Before revision:  We show that SA-CCR is, by parameter identification and re-construction, based on a 3-factor Gaussian Market Model. Hence we propose a Revised SA-CCR (RSA-CCR) based on cashflow decomposition and this 3-factor Gaussian Market Model . RSA-CCR is free of SA-CCR's issues, simple to use in practice, and can be extended easily given that it is model-based.
After revision:  We show that SA-CCR self-consistent and appropriately risk-sensitive by cashflow decomposition in a 3-Factor Gaussian Market Model . RSA-CCR is free of SA-CCR's issues, simple to use in practice, and can be extended easily given that it is model-based.