Counterparty Credit Limits and

Exposure Management Survey

A Survey by the
Professional Risk
Managers International
Association
NOVEMBER

2008

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ABOUT PRMIA
PRMIA is the Professional Risk Managers International Association. Formed in January 2002,
PRMIA sets a higher standard for risk professionals with more than 65 chapters around the
world and over 55,000 members from more than 180 countries. A non-profit, member-led
association, PRMIA is dedicated to defining and implementing the best practices of risk
management through education, certification, events, networking, and online resources.
More information can be found at www.PRMIA.org.
Contact PRMIA at surveys@prmia.org

ABOUT SUNGARD ADAPTIV

SunGards Adaptiv provides enterprise-wide credit and market risk management and operations solutions for financial services institutions. Adaptiv assists institutions of varying size
and complexity to deploy technology to meet both internal and regulatory requirements for
risk management and operational control.
To find out more contact: telephone: +44 (0)208 081 2779
email: adaptiv.marketing@sungard.com, web: www.sungard.com/adaptiv

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Counterparty Credit Limits and

Exposure Management Survey

INTRODUCTION

ounterparty risk has never been of more importance than now. We are
experiencing a maelstrom in the capital markets the likes of which has not
been seen since the great depression of the 1930s. We have seen recurring
banking disasters as Wall Street and the City of London watched centuries-old
institutions fail, be absorbed by others or be bailed out by government support.
The prospect of a bulge-bracket primary dealer being allowed to fail seemed almost
inconceivable as recently as a year ago. Now this remote possibility has become a
reality. Similarly inconceivable was a situation where hedge funds would be more
concerned about the creditworthiness of their prime brokers than vice versa.

The sense of crisis has been massively exacerbated by a lack of timely and reliable
risk information at many institutions that hampered their ability to react effectively.
When it takes weeks to compile a comprehensive report on all your exposures to a
given counterparty you cannot hope to be able to react to daily events.
In the present circumstances, it is hardly surprising to observe such urgency among
banks to reassess their counterparty risk management, methodologies and systems.
It is with this urgency in mind that SunGard, in conjunction with the Professional Risk
Managers International Association (PRMIA), launched the following survey into
counterparty risk. The questions are designed to explore best practices in the areas of
risk policies, exposure measurement and systems. Responses were provided by more
than 450 risk professionals from around the world.

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S U R V E Y R E S U LT S

Please assess the importance of the following features of a credit exposure monitoring system.
0%

20%

40%

60%

80%

100%

Flexible credit limits framework (global limits, sub-limits, etc).

Real-time exposures updates.
Accuracy of exposure modelling.
Consolidation of exposures arising from the Trading Book (counterparty
risk on OTC derivatives) and the Banking Book (lending activities).
Inclusion of Issuer Exposures.
Ability for risk takers to perform fast pre-deal limit checks.

Very Important
Somewhat Important
Somewhat Unimportant
Not Important

Single view of all entity-specific exposures.

Calculation of regulatory exposure.
Graphical representation of exposure profiles.
Real-time notification of violations & excesses.
Approval workflow for violations & excesses (post-deal).
Workflow for pre-deal approvals.
Approval workflow for credit limits.
Credit grading (scoring) models.
Indication of the sensitivity of portfolio exposures to underlying risk factors.
Reporting of wrong-way risk positions.

FIGURE 1

Tied for 1st and 2nd in terms of importance were accuracy of exposure estimates and
flexibility of the limit structures the system can handle.
In 3rd place was gaining a consolidated exposure view across derivatives, issuer risk
and banking book.
4th place was tactical decision support such as pre-deal checking and not just afterthefact reporting.
Exposure sensitivity analysis is not widely available in existing systems. The resulting
unfamiliarity with the concept is likely to be the reason that a somewhat smaller share
of respondents rated it as Very important or Somewhat important. Nevertheless,
almost half of all respondents rated it Very important and another 36% rated it
Somewhat important. Recent fears concerning the stability of even major financial
institutions is likely to have boosted the perceived importance of this functionality.
Generally work flow and presentation functionality were viewed as desirable but less
important than the analytical core of the system.

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S U R V E Y R E S U LT S
With respect to the real-time aspect, how should
exposure updates be applied, including those
from what-if pre-deal checks?

How should pre-deal limit checks be performed?

11%
46%
14%

42%

29%
58%

From the relevant front office system, via real-time

interface to the credit limits system.

With some proxy gross exposure,

pending full portfolio recalculation.

Within the front office system, against sub-limits

allocated to each front office system.

With accurate netted portfolio-based exposure.

FIGURE 2

A significant amount of doubt was evident concerning the

feasibility of real-time what-if limit checks based on simulated PFE. This is likely conditioned by the functionality
and performance of systems with which respondents are
familiar.

Should the credit limits system calculate Exposure

or Risk?
32%

Via a dedicated credit checking user interface

(which may be part of the credit limits system).
A combination of the above.
FIGURE 4

Although the responses were relatively mixed with a combination of the above being the most popular choice, the
most surprising result was the low vote (11%) for checking
against allocated sub-limits versus a central credit system.
These answers may well be influenced by the respondents
perception of the possible alternatives based on their
individual experience. Nevertheless, most of the market has
come to the logical conclusion that risk is a portfolio issue
and that counterparty credit risk must be treated accordingly.
In many banks the reality is that risk managers are woefully
short of the information they need to assess counterparty
risk accurately. While this is a regrettable state of affairs, the
upside is that recent events may act as the overdue catalyst
needed to support a portfolio approach to credit risk.

68%

It should just calculate portfolio exposures

(Exposure At Default).
It should also calculate portfolio risk (Credit VaR,
economic capital, etc.).

FIGURE 3

A strong consensus is evident that risk estimation is a

necessary functionality in addition to accurate exposure
profiling.

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S U R V E Y R E S U LT S
Should pre-deal limit checks also provide an
indication of the cost-of-credit (CVA = Credit
Valuation Adjustment)?

20%

30%

How should cost-of-credit be defined?

14%

16%

70%
Provisions required to cover expected losses.

23%
27%
No, this should be kept separate to limit checking.
Ideally, yes, but this is technically not feasible.
Yes, although the CVA indication may be based on a gross
calculation, and may therefore not include all portfolio effects.
Yes, and the calculation should consider incremental
FIGURE 5
portfolio effects.

There was a nearly equal distribution across the possible

responses for this question. Almost a quarter (23%) of
respondents believed the addition of cost of credit would
complicate what should be as simple and efficient a
process as possible. The consensus, however, appeared to
be that calculating a sophisticated real-time cost of credit
in some form is highly desirable. Despite this, the survey
reflects considerable doubt regarding the commercial
practicality of achieving this given the perceived complexity
and cost of such a move. Individual comments included:
Ideally, but this is difficult and the value it adds
should be measured against the cost and difficulty of
implementation.

Cost of capital required to cover unexpected losses.

Both provisions for expected losses and cost of
capital for unexpected losses.

FIGURE 6

As with the previous question, there was a clear consensus

of opinion among respondents that cost-of-credit should
be defined by a combination of loss provisions and cost of
capital for unexpected losses. Again, as with the previous
question, there were doubts about the feasibility and
expense of achieving this aim.

In the development of risk systems there is always a tradeoff between the cost of development and the value of the
system but in this respect there seems to be an underestimation of the technology possibilities. This may be because
many respondents have come from an in-house technology
background an environment where it is harder to take a
long-term perspective to development due to the budgetary
constraints. Typically systems are developed to fill only the
immediate need. Additionally the amount of consolidation
in the banking sector of late means that many banks
development plans are hampered by the volume of
necessary integration work.

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S U R V E Y R E S U LT S
When combining derivative (counterparty) exposures with lending exposures, what is the most
appropriate measure?
A surprising share of respondents (39%) opted for PFE at a
given confidence level (e.g. 95%) although an equal number opted for either EPE (9%) or a hybrid measure between
EPE and PFE (30%). It is possible that some respondents
did not understand the question in the anticipated manner
that the issue is how to set relationship caps that include
both banking book loan exposures and derivative credit
exposure. The banking book component is usually stated in
terms of outstanding loan exposure and the question is
what measure for derivative credit exposure should count
against the cap.

6%
9%

39%
16%

30%
Potential Future Exposure at a given
confidence level ( e.g. 95%).
Expected exposure.
A hybrid measure in-between EE
and PFE.
Notional Amount.
Current MtM exposure.

FIGURE 7

One aspect of counterparty risk that is difficult to capture

in surveys is that measures for setting individual counterparty limits may not be equally appropriate for portfolio
analysis. There needs to be a consistent grammar
between mainstream banking book credit exposures and
trading book counterparty exposures but the best measure
to apply for trading book exposures may differ depending
on the situation.

With respect to issuer exposures, please assess the following features:

0%

20%

40%

60%

80%

100%

The ability to set limits to control the maximum exposure to an issuer.

The monitoring of the maximum holding period for securities.
The monitoring of any concentration risk in certain types of securities.
The monitoring of issuer exposures alongside credit exposures.

Very Important
Somewhat Important
Somewhat Unimportant
Not Important

The ability to offset issuer exposures via credit derivatives.

FIGURE 8

The ability to set (and by implication to track and control) limits on maximum exposure to an issuer
was the overwhelming favourite, although all the options were deemed very important or somewhat
important by an overwhelming majority of respondents. Monitoring concentrations and viewing issuer
risk along side other credit risks were considered to be the next most important features. What these
responses reflect is the importance of flexibility to configure counterparty risk systems to individual
institutional preferences.

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S U R V E Y R E S U LT S
How should issuer exposures (arising from holdings in securities positions) be monitored?

How should issuer exposures on securities

holdings be measured?
2%

14%

37%
24%

62%

11%

Within a credit limits framework.

Notional amount.

Within a market risk framework.

Market value.

Under a hybrid framework.

50%

Historical cost.
FIGURE 9

This question raises the prominent issue of integrating the

market and credit risk disciplines, a point which is also
addressed later in this survey. Over 60% of respondents
opted for a hybrid approach rather than a strictly market risk
or traditional credit risk approach. Presumably the nature of
the hybrid approach would vary depending on the liquidity
of the securities involved; therefore some variation in
respondents answers is to be expected.

A combination of the above depending

on which book (trading or investment)
the securities are held in.

FIGURE 10

Approximately half of the respondents said the method

should differ with the book in which the securities are held.
This is consistent with exposure being the potential for loss
not already recognized through a decline in market value.
Historical cost was chosen by a surprisingly low 2% of
respondents even though this is standard operating
procedure for certain investment accounts.

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S U R V E Y R E S U LT S
With respect to Banking Book exposures (loans,
LCs, etc.), how should one monitor the compliance with the terms of individual facilities?

Is it mandatory for risk takers to always check

credit limits before committing to a transaction?
1%
24%

26%

12%

63%

43%
31%
The global limits system should monitor the overall customer
exposure, but not the terms of each facility; the latter would be
the role of a dedicated Banking Book system, e.g. a loan
administration system or a facility management system.
In addition to the overall customer exposure, the global limits
system should also monitor the essential elements of each
facility, e.g. the facility limit and facility tenor. Other terms
(e.g. the permissible drawdown methods, subfacility limits,
etc.) should be monitored by the loan administration system.
The global limits system should monitor compliance with all
terms and conditions of banking book facilities.
FIGURE 11

A remarkable lack of consensus prevails here. The majority

response was for a global limits system for customer exposure that also monitors the essential elements of each facility.
A significant minority of respondents (31%) indicated a fully
integrated system would be best, although many expressed
significant scepticism about the feasibility of implementing
such an approach. Many observers feel that adopting one
monolithic solution to risk systems is impractical. They
argue that the risk area is so complex that such a system
would never allow risk managers to be agile enough to track
and analyze the full range of risks properly.

Yes, credit limits must always be checked

before entering into any risktaking activity.
Yes, except if the entity is rated at or
above a defined threshold (e.g. AA+).
In theory, yes, but pre-deal limit checking
is not always feasible, due to timing
and system constraints.
Pre-deal checking cannot be enforced
and is hence not mandatory.

FIGURE 12

Almost two-thirds said yes, credit limits must always be

checked. Several indicated that it is necessary to recognize
that always executing the actual check may be impractical
but that the risk of being penalized for breaching a limit
falls on the trader.

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S U R V E Y R E S U LT S
What best describes your opinion about limit
excesses?

How should counterparty limits be segregated?

9%

11%

2%

12%
9%

49%

31%
40%

37%

Product groups.
Excesses are a necessary evil that have to be
dealt with as efficiently as possible.

Business areas.
Local branches.

Excesses should be kept to a minimum, by

ensuring that adequate credit limits are in
place to meet the needs of the business.

A combination of the above.

None of the above (i.e. global counterparty
limits should be cross-product and crosslocation).

True excesses should be pre-approved. If this

is not the case, a disciplinary process will apply.
Excesses are intolerable. All risk-taking
activities must take place within approved
credit limits.

FIGURE 14

FIGURE 13

40% opted for True excesses should be pre-approved.

If this is not the case, a disciplinary process will apply.
Slightly fewer respondents chose Excesses should be kept
to a minimum, by ensuring that adequate credit limits are in
place to meet the needs of the business. The remaining
responses were split roughly evenly between Excesses are
a necessary evil that have to be dealt with as efficiently as
possible, and Excesses are intolerable. All risk-taking
activities must take place within approved credit limits.

Half of the respondents opted for the safety of A combination. 31% chose a single global limit per counterparty. One
comment pointed out the need to differentiate by documentation, although this is not necessary as long as netting is
handled properly. In the absence of a proper exposure
simulation methodology, segregation by agreement does
indeed make sense.

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S U R V E Y R E S U LT S
How should collateralised exposures (under ISDA
CSA) be measured?

How should Banking Book collateralised exposures be measured?

17%
24%

61%
41%

15%
42%

By capping the exposure profile to the threshold

plus minimum transfer amount.
By capping the exposure profile to the threshold
amount plus a buffer for potential exposure
movements during the 'cure' period. Buffer
represents a fixed percentage of the threshold.
Same as above, but the buffer is modelled
analytically based on the actual portfolio
composition.

The lending value of the collateral should be

recorded pro memoria, and should therefore
not reduce the original exposure amount
A combination of the above, depending on
whether the collateral is deemed to be liquid
or illiquid.

FIGURE 16

FIGURE 15

Roughly 40% opted for the most sophisticated approach

of modeling the buffer during the cure period analytically
and another 40% opted for modeling the buffer as a fixed
proportion of the threshold. The latter would probably
prefer modeling the buffer analytically but considered it
impractical. Less than 20% opted for using just the
threshold plus the minimum transfer amount with no
allowance for volatility during the cure period.

11

The lending value of the collateral should act

as an offset against the customer exposure.

Just over 60% chose a combination of approaches based on

the liquidity of the collateral. A quarter opted for full offset
of the exposure for the value of the collateral and 15%
argued that the collateral should be recorded pro memoria and not treated as an offset at all. The comments were
quite varied but no one mentioned an approach that some
find compelling, namely to treat the threshold plus an
appropriate buffer as unsecured risk with the Loss Given
Default (LGD) of the obligor while collateral held is shown
as exposure with a much lower LGD (higher recovery rate)
but the same probability of default of the obligor.

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S U R V E Y R E S U LT S
How should guaranteed exposures be measured
(including exposures protected by credit
derivatives)?

Please rate the importance of having a

combined credit risk and market risk system.
6%

25%

1%

26%

67%

75%

By completely transferring the exposure from

the primary obligor to the guarantor.

Very important.

Continue to record the exposure to the

primary obligor as guaranteed, and record
the exposure to the guarantor as indirect.

Somewhat unimportant.

Somewhat important.

Not important.

FIGURE 18

FIGURE 17

25% opted for transferring the exposure to the guarantor

while 75% opted for leaving it with the obligor and recording
indirect exposure to the guarantor. One comment
mentioned using the Basel II double default method. Quite
obviously the problem of how to handle joint responsibility
for an exposure continues to bedevil designers of risk
information systems.

A full two-thirds of respondents rated a combined credit

and market risk system as Very important. Another onequarter of respondents rated it as Somewhat important.
Clearly the increasing prevalence of traded credit risk has
raised the perceived urgency of a combined risk solution.
Some who argued for separate systems did so for practical
or cost reasons, stating that much of the benefit of more
integrated analysis across these areas can be achieved
without extensive system unification.

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S U R V E Y R E S U LT S
How long would you expect the implementation of a global credit exposure & limits system to take?
0%

10%

5%

15%

9.9%

9 months.

26.3%

12 months.

4.7%
12.9%

18 months.

16.1%

24 months.

More than 30 months.

30%

14.9%

6 months.

30 months.

25%

5.7%

3 months.

15 months.

20%

2.5%
6.9%

FIGURE 19

Most respondents who commented emphasised the heavy dependence on the size and complexity
of the organisation and its trading activities. In some cases there was also confusion about whether
this was the time to build a system from scratch or to deploy a system already well developed but
requiring some configuration or customisation. One respondent even offered a formula, namely
2 years (Tier * 6 months). This appears to mean 18 months for a Tier 1 organization and as
little as 6 months for a Tier 3 organization. In general, these are not unreasonable figures for
deployment of a fairly well developed system but when applied to the development of a system
from scratch to full deployment seems an overly aggressive timetable.

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CONCLUSION

he current crisis has enhanced awareness of the need for reliable, timely and
sophisticated counterparty credit exposure and credit risk information. There is
a growing recognition that this has to be undertaken at a portfolio level, using
appropriately sophisticated risk measures. Enhanced analysis to identify wrongway risk
and portfolio sensitivities is getting much more attention than even a year ago.
This survey indicates significant recognition of the importance of more detailed, more
comprehensive and more timely information on counterparty credit exposure and credit
risk. There is however disagreement on the exact detail of how best to achieve this. This
highlights the importance that vendors must place on flexibility and the ability of users
to customize counterparty risk systems to accommodate the views of their own
institutions. The task of deploying, maintaining and upgrading effective counterparty
credit systems remains a daunting one. Nevertheless, regulators, investors and the
general public will expect better performance in the future than has been evident in the
recent past.
Without a doubt both financial institutions and vendors will face serious challenges in
coming years to meet the demands for better counterparty credit risk management
information. The good news is that the tools, techniques and systems already exist
which will form the underlying architecture for such solutions. Now is the time for
institutions to invest in updating their risk infrastructures so that, next time around,
they are able to respond to fastchanging market conditions in minutes rather than days.

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