Basel III – Changes in Capital and Liquidity Regulations
Raj Parthasarathy
Managing Director & Regional Head
Financial Services Advisory
Protiviti Member Firm (Middle East)
May, 2014
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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
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Need for Basel III
Section 1
Implementation Timelines
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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
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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
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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
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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
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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
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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
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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
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Basel III - Key Reforms
under Pillar 1
Section 2
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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
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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
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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
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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
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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
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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)
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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%
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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)
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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
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Basel III - Key Reforms
under Pillar 2 and 3
Section 3
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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
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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.
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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
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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.
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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.
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Basel III – Liquidity Norms
Section 4
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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.
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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
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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
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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
© 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
© 2012 Global Association of Risk Professionals. All rights reserved.
Contact Details
Raj Parthasarathy Managing Director
Mobile: +973 3902 7611
Email : [email protected]
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