 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. 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. We recommend updating SA-CCR to RSA-CCR in order to resolve SA-CCR's issues of 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, and ambiguity of application for cases not explicitly described.
From SA-CCR to RSA-CCR: making SA-CCR self-consistent and appropriately risk-sensitive by cashflow decomposition in a 3-Factor Gaussian Market Model 
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From
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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
to RSA-CCR: making
R
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
self-consistent and appropriately risk-sensitive by cashflow decomposition in a 3-Factor
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. 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. We recommend updating SA-CCR to RSA-CCR in order to resolve SA-CCR's issues of 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, and ambiguity of application for cases not explicitly described.