涉及巴III(BCBS188)的第35-37三段(附后)。35段很简单,对36和37段,我的理解说了两层意思:
1、要注意30日内一级、二级资产的调整。比如银行用某普通公司股票(非一级资产)做抵押(担保)funding到1million现金(一级资产),但这个担保合约将在20天后到期,也就是说,20天后这1 million现金将不复存在,所以要从一级资产中扣减。二级资产同理。
2、一级、二级资产都扣减以后,剩余的二级资产在全部优质流动性资产中的占比仍然不能超过40%。36段中的“ The maximum amount……”一句,说的更通俗一些就是调整后的二级资产的最多不能超过调整后一级资产的2/3,简单计算即可得到,这句话等同于说调整后的二级资产不能超过全部的40%。
所以,这两段实际上是对第35段的补充、深化。35段提出了40%的问题,36和37段详细解释了计算40%时需要注意的调整事项。
不知道以上理解是否正确?欢迎各位高手指导。谢谢。
35. There are two categories of assets that can be included in the stock. Assets to be included in each category are those that the bank is holding on the first day of the stress period. “Level 1” assets can be included without limit, while “Level 2” assets can only comprise up to 40% of the stock.
36. The calculation of the 40% cap should take into account the impact on the amounts held in cash or other Level 1 or Level 2 assets caused by secured funding transactions (or collateral swaps) maturing within 30 calendar days undertaken with any non-Level 1 assets. The maximum amount of adjusted Level 2 assets in the stock of high-quality liquid assets is equal to two-thirds of the adjusted amount of Level 1 assets after haircuts have been applied.
37. The adjusted amount of Level 1 assets is defined as the amount of Level 1 assets that would result if all short term secured funding, secured lending and collateral swap transactions involving the exchange of any Level 1 assets for any non-Level 1 assets, were unwound. The adjusted amount of Level 2 assets is defined as the amount of Level 2 assets that would result if all short term secured funding, secured lending and collateral swap transactions involving the exchange of any Level 2 assets for any non-Level 2 assets, were unwound, and includes cash or other Level 1 assets. In this context, short term transactions are transactions with a maturity date up to and including 30 calendar days. As outlined below, relevant haircuts would be applied prior to calculation of the cap.