Derivatives Exposure: Adjusting Notional Amounts

Our previous post gave the best account we could of what the SEC staff has said about calculating the "gross notional amount" of derivatives transactions. In this post, we examine three adjustments that a fund may (but is not required to) make when calculating its "derivatives exposure." Specifically, a fund may:

• exclude any closed-out positions;
• delta adjust the notional amounts of options contracts; and
• convert the notional amount of interest rate derivatives to 10-year bond equivalents.

We anticipate that a fund seeking to qualify as a "limited derivatives user" would make these adjustments to lower its derivatives exposure.

Closed-Out Positions

The definition of derivatives exposure provides that a closed-out position must: