Before revision:  SA-CCR has major issues including: lack of self-consistency for linear trades; lack of appropriate risk sensitivity (zero positions can have material add-ons; moneyness is ignored); dependence on economically-equivalent confirmations. We show that SA-CCR is, by parameter identification and re-construction, based on a 3-factor Gaussian Market Model.
After revision:  SA-CCR to RSA-CCR: making SA-CCR is, by parameter identification and re-construction, based on a 3-factor Gaussian Market Model.