AMLR, AMLD6 and AMLA — What Changes and What to Build
Julian R. Sterling
One Excel workbook. Chapter 16 makes three claims about the back book — that it is the
most expensive part of the transition, that it is an operational problem of contact rates and
staffing, and that assuming the longer transition and being wrong is asymmetric — and turns
none of them into a number. This file computes all three. It is free. Nothing is gated behind a
sign-up, and no email address is asked for.
The two cuts reconciled. Chapter 16 segments the back book two ways
— three components by remediation route, four tranches by priority — and never
puts them together. Reconciled on a 250,000-customer portfolio, the effort is
82,062 analyst-days, or 373 analyst-years. The three routes differ by a factor
of fifteen in throughput, from twelve files an analyst-day for a re-rating to 0.8 for an
enhanced due diligence file. That factor is why the chapter says a fortnight of segmentation
is worth it before anything else.
The asymmetry is sharper than the chapter says. Staffed for five years, the
team is 120. Staffed for one, it is 373 — a factor of 3.1. Being wrong the cheap way
— staffing for one year and finding the transition intact — costs
€21.5 million of temporary over-staffing and finishes the programme
in month twelve instead of month sixty. Being wrong the other way, at month six, requires
626 analysts against 120 in place; and because a new analyst is not productive for fourteen
weeks, the effective requirement is 1,357 — eleven times the standing team.
One branch is a number a finance director can approve. The other is not a size at all.
And there is a date the chapter does not give. Run it month by month: news at
month one needs 4.7 times the team, month five 8.6, month eight 38.2 — and at
month nine the window has closed before the first new analyst is productive.
So the trigger cannot be publication of the adopted act alone, because publication may come
later than that. It needs a dated review at month six or seven where the absence of
news is itself the signal.
Non-response is a programme, not an edge case. Three attempts at 45, 25 and
15 per cent reach 64.9 per cent cumulatively. On this portfolio that leaves
52,155 customers who never respond — 20.9 per cent of the whole book,
each needing a decision to restrict, escalate or exit. That is the volume behind the
chapter’s instruction to approve the non-response policy in advance.
The premium, priced. The chapter recommends a base plan delivering the higher
tranches well inside one year. Pulling tranche two into it costs 27.3 analysts, or
€2.32 million in year one — 22.7 per cent of the full plan’s
annual cost. That is the price of not depending on an unadopted instrument, and it is the
figure that belongs beside the sentence naming the draft standard as an assumption. A board
approves a premium it can see. Twenty-eight checks.
The_Back_Book_Sized.xlsx · XLSX · 17 KB
What to try first
Go to sheet 5 and read the last column downwards. The multiple required to recover the
one-year window is 4.7 at month one, 8.6 at month five, 38.2 at month eight — and unreachable
at month nine. That column is the chapter’s asymmetry, and it is the argument for a dated
review rather than a condition-based trigger. Then change the customer count on sheet 1:
everything is linear in portfolio size, so a different book rescales in one keystroke.
What the arithmetic does not settle
It cannot tell you whether the draft technical standard survives adoption unchanged — that is
the whole point, and it is why the chapter insists the transition be named as an assumption rather
than relied on as an entitlement. It cannot tell you your own analyst throughput or your own
response rates; those live in your operations data, and they are the first inputs to replace. And
it cannot decide what happens to a customer who never responds. It can only tell you how many of
them there will be, which is the part that gets discovered too late.
Conventions used throughout
Amber fill
an input — you may edit these
Grey fill
a formula — do not overtype these
ADDED
an input the book does not state, each labelled with the reason
Checks sheet
twenty-eight controls — three exist to make the chapter’s central claim measurable
Every figure is illustrative. The firm is invented, as every firm in the book is; the segmentation,
the tranching and the dates are the book’s own, and the throughput and response rates are
added because the chapter states none of them. Each is an editable cell, and the whole model is
linear in portfolio size.
Opening the file
The workbook opens in Microsoft Excel, LibreOffice Calc, Google Sheets and Numbers. It uses no
macros and no add-ins, so nothing needs to be enabled or trusted. If your spreadsheet asks to
update links on opening, decline — there are none.
Also by Julian R. Sterling
The other books with companion files. The full list of titles is on the
author page.
Closing the DealTwo defensible bridges 20.70 million apart, a peg worth 7.00 million, and the six choices that remove 6.60 of a 12.00 earn-out.
CMBS and CRE CLOsWhere the loss actually lands, from appraisal reduction to realised severity, and what the B-piece is really being paid for.
How to Read a Commercial LeaseThe three refinements chapter 19 names and never performs, and the renewal rate below which the mark-to-market is worth nothing.
How to Read a Credit AgreementWhere the default actually comes from, the cure that costs 5.5 times the other, and the capacity nobody adds up.
How to Read a Real Estate Loan AgreementThe cure ratio in closed form, the four-point window in which the cheap cure works, and the cure sized to the wrong threshold.
Office Real EstateA six per cent yield that returns 3.2 per cent once the re-letting cycle is paid for, and the headline-to-net-effective rent arithmetic.
Private Equity Real EstateBoth worked waterfalls to the dollar, the two capital stacks, and the arithmetic of the promote made changeable.
Private Markets PerformanceThirty-one of the thirty-three figures chapter 19 publishes reproduce exactly — and the two that do not are named rather than quietly adopted.
Raising a Real Estate FundThe chapter 17 funnel run on a calendar — when the first close actually lands, and why more travel does not help.
Real Estate FinanceFour people look at one building and reach four numbers; the lender is whole only above 105,109,489, twelve per cent below today’s value rather than forty.
Real Estate Financial ModelingProperty, development and fund models built line by line, and the modelling test worked end to end.
Real Estate Fund ManagementThe waterfall of 6.11, the build-to-core of 8.7 and the proceeds gap, reproduced as live formulas rather than asserted.
REIT Analysis and ValuationFFO of 532.0, AFFO of 381.0, net asset value and dividend safety — every figure a formula you can change.
Retail Real EstateThe occupancy cost of every unit in a centre, the sixteen per cent of the rent roll no tenant can sustain, and the right-size-convert-or-hold decision priced.
Sale and LeasebackA €179.5 million transaction end to end, with rent cover measured on the entity that actually signs the lease.
Self-Storage Real EstateThe cohort engine behind a 590-unit store, and the rate increase on existing customers priced against the move-outs it causes.
The Fund Finance ProfessionalChapter 8 builds the reported-to-eligible NAV bridge; chapter 9 computes every ratio without it. Two points at every state — and what a subscription line does to the IRR.
The Growth Equity InvestorWhat a pro rata cheque really costs, and the band where defending your ownership loses money.
The Private Credit InvestorThe two coverage ratios are not measured on the same thing: the erosion is 47.7 per cent, not the 28.7 the headline implies.
The Private Equity Fund Controller PlaybookThe book defines IRR, DPI, RVPI and TVPI, tells you to update them at the exit, and prints not one value. Computed: a 1.833× deal inside a fund at 0.892 TVPI.
The Venture Capital AssociateWhat defending a position costs, and how many companies a reserve pool actually defends.
Financial Risk ManagementA fund inside every limit that cannot meet a redemption — and the number that decides it is the one with no currency attached.
Business ValuationThree advisers land 26.8 per cent apart on one company, and the whole gap turns out to be 1.96 points of perpetual growth.
Quantitative FinanceThree models agree to a quarter of one per cent about a number that one unobservable input moves a hundred and three times as much.
Asset ManagementFour people quote four returns for one mandate, all correct and 2.7017 points apart — forty-eight times the manager’s net skill.
Alternative InvestmentsA manager reports 13.29 per cent and the endowment earns 6.26 — both correct, and only a third of the advertised advantage arrives.
Credit AnalysisFour defensible EBITDAs on one borrower give leverage from 3.19x to 6.47x — and the add-back argument is fifty times the covenant headroom.
Venture CapitalOne company out of twenty-eight returns 56.7 per cent of the fund, and half the capital goes in after the decision — at half the return.
Machine Learning for FinanceFive people quote the accuracy of one credit model, all five are right, and the number that decides how much money it makes is none of them.
Commercial Real Estate InvestingThe equity earned 8.6647 per cent and the investor received exactly 8.0000 — the preferred return, and nothing above it.
Mergers and AcquisitionsThe board paper says the deal creates 13,436,667 of value. The arithmetic says it destroys 17,530,855. Nobody is lying.
DerivativesThe treasury report says the hedge cost 1,233,698. That is the interest differential, not a cost.
Treasury ManagementFive cash balances for one company, all correct and 145,600,000 apart — and the revolver that is two-thirds of the liquidity leaves at a revenue fall of 8.4127 per cent.
Financial Planning and AnalysisRevenue 3.0190 per cent above budget and operating profit 16.3209 per cent below it, in the same quarter, with every figure correctly stated.
Energy TradingA position report that is 91.7031 per cent hedged and correctly computed, on a book that is short 2,542,000 MWh — and a margin call of 198,400,000 the next morning.
Construction Cost ControlA contract sum of 26,301,102 became a final account of 29,153,363 on the building that was drawn — and 85.8 per cent of what was lost was knowable on the day it was signed.
Pricing StrategyA list price of 148.00, a pocket price of 112.51, and the nine deductions in between — with what one point of price is actually worth.
If this book helped — or didn’t — a few lines on Amazon are worth more than they look: they are what the next reader goes on. Write a review. The workbook stays free either way.