SA-CCR, a methodology to calculate the capital required to address the risk that the counterparty to a derivative contract will not live up to its contractual obligations, is a replacement for two existing ‘simple’ and outdated non-modelled exposure methods – CEM and SM.
While SA-CCR is intended to address some of the long-standing criticisms of the CEM and SM approaches, it still has several shortcomings, including its calibration and lack of recognition of margining and netting, which result in significantly overstated exposures. This could severely impact the availability and pricing of hedging products for end users.
Moreover, the full impact resulting from the implementation of SA-CCR remains untested. It is therefore imperative that the shortcomings of SA-CCR be remedied, as well as a full impact study on its calibration and its aggregate impact performed before it is implemented through the European Union’s Capital Requirements Regulation.
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