Professional Documents
Culture Documents
CONTENTS
ANNEXURES
Annexure A –
102
Regulatory and legislative developments
impacting the group 102
Annexure B –
Basel pillar 3 credit tables 108
Annexure C –
Composition of capital 128
Annexure D –
Map of cross-reference of pillar 3 tables 132
Standard Bank Group
References
These icons refer readers
to information elsewhere in
this report or in our other reports,
which are available online.
ANNUAL INTEGRATED
REPORT 2017
It considers the issues that are material Requirements report has been extracted
to our commercial viability and social •King Code from the group’s audited
relevance, which are required to achieve •<IR> Framework of the annual financial
our strategy in the medium to long term. International Integrated statements.
These include the macroeconomic and Reporting Council
socio-political conditions in which
AIR
we operate. Where applicable,
information in this report has been
extracted from other publications
in our reporting suite.
Intended readers: primarily our providers of financial capital, being our shareholders, depositors and bondholders,
but information relevant to our other stakeholders is also included.
Report to society
RobecoSAM
Our supplementary environmental,
•Sustainalytics
social and governance report, and
•Carbon Disclosure RTS
our transformation report to society
Project
are available online.
•United Nations
Sustainable
Development Goals
Intended readers: the group’s broad base of
•Equator Principles
stakeholders, particularly clients, employees,
business partners, regulators, government and civil •Global
society organisations. Reporting Initiative
(as a guide)
*Definitions:
Banks Act – South African Banks Act 94 of 1990 The invitation to the annual general
Companies Act – South African Companies Act 71 of 2008 meeting and the notice of the
FTSE – Financial Times Stock Exchange resolutions to be tabled at the meeting
IFRS – International Financial Reporting Standards will be sent separately to shareholders
JSE – Johannesburg Stock Exchange and is also available on our website at:
King Code – King Report on Corporate Governance, also known as King IV www.standardbank.com
The group – Standard Bank Group
2
Intended readers of the reports below: shareholders, debt providers and regulators.
GOVERNANCE AND
REMUNERATION Requirements been extracted from the
REPORT 2017
ANNUAL FINANCIAL
STATEMENTS 2017
including the report of the group •Companies Act opinion expressed
audit committee. by KPMG Inc. and AFS
•Banks Act
PricewaterhouseCoopers Inc.
•JSE Listings
Requirements
•King Code
This
report
Risk and capital management report
To assist in the reduction of the group’s carbon footprint we urge our stakeholders to make
use of our reporting site to view our reporting suite at www.standardbank.com/reporting
or scan the above code to be taken there directly.
THIS REPORT
GOV Remuneration awarded
This risk and capital management REM during the financial year
(REM1): page 109
4
BOARD RESPONSIBILITY
The group’s board of directors (the board) has the ultimate responsibility
for the oversight of risk.
In the instances where the group incurred losses, breached risk appetite or was
fined by its regulators, the board is satisfied that management has taken
appropriate remedial action.
BASEL PILLAR 3
KING IV
DISCLOSURE
The group abides by a disclosure policy The board is supportive of the revised
which incorporates the revised pillar 3 King Code which was formally adopted
disclosure requirements as set out by the from 1 October 2017. The group’s adherence
Basel Committee on Banking Supervision in relation to the specific practices and
(BCBS). disclosure requirements attendant to the
principles was assessed and all committee
mandates have been amended to align to
Key elements of this the new requirements.
policy include:
•frequency of reporting
•governance processes
RISK TYPES
Each risk is defined below. The relevant sections include:
•an explanation of the application of the group’s risk, compliance
and capital management (RCCM) governance framework to the
specific risk
•the approved regulatory treatment for capital requirements to be
held against the specific risk in terms of Basel
•a description of the relevant portfolio characteristics both in K
RIS
terms of prescribed disclosure and the group’s business model. DIT
E
CR
41
Credit risk
Credit risk is the risk of loss arising out of the failure
of obligors to meet their financial or contractual
obligations when due. It is composed of obligor risk,
K
RIS
concentration risk and country risk.
NCE
PLIA
COM
66
Compliance risk
Compliance risk is the risk of legal or regulatory
sanction, financial loss or damage to reputation that
the group may suffer as a result of its failure to
comply with laws, regulations, codes of conduct and
standards of good practice applicable to its financial
services activities.
COU
NTR
YR
68
ISK
Country risk
Country risk, also referred to as cross-border country
risk, is the uncertainty that obligors (including the
relevant sovereign, and the group’s branches and
subsidiaries in a country) will be able to fulfil
obligations due to the group given political or
economic conditions in the host country.
FU
ND
IN
GA
ND
LIQ
UID
ITY
RISK
72
Funding and liquidity risk
Liquidity risk is defined as the risk that an entity,
although solvent, cannot maintain or generate
sufficient cash resources to meet its payment
obligations in full as they fall due, or can only do so at
materially disadvantageous terms.
6
98
Reputational risk
REPUT Reputational risk is the risk of potential or actual
ATIO
NAL damage to the group’s image which may impair the
RIS
K profitability and/or sustainability of its business.
B
US
IN
96
ES
Business risk
S
RI
SK
90
OPERATIONAL RISK
Operational risk
Operational risk is the risk of loss suffered as a result
of the inadequacy of, or failure in, internal processes,
people and/or systems or from external events.
86
Insurance risk
Insurance risk is the risk that actual future
underwriting, policyholder behaviour and expense
experience will differ from that assumed in measuring
policyholder contract values and in pricing products.
K
IS
insurance contracts.
SU
IN
79
ISK
ET R Market risk
MARK
Market risk is the risk of a change in the market value,
actual or effective earnings, or future cash flows of a
portfolio of financial instruments, including
commodities, caused by adverse movements in
market variables such as equity, bond and
commodity prices, currency exchange and interest
rates, credit spreads, recovery rates, correlations and
implied volatilities in all of these variables.
HIGHLIGHTS
Neil Surgey
Chief risk officer
8
RISK APPETITE
AND STRESS
TESTING
CAPITAL
MANAGEMENT
Year in brief
During 2017, a number of risks threatened to escalate
further. Key among these were:
•rising geopolitical volatility
•the South African ratings downgrade
Year in brief •the uneasy social and political environment
The group remained adequately capitalised above •pressure on commodity prices
minimum regulatory requirements. •a loss of investment in emerging markets
•threats to the stability of the financial sector in both
The group issued its debut Basel III compliant additional South Africa and across the African continent
tier I (AT1) capital instrument for R1.7 billion on
•de-risking by correspondent banks.
30 March 2017, followed by a second issuance on
21 September 2017 for R1.8 billion. These AT1 issuances Additionally, sovereign risk arising from elections in
contribute towards a more optimal composition of the certain countries, policy changes and spill-over effects
group’s capital resources. from South Africa were also considered as risks specific
to individual African countries. These all formed the
The downgrades to the South African sovereign rating
basis of various macroeconomic stress testing exercises
and consequential downgrades in the credit ratings of
performed during the year within the group and
South African banks in the first half of 2017 did not have
individual legal entities. The group continued to focus
a material impact on the group’s capital adequacy ratios,
on the implementation and cascading of the risk
although there was an increase in market risk risk-
appetite on a groupwide, business unit, legal entity
weighted assets (RWA).
and risk-type basis.
The BCBS published the final Basel III post-crisis reform
proposals in December 2017, with an implementation
date of 1 January 2022 and with transitional FOCUS AREAS FOR 2018
arrangements for the phasing-in of the aggregate output Stress testing has evolved from a regulatory tool
floor from 1 January 2022 to 1 January 2027. used by supervisors to assess banks’ ability to
withstand stress, to an internal risk management
tool. Embedding the use of stress testing results to
FOCUS AREAS FOR 2018 benefit risk management and decision-making at
During 2018, the group will focus on: various levels in the organisation is ongoing, driven
by a focus on:
•optimising the level and composition of capital
with due consideration of business plans, as well •continual refinement of internal models to
as current and future regulatory requirements determine the impact of stress scenarios
•effectively allocating resources, including capital •further integration of stress testing and risk
and liquidity between product lines, trading desks, appetite with strategic planning, as well as
industry sectors and legal entities to enhance the financial planning
overall group economic profit and return on equity •monitoring the consequences of a number of
(ROE) events, including:
•analysing the impact of the Basel III post-crisis – political and policy changes in South Africa
reform proposals on the group’s capital adequacy and elsewhere
ratios, systems and processes to support the new – actions by rating agencies with regard to the
requirements South African sovereign rating
•engaging with the SARB on the South African – volatile macroeconomic environment in key
implementation of the Basel III post-crisis reform markets
proposal, including areas of national discretion •embedding qualitative and quantitative risk
specified by the BCBS. appetite across the group.
Highlights continued
CREDIT
RISK
While economic growth across the continent was positive during the year,
business confidence in key markets such as South Africa remained under
pressure, reflecting prevailing political and economic uncertainty through
much of 2017.
In the retail and business portfolios, the focus for The CIB total CLR increased to 0.33% in 2017 from 0.30%
the year was on proactive engagement with in 2016 (the customer CLR remained unchanged at 0.44%),
distressed customers, decentralisation of credit driven largely by higher portfolio impairments in South
teams to support a more customer-centric Africa reflecting adjustments to the sovereign risk outlook
organisational design, digitisation of credit and a low growth environment. There was an improvement
processes and enhancements in customer scoring. in the CLR in CIB’s Africa Regions operations (total CLR of
0.97% in 2017 from 1.06% in 2016) following an extensive
review of lending exposures. CIB’s CLR remains within the
The PBB total CLR improved from 1.25% in 2016 to 1.20% target range, reflecting the group’s proactive management
in 2017, largely due to the decline in impairments within of exposures to sectors and countries that are experiencing
South African secured products and card but also reflective strain and the group’s ability to assist clients in times of
of some consumer resilience. financial pressure.
10
COMPLIANCE
RISK
Highlights continued
COUNTRY
RISK
LIQUIDITY
RISK
Sub-Saharan Africa
recorded modest Appropriate liquidity buffers were held in
economic growth due to line with regulatory and internal stress
a recovery in commodity testing requirements, taking into account
prices and the end of the the global risk profile and market
2016 drought, although conditions.
some areas remain
drought stricken. Year in brief
The group maintained the liquidity coverage ratio (LCR) in excess of the
Year in brief 80% minimum regulatory requirement throughout 2017.
Political and social risks, uncertain The group successfully managed the balance sheet structure in order
regulatory environments, below average to meet both the LCR and net stable funding ratio (NSFR) regulatory
economic growth and sovereign debt requirements with effect January 2018.
vulnerability continue to be a feature of
some of the group’s presence markets, The group successfully increased longer-term funding during 2017, raising
but the majority are now showing R32.4 billion through a combination of senior debt and syndicated loans.
recovery or stronger growth. An additional R24.6 billion was raised through negotiable certificate of
deposits (NCDs) funding in excess of 12 months.
The focus continued to be on mitigating
transfer and convertibility risks and The group implemented certain mitigating strategies to address the
managing risk appetite within agreed liquidity risks from the downgrade of the South African sovereign to
parameters, and proactively managing sub-investment grade in the first half of 2017. The foreign and local
country-specific risks and concentrations currency downgrades have had a more benign impact than previously
on a forward-looking basis. anticipated on the availability and cost of foreign currency funding. This
was largely due to the supportive global liquidity environment for
emerging markets. The group continues to monitor the implications of
FOCUS AREAS FOR 2018 further credit rating agency downgrades for both local and foreign
The group anticipates continuing currency, which could have a more significant impact on the group’s
sovereign debt vulnerability in some access and cost of foreign currency liquidity sources.
countries as political and social
issues continue to weigh down on
fiscal consolidation and the FOCUS AREAS FOR 2018
regulatory environment. Continued During 2018, the group will focus on:
recovery in economic growth on the
•the strategy on balance sheet optimisation and mix in conjunction
back of a stronger global economy
with both LCR and NSFR compliance from January 2018. This is to
and commodity prices is expected to
ensure that the group has the appropriate amount, diversification
result in improved foreign exchange
and tenor of funding and liquidity to support its asset base at all
reserves and reduced currency
times while continuing to minimise the overall cost of funding
liquidity shortages.
•ensuring mitigating actions are available to address the
The focus will continue to be on implications of further South African sovereign credit rating
managing country specific risks, downgrades, with a focus on diversifying its funding base across
extending local currency risk both rand and foreign currency
products and mitigating foreign •ongoing system enhancements to ensure continued data quality,
currency liquidity risks. The effects efficiency and effectiveness, especially when considering the daily
of climatic changes and related liquidity reporting requirements, across all entities
emerging risks remain a focus in •ongoing enhancements to funds transfer pricing methodology to
relevant markets. steer further balance sheet optimisation and growth strategies.
12
MARKET
RISK
Year in brief
Examples of market volatility experienced include:
•two rating agencies downgraded South Africa to INSURANCE
sub-investment grade during the year RISK
•the ANC held presidential elections which, post-
elections, resulted in significant rand strength
•certain equity counters experienced significant
volatility in December 2017
•a number of African currencies devalued significantly.
Highlights continued
OPERATIONAL
RISK
14
ENTERPRISE RISK
MANAGEMENT
16 EMERGING ENTERPRISE RISKS
20 KEY COMPONENTS OF THE ENTERPRISE RISK
MANAGEMENT PROCESS
21 RISK GOVERNANCE
24 THREE LINES OF DEFENCE MODEL
24 RISK CULTURE
24 REPORTING
Environmental concerns are high following the droughts The rise of cryptocurrencies has the potential to result in a loss of
experienced across Africa and hurricane and flood activity in the confidence in paper money and banking systems. The bank
Gulf of Mexico, Caribbean and Bangladesh. The South African continues to leverage relationships with fintechs to maintain
city of Cape Town is widely recognised as the first major city to relevance in the market.
potentially run out of water. The group is managing our exposure
to this situation with an on-the-ground team focusing on the We operate in an environment undergoing significant social
business continuity in our affected businesses and the impact on change. Our staff are multi-generational and increasingly digitally
our staff. enabled. Communication from our clients and staff has
transitioned towards social media. Digitisation is a core strategic
Technology is evolving at an unwavering pace. Reports in both objective for the group, with an increased focus on accelerating
local and international media demonstrates the increasing digital execution in order to better respond to increasing
number of cyber crime incidents and the growing sophistication demands.
of attacks, including the involvement of Nation States in many
instances. Radical cyber attacks are ever present evidenced by Regulations are becoming more punitive and prescriptive and
the global Wannacry and Petya attacks. The group continues to regulations continue to grow across multiple jurisdictions. The
place focus on our cyber and technology resilience to ensure that potential for legal action from infringements is uncertain.
information is protected and our services are always on and Compliance resourcing has increased to meet the demands of
always available. regulatory change and supervisory expectations.
In 2017, the South African Reserve Bank (SARB) issued guidelines Third-party relationships continue to be leveraged to acquire
to banks to ensure that they are developing resilient systems specialised skills in response to competition and demands.
that can recover quickly in the event of a cyber incident. Other
regulators on the continent are following suit with the Kenyan In addition to the core banking risks of credit, market and
Central Bank issuing similar guidelines. liquidity risk, the group recognises the following emerging
enterprise risks.
Technology risk
Cyber risk
Conduct risk
16
MANAGEMENT
ENTERPRISE RISK
Emerging enterprise risks
1 2 3
The inability to manage, develop The risk of financial loss, The risk of reputational and
and maintain secure, agile disruption or damage to financial losses due to the inability
technology assets to support reputation from breaches or to comply with or keep abreast of
strategic objectives attacks on transaction sites, regulatory requirements
systems or networks
* Risk drivers and mitigants are examples and do not represent all activities being pursued to manage these risks.
4 5 6
The risk of regulatory sanction The risk of loss due to inaccurate The risk of failure of the
and reputational and financial data, data breaches workforce to adequately
losses due to fraud, crime and or being unable to protect and efficiently serve clients,
misconduct from staff or client information support operations and
syndicates deliver business strategy
* Risk drivers and mitigants are examples and do not represent all activities being pursued to manage these risks.
18
MANAGEMENT
ENTERPRISE RISK
7 8 9
BUSINESS
DISRUPTION THIRD-PARTY CONDUCT
* Risk drivers and mitigants are examples and do not represent all activities being pursued to manage these risks.
Group strategy
Managing risk is a key part of the group’s The board has the ultimate responsibility These committees are responsible for
everyday activities. The framework for the oversight of risk, including approval management of all risks and
ensures risks are managed in a consistent of strategy and risk appetite. implementation of risk governance
way across the group with appropriate processes, standards, policies and
oversight and accountability. frameworks.
24
Control framework
Risk standards, frameworks, policies
and internal controls
Underpinned by:
20
MANAGEMENT
ENTERPRISE RISK
RISK GOVERNANCE
The group’s approach to managing risk and capital is set out in the
group’s RCCM governance framework, which is approved by the
group risk and capital management committee (GRCMC).
The framework has two components:
Governance committees
STANDARD BANK GROUP BOARD
The board committees that are responsible for the oversight of GAC
the group’s RCCM comprise the GRCMC, the group audit The GAC has oversight of the group’s financial position and
committee (GAC), the group technology and information makes recommendations to the board on all financial matters,
committee and the group model approval committee. financial risks, internal financial controls and compliance. In
relation to RCCM, the GAC plays a role in assessing the adequacy
The key roles and responsibilities of these committees, as they
and operating effectiveness of the group’s internal financial
relate to RCCM, are summarised in the sections that follow.
controls. In addition, the GAC:
Board subcommittees •monitors and reviews the adequacy and effectiveness of
GRCMC accounting policies, financial and other internal control
The GRCMC provides an independent objective oversight of risk systems and financial reporting processes
and capital management in the group. It also reviews and •provides independent oversight of the group’s assurance
assesses the adequacy and effectiveness of the group RCCM functions, with particular focus on combined assurance
governance framework, and the integrity of risk controls and arrangements, including external audit, internal audit,
systems. In addition, the GRCMC: compliance, risk and internal financial control functions
•sets the direction for how risk and capital management should •reviews the independence and effectiveness of the group’s
be approached and addressed in the group external audit, internal audit and compliance functions
•assesses the group’s compliance with applicable legal,
•reviews and approves the risk appetite statement for the
regulatory and accounting standards and policies in the
group’s banking activities
preparation of fairly presented financial statements and
•reviews risk management reports and monitors the group’s
external reports, thus providing independent oversight of
risk profile
the integrity thereof.
•evaluates and agrees the opportunities and associated risks
that the organisation should be willing to take. Membership comprises six independent non-executive directors,
which includes the group technology and information and group
The chairmen of the board, the GAC, the remuneration remuneration committee chairmen.
committee, the group social and ethics committee, the group
model approval committee and the group technology and In order to ensure the independence of the second line of
information committee are all members of the GRCMC. This defence functions, the chairman of the GAC meets individually
common membership supports an integrated view of financial, with the group chief compliance and data officer (GCCDO), the
IT and risk controls and ensures that relevant finance and risk group financial director and the group chief audit officer, without
input is considered in determining levels of compensation. management being present, on a quarterly basis and as required.
22
MANAGEMENT
ENTERPRISE RISK
Group technology and information committee Management committee
The group technology and information committee’s purpose is to GROC has been established as a subcommittee of the group
assist the board in fulfilling its corporate governance management committee to provide group-level oversight of all
responsibilities with respect to technology and information, and risk types and assists the GRCMC in fulfilling its mandate. As is
reports to the board through its chairman. In line with King IV and the case with the GRCMC, GROC calls for and evaluates in-depth
the board briefing on IT governance, as published by the IT investigations and reports based on its assessment of the group’s
Governance Institute, this committee ensures that prudent and risk profile and external factors.
reasonable steps are taken with respect to technology and
information governance. GROC delegates authority to various subcommittees which deal
with specific risk types or oversight activities. Material matters
The committee has the authority to review and provide guidance are escalated to GROC through reports or feedback from each
on matters related to the group’s IT strategy, budget, operations, subcommittee chairman.
policies and controls, the group’s assessment of risks associated
with IT, including disaster recovery, business continuity and IT CIB credit governance committee
security, as well as oversight of significant IT investments and Chaired by: CIB CRO
expenditure.
PBB credit governance committee
The committee oversees the governance of technology and Chaired by: PBB CRO
information in a way that supports the organisation in setting and
achieving its strategic objectives. Group asset and liability committee (ALCO)
Chaired by: group financial director
Membership comprises five independent non-executive directors,
two non-executive directors, all three executive directors and Group compliance committee
the group’s head of digitisation. This is complemented by an Chaired by: GCCDO
independent IT subject matter expert, the group chief
information officer, group chief risk officer (CRO), group chief Group country risk management committee
audit officer, business unit chief executives, group head of Chaired by: group CRO
operational risk, IT executive management members, GCCDO,
and the head of data management. The group’s external audit IT Group equity risk committee (ERC)
partners are standing invitees to committee meetings. Chaired by: CIB CRO
Group model approval committee Group internal financial control governance committee
This committee assists the board in discharging its obligations Chaired by: group financial director
for model risk as it pertains to the advanced internal rating-based
Group operational risk committee
(AIRB) approach for the measurement of the group’s exposure
Chaired by: group head of operational risk management
to credit risk as envisaged in the regulations of the Banks Act.
Group sanctions and client risk review committee
It performs functions that may be prescribed by regulation, from
Chaired by: group CRO
time-to-time, including the evaluation of risk evaluation models
that may need to be approved by the committee before being
Group stress testing and risk appetite committee
used to calculate a regulatory capital charge.
Chaired by: group CRO
Membership comprises three non-executive directors, all three
Group recovery and resolution plan committee
executive directors, the chief executives of PBB and CIB and the
Chaired by: group financial director
group CRO.
GOV For details on the activities of the committees, refer to the group’s
REM governance and remuneration report.
THE SECOND
LINE
Risk management and compliance
24
CAPITAL
MANAGEMENT
26 OVERVIEW AND OBJECTIVES
26 REGULATORY UPDATE
26 REGULATORY CAPITAL
32 ECONOMIC CAPITAL
33 RISK-ADJUSTED PERFORMANCE
MEASUREMENT
33 COST OF EQUITY
OVERVIEW AND OBJECTIVES Annexure A provides a summary of the regulatory and legislative
developments that impact the group. In particular, the impact of
The group’s capital management function is designed to ensure IFRS 9 as well as final Basel III post-crisis reform proposals that
that regulatory requirements are met at all times and that were published by the BCBS in December 2017 and the potential
the group and its principal subsidiaries are capitalised in line with requirements for loss absorbing and recapitalisation capacity of
the group’s risk appetite and target ratios, both of which are systemically important banks may impact capital levels going
approved by the board. forward. The implementation date of the Basel III post-crisis
reform proposals is 1 January 2022 with transitional
It further aims to facilitate the allocation and use of capital, such arrangements for the phasing in of the aggregate output floor
that it generates a return that appropriately compensates from 1 January 2022 to 1 January 2027. The Basel III post-crisis
shareholders for the risks incurred. Capital adequacy is actively reform proposals provide for areas of national discretion and the
managed and forms a key component of the group’s budget and group will, through relevant industry bodies, engage the SARB on
forecasting process. The capital plan is tested under a range of the South African implementation of the proposals.
stress scenarios as part of the group’s annual internal capital
adequacy assessment process (ICAAP) and recovery plan.
REGULATORY CAPITAL
The capital management function is governed primarily by The group manages its capital levels to support business growth,
management level subcommittees that oversee the risks maintain depositor and creditor confidence, create value for
associated with capital management, namely the group ALCO shareholders and ensure regulatory compliance.
and one of its subcommittees, the group capital management
committee. The principal governance documents are the capital The main regulatory requirements to be complied with are those
management governance framework and the model risk specified in the Banks Act and related regulations, which are
governance framework. aligned with Basel III.
4
6.50 6.25 6.00
2
26
CAPITAL MANAGEMENT
The following graph discloses the group’s total capital adequacy RWA history1 (Rbn)
and the components thereof and indicates that the group’s
capital is well above the required level of capital. 2 000
1 000
15.0
500
10.0
QQTier I QQTier II Required capital Maturity profile of the group’s tier II instruments (Rm)
5 000
RWA are calculated in terms of the Banks Act and related 4 000
regulations, which are aligned with Basel III. 3 000
The group issued its debut Basel III compliant AT1 capital
instrument for R1.7 billion on 30 March 2017, followed by a
second issuance for R1.8 billion on 21 September 2017. The group
has not issued Basel III compliant tier II instruments during the
period under review.
Credit risk (excluding counterparty credit risk (CCR)) 666 422 627 691 71 641
Of which standardised approach2 CR4 267 924 258 526 25 941
Of which internal rating-based (IRB) approach CR6, CR7, CR8 398 498 369 165 45 700
CCR CCR1 24 350 21 184 2 618
Of which standardised approach for CCR 3 424 2 640 368
Of which IRB approach 20 926 18 544 2 250
Equity positions in banking book under
market-based approach CR10 6 154 6 167 662
Securitisation exposures in banking book 747 678 80
Of which IRB approach SEC3 394 228 61
Of which IRB supervisory formula approach SEC3 353 450 19
Market risk 60 021 39 444 6 452
Of which standardised approach MR1 47 217 21 411 5 076
Of which internal model approach (IMA) MR2 12 804 18 033 1 376
Operational risk 158 670 149 163 17 058
Of which standardised approach 91 818 89 971 9 871
Of which advanced measurement approach (AMA) 66 852 59 192 7 187
Amounts below the thresholds for deduction (subject to 250% risk weight) 40 682 38 852 4 373
Total 957 046 883 179 102 884
1 Capital requirement at 10.8% (December 2016: 10.38%) excludes the confidential bank-specific add-ons.
2 Portfolios on the standardised approach relate to the Africa Regions and portfolios for which application to adopt the IMA has not been submitted, or for which an
application has been submitted but approval has not been granted.
28
CAPITAL MANAGEMENT
RWA reconciliation (Rbn) (Banking operations)
1 200
600
400
200
24.0
3.0 (1.5)
20.0
(1.8)
16.6 0.2 (0.5)
16.0
16.0
12.0
8.0
4.0
Total capital adequacy ratio 10.8 15.0 – 16.0 16.0 16.6 14.8 15.6
Tier I capital adequacy ratio 8.5 12.0 – 13.0 14.2 14.3 13.1 13.4
CET I capital adequacy ratio 7.3 11.0 – 12.5 13.5 13.9 12.4 13.0
1 Group, including Liberty.
2 Excludes confidential bank-specific add-ons.
The SARB has not activated a CCyB requirement for banks in South Africa, but the group is subject to CCyB requirements on exposures
in other jurisdictions where these buffers apply from time-to-time.
The proportion of capital held for CCyB requirements in geographies other than South Africa are shown in the table below.
The SARB adopted the leverage framework that was issued by the BCBS in January 2014 with formal disclosure requirements
commencing from 1 January 2015. The minimum leverage ratio has been set at 4% by the SARB.
The non-risk-based leverage measure is designed to complement the Basel III risk-based capital framework.
30
CAPITAL MANAGEMENT
LR1 – SUMMARY COMPARISON OF ACCOUNTING ASSETS VS LEVERAGE RATIO EXPOSURE MEASURE
(BANKING OPERATIONS)
2017 20161
Rm Rm
Total consolidated assets as per published financial statements 1 597 968 1 543 758
Adjustment for investments in banking, financial, insurance or commercial entities that are
consolidated for accounting purposes but outside the scope of regulatory consolidation 10 605 10 426
Adjustment for fiduciary assets recognised on the balance sheet pursuant to the operative accounting
framework but excluded from the leverage ratio exposure measure
Adjustments for derivative financial instruments (29 263) (11 105)
Adjustment for securities financing transactions (repos and similar secured lending) 794 2 256
Adjustment for off-balance sheet items (conversion to credit equivalent amounts of off-balance
sheet exposures) 109 106 103 118
Other adjustments (1 688) 5 295
Leverage ratio exposure 1 687 522 1 653 748
1 Restated. Refer to page 101.
Total consolidated assets per published financial statements 1 597 468 1 543 758
Derivative assets as per the statement of financial position (SOFP) (72 629) (61 752)
Security financing transactions per the SOFP (66 590) (126 037)
Total consolidated assets per published financial statements (excluding derivative and
SFT assets) 1 458 749 1 355 969
Gross-up for cash management schemes 30 637 37 971
Adjustment for share of consolidated insurance assets 10 605 10 426
Total on-balance sheet items as per line 1 of common disclosure table 1 499 991 1 404 366
1 Restated. Refer to page 101.
32
CAPITAL MANAGEMENT
Liberty is currently producing SAM assessments in parallel to
those required by the existing regulations and is confident of
transitioning on the effective date of SAM implementation.
RISK-ADJUSTED PERFORMANCE
MEASUREMENT
Risk-adjusted performance measurement (RAPM) maximises
shareholder value by optimally managing financial resources
within the board-approved risk appetite. Capital is centrally
monitored and allocated, based on usage and performance in a
manner that enhances overall group economic profit and ROE.
Business units are held accountable for achieving their RAPM
targets. RAPM is calculated on both regulatory and economic
capital measures.
160 000 16
120 000 12
80 000 8
40 000 4
COST OF EQUITY
The group’s rand-based cost of equity (COE) is estimated using
the capital asset pricing model applying estimates of a risk-free
rate at 8.8% (2016: 8.8%), equity risk premium of 6.4%
(2016: 6.5%) and a beta factor of 79.2% (2016: 79.3%). The beta
factor for banking activities is estimated at 80.8% (2016: 81.4%).
The group’s average COE as at 31 December 2017 is 13.9%
(2016: 14.0%).
34
RISK APPETITE AND STRESS TESTING
OVERVIEW The group has adopted the following definitions, where entity
refers to a business line or legal entity within the group, or the
The key to the group’s long-term sustainable growth and group itself:
profitability lies in ensuring that there is a strong link between its •risk appetite: an expression of the amount or type of risk an
risk appetite and its strategy. entity is willing to take in pursuit of its financial and strategic
objectives, reflecting its capacity to sustain losses and
Risk appetite is set, and stress testing activities are undertaken,
continue to meet its obligations as they fall due, under both
at a group level, in business units, in risk types and at a legal
normal and a range of stress conditions
entity level.
•risk appetite trigger: an early warning trigger set at a level
that accounts for the scope and nature of available
GOVERNANCE management actions, and ensures that corrective
management action can take effect and prevent a risk
The primary management level governance committee
tolerance limit breach
overseeing risk appetite and stress testing is the group stress
testing and risk appetite committee. •risk tolerance: the maximum amount of risk an entity is
prepared to tolerate above risk appetite. The metric is referred
The principal governance documents are the risk appetite to as a risk tolerance limit
governance framework and the stress testing governance •risk capacity: the maximum amount of risk the entity is able
framework. to support within its available financial resources
•risk appetite statement (RAS): the documented expression
RISK APPETITE of risk appetite and risk tolerance which have been approved
by the entity’s relevant governance committee. The RAS is
Risk appetite governance framework reviewed and revised, if necessary, on an annual basis
The risk appetite governance framework guides: •risk profile: the risk profile is defined in terms of three
dimensions, namely:
•the setting and cascading of risk appetite by group, business
line, risk type and legal entity – current or forward risk profile
•measurement and methodology – unstressed or stressed risk profile
•governance – pre- or post-management actions.
•monitoring and reporting of the risk profile The following diagram provides a schematic view of the three
•escalation and resolution. levels of risk appetite and the integral role that risk types play in
the process of cascading risk appetite from dimensions such as
regulatory capital, economic capital, stressed earnings and
liquidity to more granular portfolio limits.
RISK APPETITE
•regulatory capital •credit and equity risk Credit and equity risk
•economic capital •operational risk •CLR
•stressed earnings •market risk •NPL
•liquidity •interest rate risk •concentrations
•business risk Operational risk
•liquidity risk •operational risk losses % to
total income
Capital demand/earnings at Market risk
risk utilisation per risk type •normal value-at-risk (VaR) and
stressed VaR (SVaR) limits
Interest rate risk
•interest rate sensitivity
Business risk
•cost-to-income ratio
•ROE
•headline earnings
per share (HEPS)
Liquidity risk
•depositor concentration
RAS
36
RISK APPETITE AND STRESS TESTING
Additional stress testing
Groupwide macroeconomic stress testing results are
supplemented with additional ad hoc stress testing at the group,
legal entity, business line, sector, or risk type level that may be
required from time-to-time for risk management or planning
purposes. The purpose of this stress testing is to inform
management of risks that may not yet form part of routine stress
testing or where the focus is on a specific portfolio or business
unit. Additional stress testing can take the form of either scenario
analysis or sensitivity analysis.
LINKAGES
38
LINKAGES
OVERVIEW
Table LI1 highlights the difference between the accounting and regulatory scopes of consolidation and also provides a mapping of the
in-scope portion of the IFRS financial statements to the Basel III regulatory risk categories.
Table LI2 provides a reconciliation of the in-scope carrying values as included in the IFRS financial statements to the exposure amounts
used for regulatory purposes.
Assets
Cash and balances
with central banks 75 310 75 277 75 277
Derivative assets 75 610 72 629 72 629 67 547
Trading assets 160 894 159 798 12 334 26 412 159 798
Pledged assets 20 785 8 879 8 879
Financial
investments 533 314 178 715 162 872 15 842
Current tax assets 612 610 610
Loans and advances 1 048 027 1 048 481 1 006 451 41 562 468
Policyholder assets 7 484
Other assets 22 996 12 339 12 339
Interest in associates
and joint ventures 9 665 22 128 12 988 9 141
Investment property 32 226
Property and
equipment 16 179 12 671 12 671
Goodwill and other
intangible assets 23 329 23 064 23 064
Deferred tax assets 1 497 1 155 1 078 78
Total assets 2 027 928 1 615 746 1 296 620 165 324 468 227 345 32 283
Derivative liabilities 76 896 73 624 73 624 72 416
Trading liabilities 62 855 63 577 63 577
Current tax liabilities 5 107 1 822 1 822
Deposits and debt
funding 1 243 911 1 258 771 9 536 1 258 771
Policyholders’
liabilities 322 918
Subordinated debt 24 289 18 966 18 966
Provisions and other
liabilities 98 428 22 310 22 310
Deferred tax
liabilities 3 507 2 425 2 425
Total liabilities 1 837 911 1 441 495 83 160 135 993 1 304 294
1 The most significant differences between columns a and b of the table are as a result of exclusion of Liberty Holdings, the group’s insurance operations, from regulatory
scope of consolidation.
2 Including Liberty.
3 Refer to the group’s website for reporting framework consolidation differences.
Linkages continued
40
LINKAGES
CREDIT RISK
42 BANKING OPERATIONS
42 Approach to managing and measuring credit risk
42 Governance
43 Credit portfolio analysis
43 Approved regulatory capital approaches
49 Key portfolio models
49 Concentration risk
50 Credit risk mitigation
56 Counterparty credit risk
62 Securitisation
65 INSURANCE OPERATIONS
65 Consolidated mutual funds
65 Credit exposure to debt instruments
65 Reinsurance
65 Impairments – policyholder loans
Credit risk
42
CREDIT RISK
Credit portfolio analysis
The credit quality of the group’s on- and off-balance sheet assets is reflected in table CR1 below, through the disclosure of the gross
carrying values of both defaulted and non-defaulted exposures, as well as the net exposures after impairments and allowances. Table
CR2 presents the movement in the balance of defaulted exposures for the reporting period, including loans and debt securities that have
defaulted since the last reporting period, those that have returned to default status and the amounts that have been written off.
Non- Allowances/
Defaulted defaulted impair-
exposures exposures Total ments1 Net values
(a) (b) exposure (c) (a+b-c)
Rm Rm Rm Rm Rm
2017
Loans2 34 938 1 078 545 1 113 483 22 366 1 091 117
Debt securities and other investments 78 140 921 140 999 78 140 921
On-balance sheet exposures 35 016 1 219 466 1 254 482 22 444 1 232 038
Off-balance sheet exposures 1 546 299 857 301 403 301 403
Total 36 562 1 519 323 1 555 885 22 444 1 533 441
CR2 AFS
2016
Loans2 34 426 1 004 915 1 039 341 21 793 1 017 548
Debt securities and other investments 155 227 155 227 155 227
On-balance sheet exposures 34 426 1 160 142 1 194 568 21 793 1 172 775
Off-balance sheet exposures 431 288 342 288 773 288 773
Total 34 857 1 448 484 1 483 341 21 793 1 461 548
CR2 AFS
1 As reported in the annual financial statements.
2 Included in loans are placements with central banks outside of South Africa. Placements under resale agreement are included within the CCR framework and excluded
from credit risk.
CR2: CHANGES IN STOCK OF DEFAULTED LOANS AND DEBT SECURITIES (BANKING OPERATIONS)
2017 2016
Rm Rm
Approved regulatory capital approaches For bank and certain corporate asset class credit exposures on
the standardised approach the group makes use of the ratings of
The group has approval from the SARB to adopt the AIRB
two regulatory-approved external credit assessment institutions,
approach for most credit portfolios in SBSA. The group has
Fitch and Moody’s.
adopted the standardised approach for its Africa Regions
portfolios and for some of its less material subsidiaries and With respect to mainly sovereign credit exposures subject to the
portfolios. The group has approval from the SARB to adopt either standardised approach (particularly in the Africa Regions)
the market-based or the probability of default (PD)/loss given reference is also made to the export credit ratings issued by the
default (LGD) approaches for material equity portfolios, with the Organisation for Economic Co-operation and Development. The
latter applied to equity held on the banking book. group applies issuer ratings to calculate risk weights and will only
apply an issuer-specific rating in the event that it invests in a
Standardised approach particular issue that has an issue-specific assessment.
The calculation of regulatory capital is based on a risk weighting
and the net counterparty exposures after recognising a limited Regulatory capital for the credit risk arising on the owner-
set of qualifying collateral. The risk weighting is based on the occupied sub-portfolio of the commercial property finance
exposure characteristics and, in the case of corporate, bank and portfolio in South Africa was calculated on the standardised
sovereign exposures, the external agency credit rating of the approach.
counterparty.
The credit rating scale on page 48 is used for the alignment with the group’s master rating scale. In the case of obligors for which there
are no credit ratings available, exposures are classified as unrated for determining regulatory capital requirements.
The table that follows presents the breakdown of credit risk exposures under the standardised approach by Basel asset class and risk
weight. The total credit exposure amount represents on- and off-balance sheet amounts before application of credit risk mitigation
(CRM) and CCF. The capital requirements calculation is based on the amounts after also considering write-offs and allowances.
2017
Asset classes
Corporate 5 264 102
SME corporate 244
Public sector entities 1 272
Local governments and municipalities 72
Sovereign 39 601 1 477 2 257
Banks 3 218 14 819
Securities firms 4 1
Retail mortgage advances 7 693 192
Retail revolving credit 9
SME retail 107
Other retail 225
Securitisation and re-securitisation exposure
Other assets 43 157 1 321
Total 82 758 6 020 12 957 19 300
2016
Asset classes
Corporate 644 488 7 069 711 1 325
SME corporate 1 721 432 916 808 2 190
Public sector entities 1 958
Local governments and municipalities 62
Sovereign 19 449 2 021 3 416
Banks 3 492 23 201
Securities firms 95
Retail mortgage advances 284 91 2 567 4 327 2 249
Retail revolving credit 1 203
SME retail
Other retail 208
Securitisation and re-securitisation exposure
Other assets 49 765 54
Total 69 214 2 649 6 578 10 552 5 846 35 907
44
CREDIT RISK
Risk weights Total credit
exposures
amount
(post-CCF
75% 100% 150% 225% 350% 650% 1 250% Others and post-CRM)
25 758 70 236
35 679 191 365 15 040 363 119
(CR4/LI2)
Internal ratings-based approach All IRB models are managed under model development and
Under the IRB regulatory capital approaches, the calculation of validation policies that set out the requirements for model
regulatory capital is based on an estimate of EAD and a risk governance structures and processes, and the technical
weighting. The risk weighting is based on asset class, and framework within which model performance and appropriateness
estimates of PD, LGD, and maturity. Under the AIRB approach all is maintained. The models are developed using internal historical
the parameters need to be estimated internally, while only PD is default and recovery data. In low-default portfolios, internal data
estimated internally under the foundation IRB approach. EAD, is supplemented with external benchmarks and studies. Models
LGD and maturity are regulatory-prescribed under the foundation are subjected to validation to demonstrate the reliability of the
IRB approach. model’s output.
Model development is governed by a group model risk Model validation takes place when a model is first designed and
governance framework, which applies to all models used in the annually thereafter, when there are material changes to the
assessment of credit risk, including but not limited to models model or when rating systems are replaced or enhanced. Models
used for the IRB approaches. Credit risk model development is are thus assessed frequently to ensure ongoing appropriateness
conducted within the independent risk function, while validation as business environments and strategic objectives change, and
is independently undertaken by a quantitative analytics function. are recalibrated annually using the most recent internal data. Any
changes to models or to model outputs are controlled through
access rights and are subject to approval at the relevant business
unit or group governance committee.
CR6: IRB – CREDIT RISK EXPOSURES BY PORTFOLIO AND PD RANGE (BANKING OPERATIONS)
TOTAL (ALL PORTFOLIOS)1
Original Off-balance
on-balance sheet EAD post-
sheet gross exposures Average CRM and Average
exposures pre-CCF CCF post-CCF PD
PD scale Rm Rm % Rm %
2017
0.00 to < 0.15 144 735 44 998 59.81 174 055 0.05
0.15 to < 0.25 57 074 36 725 55.35 78 755 0.21
0.25 to < 0.50 173 138 71 144 46.10 207 518 0.39
0.50 to < 0.75 127 043 28 950 44.66 140 580 0.63
0.75 to < 2.50 280 249 39 042 50.81 300 079 1.38
2.50 to < 10.00 122 356 10 993 56.87 128 391 4.32
10.00 to < 100.00 39 952 2 357 49.08 41 869 25.81
100.00 (default) 28 478 1 546 45.52 29 182 100.00
Total 973 025 235 755 50.69 1 100 429 4.69
LI2
2016
0.00 to < 0.15 138 279 45 363 61.14 171 068 0.04
0.15 to < 0.25 73 363 40 337 48.67 94 963 0.21
0.25 to < 0.50 181 091 60 804 50.76 211 894 0.39
0.50 to < 0.75 108 942 28 823 47.02 121 889 0.64
0.75 to < 2.50 237 519 35 719 54.38 252 605 1.39
2.50 to < 10.00 125 350 14 581 55.52 129 398 4.32
10.00 to < 100.00 40 637 1 524 74.26 41 628 26.19
100.00 (default) 28 262 430 50.00 28 477 100.00
Total 933 443 227 581 52.86 1 051 922 4.79
LI2
46
CREDIT RISK
Ongoing overall South African supervisory approval of the Table CR6 provides information on the main parameters used for
approach taken by the group to model its exposure to credit risk the calculation of capital requirements for exposures under the
on the IRB approach, as well as for all credit risk models used for IRB approach. Note the following:
regulatory capital purposes, is obtained primarily by way of an •the original on-balance sheet gross exposure is gross of
annual self-assessment. The assessment addresses all aspects of accounting provisions and does not include the effect of CRM
model design, the rating structure and criteria for ratings, the techniques
assessment horizon, integrity of the rating process, governance
•the off-balance sheet exposure pre-CCF is the exposure value
around rating overrides, maintenance of data, stress tests for
without taking into account accounting provisions, CCF and
capital adequacy, integrity of estimates used and validation of the
the effect of CRM techniques
models.
•average CCF is the EAD post-conversion factor for off-balance
The technical aspects of model usage, development, monitoring sheet exposure to total off-balance sheet exposure pre-CCF
and validation are reviewed by a technical committee. The •average PD and LGD are weighted by EAD
outcomes of model technical discussions are reported to the •average maturity is provided only for those asset classes
relevant model approval committee. where it is used for the RWA calculation and is weighted
by EAD
GIA is responsible, within its regular audits, for expressing an •RWA density is total RWA to EAD post-CRM and post-CCF.
opinion on the extent of compliance with the model risk
governance framework and for reviewing model inputs.
IRB risk components The group distinguishes between through-the-cycle PDs and
Probability of default point-in-time PDs, and utilises both measures in decision-making,
PD is calculated using actual historical default rates, and in the managing credit risk exposures and measuring impairments
case of retail exposures calibrated to a specific behaviour against credit exposures.
scorecard using a monotonic calibration technique that ensures
a clear ranking of risk by mapping higher scores to lower PDs and The table below describes the internally defined relationship
vice versa. The estimates are adjusted to the long-run average between the group master rating scale, generally accepted
default rate (through-the-cycle) to cater for potential downturn defined investment grades, the group’s credit quality definitions
economic conditions. and external rating scales.
Group master
rating scale MOODY’S
CREDIT INVESTOR STANDARD
GRADING QUALITY SERVICES & POOR’S FITCH1
1–4 Aaa, Aa1, Aa2, Aa3 AAA, AA+, AA, AA- AAA, AA+, AA, AA-
Investment
5–7 A1, A2, A3 A+, A, A- A+, A, A-
grade
Normal
8 – 12 monitoring Baa1, Baa2, Baa3 BBB+, BBB, BBB- BBB+, BBB, BBB-
48
CREDIT RISK
Use of internal estimates Specialised lending’s creditworthiness is assessed on a
The group’s credit risk rating systems and processes differentiate transactional level, rather than on the financial strength of the
and quantify credit risk across counterparties and asset classes. borrower, in so far as the group relies only on repayment from the
Internal risk parameters are used extensively in risk management cash flows generated by the underlying assets financed.
and business processes, including:
•setting risk appetite Retail portfolio
Retail mortgage exposures relate to mortgage loans to individuals
•setting concentration and counterparty limits
and are a combination of both drawn and undrawn EADs.
•credit approval and monitoring
•pricing transactions Qualifying retail revolving exposure (QRRE) relates to current
•determining portfolio impairment provisions accounts, credit cards and revolving personal loans and products,
•calculating economic capital. and includes both drawn and undrawn exposures.
Retail other covers other branch lending and vehicle finance for
Key portfolio models retail, personal, and small and medium enterprise portfolios.
The group makes use of the following key models for its credit Bank lending includes both drawn and undrawn exposures, while
risk regulatory capital purposes: vehicle and asset finance only has drawn exposures.
•credit rating models for corporate exposures, with distinctions
made between South Africa, Africa Regions, small and medium Internally developed behavioural scorecards are used to measure
enterprises (SME) and Standard Bank International the anticipated performance for each account.
•for the CIB portfolio, distinct credit rating models are used for
exposures to banks, sovereigns, local government, brokers, Mapping of the behaviour score to a PD is performed for each
hedge funds, pension funds, asset managers, long- and portfolio using a statistical calibration of portfolio-specific
short-term insurers, property finance (both developer and historical default experience.
investor cash flow) and project finance respectively
The behavioural scorecard PDs are used to determine the
•in the retail and personal lending segments, behavioural portfolio distribution on the master rating scale. Separate LGD
scorecard models are used for retail cheque portfolio, retail models are used for each product portfolio and are based on
SME, card, personal loans, home loans, retail and corporate historical recovery data. EAD is measured as a percentage of the
SMEs, vehicle and asset finance, Blue Banner securitisation credit facility limit and is based on historical averages. EAD is
vehicle RC1 Proprietary Limited, pension-backed lending, estimated per portfolio and per portfolio-specific segment, using
Diners Club S.A. card and access loans. internal historical data on limit utilisation.
PD, EAD and LGD modelling is integral to all of the models and
Equity portfolio
portfolios detailed above.
Equity risk held in the banking book is substantively controlled in
accordance with the credit risk governance standard, except in so
Portfolios far as it is approved and overseen under the mandate of the ERC
Corporate, sovereign and bank portfolios rather than under the normal credit risk delegated authority
Corporate entities include large companies, as well as SMEs that structures.
are managed on a relationship basis or have a combined
exposure to the group of more than R12 million. Corporate Concentration risk
exposures also include specialised lending (project, object and
commodity finance, as well as income-producing real estate), Concentration risk is the risk of loss arising from an excessive
public sector entities and derivative trading counterparties. concentration of exposure to a single counterparty, an industry, a
product, a geography, maturity, or collateral. The group’s credit
Sovereign and bank borrowers include sovereign government risk portfolio is well diversified. The group’s management
entities, central banks, local and provincial government entities, approach relies on the reporting of concentration risk along key
bank and non-bank financial institutions. dimensions, the setting of portfolio limits and stress testing.
The creditworthiness of corporate (excluding specialised The group’s audited annual financial statements include an
lending), sovereign and bank exposures is assessed based on a industry segmental and geographical analysis of gross loans and
detailed individual assessment of the financial strength of the advances and specific credit impairments.
borrower. This quantitative analysis, together with expert
AFS Refer to annexure C in the group’s annual financial statements.
judgement and external rating agency ratings, leads to an
assignment of an internal rating to the entity.
RESTRUCTURED EXPOSURES SPLIT BETWEEN IMPAIRED AND NOT IMPAIRED (BANKING OPERATIONS)1
2017 2016
Not Not
impaired Impaired impaired Impaired
Rm Rm Rm Rm
Credit risk mitigation For trading and derivatives transactions where collateral support
is considered necessary, the group typically uses recognised and
Wherever warranted, the group will attempt to mitigate credit
enforceable international swaps and derivatives association
risk, including CCR, to any counterparty, transaction, sector, or
agreements (ISDA), with a credit support annexure.
geographic region, so as to achieve the optimal balance between
risk, cost, capital utilisation and reward. Risk mitigation may Netting agreements, such as collateral under the credit support
include the use of collateral, the imposition of financial or annexure of an ISDA agreement, are obtained only where the
behavioural covenants, the acceptance of guarantees from group firstly has a legally enforceable right to offset credit risk by
parents or third parties, the recognition of parental support, and way of such an agreement, and secondly where the group has the
the distribution of risk. intention of utilising such agreement to settle on a net basis.
Collateral, parental guarantees, credit derivatives and on- and Other credit protection terms may be stipulated, such as
off-balance sheet netting are widely used to mitigate credit risk. limitations on the amount of unsecured credit exposure
CRM policies and procedures ensure that risk mitigation acceptable, collateralisation if the mark-to-market credit
techniques are acceptable, used consistently, valued exposure exceeds acceptable limits, and termination of the
appropriately and regularly, and meet the risk requirements of contract if certain credit events occur, for example, downgrade of
operational management for legal, practical and timely the counterparty’s public credit rating.
enforcement. Detailed processes and procedures are in place to
guide each type of mitigation used. Wrong-way risk arises in transactions where the likelihood of
default (the PD) by a counterparty and the size of credit exposure
In the case of collateral where the group has an unassailable legal (as measured by EAD) to that counterparty tend to increase at
title, the group’s policy requires collateral to meet certain criteria the same time. This risk is managed both at an individual
for recognition in LGD modelling, including: counterparty level and at an aggregate portfolio level by limiting
•being readily marketable and liquid exposure to such transactions, taking adverse correlation into
•being legally perfected and enforceable account in the measurement and mitigation of credit exposure
•having a low valuation volatility and increasing oversight and approval levels. The group has no
appetite for wrong-way risk arising where the correlation between
•being readily realisable at minimum expense
EAD and PD is due to a legal, economic, strategic or similar
•having no material correlation to the obligor credit quality
relationship (specific wrong-way risk). General wrong-way risk,
•having an active secondary market for resale. which arises when the EAD and PD for the counterparty is
correlated due to macro factors, is closely managed within
The main types of collateral obtained by the group for its banking existing risk frameworks.
book exposures include:
•mortgage bonds over residential, commercial and industrial To manage actual or potential portfolio risk concentrations in
properties areas of higher credit risk and credit portfolio growth, the group
•cession of book debts implements hedging and other strategies from time-to-time. This
•pledge and cession of financial assets is done at individual counterparty, sub-portfolio and portfolio
levels through the use of syndication, distribution and sale of
•bonds over plant and equipment
assets, asset and portfolio limit management, credit derivatives
•the underlying movable assets financed under leases and and credit protection.
instalment sales.
50
CREDIT RISK
CR3: CRM TECHNIQUES – OVERVIEW (BANKING OPERATIONS)
Exposures Exposures
Exposures secured by secured by
secured by financial credit
Exposures collateral, Exposures guarantees, Exposures derivatives,
unsecured: Exposures of which secured by of which; secured of which;
carrying Exposures secured by secured financial secured by credit secured
amount1 secured1 Total collateral amount guarantees amount derivatives amount
Rm Rm Rm Rm Rm Rm Rm Rm Rm
2017
Loans 509 160 581 957 1 091 117 563 770 558 392 18 137 16 037 50 50
Debt securities 136 449 4 472 140 921 2 513 2 513 1 959 1 959
Off-balance sheet
exposures 290 621 10 782 301 403 9 220 4 630 1 562 1 292
Total 936 230 597 211 1 533 441 575 503 565 535 21 658 19 288 50 50
Of which
defaulted 1 618 12 500 14 118 12 500 1 424
2
2016
Loans 473 212 544 336 1 017 548 529 894 525 958 10 577 8 654 3 866 2 711
Debt securities 154 618 609 155 227 609 609
Off-balance sheet
exposures 275 333 13 440 288 773 11 582 9 824 1 859 1 859
Total 903 163 558 385 1 461 548 541 476 535 782 13 045 11 122 3 866 2 711
Of which
defaulted 7 876 12 996 20 872 12 996 12 996
1 Exposures are net of impairments.
2 Restated. Refer to page 101.
CR4: STANDARDISED APPROACH – CREDIT RISK EXPOSURE AND CRM EFFECTS (BANKING OPERATIONS)
Exposures Exposures RWA and
pre-CCF and pre-CRM post-CCF and post-CRM RWA density
2017
Corporate 49 090 23 184 42 195 7 922 47 836 95
SME corporate 36 651 18 322 35 703 4 535 41 094 102
Public sector entities 3 879 595 3 879 316 3 824 91
Local governments and municipalities 78 76 40 53
Sovereign 130 823 130 823 94 478 72
Banks 13 850 11 584 13 835 4 202 8 054 45
Securities firms 5 5 2 40
Retail mortgage advances 17 138 1 344 16 934 724 12 313 70
Retail revolving credit 4 089 692 3 910 3 732 95
SME retail 9 939 6 326 9 466 1 882 13 806 122
Other retail 15 915 3 601 15 520 956 16 722 101
Other assets 70 236 70 236 26 023 38
Total 351 693 65 648 342 582 20 537 267 924 74
Sum of exposures post-CCF and
post-CRM 363 119
LI2 OV1
CR5
2016
Corporate 46 286 19 022 42 254 10 445 45 321 86
SME corporate 43 349 19 793 43 349 594 46 199 105
Public sector entities 4 780 1 335 4 780 470 4 047 77
Local governments and municipalities 80 80 42 53
Sovereign 98 881 14 98 868 77 821 79
Banks 21 431 8 838 21 432 5 261 11 912 45
Securities firms 5 590 5 190 148 76
Retail mortgage advances 16 053 1 446 16 053 822 9 363 55
Retail revolving credit 18 783 2 158 18 783 21 011 112
SME retail 9 558 6 592 9 558 4 025 13 673 101
Other retail 2 564 1 404 2 564 427 2 125 71
Other assets 80 599 80 599 26 864 33
Total 342 369 61 192 338 325 22 234 258 526 72
Sum of exposures post-CCF and
post-CRM 360 559
LI2 OV1
CR5
52
CREDIT RISK
CR7: IRB – EFFECT ON RWA OF CREDIT DERIVATIVES USED AS CRM TECHNIQUES (BANKING OPERATIONS)
2017 2016
Pre-credit Pre-credit1
derivatives Actual derivatives Actual
RWA RWA RWA RWA
Rm Rm Rm Rm
The table that follows explains the variations in credit RWA under the IRB approach attributable to each of the key risk drivers. Note the
following:
•asset size represents organic changes in the book size and composition
•asset quality represents changes due to changes in borrower risk, such as risk grade migration or similar effects
•foreign exchange movements are changes driven by changes in foreign exchange rates.
CR8: IRB – RWA FLOW STATEMENTS OF CREDIT RISK EXPOSURES (BANKING OPERATIONS)
2017 2016
RWA RWA
amounts amounts
Rm Rm
The table below provides backtesting data to validate the reliability of PD calculations.
Current weighted average PD estimates are determined at the beginning of a 12-month horizon using the calibrated regulatory models.
The models are calibrated to actual long-run default experience to ensure stable regulatory estimates over a complete credit cycle.
The PD estimates would thus tend to underestimate actual default experience at the top of the cycle and overestimate actual default
experience at the bottom of the credit cycle. The average historical default rate is the actual, annual default rate experience, averaged
over a five-year period.
2017
Bank 0.03%; 10.24% BBB 0.25% 0.34%
Corporate 0.01%; 40.96% BB 0.93% 1.49%
Sovereign 0.01%; 1.81% BB+ 0.05% 0.39%
Corporate specialised lending 0.11%; 14.48% BB+ 0.94% 0.99%
High volatility commercial real estate 0.45%; 3.62% BB 1.41% 1.41%
Income-producing real estate 0.11%; 14.48% BB+ 0.81% 1.00%
Project finance 0.23%; 7.24% BB+ 1.05% 0.87%
Retail mortgages 0.035% – 100% Ba1 3.26% 3.10%
Retail other 0.123% – 100% Ba3 5.02% 9.68%
Retail SME 0.030% – 100% Ba2 2.95% 4.12%
QRRE 0.030% – 100% B1 4.76% 5.48%
2016
Bank 0.03%; 10.24% BBB+ 0.15% 0.2%
Corporate 0.01%; 40.96% BB 0.85% 1.18%
Sovereign 0.01%; 1.81% BB+ 0.04% 0.47%
Corporate specialised lending 0.11%; 14.48% BB+ 1.08% 1.10%
High volatility commercial real estate 0.45%; 3.62% B+ 2.32% 3.02%
Income-producing real estate 0.11%; 14.48% BB+ 1.10% 0.89%
Project finance 0.23%; 7.24% BB 1.21% 0.87%
Retail mortgages 0.035% – 100% Ba1 3.38% 3.20%
Retail other 0.123% – 100% Ba3 4.83% 10.26%
Retail SME 0.030% – 100% Ba2 2.93% 3.92%
QRRE 0.030% – 100% B1 4.78% 5.19%
1 The dimension portfolio includes the following prudential portfolios for the foundation IRB (FIRB) approach:
(i) sovereign; (ii) banks; (iii) corporate; (iv) corporate – specialised lending; (v) equity (PD/LGD method); (vi) purchased receivables, and the following prudential
portfolios for the AIRB approach: (i) sovereign; (ii) banks; (iii) corporate; (iv) corporate – specialised lending; (v) equity (PD/LGD method); (vi) retail – QRRE; (vii) retail –
residential mortgage exposures; (viii) retail – SME; (ix) other retail exposures; and (x) purchased receivables.
• Weighted average PD: excludes defaults and is therefore not the same as CR6
• Arithmetic average PD by obligors: PD within range by number of obligor within the range
• Defaulted obligors in the year: number of defaulted obligors during the year; of which: new obligors defaulted in the year: number of obligors having defaulted during
the last 12-month period that were not funded at the end of the previous financial year
• Average historical annual default rate: the five-year average of the annual default rate (obligors at the beginning of each year that defaulted during that year/total
obligor held at the beginning of the year) is a minimum.
54
CREDIT RISK
Number of obligors
Of which:
End of End of Defaulted obligors new defaulted Average historical
previous year the year in the year obligors in the year annual default rate
CR10: IRB EQUITIES UNDER THE SIMPLE RISK WEIGHT METHOD (BANKING OPERATIONS)
On-
balance
sheet Risk
amount weight RWA
Categories Rm % Rm
2017
Exchange-traded equity exposures
Private equity exposures 1 451 400 6 154
Total 1 451 6 154
LI2 OV1
2016
Exchange-traded equity exposures 300
Private equity exposures 1 454 400 6 167
Total 1 454 6 167
LI2 OV1
Counterparty credit risk For trades that are not subject to margining requirements, the
replacement cost is the loss that would occur if a counterparty
The group is exposed to CCR through movements in the fair
were to default and its transactions closed immediately. For
value of securities financing and derivatives contracts. The risk
margined trades, it is the loss that would occur if a counterparty
amounts reflect the aggregate replacement costs that would be
were to default at the current or future date, assuming that the
incurred by the group in the event of counterparties defaulting on
closeout and replacement of transactions occur instantaneously.
their obligations.
However, the close-out of a trade upon a counterparty default
may not be instantaneous. The replacement cost under the
The group’s exposure to CCR is affected by the nature of the
current exposure method is determined by marking contracts
trades, the creditworthiness of the counterparty, and underlying
to market.
netting and collateral arrangements. CCR is measured in PFE
terms and recognised on a net basis where netting agreements
PFE is any potential increase in exposure between the present
are in place and are legally enforceable, or otherwise on a gross
and up to the end of the margin period of risk. The PFE for the
basis. Exposures are generally marked-to-market daily. Cash or
current exposure method is determined by applying a prescribed
near cash collateral is posted where contractually provided for.
add-on factor to the underlying notional amount to determine
the PFE over the life of the contract.
Demand for economic capital, as a risk appetite dimension, is
allocated to risk types (including CCR) in accordance with the
Effective expected positive exposure is the weighted average over
group risk appetite governance framework, and serves as the
time of the effective expected exposure over the first year, or, if all
basis for the setting of internal CCR appetite limits against which
the contracts in the netting set mature before one year, over the
aggregate risk type exposure can be measured.
time period of the longest-maturity contract in the netting set
where the weights are the proportion that an individual expected
CCR, reflecting both pre-settlement and settlement risk, is
exposure represents of the entire time interval.
subjected to explicit credit limits which are formulated and
approved for each counterparty and economic group, with
EAD post-CRM refers to the amount that is relevant for the
specific reference to its credit rating and other credit exposures
capital requirements calculation having applied CRM techniques,
to that counterparty.
credit valuation adjustments (CVA) and specific wrong-way
adjustments.
In the event of a rating downgrade, the collateral that the group
would have to provide is dependent on a number of variables,
including the netting of existing positions and a reduction in the
threshold above which collateral would have to be posted with
counterparties to cover the group’s negative mark-to-market.
With respect to additional collateral that the group may be
required to lodge with trading counterparties in the event of a
rating downgrade, refer to page 78.
56
CREDIT RISK
CCR1: ANALYSIS OF CCR EXPOSURE BY APPROACH (BANKING OPERATIONS)
Alpha
Potential used for
Replacement future computing EAD
cost exposure regulatory post-CRM RWA
Rm Rm EAD Rm Rm
2017
Current exposure method (for derivatives) 73 001 42 623 1.4 28 985 12 563
Comprehensive approach for CRM (for SFTs) 5 037 1 475
Total 73 001 42 623 34 022 14 038
CVA from CCR2 10 132
CCP and default funds from CCR8 179
Total 1.4 24 349
LI2 LI2 OV1
20161
Current exposure method (for derivatives) 61 752 53 787 1.4 35 081 11 605
Comprehensive approach for CRM (for SFTs) 9 120 2 488
Total 61 752 53 787 44 201 14 093
CVA from CCR2 6 827
CCP and default funds from CCR8 264
Total 1.4 21 184
LI2 LI2 OV1
1 Restated. Refer to page 101.
EAD EAD
post-CRM RWA post-CRM RWA
Rm Rm Rm Rm
All portfolios subject to the standardised CVA capital charge 28 985 10 132 33 378 6 827
Total subject to the CVA capital charge 28 985 10 132 33 378 6 827
CCR1 CCR1
1 Restated. Refer to page 101.
CCR3: STANDARDISED APPROACH – CCR EXPOSURES BY REGULATORY PORTFOLIO AND RISK WEIGHTS
(BANKING OPERATIONS)
2017
Regulatory portfolios
Corporate
SME corporate
Public sector entities
Local governments and municipalities
Sovereign
Banks 323 484
Securities firms 85
Retail exposure
Retail mortgage advances
Retail revolving credit
SME retail
Other retail
Securitisation and re-securitisation exposure
Total 323 569
EAD
Total
2016
Regulatory portfolios
Corporate
SME corporate
Public sector entities
Local governments and municipalities
Sovereign
Banks 546 151
Securities firms 210 34
Retail exposure
Retail mortgage advances
Retail revolving credit
SME retail
Other retail
Securitisation and re-securitisation exposure
Total 756 185
EAD
Total
58
CREDIT RISK
Total credit
100% 150% 225% 350% 650% 1 250% Others exposure
1 542 7 1 549
421 421
286 286
807
85
6 6
2 255 7 3 154
LI2
30 868 CCR4/LI2
34 022 CCR1/LI2
1 402 1 402
200 200
5 5
1 1
610 610
237 934
244
2 455 3 396
LI2
40 805 CCR4/LI2
44 201 CCR1/LI2
The table below provides information on all the relevant parameters used for the calculation of CCR capital requirements under the IRB
approach. To note:
•EAD post-CRM is the EAD as calculated under the applicable CCR approach and after applying CRM but gross of accounting
provisions
•number of obligors correspond to the number of individual PDs in a band
•average PD and LGD are weighted by EAD
•RWA density is total RWA to EAD post-CRM
CCR4: IRB – CCR EXPOSURES BY PORTFOLIO AND PD SCALE (TOTAL)1 (BANKING OPERATIONS)
EAD Average Average Average RWA
post-CRM PD Number of LGD maturity RWA density
PD scale Rm % obligors % Years Rm %
2017
0.00 to < 0.15 17 525 0.05 73 37.90 1.6 3 152 17.99
0.15 to < 0.25 2 498 0.22 53 32.33 2.3 862 34.49
0.25 to < 0.50 7 388 0.43 184 40.80 1.7 4 705 63.71
0.50 to < 0.75 1 817 0.64 96 36.80 2.9 1 302 71.63
0.75 to < 2.50 1 398 1.32 154 35.28 2.5 1 137 81.31
2.50 to < 10.00 236 3.18 58 38.84 1.2 251 105.97
10.00 to < 100.00 6 37.10 6 37.58 1.0 13 198.34
100.00 (default) 100.00 2 40.09 1.0 1 531.19
Total 30 868 0.28 626 37.97 1.8 11 423 37.01
CCR3/LI2
2016
0.00 to < 0.15 27 975 0.06 74 39.28 1.6 5 819 0.21
0.15 to < 0.25 6 056 0.18 66 38.74 1.9 2 263 0.37
0.25 to < 0.50 4 382 0.39 171 35.66 1.8 1 870 0.43
0.50 to < 0.75 774 0.64 95 36.44 2.7 511 0.66
0.75 to < 2.50 1 179 1.28 156 44.73 1.7 1 075 0.91
2.50 to < 10.00 439 3.44 65 38.41 1.2 468 1.07
10.00 to < 100.00
100.00 (default)
Total 40 805 0.19 627 39.04 1.70 12 006 0.30
CCR3/LI2
1 Refer to annexure B for exposures by portfolio.
60
CREDIT RISK
Table CCR5 discloses a breakdown of all types of collateral posted or received to support or reduce the counterparty credit risk
exposures related to derivative and securities financing transactions. The total collateral posted or received is reflected.
2017
Cash – domestic currency 7 924 3 166 34 620 21 531
Cash – other currencies 1 612 8 580 31 946
Domestic sovereign debt 755 8 098 11 215
Other sovereign debt 4 508
Government agency debt 41 38
Corporate bonds 24 807 1 140
Equity securities 794 3 191 5 657
Other collateral 15 240 16 799
Total 11 085 11 746 90 505 88 326
2016
Cash – domestic currency 6 478 2 220 31 455 15 215
Cash – other currencies 2 172 9 863 108 695
Domestic sovereign debt 2 022 1 8 853
Other sovereign debt 53 990
Government agency debt 850
Corporate bonds 55 556 313
Equity securities 576 11 030 8 152
Other collateral 5 807 13 234
Total 11 248 12 083 158 689 154 462
1 Per the requirement of the framework, collateral includes both cash and securities that are subject to the transaction. Collateral items are presented at fair value and
gross of haircuts.
2 Unsegregated refers to collateral not held in a bankruptcy-remote manner.
The table that follows details the group’s exposure to credit derivatives with a distinction made between protection bought and sold.
Notionals
Single-name credit default swaps1 5 870 26 698 5 520 36 131
Index credit default swaps 3 060 4 211 4 047 4 926
Total return swaps 2 875 1 014 865 259
Other credit derivatives 24 830 2 411 27 904 4 175
Total notionals 36 635 34 334 38 336 45 491
Fair values
Positive fair value (asset) 432 366 3 456 199
Negative fair value (liability) 669 498 2 595 1 464
1 Restated. Refer to page 101.
EAD EAD
(post-CRM) RWA (post-CRM) RWA
Rm Rm Rm Rm
CCR1 CCR1
62
CREDIT RISK
SEC1: SECURITISATION EXPOSURES IN THE BANKING BOOK (BANKING OPERATIONS)
Bank acts as originator Bank acts as sponsor
Traditional Traditional
Rm Rm
2017
Retail (other) – of which: 50 485 3 818
residential mortgages 50 485 3 061
other retail exposures 288
re-securitisation 469
Wholesale (total) – of which: 1 511
loans to corporates
re-securitisation 1 511
2016
Retail (other) – of which: 19 099 4 492
residential mortgages 19 099 3 562
other retail exposures 204
re-securitisation 726
Wholesale (total) – of which: 2 031
re-securitisation 2 031
For originated and sponsored or administered securitisations For local securitisations in South Africa, Moody’s Investor
consolidated under IFRS (that is, BG 1 – 4, Siyakha and BTC), Services and/or Global Ratings Company act as rating agencies.
intragroup exposures to and between these securitisations have
been eliminated and the underlying assets consolidated in the The transfer of assets by the group to an SE may give rise to the
relevant sections and classes in this report. Only exposures to full or partial derecognition of the financial assets concerned.
securitisations of assets originated by third-parties are disclosed Only in the event that derecognition is achieved are sales and any
below. The approach applied in the calculation of RWA is resultant gains or losses on disposals recognised in the financial
dependent on the group’s approved model for the underlying statements. Where the SEs are consolidated at group level, such
assets and the existence of a rating from an eligible external gains or losses are eliminated.
credit assessment institution.
SEC3: SECURITISATION EXPOSURES IN THE BANKING BOOK AND ASSOCIATED REGULATORY CAPITAL
REQUIREMENTS – BANK ACTING AS ORIGINATOR OR AS SPONSOR (BANKING OPERATIONS)
Exposure values RWA
Exposure values (by regulatory (by regulatory Capital charge after
(by RW1 bands) approach) approach) cap
2017
Total exposures 3 111 706 1 013 2 804 394 353 46 41
Traditional securitisation 3 111 706 1 013 2 804 394 353 46 41
Of which securitisation 3 111 238 1 013 2 336 394 180 46 21
Of which retail underlying 3 111 238 1 013 2 336 394 180 46 21
Of which wholesale
Of which re-securitisation 468 468 173 20
Of which senior
Of which non-senior 468 468 173 20
Synthetic securitisation
Of which securitisation
Of which retail underlying
OV1 OV1
2016
Total exposures 4 094 10 387 881 3 610 228 450 24 47
Traditional securitisation 4 094 10 387 881 3 610 228 450 24 47
Of which securitisation 3 516 10 234 881 2 879 228 219 24 23
Of which retail underlying 3 516 10 234 881 2 879 228 219 24 23
Of which wholesale
Of which re-securitisation 578 153 731 231 24
Of which senior 153 153 121 13
Of which non-senior 578 578 110 11
Synthetic securitisation
Of which securitisation
Of which retail underlying
OV1 OV1
1 Risk weight.
2 Ratings-based approach.
3 Internal assessment approach.
4 Supervisory formula approach.
64
CREDIT RISK
INSURANCE OPERATIONS Reinsurance
Reinsurance is used to manage insurance risk and consequently,
Consolidated mutual funds in the liability valuation process, reinsurance assets are raised for
Liberty invests in mutual funds through which it is also exposed expected recoveries on projected claims. This does not, however,
to the credit risk of the underlying assets in which the mutual discharge Liberty’s liability as primary insurer. In addition,
funds are invested. Liberty’s exposure to mutual funds is reinsurance debtors are raised for specific recoveries on claims
classified at fund level and not at the underlying asset level and, recognised.
although mutual funds are not rated, fund managers are required
to invest in credit assets within the defined parameters stipulated A detailed credit analysis is conducted prior to the appointment
in the fund’s mandate. These rules limit the extent to which fund of reinsurers, as well as an annual analysis thereafter. Cognisance
managers can invest in unlisted and/or unrated credit assets and is also taken of the potential future claims on reinsurers in the
generally restrict funds to the acquisition of investment grade assessment process. Financial position strength, performance,
assets. track record, relative size, ranking within the industry and credit
standing of reinsurers are taken into account when determining
Liberty is exposed to CCR in respect of investment reinsurance the allocation of business to reinsurers. In addition, efforts are
policies, as well as the underlying debt instruments supporting made to appropriately diversify exposure by using several
the valuation of the policy. reinsurers.
DEFINITION
Compliance risk is the risk of legal or regulatory
sanction, financial loss or damage to reputation
that the group may suffer as a result of its
failure to comply with laws, regulations, codes
of conduct and standards of good practice
applicable to its financial services activities.
COMPLIANCE
RISK
67 APPROACH TO MANAGING
COMPLIANCE RISK
67 GOVERNANCE
66
COMPLIANCE RISK
APPROACH TO MANAGING embedding good conduct is accentuated and strengthened by
the group’s ethical culture as articulated in the code of ethics and
COMPLIANCE RISK values. Initiatives are aligned to the pending regulatory reforms
that will provide for separate prudential and conduct authorities.
General approach
The compliance function is mandated by the GAC to operate Approach to managing money laundering
independently of business as a second line of defence function, in and terrorist financing
terms of the requirements of the Banks Act and regulations.
The AML and CFT legislative regime provides for a rules-based
The management of compliance risk is standardised across the approach to compliance.
group and is premised on internationally accepted principles of
The South African Financial Intelligence Centre Act has been
compliance risk management for financial service providers and
amended to incorporate a risk-based approach to compliance in
supervisory and client expectations.
relation to the AML/CFT regulatory framework. This includes the
Compliance risk management is a core risk management activity requirement for developing, documenting, maintaining and
overseen by the GCCDO. The GCCDO has unrestricted access to implementing a risk management and compliance programme
the chairman of the GAC and is a standing attendee at GAC that must demonstrate the group’s ability to effectively apply a
meetings. The GCCDO has a functional reporting line to the chief risk-based approach.
executive and is a member of various group management
An implementation programme with an impact analysis that will
committees, including the group executive committee, the group
ensure that the group continues to be aligned with all regulatory
management committee, GROC, and the group social and ethics
requirements is in progress.
committee.
COUNTRY
RISK
69 APPROACH TO MANAGING
COUNTRY RISK
69 GOVERNANCE
69 APPROVED REGULATORY CAPITAL
APPROACHES
70 COUNTRY RISK PORTFOLIO
CHARACTERISTICS AND METRICS
68
COUNTRY RISK
APPROACH TO MANAGING GOVERNANCE
COUNTRY RISK The primary management level governance committee
overseeing this risk type is the group country risk management
All countries to which the group is exposed are reviewed at least committee.
annually. Internal rating models are employed to determine
ratings for jurisdiction, sovereign and transfer and convertibility The principal governance document is the country risk
risk. In determining the ratings, extensive use is made of the governance standard.
group’s network of operations, country visits and external
information sources. These ratings are also a key input into the
group’s credit rating models. APPROVED REGULATORY
The model inputs are continuously updated to reflect economic
CAPITAL APPROACHES
and political changes in countries. The model outputs are internal There are no regulatory capital requirements for country risk.
risk grades that are calibrated to a jurisdiction risk grade from
aaa to d, as well as sovereign risk grade, and transfer and Country risk is, however, incorporated into regulatory capital for
convertibility risk grade (SB) from SB01 to SB25. Countries with credit in the IRB approaches through the jurisdiction risk and
sovereign/jurisdiction risk ratings weaker than SB07/a, referred transfer and convertibility risk ratings’ impact on credit grades.
to as medium- and high-risk countries, are subject to more
detailed analysis and monitoring.
2017
Risk grade
SB01 – SB07 0.58 23.97 1.40 26.04 1.63 10.71
SB08 – SB11 4.61 0.92 0.15
SB12 – SB14 8.01 0.71 0.17
SB15 – SB17 15.91
SB18 – SB21 0.95 0.33
SB22+ 3.91
20161
Risk grade
SB01 – SB07 0.80 26.63 1.12 19.67 2.04 4.92
SB08 – SB11 5.65 0.29 1.15
SB12 – SB14 9.17 0.12
SB15 – SB17 21.56
SB18 – SB21 4.63 0.56 0.80
SB22+ 0.89
1 Restated. Refer to page 101.
18
15
12
Exposure to the top five medium- and high-risk countries is shown together with comparatives in the graph on the following page.
These exposures are in line with the group’s growth strategy, which is focused on Africa.
70
COUNTRY RISK
Top five medium- and high-risk country EAD (USDm)
2 000
1 750
1 500
1 250
1 000
750
500
250
QQ2017 QQ2016
30
25
20
15
10
SB08 SB09 SB10 SB11 SB12 SB13 SB14 SB15 SB16 SB17 SB18 SB19 SB20 SB21 SB22+
QQ2017 QQ20161
1 Restated. Refer to page 101.
FUNDING AND
LIQUIDITY RISK
73 BANKING OPERATIONS
73 Approach to managing liquidity risk
74 Governance
74 Liquidity characteristics and metrics
77 The group’s credit ratings
78 Conduits
78 INSURANCE OPERATIONS
78 Long-term insurance
78 Short-term insurance
72
FUNDING AND LIQUIDITY RISK
BANKING OPERATIONS geographies across both the corporate and retail sectors to
ensure that payment obligations can be met by the group’s legal
Approach to managing liquidity risk entities, under both normal and stressed conditions and that
regulatory minimum requirements are met at all times. This is
The nature of the group’s banking and trading activities gives rise achieved through a combination of maintaining adequate liquidity
to continuous exposure to liquidity risk. Liquidity risk may arise buffers, to ensure that cash flow requirements can be met, and
where counterparties, who provide the group with short-term ensuring that the group’s SOFP is structurally sound and
funding, withdraw or do not roll over that funding, or normally supportive of the group’s strategy. Liquidity risk is managed on a
liquid assets become illiquid as a result of a generalised consistent basis across the group’s banking subsidiaries, allowing
disruption in asset markets. for local requirements. Liquidity risk management ensures that
the group has the appropriate amount, diversification and tenor
The group manages liquidity in accordance with applicable of funding and liquidity to support its asset base at all times.
regulations and within the group’s risk appetite framework.
The group’s liquidity risk management governance framework The group manages liquidity risk as three interrelated pillars,
supports the measurement and management of liquidity, in all which are aligned to the Basel III liquidity requirements.
The funding and liquidity risk disclosure is based on Basel III The group exceeded the 80% minimum phase-in requirement
principles, including behavioural profiling methods and for 2017 with a ratio of 135.1% (2016: 117.1%).
assumptions, as well as phasing-in requirements where applicable.
The group successfully managed the balance sheet structure and
The LCR is a metric introduced by the BCBS to measure a bank’s achieved NSFR compliance with effect from 1 January 2018
ability to manage a sustained outflow of customer funds in an within specified risk appetite and regulatory requirements. This
acute stress event over a 30-day period. The ratio is calculated metric is designed to ensure that the majority of term assets are
by taking the group’s high-quality liquid assets (HQLA) and funded by stable sources, such as capital, term borrowings or
dividing it by net cash outflows. The minimum regulatory LCR other stable funds.
requirement for 2017 was 80%, increasing by 10% annually to
reach 100% by 1 January 2019.
Governance
The primary governance committee overseeing liquidity risk is the group ALCO. ALCOs have been established in each of the group’s
banking subsidiaries and manage in-country liquidity risk.
The principal governance documents are the liquidity risk governance standard and model risk governance framework.
Contingency liquidity risk management Liquidity stress testing and scenario analysis
Contingency funding plans Stress testing and scenario analysis are based on hypothetical
Contingency funding plans are designed to protect stakeholder and historical events. These are conducted on the group’s
interests and maintain market confidence in the event of a funding profiles and liquidity positions. The crisis impact is
liquidity crisis. The plans incorporate an early warning indicator typically measured over a 30 calendar-day period as this is
process supported by clear crisis response strategies. Early considered the most crucial time horizon for a liquidity event.
warning indicators cover bank-specific and systemic crises and This measurement period is also consistent with the Basel III
are monitored according to assigned frequencies and tolerance LCR requirements.
levels.
Anticipated on- and off-balance sheet cash flows are subjected to
Crisis response strategies are formulated for the relevant crisis a variety of bank-specific and systemic stresses and scenarios to
management structures and address internal and external evaluate the impact of unlikely but plausible events on liquidity
communications and escalation processes, liquidity generation positions. The results are assessed against the liquidity buffer
management actions and operations, and heightened and and contingency funding plans to provide assurance as to the
supplementary information requirements to address the crisis group’s ability to maintain sufficient liquidity under adverse
event. The updating of contingency funding plans, while conditions.
considering budget forecasting, continues to be a focus area for
the asset liability management teams across the group. Internal stress testing metrics are supplemented with the
regulatory Basel III LCR in monitoring the group’s ability to
The group, in line with the SARB’s requirements, updates and survive severe stress scenarios.
submits its recovery and resolution plans to the SARB on an
annual basis. The group’s recovery plan incorporates the The Basel III LCR analysis that follows includes banking and/or
contingent liquidity funding plan in addition to the focus given to deposit taking entities and represents an aggregation of the
capital planning and business continuity planning. relevant individual net cash outflows and HQLA portfolios. These
results reflect the simple average of 92 days of daily observations
over the quarter ended 31 December 2017 and the simple
average of the three month-end data points for the quarter
ended 31 December 2016.
74
FUNDING AND LIQUIDITY RISK
LCR
20171 20162
HQLA
Total HQLA 240 935 208 656
Cash outflows 1 393 532 338 822 1 319 414 362 115
Retail deposits and deposits from small business customers, of
which: 428 381 31 784 345 433 29 263
5
Stable deposits 14 425 721 8 482 424
Less stable deposits5 413 956 31 063 336 951 28 839
Unsecured wholesale funding, of which: 538 457 266 296 555 618 293 451
Operational deposits (all counterparties) and deposits
in networks of cooperative banks 165 342 41 336 152 696 38 174
Non-operational deposits (all counterparties) 372 884 224 729 402 822 255 177
Unsecured debt 231 231 100 100
Secured wholesale funding 2 11
Additional requirements 107 747 26 684 115 915 24 234
Outflows related to derivative exposures and other
collateral requirements 14 151 14 142 26 307 12 448
Outflows related to loss of funding on debt products 3 012 3 012 2 995 2 995
Credit and liquidity facilities 90 584 9 530 86 613 8 791
Other contractual funding obligations 2 273 2 273 4 228 4 228
Other contingent funding obligations 316 674 11 783 298 220 10 928
Cash inflows 202 554 160 485 227 530 183 984
Total Total
adjusted value6 adjusted value6
Rm Rm
The group seeks to exceed the minimum LCR requirement with a The graph that follows shows the group’s cumulative maturity
sufficient buffer to allow for funding flow volatility as determined mismatch between assets and liabilities for the 0 to 12 months
by its internal liquidity risk appetite. A buffer is maintained above maturity bucket, after applying behavioural profiling. The
the minimum regulatory requirement to cater for balance sheet cumulative maturity is expressed as a percentage of the group’s
and market volatility. total funding-related liabilities.
Total contingent liquidity Expected aggregate cash outflows are subtracted from expected
Portfolios of marketable and liquid instruments to meet aggregate cash inflows. These mismatches are monitored on a
regulatory and internal stress testing requirements are regular basis with active management intervention, if potential
maintained as protection against unforeseen disruptions in cash risk appetite breaches are evidenced. Liquidity transfer
flows. These portfolios are managed within ALCO-defined limits restrictions across the group are considered as part of the
on the basis of diversification and liquidity. prudent liquidity risk management assumptions that are
followed.
The table below provides a breakdown of the group’s liquid
and marketable instruments as at 31 December 2017 and The group’s cumulative liquidity mismatch remains within
31 December 2016. Eligible Basel III LCR HQLA are defined liquidity risk appetite and is well positioned for NSFR compliance
according to the BCBS January 2013 LCR and liquidity risk with effect from January 2018.
monitoring tools framework. Managed liquidity represents
unencumbered marketable instruments other than eligible While following a consistent approach to liquidity risk
Basel III LCR HQLA (excluding trading assets) which would be management in respect of the foreign currency component of the
able to provide sources of liquidity in a stress scenario. SOFP, specific indicators are observed in order to monitor
changes in market liquidity, as well as the impacts on liquidity as
TOTAL CONTINGENT LIQUIDITY a result of movements in exchange rates.
1
Eligible LCR HQLA comprising: 251.3 220.4 8
76
FUNDING AND LIQUIDITY RISK
Funding diversification by product (%) from increased demand for bank term issuance. Cost of liquidity
in money markets measured by the 12-month NCD cost traded in
a tight range during 2017. Marginal widening of term funding
spreads was experienced in the final quarter driven largely by
political risk and market credit events.
2017 2016
SBSA 12- and 60-month liquidity spread (bps)
180
160
140
2017 2016
Call deposits 25 24 120
Term deposits 19 19 100
Current accounts 17 16
Cash management deposits 13 13 80
Deposits from banks and central banks1 7 10 60
Negotiable certificates of deposits 11 10
40
Senior and subordinated debt 6 6
Savings accounts 2 2 20
2017 2016
% %
LONG-TERM MOODY’S
Single depositor (limit 10%) 1.7 2.4
Top 10 depositors (limit 20%) 7.6 9.5 Group issuer rating Ba1
The group successfully increased the longer-term funding during Credit ratings for SBSA are dependent on multiple factors,
2017, raising R32.4 billion through a combination of senior debt including the South African sovereign rating, capital adequacy
and syndicated loans. An additional R24.6 billion was raised levels, quality of earnings, credit exposure, the credit risk
through NCDs in excess of 12 months. The group issued governance framework and funding diversification. These
R3.5 billion of Basel III compliant AT1 bond instruments in 2017, parameters and their possible impact on the borrowing entity’s
the proceeds of which have been invested as AT1 in SBSA. credit rating are monitored closely and incorporated into the
group’s liquidity risk management and contingency planning
The graph that follows is a representation of the market cost of considerations.
liquidity, which is measured as the spread paid on NCDs relative
to the prevailing reference rate. The graph is based on actively- The foreign and local currency ratings downgrades in the first
issued money market instruments by banks, namely 12- and half of 2017 have had a more benign impact than previously
60-month NCDs. For the period under review, market cost of anticipated on the availability and cost of foreign currency
liquidity compressed in the 60-month tenor, as banks benefited funding. This was largely due to the supportive global liquidity
Conduits
The group provides standby liquidity facilities to two conduits,
namely BTC and Thekwini Warehouse Conduit.
INSURANCE OPERATIONS
Long-term insurance
Refer to annexure C of the AFS for Liberty’s liquidity risk
disclosures.
Short-term insurance
SIL’s investments are made considering the nature, term and
uncertainty of its liabilities. SIL manages its liquidity risk in
accordance with its risk appetite statement. This covers
monitoring available liquid assets against immediate expenses
such as operational expenses, technical provisions for claims
outstanding and any outstanding reinsurance premium. SIL also
includes the impact of unexpected losses from several
catastrophic events in its liquidity risk management. SIL manages
liquidity risk on a stand-alone basis such that no reliance is
placed on the group to provide contingent funding to the
insurance entity.
78
FUNDING AND LIQUIDITY RISK
MARKET RISK
80 BANKING OPERATIONS
80 Approved regulatory capital
approaches
80 Governance
80 Trading book market risk
83 Post-employment obligation risk
83 INSURANCE OPERATIONS
83 Long-term insurance
85 Short-term insurance
BANKING OPERATIONS
Approved regulatory capital approaches
The group has approval from the SARB to adopt the internal models approach for most asset classes and across most market variables
in SBSA with the balance on the standardised model.
For material equity portfolios, the group has approval from the SARB to adopt either the market-based or PD/LGD approach.
There are no regulatory capital requirements for interest rate risk in the banking book (IRRBB), structural foreign exchange exposures or
own equity-linked transactions. The group does not apply the incremental risk charge or comprehensive risk capital charge approach.
Governance
The governance management level committees overseeing market risk are group ALCO.
The principal governance documents are the market risk governance standard and the model risk governance framework.
80
MARKET RISK
MR2: RWA FLOW STATEMENTS OF MARKET RISK EXPOSURES UNDER IMA
Total
VaR SVaR RWA
Rm Rm Rm
Approach to managing market risk in the Daily losses exceeding the VaR are likely to occur, on average,
trading book 13 times in every 250 days.
The group’s policy is that all trading activities are undertaken
SVaR uses a similar methodology to VaR, but is based on a
within the group’s global markets’ operations.
251-day period of financial stress which is reviewed quarterly and
assumes a ten-day holding period and a worst case loss. The
The market risk functions are independent of the group’s trading
ten-day period is based on the average expected time to reduce
operations and are accountable to the relevant legal entity
positions. The period of stress for SBSA is currently the
ALCOs. ALCOs have a reporting line into group ALCO, a
2008/2009 financial crises while, for other markets, more recent
subcommittee of GROC.
stress periods are used.
All VaR and SVaR limits require prior approval from the respective
Where the group has received internal model approval, the
entity ALCOs. The market risk functions have the authority to set
market risk regulatory capital requirement is based on VaR and
these limits at a lower level.
SVaR, both of which use a confidence level of 99% and a ten-day
Exposures and excesses are monitored and reported daily. Where holding period.
breaches in VaR or SVaR limits occur, actions are taken by market
Limitations of historical VaR are acknowledged globally
risk functions to bring exposures back in line with approved
and include:
market risk appetite, with such breaches being reported to
management and entity ALCOs. •the use of historical data as a proxy for estimating future
events may not encompass all potential events, particularly
Measurement those which are extreme in nature
The techniques used to measure and control trading book •the use of a one-day holding period assumes that all positions
market risk and trading volatility include VaR and SVaR, stop-loss can be liquidated or the risk offset in one day. This will usually
triggers, stress tests, backtesting and specific business unit and not fully reflect the market risk arising at times of severe
product controls. illiquidity, when a one-day holding period may be insufficient to
liquidate or hedge all positions fully
VaR and SVaR •the use of a 95% confidence level, by definition, does not take
The group uses the historical VaR and SVaR approach to quantify into account losses that might occur beyond this level of
market risk under normal and stressed conditions. confidence.
For risk management purposes VaR is based on 251 days of VaR is calculated on the basis of exposures outstanding at the
unweighted recent historical data updated at least monthly, a close of business and, therefore, does not necessarily reflect
holding period of one day and a confidence level of 95%. The intra-day exposures. VaR is unlikely to reflect loss potential on
historical VaR results are calculated in four steps: exposures that only arise under significant market movements.
•calculate 250 daily market price movements based on 251
Trading book credit risk
days’ historical data. Absolute movements are used for interest
rates and volatility movements; relative for spot, equities, Credit issuer risk is assumed in the trading book by virtue of
credit spreads, and commodity prices normal trading activity, and is managed according to the group’s
market risk governance standard. These exposures arise from,
•calculate hypothetical daily profit or loss for each day using
among others, trading in debt securities issued by corporate and
these daily market price movements
government entities, as well as trading credit derivative
•aggregate all hypothetical profits or losses for day one across transactions with other banks and corporate clients.
all positions, giving daily hypothetical profit or loss, and then
repeat for all other days The credit spread risk is incorporated into the daily price
•VaR is the 95th percentile selected from the 250 days of daily movements used to compute VaR and SVaR mentioned above.
hypothetical total profit or loss.
The VaR models used for credit issue risk are only intended to Backtesting
capture the risk presented by historical day-to-day market The group backtests its VaR models to verify the predictive ability
movements, and, therefore, do not take into account of the VaR calculations and ensure the appropriateness of the
instantaneous or jump to default risk. Issuer risk is incorporated models within the inherent limitations of VaR.
in the standardised approach interest rate risk charge for SBSA.
Backtesting compares the daily hypothetical profits and losses
Stop-loss triggers under the one-day buy and hold assumption to the prior day’s
Stop-loss triggers are used to protect the profitability of the calculated VaR. In addition, VaR is tested by changing various
trading desks, and are monitored by market risk on a daily basis. model parameters, such as confidence intervals and observation
The triggers constrain cumulative or daily trading losses through periods to test the effectiveness of hedges and risk-mitigation
acting as a prompt to review or close-out positions. instruments.
Stress tests Refer to the graph below for the results of the group’s
Stress testing provides an indication of the potential losses that backtesting for 2017. The volatility in hypothetical profit in
could occur under extreme but plausible market conditions, May 2017 is largely as a result of the devaluation of the
including where longer holding periods may be required to exit Nigerian naira and introduction of the Nigerian autonomous
positions. Stress tests comprise individual market risk factor foreign exchange fixing rate.
testing, combinations of market factors per trading desk and
combinations of trading desks using a range of historical, Regulators categorise a VaR model as green, amber or red and
hypothetical and Monte Carlo simulations. Daily losses assign regulatory capital multipliers based on this categorisation.
experienced during the period under review, did not exceed the A green model is consistent with a satisfactory VaR model and is
maximum tolerable losses as represented by the group’s stress achieved for models that have four or less backtesting exceptions
scenario limits. in a 12-month period at 99% VaR. All of the group’s approved
models were assigned green status for the period under review
(2016: green).
Five exceptions occurred in 2017 (2016: nine) for 95% VaR and
one exception (2016: one) for 99% VaR.
QQHypothetical income 95% VaR (including diversification benefits) 99% VaR (including diversification benefits)
Specific business unit and product controls MR3: IMA VALUES FOR TRADING PORTFOLIOS
Other market risk limits and controls specific to individual
business units include permissible instruments, concentration of 2017 2016
exposures, gap limits, maximum tenor, stop-loss triggers, price Rm Rm
validation and balance sheet substantiation.
VaR (ten-day 99%)
Maximum value 278 314
Trading book portfolio characteristics
Average value 135 147
VaR for the period under review Minimum value 57 74
Trading book market risk exposures arise mainly from residual Period end 63 262
exposures from client transactions and limited trading for the
group’s own account. In general, the group’s trading desks have SVaR (ten-day 99%)
run similar levels of market risk throughout 2017 when compared Maximum value 361 361
to 2016 aggregate normal VaR, and similar levels when compared Average value 207 187
to aggregate SVaR. Minimum value 78 98
Period end 201 275
82
MARKET RISK
Analysis of trading profit
The graph that follows shows the distribution of daily trading income for the period ended 31 December 2017. It captures trading volatility
and shows the number of days in which the group’s trading-related revenues fell within particular ranges. The distribution is skewed
favourably to the profit side.
For the period under review, trading profit was positive for 250 out of 259 days (2016: 242 out of 260 days) on an aggregated global
basis.
140
120
100
Frequency of days
80
60
40
20
QQ2017 QQ2016
Post-employment obligation risk Liberty’s shareholders are exposed to the categories of market
risk, arising predominantly from:
The group operates both defined contribution plans and defined
benefit plans, with the majority of its employees participating in •the long-term policyholder asset/liability mismatch risk. This
defined contribution plans. The group’s defined benefit pension occurs if Liberty’s property and financial assets do not move in
and healthcare provider schemes for past and certain current the same direction or by the same magnitude as the
employees create post-employment obligations. Post-employment obligations arising under its insurance and investment
obligation risk arises from the requirement to contribute as an contracts despite the controls and hedging strategies
employer to an under-funded defined benefit plan. employed
•exposure to management fee revenues not already recognised
The group mitigates these risks through independent asset in the negative rand reserves1
managers and independent asset and liability management •financial assets forming Liberty’s capital base (also referred to
advisors for material funds. Potential residual risks which may as shareholders’ equity), including currency risks on capital
impact the group are managed within the group asset and liability invested outside South Africa
management process. Refer to note 45 in the annual financial •financial assets held to back liabilities other than long-term
statements for more detail on the group’s post-employment policyholder liabilities.
obligation risk.
The market risk associated with assets backing long-term
INSURANCE OPERATIONS policyholder investment-linked liabilities, including discretionary
participation features is largely borne by the policyholders.
Long-term insurance However, poor performance on policyholder funds can lead to
reputational damage and subsequently, to increased policyholder
For management purposes, Liberty’s market risk is split into the
withdrawals and a reduction in new business volumes.
following three categories:
•market risks to which Liberty wishes to maintain exposure on a Shareholder investment portfolio
long-term strategic basis: these include market risks arising
Liberty recognises the importance of investing its capital base,
from assets within the shareholder investment portfolio which
namely the shareholder funds, in a diversified portfolio of
is managed by LibFin Investments
financial assets.
•market risks to which Liberty does not wish to maintain
exposure on a long-term strategic basis as they are not The Liberty board approves the long-term asset mix of the
expected to provide an adequate return on economic capital portfolio. The long-term asset mix, also known as the strategic
over time, may be mitigated, either through improved product asset allocation is defined on a through-the-cycle basis and aims
design or through open market activity to maximise after-tax returns for a level of risk consistent with
•market risks to which Liberty does not wish to maintain the group’s risk appetite statement. In determining the strategic
exposure but where Liberty is unable to adequately and/or asset allocation, consideration is given to the risk capacity
economically mitigate these risks through hedging. In certain already utilised by Liberty’s core business activities, as well as to
instances, these market risks are second order risks resulting liquidity, regulatory and/or operational constraints.
from, for example, liquidity risks or reputational risks. While
these risks cannot necessarily be hedged, they are identified, 1 Negative rand reserves are negative liabilities (within long-term policyholder
measured and monitored as far as possible. liabilities) and policyholder assets arising when the discounted value of
expected future inflows exceeds the discounted value of expected future
outflows.
LibFin is responsible for implementing the investment strategy activity may in certain cases mitigate risk in one dimension while
and monitoring performance with oversight from group risk resulting in increased risk in others. In recognition of these
functions and ultimately the Liberty board. The implementation unintended consequences, the impact of hedging decisions is
of the investment strategy is in part achieved through the assessed across all dimensions prior to transacting. Post-
mandating of STANLIB and other asset managers. Tactical asset transacting, hedge effectiveness is monitored closely by Liberty’s
allocation is primarily performed by STANLIB within a mandate market risk team.
approved by the Liberty board.
The nature of the existing business results in certain risks being
The typical asset classes included in this portfolio are equities, difficult to hedge, such as long-dated implied volatility exposures,
fixed income, property and cash, both in local and foreign movements in long-dated interest rates and correlation risks. It is
currency. Allocations are also made to alternative asset classes in not possible to entirely hedge these risks and, hence, some
search of yield and diversification benefits. As a result, the residual unhedged risks and associated volatility remain. In such
portfolio is exposed to currency movements, as well as market instances limits are imposed on the magnitude of risk accepted.
movements in the underlying asset classes. In addition, capital is held against unhedgeable risks.
In the short-term, market movements may contribute to some Foreign currency risk
earnings volatility. The diversified nature of the portfolio should, Offshore assets are held in policyholders’ portfolios to match the
however, serve to minimise the overall impact on earnings. corresponding liabilities. Liberty is exposed to currency risk
through minimum investment return guarantees issued on
Asset liability management portfolio contracts invested in offshore portfolios and related mismatches,
Liberty has chosen to mitigate a number of market risk as well as through the 90/10 fee exposure and management fees.
exposures, arising from asset/liability mismatches, to which it In addition, some of the shareholder capital base is invested in
does not wish to be exposed on a long-term strategic basis. offshore assets, including subsidiaries in the Africa Regions.
The decision to hedge these risks is based on the following Investment guarantees have not been offered on new business
factors: invested in offshore portfolios since 2005. The rand-denominated
•continuing to assume these market risks may result in Liberty value of management fees derived from these contracts is
operating outside of its risk appetite subject to currency risk. Strengthening of the rand against the
•there is a liquid and tradable market in which to hedge these offshore currencies reduces the rand value of management fees
market risks on offshore portfolios and increases the liability in respect of
rand-denominated minimum investment return guarantees
•these market risks are capital intensive and over time have the
on this business. The weakening of the rand will have the
potential to reduce shareholders’ returns on capital unless
opposite effect.
actively managed
•some of the risks (for instance, those which arise from selling The gross exposure to foreign-denominated financial
investment guarantees) are asymmetric in nature, and could instruments expressed in rand (converted at closing rates)
compromise Liberty’s solvency in severe market conditions. as at 31 December 2017 is R74.6 billion (2016: R84.4 billion).
It is not practical to isolate foreign currency assets contained
Risk mitigation is achieved through a dynamic hedging within rand-denominated mutual funds (which are not
programme, managed by LibFin. The hedging programme aims subsidiaries) and investment policies.
to manage the risks within the group’s agreed risk appetite
framework through the use of best practice market risk
Property market risk
management techniques.
Liberty is exposed to tenant default, depressed rental markets
The exposures which are included in this hedging programme and unlet space within its investment property portfolio affecting
include the following: property values and rental income. The managed diversity of
the property portfolio and the existence of multi-tenanted
•embedded derivatives provided in contracted policies, for buildings significantly reduce the exposure to this risk. As at
example, minimum investment return guarantees and 31 December 2017, the proportion of unlet space in the property
guaranteed annuity options portfolio was 7% (2016: 5%).
•the interest rate exposure from writing guaranteed immediate
annuities, deferred annuities and guaranteed investment plans Property market risk also arises with respect to shareholder
•guaranteed index trackers exposures to investment guarantees and negative rand reserves.
•negative rand reserves.
Derivative financial instruments and risk mitigation
These risks are managed in the asset and liability management Certain Liberty entities are party to contracts for derivative
portfolio using a variety of hedging instruments available in the financial instruments, mainly entered into as part of the dynamic
market. hedging strategy used to manage asset-liability mismatches and
to facilitate investment portfolio optimisation. Instruments used
In some instances, reducing exposure to undesirable risks may to mitigate risks such as equity, interest rate and currency risk
result in increased exposure to other risks. In addition to this, as include vanilla futures, options, swaps, swaptions and forward
the risk appetite limits cover different dimensions, hedging exchange contracts.
84
MARKET RISK
Derivative financial instruments give rise to credit default and
operational risk, both of which are managed appropriately.
Derivative financial instruments are either traded on a regulated
exchange, for example, the South African Futures Exchange
(SAFEX), or negotiated over-the-counter (OTC) as a direct
arrangement between two counterparties. Instruments traded on
SAFEX are margined and SAFEX is the counterparty to each and
every trade. OTC instruments are only entered into with
appropriately approved counterparties and are entered into in
terms of signed ISDAs and collateral support agreements with
each counterparty.
Short-term insurance
Market risk arises from investments in cash, corporate money
market and collective investment schemes. It is not as material
for the short-term insurance business as it is in the group context
due to the nature of SIL’s liabilities, where larger portions of
investments are in cash and bond-type investments.
INSURANCE
RISK
87 OVERVIEW
87 LONG-TERM INSURANCE RISK
87 Overview
87 Approach to managing long-term
insurance risks
87 Long-term insurance risk subtypes
88 SHORT-TERM INSURANCE RISK
88 Overview
88 Approach to managing short-term
insurance risk
88 Short-term insurance risk subtypes
86
INSURANCE RISK
OVERVIEW Risk management post-implementation of
products and of in-force policies
Insurance risk arises due to uncertainty regarding the timing and
The ongoing management of insurance risk, once the risk has
amount of future cash flows from insurance contracts. This could
been contracted, includes the management of costs, premium
be due to variations in mortality, morbidity, policyholder
adjustments where permitted and appropriate, and management
behaviour or expense experience in the case of life products, and
strategies to encourage customers to retain their contracts; and
claims incidence, claim severity or expense experience in the
careful follow up on disability claims and annuitant deaths.
case of short-term insurance products.
Investigations are conducted at least annually on all significant
Insurance risk applies to the long-term insurance operations
insurance risks to ascertain the extent of deviations from
housed in Liberty and the short-term insurance operations
assumptions and their financial impacts. If the investigations
housed in Liberty Africa, Liberty Health and SIL.
indicate that these deviations are likely to persist in future, the
assumptions will be adjusted accordingly for the subsequent
LONG-TERM INSURANCE RISK measurement of policyholder contract values. Furthermore, any
deviations that are likely to persist are also used to inform the
Overview product development and pricing of new and existing products.
The management and staff in all business units accepting
insurance risk are responsible for the day-to-day identification, Insurance risks are assessed and reviewed against the group’s
analysis, pricing, monitoring and management of insurance risk. risk appetite and risk target. Mitigating actions are developed for
It is also management’s responsibility to report any material any risks that fall outside of management’s assessment of risk
insurance risks, risk events and issues identified to senior appetite in order to reduce the level of risk to within the approved
management through certain predefined escalation procedures. tolerance limits.
Liberty’s statutory actuaries, the group insurance risk Long-term insurance risk subtypes
department and the heads of risk in the business units provide
independent oversight of compliance with Liberty’s risk
Policyholder behaviour risk
management policies and procedures, and the effectiveness of Policyholder behaviour risk is the risk of adverse financial impact
Liberty’s insurance risk management processes. caused by actual policyholders’ behaviour deviating from
expected policyholders’ behaviour, mainly due to:
Approach to managing long-term •regulatory and law changes (including taxation)
•changes in economic conditions
insurance risks
•sales practices
Risk management takes place prior to the acceptance of risks
•competitor behaviour
through product development, pricing processes and at the point
of sale. Risks continue to be managed through the measurement, •policy conditions and practices
monitoring and treatment of risks once the risks are contracted. •policyholders’ perceptions.
Risk management through product development, Policyholder behaviour risk, in particular withdrawal risk, remains
significant with the experience being volatile and linked in part to
pricing and at the point of sale
the economic cycle. This risk is managed through frequent
The product development and pricing process defines the terms
monitoring of experience and actively driving retention initiatives
and conditions on which the group is willing to accept risks. Once
in areas exhibiting deteriorating experience. A focus on being
a policy has been sold, the group is placed on risk for the
customer centric, including listening to customers to understand
duration of the contract and the group cannot unilaterally change
the drivers of the experience, enables appropriate actions to
the terms and conditions of the policy except where the policy
be taken.
allows for rate reviews. It is for these reasons that risks need to
be carefully assessed and appropriately mitigated before a
Underwriting risks
product is launched and before new policies are accepted onto
the group’s balance sheet. The product development and Underwriting risks are the risks that future demographic or
approval process ensures that: claims incidence experience will exceed the allowance for
expected demographic or claims incidence experience, as
•risks inherent in new products are identified and quantified determined through provisions, pricing, risk measures and value
•sensitivity tests are performed to enhance the understanding measures. Underwriting risks include, among others, mortality,
of the risks and appropriateness of mitigating actions morbidity and longevity risks.
•pricing is adequate for the risk undertaken
•product design takes account of various factors, including the Liberty views these underwriting risks as risks that are core to
size and timing of fees and charges, appropriate levels of their business. Liberty uses its specialist skills (with assistance
minimum premiums, commission structures and policy terms from reinsurers where considered necessary) to enhance risk
and conditions selection for the assessment, pricing and management of these
•the group makes use of reinsurance to reduce its exposures to risks to generate favourable shareholder returns. These risks are
some insurance risks diversified by exposure across many different lives, geographies,
and product types and will generally be retained if they are within
•customers’ needs and expectations will be met by the product
risk appetite.
•the controls required to provide the product within risk
appetite are identified and established
•post-implementation reviews are performed to ensure that
intended outcomes are realised and to determine if any further
action is required.
Mortality and morbidity risk Liberty manages the expense and new business risk by:
Mortality risk is the risk of an adverse financial impact due to •regularly monitoring actual expenses against the budgeted
actual mortality (death) claims being higher than anticipated. expenses
Morbidity risk is the risk of an adverse financial impact due to •regularly monitoring new business volumes and mix
policyholder health-related (disablement and dread disease) •regularly monitoring withdrawal rates, including lapses
claims being higher than expected.
•implementing cost control measures in the event of expenses
exceeding budget or of significant unplanned reductions in the
Liberty has a range of standard processes and procedures in
number of in-force policies.
place to manage mortality and morbidity risk, including
differentiating by the individual characteristics, right of review of
Even though expense risk does not give rise to large capital
premiums, underwriting at inception, medical tests, and use of
requirements, the management of expense risk is core to the
experienced reinsurers and claims assessors.
business. The expenses that the group expects to incur on
policies are allowed for in product pricing. If the expenses
These risks will generally be retained. Mortality and morbidity
expected to be incurred are considerably higher than those of
risk give rise to significant economic capital requirements
other insurers offering competing products, the ability of the
particularly due to potential catastrophic events. Since it is
group to sell business on a profitable basis will be impaired. This
difficult to obtain reinsurance for certain catastrophic events on
not only has capital implications, but can also affect the group’s
reasonable terms, the mortality and morbidity economic capital
ability to function as a going concern in the long term.
requirements are likely to remain significant.
Allowance is made for expected future maintenance expenses in Short-term insurance risk types
the measurement of long-term policyholder contract values
using a cost per policy methodology. These expected expenses The underwriting strategy seeks diversity to ensure a balanced
are dependent on estimates of the number of in-force and new portfolio and is based on a large portfolio of similar risks over a
business policies. As a result, the risk of expense loss arises due large geographical area. This strategy is cascaded down to
to expenses increasing by more than expected, as well as from individual underwriters through detailed underwriting authorities
the number of in-force and/or new business policies being less that set out the limits that any one underwriter can write by line
than expected. size, class of business, territory and industry in order to enforce
appropriate risk selection within the portfolio.
88
INSURANCE RISK
The key risks associated with short-term insurance are Short-term insurance operations are impacted by adverse
underwriting risk, competitor risk and claims experience risk economic conditions which could lead to lower new business
(including the variable incidence of natural disasters). Property take-up rates, higher than budgeted cancellation rates and fraud.
is subject to a number of risks, including theft, fire, business The potential for fraudulent behaviour is also very high. New
interruptions and weather. business and lapse rates are budgeted each year and monitored
on a monthly basis. These rates are reported and compared to
For property classes of business there is a significant budget figures.
geographical concentration of risk such that external factors, like
adverse weather conditions, may adversely impact upon a large Catastrophe risk
proportion of a particular geographical portion of the company’s The risk of adverse financial impact due to a single event or
property risks. Claim inducing perils such as storms, floods, series of events of major magnitude, usually over a short period
subsidence, fires, explosions and rising crime levels will occur on (often 72 hours), leads to a significant deviation in actual claims
a regional basis, meaning that SIL has to manage its geographical from the total expected claims.
risk dispersion carefully.
Claims incidence risk
The greatest likelihood of significant losses to the group arises
from catastrophic events such as flood, storm or earthquake This is the risk of loss in excess of what has been priced for,
damage. To mitigate this risk, the insurance entity buys arising from accident, fire and theft on short-term insurance
reinsurance across a diversified panel of multiple third-party business.
reinsurers, each participating on different structures according to
On certain types of business, for example, third-party liability
their own risk tolerance. Reinsurance protects the insurance
claims, the claim distribution is longer tailed. This means that the
entity from downside risk from individual large claims, several
final cost of the claim is only known many years into the future.
accumulations of claims and catastrophic claims such as hail
The risk here is that the group reserves inadequately for this
damage and earthquakes.
ultimate claims cost.
Risk and catastrophe reinsurance
Expense risk
The business reinsures a portion of the risks it underwrites in
This is the risk of an adverse financial impact due to the timing
order to control its exposure to losses and protect capital
and/or amount of expenses incurred, or both differing from those
resources. For example, excess of loss reinsurance and
expected in administering policies, e.g. assumed in the pricing
catastrophe reinsurance protect against major losses on high
basis or actual cost per policy.
sums insured and major natural disasters respectively. The key
natural disasters affecting the business includes hail and water
The expenses that the group is expected to incur on policies are
damage, which has impacted South Africa more regularly over
allowed for in product pricing. If the expenses expected to be
the last few years, as well as the potential of earthquake damage,
incurred are considerably higher than those of insurers offering
which is, however, a more remote risk.
competing products, the group’s ability to sell business on a
profitable basis will be restricted. This does not only have capital
Policyholder behaviour risk implications, but can also affect the group’s short-term insurance
Policyholder behaviour risk is the risk of loss arising due to actual operations ability to function as a going concern in the long term.
policyholders discontinuing their insurance policies earlier or
more frequently than expected. This may arise due to a change in New business risk
economic conditions and/or inconsistent policy practices,
This is the risk of an adverse financial impact due to the actual
regulatory and tax changes, selling practices and policyholder
volume and/or quality of new business deviating from the
perceptions.
expected volume and/or quality.
The primary policyholder behaviour risk is persistency risk, which
arises due to policyholders cancelling insurance cover on
short-term insurance business. This could lead to a reduction in
premium income, an increase in the expense ratio and a
reduction on the return on capital.
OPERATIONAL
RISK
91 APPROACH TO MANAGING
OPERATIONAL RISK
93 INSURANCE COVER
93 GOVERNANCE
93 APPROVED REGULATORY CAPITAL
APPROACH
93 OPERATIONAL RISK SUBTYPES
93 Cyber risk
93 Information risk
94 Financial crime risk
94 Technology risk
94 Model risk
94 Tax risk
95 Legal risk
95 Environmental and social risk
90
OPERATIONAL RISK
APPROACH TO MANAGING The core capabilities of operational risk ensure alignment and
integration across:
OPERATIONAL RISK •developing and maintaining the operational risk governance
The group recognises that operational risk exists in the natural framework
course of business activity and adheres to the group’s •facilitating the business’s adoption of the operational risk
operational risk governance framework, which sets out the framework
minimum standards for operational risk management adopted •regulatory oversight
across the group. This framework aligns to the group’s strategy •monitoring and assurance
by demonstrating that the purpose of operational risk •reporting
management is not to eliminate all risks, which is not •challenging the risk profile and providing guidance and advice
economically viable, but rather to enable management to weigh as thought leaders.
the payoff between risk and reward. The framework also ensures
that adequate and consistent governance is in place, guiding The operational risk management function analyses root causes
management to avoid unacceptable risks such as: of internal incidents and events to allow for the implementation
•breaking the law and recommendation of controls to curb future threats. These
•damaging the group’s reputation analyses are followed by self-assessments and risk-focused
•disrupting services to customers reviews, where an independent team provides objective
monitoring and assessment of the adequacy and effectiveness
•wilful conduct failures
encompassing the implementation of the operational risk
•inappropriate market conduct governance framework. The function also plays a role in
•knowingly breaching regulatory requirements influencing risk decision-making and implementing of risk
•causing environmental damage. controls, which results in acceptance, mitigation, or avoidance of
risk. The function also provides an assessment of regulatory
The group’s approach to managing operational risk is to adopt requirements that need to be implemented within embedded
fit-for-purpose operational risk practices that assist line operational risk management functions to ensure regulatory
management in understanding their residual risk and managing compliance.
their risk profile within risk appetite. The management of
operational risk primarily resides in first line, supported by Individual teams are dedicated to each business line and report
second line with dedicated centres of excellence. The operational to the respective PBB and CIB CRO with a functional reporting
risk management function forms part of the second line of line to the group head of operational risk management. The
defence and is an independent area, reporting to the group CRO. group function provides dedicated teams to corporate functions
such as finance, IT and human capital. These teams work
The framework ensures that those banking entities adopting the alongside their corporate functions and facilitate the adoption of
AMA or the standardised approach for regulatory capital the operational risk governance framework. As part of the second
purposes can meet the relevant regulatory criteria. The AMA line of defence, they also monitor and challenge management in
capital is currently estimated twice per year. The AMA capital respect of their operational risk profile.
model is validated by an independent model validation team and
approved for ongoing use by the PBB, CIB and group model Business continuity management is a process that identifies
approval committees. potential operational disruptions and provides a basis for
planning for the mitigation of the negative impact from such
disruptions. In addition, it promotes operational resilience and
ensures an effective response that safeguards the interests of
both the group and its stakeholders. The group’s business
continuity management framework encompasses emergency
response preparedness and crisis management capabilities to
manage the business through a crisis to full recovery. The group’s
business continuity capabilities are evaluated by testing business
continuity plans and conducting crisis simulations.
66 more information
The following risk types are part of the •physical assets risk RCM –67 on pages 66 –67.
extended operational risk taxonomy •human capital risk
and are considered for capital •accounting and financial risk.
allocation in the ICAAP process:
92
OPERATIONAL RISK
INSURANCE COVER activity, and in South Africa the largest breach of confidential
records (an estimated 63 million records) was reported as a
The group buys insurance to mitigate operational risk. This cover result of a property company failing to secure its website.
is reviewed on an annual basis. The group insurance committee
oversees a substantial insurance programme designed to protect The escalation in the scale and sophistication of cyber crime is
the group against loss resulting from its business activities. amplified by the growing digitisation of businesses and the
complexity of running ageing systems.
The principal insurance policies in place are the group crime and
professional indemnity, and group directors’ and officers’ liability The group is cognisant of the mounting risk posed by cyber
policies. In addition, the group has fixed assets and liabilities crime and significant investments are made to enhance security
coverage in respect of office premises and business contents, capabilities and accelerate its strategic directives. Cyber risk
third-party liability for visitors to the group’s premises, and receives extensive focus at every level of the organisation across
employer’s liability. The group’s business travel policy provides various governance and management committees. Financial
cover for group staff while travelling on behalf of the group. services remain the most targeted sector from a cyber crime
perspective and, consistent with this trend, a number of attempts
were successfully mitigated without any impact to the group’s
GOVERNANCE operations or customers. Many of these incidents were prevented
The primary management level governance committees as a direct result of the advanced cyber defence capabilities
overseeing operational risk are GROC and the group operational introduced in 2016 and 2017.
risk committee. The primary governance documents are the
operational risk governance framework, and the operational risk Financial institutions in particular are vulnerable to distributed
governance standard. denial of service (DDOS) attacks. The group has activated a
DDOS mitigation service provided by our internet service
Operational risk subtypes report to various governance provider, that is capable of mitigating the majority of DDOS
committees and have governance documents applicable to each attack types, allowing our services, like internet banking, to
risk subtype. remain usable during an attack.
2017 saw a continued focus on improving cyber security The global shortage of cyber security skills is well documented
capabilities. and, in an attempt to reduce this shortage, graduate staff will be
taken through a specialised development programme.
In response to the growing volume and sophistication of cyber
crime incidents and attacks, the group has developed a IT cyber
security strategy which is centred around the four key pillars of
Information risk
governance, culture, capability and community, all of which are In 2017 the group experienced no material exposures as a result
crucial for an effective cyber defence strategy. of information breaches. Prevention and proactive detection
mechanisms, which are at the forefront of the group’s strategic
Cyber crime includes cyber fraud, data theft, extortion initiatives, coupled with clear governance, standards and
(ransomware) and malicious business disruption. Many frameworks has contributed towards the protection of the
industries and organisations globally experienced high-profile group’s information and reputation.
cyber crimes in 2017, including healthcare in the UK, a credit
bureau in the USA and financial services in the East. Breaches of
confidential records often lead to an increase in cyber crime
With the aim of ensuring that information is secure and Technology risk
customers are consistently educated, targeted awareness
Stability continued to improve in 2017 with a significant decline in
campaigns driving risk-conscious behaviour, improved third-
the volume of high-priority incidents. This can be attributed to
party management, behavioural analytics capabilities and
the executive focus being placed on all dimensions of IT and the
research on trending information risk topics were introduced
management of risks associated with incidents, which also
during 2017.
minimises customer impact. Given the nature and scale of the
group’s business, some interruption is inevitable and IT incidents
Financial crime risk and downtime cannot be completely avoided.
The cost of financial crime is staggering. Each year, tech-savvy
perpetrators defraud banks of more than $50 billion. As Management focus and capability is placed on the ability to
customers, regulators, and the financial industry have gained predict, prevent, detect and rapidly respond to, and manage the
familiarity with various forms of financial crime, the group has risks associated with incidents. For Africa Regions there has been
seen that the underlying risk of financial crimes not only includes a substantial decrease in incidents related directly to applications
the direct action taken by criminals, but also includes the cost of but network links remain a primary challenge.
deterrence, detection, and resolution.
The implementation of the core banking system has been
Credit card fraud is plaguing the industry and the rifest method is completed in target entities within the approved scope and
‘card not present’ fraud. The growing popularity of e-commerce budget. The core banking modernisation programme across the
transactional volumes also provides the ideal opportunity for continent has proved invaluable in mitigating operational risks
criminals to siphon or breach sensitive card data. The group associated with non-standardised legacy platforms. As the group
continuously strives to maintain a balance between the customer continues to augment the technology stack, a portion of
experience and anti-fraud measures by analysing data to investment will always be reserved for security and stability.
establish behaviour towards predicting, preventing, detecting and
responding rapidly to changes in the card fraud threat landscape. Complexity has been identified as a key factor driving many of
the top risks and can negatively impact the achievement of
In 2017 the group introduced new technology and processes to strategic objectives. In order to reduce the risks and continue to
enable detection, monitoring and intervention, to known threats improve customer and staff experience, simplification has been
and fraudulent activities on customers’ accounts, both in South incorporated as one of the group’s key strategic themes.
Africa and in the Africa Regions. To ensure that responses to
fraud incidents are efficient and in near-real time, fraud response Model risk
centres in South Africa, Swaziland, Botswana, Uganda, Ghana,
Model risk is mitigated through the following principles:
Namibia, Lesotho and Zimbabwe were introduced, with a
co-location of multi-disciplinary teams made up of members •fit-for-purpose governance
from the fraud and security value chain. •maintaining a pool of skilled and experienced technical
specialists
The popularity of the online and application banking channels •robust model-related processes.
has contributed towards the prevalence of phishing attacks
industrywide. The group introduced phishing detection and To give effect to these principles, model risk is governed by the
malware detection capabilities in Africa Regions countries to model risk governance framework. This framework defines model
detect compromised cards on phishing sites and account risk, the scope of models, documentation needs, model
takeover. Additionally, malware detection and remediation materiality considerations, high-level model development
solution, which removes malware from infected machines, are requirements, validation requirements, usage and monitoring
available to customers. requirements, the governance and approval processes, and the
roles and responsibilities across the three lines of defence. Model
Phishing site attacks targeting Standard Bank clients reduced risk leverages the operational risk framework.
significantly in 2017, down 53% from 2016. This reduction has
seen a corresponding reduction in the number of online banking In 2017, there were no material exposures related to model risk.
fraud incidents reported over the same period, down 48% from
2016. The decrease in phishing attacks and online fraud incidents Tax risk
is largely due to the implementation of new prevention and
The group’s approach to tax risk is governed by the GAC-
detection controls.
approved tax risk control framework, which includes the tax
The organisation continues to operate with a zero tolerance for strategy and governance standard, supported by policies dealing
employee misconduct and independently investigates all with specific aspects of tax risk such as transfer pricing, indirect
allegations of employee misconduct. Employees are also taxes, withholding taxes and remuneration-related taxes.
provided with ongoing awareness and training and are provided
with the appropriate tools for escalating and reporting
misconduct anonymously.
94
OPERATIONAL RISK
In 2017, the group was exposed to transfer pricing risk, as well Initiatives in 2018 include implementing an electronic litigation
as increased levels of tax assessments raised in Nigeria. A management system to assist with oversight and management of
consistent approach to responding to transfer pricing queries litigation risk.
was coordinated to mitigate the exposure. An overarching tax risk
management strategy will be developed for Nigeria during 2018. Environmental and social risk
Certain aspects of the Africa Regions tax calculations and Environmental and social risk assessment and management
consolidations have been automated to reduce manual deals with two aspects:
intervention and resultant risk. •indirect risk: the environmental and social risks which occur
as a result of our lending or financial services activities
From an industry perspective, the group has been involved in •direct risk: these include our direct environmental and social
various successful lobbying efforts with tax regulators benefiting impact, such as our waste management and the use of energy
the group. and water within group facilities.
BUSINESS
RISK
96
BUSINESS RISK
Business risk includes strategic risk. Strategic risk is the risk that •stakeholder management to ensure favourable outcomes from
the group’s future business plans and strategies may be external factors beyond the group’s control
inadequate to prevent financial loss or protect the group’s •monitoring the profitability of product lines and customer
competitive position and shareholder returns. The group’s segments
business plans and strategies are discussed and approved by •maintaining tight control over the group’s cost base, including
executive management and the board and, where appropriate, the management of its cost-to-income ratio, which allows for
subjected to stress tests. early intervention and management action to reduce costs
•being alert and responsive to changes in market forces
Business risk is usually caused by the following:
•a strong focus in the budgeting process on achieving headline
•inflexible cost structures
earnings growth while containing cost growth; and building
•market-driven pressures, such as decreased demand, contingency plans into the budget that allow for costs to be
increased competition or cost increases significantly reduced in the event that expected revenues do
•group-specific causes, such as a poor choice of strategy, not materialise
reputational damage or the decision to absorb costs or losses •increasing the ratio of variable costs to fixed costs which
to preserve reputation. creates flexibility to reduce costs during an economic
downturn
The group mitigates business risk in a number of ways, including:
•stress testing techniques applied to assess the resilience of
•performing extensive due diligence during the investment the group’s planned earnings under macroeconomic downturn
appraisal process, in particular for new acquisitions and joint conditions.
ventures
•detailed analysis of the business case for, and financial, The primary governance committee for overseeing this risk is the
operational and reputational risks associated with, disposals group ALCO.
•the application of new product processes per business line
through which the risks and mitigating controls for new and
amended products and services are evaluated
REPUTATIONAL
RISK
98
REPUTATIONAL RISK
Reputation is defined as what stakeholders say and think about reputational impact of such events or developments. Crisis
the group, including its staff, customers and clients, investors, management teams are in place both at executive and business
counterparties, regulators, policymakers, and society at large. line level. This includes ensuring that the group’s perspective is
Analysts, journalists, academics and opinion leaders also fairly represented in the media. In addition, more attention is
determine the group’s reputation. The group’s reputation can be being paid to leveraging opportunities to proactively bolster the
harmed from an actual or perceived failure to fulfil the group’s reputation among influential stakeholders through
expectations of our stakeholders due to a specific incident or programmes, including stakeholder engagement, advocacy,
from repeated breaches of trust. sponsorships, and corporate social initiatives.
Reputational harm can adversely affect the group’s ability to The principal governance document is the reputational risk
maintain existing business, generate new business relationships, governance standard and the group’s qualitative RAS includes a
access capital, enter new markets, and secure regulatory licences statement on reputation.
and approvals.
The newly established supplier risk management committee
Safeguarding and proactively managing the group’s reputation ensures enhanced due diligence for the suppliers that the group
is of paramount importance. There is growing awareness of deals with. In this regard, matters such as participation in
reputational risks arising from compliance breaches, social financial crime or in activities that could cause reputational
and environmental considerations, as well as from ethical damage to the group are considered. This committee considers
considerations linked to countries, clients and sectors. new relationships, as well as relationships where the risk profile
of the supplier changed.
The group is increasingly managing reputational risk from a
tactical and reactive perspective, as well as from a strategic and The group’s code of ethics is an important reference point for all
proactive perspective. In respect to crisis response, the group’s staff. The group ethics officer and group chief executive are the
crisis management processes are designed to minimise the formal custodians of the code of ethics.
RESTATEMENTS
100
RESTATEMENTS
CAPITAL ADEQUACY RATIOS OF CCR1: ANALYSIS OF CCR EXPOSURE
BANKING SUBSIDIARIES BY APPROACH AND CCR2: CVA CAPITAL
The capital adequacy ratio for 2016 was restated to align to CHARGE
Liberty’s disclosure. Figures have been reclassified to take into account CCR8
Refer to page 30. CCP and default funds
RCM 30
Refer to page 57.
RCM 57
FINANCIAL STATEMENTS
The 2016 reported figures were restated to give effect to the
further clarity provided by the BCBS on the treatment of
insurance entities outside the scope of regulatory
consolidation.
Refer to
RCM 31–
32 pages 31 –32.
derivatives only.
Refer to page 53.
RCM 53
The impact of new regulatory standards that have been Regulations developed over the past number of years can be
developed by international standard setting bodies and classified into three main categories:
regulators in the wake of the global financial crisis is significant •conduct and culture
for financial institutions. Different regulatory regimes apply in the
•resolvability
countries in which the group operates, but there is commonality
•financial sustainability.
in many of the focus areas.
In line with the international regulatory agenda, South Africa is
The group continues to take a strategic approach to its internal
adopting Twin Peaks in the form of the Financial Sector
regulatory response in order to efficiently and effectively deal
Regulation Act, which establishes two new regulatory authorities,
with the breadth and complexity of emerging regulations. This
namely the Prudential Authority and the Financial Sector
ensures that the group entities are appropriately positioned
Conduct Authority, with the SARB playing the role of the
within the context of the new regulations and are able to deliver
Resolution Authority. The diagram below provides a view of the
the best client outcomes.
regulatory changes across the three main categories.
Focus on: •meet all legislative require- ROE more than covers the cost
•customer fairness ments for resolution of equity
•market integrity •credible and effective •profitable business lines
•consumer empowerment resolution funding plans •cost control.
•executive and board •facilitate resolution planning
accountability by the authorities
•bias and conflicts of interest •legal and operational
•fees structure Capital and liquidity
•transparency •continuity of critical economic
•transformation. functions and of the services
that support them •meet all regulatory capital
•sufficient loss absorbing leverage and liquidity
capacity. requirements
Enabling policy and legislation
•meet internally assessed
capital and liquidity require-
ments
•Financial Sector Regulation Enabling regulations •capital and liquidity planning
Act •ability to access equity and
•Insurance Act additional funding as and
•Conduct of Financial •higher loss absorbing capacity when required.
Institutions Bill requirements (D-SIB), total
•Retail Distribution Review loss absorbing capacity
•National Credit Amendment •recovery and resolution plans
Bill. •South African resolution Enabling regulations
framework and standards
•resolvability assessment
•structural reform. •capital quality and buffers
•range of risks assessed:
IRRBB, fundamental review of
the trading book (FRTB),
securitisations, credit risk
approaches, implications of
output floors and CVA
•LCR and NSFR
•leverage ratio
•SAM
•OTC derivatives.
102
The key regulations that have been finalised over the past year, as well as the regulations that are expected to be finalised in the short
term are outlined below.
BASEL
In response to the financial crisis, the BCBS introduced a range of reforms which were designed to enhance the resilience of the banking
system against shocks.
During November 2014, the BCBS issued its work programme aimed at addressing excessive variability in banks’ regulatory capital
ratios. In December 2017, the BCBS finalised these post-crisis regulatory reforms. The revisions seek to restore credibility in the
calculation of RWA and improve the comparability of banks’ capital ratios.
Refer to the table below for an overview of the Basel III regulatory reforms, as well as the remaining/outstanding key aspects under
consideration by the BCBS.
Credit risk –
Credit risk –
standardised
IRB
approach
•generally, the
revisions •new and/or increased input floors for PDs and LGDs, for both corporate
and retail exposures
introduce more
risk-sensitive, •removal of the conservative IRB scaling factor of 1.06
granular, and •greater specification of parameter estimation practices to reduce RWA
detailed variability
approaches, •the revised scope of IRB approaches for asset classes are outline below.
including, for
example: Current SBSA Basel III available
– for residential Asset class approach approaches
FINALISED
and commercial
real estate •Large and mid-sized •AIRB •FIRB, standardised
corporates approach
– for unrated
exposures to •Banks* and other •AIRB •FIRB, standardised
banks and financial institutions approach
corporates
•Equities •Market-based •Standardised
•recalibration of approach approach
risk weighting for
rated exposures •Specialised lending •AIRB •AIRB, FIRB, slotting,
•separate standardised
approach.
treatment for
covered bonds, * Requirement for claims to domestic public sector enterprises that are not treated as
specialised exposures to sovereigns under the standardised approach are to be treated like banks and
lending and thus be risk-weighted using the FIRB rules.
exposures to
SMEs.
Operational risk –
Market risk – FRTB
standardised approach
Leverage
•definition for derivatives and off-balance sheet items
•introduction of a G-SIB buffer.
104
OTC DERIVATIVES RECOVERY AND RESOLUTION
The Financial Markets Act (FMA) regulatory reform framework PLANNING
consists of regulations and board notices. Local banks, including
SBSA, are working closely with the National Treasury (NT), the Recovery and resolution planning topics under discussion by the
SARB and the local FSB to ensure that the FMA regulations and global FSB include:
board notices meet the objectives set by the Group of Twenty •operationalising bail-in
(G20) leaders, are harmonised in so far as is possible with the •funding in resolution
frameworks being implemented in other G20 countries, and does •valuation in resolution
not impede on the ability of local counterparts to continue to
•operational continuity.
hedge risk effectively and efficiently with local and/or offshore
counterparts. The FMA regulations will introduce a requirement South Africa is in the process of adopting the global FSB
for standardised OTC derivatives transactions to be cleared standards for the effective management of institutions under
through a CCP, and for non-cleared transactions to become severe circumstances that could affect the stability of the
subject to bilateral exchange of initial and variation margin, financial system. These guidelines require the development of
together with the application of additional risk mitigation recovery and resolution plans, another form of proactive planning
techniques (including portfolio reconciliation and portfolio within the risk management framework and is described in the
compression). diagram below. With recovery planning widely adopted, the South
African regulatory focus has shifted to resolution planning.
LEVELS OF STRESS
Recovery Resolution
The recovery plans for systemically important In the event that these actions prove
institutions proactively identify management unsuccessful, the resolution plan sets out
actions which can be adopted during periods the approach to resolve the entity in an
of severe stress to restore their financial orderly manner while minimising the impact
POINT OF RESOLUTION
The group’s integrated recovery plan was Multiple regulatory authorities across home
developed to provide a valuable tool to and host jurisdictions in the group are in the
management and the board to manage the process of defining their countries’
implications of severe stress and proactively resolution frameworks. These resolution
addresses potential hurdles in effecting these frameworks will address the global topics of
actions. The group is obtaining similar resolution authority mandate, tools available
benefits from planning for the stability of its under resolution such as bail-in, the creditor
subsidiaries under severe conditions and hierarchy and enabling mechanisms.
through the rollout of the development of
subsidiary recovery plans.
A view on As part of improving financial stability and in line with international developments,
recovery and five out of 18 regulators from the group’s host countries have issued draft guidelines
resolution or requirements for banks in their respective jurisdictions to develop recovery plans.
planning in the The regulatory requirements are aligned to the FSB’s key attributes of effective
Africa Regions resolution regimes for financial institutions.
Where host country requirements are not yet defined, subsidiaries develop their
recovery plans in line with group standards. Both the group and its banking
subsidiaries have obtained value in understanding their core business lines and
critical functions and from proactively identifying plausible recovery actions.
Consumer credit More than 300 regulatory developments with an impact on the
The National Credit Amendment Act was amended in 2017 and is group were issued in the Africa Regions in 2017. In recent years,
being debated in Parliament this year. Proposed changes include there has also been a significant increase in the frequency and
activities to assist over-indebted low-income customers through intensity of regulatory inspections observed in the Africa Regions.
debt relief measures, and mechanisms to allow the National More than 50 regulatory inspections were performed in 2017.
Credit Regulator to penalise reckless lenders more directly. The
Most jurisdictions on the African continent have exchange control
group is engaging with policymakers and lawmakers on the Bill.
regulations with varying degrees of restrictions. In most cases,
regulators have detailed requirements for approval and
supporting documentation for imports and exports.
106
Intense regulatory scrutiny by local regulators and regional and
global bodies has been observed on AML and CTF in 2017 and
this is expected to continue in 2018. Enhancements to legal
frameworks and enforcement mechanisms are anticipated.
Regulators have exerted pressure on financial organisations to
enhance transaction monitoring and reporting abilities and have
issued fines where these have been deemed inadequate.
IFRS
The group is actively preparing for the adoption of new IFRS
accounting developments, some of which are effective from
1 January 2018.
These include:
•IFRS 9 – Financial Instruments, effective 1 January 2018
•IFRS 15 – Revenue from Contracts with Customers, effective
1 January 2018
•IFRS 16 – Leases, effective 1 January 2019
•IFRS 17 – Insurance Contracts, effective 1 January 2021
For further information regarding these and other accounting
AFS developments, please refer to annexure F – detailed
accounting policies in the group’s AFS.
CR6: IRB – CREDIT RISK EXPOSURES BY PORTFOLIO AND PD RANGE (BANKING OPERATIONS)1
Refer to page 46 – 47 for the total of the following asset classes.
Corporates
Original Off-balance
on-balance sheet EAD post-
sheet gross exposures Average CRM and Average
exposures pre-CCF CCF post-CCF PD
PD scale Rm Rm % Rm %
2017
0.00 to < 0.15 18 117 12 033 43.47 23 403 0.08
0.15 to < 0.25 34 760 15 078 44.24 41 536 0.22
0.25 to < 0.50 82 151 54 091 43.74 106 153 0.39
0.50 to < 0.75 39 161 12 237 46.03 44 943 0.64
0.75 to < 2.50 60 760 15 262 48.79 68 549 1.35
2.50 to < 10.00 10 885 3 015 59.07 12 701 3.77
10.00 to < 100.00 2 053 1 201 44.06 2 615 15.88
100.00 (default) 2 401 1 546 45.52 3 105 100.00
Subtotal 250 288 114 463 44.97 303 005 1.89
2016
0.00 to < 0.15 10 796 10 580 45.80 18 700 0.09
0.15 to < 0.25 40 465 13 430 43.06 47 939 0.22
0.25 to < 0.50 85 036 46 696 47.75 107 542 0.39
0.50 to < 0.75 38 963 18 756 46.23 47 136 0.64
0.75 to < 2.50 49 490 16 472 48.87 57 155 1.38
2.50 to < 10.00 14 488 5 488 52.90 14 324 3.81
10.00 to < 100.00 2 453 330 73.88 2 710 17.26
100.00 (default) 2 724 430 50.00 2 939 100.00
Subtotal 244 415 112 182 47.29 298 445 1.87
Original Off-balance
on-balance sheet EAD post-
sheet gross exposures Average CRM and Average
exposures pre-CCF CCF post-CCF PD
PD scale Rm Rm % Rm %
2017
0.00 to < 0.15
0.15 to < 0.25
0.25 to < 0.50
0.50 to < 0.75
0.75 to < 2.50 30 30 1.41
2.50 to < 10.00
10.00 to < 100.00
100.00 (default) 1 1 100.00
Subtotal 31 31 3.85
2016
0.00 to < 0.15
0.15 to < 0.25
0.25 to < 0.50 75 75 0.45
0.50 to < 0.75
0.75 to < 2.50 11 11 0.90
2.50 to < 10.00 388 388 3.58
10.00 to < 100.00
100.00 (default) 39 39 100.00
Subtotal 513 513 10.40
1 Refer to page 47 for an explanation of the items included in this analysis.
108
Average Average RWA
Number LGD maturity RWA density EL Provisions
of obligors % Years Rm % Rm Rm
1 14.11 5.00
4 23.02 2.10 15 47.71
2 15.21 5.00 26
8 22.07 1.30 301 58.87 29 28
CR6: IRB – CREDIT RISK EXPOSURES BY PORTFOLIO AND PD RANGE (BANKING OPERATIONS)1 CONTINUED
Specialised lending – income-producing real estate
Original Off-balance
on-balance sheet EAD post-
sheet gross exposures Average CRM and Average
exposures pre-CCF CCF post-CCF PD
PD scale Rm Rm % Rm %
2017
0.00 to < 0.15 3 3 0.11
0.15 to < 0.25 635 635 0.21
0.25 to < 0.50 6 452 2 309 40 7 364 0.43
0.50 to < 0.75 2 951 2 950 0.64
0.75 to < 2.50 5 509 83 59 5 559 1.07
2.50 to < 10.00 1 082 1 082 3.10
10.00 to < 100.00 8 8 28.96
100.00 (default) 23 23 100.00
Subtotal 16 663 2 392 39.97 17 624 0.97
2016
0.00 to < 0.15 2 2 0.11
0.15 to < 0.25 382 382 0.20
0.25 to < 0.50 5 600 19 100.00 5 620 0.43
0.50 to < 0.75 3 422 44 99.07 3 465 0.64
0.75 to < 2.50 5 080 5 98.10 5 085 1.16
2.50 to < 10.00 937 937 3.57
10.00 to < 100.00 9 9 20.40
100.00 (default) 31 31 100.00
Subtotal 15 463 68 99.26 15 531 1.11
Original Off-balance
on-balance sheet EAD post-
sheet gross exposures Average CRM and Average
exposures pre-CCF CCF post-CCF PD
PD scale Rm Rm % Rm %
2017
0.00 to < 0.15
0.15 to < 0.25 1 515 533 54 1 803 0.23
0.25 to < 0.50 4 125 214 71 4 277 0.37
0.50 to < 0.75 5 431 150 49 5 505 0.64
0.75 to < 2.50 5 184 533 90 5 664 1.15
2.50 to < 10.00 2 326 2 326 3.63
10.00 to < 100.00
100.00 (default) 709 709 100.00
Subtotal 19 290 1 430 65.40 20 284 4.51
2016
0.00 to < 0.15
0.15 to < 0.25 367 367 0.23
0.25 to < 0.50 5 502 319 64.80 5 709 0.42
0.50 to < 0.75 4 035 68 50.00 4 069 0.64
0.75 to < 2.50 5 283 870 68.96 5 882 1.36
2.50 to < 10.00 1 933 1 933 4.46
10.00 to < 100.00
100.00 (default) 759 759 100.00
Subtotal 17 879 1 257 66.50 18 719 5.21
1 Refer to page 47 for an explanation of the items included in this analysis.
110
Average Average RWA
Number LGD maturity RWA density EL Provisions
of obligors % Years Rm % Rm Rm
CR6: IRB – CREDIT RISK EXPOSURES BY PORTFOLIO AND PD RANGE (BANKING OPERATIONS) 1 CONTINUED
SME corporate
Original Off-balance
on-balance sheet EAD post-
sheet gross exposures Average CRM and Average
exposures pre-CCF CCF post-CCF PD
PD scale Rm Rm % Rm %
2017
0.00 to < 0.15 588 64 74 650 0.10
0.15 to < 0.25 2 523 127 74 2 643 0.22
0.25 to < 0.50 1 922 348 73 2 242 0.34
0.50 to < 0.75 8 192 369 71 8 486 0.63
0.75 to < 2.50 13 455 749 65 14 009 1.39
2.50 to < 10.00 5 441 379 66 5 719 4.14
10.00 to < 100.00 779 25 70 798 18.01
100.00 (default) 779 50 779 100.00
Subtotal 33 679 2 061 68.47 35 326 4.03
2016
0.00 to < 0.15 645 80 70.68 1 514 0.07
0.15 to < 0.25 2 675 131 74.63 3 053 0.17
0.25 to < 0.50 2 719 565 72.41 2 400 0.36
0.50 to < 0.75 5 369 246 63.08 5 539 0.64
0.75 to < 2.50 12 276 930 65.24 12 729 1.28
2.50 to < 10.00 2 197 344 63.59 2 437 4.40
10.00 to < 100.00 595 23 70.83 616 11.32
100.00 (default) 469 50.00 469 100.00
Subtotal 26 945 2 319 67.25 28 757 2.99
Securities firms
Original Off-balance
on-balance sheet EAD post-
sheet gross exposures Average CRM and Average
exposures pre-CCF CCF post-CCF PD
PD scale Rm Rm % Rm %
2017
0.00 to < 0.15 373 90 100.00 463 0.07
0.15 to < 0.25
0.25 to < 0.50 113 42.24 48 0.36
0.50 to < 0.75
0.75 to < 2.50 1 39.50 1.81
2.50 to < 10.00 1 1 6.47
10.00 to < 100.00
100.00 (default)
Subtotal 374 204 56.65 512 0.11
2016
0.00 to < 0.15 380 380 0.08
0.15 to < 0.25 133 167 30.22 201 0.23
0.25 to < 0.50 15 3 50.00 16 0.32
0.50 to < 0.75
0.75 to < 2.50 7 1 99.43 7 1.76
2.50 to < 10.00
10.00 to < 100.00
100.00 (default)
Subtotal 535 171 30.88 604 0.16
1 Refer to page 47 for an explanation of the items included in this analysis.
112
Average Average RWA
Number LGD maturity RWA density EL Provisions
of obligors % Years Rm % Rm Rm
CR6: IRB – CREDIT RISK EXPOSURES BY PORTFOLIO AND PD RANGE (BANKING OPERATIONS)1 CONTINUED
Sovereign
Original Off-balance
on-balance sheet EAD post-
sheet gross exposures Average CRM and Average
exposures pre-CCF CCF post-CCF PD
PD scale Rm Rm % Rm %
2017
0.00 to < 0.15 73 620 12 26.59 73 623 0.01
0.15 to < 0.25 30.33 0.21
0.25 to < 0.50 2 307 15 11.63 2 310 0.45
0.50 to < 0.75 2 46 29.94 16 0.61
0.75 to < 2.50 1 926 14 35.60 1 927 0.95
2.50 to < 10.00 6 24 26.81 10 9.23
10.00 to < 100.00 21 14 38.37 21 30.20
100.00 (default) 4 4 100.00
Subtotal 77 886 125 25.30 77 911 0.06
2016
0.00 to < 0.15 80 631 3 53.67 82 357 0.01
0.15 to < 0.25
0.25 to < 0.50 2 591 19 13.64 2 594 0.45
0.50 to < 0.75 12 10.14 1 0.67
0.75 to < 2.50 2 608 323 51.32 1 040 1.10
2.50 to < 10.00 18 16 37.97 19 4.73
10.00 to < 100.00 21 17 42.16 22 21.54
100.00 (default) 3 3 100.00
Subtotal 85 872 390 50.04 86 036 0.05
Original Off-balance
on-balance sheet EAD post-
sheet gross exposures Average CRM and Average
exposures pre-CCF CCF post-CCF PD
PD scale Rm Rm % Rm %
2017
0.00 to < 0.15 4 348 4 348 0.02
0.15 to < 0.25 1 237 99.85 1 236 0.23
0.25 to < 0.50 842 2 994 38.12 1 986 0.34
0.50 to < 0.75 4 582 6 214 39.13 7 014 0.64
0.75 to < 2.50 11 216 2 751 62.32 12 939 1.67
2.50 to < 10.00 560 4 16.79 560 5.13
10.00 to < 100.00 4 345 43.47 152 10.52
100.00 (default) 100.00
Subtotal 21 552 13 545 44.84 28 235 1.12
2016
0.00 to < 0.15 9 747 5 891 42.53 12 236 0.02
0.15 to < 0.25 2 784 1 818 33.10 3 395 0.22
0.25 to < 0.50 6 611 543 41.64 6 816 0.40
0.50 to < 0.75 8 18.49 2 0.66
0.75 to < 2.50 18 7 39.23 20 1.28
2.50 to < 10.00 641 9 72.67 642 3.62
10.00 to < 100.00 5 1 39.40 5 22.19
100.00 (default)
Subtotal 19 806 8 277 41.55 23 116 0.27
1 Refer to page 47 for an explanation of the items included in this analysis.
114
Average Average RWA
Number LGD maturity RWA density EL Provisions
of obligors % Years Rm % Rm Rm
CR6: IRB – CREDIT RISK EXPOSURES BY PORTFOLIO AND PD RANGE (BANKING OPERATIONS)1 CONTINUED
Local government and municipalities
Original Off-balance
on-balance sheet EAD post-
sheet gross exposures Average CRM and Average
exposures pre-CCF CCF post-CCF PD
PD scale Rm Rm % Rm %
2017
0.00 to < 0.15 205 205 0.14
0.15 to < 0.25 3 75.00 3 0.21
0.25 to < 0.50 45 1 9.73 45 0.42
0.50 to < 0.75 391 391 0.64
0.75 to < 2.50 1 442 500 39.50 1 639 1.85
2.50 to < 10.00 13 1 9.74 13 4.33
10.00 to < 100.00 2 2 11.70
100.00 (default) 100.00
Subtotal 2 098 505 39.22 2 298 1.49
2016
0.00 to < 0.15 67 67 0.12
0.15 to < 0.25 2 3 75.00 5 0.23
0.25 to < 0.50 51 700 39.45 329 0.32
0.50 to < 0.75 1 123 199 54.00 1 230 0.64
0.75 to < 2.50 206 72 73.51 277 1.26
2.50 to < 10.00 459 68.59 459 2.85
10.00 to < 100.00 20 20 11.46
100.00 (default) 1 1 100.00
Subtotal 1 929 974 45.06 2 388 1.21
Banks
Original Off-balance
on-balance sheet EAD post-
sheet gross exposures Average CRM and Average
exposures pre-CCF CCF post-CCF PD
PD scale Rm Rm % Rm %
2017
0.00 to < 0.15 42 676 5 633 95.44 48 053 0.07
0.15 to < 0.25 539 272 83.95 768 0.17
0.25 to < 0.50 19 841 76 68.65 19 893 0.45
0.50 to < 0.75 2 52 96.55 52 0.64
0.75 to < 2.50 4 960 956 27.63 5 224 1.37
2.50 to < 10.00 226 63 93.79 285 2.57
10.00 to < 100.00 10.24
100.00 (default) 100.00
Subtotal 68 244 7 052 71.11 74 275 0.27
2016
0.00 to < 0.15 32 774 6 691 87.74 38 645 0.08
0.15 to < 0.25 9 133 593 95.87 9 701 0.21
0.25 to < 0.50 839 311 55.94 1 011 0.33
0.50 to < 0.75 21 25 87.91 43 0.64
0.75 to < 2.50 3 654 407 23.60 3 750 1.48
2.50 to < 10.00 685 793 20.51 848 2.58
10.00 to < 100.00 14 99.76 14 10.26
100.00 (default) 22 22 100.00
Subtotal 47 128 8 834 78.19 54 034 0.29
1 Refer to page 47 for an explanation of the items included in this analysis.
116
Average Average RWA
Number LGD maturity RWA density EL Provisions
of obligors % Years Rm % Rm Rm
CR6: IRB – CREDIT RISK EXPOSURES BY PORTFOLIO AND PD RANGE (BANKING OPERATIONS)1 CONTINUED
Retail mortgages
Original Off-balance
on-balance sheet EAD post-
sheet gross exposures Average CRM and Average
exposures pre-CCF CCF post-CCF PD
PD scale Rm Rm % Rm %
2017
0.00 to < 0.15 2 075 17 801 58.32 12 455 0.11
0.15 to < 0.25 14 479 15 201 62.46 23 974 0.20
0.25 to < 0.50 42 662 5 468 69.11 46 444 0.39
0.50 to < 0.75 61 251 1 645 102.94 62 949 0.63
0.75 to < 2.50 118 891 483 148.05 119 687 1.31
2.50 to < 10.00 50 728 114 118.01 50 888 4.17
10.00 to < 100.00 23 053 2 122.18 23 057 28.01
100.00 (default) 14 316 14 316 100.00
Subtotal 327 455 40 714 62.83 353 770 7.09
2016
0.00 to < 0.15 881 12 805 43.48 6 452 0.12
0.15 to < 0.25 14 597 20 199 45.21 23 744 0.19
0.25 to < 0.50 60 590 5 931 62.21 64 293 0.39
0.50 to < 0.75 51 075 776 124.11 52 051 0.65
0.75 to < 2.50 101 134 339 148.39 101 083 1.35
2.50 to < 10.00 53 908 116 104.76 54 067 4.21
10.00 to < 100.00 24 196 5 84.30 24 201 27.83
100.00 (default) 13 417 13 417 100.00
Subtotal 319 798 40 171 47.47 339 308 7.20
1 Refer to page 47 for an explanation of the items included in this analysis.
2 Average maturity years have not been provided since it has not been used in the RWA calculation.
QRRE
Original Off-balance
on-balance sheet EAD post-
sheet gross exposures Average CRM and Average
exposures pre-CCF CCF post-CCF PD
PD scale Rm Rm % Rm %
2017
0.00 to < 0.15 318 3 990 96.90 4 184 0.11
0.15 to < 0.25 528 2 228 90.35 2 536 0.19
0.25 to < 0.50 1 110 2 507 84.33 3 204 0.35
0.50 to < 0.75 1 906 6 832 39.21 4 250 0.67
0.75 to < 2.50 19 844 14 870 50.66 26 144 1.60
2.50 to < 10.00 28 193 4 736 82.77 30 861 4.44
10.00 to < 100.00 6 484 535 86.16 7 309 26.22
100.00 (default) 6 092 6 092 100.00
Subtotal 64 475 35 698 56.96 84 580 11.64
2016
0.00 to < 0.15 249 4 122 98.63 4 317 0.10
0.15 to < 0.25 398 1 978 89.82 2 173 0.20
0.25 to < 0.50 948 2 493 81.83 2 964 0.35
0.50 to < 0.75 2 008 7 324 35.59 4 470 0.66
0.75 to < 2.50 18 863 13 564 57.32 24 921 1.58
2.50 to < 10.00 29 076 4 828 74.68 31 727 4.59
10.00 to < 100.00 6 102 821 89.04 6 693 26.95
100.00 (default) 6 490 6 490 100.00
Subtotal 64 134 35 130 64.34 83 755 12.17
1 Refer to page 47 for an explanation of the items included in this analysis.
2 Average maturity years have not been provided since it has not been used in the RWA calculation.
118
Average Average RWA
Number LGD maturity2 RWA density EL Provisions
of obligors % Years Rm % Rm Rm
CR6: IRB – CREDIT RISK EXPOSURES BY PORTFOLIO AND PD RANGE (BANKING OPERATIONS) 1 CONTINUED
Retail – other
Original Off-balance
on-balance sheet EAD post-
sheet gross exposures Average CRM and Average
exposures pre-CCF CCF post-CCF PD
PD scale Rm Rm % Rm %
2017
0.00 to < 0.15 38 25 109.21 65 0.13
0.15 to < 0.25 132 8 114.50 142 0.18
0.25 to < 0.50 3 472 21 117.55 3 497 0.28
0.50 to < 0.75 666 21 113.57 690 0.63
0.75 to < 2.50 16 340 47 75.93 16 375 1.63
2.50 to < 10.00 14 970 29 111.48 15 004 5.14
10.00 to < 100.00 4 321 18.08 4 322 22.20
100.00 (default) 1 797 1 797 100.00
Subtotal 41 736 151 98.30 41 892 9.09
2016
0.00 to < 0.15 10 2 119.62 13 0.14
0.15 to < 0.25 128 9 117.04 138 0.20
0.25 to < 0.50 2 409 32 112.85 2 446 0.34
0.50 to < 0.75 494 11 112.75 506 0.64
0.75 to < 2.50 17 652 79 100.98 17 733 1.61
2.50 to < 10.00 12 476 51 112.14 12 533 4.69
10.00 to < 100.00 3 726 118.90 3 726 24.39
100.00 (default) 1 782 1 782 100.00
Subtotal 38 677 184 107.82 38 877 9.20
1 Refer to page 47 for an explanation of the items included in this analysis.
2 Average maturity years have not been provided since it has not been used in the RWA calculation.
SME retail
Original Off-balance
on-balance sheet EAD post-
sheet gross exposures Average CRM and Average
exposures pre-CCF CCF post-CCF PD
PD scale Rm Rm % Rm %
2017
0.00 to < 0.15 2 306 5 350 79.01 6 535 0.07
0.15 to < 0.25 1 963 2 038 74.58 3 479 0.19
0.25 to < 0.50 7 614 2 987 63.07 9 460 0.40
0.50 to < 0.75 2 398 1 384 60.46 3 224 0.59
0.75 to < 2.50 19 813 2 793 58.63 21 454 1.39
2.50 to < 10.00 7 345 2 628 34.52 8 361 4.82
10.00 to < 100.00 3 226 235 39.91 3 584 24.81
100.00 (default) 2 278 2 278 100.00
Subtotal 46 943 17 415 59.04 58 375 6.74
2016
0.00 to < 0.15 2 097 5 189 82.53 6 385 0.07
0.15 to < 0.25 2 208 2 009 78.30 3 774 0.20
0.25 to < 0.50 7 822 3 173 63.89 9 796 0.40
0.50 to < 0.75 2 179 1 354 70.14 3 124 0.59
0.75 to < 2.50 20 648 2 650 63.51 22 323 1.37
2.50 to < 10.00 7 537 2 936 32.66 8 477 4.77
10.00 to < 100.00 3 510 313 36.76 3 612 25.03
100.00 (default) 2 447 2 447 100.00
Subtotal 48 448 17 624 65.76 59 938 6.89
1 Refer to page 47 for an explanation of the items included in this analysis.
2 Average maturity years have not been provided since it has not been used in the RWA calculation.
120
Average Average RWA
Number LGD maturity2 RWA density EL Provisions
of obligors % Years Rm % Rm Rm
CR6: IRB – CREDIT RISK EXPOSURES BY PORTFOLIO AND PD RANGE (BANKING OPERATIONS) 1 CONTINUED
Equity
Original Off-balance
on-balance sheet EAD post-
sheet gross exposures Average CRM and Average
exposures pre-CCF CCF post-CCF PD
PD scale Rm Rm % Rm %
2017
0.00 to < 0.15 68 68 0.11
0.15 to < 0.25
0.25 to < 0.50 595 595 0.39
0.50 to < 0.75 110 110 0.64
0.75 to < 2.50 879 879 0.95
2.50 to < 10.00 580 580 2.56
10.00 to < 100.00 1 1 28.96
100.00 (default) 78 78 100.00
Subtotal 2 311 2 311 4.53
2016
0.00 to < 0.15
0.15 to < 0.25 91 91 0.16
0.25 to < 0.50 283 283 0.32
0.50 to < 0.75 253 253 0.64
0.75 to < 2.50 589 589 1.38
2.50 to < 10.00 607 607 2.62
10.00 to < 100.00
100.00 (default) 78 78 100.00
Subtotal 1 901 1 901 5.51
1 Refer to page 47 for an explanation of the items included in this analysis.
122
Average Average RWA
Number LGD maturity RWA density EL Provisions
of obligors % Years Rm % Rm Rm
2 90.00 5.0 70
16 90.00 5.0 5 960 313.52 92 76
Corporate
2017
0.00 to < 0.15 493 0.09 13 30.31 1.5 89 18.11
0.15 to < 0.25 1 714 0.22 48 32.03 1.2 454 26.48
0.25 to < 0.50 1 867 0.39 149 34.62 1.5 819 43.86
0.50 to < 0.75 1 061 0.64 72 38.45 2.6 765 72.08
0.75 to < 2.50 574 1.26 115 39.06 1.5 480 83.66
2.50 to < 10.00 217 3.01 43 39.22 1.1 228 105.19
10.00 to < 100.00 6 38.70 3 37.80 1.0 13 202.29
100.00 (default) 100 2 40.09 1.0 1 531.19
Subtotal 5 932 0.59 445 34.80 1.6 2 849 48.03
2016
0.00 to < 0.15 410 0.08 17 34.35 1.1 61 0.15
0.15 to < 0.25 2 428 0.20 47 34.24 1.9 733 0.30
0.25 to < 0.50 3 385 0.40 157 35.28 1.5 1 337 0.39
0.50 to < 0.75 705 0.64 83 36.38 2.7 465 0.66
0.75 to < 2.50 336 1.32 117 38.55 1.6 281 0.84
2.50 to < 10.00 390 3.42 51 38.48 1.2 424 1.09
10.00 to < 100.00
100.00 (default)
Subtotal 7 654 0.58 472 35.32 1.8 3 301 0.49
SME Corporate
2017
0.00 to < 0.15 42 0.08 1 40.09 5.0 15 36.22
0.15 to < 0.25 14 0.23 1 43.89 5.0 8 57.77
0.25 to < 0.50 36 0.32 3 40.09 1.0 14 38.96
0.50 to < 0.75 69 0.64 8 40.09 2.4 44 64.01
0.75 to < 2.50 33 1.14 11 41.36 2.6 32 95.62
2.50 to < 10.00 6 4.17 6 30.62 1.0 5 82.34
10.00 to < 100.00 10.24 1 40.09 1.0 145.79
100.00 (default)
Subtotal 200 0.63 31 40.30 2.9 118 59.06
2016
0.00 to < 0.15 151 0.09 2 40.09 4.2 49 0.32
0.15 to < 0.25 258 0.16 3 40.27 1.2 70 0.27
0.25 to < 0.50 130 0.40 2 40.09 1.0 57 0.44
0.50 to < 0.75 56 0.64 7 34.73 3.6 37 0.66
0.75 to < 2.50 167 1.27 19 39.48 4.5 156 0.93
2.50 to < 10.00 43 3.62 9 39.49 1.0 39 0.91
10.00 to < 100.00
100.00 (default)
Subtotal 805 0.64 42 39.62 2.6 408 0.51
124
Securities firm
2017
0.00 to < 0.15 6 449 0.05 12 38.98 1.1 1 004 15.57
0.15 to < 0.25 0.23 2 40.09 1.0 30.70
0.25 to < 0.50 1 171 0.45 8 39.07 1.0 696 59.45
0.50 to < 0.75 4 0.64 3 38.65 1.0 3 69.97
0.75 to < 2.50
2.50 to < 10.00 2.56 2 31.11 1.0 76.28
10.00 to < 100.00
100.00 (default)
Subtotal 7 624 0.12 27 38.99 1.1 1 703 22.34
2016
0.00 to < 0.15 8 011 0.07 10 40.42 1.6 1 891 0.24
0.15 to < 0.25 478 0.16 8 42.80 1.2 178 0.70
0.25 to < 0.50 285 0.32 4 40.09 1.0 143 0.50
0.50 to < 0.75 0.64 1 40.09 1.0
0.75 to < 2.50 1 1.81 4 40.09 1.0 1 1.00
2.50 to < 10.00
10.00 to < 100.00
100.00 (default)
Subtotal 8 775 0.09 27 40.55 1.50 2 213 0.25
Sovereign
2017
0.00 to < 0.15 1 538 0.01 2 28.13 1.0 36 2.30
0.15 to < 0.25 770 0.23 1 32.77 4.6 400 51.89
0.25 to < 0.50
0.50 to < 0.75
0.75 to < 2.50 1 0.90 1 26.29 4.1 67.36
2.50 to < 10.00
10.00 to < 100.00
100.00 (default)
Subtotal 2 309 0.08 4 29.67 2.2 436 18.87
2016
0.00 to < 0.15 1 471 0.01 2 27.78 1.1 35 0.02
0.15 to < 0.25 517 0.23 1 32.77 4.9 281 0.54
0.25 to < 0.50
0.50 to < 0.75
0.75 to < 2.50
2.50 to < 10.00
10.00 to < 100.00
100.00 (default)
Subtotal 1 988 0.07 3 29.07 2.10 316 0.16
CCR4: IRB – CCR EXPOSURES BY PORTFOLIO AND PD SCALE (BANKING OPERATIONS) CONTINUED
Public sector entities
2017
0.00 to < 0.15
0.15 to < 0.25 0.23 1 26.29 1.0 20.13
0.25 to < 0.50 987 0.42 4 42.54 3.1 717 72.82
0.50 to < 0.75 131 0.64 2 26.29 1.6 54 41.11
0.75 to < 2.50 318 1.80 3 26.29 2.5 220 68.94
2.50 to < 10.00 4 5.12 2 26.29 1.0 4 82.44
10.00 to < 100.00 10.24 1 26.29 1.0 109.91
100.00 (default)
Subtotal 1 440 0.76 13 37.41 2.8 995 69.10
2016
0.00 to < 0.15
0.15 to < 0.25 33 0.23 4 26.29 3.7 12 0.36
0.25 to < 0.50 408 0.24 3 28.61 3.3 202 0.50
0.50 to < 0.75
0.75 to < 2.50
2.50 to < 10.00 6 3.62 1 26.29 1.0 5 0.83
10.00 to < 100.00
100.00 (default)
Subtotal 447 0.45 8 28.41 3.30 219 0.49
2017
0.00 to < 0.15
0.15 to < 0.25
0.25 to < 0.50 197 0.36 13 18.56 4.3 68 34.74
0.50 to < 0.75 438 0.64 6 32.75 4.7 354 80.85
0.75 to < 2.50 335 1.06 6 31.29 4.8 279 83.13
2.50 to < 10.00 5 7.24 1 33.18 5.0 8 156.66
10.00 to < 100.00
100.00 (default)
Subtotal 975 0.76 26 29.38 4.6 709 72.71
1 2016 numbers were not available and have therefore not been shown here.
126
Banks
2017
0.00 to < 0.15 9 003 0.05 45 39.21 2.0 2 008 22.31
0.15 to < 0.25
0.25 to < 0.50 3 130 0.45 7 45.98 1.4 2 391 76.39
0.50 to < 0.75 114 0.64 5 47.04 1.5 82 71.85
0.75 to < 2.50 137 1.14 18 48.75 1.0 126 92.42
2.50 to < 10.00 4 3.98 4 52.43 1.0 6 148.92
10.00 to < 100.00 10.24 1 55.44 1.0 270.59
100.00 (default)
Subtotal 12 388 0.17 80 41.10 1.8 4 613 37.23
2016
0.00 to < 0.15 17 932 0.06 43 39.81 1.6 3 783 0.21
0.15 to < 0.25 2 342 0.16 3 43.89 1.5 989 0.42
0.25 to < 0.50 174 0.37 5 45.35 2.6 131 0.75
0.50 to < 0.75 13 0.64 4 47.04 1.0 9 0.69
0.75 to < 2.50 675 1.27 16 49.11 1.0 637 0.94
2.50 to < 10.00 3.31 4 51.85 1.0 1.38
10.00 to < 100.00
100.00 (default)
Subtotal 21 136 0.11 75 40.61 1.60 5 549 0.26
2017 2016
Basel III Basel III
Rm Rm
1 Disclosure based on prescribed SARB template. All blank line items are not applicable as at 31 December 2017 and 31 December 2016.
128
2017 2016
Basel III Basel III
Rm Rm
Directly issued capital instruments subject to phase-out from AT1 5 495 5 495
AT1 instruments (and CET I instruments not included in common share capital) issued by
subsidiaries and held by third-parties (amount allowed in group AT1), including: 416 322
Instruments issued by subsidiaries subject to phase-out
Regulatory adjustments
Total regulatory adjustments to AT1 capital
Investments in own AT1 instruments
Reciprocal cross-holdings in AT1 instruments
Investments in the capital of banking, financial and insurance entities that are outside the
scope of regulatory consolidation, net of eligible short positions, where the bank does not
own more than 10% of the issued share capital (amount above 10% threshold)
Significant investments in the common stock of banking, financial and insurance entities
that are outside the scope of regulatory consolidation, net of eligible short positions
(amount above 10% threshold)
National-specific regulatory adjustments:
Regulatory adjustments applied to CET I in respect of amounts subject to pre-Basel III
treatment
Regulatory adjustments applied to AT1 due to insufficient AT1 due to insufficient tier II to cover
deductions
2017 2016
Basel III Basel III
Rm Rm
16 950 20 130
Total capital 141 939 138 150
Total RWA 957 046 883 179
Risk-weighted in respect of amounts subject to pre-Basel III treatment
130
2017 2016
Basel III Basel III
Rm Rm
132
CONTACT AND OTHER DETAILS
STANDARD BANK GROUP
Registration No. 1969/017128/06
Incorporated in the Republic of South Africa
GROUP SECRETARY
Zola Stephen
Tel: +27 11 631 9106 Please direct all customer-related queries
and comments to:
REGISTERED ADDRESS Information@standardbank.co.za
9th Floor, Standard Bank Centre
5 Simmonds Street
Johannesburg 2001
Please direct all investor relations queries
PO Box 7725
and comments to:
Johannesburg 2000
InvestorRelations@standardbank.co.za
Disclaimer
This document contains certain statements that are ‘forward-looking’ with respect to certain of the group’s plans, goals and
expectations relating to its future performance, results, strategies and objectives. Words such as “may”, “could”, “will”, “expect”, “intend”,
“estimate”, “anticipate”, “aim”, “outlook”, “believe”, “plan”, “seek”, “predict” or similar expressions typically identify forward-looking
statements. These forward-looking statements are not statements of fact or guarantees of future performance, results, strategies and
objectives, and by their nature, involve risk and uncertainty because they relate to future events and circumstances which are difficult to
predict and are beyond the group’s control, including but not limited to, domestic and global economic conditions, market-related risks
such as fluctuations in interest rates and exchange rates, the policies and actions of regulatory authorities (including changes related to
capital and solvency requirements), the impact of competition, as well as the impact of changes in domestic and global legislation and
regulations in the jurisdictions in which the group and its affiliates operate. The group’s actual future performance, results, strategies
and objectives may differ materially from the plans, goals and expectations expressed or implied in the forward-looking statements.
The group makes no representations or warranty, express or implied, that these forward-looking statements will be achieved and
undue reliance should not be placed on such statements. The group undertakes no obligation to update the historical information or
forward-looking statements in this document and does not assume responsibility for any loss or damage arising as a result of the
reliance by any party thereon.
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