What is the margin period of risk, and how does it affect collateral haircuts and exposure calculations?
I'm reviewing FRM Part II counterparty risk and the margin period of risk (MPOR) keeps appearing. I understand it's the time between a counterparty's last margin payment and portfolio closeout, but I'm unclear on how it varies by trade type and why regulators require different assumptions for bilateral vs. cleared trades.
The margin period of risk (MPOR) is the assumed time interval between a counterparty's last variation margin payment and the complete liquidation or replacement of the portfolio following a default. It directly scales the potential future exposure (PFE) component and determines how large collateral haircuts must be.\n\nWhy MPOR Matters:\n\nDuring the MPOR, market prices can move adversely while no new margin is received. A longer MPOR means more potential exposure, requiring:\n- Higher PFE in capital calculations\n- Larger haircuts on collateral (collateral values can also deteriorate)\n- More conservative initial margin requirements\n\nRegulatory MPOR Assumptions:\n\n| Context | MPOR | Rationale |\n|---|---|---|\n| Bilateral OTC (< 5,000 trades) | 10 business days | Standard closeout period |\n| Bilateral OTC (>= 5,000 trades) | 20 business days | Complex portfolios take longer to unwind |\n| Centrally cleared | 5 business days | CCP has standardized closeout procedures |\n| Disputed margin (bilateral) | 20 business days | Disputes delay margin collection |\n| Illiquid trades (bilateral) | 20 business days | Hard-to-replace positions extend closeout |\n\nHaircut Scaling:\n\nCollateral haircuts scale with the square root of the MPOR. If the base haircut for a 10-day MPOR is H_10, the adjusted haircut for a different MPOR is:\n\nH_MPOR = H_10 x sqrt(MPOR / 10)\n\nWorked Example:\nRedwood Capital holds $50 million in investment-grade corporate bonds as collateral against a bilateral derivative portfolio. The base 10-day haircut for IG corporates is 6%.\n\nScenario A -- Standard bilateral (MPOR = 10 days):\nHaircut = 6% x sqrt(10/10) = 6.00%\nUsable collateral: $50M x (1 - 0.06) = $47.0 million\n\nScenario B -- Large portfolio (MPOR = 20 days):\nHaircut = 6% x sqrt(20/10) = 6% x 1.4142 = 8.49%\nUsable collateral: $50M x (1 - 0.0849) = $45.755 million\n\nScenario C -- Cleared through CCP (MPOR = 5 days):\nHaircut = 6% x sqrt(5/10) = 6% x 0.7071 = 4.24%\nUsable collateral: $50M x (1 - 0.0424) = $47.88 million\n\nImpact on Capital:\nThe difference between Scenario A and B reduces effective collateral by $1.245 million. For a bank with thousands of netting sets, this aggregates into materially higher capital requirements.\n\nKey Exam Points:\n- MPOR is a floor, not an estimate -- actual closeout may be faster or slower\n- During the 2008 crisis, some Lehman portfolios took months to unwind, far exceeding any assumed MPOR\n- The 5,000-trade threshold for the 20-day MPOR incentivizes portfolio compression\n- Wrong-way risk (counterparty default correlated with adverse market moves) makes MPOR assumptions more critical\n\nPractice MPOR calculations in our FRM Part II question bank.
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