Related provisions for BIPRU 7.10.126
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BIPRU 7.10 provides details of when the FSA expects to allow a firm to use a VaR model (value at risk model) for the purpose of calculating part or all of its PRR. It introduces the concept of a VaR model, the methodology behind it and the link to the standard market risk PRR rules. It then goes on to detail the application and review process. The bulk of BIPRU 7.10 specifies the model standards and risk management standards that firms will be required to meet in order to use
BIPRU 7.10 sets out the minimum standards that the FSA expects firms to meet before granting a VaR model permission. The FSA will not grant a VaR model permission unless it is satisfied that the requirements of BIPRU 7.10 are met and it is satisfied about the procedures in place at a firm to calculate the model PRR. In particular the FSA will not normally grant a VaR model permission unless it is satisfied about the quality of:(1) the internal controls and risk management relating
At least once a year, a firm must conduct, as part of its regular internal audit process, a review of its risk management process. This review must include both the activities of the business trading units and of the independent risk control unit, and must be undertaken by suitably qualified staff independent of the areas being reviewed. This review must consider, at a minimum:(1) the adequacy of the documentation of the risk management system and process;(2) the organisation
A firm must have processes in place to ensure that its VaR model has been adequately validated by suitably qualified parties independent of the development process to ensure that it is conceptually sound and adequately captures all material risks. This validation must be conducted when the VaR model is initially developed and when any significant changes are made to the VaR model. The validation must also be conducted on a periodic basis but especially where there have been any
(1) In addition to regulatory backtesting programs, testing for model validation should be carried out using additional tests which may include for example:(a) testing carried out using hypothetical changes in portfolio value that would occur were end of day positions to remain unchanged;(b) testing carried out for longer periods than required for the regular backtesting programme (for example, 3 years);(c) testing carried out using confidence intervals other than the 99 percent
In assessing whether the VaR model is implemented with integrity as described in BIPRU 7.10.58R (Stress testing), the FSA will consider in particular the information technology systems used to run the model and associated calculations. The assessment may include:(1) feeder systems; risk aggregation systems; time series databases; the VaR model system; stress testing system; the backtesting system including profit and loss cleaning systems where appropriate; data quality; reconciliations
A firm must ensure that it has adequate controls relating to:(1) the derivation of the model PRR;(2) the integrity of the backtesting programme, including the calculation of the profit and loss account;(3) the integrity and appropriateness of the VaR model, including the VaR model's geographic coverage and the completeness of data sources;(4) the VaR model's initial and ongoing development, including independent validation;(5) the valuation models, including independent validation;
Backtesting conducted only at a whole portfolio level using a single measure of profit and loss has limited power to distinguish an accurate VaR model from an inaccurate one. Backtesting should therefore be regarded as an additional safeguard rather than a primary validation tool. Such testing does however form the basis of the FSA'splus factor system. The test has been chosen as the basis of the backtesting regime because of its simplicity. A firm will therefore be expected to
The ultimate purpose of backtesting is to assess whether capital is sufficient to absorb actual losses. Therefore backtesting should be performed using a measure of actual daily profit and loss. Actual daily profit and loss means the day's profit and loss arising from trading activities within the scope of the VaR model permission. This measure should, however, be 'cleaned' using BIPRU 7.10.100R inclusion in profit and loss of non-modelled factors.
The FSA will review as part of a firm'sVaR model permission application the processes and documentation relating to the derivation of profit and loss used for backtesting. A firm's documentation should clearly set out the basis for cleaning profit and loss. To the extent that certain profit and loss elements are not updated every day (for example certain reserve calculations) the documentation should clearly set out how such elements are included in the clean profit and loss
A backtesting exception is deemed to have occurred for any business day if the clean profit and loss figure for that business day shows a loss, which in absolute magnitude, exceeds the one-day VaR measure for that business day. The only exception is if that business day is identified in the firm'sVaR model permission as giving rise to an excluded backtesting exception.
If a backtesting exception occurs, the firm must notify its usual supervisory contact at the FSA orally by close of business two business days after the business day for which the backtesting exception occurred. Within five business days following the end of each Month, the firm must submit to the FSA a written account of the previous Month'sbacktesting exceptions (if any). This explanation must include the causes of the backtesting exceptions, an analysis of whether the backtesting
(1) This paragraph gives guidance on the backtesting calculation and reporting process in BIPRU 7.10.96R - BIPRU 7.10.104R.(2) Let the day on which the loss referred to in BIPRU 7.10.100R is made be day n. The value-at-risk measure for that day will be calculated on day n-1, or overnight between day n-1 and day n. Profit and loss figures are produced on day n+1, and backtesting also takes place on day n+1. The firm's supervisor should be notified of any backtesting exceptions
(1) This paragraph gives guidance on the process for excluding backtesting exceptions as referred to in BIPRU 7.10.103R.(2) The FSA will respond flexibly to backtesting exceptions. However, the FSA's starting assumption will be that a backtesting exception should be taken into account for the purpose of the calculation of plus factors. If the firm believes that a backtesting exception should not count for that purpose, then it should seek a variation of its VaR model permission
If a firm'sVaR model permission covers specific risk, the firm must validate its VaR model through backtesting aimed at assessing whether specific risk is being accurately captured. This backtesting must be carried out in accordance with the provisions of its VaR model permission. If the VaR model permission provides for this backtesting to be performed on the basis of relevant sub-portfolios, these must be chosen in a consistent manner.
Specific risk backtesting involves the backtesting of a standalone specific riskVaR measure against a profit and loss series determined by reference to exposure risk factors categorised as specific risk. Alternatively specific risk backtesting may take the form of regular backtesting of trading books and portfolios that are predominantly exposed to risk factors categorised as specific risk. The precise requirements for specific risk backtesting will be specified in the firm'sVaR
Where backtesting reveals severe problems with the basic integrity of the VaR model, the FSA may withdraw model recognition. In particular, if ten or more backtesting exceptions are recorded in a 250 business day period, the FSA may apply a plus factor greater than one or the FSA may consider revoking a firm'sVaR model permission. The FSA may also consider revoking a firm'sVaR model permission if ten or more specific riskbacktesting exceptions occur in such a period.
A firm must also perform backtesting against a clean hypothetical profit and loss figure with respect to each business day. A clean hypothetical profit and loss figure for a business day means the clean profit and loss figure that would have occurred for that business day if the portfolio on which the VaR number for that business day is based remained unchanged.
(1) A clean hypothetical profit and loss figure is based on the day's change in the value of the same portfolio that was used to generate the value-at-risk forecast.(2) Backtesting under BIPRU 7.10.111R, although carried out with respect to each business day, need not be carried out each day. A firm need only carry it out sufficiently frequently to comply with its reporting requirements under BIPRU 7.10.129R. An exception arising out of such backtesting need not be reported to
The table in BIPRU 7.10.125R sets out the plus factors to be added to the minimum multiplication factor for any business day. It is based on the number of backtesting exceptions that occurred during the backtesting period as referred to in BIPRU 7.10.96R (Backtesting: Basic testing requirements) ending three business days preceding the business day for which the model PRR is being calculated.
A firm must, no later than the number of business days after the end of each quarter specified in the VaR model permission for this purpose, submit, in respect of that quarter, a report to the FSA about the operation of the VaR model, the systems and controls relating to it and any changes to the VaR model and those systems and controls. Each report must outline as a minimum the following information in respect of that quarter:(1) methodological changes and developments to the
A firm may change its VaR model to such extent as it sees fit, except that it must not make a change that (either on its own or together with other changes since the date of VaR model permission) would:(1) be inconsistent with VaR model permission or BIPRU 7.10; or(2) mean that backtesting in accordance with BIPRU 7.10 and the VaR model permission would result in the use of data that is inappropriate for the purposes of measuring the performance of the VaR model.