Basel Reg
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Basel Regulations
Banking Risk: An Overview
Credit risk
Market risk
Risk arising due to default or deterioration of the credit quality of the obligor/borrower Risk arising due to market movement of different benchmark rates.
Operational risk
Loss resulting due to errors instructing payments or setting transactions.
Credit Risk Component
Arises at two levels
Transaction level
At the sanction level – issues of appraisal, credit worthiness of the obligor etc.
Portfolio level
How to manage risk once the bank has built up its portfolio – does the individual obligor default? – if so, what is the probability of default? – in the event of default what is the expected and unexpected loss? – any cushion required?
Market Risk Component
Can arise due to movement of rates (e.g. interest rate, stock prices, exchange rate etc.) in different markets.
Bank may have exposure to different markets such as equity, foreign exchange, commodity etc. By far, interest rate risk is the most prominent component because
Most of the banks’ assets are benchmarked to interest rates which are deregulated.
Market Risk Contd..
Investment portfolio of banks consists of a substantial investment on treasury bonds (Gsecs) which are interest rate sensitive. Reasonable exposure to international benchmark interest rate such as LIBOR (London Interbank Offer Rate)
Operational Risk Component
Operational risk is the risk of loss resulting from inadequate or failed internal processes, people and systems or from external events. Internal fraud External fraud Employment practices & workplace safety Clients, products & business practices Damage to physical assets Business disruption & system failures Execution and delivery
Risk Based Capital Standard
Why do banks need to hold capital in order to do business?
Provides a cushion against unexpected loss that may arise due to credit/market/operational risk. Capital that needs to be maintained as a proportion of risk based assets is termed as risk based capital – otherwise termed as capital adequacy ratio (CAR). e.g., bank does not maintain any capital towards credit risk component of GoI bonds as it is nonexistent.
Evolution of Capital Standard
Originated in July 1988 under the auspices of Bank for International Settlement (BIS) in Basle, Switzerland – popularly termed as Basle Committee.
Basel I defines a common measure of solvency, called the Cooke ratio which covers only credit risk – one size fits all policy. Specifies 8% (9% in India) capital charge on all exposures. Exposures being defined by respective risk weights 1988 accord is termed as Basel – I.
Evolution of Capital Standard 1988
1992
1988 Basel Accord Capital Charge for Credit Risk
1996
1998
Jan 2001
Sept 2001
1st Consultative Working Paper on Document: Operational Risk A New Capital Adequacy Framework Proposed new framework to replace existing Accord and introduced capital charge Discussion for operational risk.2nd Consultative Paper: Package: Operational Risk The New Basel Capital Accord including capital charge for Operational Risks
Introduction of capital charge for Market Risk
Implementation of 1998 Accord
June 1999
Risk Weights and Capital Allocation Risk weight (%)
Asset Category (On-balance sheet)
0
Cash and gold held in bank/Obligation on OECD government and US treasuries
20
Claims on OECD banks/securities issued by US government agencies/Claims on municipalities
50
Residential mortgages
100
All other claims such as corporate debt/Claims on non-OECD banks/Less developed countries’ debt etc.
Risk Weights and Capital Allocation Risk weight (%)
Asset Category (Off-balance sheet)
0
OECD governments
20
OECD banks and public sector entities
50
Corporate and other counterparties
Note: OBSIs include undrawn portion of the loans, Letters of credit, guarantees, derivatives etc.
A Closer Look into Basel I
Capital in regulatory context
Tier 1 Capital Shareholders’ equity and disclosed reserves Tier 2 Capital (Supplementary) Perpetual securities, unrealized gains on investment securities, hybrid capital instruments, long term subordinated debt. Total of tier 2 capital is limited to a maximum of 100% of the total tier 1 capital. Basel I requires tier 1 and tie 2 capital to be at least 8% of the total risk weighted assets.
1996 Amendment to Incorporate Market Risk
1996 amendment treats trading positions in bonds, equity, foreign exchange and commodity in the market risk framework. Provides explicit capital charges on bank’s open position in each instrument Provides scope for BIS ‘standardized approach’ and ‘internal models approach’.
Banks can either choose BIS prescribed model or their own internal model (e.g. Value at Risk) to assess market risk subject to supervisory compliance.
1996 Amendment Contd..
Capital charge is to be made on the following
Held for trading (HFT) category Available for sale (AFS) Foreign exchange positions Trading positions on derivatives Note: Any position which is marked to the market carries a capital charge.
1996 Amendment Contd..
Allows banks to use new ‘Tier 3’ capital
Includes short term subordinated debt to meet the market risk. Tier 3 capital being restricted only to market risk. No such capital can be repaid if that payment results in a bank’s overall capital being lower than a minimum capital requirement.
Basel I in India
Basel I was implemented in India by 1996 (Process got started in 1992-93 and was spread over 3/4 years). However, capital charges for market risk under Basel I got implemented in June 2004. Banks in India are statutorily required to maintain capital for credit risk and market risk. In India, Capital adequacy ratio, termed as Capital to risk assets ratio (CRAR) is set at 9%. However, banks are not allowed, at present, to use Tier III capital towards market risk capital charge.
CRAR of Indian Public Sector Banks CRAR of Public Sector Banks in India (1995-1996 to 2004-2005) (Percent)
Banks
1995-
1996-
1997-
1998-
1999-
2000-
2001-
2002-
2003-
2004-
96
97
98
99
0
1
2
3
4
5
10.2
10.9
12.2
13.1
13.2
Nationalized Banks Andhra Bank
5.07
12.05
12.37
11.02
13.36
13.4
12.59
13.62
13.71
12.11
11.19
11.8
12.05
13.3
12.1
12.8
11.32
12.65
13.91
12.61
Bank of India
8.44
10.26
9.11
10.55
10.57
12.23
10.68
12.02
13.01
11.52
Bank of Maharashtra
8.49
9.07
10.9
9.76
11.66
10.64
11.16
12.05
11.88
12.68
Central Bank of India
2.63
9.41
10.4
11.88
11.18
10.02
9.58
10.51
12.43
12.15
Corporation Bank
11.3
11.3
16.9
13.2
12.8
13.3
17.9
18.5
20.12
16.23
Dena Bank
8.27
10.81
11.88
11.14
11.63
7.73
7.64
6.02
9.48
11.91
Indian Bank
Neg.
-18.81
1.41
Neg.
Neg
Negative
1.7
10.85
12.82
14.14
Indian Overseas Bank
5.95
10.07
9.34
10.15
9.15
10.24
10.82
11.3
12.49
14.2
16.99
17.53
15.28
14.1
12.72
11.81
10.99
14.04
14.47
9.21
Punjab National Bank
8.23
9.15
8.81
10.79
10.31
10.24
10.7
12.02
13.1
14.78
Syndicate Bank
8.42
8.8
10.49
9.57
11.45
11.72
12.12
11.03
11.49
10.7
9.5
10.53
10.86
10.09
11.42
10.86
11.07
12.41
12.32
12.09
State Bank Group
12.7
13.3
13.4
13.4
12.4
Public Sector Banks
11.2
11.8
12.6
13.2
12.9
Bank of Baroda
Oriental Bank of Commerce
Union Bank of India
Problems with Basel I
Does not distinguish among different credit exposures
Both AAA and BBB assets attract the same capital charge.
No capital charges for short term instruments. Does not allow any capital charge for operational risk.
Basel II
Will replace 1988 Basel Accord. Based on the consultative paper issued by Basel Committee on Banking Supervision (BCBS). Based on three mutually enforcing pillars. Specific reference to operational risk in banking. Implementation scheduled for 2005 (By 2007 in India).
The New Basel Capital Accord PILLAR I Minimum capital requirements Credit risk Market risk Operational risk
PILLAR II Supervisory Review Review of the institution’s capital adequacy Review of the internal assessment process
PILLAR III Market Discipline Enhancing transparency through rigorous disclosure norms.
The New Basel Capital Accord Total Capital
= Capital Ratio (minimum 8%)
Credit + Market + Operational Risk Risk Risk
Revised
Unchanged
New
The new Accord focuses on revising only the denominator (riskweighted assets), the definition and requirements for capital are unchanged from the original Accord.
The New Basel Capital Accord
Credit Risk
Standardized approach Internal Rating Based (IRB) approach
Foundation vs. Advanced
Operational Risk
Basic indicator approach Standardized approach Advanced measurement approach
Credit Risk and Standardized Approach
Risk weights of sovereigns
Risk weights (%)
AAA to A+ to AAA-
BBB+ to BBB-
BB+ to B- Belo w B-
Unrated
0
50
100
100
20
150
Credit Risk and Standardized Approach
Risk weights of corporates
AAA to AA- A+ to ARisk weights 20 (%)
50
BBB+ to Below Unrated BBBB100
150
100
Credit Risk and IRB Approach
IRB approach determines the economic capital whereby banks are allowed to use an approach for determining capital requirement for a given exposure that is based on their own internal assessment. Exclusively driven by Internal credit rating system (best examples are PNB, SBI, OBC and a number of new generation private sector banks in India). Provides separate schemes for retail banking, project finance etc.
Operational Risk
Basic indicator approach
Sets the charge for operational risk as a percentage of gross income, defined to include net interest income and net noninterest income, but excludes extraordinary or irregular items. Links to the risk of an expected loss due to internal or external events.
Operational Risk
Basic indicator approach
KBIA = EI*α
Where KBIA = the capital charge under the Basic Indicator Approach EI = the level of an exposure indicator for the whole institution, provisionally gross income α = a fixed percentage, set by the Committee, relating the industry-wide level of required capital to the industry-wide level of the indicator
Operational Risk
Standardized approach
Requires that the institution partition its operation into different lines of business. The capital charge is estimated as an exposure indicator for each line of business multiplied by a coefficient. Provisionally, the Basel committee intends to use gross income for this purpose.
Operational Risk
Advanced measurement approach (AMA)
Capital requirement is based on bank’s internal operational risk measurement system. Focuses on both measurement and management of operational risk. Requires supervisory approval based on qualitative and quantitative standards.
Supervisory Review Process
Four basic principles
Banks should have a process for assessing their overall capital Supervisory review of bank’s internal capital adequacy and compliance Supervisor must expect the banks to operate above the minimum capital requirements. Appropriate intervention on behalf of the supervisor before it gets too late!
Market Discipline
Comprehensive disclosure is essential for market participants to understand the relationship between risk profile and capital of an institution. Includes the disclosure of capital structure, capital adequacy, risk exposure such as market, credit and operational etc.
Basel II in India
Reserve Bank of India circular on ‘Prudential guidelines on capital adequacy – Implementation of new capital adequacy framework’. The banks are required to adopt new Basel II norms by March 31, 2007. Basel II compliance is expected to increase the capital requirement as it captures operational risk. The cushion available in the system, which at present has a Capital to Risk Assets Ratio (CRAR) of over 12 per cent, provides for some comfort (as a survey made by FICCI shows). However, keeping in mind a sustainable requirement of capital, the Reserve Bank has, for its part, issued policy guidelines enabling issuance of several instruments by the banks innovative perpetual debt instruments, perpetual non-cumulative preference shares, redeemable cumulative preference shares and hybrid debt instruments.
Basel II Norms in India: An Overview
Credit risk
Operational risk
Adopts standardized approach Adopts the basic indicator approach
Market risk
Banks are allowed to use their internal models to assess the market risk (i.e., status quo has been maintained in this respect). However, RBI’s guideline on Basel II remains silent on the issue of Tier III capital in Indian context.
Banking Risk: An Overview
Credit risk
Market risk
Risk arising due to default or deterioration of the credit quality of the obligor/borrower Risk arising due to market movement of different benchmark rates.
Operational risk
Loss resulting due to errors instructing payments or setting transactions.
Credit Risk Component
Arises at two levels
Transaction level
At the sanction level – issues of appraisal, credit worthiness of the obligor etc.
Portfolio level
How to manage risk once the bank has built up its portfolio – does the individual obligor default? – if so, what is the probability of default? – in the event of default what is the expected and unexpected loss? – any cushion required?
Market Risk Component
Can arise due to movement of rates (e.g. interest rate, stock prices, exchange rate etc.) in different markets.
Bank may have exposure to different markets such as equity, foreign exchange, commodity etc. By far, interest rate risk is the most prominent component because
Most of the banks’ assets are benchmarked to interest rates which are deregulated.
Market Risk Contd..
Investment portfolio of banks consists of a substantial investment on treasury bonds (Gsecs) which are interest rate sensitive. Reasonable exposure to international benchmark interest rate such as LIBOR (London Interbank Offer Rate)
Operational Risk Component
Operational risk is the risk of loss resulting from inadequate or failed internal processes, people and systems or from external events. Internal fraud External fraud Employment practices & workplace safety Clients, products & business practices Damage to physical assets Business disruption & system failures Execution and delivery
Risk Based Capital Standard
Why do banks need to hold capital in order to do business?
Provides a cushion against unexpected loss that may arise due to credit/market/operational risk. Capital that needs to be maintained as a proportion of risk based assets is termed as risk based capital – otherwise termed as capital adequacy ratio (CAR). e.g., bank does not maintain any capital towards credit risk component of GoI bonds as it is nonexistent.
Evolution of Capital Standard
Originated in July 1988 under the auspices of Bank for International Settlement (BIS) in Basle, Switzerland – popularly termed as Basle Committee.
Basel I defines a common measure of solvency, called the Cooke ratio which covers only credit risk – one size fits all policy. Specifies 8% (9% in India) capital charge on all exposures. Exposures being defined by respective risk weights 1988 accord is termed as Basel – I.
Evolution of Capital Standard 1988
1992
1988 Basel Accord Capital Charge for Credit Risk
1996
1998
Jan 2001
Sept 2001
1st Consultative Working Paper on Document: Operational Risk A New Capital Adequacy Framework Proposed new framework to replace existing Accord and introduced capital charge Discussion for operational risk.2nd Consultative Paper: Package: Operational Risk The New Basel Capital Accord including capital charge for Operational Risks
Introduction of capital charge for Market Risk
Implementation of 1998 Accord
June 1999
Risk Weights and Capital Allocation Risk weight (%)
Asset Category (On-balance sheet)
0
Cash and gold held in bank/Obligation on OECD government and US treasuries
20
Claims on OECD banks/securities issued by US government agencies/Claims on municipalities
50
Residential mortgages
100
All other claims such as corporate debt/Claims on non-OECD banks/Less developed countries’ debt etc.
Risk Weights and Capital Allocation Risk weight (%)
Asset Category (Off-balance sheet)
0
OECD governments
20
OECD banks and public sector entities
50
Corporate and other counterparties
Note: OBSIs include undrawn portion of the loans, Letters of credit, guarantees, derivatives etc.
A Closer Look into Basel I
Capital in regulatory context
Tier 1 Capital Shareholders’ equity and disclosed reserves Tier 2 Capital (Supplementary) Perpetual securities, unrealized gains on investment securities, hybrid capital instruments, long term subordinated debt. Total of tier 2 capital is limited to a maximum of 100% of the total tier 1 capital. Basel I requires tier 1 and tie 2 capital to be at least 8% of the total risk weighted assets.
1996 Amendment to Incorporate Market Risk
1996 amendment treats trading positions in bonds, equity, foreign exchange and commodity in the market risk framework. Provides explicit capital charges on bank’s open position in each instrument Provides scope for BIS ‘standardized approach’ and ‘internal models approach’.
Banks can either choose BIS prescribed model or their own internal model (e.g. Value at Risk) to assess market risk subject to supervisory compliance.
1996 Amendment Contd..
Capital charge is to be made on the following
Held for trading (HFT) category Available for sale (AFS) Foreign exchange positions Trading positions on derivatives Note: Any position which is marked to the market carries a capital charge.
1996 Amendment Contd..
Allows banks to use new ‘Tier 3’ capital
Includes short term subordinated debt to meet the market risk. Tier 3 capital being restricted only to market risk. No such capital can be repaid if that payment results in a bank’s overall capital being lower than a minimum capital requirement.
Basel I in India
Basel I was implemented in India by 1996 (Process got started in 1992-93 and was spread over 3/4 years). However, capital charges for market risk under Basel I got implemented in June 2004. Banks in India are statutorily required to maintain capital for credit risk and market risk. In India, Capital adequacy ratio, termed as Capital to risk assets ratio (CRAR) is set at 9%. However, banks are not allowed, at present, to use Tier III capital towards market risk capital charge.
CRAR of Indian Public Sector Banks CRAR of Public Sector Banks in India (1995-1996 to 2004-2005) (Percent)
Banks
1995-
1996-
1997-
1998-
1999-
2000-
2001-
2002-
2003-
2004-
96
97
98
99
0
1
2
3
4
5
10.2
10.9
12.2
13.1
13.2
Nationalized Banks Andhra Bank
5.07
12.05
12.37
11.02
13.36
13.4
12.59
13.62
13.71
12.11
11.19
11.8
12.05
13.3
12.1
12.8
11.32
12.65
13.91
12.61
Bank of India
8.44
10.26
9.11
10.55
10.57
12.23
10.68
12.02
13.01
11.52
Bank of Maharashtra
8.49
9.07
10.9
9.76
11.66
10.64
11.16
12.05
11.88
12.68
Central Bank of India
2.63
9.41
10.4
11.88
11.18
10.02
9.58
10.51
12.43
12.15
Corporation Bank
11.3
11.3
16.9
13.2
12.8
13.3
17.9
18.5
20.12
16.23
Dena Bank
8.27
10.81
11.88
11.14
11.63
7.73
7.64
6.02
9.48
11.91
Indian Bank
Neg.
-18.81
1.41
Neg.
Neg
Negative
1.7
10.85
12.82
14.14
Indian Overseas Bank
5.95
10.07
9.34
10.15
9.15
10.24
10.82
11.3
12.49
14.2
16.99
17.53
15.28
14.1
12.72
11.81
10.99
14.04
14.47
9.21
Punjab National Bank
8.23
9.15
8.81
10.79
10.31
10.24
10.7
12.02
13.1
14.78
Syndicate Bank
8.42
8.8
10.49
9.57
11.45
11.72
12.12
11.03
11.49
10.7
9.5
10.53
10.86
10.09
11.42
10.86
11.07
12.41
12.32
12.09
State Bank Group
12.7
13.3
13.4
13.4
12.4
Public Sector Banks
11.2
11.8
12.6
13.2
12.9
Bank of Baroda
Oriental Bank of Commerce
Union Bank of India
Problems with Basel I
Does not distinguish among different credit exposures
Both AAA and BBB assets attract the same capital charge.
No capital charges for short term instruments. Does not allow any capital charge for operational risk.
Basel II
Will replace 1988 Basel Accord. Based on the consultative paper issued by Basel Committee on Banking Supervision (BCBS). Based on three mutually enforcing pillars. Specific reference to operational risk in banking. Implementation scheduled for 2005 (By 2007 in India).
The New Basel Capital Accord PILLAR I Minimum capital requirements Credit risk Market risk Operational risk
PILLAR II Supervisory Review Review of the institution’s capital adequacy Review of the internal assessment process
PILLAR III Market Discipline Enhancing transparency through rigorous disclosure norms.
The New Basel Capital Accord Total Capital
= Capital Ratio (minimum 8%)
Credit + Market + Operational Risk Risk Risk
Revised
Unchanged
New
The new Accord focuses on revising only the denominator (riskweighted assets), the definition and requirements for capital are unchanged from the original Accord.
The New Basel Capital Accord
Credit Risk
Standardized approach Internal Rating Based (IRB) approach
Foundation vs. Advanced
Operational Risk
Basic indicator approach Standardized approach Advanced measurement approach
Credit Risk and Standardized Approach
Risk weights of sovereigns
Risk weights (%)
AAA to A+ to AAA-
BBB+ to BBB-
BB+ to B- Belo w B-
Unrated
0
50
100
100
20
150
Credit Risk and Standardized Approach
Risk weights of corporates
AAA to AA- A+ to ARisk weights 20 (%)
50
BBB+ to Below Unrated BBBB100
150
100
Credit Risk and IRB Approach
IRB approach determines the economic capital whereby banks are allowed to use an approach for determining capital requirement for a given exposure that is based on their own internal assessment. Exclusively driven by Internal credit rating system (best examples are PNB, SBI, OBC and a number of new generation private sector banks in India). Provides separate schemes for retail banking, project finance etc.
Operational Risk
Basic indicator approach
Sets the charge for operational risk as a percentage of gross income, defined to include net interest income and net noninterest income, but excludes extraordinary or irregular items. Links to the risk of an expected loss due to internal or external events.
Operational Risk
Basic indicator approach
KBIA = EI*α
Where KBIA = the capital charge under the Basic Indicator Approach EI = the level of an exposure indicator for the whole institution, provisionally gross income α = a fixed percentage, set by the Committee, relating the industry-wide level of required capital to the industry-wide level of the indicator
Operational Risk
Standardized approach
Requires that the institution partition its operation into different lines of business. The capital charge is estimated as an exposure indicator for each line of business multiplied by a coefficient. Provisionally, the Basel committee intends to use gross income for this purpose.
Operational Risk
Advanced measurement approach (AMA)
Capital requirement is based on bank’s internal operational risk measurement system. Focuses on both measurement and management of operational risk. Requires supervisory approval based on qualitative and quantitative standards.
Supervisory Review Process
Four basic principles
Banks should have a process for assessing their overall capital Supervisory review of bank’s internal capital adequacy and compliance Supervisor must expect the banks to operate above the minimum capital requirements. Appropriate intervention on behalf of the supervisor before it gets too late!
Market Discipline
Comprehensive disclosure is essential for market participants to understand the relationship between risk profile and capital of an institution. Includes the disclosure of capital structure, capital adequacy, risk exposure such as market, credit and operational etc.
Basel II in India
Reserve Bank of India circular on ‘Prudential guidelines on capital adequacy – Implementation of new capital adequacy framework’. The banks are required to adopt new Basel II norms by March 31, 2007. Basel II compliance is expected to increase the capital requirement as it captures operational risk. The cushion available in the system, which at present has a Capital to Risk Assets Ratio (CRAR) of over 12 per cent, provides for some comfort (as a survey made by FICCI shows). However, keeping in mind a sustainable requirement of capital, the Reserve Bank has, for its part, issued policy guidelines enabling issuance of several instruments by the banks innovative perpetual debt instruments, perpetual non-cumulative preference shares, redeemable cumulative preference shares and hybrid debt instruments.
Basel II Norms in India: An Overview
Credit risk
Operational risk
Adopts standardized approach Adopts the basic indicator approach
Market risk
Banks are allowed to use their internal models to assess the market risk (i.e., status quo has been maintained in this respect). However, RBI’s guideline on Basel II remains silent on the issue of Tier III capital in Indian context.
