(7) Capital Adequacy by Anujit Mitra.ppt

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    Report on Capital Adequacy

    Under Basel IIRCA 2

    First return developed on XBRL

    Anujit Mitra ([email protected])

    Department of Banking Supervision, RBI

    mailto:[email protected]:[email protected]
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    Approach for Basel II

    All commercial banks in India (excluding Local AreaBanks and Regional Rural Banks) to adopt

    Standardised Approach (SA) for credit risk

    Basic Indicator Approach (BIA) for operational risk Standardised Duration Approach (SDA) for computing

    capital requirement for market risks

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    Timeline - achieved

    Mar 31, 2008for all Foreign Banks operating in India and otherIndian Banks having operational presence outside India

    All other commercial banks (except Local Area Banks and Regional

    Rural Banks) were encouraged to migrate to these approaches underthe Revised Framework in alignment with them but in any case notlater thanMarch 31, 2009

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    Parallel Run Banks migrating to the revised framework were

    advised to have parallel run and they have been

    submitting the quarterly reports to their board and toRBI

    Detailed return for the same has been introduced inDecember 2009, this was the first return implemented

    on XBRL platform by RBI

    The same was re-launched over Internet in March2009

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    Migration to the Advancedapproaches - FlexibilityBanks, at their discretion, would have the option of

    adopting the advanced approaches for one or moreof the risk categories, as per their preparedness,

    while continuing with the simpler approaches forother risk categories

    It would not be necessary to adopt the advancedapproaches for all the risk categoriessimultaneously.

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    Presenting the systemUsers From RBI

    Administrator

    Manages Bank Master and creates Administrators forthose banks

    View system MIS reports and log

    Has full access right over all banks to view their returns

    May Reject returns submitted by the bank (s)

    Users

    Has predefined access right to view returns and generate

    reports

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    Users from BanksAdministrator

    Creates / deletes users from the banks anddefines the role of each user (maker-checker)

    Users

    Maker - Enabled to enter, modify and view databut would not be able to submit data to RBI

    Checker - Enabled to view and submit data

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    Banks view of the system

    Accessible through the ORFS page secure

    accessData Preparation

    Login

    Download Excel Template Fill in data

    Validate - debug

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    Submission of Data Create Instance Document

    XBRL instance created transparent to the user Save document

    Submit to RBI

    Encrypt with digital signature or symmetricencryption

    Print for records, if required

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    Retrieve submitted returns

    After logging in user may be able to view /download returns already submitted

    He may download the same and modifyHe may resubmit

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    Advanced approachUse the MIS to create the XML output or

    even better make use of the XBRLUpload document

    Submit to RBI

    Encrypt with digital signature orsymmetric encryption

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    Expected developments in RBIFurther versions of RCA II next one

    possibly by December 2009Working group on OSMOS re-devolopment

    Reviewing the return structures

    May suggest quick XBRL adoption for allOSMOS returns

    May suggest few new returns for Basel II

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    At RBI - Analysis of returns

    Through Standard reports

    Fixed format

    Frequently used

    Easy to generate and use Through Adhoc reports

    User to choose elements

    Downloadable to Excel for further Analysis

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    Analysis - A look at CapitalAdequacy

    Need for capitalAcceptable capital standards

    Initiatives of Basel (BCBS)

    Basel I AccordBasel II Accord

    Risk assessment under Basel II

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    Need for capitalSupports banks operations (source of funds)

    Provides cushion against unexpected losses stemming

    from credit, market and operational risks thusmaintains solvency of a bank

    Encourages depositors confidence

    Encourages shareholders interest in governance of the

    bank Regulatory comfort as bank insolvency is costly to the

    economy

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    How much capital?? Before Basel standards, regulators set minimum capital

    requirements in absolute terms or as gearing ratio.

    After Basel, capital is aligned to the quantum of riskscarried by a bank.

    Elimination of probability of bank insolvency is notpossible hence the present capital standards aim to ensurethat a bank would not be insolvent under an acceptableprobability.

    Measuring losses to quantify the level of capital

    requirement is the core issue.

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    Basel I to Basel II Weaknesses of Basel I

    One size fits all approach

    Crude method of credit risk measurement However, measurementof market risks is more scientific and aligned to reality

    Inadequate differentiation of credit risk

    Risk mitigation techniques not recognised

    No incentives for better risk management

    Not addressed all risks

    Encouraged regulatory arbitrage (securitisation and creditderivatives)

    Hence the need for Basel II

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    Basel II Accord Extensive consultative process beginning June 1999

    Rests on three mutually reinforcing Pillars

    Quantum of capital linked to riskiness of exposure

    Covers capital charge for operational risk besides credit and marketrisks

    Provides a menu of options to calculate credit risk and operational risk

    Incorporates supervisory review process to address risks not coveredunder Pillar I and allows risk based supervision

    Incentives for better risk management and control environmentthrough lesser capital requirement

    Ensures market discipline through comprehensive disclosurerequirements

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    Basel I Vs. Basel IIAll Banks CRAR(as of Mar 2009)(Amounts in Rs.Cr.) Basel I Basel II

    Tier I Capital 331,494 333,810Tier II Capital 157,143 154,016

    Total Capital 488,637 487,826

    Total RWA 3704,827 3488,303

    CRAR 13.19 13.98

    Core CRAR 8.95 9.57

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    Basel I Vs. Basel II - Foreign Banks(as of Mar 2009)(Amounts in Rs.Cr.) Basel I Basel II

    Tier I Capital 51407 51811Tier II Capital 9203 9105

    Total Capital 60609 60916

    Total RWA 403033 425327

    CRAR 15.04 14.32

    Core CRAR 12.75 12.18

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    Basel I Vs. Basel IINationalised

    Banks(as of Mar 2009)

    (Amounts in Rs.Cr.) Basel I Basel II

    Tier I Capital 191053 192268Tier II Capital 116692 114063

    Total Capital 307745 306331

    Total RWA 2498398 2271344

    CRAR 12.32 13.49

    Core CRAR 7.65 8.46

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    Basel I Vs. Basel IINPBs(as of Mar 2009)(Amounts in Rs.Cr.) Basel I Basel II

    Tier I Capital 72602 73152Tier II Capital 27944 27756

    Total Capital 100546 100908

    Total RWA 665762 658331

    CRAR 15.10 15.33

    Core CRAR 10.91 11.11

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    Basel I Vs. Basel IIOPBs(as of Mar 2009)(Amounts in Rs.Cr.) Basel I Basel II

    Tier I Capital 16360 16579Tier II Capital 3301 3092

    Total Capital 19662 19671

    Total RWA 137180 133301

    CRAR 14.33 14.76

    Core CRAR 11.93 12.44

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    Basel I Vs. Basel IIwho benefitted(as of Mar 2009) Out of the 80 banks 49 banks shown higher CRAR

    17 out of 30 foreign banks got CRAR lower under Basel II9 out of 15 Old Private Sector Banks and 2 out of 7 New

    Private Sector Banks shown higher CRAR under Basel II

    Only 6 out of 27 Nationalised Banks including SBI Group

    have shown lower CRAR

    35 banks have shown higher RWA under Basel II

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    Assessment of Capital AdequacyStandardised

    Approach

    A banks capital base is dynamic reflecting the success or otherwise ofthe banks ongoing business of managing risks through its controlenvironment

    Analysis should broadly include

    Regulatory capital and

    Risk assets on and off balance sheet

    Regulatory capital

    Level of capital adequacy ratio and trend over periods

    Quality proportion of Tier I capital to total capital and trend over periods

    Components of Tier I capital

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    Assessment of Capital Adequacy

    Standardised Approach Credit Risk Off Balance Sheet (OBS) Exposures

    Non Market related

    Trends in quantum and composition of contingent credits &

    commitments Volume of financial guarantees, undrawn committed lines of credit,

    Letter of credits

    Share in total off balance sheet exposures

    Market related (Derivatives)

    Quantum and composition

    Maturity & potential future CCF wise distribution

    Trend in potential and current exposure

    Total OBS exposures as % of total on balance sheet assets

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    Assessment of Capital Adequacy

    Capital charge for failed transactions

    Securities transactions Foreign exchange transactions

    Market Risk Exposures

    Trends in capital charge

    Specific risk for securities held in HFT and AFS General market risk for securities held in HFT & AFS

    Equity position

    Foreign exchange and gold position

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    Assessment of Capital Adequacy

    Residual maturity wise securities held in (reflect

    potential market risk exposure) HFT category

    AFS category

    Bonds of banks attracting higher capital charge due to

    adverse CRAR Operational Risk

    Trends in capital charge

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    Assessment of Capital Adequacy

    Issues

    To provide input for Supervisory Review &Evaluation Process (SREP) under Pillar II

    So deciding the trade off betweengranularity to be captured and ease ofcompilation / data management is crucial

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    Thank you !!!