Prof. B.B.Bhattacharyya
Minimum Capital
Should be enough to absorb maximum losses 1996 amendment to include market risk
Basel I Capital
Minimum Capital Ratio (8%) * (Credit Risk + Market Risk)
Basel II Capital
Minimum Capital Ratio (8%) * (Credit Risk + Market Risk + Operational Risk)
IRB Approach
Banks internal assessment of the risk parameters serve as primary inputs to capital calculation.
IRB
1) P.D. Likelihood that the borrower will default over a given time period. 2) L.G.D. Proportion of the exposure that will be lost, should default occurs 3) E.A.D. Amount likely to be drawn in the event of a default 4) M Residual Maturity of the exposure
Operational Risk BIA 15% of average gross income over three years
Principle 2 :- Supervisors should review and evaluate the banks internal capital adequacy assessments and strategies. Principle 3 :- Supervisors should expect banks to operate above the minimum regulatory capital ratios and should have the ability to require the banks to hold capital in excess of the minimum. Principle 4 :- Supervisors should seek to intervene at an early stage to prevent capital from falling below the minimum levels.
Classification of exposure
No specific recommendation
Specific guidelines provided Disclosure requirements pertaining to risk information made more stringent
Overall parameters specified Detailed implementation schedule to be stipulated for each bank
Implementation approach
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16
Basel II Framework
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Credit Risk
Market Risk
Operational Risk
Standardized Approach
Standardized
Advanced Measurement
Foundation
6/26/2013
Advanced
Specific Risk
Other Risks
Business Strategy Risk Environment Risk Group Risk Control Risk Liquidity Risk Reputation Risk
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19
AAA
AA
Unrated
Risk weight
20%
50%
100%
100%
Risk weights for exposure to retail exposures Secured by mortgages on residential property linked to loan to value ratio (LTV)
LTV of less than or equal to 80% Risk weight of 75% LTV of more than 80% - Risk weight of 100% Other retail exposures 75%
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Risk Sensitivity
IT infrastructure Communication gap Cross Border Issues for Foreign Banks
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ICAAP and SREP are the two important components of Pillar 2. The ICAAP comprises a banks procedure and measures designed to ensure the following :(a) An appropriate identification and measurement of risks. (b) An appropriate level of internal capital in relation to the banks risk profile. (c) Application and further development of suitable risk management systems in the bank.
Constituents Of Capital
Tier I Capital Tier II Capital Tier III Capital
Tier I Capital
Consists of superior quality instruments and is the mainstay of the capital of a bank. Innovative instruments like perpetual debt can also form a part of Tier I capital.
Tier II Capital
Consists of revaluation reserves, general reserves, hybrid debt capital and subordinated term debt and investment reserve. It can be considered for purposes of capital adequacy only upto an amount equal to the Tier I capital of a bank.
loan-loss
loan-loss
General Market risk defined as the risk of loss caused by an adverse market movement unrelated to any specific security or issuer. Both general market and specific risks cause changes in the market price of an instruments.
BASEL III
BASEL III requirements will be phased in gradually from 1 January 2013. Liquidity Coverage Ratio (LCR)
Stock of high quality liquid assets = > 100% Net Cash Outflows over a 30-day period
= > 100%
MIN TIER 1 CAPITAL MIN TOTAL CAPITAL MIN TOTAL CAPITAL PLUS CAPITAL CONVERSIO N BUFFER
4.5% 5.5% 6.0% 6.0% 8.0% 8.0% 8.0% 8.0% 8.0% 8.0% 8.0% 8.625 %
6.0% 8.0%
6.0% 8.0%
9.875% 10.5%
BASEL - III
A set and reform measures developed by BCBS to strengthen the regulation, supervision and risk management of banking sector. The measures focus on : - improving ability of the Banking sector to absorb shocks arising from financial and economic stress. - improve risk management and governance - strengthen transparency and disclosures of banks -Micro prudential and macro prudential supervision.
BASEL - III
Seeks to address four key aspects identified as the main cause of global crisis. - Quality and composition of capital (Enhancing Tier I capital requirement and introduction of capital buffers, strict definition of capital). - Liquidity crunch due to borrowing short and lending long (Introduction of ratios to stress testing of a financial institutions ability to withstand liquidity pressures).
BASEL - III
Balance sheet leveraging (Introduction of Leverage ratios to improve balance sheet structure). Inconsistencies in Accounting and valuation practices (Computation of capital charges based on covered international accounting standards).
Distribution by Category - Policies related to such limitations should allow for deviations that are approved by the board. Type of Loans - A lending policy should specify the types of loans and other credit instruments that the bank intends to offer to clients and should provide guidelines for specific loans.
Maturities - A lending policy should establish the maximum maturity for each type of credit, and loans should be granted with a realistic repayment schedule. Loan pricing - Rates on various loan types must be sufficient to cover the costs of funds, loan supervision, administration (including general overhead), and probable losses. At the same time, they should provide a reasonable margin of profit.
Lending authority determined by the size of a bank. Appraisal process - A lending policy should outline where the responsibility for appraisals lies and should define standard appraisal procedures. Maximum ratio of loan amount to the market value of pledged securities - A lending policy should set forth margin requirements for all types of securities which are accepted as collateral.
Impairment - A bank should identify and recognize the impairment of a loan or a collectively assessed group of loans. Collections - A lending policy should define delinquent obligations of all types and specify the appropriate reports to be submitted to the board. Financial information - The safe extension of credit depends on complete and accurate information regarding every detail of the borrowers credit standing.
Lending process review - The integrity and credibility of the lending process depend on objective credit decisions that ensure an acceptable risk level in relation to the expected return. Human resources analysis - Staff organization, skills, and qualifications should be analyzed. Information flows - A bank must have efficient systems for monitoring adherence to established guidelines.
Interbank Deposits - The most important category of assets for which a bank carries the credit risk. Off-balance-sheet commitments
Public-disclosure requirements - Disclosure principles related to sound credit risk should be mandated by regulatory authorities as recommended by the Basel Committee on Bank Supervision.
Related-party lending - Lending to connected parties is viewed adversely towards credit risk exposure. It includes banks parent, major shareholders, subsidiaries, affiliate companies, directors and executive officers. Overexposure to geographical areas or economic sectors - Another dimension of risk concentration is the exposure of a bank to a single sector of the economy or a narrow geographical region.
Renegotiated Debt - This refers to loans that have been restructured to provide a reduction of either interest or principal payments because of the borrowers deteriorated financial position.
7. Asset Classification
Asset classification is a process whereby an asset is assigned a credit risk grade, which is determined by the likelihood that debt obligations will be serviced and debt liquidated according to contract terms. All assets for which a bank is taking a risk should be classified. It is a key risk management tool. Assets are classified at the time of origination and then reviewed and reclassified as necessary
Foreign currencies aspects . - The liquidity strategy for each currency, should be a central concern of the bank. - A bank should have a management system for its liquidity positions in all major currencies in which it is active.
Financial market borrowing - The marginal cost of liquidity is of paramount importance in evaluating the sources of liquidity.
Liquidity risk management involve various scenarios : - The going-concern scenario : This is ordinarily applied to the management of a banks use of deposits. - A second scenario relates to a banks liquidity in a crisis situation when a significant part of its liabilities can not be rolled over or replaced. - A third scenario refers to general market crisis, wherein liquidity is affected in the entire banking system.
If a bank purchases liabilities to support assets that are already on its books, the high cost of purchased funds may result in a negative yield spread. When national monetary tightness occurs, interest rate discrimination may develop, making the cost of purchased funds prohibitive to all but a limited number of large banks. Preoccupation with lowest possible cost and with insufficient regard to maturity distribution can greatly intensify a banks exposure to the risk of interest rate fluctuations.
Volatility Volatility prevails in mature markets, though it is much higher in new or illiquid markets.
Proprietary trading versus stable investment portfolio management liquidity
Proprietary trading is aimed at exploiting market opportunities with leveraged funding whereas the stable liquidity investment portfolio is held and traded as a buffer. Both the investment portfolios are subject to market risk.
Value at risk (VAR) VAR is a modeling technique that typically measures a banks aggregate market risk exposure. The risks covered by the model should include all interest, currency, equity and commodity for both on-and-off balance sheet positions. The VAR amount may be calculated by using the following methodologies: - Historical simulation approach - Delta-normal or variance/covariance - Monte Carlo simulation Risk capital The Basel Committee amended the 1988 Capital Accord in January 1996 by adding specific capital charges for market risk.
Position limits:- A market risk management policy should provide for limits on positions, bearing in mind the liquidity risk that could arise on execution of unrealized transactions. Such position limits should be related to the capital available to cover market risk. Stop-loss provisions:- The stop-loss exposure limit should be determined with regard to a banks capital structure and earning trends, as well as to its overall risk profile.
Limits to new market presence:- Limits related to a new market presence should be frequently reviewed and adjusted. Once a market becomes established and sufficiently liquid, a bank should readjust the limits to levels applicable to mature markets.
Commodity risk - refers to holding or taking positions in exchange-traded commodities, futures, and other derivatives.
another operational aspect of this risk relates to delivery risk and the necessity to close out positions before delivery.
Stress Testing
The purpose of stress testing is to identify events or influences that may result in a loss. It should be both qualitative and quantitative in nature. The stress test scenarios and the testing results normally are subject to supervisory attention. The complexity of stress tests normally reflects the complexities of a banks market risk exposures and respective market environments. It is virtually impossible to develop a standard stress test scenario that has a consistent impact on all banks.
Repricing risk The most common type of interest rate risk arises from timing differences in the maturity of fixed rates and the repricing of the floating rates of bank assets, liabilities, and off-balancesheet positions. Yield curve risk Yield curve risk materializes when yield curve shifts adversely affect a banks income or underlying economic value.
Basic risk - Also described as Spread risk. - It arises when assets and liabilities are priced off different yield curves and the spread between these curves shifts. - It derives from unexpected change in the spread between the two index rates. Optionality An important source of interest rate risk stems from the options embedded in many bank assets and liabilities or they may be embedded within otherwise standard instruments.
Assessing interest rate risk exposure Since interest rate risk can have adverse effects on both a banks earnings and its economic value, two separate but complementary approaches exist for assessing risk exposure.
A banks risk monitoring and control functions should be sufficiently independent from its risk-taking functions. Bank should have an adequate system of internal controls to oversee the interest rate risk management process. The design of the system of limits should ensure that positions which exceed assigned limits are promptly addressed by management.
Repricing gap model - Repricing gap is a static measure and does not give the complete picture.
Repricing gap models nonetheless are a useful starting point for the assessment of interest rate exposure.
Currency risk comprises the following : - Transaction risk - Economic or business risk - Revaluation risk or translation risk
There are other types of risks also which accompany currency risk are : counterparty risk, settlement risk, liquidity risk and currencyrelated interest rate risk.
Risk exposure limit - Banks should have written policies to govern their activities in foreign currencies and to limit their exposure to currency risk. Limits may be applicable in various timeframes depending on the dynamics of the particular activity.
The net open position limit - It is an aggregate limit of a banks currency risk exposure.
It normally represents a proxy for the maximum loss that a bank might incur due to currency risk. The prudential limit to the net open position is frequently set at 10 15% of a banks qualifying capital.
Currency position limits - It can apply to balance sheet revaluation points, overnight positions, or intraday positions.
- It can be adjusted on a case-by-case basis depending on the banks expectations of shifts in the exchange rate between the domestic and foreign currency.
Other position limits - If engaged in currency dealings, a bank should normally maintain limits on spot positions in each currency. - If a bank is engaged in business with derivatives, it should establish limits on the size of mismatches in the foreign exchange book. - These limits are expressed as the maximum aggregate value of all contracts that may be outstanding for a particular maturity.
Stop loss provisions It should be determined based on a banks overall risk profile, capital structure and earning trends. When losses reach their respective stop-loss limits, open positions should automatically be covered. Concentration limit High concentration always increases risk. Therefore, banks should establish limits on the maximum face value of a contract.
Settlement risk - While settlement risk can be mitigated by a request for collateral, a bank should also establish specific limits on exposure to settlement risk. These limits should be related to the total outstanding amount and subject to settlement risk on any given day.
Counterparty risk - All transactions involving foreign contracts or currency receivables also involve counterparty risk. - Such risk may be due to circumstances in the country in which the counterparty conducts business. - This risk is particularly pronounced in countries that lack external convertibility and where the government imposes restrictions on access to the foreign exchange market.
Revaluation (or Translation) Revaluation is essentially the same as marking to market, except that it pertains to changes in the domestic currency value of assets, liabilities and off-balance sheet instruments that are denominated in foreign currencies. It is an important risk management tool.
Liquidity risk concerns Currency risk management should incorporate an additional liquidity risk-related aspect. Foreign currency transactions may introduce cash flow imbalances and may require the management of foreign currency liquidity.
The accounting treatment Accounting treatment may vary among countries, depending on the purpose of revaluation. An analyst should be familiar with the rules applicable on the accounting treatment of gains or losses arising from currency risk. The analyst should also be familiar with the accounting rules used by a bank under review for risk and internal management reporting purposes.
Recognition of the increased risk and of the needed technical skills associated with the foreign exchange business has prompted regulators in almost all countries that do not maintain external convertibility to introduce two types of bank licenses. Banks averse to risk may avoid dealing in forward contracts altogether and instead engage in currency swaps. A currency swap avoids a net open currency position but still has to be marked to market. In a dynamic trading environment it is virtually impossible for a bank active in currency markets to maintain covered positions in all currencies at all times.
Currency risk exposure implies certain capital charges which are added to the charge calculated for market risk. According to various countries, the net open foreign currency position established by bank should not exceed 10 15% of qualifying capital and reserves. By using shorthand method, capital adequacy is calculated as 8% of the overall net open position. Adequate procedures and internal controls should be in place for all other key functions related to foreign exchange operations.
Line management should be responsible for overseeing foreign currency transactions and ensuring compliance with risk limits. A bank with a high volume of foreign exchange operations must have proper information support if it is to develop strategies for trading operations and executing specific transactions.
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