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// WORKED EXAMPLETHE ARITHMETIC A DECISION RESTS ON

Wrong-Way Risk: a Worked Example

The swap pays off for the bank in exactly the wrong year.

BY MICHAEL SHANG · SIXTEEN YEARS IN COMMERCIAL BANKING · UPDATED

// THE SHORT ANSWER

Wrong-way risk is what a lender has when the claim it holds on a customer gets larger in the same conditions that make the customer less able to pay it. The usual place a commercial lender finds it is a hedge: a pay-fixed interest rate swap whose value swings in the bank's favour when rates are cut, often because the economy has turned against the borrower. It also sits in security and support whose value depends on the borrower's own fortunes. The question it asks of a file is when the exposure would peak, not only how large it could become.

BASIS  Practitioner judgment from sixteen years in commercial banking, set out in How Bankers Think (Highbank Press, 2026). Every borrower on this site is a composite constructed for teaching, not a client. The market is mid-market commercial lending as practised in New Zealand and Australia; where a convention differs elsewhere, the page says so.

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// 01 — WHY TIMING MATTERS MORE THAN SIZE

A loan's exposure is known: the balance drawn, plus whatever headroom the borrower can still draw. A derivative's exposure is not. It depends on where markets go, so a bank measures it as a range of future values, the potential future exposure that a derivative credit limit is sized on. That range is usually built as if the market and the customer were unrelated. Wrong-way risk is the case where they are not, and the high end of the range arrives in the same months that the customer's probability of default rises.

The literature separates two kinds. General wrong-way risk comes from the economy: a market factor such as interest rates, a currency or a commodity price moves in a way that both enlarges the exposure and weakens the customer. Specific wrong-way risk comes from the transaction itself, where the structure ties the exposure to the customer's own credit, such as protection bought from a company on its own group or collateral issued by the borrower. The UK's capital rules name both in article 291 of the retained Capital Requirements Regulation, in the part written for banks that model their derivative exposures, and require them to be identified, stress-tested and reported to senior management.

// 02 — HOW IT IS FOUND AND MEASURED

There is no single formula. Banks with models compare the exposure they expect in scenarios where the counterparty is close to default with the exposure they expect on average, and treat a large gap as the warning. The standardised measures have no such step. Australia's counterparty credit standard, APS 180, has no internal-model route: banks measure derivative exposure with the standardised approach (SA-CCR) or, where not approved to use it, an adjusted current exposure method, both built from fixed supervisory factors that do not change with the counterparty's own credit, and the standard does not use the term. For a mid-market lender the work is therefore mostly judgement, and it starts with three questions.

1. What moves this exposure? the market factor
2. What does that factor do to the revenue, costs, asset values
customer's business?
3. Do the two move in the same wrong-way if yes,
direction at the same time? right-way if opposite

The same reading applies to support. A guarantee, a pledge or a piece of collateral reduces risk only if it holds its value when the borrower does not. UK capital rules make the point for financial collateral: the obligor's credit and the collateral's value must not have a material positive correlation, and securities issued by the obligor or a related group company are not eligible, outside a narrow exception for its own covered bonds posted in a repurchase transaction.

// 03 — THE EXAMPLE

A scaffolding hire business, constructed for this page like every figure in it, borrows US$12m on a five-year floating-rate term loan and fixes the rate with a pay-fixed swap at 4.40% on the full amount. Its earnings follow building activity. A year later construction has slowed, the central bank has cut, and the swap rate for the four years left has fallen to 2.40%. The rates and the business's figures are the example's, and the swap is valued with annual payments for simplicity.

Swap owed to the bank: 12,000,000 × (4.40% − 2.40%) × 3.771
= 905,000
(3.771 = value of 1 a year for 4 years at 2.40%)
at signing a year into the slowdown
Term loan 12.0m 12.0m
Swap owed to the bank 0 0.9m
Owed to the bank 12.0m 12.9m
EBITDA 4.8m 3.0m
Owed ÷ EBITDA 2.5× 4.3×
Hire fleet, resale 9.0m 6.5m

Every line moved against the bank at once. The swap did its job for the borrower's interest cost, but it took away the relief that falling rates would otherwise have given, and it added a liability of US$0.9m that would be payable in full if the swap were closed out on a default. Meanwhile the earnings and the resale value of the security fell for the same reason the rates did. A limit sized on the swap alone, without asking what the business would look like when the swap was worth most, would have read this as a hedge working as intended.

The business's sister company, which makes formwork for the same builders, had guaranteed the loan. In the year the bank might need it, its order book was falling too.

// 04 — HOW IT DIFFERS FROM RIGHT-WAY RISK

Right-way risk is the opposite pairing: the exposure shrinks as the customer weakens. A hedge of the business's own trading risk tends to work this way. An importer that buys foreign currency forward is hurt when its home currency falls, but in that case the forward is worth money to the importer, so the bank's claim on it falls just as its costs rise. An exporter that sells currency forward is the mirror image. The scaffolding swap differs because the rate cut is a symptom of the downturn, so the hedge pays the bank in the year the customer is weakest.

It also differs from connected exposure and concentration. Those ask whether several exposures will fail together; wrong-way risk asks whether one exposure grows as its counterparty fails. A file can show both, as the sister-company guarantee does.

DEFINED IN ONE PARAGRAPH → · SWAP MARK-TO-MARKET → · DERIVATIVE CREDIT LIMIT →

// 05 — WHERE IT DECIDES A FILE

The first place is the derivative limit. A credit officer who sees wrong-way risk in a hedge can size the limit on a stressed scenario in which the borrower is also weak, shorten the tenor, or hedge less than the full loan, which is one reason a bank's hedging policy and the borrower's hedge ratio are read together. The second is the security. Facility documents commonly make the swap obligations secured money ranking with the loan, so that a close-out amount does not fall outside the security when it is largest.

The third is support. A guarantee from a company in the same group or the same market, or a share pledge over the borrower's own group, is counted for what it would be worth on the day it is called, and in a wrong-way file that is less than its value today. The borrower's side of the reading is in the interest rate swap guide: the break cost that makes a swap expensive to leave is the same amount the bank is owed.

HOW BANKS MANAGE CREDIT RISK → · INTEREST RATE SWAP, DEFINED →

// SOURCES

The documents the statements on this page rest on. Each was opened and checked when cited.

  1. Regulation (EU) No 575/2013 as retained in UK law (UK CRR), article 291 — wrong-way risk — Defines general and specific wrong-way risk and requires firms to identify, stress-test, monitor and report them, with separate treatment where a legal connection exists — section 01 and the FAQ.
  2. Regulation (EU) No 575/2013 as retained in UK law (UK CRR), article 207(2) — requirements for financial collateral — Requires that the obligor's credit quality and the collateral's value have no material positive correlation, and excludes securities issued by the obligor or a related group entity, save the obligor's own covered bonds posted in a repurchase transaction — section 02.
  3. Australian Prudential Regulation Authority, Prudential Standard APS 180 Capital Adequacy: Counterparty Credit Risk — Sets derivative exposure under SA-CCR for IRB banks, and under an adjusted current exposure method for standardised banks unless APRA approves SA-CCR, with supervisory factors that do not vary with the counterparty's own credit quality; the standard does not use the term wrong-way risk — section 02.

// QUESTIONS PEOPLE ASK

What is the difference between general and specific wrong-way risk?
General wrong-way risk comes from the wider economy: a market factor such as rates, a currency or a commodity price moves in a way that both increases the exposure and weakens the counterparty, as when rate cuts arrive with a downturn. Specific wrong-way risk comes from the structure of the deal, where the exposure is tied to the counterparty's own credit, such as collateral issued by the borrower or protection sold by a company on its own group. UK rules give specific wrong-way risk with a legal connection its own capital treatment.
What is right-way risk?
It is the favourable pairing: the bank's exposure to a customer falls in the conditions that weaken the customer. A business hedging its own trading risk often creates it. An importer buying currency forward is hurt when its home currency weakens, but that same move makes the forward valuable to the importer and reduces what it owes the bank. Right-way risk is not a reason to relax, since the hedge can still be large in other scenarios, but it changes which scenario the limit is sized for.
Is an interest rate swap wrong-way risk for a bank?
Not by itself. A pay-fixed swap creates exposure to the borrower when rates fall, and whether that is wrong-way depends on the business. For a firm whose trade weakens in the downturns that bring rate cuts, such as one tied to construction or consumer spending, it is. For a firm whose earnings are steady through the cycle, or that benefits from conditions that bring rates down, the correlation is weaker. The bank's job is to ask which kind of business it is hedging.
How do banks manage wrong-way risk?
By stressing exposure in scenarios where the counterparty is also under strain, setting tighter limits or shorter tenors where the link is strong, securing derivative obligations alongside the loan, and discounting support whose value depends on the borrower's own fortunes. Margin collateral keeps pace with an exposure that drifts upward, less so with one that leaps when the counterparty fails. Banks that model counterparty exposure also report wrong-way positions to senior management, which UK rules require of firms within article 291.

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