

    The VaR margin so collected shall be released on

    completion of pay-in of the settlement.

    Extreme Loss Margin

    The Extreme Loss Margin for any security shall be

    higher of:5%, or 1.5 times the standard deviation of daily

    logarithmic returns of the security price in the last six

    months. This computation shall be done at the end of each

    month by taking the price data on a rolling basis for the pa st

    six months and the resulting value shall be applicable for the

    next month. In view of market volatility, SEBI may direct

    stock exchanges to change the margins from time -to-time in

    order to ensure market safety and safeguard the interest of

    investors.The Extreme Loss Margin shall be collected/adjusted against the total liquid assets of the member on a

    real time basis.The Extreme Loss Margin shall be collected

    on the gross open position of the member. The gross open

    position for this purpose would mean th e gross of all net

    positions across all the clients of a member including its

    proprietary position.

    There would be no netting off of positions across different

    settlements. The Extreme Loss Margin collected shall be

    released on completion of pay-in of the settlement.

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    Mark-to-Market Margin

    Mark to market loss shall be calculated by marking each

    transaction in security to the closing price of the security at

    the end of trading. In case the security has not been traded

    on a particular day, the latest available closing price at the

    NSE shall be considered as the closing price. In case the net

    outstanding position in any security is nil, the difference

    between the buy and sell values shall be considered as

    notional loss for the purpose of calculating the mark-to-market margin payable.

    MTM Profit/Loss = [(Total Buy Qty X Close price) Total

    Buy Value] - [Total Sale Value - (Total Sale Qty X Close

    price)]

    The mark to market margin (MTM) shall be collected from

    the member before the start of the trading of the next day.

    The MTM margin shall also be collected/adjusted

    from/against the cash/cash equivalent component of the

    liquid net worth deposited with the Exchange.

    Example 1:

    A trading member has two clients with the following MTM

    positions. What will be the MTM for the trading me mber?

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    Client Security X Security Y Security Z

    T-1 Day T Day T-1 Day T Day T-1 Day T Day

    A 800 300 -500 -1200 0 0

    B 1000 500 0 0 -1500 -800

    The MTM for the trading member will be -1700.

    The MTM margin shall be collected on the gross open

    position of the member. The gross open position for this

    purpose would mean the gross of all net positions across all

    the clients of a member including its proprietary position.

    For this purpose, the position of a client would b e netted

    across its various securities and the positions of all the

    clients of a broker would be grossed.

    There would be no netting off of the positions and setoff

    against MTM profits across two rolling settlements i.e. T

    day and T-1 day. However, for computation of MTM

    profits/losses for the day, netting or setoff against MTM

    profits would be permit Example 2:A trading member has

    two clients with the following positions. What will be the

    gross open position for the member in X, Y and Z?

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    Client Security Settlement Buy Value Sell Value

    Client

    A Security X 2005001 1000 1100

    Security Y 2005002 3000 2550

    Client

    B Security X 2005001 4500 2400

    Security Z 2005002 7000 10450

    The gross open position for the member in X, Y & Z will be

    2200, 450, 3450 respectively.

    In case of Trade for Trade Segment (TFT segment) each

    trade shall be marked to market based on the closing price of

    that security.

    The MTM margin so collected shall be released on

    completion of pay-in of the settlement.

    6.3Margin short foll

    In case of any shortfall in margin:

    The members shall not be permitted to trade withimmediate effect.

    A penalty of Rs.5000/- will be levied for violation of margin

    which shall be paid by next day. In case of subsequent

    violations during the day, penalty shall be increased by

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    Rs.5000/- for each such instance. (For example in case of

    second violation for the day the penalty levied will be

    Rs.10000/-, Rs.15000/- for third instances and so on).The

    penalty will be debited to the clearing account of the

    member.

    Penal charge of 0.07% per day shall be levied on the amount

    of margin shortage throughout the period of non -payment.

    6.4Exemption from margins:

    Institutional businesses i.e., transactions done by all

    institutional investors shall be exempt from margin

    payments. For this purpose, institutional investors shall

    include:

    Foreign Institutional Investors registered with SEBI(FII).

    Mutual Funds registered with SEBI (MF).

    Public Financial Institutions as defined under Section 4A of

    the Companies Act, 1956 (DFI).

    Banks, i.e., a banking company as defined under Section

    5(1)(c) of the Banking Regulations Act, 1949 (BNK).

    In cases where early pay-in of securities is made prior

    to the securities

    pay-in, such positions for which early pay-in (EPI) of

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    securities is made shall be exempt from margins. The EPI

    would be allocated to clients having net deliverable position,

    on a random basis. However, members shall ensure to pass

    on appropriate early pay-in benefit of margin to the relevant

    clients.

    6.5Derivatives Segment

    NSCCL has developed a comprehensive risk containment

    mechanism for the Futures & Options segment. The most

    critical component of a risk containment mechanism for

    NSCCL is the online position monitoring and margining

    system. The actual margining and position monitoring is

    done on-line, on an intra-day basis. NSCCL uses the SPAN

    (Standard Portfolio Analysis of Risk) system for the purpose

    of margining, which is a portfolio based system.

    The objective of SPAN is to identify overall risk in aportfolio of futures and options contracts for each member.

    The system treats futures and options contracts uniformly,

    while at the same time recognizing the unique exposures

    associated with options portfolios like extremely deep out-

    of-the-money short positions, inter- month risk and inter-

    commodity risk.

    SPAN is used to determine performance bond requirements

    (margin requirements), its overriding objective is to

    determine the largest loss that a portfolio might reasonably

    be expected to suffer from one day to the next day.

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    SPAN constructs scenarios of probable changes in

    underlying prices and volatilities in order to identify the

    largest loss a portfolio might suffer from one day to the next.

    It then sets the margin requirement at a level sufficient to

    cover this one-day loss.

    6.6Initial Margin

    NSCCL collects initial margin up-front for all the open

    positions of a CM based on the margins computed by

    NSCCL-SPAN. A CM is in turn required to collect the

    initial margin from the TMs and his respective clients.

    Similarly, a TM should collect upfront margins from his

    clients.

    Initial margin requirements are based on 99% value at risk

    over a one day time horizon. However, in the case of futures

    contracts (on index or individual securities), where it maynot be possible to collect mark to market settlement value,

    before the commencement of trading on the next day, the

    initial

    margin may be computed over a two-day time horizon,

    applying the appropriate statistical formula. The

    methodology for computation of Value at Risk percentage is

    as per the recommendations of SEBI from time to time.

    6.7Premium Margin

    In addition to Initial Margin, Premium Margin would be

    charged to members. The premium margin is the client wise

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    margin amount payable for the day and will be required to

    be paid by the buyer till the premium settlement is complete.

    6.8Assignment Margin

    Assignment Margin is levied on a CM in addition to SPAN

    margin and Premium Margin. It is required to be paid on

    assigned positions of CMs towards Interim and Final

    Exercise Settlement obligations for option contracts on

    individual securities and index, till such obligations are

    fulfilled.

    The margin is charged on the Net Exercise Settlement Value

    payable by a Clearing Member towards Interim and Final

    Exercise Settlement and is deductible from the effective

    deposits of the Clearing Member available towards margins.

    Assignment margin is released to the CMs for exercise

    settlement pay-in.

    6.9Payment of Margins ;The initial margin is payable

    upfront by Clearing Members. Initial margins can be paid by

    members in the form of Cash, Bank Guarantee, Fixed

    Deposit Receipts and approved securities.

    Non-fulfillment of either the whole or part of the margin

    obligations will be treated as a violation of the Rules, Bye-

    Laws and Regulations of NSCCL and will attract penal

    charges @ 0.07% per day of the amount not paid throughout

    the period of non-payment. In addition NSCCL may at its

    discretion and without any further notice to the clearing

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    member, initiate other displinary action, inter-alia including,

    withdrawal of trading facilities and/ or clearing facility,

    close out of outstanding positions, imposing penalties,

    collecting appropriate deposits, invoking bank guarantees/

    fixed deposit receipts, etc.

    6.10Violations

    PRISM (Parallel Risk Management System) is the real-time

    position monitoring and risk management system for the

    Futures and Options market segment at NSCCL. The risk of

    each trading and clearing member is monitored on a real -

    time basis and alerts/disablement messages are generated if

    the member crosses the set limits.

    yInitial Margin ViolationyExposure Limit Violation

    Trading Memberwise Position Limit Violation

    Client Level Position Limit Violation

    Market Wide Position Limit Violation

    Violation arising out of misutilisation of trading member/

    constituent collaterals and/or deposits

    Violation of Exercised Positions

    Clearing members, who have violated any requirement and /

    or limits, may submit a written request to NSCCL to either

    reduce their open position or, bring in additional cash

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    deposit by way of cash or bank guarantee or FDR or

    securities.

    A penalty of Rs. 5000/- is levied for each violation and is

    debited to the clearing account of clearing member on the

    next business day. In respect of violation on more than one

    occasion on the same day, penalty in case of second and

    subsequent violation during the day wil l be increased by

    Rs.5000/- for each such instance. (For example in case of

    second violation for the day the penalty leviable will beRs.10000/-, Rs.15000 for third instance and so on). The

    penalty is charged to the clearing member irrespective of

    whether the clearing member brings in margin deposits

    subsequently.

    Where the penalty levied on a clearing member/ trading

    member relates to a violation of Client-wise Position Limit,

    the clearing member/ trading member may in turn, recover

    such amount of penalty from the concerned clients who

    committed the violation

    Market Wide Position Limits for derivative contracts on

    underlying stocks

    At the end of each day the Exchange shall test whether the

    market wide open interest for any scrip exceeds 95% of the

    market wide position limit for that scrip. If so, the Exchange

    shall take note of open position of all client/ TMs as at the

    end of that day in that scrip, and from next day onwards the

    client/ TMs shall trade only to decrease their positions

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    through offsetting positions till the normal trading in the

    scrip is resumed.

    The normal trading in the scrip shall be resumed only after

    the open outstanding position comes down to 80% or below

    of the market wide position limit.

    A facility is available on the trading system to display an

    alert once the open interest in the futures and options

    contract in a security exceeds 60% of the

    market wide position limits specified for such security. Such

    alerts are presently displayed at time intervals of 10 minutes.

    At the end of each day during which the ban on fresh

    positions is in force for any scrip, when any member or

    client has increased his existing positions or has created a

    new position in that scrip the client/ TMs shall be subject to

    a penalty of 1% of the value of increased p osition subject to

    a minimum of Rs.5000 and maximum of Rs.1,00,000. The

    positions, for this purpose, will be valued at the underlying

    close price.

    The penalty shall be recovered from the clearing member

    affiliated with such trading members/clients on a T+1 day

    basis along with pay-in. The amount of penalty shall be

    informed to the clearing member at the end of the day

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    Chapter 7 :Credit Default Swaps

    1. Credit Default Swaps (CDS) are a class of credit

    derivatives that can be used to transfer credit risk from the

    investor exposed to the risk (the protection buyer) to an

    investor willing to assume that risk (the protection seller).

    While dealing in CDS, both buyer and seller of credit

    protection specify a reference entity, reference obligation,

    maturity of the contract, notional amount, credit events, etc.

    2. CDSis a bilateral derivative contract on one or more

    reference assets in which the protection buyer pays a

    premium through the life of the contract in return for a credit

    event paymentby the protection seller following a credit

    eventof the reference entities. In most instances, the

    protection buyer makes quarterly payments to the protection

    seller. The periodic payment (premium) is typically

    expressed in annualised basis points of a transactions

    notional amount. If any one of the credit events occurs

    during the life of the contract, the protection buyer will

    receive from the protection seller, a credit event payment,

    which will depend upon whether the terms of a particular

    CDS call for a physical or cash settlement. Generally, the

    legal framework of CDS i.e., the documentation

    evidencing the transaction is based on a confirmation

    document and legal definitions set forth by the International

    Swaps and Derivatives Association, Inc. (ISDA). If a credit

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    event occurs, the contract is settled through one of the types

    of settlement specified in the contract.

    3. In option terminology, the CDS protection buyer (long

    put) is short the credit risk and pays the premium or CDS

    spread to the protection seller (short put) who is long the

    credit risk. If there is no credit event by the contract

    expiration date, the protection buyer loses the premiums

    paid. On the other hand, if there is a credit event during the

    term of the contract, the protection seller will make a

    contingent payment to the protection buyer. Thus, procedure

    following the credit event is analogous to exercising an in -

    the money put option.

    4 Credit default swaps can be conceptualised as a piece

    of a debt obligation consisting of the credit spread (i.e., the

    interest beyond the risk-free rate) and the default risk of the

    instrument, both of which are transferred to the protection

    seller. A hedge buyer of a credit default swap essentially

    transforms part or all of his existing exposure on a debt

    obligation into something close to a high-quality government

    bond the "closeness" varying with the credit risks

    associated with the counterparty to the swap. Conversely, the

    seller of a credit default swap buys a slice of the original

    debt obligation, taking on the role of a lender but without

    incurring any funding costs or interest rate risks. The seller

    has acquired an instrument that will turn almost entirely on

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    the firm-specific risks of the reference debtor. [Lubben,

    2007]

    5 CDS andCredit Guarantee: The credit default swap

    structure is very close to that of a guarantee but differs in

    three important ways: the range of credit events that trigger

    payment is much broader under CDS; the protection buyer is

    not required to prove that it itself had suffered a loss, in

    order to receive payment; and CDSs are based onstandardised documentation and are traded. Credit default

    swaps are traditionally traded over-the-counter (OTC), rather

    than on an exchange. These are customised risk transfer

    instruments that are negotiated and executed bilaterally

    between counterparties. CDS counterparties typically post

    collateral to guarantee that they will fulfill their obligations.

    Post-crisis, the regulators and market participants are

    moving towards centralised clearing of these instruments.

    6 Single Name, Index and BasketCDS: There are three

    types of CDS. First, the single-name CDS offers protection

    for a single corporate or sovereign reference entity. Second,

    CDS indices are contracts which consist of a pool of single-

    name CDSs, whereby each entity has an equal share of the

    notional amount within the index. The standardization and

    transparency of indices has contributed strongly to the

    growth of index contracts. Third, basket CDS is a CDS on a

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    portfolio with many reference entities. The payoff trigger

    can be the first default (1 st-to-default), the second default

    (2nd-to-default) or the nth default (nth-to-default).

    7 The features of a credit default swap are:

    (i) Reference Entity: CDS generally references to thecredit quality of the issuer and not the obligation.

    Credit default swap contracts specify a reference

    obligation (a specific bond or loan) which defines the

    issuing entity through the bond prospectus. Following

    a credit event, bonds or loans pari passu with the

    reference entity bond or loan are deliverable into the

    contract. Typically a senior unsecured bond is the

    reference obligation, but bonds at other levels of the

    capital structure may be referenced.

    (ii) Notional amount: The amount of credit risk beingtransferred. This amount is agreed between the buyer

    and seller of CDS protection.

    (iii) Spread: The payments (cost of CDS to the buyer)quoted in basis points paid annually. Payments are

    paid quarterly, and accrue on an actual/360 day basis.

    The spread is also called the fixed rate, coupon, or

    price.(iv) Maturity: The expiration of the contract, usually on

    the 20th of March, June, September or December in

    case of standardised contracts.

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    8 Credit Events: A credit event is a pre-specified event

    that triggers a contingent payment on a credit default swap.

    Credit events are defined in the 2003 ISDA Credit

    Derivatives Definitions and include the following:

    (i) Bankruptcy: includes insolvency, appointment ofadministrators/liquidators, and creditor arrangements.

    (ii) Failure to pay: includes payment failure on one ormore obligations after expiration of any applicable

    grace period; typically subject to a materialitythreshold (e.g., USD 1million for North American

    CDS contracts).

    (iii) Restructuring: refers to a change in the agreementbetween the reference entity and the holders of an

    obligation (such agreement was not previously

    provided for under the terms of that obligation) due to

    the deterioration in creditworthiness or financial

    condition to the reference entity with respect to

    reduction of interest or principal / postponement of

    payment of interest or principal.

    (iv) Repudiation/moratorium: authorised governmentauthority (or reference entity) repudiates or imposes

    moratorium and failure to pay or restructuring occurs.

    (v) Obligation acceleration: one or more obligations havebecome due and payable before they would otherwise

    have been due and payable as a result of, or on the

    basis of, the occurrence of a default, event of default

    or other similar condition or event (however

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    described), other than a failure to make any required

    payment, in respect of a Reference Entity under one or

    more Obligations in an aggregate amount of not less

    than the Default Requirement.

    (vi) Obligation Default: one or more obligations havebecome capable of being declared due and payable

    before they would otherwise become due and payable

    as a result of, or on the basis of, the occurrence of a

    default, event of default, or other similar condition or

    event (however described), other than a failure to

    make any required payment, in respect of a reference

    entity under one or more obligations in an aggregate

    amount of not less than the default requirement.

    However, recently in the US market restructuring has been

    excluded from credit events. Further, there are several

    versions of the restructuring credit event that are used in

    different markets (e.g. modified restructuring in the Euro

    zone).

    9 Monetising the CDS: It is not necessary that a credit

    event must occur to enable credit default swap investors to

    capture gains or losses. Credit default swap spreads widenwhen the market perceives credit risk has increased and

    tightens when the market perceives credit risk has improved.

    Investors could monetise unrealised profits using two

    methods. First, investor could enter into the opposite trade,

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    selling/ buying protection for effectively locking in profits

    till contract maturity. The second method to monetise trades

    is to unwind them with another investor and receive the

    present value of the expected future payments.

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    Chapter 8 :on-line Monitoring

    NSCCL has in place an on-line position monitoring and

    surveillance system whereby positions of the members is

    monitored on a real time basis. A system of alerts has been

    built in so that both the member and NSCCL are alerted

    when the margins of a member approaches pre -set levels

    (70%, 85%, 90%, 95% and 100%). The system also allows

    NSCCL to further check the micro-details of members

    positions, if required.

    This facilitates NSCCL to take pro-active action. NSCCL

    has discretion to initiate action suo moto for reducing a

    member position, if required, more particularly where a

    member, after NSCCL requiring him to reduce his position

    fails to close out positions or make additional margin calls.

    The on-line surveillance mechanism also generates various

    alerts/reports on any price/volume movement of securities

    not in line with past trends/patterns. For this pur pose the

    exchange maintains various databases to generate alerts.

    Alerts are scrutinized and if necessary taken up for follow up

    action. Open positions of securities are also analysed.

    Besides this, rumors in the print media are tracked and

    where they are price sensitive, companies are contacted for

    verification. Replies

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    yCase StudyCredit Default Swap

    Although swaps can be used to hedge against any sort of credit risk, they

    are easiest to explain through a notional case study of an instrument such

    as a bond. A fund may, for example, hold $8,000,000 of Mega Car

    Companys five-year bond, and is concerned about the possibility of

    default due to market conditions arising from rising oil prices, increased

    government regulation on emissions, or the macroeconomic climate.

    The fund decides to buy a credit default swap in a notional amount of

    $8,000,000 to cover the potential default value. The CDS in this case

    trades at 150 basis points, so the fund will pay 1.5% of $8,000,000, or

    $120,000 annually.

    If Mega Car Company does not default, the fund will simply receive the

    full $8,000,000. In this case its return will not be as good as it would have

    been without the CDS.

    On the other hand, if the corporation does default after, say, two years,

    the fund will receive its $8,000,000 from the seller of the CDS. It could

    be that the seller will take the bond or pay the difference between the

    recovery value and the par value of the bond.

    Alternatively, Mega Car Company could make a breakthrough in low -

    emission technology and dramatically improve its credit profile. In that

    case the fund might decide to reduce its outgoings by selling the

    remaining period of the CDS.

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    Back to top

    Advantages

    y Derivatives such as a CDS will reduce or entirely remove the riskof default.

    Back to top

    Disadvantages

    y The cost of hedging will reduce the return on investment.

    Credit Risk Management at JP Morgan Chase

    JP Morgan Chase (JP), the second largest financial services company in

    the US, is exposed to credit risk through its lending, trading and capital

    market activities. JP''s credit risk management practices are designed to

    preserve the independence and integrity of the risk assessment process. JP

    has taken various steps to ensure that credit risks are adequately assessed,

    monitored and managed. In early 2003, JP has combined its Credit Risk

    Policy and Global Credit Management functions to form Global Credit

    Risk Management consisting of the five primary functions - Credit Risk

    Management, Credit Portfolio Group, Policy & Strategic Group, Special

    Credits Group and Chase Financial Services (CFS) Consumer Credit

    Management Risk. JP Morgan Chase (JP) was exposed to credit riskthrough its lending, trading and capital market activities. JP's credit risk

    management (CRM)1 practices were designed to preserve the

    independence and integrity of the risk assessment process. JP had taken

    various steps to ensure that credit risks were adequately assessed,

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    monitored and managed.

    In early 2003, the Credit Risk Policy and Global Cr edit Management

    functions were combined to form Global CRM consisting of the five

    primary functions Credit Risk Management, Credit Portfolio Group,

    Policy & Strategic Group, Special Credits Group and Chase Financial

    Services (CFS) Consumer Credit Management Risk. (See Exhi Consumer

    Credit Management Risk. (See Exhibit 6).

    Business Strategy & Risk Management

    Commercial

    JP's business strategy for its large corporate commercial portfolio

    remained primarily one of origination for distribution. Bulk of the

    wholesale loan originations were distributed into the marketplace.

    Residual holds averaged less than 10%. The commercial loan portfolio

    declined by 9% in 2003, due to a combination of continued weak loan

    demand, ongoing goal of reducing commercial credit co ncentrations and

    refinancings into more liquid capital markets.

    To measure commercial credit risk, JP estimated the likelihood of default;

    the amount of exposure in case of default and the loss severity given a

    default event. Based on these factors and r elated market-based inputs, JP

    estimated both expected and unexpected losses for each segment of the

    portfolio. Expected losses were statistically based estimates of credit

    losses over time.

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    They were used to set risk-adjusted credit loss provisions. Such losses

    could be factored into the pricing and covered as a normal and recurring

    cost of doing business. Unexpected losses represented the potential

    volatility of actual losses relative to the expected level of losses and

    formed the basis for the credit risk capital-allocation process...

    Commercial and Consumer Credit Portfolio

    JP's total credit exposure was $730.9 billion as on 31st December 2003

    (Exhibit 9), a 2% increase when compared to 2002. The increase reflected

    a $41.5 billion in consumer exposure, partially offset by a $30.2 billion

    decrease in commercial exposure...

    Commercial Credit Portfolio

    As on 31st December 2003, 83% of the total commercial credit exposure

    of $383 billion (See Exhibit 9) was considered investment -grade, an

    improvement from 80% in 2002...

    Consumer Credit Portfolio

    Consumer portfolio's largest component consisted primarily of 14

    family residential mortgages, credit cards and automobile financings. The

    consumer portfolio was predominantly US-based. 14 family residential

    mortgage loans were primarily secured by first mortgages...

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    ...