In a world where market turmoil and systemic risks are pervasive, effective counterparty credit risk management (CCR) becomes increasingly vital. Recent events, such as the collapse of Archegos Capital Management which caused over $10 billion in losses, commodity market volatility after Russia’s invasion of Ukraine in 2022, and UK gilt market disruption in late 2022 and early 2023, have underscored the critical need for enhanced guidelines CCR management. 

Last week, the Basel Committee on Banking Supervision (BCBS) responded to this ongoing challenge by issuing a consultation document aimed at addressing systemic vulnerabilities exposed by these tumultuous market events. The document proposes comprehensive guidelines aimed at bolstering the management of CCR and is focused on four key areas – due diligence, credit risk mitigation strategies, improved measurement of CCR and a strong CCR governance framework. Here we will explore each of these areas and what they mean for banks.  

1. Vigilant Oversight at Every Stage 

The Basel Committee’s consultation document emphasises the importance of conducting thorough assessments of counterparties from the outset of any relationship, advocating for a deep understanding of counterparties’ business models, risk exposures, and risk management practices. Unsurprisingly the document also stresses the need to continuously monitor counterparties throughout the relationship.  

Beyond initial onboarding and ongoing monitoring, the document advocates for periodic reviews and reassessments to adapt to evolving market conditions, along with scenario analysis and stress testing to identify vulnerabilities. It also highlights the importance of leveraging external data sources and intelligence gathering to augment internal assessments and encourages peer benchmarking and best practices to refine due diligence approaches.  

2. Strategies for Mitigation and Resilience 

This section includes insights into mitigating CCR through robust risk mitigation strategies. A key recommendation is the utilisation of advanced margining techniques, mandating counterparties to provide collateral, whether cash or securities, to offset potential losses in the event of default. The document emphasises the need for enforceable and resilient collateral agreements, ensuring that financial institutions are adequately safeguarded. 

Additionally, the document promotes the deployment of supplementary financial safeguards, such as guarantees and credit derivatives, to augment the risk mitigation toolkit which offer additional layers of protection and bolster resilience against CCR.  

3. Elevated CCR Measurement  

Next, the document outlines guidelines aimed at refining the measurement and management of exposure to CCR emphasises the importance of employing quantitative metrics, such as potential future exposure (PFE) and stress testing, to assess the impact of adverse scenarios.  

Specifically, the document underscores the critical role of these metrics in comprehending the maximum possible loss under extreme yet plausible market conditions. By incorporating these advanced quantitative techniques into their risk management frameworks, banks can gain a nuanced understanding of their exposure to CCR.  

4. Strengthening Governance Frameworks 

Finally, the BCBS highlights the importance of establishing a robust governance framework for managing CCR to ensure that responsibilities are clearly defined, and procedures are in place to effectively manage CCR. This includes establishing oversight mechanisms at both senior management and board levels to monitor and assess CCR exposures.  

Further, the document emphasises the need for a strong risk culture within financial institutions, where CCR management is integrated into the strategic goals of the organisation.  

Call to Action 

Financial institutions and regulatory bodies are urged to adopt and implement these new guidelines swiftly and rigorously. By doing so, they will not only align with best practices for managing CCR but also contribute to the overall resilience and stability of the global financial system.  

Banks are encouraged to revise their current risk management frameworks, enhance training for risk officers, and invest in better risk assessment tools as guided by these recommendations. Supervisors are also called upon to ensure compliance and to foster a proactive approach to risk management within the banking sector. This collective effort will help mitigate the risks of future financial disruptions and protect against potential losses from counterparty failures. 

The Basel Committee on Banking Supervision welcomes comments on all aspects of the proposed guidelines. Comments should be submitted by 28 August 2024.