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Basel II

Basel I

The first Basel agreement came in 1988, following


events like the Third World debt crisis.

Basel I was intended to save the banks from the


same fate by asking them to keep more capital
(8% capital adequacy).

It focused mainly on Credit risk and set minimum


levels of capital for banks.
Existing Capital Adequacy Framework: Basel I
The international standards in the field of banking supervision are set
by the Basel Committee on Banking Supervision (BCBS).

Basel I has improved capital adequacy of banks globally and fostered


competitive equality.

However, recent technological advancement, innovations in financial


products and further globalization have underscored the limitations
of the current framework:

Risk weightings are too broad-brush and insufficiently risk-sensitive


It does not provide incentives for risk mitigation techniques
Shortcomings of Basel I
 Under the current Accord, capital requirements are only moderately related
to a bank’s risk taking.

 The requirement on a credit exposure is the same whether the borrower’s


credit rating is AAA or CCC.

 During this period (1988-1998), markets for credit derivatives and


securitizations grew rapidly, as banks were employing these to take
advantage of shortcomings in the 1988 Accord's crude system of risk
weights.

 Banks are encouraged to structure transactions to minimize regulatory


requirements or, in some cases, to undertake transactions whose main
purpose is to reduce capital requirements with no commensurate
reduction in actual risk taking.
Difference between Basel I and Basel II
Basel I Basel II
1. Stress on Capital 1. Emphasis on Capital
Adequacy Enhancement and
2. Broad Brush Approach Capital Optimization
3. Lack of flexibility and 2. Risk Sensitive
incentives for better Risk 3. Risk weightage to assets
Management assigned on the basis of
4. Use of arbitrary risk ratings and strength of
categories and risk
weightage the assets
5. All assets within the same 4. Incentives for better
category assigned equal Risk Management
risk weightage techniques, especially
6. Capital Charge only for for Credit Risk
Credit Risk and Market 5. Capital Charge for
Risk Operational Risk also
Risk management has emerged as a key area of focus for
banks in recent times especially due to Basel II accord

Corporate Bank Sovereign Retail Project Equity


Finance

Internal
Process
Interest Rate
Credit Risk – in banking
and trading
People books

Foreign
Operational Types of Risks Market
Exchange
Risk Risk
External Equity
Factors
Information Commodity
Risk

Systems Risk Security and Integrity


Risk
Agenda

 Understanding the global trends


 Evolution of Basel II
 Basel II – The Three Pillars
 Capital Adequacy Calculation
 Overview of the New Basel Capital Accord
 Credit Risk Measurement Approaches under Pillar I
 Operational Risk Measurement Approaches under Pillar I
 Strategic implications on Banking sector
 Challenges in Basel II implementation
 Phased approach to migration to Basel II implementation
 Basel II Survey
 Conclusions
Top 10 concerns of bankers *

1. Complex Financial Instruments


2. Credit risk
3. Macro economy
4. Insurance
5. Business continuation
6. International regulation
7. Equity markets
8. Corporate governance
9. Interest rates
10.Political shocks

* Banana Skins 2003 – The CSFI’s annual survey of the risks facing banks
Regulatory developments – Basel II and IFRS

1. Complex Financial Instruments IFRS


2. Credit risk Basel II
3. Macro economy Basel II
4. Insurance
5. Business continuation
6. International regulation IFRS Basel II
7. Equity markets
8. Corporate governance Basel II
9. Interest rates Basel II
10.Political shocks
Agenda

 Understanding the global trends


 Evolution of Basel II
 Basel II – The Three Pillars
 Capital Adequacy Calculation
 Overview of the New Basel Capital Accord
 Credit Risk Measurement Approaches under Pillar I
 Operational Risk Measurement Approaches under Pillar I
 Strategic implications on Banking sector
 Challenges in Basel II implementation
 Phased approach to migration to Basel II implementation
 Basel II Survey
 Conclusions
The Basel Accord is a constant WIP

July 1988 “Basel Accord”


Nov 1991 Amendments for general provisions
July 1994 Amendment for re-structured country debt
April 1995 Netting amendments for derivatives
Jan 1996 Market risk amendments
April 1998 Securities firms added to “OECD banks” cat
June 1999 CP 1
Jan 2002 CP 2
Apr 2003 CP 3
Jun 2004 Final accord
Existing Basel Capital Accord – Why Changes ?

1988 Capital Accord served the industry well, but

– Severe limitations
• Insufficiently sensitive to risk (broad categories)
• Very limited account of risk mitigation

– Perverse incentives leading to regulatory arbitrage


• To lend to poorer quality credits
• To securitise better quality assets

– No incentive structure to improve risk measurement and risk


management practice
Basel II : A Major Paradigm Shift

The Existing Accord The New Accord

• Focus on a single risk • More emphasis on banks’


measure internal methodologies,
supervisory review &
market discipline

• One size fits all • Flexibility, menu of


approaches, capital
incentives for good risk
management

• Broad brush structure • Increased risk sensitivity


Agenda

 Understanding the global trends


 Evolution of Basel II
 Basel II – The Three Pillars
 Capital Adequacy Calculation
 Overview of the New Basel Capital Accord
 Credit Risk Measurement Approaches under Pillar I
 Operational Risk Measurement Approaches under Pillar I
 Strategic implications on Banking sector
 Challenges in Basel II implementation
 Phased approach to migration to Basel II implementation
 Basel II Survey
 Conclusions
Basel II – The Three Pillars

Basel II
Three Pillars

Minimum Supervisor Market


Capital y Review Discipline
Requiremen
ts

Providing a flexible, risk-sensitive capital


management framework
The Basel Committee recommendations urge banks to
adopt more risk sensitive approaches to Risk
Management…

The new Basel Accord is based on Three Pillars

Minimum Capital Supervisory Review Market Discipline

 Advanced methods for  Focus on internal  Focus on disclosure


capital allocation capabilities
 Capital charge for  Supervisors to review
operational risk banks internal
assessment and
strategies

…and has proposed a challenging implementation deadline of 2006 for


internationally active banks
BASEL II Structure
Agenda

 Understanding the global trends


 Evolution of Basel II
 Basel II – The Three Pillars
 Capital Adequacy Calculation
 Overview of the New Basel Capital Accord
 Credit Risk Measurement Approaches under Pillar I
 Operational Risk Measurement Approaches under Pillar I
 Strategic implications on Banking sector
 Challenges in Basel II implementation
 Phased approach to migration to Basel II implementation
 Basel II Survey
 Conclusions
Risk Components to Capital Adequacy Calculation

Unchanged

Total Capital
≥ 8%
Credit Risk + Market Risk + Operational Risk

Significantly Relatively New


Refined Unchanged
Capital Adequacy under Basel II – Pillar I

Market risk – as per Basel Accord

Credit risk
 (a) Standardised approach – more granular version of Basel I
 (b) Foundation IRB – uses banks’ own credit ratings
 (c) Advanced IRB – other inputs also determined by bank

Operational risk
 (a) Basic indicator approach - % of revenue
 (b) Standard indicator approach - % of revenue/assets, by line
of business
 (c) Advanced Measurement Approach – internal models etc
The credit portfolio of ABC Bank has undergone
a uniform downgrade as on 31-3- 2008
after an economic downturn. The position prior
to the downgrade is given below:
The minimum capital required after downgrade is …………..

Rating Scale Risk Weight (%) Exposure Extent of downgrade


Rs. In crores

AAA 20 200 20 %

AA 50 200 20 %

A 50 100 20 %

BBB 100 200 20 %

BB& Below 150 100  

    800  

Minimum capital under Basel II Rs.48.60 crores    


Working
Rating Risk Exposure RWA Exposure after RWA
Scale Weight Before down Downgrade AFTER DOWNGRADE
grade

AAA 20% 200 40 160 80

AA 50% 200 100 200 100

A 50% 100 50 120 60

BBB 100% 200 200 180 180

BB & 150% 100 150 140 210


below

540 630
The Capital required will be

A]56.7 crores*
B]58.6 crores
C]60.6 crores
D]62.6 crores
Agenda

 Understanding the global trends


 Evolution of Basel II
 Basel II – The Three Pillars
 Capital Adequacy Calculation
 Overview of the New Basel Capital Accord
 Credit Risk Measurement Approaches under Pillar I
 Operational Risk Measurement Approaches under Pillar I
 Strategic implications on Banking sector
 Challenges in Basel II implementation
 Phased approach to migration to Basel II implementation
 Basel II Survey
 Conclusions
Overview of the New Basel Capital Accord

Pillar 1 – Minimum capital requirements Pillar 2 – Supervisory Review Pillar 3 – Market Discipline
Market risk  Banks should have a process for  Market discipline reinforces

Unchanged from existing Basel assessing their overall capital efforts to promote safety and
Accord adequacy and strategy for soundness in banks
maintaining capital levels  Core disclosures (basic
Credit risk
 Supervisors should review and information) and supplementary
 Significant change from existing
evaluate banks’ internal capital disclosures to make market
Basel Accord adequacy assessment and discipline more effective
 Three different approaches to the strategies
calculation of minimum capital  Supervisors should expect banks
requirements to operate above the minimum
 Capital incentives to move to capital ratios and should have the
more sophisticated credit risk ability to require banks to hold
management approaches based capital in excess of the minimum
on internal ratings (cf. trigger / target ratios in UK)
 Sophisticated approaches have  Supervisors should seek to
systems / controls and data intervene at an early stage to
collection requirements prevent capital falling below
Operational risk minimum levels
 Not covered in existing Basel
Accord
 Three different approaches to the
calculation of minimum capital
requirements
 Adoption of each approach
subject to compliance with
defined ‘qualifying criteria’
Agenda

 Understanding the global trends


 Evolution of Basel II
 Basel II – The Three Pillars
 Capital Adequacy Calculation
 Overview of the New Basel Capital Accord
 Credit Risk Measurement Approaches under Pillar I
 Operational Risk Measurement Approaches under Pillar I
 Strategic implications on Banking sector
 Challenges in Basel II implementation
 Phased approach to migration to Basel II implementation
 Basel II Survey
 Conclusions
Credit Risk Measurement Approaches under Pillar I

Internal Ratings Based (IRB) Approach


Criteria Standardized Approach Foundation Approach Advanced Approach

Rating External Internal Internal

Risk Weight Calibrated on the basis of Function provided by the Function provided by the Basel
external ratings by the Basel Basel Committee Committee
Committee
Probability of Default (PD) Implicitly provided by the Provided by bank based on Provided by bank based on own
the likelihood that a Basel Committee; tied to risk own estimates estimates
borrower will default over weights based on external
a given time period ratings

Exposure of Default (EAD): Supervisory values set by the Supervisory values set by Provided by bank based on own
for loans, the amount of Basel Committee the Basel Committee estimates
the facility that is likely to
be drawn if a default
occurs
Loss Given Default (LGD); Implicitly provided by the Supervisory values set by Provided by bank based on own
the proportion of the Basel Committee; tied to risk the Basel Committee estimates; extensive process
exposure that will be lost weights based on external and internal control requirement
if a default occurs ratings

Maturity: the remaining Implicitly recognition Supervisory values set by Provided by bank based on own
economic maturity of the the Basel Committee estimates (with an allowance to
exposure Or exclude certain exposures)
At national discretion,
provided by bank based on
own estimates (with an
allowance to exclude certain
exposures
Credit Risk Measurement Approaches under Pillar I
(contd..)

Internal Ratings Based (IRB) Approach


Criteria Standardized Approach Foundation Approach Advanced Approach

Data Requirements  Provision dates  Rating data Same as IRB Foundation, plus:
 Default events  Default events  Historical loss data to
 Exposure data  Historical data to estimate LGD (7 years)
 Customer segmentation estimate PDs (5 years)  Historical exposure data to
 Collateral data estimate EAD (7 years)
 Data collateral
segmentation
 External ratings
 Collateral data

Credit Risk Mitigation Defined by the supervisory All collaterals from All types of collaterals if bank
Techniques (CRMT) regulator; including financial Standardized Approach; can prove a CRMT by internal
collateral, guarantees, credit receivables from goods and estimation
derivatives, “netting” (on and services; other physical
off balance sheet), and real securities if certain criteria
estate are met

Maturity: the remaining  Minimum requirements for Same as Standardized, plus Same as IRB Foundation, plus
economic maturity of the collateral management minimum requirements to minimum requirements to
exposure (administration/evaluation) ensure quality of internal ensure quality of estimation of
 Provisioning process ratings and PD estimation all parameters
and their use in the risk
management process
Agenda

 Understanding the global trends


 Evolution of Basel II
 Basel II – The Three Pillars
 Capital Adequacy Calculation
 Overview of the New Basel Capital Accord
 Credit Risk Measurement Approaches under Pillar I
 Operational Risk Measurement Approaches under Pillar I
 Strategic implications on Banking sector
 Challenges in Basel II implementation
 Phased approach to migration to Basel II implementation
 Basel II Survey
 Conclusions
Operational Risk Measurement Approaches under Pillar I

Calculation of Capital Charge Basic Indicator Approach Standardized Approach Advanced Measurement Approach (AMA)

Calculation of Capital  Average of gross income  Gross income per  Capital charge equals
charge over three years as regulatory business line internally generated measure
indicator as indicator based on:
 Capital charge equals 15%  Depending on business – Internal loss data
of that indicator line, 12%, 15%, or 18% of – External loss data
that indicator as capital
– Scenario analysis
charge
– Business environment and
 Total capital charge
equals sum of charge per internal control factors
business line  Recognition of risk mitigation
(up to 20% possible)

Qualifying Criteria  No specific criteria  Active involvement of  Market discipline reinforces


 Compliance with the Basel board of directors and efforts to promote safety and
Committee’s “Sound senior management soundness in banks
Practices for the  Existence of OpRisk  Core disclosures (basic
Management and management function information) and
Supervision of Operational  Sound OpRisk supplementary disclosures to
Risk” recommended management system make market discipline more
effective
 Systematic tracking of
loss data
Operational risk is inherent to banking business and not
received adequate attention in past
Banking

Commercial Payment and Treasury


Retail Banking
Banking Settlement (Trading & Sales)

Retail Deposits & Payments and


Project Finance Sales
Lending Collections

Private Banking Trade Finance Funds Transfer Market Making


ACTIVITY

Card Services Working Capital Clearing and Proprietary


Finance Settlement Positions

Treasury
Advisory Services

Internal External Employment Clients, Physical Business Execution,


Fraud Fraud Practices & Products & Damage to Disruption Delivery &
Operation Risk Workplace Business Assets and System Process
categories Safety Practices Failures Management
Designing and implementing action plans for operational risk management could be in many
Basel accord requires
forms, depending on the bank’s
Soundneeds ...
Practices for Management and Supervision of
operational Risk

 Establish a structured risk management framework for the


bank
 Redesign process and approach
 Strengthen existing controls, policies and procedures
 Invest in staff training
 Automate processes
 Acceptance of risk as cost of doing business
 Transfer risk through subcontracting
 Contingency plan - Insurance
 Create risk awareness culture

…based on a cost-benefit assessment


Agenda

 Understanding the global trends


 Evolution of Basel II
 Basel II – The Three Pillars
 Capital Adequacy Calculation
 Overview of the New Basel Capital Accord
 Credit Risk Measurement Approaches under Pillar I
 Operational Risk Measurement Approaches under Pillar I
 Strategic implications on Banking sector
 Challenges in Basel II implementation
 Phased approach to migration to Basel II implementation
 Basel II Survey
 Conclusions
Strategic implications on Banking sector

Capital requirements Products


Capital release:  Focus on key products / those with
 Prime mortgages best return on regulatory capital
 High quality corporate lending  Impact of differing capital treatment
 High quality liquidity portfolios and return transparency will impact
 Collaterised & hedged exposures product design
Capital absorption:  Increased risk based product pricing
 Leveraged finance for those on sophisticated credit risk
 Specialised lending approaches
 Small business  Those with less sophisticated risk
 Commitments & pipeline approaches may be priced out of the
Opportunities to use surplus capital market

Wider market Customers


Basel II
 Significant barriers to entry as a bank  Increased transparency of account
 Increased competition for low risk profitability
customers  Risk-differentiated customer
 Disclosure under Pillar III management through:
 Peer group pressure will lead to adoption - Winners:
of more advanced approaches - Prime mortgage customers
 Risk Transfer: - Well rated entities
- Outside Basel regulated banking - Losers:
system e.g. insurance industry - Small & medium sized businesses
- Higher credit risk individuals
Agenda

 Understanding the global trends


 Evolution of Basel II
 Basel II – The Three Pillars
 Capital Adequacy Calculation
 Overview of the New Basel Capital Accord
 Credit Risk Measurement Approaches under Pillar I
 Operational Risk Measurement Approaches under Pillar I
 Strategic implications on Banking sector
 Challenges in Basel II implementation
 Phased approach to migration to Basel II implementation
 Basel II Survey
 Conclusions
Challenges in Basel II implementation

Constituent Challenges

Banks  Interpret new regulations and understand effects on business


 Secure and maintain board and senior management sponsorship
 Face new expectations from regulators, rating agencies, and customers
 Need to consider whether to target certain customers/products or
eliminate others
Customers  Face new costs resulting from need to provide lenders with new, timely
information
 Use key performance indicators to monitor performance
 Face request for better collateralization
 Manage rating process
Regulators  Need well-trained, educated professionals to fill roles.
 Create regulation that reflects the linkages among risks
 Provide incentives for banks to evaluate risks through stress-testing and
scenario analysis

Rating Agencies  Seek to improve reputation (national agencies)


 Maintain high quality of ratings

Financial  Interpret new regulations and understand effects on business and risk
institutions out management
of Basel II’s  Demonstrate quality as Basel II emerges as a best practice standard
scope
Agenda

 Understanding the global trends


 Evolution of Basel II
 Basel II – The Three Pillars
 Capital Adequacy Calculation
 Overview of the New Basel Capital Accord
 Credit Risk Measurement Approaches under Pillar I
 Operational Risk Measurement Approaches under Pillar I
 Strategic implications on Banking sector
 Challenges in Basel II implementation
 Phased approach to migration to Basel II implementation
 Basel II Survey
 Conclusions
Phased approach to migration to Basel II implementation

Phase Phase Phase Phase


1 2 USE 3
TEST 4
MONITOR
ASSESS AND PLAN DESIGN AND IMPLEMENT AND AND
APPROVAL CONTROL

Corporate Governance/
ORGANIZATION Risk Management

Basel II Implementation

Use Test and Approval


Basel II Roll-Out Plan
Credit Risk

Monitor and Control


implementation
Impact Analysis

PROCESSES
Gap Analysis

Master Plan
Approach Operational Risk
Basel II
METHODS Market and Other Risks

Capital Planning
DATA
Disclosure
(including linkage to IFRS)

SYSTEMS Supervisory Review Process

BASEL II PROJECT MANAGEMENT


Agenda

 Understanding the global trends


 Evolution of Basel II
 Basel II – The Three Pillars
 Capital Adequacy Calculation
 Overview of the New Basel Capital Accord
 Credit Risk Measurement Approaches under Pillar I
 Operational Risk Measurement Approaches under Pillar I
 Strategic implications on Banking sector
 Challenges in Basel II implementation
 Phased approach to migration to Basel II implementation
 Basel II Survey
 Conclusions
Basel II Survey

245 participants, most from Asia-Pacific

Survey conducted by Ernst & Young in conjunction with AsiaRisk from


mid November to early December 2004
Basel II Survey

Two third of respondents indicated that they are either in early


stages of implementation or have not yet started
Basel II Survey

Internal rating and its linkage to business processes were


identified as key concerns for credit risk management
Basel II Survey

Operational risk management has progressed, while concerns


were raised in some quantitative areas
Basel II Survey

Most institutes expect major benefits from Basel II beyond


regulatory capital reduction
Agenda

 Understanding the global trends


 Evolution of Basel II
 Basel II – The Three Pillars
 Capital Adequacy Calculation
 Overview of the New Basel Capital Accord
 Credit Risk Measurement Approaches under Pillar I
 Operational Risk Measurement Approaches under Pillar I
 Strategic implications on Banking sector
 Challenges in Basel II implementation
 Phased approach to migration to Basel II implementation
 Basel II Survey
 Conclusions
Conclusions

 Basel II generally favors retail lending over corporate lending


 The implementation of Advanced Approaches, such as IRB Approach for
credit risk and Advanced Measurement Approach for Operational Risk,
require much more preparation and pose several challenges for both the
banks as well as the supervisors.
 The banks would require to meet the minimum requirements relating to
internal ratings at the outset and on an ongoing basis.
 The manpower skills, the IT infrastructure and MIS at the banks would
have to be upgraded substantially
 The supervisors would require developing skills in validation and back
testing of models.
 The banks would need to improve the disclosure practices and adhere to
international standards
 With the focus on regulation and risk management in the Basel II
framework gaining prominence, the post Basel II era will belong to the banks
who manage their risks effectively.
Conclusions

Basel II will make the world less risky

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