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Basel III Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory Protiviti Member Firm (Middle East) May, 2014

Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

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Page 1: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

Basel III – Changes in Capital and Liquidity Regulations

Raj Parthasarathy

Managing Director & Regional Head

Financial Services Advisory

Protiviti Member Firm (Middle East)

May, 2014

Page 2: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

2 | © 2014 Global Association of Risk Professionals. All rights reserved.

Agenda

Content

1 Need for Basel III

2 Basel III - Key Reforms under Pillar 1

3 Basel III - Key Reforms under Pillar 2 and 3

4 Basel III Liquidity Standards

Page 3: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

3 | © 2014 Global Association of Risk Professionals. All rights reserved.

Need for Basel III

Section 1

Implementation Timelines

Page 4: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

4 | © 2014 Global Association of Risk Professionals. All rights reserved.

Unclear &

inconsistent

definitions

Portfolio

Invariance

Single

Global Risk Factor

Securitization

Pro-cyclicality

Subjective

Risk Inputs

Unclear & inconsistent definition of

capital

Non-application of regulatory

adjustments across jurisdictions

Prices for Over the

Counter products

Manipulation of

inputs for reducing

capital requirements

Underestimates risk in good times & overestimate in bad

times

PD, LGD & EAD tend to be point in time

Warehousing of securitization

exposures on and off-balance

sheet

One global risk factor

Non recognition of

interdependence across

exposure & geographies

Importance of diversification in Pillar 1

Credit risk capital rises linearly

regardless of exposure size

Basel II – Key Shortcomings

Page 5: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

5 | © 2014 Global Association of Risk Professionals. All rights reserved.

Shortcomings : Capital arbitrage & promise shifting

BBB rated Company

100% Risk Weighted

Bank B

20% Risk Weighted

Bank A Re-insurance Company

Outside the scope of Banking system,

thus non application of BIS capital

rules

Underwrites Risk Buys CDS on bond

Passing the promise

to redeem

Lends $1000 Sells Bond

Reducing capital requirement

Reducing the capital

requirement in the

Banking system form $80

to $ 18.6 - 70.6% fall

Increasing the leverage

from 12.5 to 53.8 in the

banking system

Transactions

Capital Requirement

Passing the promise

to redeem

Shortcomings of Basel II – Capital Arbitrage & Promise Shifting

Page 6: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

6 | © 2014 Global Association of Risk Professionals. All rights reserved.

Need for Basel III – Key reform measures post the Global Financial Crisis

Better Coverage of

Risk Exposures

▬ Trading Book

▬ Securitization

▬ Derivatives

▬ Revised RWs

Enhanced Liquidity

Buffers

▬ LCR - HQLA

▬ NSFR

▬ Monitoring Reqmts

More and Higher

Quality Capital

▬ Increased Core Cap

▬ Increased CET1 Cap

▬ Revised Filters

Additional Capital

Buffers

▬ Countercyclical Buffer

▬ Conservation Buffer

▬ SIFI Requirements

Leverage Containment

▬ Non Risk Based

Leverage Measure

▬ Integration as Pillar 1

requirement

Greater Transparency

▬ Securitization / re-

securitization

▬ Liquidity Related

▬ Off-B/s Vehicles

Stronger Risk

Management

▬ Governance Reqmt

▬ Valuations

▬ Risk Concentration

▬ Internal Controls

More focus on

Supervision

▬ Non risk based

measure / backstop

▬ Consider both on & off

balance sheet risks

Page 7: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

7 | © 2014 Global Association of Risk Professionals. All rights reserved.

Basel III Phase-in Arrangements (BIS-CBB comparison)

PHASES Time Period

2014 2015 2016 2017 2018 2019

CA

PIT

AL

Leverage Ratio

BIS Parallel run 1 Jan 2013 – 1 Jan 2017

Disclosure starts 1 Jan 2015

Migration to

Pillar 1

CBB Disclosure Migration to

Pillar 1

Minimum Common Equity Capital Ratio

BIS 4.0% 4.5% 4.5%

CBB 4.5% 4.5%

Capital Conservation Buffer

BIS 0.625% 1.25% 1.875% 2.5%

CBB 2.5% 2.5%

Minimum Total Capital plus conservation buffer

BIS 8.0% 8.625% 9.25% 9.875% 10.5%

CBB 12.5% 12.5%

LIQ

UID

ITY

Liquidity coverage ratio (LCR) minimum

requirement (CBB and BIS) 60% 70% 80% 90% 100%

Net stable funding ratio (NSFR)

Introduce

minimum

standard

(BIS)

Introduce

minimum

standard

(CBB)

Transition periods

Target state

Page 8: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

8 | © 2014 Global Association of Risk Professionals. All rights reserved.

Basel III Phase-in Arrangements (Capital Standards)

Minimum Common Equity Capital

6%

QCB

CBB 4.5%

4%

3.5%

2013 2014 2015 2016 2017 2018 2019

BIS, SAMA

Minimum Total Capital

10%

CBB QCB

SAMA BIS

2013 2014 2015 2016 2017 2018 2019

Minimum Capital Conservation Buffer

2.5% 2.5%

CBB QCB 1.875%

1.25%

0.625%

2013 2014 2015 2016 2017 2018 2019

Leverage Ratio

Parallel run 1 Jan 2013 – 1 Jan 2017

3%

2013 2014 2015 2016 2017 2018 2019

BIS, SAMA

Disclosure starts 1 Jan 2015

Migration to Pillar 1

Source:

BIS: Basel III phase-in arrangements

CBB: Basel 3 Implementation Plan, dt. 12 June 2013

QCB: Implementation instructions Basel III Framework for Conventional Banks – Pillar 1 Guidelines for Capital Adequacy

SAMA: Finalized guidance document concerning the implementation of Basel III

BIS, SAMA

Regulators across GCC have adopted capital structure and transitional arrangements for application of Basel III reforms

Page 9: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

9 | © 2014 Global Association of Risk Professionals. All rights reserved.

Basel III Phase-in Arrangements (Liquidity Standards)

Liquidity coverage ratio (LCR) minimum requirement

100%

90% BIS

80% CBB

70%

60%

2013 2014 2015 2016 2017 2018 2019

Net Stable Funding Ratio (NSFR)

BIS CBB

2013 2014 2015 2016 2017 2018 2019

Source:

BIS: Basel III phase-in arrangements

CBB: Basel 3 Implementation Plan, dt. 12 June 2013

Introduction of minimum standard

Banks will require to accommodate the minimum regulatory requirements within the stipulated timeline as

prescribed by the Central Banks

Details of implementation requirements as prescribed by CBB is highlighted in the subsequent slide

Page 10: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

10 | © 2014 Global Association of Risk Professionals. All rights reserved.

Basel III – Key Phase in arrangements by Central Bank of Bahrain

The phase-in arrangements are in-line with the advances in the region and are compared to the status of Basel III

implementation across specific geographies in the subsequent slide

Leverage

Common

Equity

Capital Ratio

NSFR

LCR

Capital

Conservation

Buffer

Total Capital

Deductions

from CET 1

– Disclosure starts 2017

– Migrate to Pillar 1 by 2018

– 4.5% from 2015

– 2.5% from 2015

– 20%-100% step-wise from 2015

to 2019

– 12.5% from 2015

– 60%-100% step-wise from

2015 to 2019

– Minimum standard to

be introduced by 2019

Page 11: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

11 | © 2014 Global Association of Risk Professionals. All rights reserved.

Basel III - Key Reforms

under Pillar 1

Section 2

Page 12: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

12 | © 2014 Global Association of Risk Professionals. All rights reserved.

Basel III – Enhanced Capital Requirements

CET 1 must be at least

4.5% of RWA at all times

Tier 1 – At least 6% of

risk weighted assets at all

time

At least 8.0% of risk

weighted assets at all

times.

TOTAL REGULATORY

CAPITAL

TIER 1 CAPITAL (Going Concern

Capital)

COMMON EQUITY

TIER 1 (CET 1)

ADDITIONAL TIER 1

TIER 2 CAPITAL (Gone Concern Capital)

• Capital Conservation Buffer (CCB) of 2.5%, comprised of

Common Equity Tier 1 (CET 1), established above regulatory

minimum capital requirement.

• Ensure that banks build up capital buffers outside periods of

stress, which can be drawn down as losses are incurred.

• Capital distribution constraints imposed when capital levels fall

within this range.

• Outside of periods of stress, banks should hold buffers of capital

above the regulatory minimum

CAPITAL CONSERVATION BUFFER

• Countercyclical Buffer of 0%-2.5%, of risk weighted assets for

international banks.

• Ensure that banking sector capital requirements take account of

the macro-financial environment in which banks operate and look

at geographic location of credit exposures.

• Calculate buffer as weighted average of requirements applied in

jurisdictions to which they have private sector credit exposures

COUNTERCYCLICAL BUFFER

Page 13: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

13 | © 2014 Global Association of Risk Professionals. All rights reserved.

Basel III – Enhanced Capital Requirements: CET1 Criteria

Common shares issued by the bank

Stock surplus (share premium)

Retained earnings

Accumulated income and disclosed reserves

Common shares issued by cons. Subsidiaries and held by third parties

Regulatory adjustments

Important Criteria for Common Equity

1 Most subordinated claim in liquidation of the bank.

2 Entitled to a claim on the residual assets

3 Principal is perpetual

4 No expectation at issuance that the instrument will be

bought back, redeemed or cancelled

5 Distributions are paid out of distributable items (retained

earnings included).

6 Non payment is not an event of default.

7 Distributions are paid only after all legal and contractual

obligations & payments on more senior capital instruments.

8 Issued capital takes the first and proportionately greatest share

of any losses as they occur

9 Paid in amount is recognized as equity capital for balance sheet

insolvency

10 Paid in amount is classifies as equity in accounting

11 Bank can not directly or indirectly fund the purchases

12 Paid in amount is neither secured nor covered by a guarantee

of the issuer or related entity

13 Only issued with the approval of the owners of the issuing bank

14 Clearly and separately disclosed on the bank’s balance sheet.

Common Equity Tier 1

Page 14: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

14 | © 2014 Global Association of Risk Professionals. All rights reserved.

Basel III – Enhanced Capital Requirements: Tier1 Criteria

Additional Tier 1 capital instruments

Stock surplus (share premium) of Additional Tier 1 capital instruments

Additional Tier 1 capital Instruments issued by subsidiaries of the bank &

held by third parties

Regulatory adjustments

Important Criteria for Additional Tier 1 Capital

1 Issued and paid-in

2 Subordinated to depositors, general creditors and subordinated

debt of the bank

3 Neither secured nor covered by a guarantee of the issuer or

related entity or other arrangement

4 Perpetual, No step-ups or other incentives to redeem

5 Callable by issuer only after a minimum of five years

6 Repayment of principal must be with prior supervisory approval

7 Dividend/coupon discretion

8 Dividends/coupons must be paid out of distributable items

9 Cannot have a credit sensitive dividend feature

10 Cannot contribute to liabilities exceeding assets if such a balance

sheet test forms part of national insolvency law.

11 Instruments classified as liabilities for accounting purposes must

have principal loss absorption

12 Bank or related party must have not purchased the instrument, nor

through any direct or indirect funding

13 Cannot have any features that hinder recapitalization

14 If issued by SPV, proceeds must be

immediately available

Tier 1 Capital

Page 15: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

15 | © 2014 Global Association of Risk Professionals. All rights reserved.

Basel III – Enhanced Capital Requirements: Tier2 Criteria

Tier 2 capital instruments

Stock surplus (share premium) of Tier 2 capital instruments

Tier 2 capital Instruments issued by subsidiaries of the bank & held by

third parties

Certain Loss Provisions

Regulatory adjustments

Important Criteria for Tier 2 Capital

1 Issued and paid-in

2 Subordinated to depositors and general creditors of the bank

3 Neither secured nor covered by a guarantee of the issuer or

related entity or other arrangement

4 Minimum maturity of five years, No step-ups or other incentives

to redeem

5 May be callable at the initiative of the issuer only after a

minimum of five years

Banks must not exercise a call unless:

• Replace capital with same or better quality instrument

• Bank’s capital position is well above the minimum capital

requirements after the call option is exercised

6 Investor must have no rights to accelerate the repayment of

future scheduled payments

7 Cannot have a credit sensitive dividend feature

8 Bank or related party must have not purchased the instrument,

nor through any direct or indirect funding

9 If issued by SPV, proceeds must be immediately available

without limitation to operating entity

Tier 2 Capital

Page 16: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

16 | © 2014 Global Association of Risk Professionals. All rights reserved.

Basel III – Capital Conservation Buffer Requirements

• Capital Conservation Buffer (CCB) of 2.5%, comprised of Common Equity Tier 1 (CET 1), established above regulatory

minimum capital requirement.

• Ensure that banks build up capital buffers outside periods of stress, which can be drawn down as losses are incurred.

• Capital distribution constraints imposed when capital levels fall within this range.

CAPITAL CONSERVATION BUFFER

Capital Conservation Buffer (CCB) of 2.5%, comprised of

Common Equity Tier 1 (CET 1), established above regulatory

minimum capital requirement.

Capital distribution constraints will be imposed when capital

levels fall within this range.

Banks to conduct business as normal when their capital levels

fall into conservation range as they experience losses.

Constraints imposed only relate to distributions, not

operation of Bank.

No dividend distribution allowed

Conserve 80% of earnings in subsequent financial year

Payout ≤ 20% as dividends, share buybacks and discretionary

bonus payments.

No constraints on dividend distribution

Minimum capital conservation ratios Bank must meet at

various levels of Common Equity Tier 1 (CET1) capital ratios

Page 17: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

17 | © 2014 Global Association of Risk Professionals. All rights reserved.

Basel III – Capital Conservation Buffer Requirements

Elements of Countercyclical Buffer

National Authorities to monitor

indicators that may signal build up of

system-wide risk

Assess whether credit growth is

excessive

Buffer requirement: 0%-2.5% of

risk weighted assets

Pre-announce (by 12 months)

decision to raise level to give Banks

time to adjust level.

National Countercyclical Buffer

requirement

Internationally active banks to

look at geographic location of

credit exposures

Calculate buffer as weighted

average of requirements applied

in jurisdictions to which they have

private sector credit exposures.

Buffer requirement: 0%-2.5% of

total risk weighted assets

Bank-specific Countercyclical

Buffer requirement Extension of Capital Conservation

Buffer

Buffer requirement to which a

Bank is subject to is implemented

through an extension of capital

conservation buffer (CCB)

Page 18: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

18 | © 2014 Global Association of Risk Professionals. All rights reserved.

Basel III – Capital Conservation Buffer Requirements

Mechanics

No constraints on dividend

distribution 4.5% CET1 + 2.5% Capital Conservation Buffer

+ 2.5% Countercyclical Capital Buffer

What International Banks have to do:

2%

1%

Countercyclical Buffer

(70% x 2%) + (30% x 1%) = 1.7%

Page 19: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

19 | © 2014 Global Association of Risk Professionals. All rights reserved.

Leverage Ratio (1/2)

Overview

Leverage ratio measures the extent of leverage an institution has

build, given an amount of high quality capital

Complements risk based minimum capital requirements under

Pillar 1.

Leverage ratio is not a risk adjusted measure

A ‘simple’, non-risk based, ‘backstop’ measure

Definition

Capital Measure

Tier 1 = CET 1 + Additional Tier 1

Exposure Measure

d

Observed weakness during financial crisis

Build-up of excessive on- and off-balance sheet

leverage by banks, while maintaining strong risk-

based capital ratios

During crisis, financial markets forced banking

sector to reduce leverage

Resulted in downward pressure on asset prices

Spiraled into feedback loop between losses, falling

bank capital and shrinking credit availability

d

Objectives of Leverage Ratio

Simple, transparent, non-risk based leverage ratio to act as a

credible supplementary measure to the risk-based capital

requirements.

Ensure comprehensive capture of both the on- and off-balance

sheet sources of banks’ leverage.

Restrict build-up of leverage in banking sector to avoid

disrupting deleveraging processes, which might impact broader

financial system and the economy

Reinforce the risk-based requirements

Source: Derived from BCBS 270, Jan 2014 (Basel III leverage ratio framework and disclosure requirements)

Page 20: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

20 | © 2014 Global Association of Risk Professionals. All rights reserved.

Leverage Ratio (2/2)

Mechanics and Current issues faced by Banks

Requires bank’s assets (irrespective of how risky they are perceived to be) must be backed up by a strict minimum amount of

equity

Local regulators hike leverage ratio requirements resulting in tighter strictures on use of borrowed money by big firms

USA

• Federal regulators in US hiked the leverage ratio to 5% for big banks and 6% for banking subsidiaries

• US banks (largest 8) will require nearly $22 billion in additional capital to meet the new requirements, $38 billion for banking subsidiaries

• If off-balance-sheet credit derivatives is measured bank assets, the banks would required additional $46 billion, bringing in a $68 billion capital shortfall in largest 8 banks

• Concerns that US banks may find it difficult compete in repo and other businesses

• Leverage constraints damp ROE, but reduce risk accepted by shareholders and creditors, better capability to withstand shocks.

EUROPE

• Pressure (by U.K.’s Prudential Regulation Authority) to clear 3% hurdle before Basel stipulated deadline

• Prompted Barclay’s into £6 billion ($10.0 billion) rights issue

• If EU banks have to follow similar stringent regulations as US banks (5% leverage ratio)

• Result in raising of awful lot of capital, to the tune of $196 billion for the 16 largest European banks

• Leverage is higher because of different business models and owning higher proportion of low-risk government bond

• Difference is less significant when allowed to risk-weight these assets

Page 21: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

21 | © 2014 Global Association of Risk Professionals. All rights reserved.

Basel III - Key Reforms

under Pillar 2 and 3

Section 3

Page 22: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

22 | © 2014 Global Association of Risk Professionals. All rights reserved.

Pillar 2 Risk Management & Supervision (1/2)

Firm-wide

Risk

Management

Identifying, measuring, monitoring and

reporting of risk

Internal Controls

Policies, procedures, limits and controls

Board and senior management

oversight ▬ Ensure appropriate policies, controls and effective

risk monitoring systems.

▬ Consistent with goals and objectives;

▬ Adequate and timely identification, measurement,

monitoring, control and mitigation of the risks.

▬ Timely and relevant information;

▬ Capture and report limit breaches.

▬ Frequently monitored and tested;

▬ Internal and external audit.

Addresses the key weaknesses revealed in risk management process of banks

Page 23: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

23 | © 2014 Global Association of Risk Professionals. All rights reserved.

Pillar 2 Risk Management & Supervision (2/2)

Specific Risk

Management Reputational risk and implicit support

Valuation practices

Off-balance sheet exposures and

securitization risk

Risk Concentrations ▬ Aggregate all similar direct and indirect exposures

▬ Communicate risk concentrations to BoD, SM

▬ Incorporate the exposures that could give rise to

reputational risk into its assessments.

▬ Relationship between liquidity and capital;

▬ Thorough liquidity risk management.

▬ Forward looking assessments of risk;

▬ Included in capital planning process.

Addresses the key weaknesses revealed in specific risk aspects of banks

Liquidity risk management and

supervision

Sound compensation practices

Sound stress testing practices

▬ Analyses of the underlying risks and contingency

plans.

▬ Adequate governance structures and control

processes.

▬ Risk-based compensation;

▬ Aligning incentives: with firm’s objectives.

Page 24: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

24 | © 2014 Global Association of Risk Professionals. All rights reserved.

Capital Planning Process: Sound Practices Followed (1/2)

d

Observed weakness in capital planning process

Under-estimation of inherent risks

Misjudged capital needs

Banks continued to pay

dividends and repurchase

common shares

Not sufficiently

comprehensive

Not adequately

formalized

Not appropriately

forward-looking

Banks issued large

amount of capital

instruments such as

hybrid debt

Ill-

equipped

to absorb

realized

losses

Banks did not scale their decisions about the level and composition of regulatory capital to the potential impact of changing economic conditions

Source: Derived from BCBS 277 (Sound capital planning process: fundamental elements)

Absence of comprehensive information

Sound capital planning practices to implement Basel III

Internal Control and governance:

A. Models followed by banks:

o Responsibilities associated with capital planning divided along functional lines ;

o Centralized model with authority and responsibility to review estimates of individual area

B. Senior management and Board involvement for forward strategy of the Bank, risk appetite

C. Comprehensive coverage with linkage between capital planning, budgeting and strategic planning processes

D. Formal process with regular independent validation

Page 25: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

25 | © 2014 Global Association of Risk Professionals. All rights reserved.

Capital Planning Process: Sound Practices Followed (2/2)

Source: Derived from BCBS 277 (Sound capital planning process: fundamental elements)

Sound capital planning practices to implement Basel III (contd.)

Capital Policy and risk capture:

A. Capital policy will refer a suite of capital- and performance-

related metrics against which management monitors the

bank’s condition.

B. Practices followed by banks:

o Widest variation in practice observed

o Management team accountable adherence to capital policy

C. Clear monitoring framework with transparent escalation matrix

D. Include expression of risk tolerance by management and BOD,

adequately reflecting all material risks

Forward-looking view:

A. Stress testing and scenario analyses: potential impact on earnings

and capital from assumed economic downturn

B. Repeatability of stress testing and the capability of performing ad

hoc scenarios outside normal stress testing procedures.

C. Incorporate combination of economic, market and bank-specific

indicators and assess impact on bank’s revenue, loss, balance

sheet, exposure measures and risk-weighted assets.

D. Capital actions, such as reductions in or cessation of dividends or

the issuance of regulatory capital instruments, in line with stress

test results

Management framework for preserving capital:

A. Senior management and BOD ensure that capital policy and associated monitoring and escalation protocols remain relevant alongside

appropriate risk reporting and stress testing framework.

B. Prioritizing and quantifying the capital actions to cushion against unexpected events.

C. Guiding principles for determining the appropriateness of particular actions under different scenarios, considering economic value added,

costs and benefits, market conditions, etc.

Page 26: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

26 | © 2014 Global Association of Risk Professionals. All rights reserved.

Pillar 3 Market Discipline

Specific Risk

Management IAA and other ABCP liquidity facilities

Resecuritization exposures

Sponsorship of off-balance sheet

vehicles

Securitization exposures in the trading

book

▬ Include securitization exposures within the trading

book in-line with banking book.

▬ Clarification of regulatory approach.

▬ Qualitative disclosure on valuation of securitization

positions.

▬ Disclosure requirements for accounting policies.

Complement the minimum capital requirements (Pillar 1) and the supervisory review process (Pillar 2).

Valuation with regard to securitization

exposures

Other

Pipeline and warehousing risks with

regard to securitization exposures

▬ Voluntary disclosure on sponsorship, on-balance sheet

securitization exposures, etc.

▬ Description of processes to monitor changes in the

credit and market risk of securitization exposures.

▬ Liquidity (LCR) incl. HQLA composition, currency

mismatch, concentration of funding sources, etc.

▬ Leverage Disclosure incl. assets, adjustments to

investments & fiduciary assets, credit equivalent of

OBS, etc.

Page 27: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

27 | © 2014 Global Association of Risk Professionals. All rights reserved.

Basel III – Liquidity Norms

Section 4

Page 28: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

28 | © 2014 Global Association of Risk Professionals. All rights reserved.

Overview of BCBS Liquidity Ratios

The core of the framework consists of two ratios, which have been developed to achieve two separate but

complementary objectives.

BCBS International Liquidity Framework

Liq

uid

ity

Co

ve

rag

e R

ati

o

Net

Sta

ble

Fu

nd

ing

Rati

o

LCR

NSFR

Stock of high quality

liquid assets

Net cash outflows over

30-day horizon

Available amount of

stable funding

Required amount of

stable funding

>

• Aim to strengthen short-term liquidity

profile

• Defines level of liquidity buffer to be held

to cover short-term funding gaps under

severe liquidity stress

• Cash flow perspective

• Predefined stress scenario

• Time horizon: 30 days

• Aim to strengthen medium-to long-term

liquidity profile

• Defines minimum acceptable amount of

stable funding in an extended firm-

specific stress scenario

• Balance sheet perspective

• Predefined stress scenario

• Time horizon: 1 year

100%

> 100%

Objective: Promote short-term resilience of liquidity risk profile by ensuring that

sufficient HQLA to survive a significant stress scenario lasting for one month.

Objective: Promote resilience over a longer time horizon by creating additional

incentives for banks to fund their activities with more stable sources of funding on

an ongoing basis.

Page 29: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

29 | © 2014 Global Association of Risk Professionals. All rights reserved.

Liquidity Coverage Ratio (LCR)

Banks must maintain an adequate level of unencumbered, high quality assets to meet their liquidity needs for

a 30-day time horizon under an acute stress scenario.

LCR by currency is expected to be monitored and reported

LCR

Stock of high quality

liquid assets

Net cash outflows

over 30-day horizon

> 100%

Market Value

Asset Factor

Characteristics of high-quality liquid assets

Definition of Liquid Assets – Level 1 & Level 2

Jurisdiction with insufficient Liquid Assets

Stress Scenarios

Cash Outflows

Cash Inflows

Cash

Outflows

Run Off

Factor

Cash Inflows

Run Off

Factor

1

2

3

4

Retail Deposits

Secured Funding

5

6

7

Additional Requirements 8

Cash Inflow Criteria 9

Unsecured Wholesale Funding

Page 30: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

30 | © 2014 Global Association of Risk Professionals. All rights reserved.

Net Stable Funding Ratio (NSFR)

This metric establishes a minimum acceptable amount of stable funding based on the liquidity characteristics

of an institution’s assets and activities over a one year horizon.

NSFR

Available amount of

stable funding (ASF)

Required amount of

stable funding (RSF)

> 100%

Carrying Value

ASF Factor

Stre

ss S

cen

ario

s

Carrying Value

RSF Factor

• Significant decline in

profitability

• Significant decline in

solvency

• Potential downgrade by

any nationally recognized

credit rating organization

• Material event which calls

into question the

reputation or credit quality

of the institution

NSFR promotes medium to long-term funding thus reducing incentives for short-term wholesale funding and supplements the LCR (by also

counterbalancing “cliff-effects”)

The stress scenario is defined differently from the one underlying the LCR –idiosyncratic stress over 1 year

“Stable funding” is defined as those types of equity and liabilities expected to be reliable sources of funds under an extended stress scenario of one

year

For determination of the required funding amount accounting and regulatory treatment is irrelevant –required funding amount depends solely on the

respective instrument’s liquidity characteristics

Page 31: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

31 | © 2014 Global Association of Risk Professionals. All rights reserved.

Liquidity Risk Management

Adequately designed and properly implemented liquidity stress tests can generate valuable information on a

bank’s liquidity profile that cannot be generated from a limited set of standardized liquidity metrics.

Stress Scenarios

Lack of interactions

among risk factors in

internal stress tests

Issues with Stress Testing Practices

Excessive focus central

bank and interbank

market funding

Lack of international

perspective

Methods, Models & Time

horizons

Liquidity risk considered

independent from credit

risk & market risk

P&L effects of longer-

lasting stress situations

are not considered

Disadvantage with cash

flow maturity mismatch

approach

Perimeter covered

Scope of liquidity stress

test driven by data

availability

Capturing changing

business profile or

structural changes in the

market environment

Issue of IT integration for

the entire banking group

Use of stress-test results

Shortcomings in FTP

approaches

Considering liability

liquidity instead of asset

liquidity for buffer

Affect of LCR, NSFR on

FTP

Page 32: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

© 2012 Global Association of Risk Professionals. All rights reserved.

This presentation is prepared to provide general information about Basel III. The information

provided in this presentation is not intended to address the circumstances of any particular

individual or entity. No one should act, or refrain from acting, upon the information contained

herein, without obtaining specific professional advice. The information and comments provided in

this presentation are the views of the author. Protiviti and it’s partners, directors, employees and

agents do not accept or assume any liability or duty of care for any loss arising from any action

taken or not taken by anyone in reliance on the information provided in this presentation or for any

decision based on it.

Important Notice

Page 33: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

© 2012 Global Association of Risk Professionals. All rights reserved.

Contact Details

Raj Parthasarathy Managing Director

Mobile: +973 3902 7611

Email : [email protected]

Page 34: Basel III Changes in Capital and Liquidity … III – Changes in Capital and Liquidity Regulations Raj Parthasarathy Managing Director & Regional Head Financial Services Advisory

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