SHARC: SHAP-Based Interpretability in Machine Learning Risk Models for Regulatory Capital under ICAAP and CCAR

Abstract

The adoption of non-parametric machine learning models for regulatory capital estimation introduces a fundamental governance challenge: the inability to explain model outputs in a manner auditable by supervisory bodies. This 'black box' problem remains a major barrier to the adoption of Gaussian Process Regression (GPR) and related ML architectures in ICAAP and CCAR workflows despite their predictive advantages over traditional parametric approaches. This paper addresses this barrier through SHARC (SHAP for Regulatory Capital), an explainability framework for the Hybrid GPR-HS architecture and its stress-testing extension. SHapley Additive exPlanations (SHAP), derived from cooperative game theory and satisfying the properties of Local Accuracy, Missingness, Consistency, and Efficiency, are applied to Stressed Value-at-Risk (SVaR) outputs under three macro scenarios: West Asia War, Climate Risk, and AI Bubble/Regulatory Burden. SHARC decomposes SVaR into baseline, mean-driven, and volatility-driven components, enabling transparent linkage between scenario design and capital outcomes. Two findings emerge. First, SHARC consistently links non-linear SVaR outputs to underlying scenario inputs, confirming framework fidelity and providing auditable traceability of capital drivers. Second, under stress conditions, the mean return component (directional loss magnitude) dominates the variance component (volatility baseline) in determining capital levels, with implications for capital limit-setting, position management, and hedging strategy. The results establish SHARC as a regulator-aligned explainability layer that makes the Hybrid GPR-HS framework fully auditable and consistent with FRTB, ICAAP Pillar 2, and CCAR transparency requirements.