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Meeting the challenges of SCCL

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January 07, 2026
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Meeting the challenges of SCCL

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Moun Seo

January 07, 2026
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  1. Single Counterparty Credit Limit (SCCL) 2 Speakers Presenter Moun Seo

    Director – Solutions Specialist Moody’s Analytics Presenter Anders A. L. Rodenberg Head of Financial Institutions and Advisory Bureau van Dijk, A Moody’s Analytics Company Moderator Olivier Brucker Senior Director – Sales Manager Moody’s Analytics
  2. Single Counterparty Credit Limit (SCCL) 3 Agenda 1. Introduction to

    the SCCL regulation 2. Key challenges 1. Data 2. Calculation / aggregation 3. Reporting and limits monitoring 3. Global hierarchy information and economic interdependencies 4. Risk transfer and aggregation 5. Reporting and limits monitoring 6. SCCL, one piece of the puzzle 7. Key takeaways
  3. Single Counterparty Credit Limit (SCCL) 5 SCCL in a glance

    » Final Rules impose limits on the aggregate amount of net credit exposure that a covered company may have to an unaffiliated counterparty. » Depending on the size and regulatory status of the parties, these limits will range from 25 percent of total capital plus ALLL to 15 percent of tier 1 capital. » Compliance timeline: US G-SIBs and FBOs that are G-SIBs must comply by January 1, 2020, and other covered companies must comply by July 1, 2020. » Covered bank: 1) US global systemically important banks ("GSIBs"), 2) (ii) US bank holding companies ("US BHCs") with $250 billion or more in total assets, 3) (iii) the US operations of foreign banking organizations ("FBOs") that have $250 billion or more in total global assets and 4) (iv) intermediate holding companies ("IHC") with $50 billion or more in total assets Scope
  4. Single Counterparty Credit Limit (SCCL) 6 » Aggregate net credit

    exposures and compare with regulatory limits – (Daily) gross and net EAD calculations at a contract level – Direct and indirect exposures and CRM to be considered – Some divergences with Basel III Standardized rules » Economic interdependence and control relationship – If counterparty net credit exposure exceeds 5% of eligible capital base, unconnected affiliates of the counterparty must be examined for economic interdependence and control relationships » Regulatory reporting disclosures – FR 2590 schedules are highly granular and require clean accurate data: exposures of a respondent organization to its top 50 counterparties – Daily compliance and quarterly reporting for major covered companies or FBO Data, granularity, calculations, and reporting SCCL operational challenges
  5. Single Counterparty Credit Limit (SCCL) 7 FED US regulatory capital

    vs. SCCL regulation » Some minor differences exist – CCF impact for the OFB sheet – The derivatives exposures – Fund and securitization computation » Other considerations – Grouping of counterparties – Risk transfer for collateral – Exemptions application – No distinction between Banking Book and Trading Book Positions Basel regulatory capital and SCCL are closely aligned
  6. Single Counterparty Credit Limit (SCCL) 8 Large exposure vs. SCCL

    regulation » SCCL regulatory reports (FR 2590) are not yet finalized but have been proposed – Granularity of information to report (exposure type, residual maturity, counterparty type…) – Reporting of credit risk mitigants and risk transfer – Counterparty group by control: more stringent voting right threshold at 25% as opposed to 50% for LE » Credit Risk Mitigation (CRM) – For SCCL, the CRM used to reduce the gross exposure must be summed up to the guarantor exposure or to the issuer of the security provided as collateral » Exposure At Default (EAD) calculation – For derivatives: EU using SA-CCR. US using CEM. SA-CCR to potentially be adopted in the future in the US now that a proposal is out. Basel LE and SCCL are 95% identical
  7. Single Counterparty Credit Limit (SCCL) 10 Overview of a SCCL

    solution Counterparty identification Hierarchy management Exposure calculation and aggregation Regulatory reporting and limits monitoring Issuer/reference entity management Counterparty information management Lending & investment book exposure OTC Derivatives traded exposure Exchange traded exposure Issuer risk Netting Collateral Protection Other CRM Exposure netting and aggregation Risk transfer Limits and threshold monitoring Regulatory reporting Core Entity and Ownership Data
  8. Single Counterparty Credit Limit (SCCL) 12 Global Hierarchy Information &

    Economic Interdependency » If counterparty credit exposure exceeds 5% of capital base, unconnected affiliates of the counterparty must be examined for economic interdependence and control relationship. – “Not an operational problem, but a compliance problem” – “Chicken or the Egg?” – Top 50 counterparties » Use SCCL to drive inclusion of hierarchy data into Master Data Management program.
  9. Single Counterparty Credit Limit (SCCL) 13 Traditional exposure analysis without

    ownership Acne Corp. Deerfield Construction Madison Real Estate XP Electronics Kings Financial Services 1.4% 3.1% 2.2% 4.1% 3.6% Percentage of Exposure Counterparties
  10. Single Counterparty Credit Limit (SCCL) 14 SCCL exposure analysis with

    ownership data Acne Corp. Deerfield Construction Madison Real Estate XP Electronics Kings Financial Services 1.4% 3.1% 2.2% 4.1% 3.6% C B A Total exposure to Company A is 6.7% Percentage of Exposure Counterparties Parent Company Ownership Link
  11. Single Counterparty Credit Limit (SCCL) 15 How do we collect

    the data? » Economic Interdependency – Main Challenge: Doesn’t exist in public domain » Global Hierarchy Information – Challenges: Magnitude, Change, and Type
  12. Single Counterparty Credit Limit (SCCL) 16 …has led to very

    complex corporate ownership structures. Multiple levels & Multiple countries Globalization… Owners Subsidiaries
  13. Single Counterparty Credit Limit (SCCL) 17 Ownership is dynamic •

    155+ million ownership links • 456 million ownership links since 2012 • 43 million beneficial owners identified • 5 million edits, every month
  14. Single Counterparty Credit Limit (SCCL) 19 Don’t ask: “Who is

    your ultimate parent?” Inherent flaws a) Some won’t have the knowledge of their ultimate parent b) Some won’t have the authority to disclose c) No line of communication when change happens
  15. Single Counterparty Credit Limit (SCCL) 21 UK registry example Octo

    Telematics UK is owned 1 level by Octo Telematics LTD, but the ultimate is different
  16. Single Counterparty Credit Limit (SCCL) 22 Global approach to collecting

    ultimate parent data Multiple, global sources and networks are essential – source transparency is key.
  17. Single Counterparty Credit Limit (SCCL) 29 » Traditionally, the EAD

    in a netting is calculated as follow: » However, the only way to “transfer” the risk to the collateral issuer within a netting is to treat security and currency volatilities on a net basis, like a repo-netting Netting advantage calculation RCnet Anet EADnet
  18. Single Counterparty Credit Limit (SCCL) 30 Value of specific exposure

    – CIU/Funds Fund (Total 150) Bank’s investment (15) Pro rata share = 15/150 = 10% Underlying asset 1 (5) Underlying asset 2 (8) Underlying asset 3 (7) Underlying asset 20 (5) Underlying asset 4 (10) Underlying asset pool 5*10%= 0.5 8*10%= 0.8 7*10%= 0.7 10*10%= 1.0 5*10%= 0.5 Large Exposure Computation » If look though applied, the exposure value of the fund underlying shall be measured as pro rata share that the bank holds in the structure multiplied by the value of the underlying asset in the structure
  19. Single Counterparty Credit Limit (SCCL) 31 Value of specific exposure

    – Securitization » If look though applied, the exposure value of the securitization underlying shall be measured as Bank’s investment (20) Pro rata share = 20/100 = 20% U. asset 1 (5) U. asset 2 (8) U. asset 3 (7) U. asset 20 (5) U. asset 4 (10) Underlying asset pool Mez Tranche 200 Sen Tranche 100 Eqt Tranche 300 Securitization Program Bank’s investment (30) Pro rata share = 30/200 = 15% Min(5,100)*20%= 1 Min(7,100)*20%= 1.4 Min(10,100)*20%= 2 Min(5,100)*20%= 1 Large Exposure Computation Min(8,100)*20%= 1.6 U. asset 1 (5) U. asset 2 (8) U. asset 3 (7) U. asset 20 (5) U. asset 4 (10) Underlying asset pool (same) Min(5,200)*15%= 0.75 Min(7,200)*15%= 1.05 Min(10,200)*15%= 1.5 Min(5,200)*15%= 0.75 Large Exposure Computation Min(8,200)*15%= 1.2
  20. Single Counterparty Credit Limit (SCCL) 32 Assignment of structure counterparty

    Look Through the structure and compare the exposure amount of each underlying asset with 0.25% of Tier1 Capital. If exposure amount of asset >= 0.25% of Tier1 Capital, then counterparty will be the counterparty of the underlying. Else if exposure amount of asset < 0.25% of Tier1 Capital, then counterparty will be the structure itself. If unable to perform look through, then compare the total amount of structure exposure with 0.25% of Tier1. If total amount of structure exposure >= 0.25% of Tier1 Capital, then counterparty will be assign to ‘UNKNOWN_CLIENT’. Else if total amount of structure exposure < 0.25% of Tier1 capital, then counterparty will be the structure itself.
  21. Single Counterparty Credit Limit (SCCL) 33 Process flow for SCCL

    Regulatory capital Banking Book Regulatory capital Trading Book Imported Risk Results Entity Links Data Layer Exposure Results Counterparty Grouping Results Before Risk Transfer Results Final SCCL Results Concentration Risk
  22. Single Counterparty Credit Limit (SCCL) 43 What are we trying

    to achieve? Rgc Credit Risk EAD SCCL / LE EC … Other Aggregation Limits Limits management Dashboard / Reporting Alerts Calculations Limits Monitoring “Transaction” Monitoring Pre-deal impact analysis Transaction Real time alerts
  23. Single Counterparty Credit Limit (SCCL) 45 1 Ability to handle

    complex instruments Including capital markets instruments, e.g. derivatives, as well as SFTs. Need to treat securitization positions with a weighted look through (only for FBO > $250B in the US). 2 Risk transfer to the collateral issuers The collateral has to be used to mitigate the EAD and transfer to the collateral issuer. The netting advantage needs to be split back to the collateral issuer. 3 Ability to handle economic links on top of ownership links Some scenarios with bilateral economic links can lead to a circular loop. Key elements to consider for SCCL 4 Out of the box rules for both calculation and reporting Given the tight timeline, it is key to have a solution that is turnkey vs implementation oriented.
  24. Single Counterparty Credit Limit (SCCL) 46 1 Common data referential

    for multiple topics The same ownership data can be shared for many other initiatives, such as KYC or … 2 Support for all local regulations of BCBS 283 Despite some differences, SCCL is part of the BCBS 283 Large Exposures framework and a solution should be able to tackle all national discretions and disclosures 3 Regulatory limits are only one type of limits monitoring The solution should be able to go beyond the regulatory limits and either apply “internal” limits to regulatory metrics or monitor internal metrics in order to drive the business decisions And beyond
  25. Single Counterparty Credit Limit (SCCL) 48 © 2018 Moody’s Corporation,

    Moody’s Investors Service, Inc., Moody’s Analytics, Inc. and/or their licensors and affiliates (collectively, “MOODY’S”). All rights reserved. CREDIT RATINGS ISSUED BY MOODY'S INVESTORS SERVICE, INC. AND ITS RATINGS AFFILIATES (“MIS”) ARE MOODY’S CURRENT OPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKE SECURITIES, AND MOODY’S PUBLICATIONS MAY INCLUDE MOODY’S CURRENT OPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKE SECURITIES. MOODY’S DEFINES CREDIT RISK AS THE RISK THAT AN ENTITY MAY NOT MEET ITS CONTRACTUAL, FINANCIAL OBLIGATIONS AS THEY COME DUE AND ANY ESTIMATED FINANCIAL LOSS IN THE EVENT OF DEFAULT. CREDIT RATINGS DO NOT ADDRESS ANY OTHER RISK, INCLUDING BUT NOT LIMITED TO: LIQUIDITY RISK, MARKET VALUE RISK, OR PRICE VOLATILITY. CREDIT RATINGS AND MOODY’S OPINIONS INCLUDED IN MOODY’S PUBLICATIONS ARE NOT STATEMENTS OF CURRENT OR HISTORICAL FACT. 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