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Basel III Handbook

Table of Contents
Figures 4

Tables 4

Abbreviations 5

1 Introduction 6

2 Definition of capital and capital buffers 12

2.1 New definition of capital 14

2.2 Components of capital 16

2.2.1 Common Equity Tier 1 capital 16


2.2.2 Additional Tier 1 capital 18
2.2.3 Tier 2 capital 19
2.3 Prudential filters and deductions 20

2.3.1 Prudential filters 20


2.3.2 Deductions from CET 1 capital 21
2.3.3 Exemptions from and alternatives to deduction from CET 1 items 22
2.3.4 Deductions from Additional Tier 1 capital 22
2.3.5 Deductions from Tier 2 items 23
2.4 Minority interests 24

2.4.1 Minority interests that qualify for inclusion in consolidated CET 1 capital 24
2.4.2 Qualifying Additional Tier 1, Tier 1, Tier 2 capital and qualifying own funds 24
2.5 Institutional networks 24

2.6 Capital buffers 25

2.6.1 Capital conservation buffer 25


2.6.2 Countercyclical capital buffer 25
2.7 Enhanced disclosure requirements 25

3 Counterparty Credit Risk 26

3.1 Effective Expected Positive Exposure 28

3.2 Credit valuation adjustment 28

3.3 Wrong way risk 29

3.4 Asset value correlation 29

3.5 Central counterparties 29

3.6 Enhanced CCR management requirements 29

2
4 Leverage ratio 30

4.1 Definition and calibration 32

5 Global liquidity standard 34

5.1 Liquidity Coverage Ratio 37

5.1.1. Definition of high quality liquid assets 38


5.1.2. Definition of net liquidity outflows 40
5.2 Net Stable Funding Ratio 42

5.3 Monitoring tools 45

5.4 Institutional networks 45

6 Enhanced governance and sanctions 46

6.1 Enhanced governance 48

6.2 Sanctions 48

7 Other topics 50

7.1 Systemically Important Financial Institutions 52

7.2 Overreliance on external ratings 53

7.3 Small and Medium-Sized Entity 53

7.4 Basel I limit 53

8 Conclusion 54

Bibliography 57

Appendix 58

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Figures
Figure 1: From Basel 2.5 to Basel III 9

Figure 2: Capital requirements Basel II/Basel 2.5 vs. Basel III 15

Figure 3: Phase-in arrangements Basel III capital requirements 15

Figure 4: Leverage Ratio within Basel III 32

Figure 5: Liquidity risk management (LRM) framework 36

Figure 6: Liquidity Coverage Ratio 37

Figure 7: LCR: High quality liquid assets 39

Figure 8: LCR: Net liquidity outflows 40

Figure 9: LCR: High quality liquid assets and net liquidity outflows 41

Figure 10: Net Stable Funding Ratio 43

Figure 11: NSFR: Available stable funding 43

Figure 12: NSFR: Required stable funding 44

Figure 13: AVC: Risk-Weights for large financial institutions – Basel II vs. Basel III 60

Tables
Table 1: Flexibility of member states within the single rule book 10

Table 2: Prudential filters Basel III 20

Table 3: Deduction from CET 1 capital in Basel III 21

Table 4: Deduction from Additional Tier 1 capital in Basel III 22

Table 5: Deductions from Additional Tier 2 capital in Basel III 23

Table 6: Options on corporate governance 49

Table 7: Basel III Summary Table 58

Table 8: AVC: Risk-Weights for large financial institutions – Basel II vs. Basel III 60

Table 9: Indicator-based measurement approach G-SIBS 61

Table 10: Ancillary indicators for assessment G-SIBS 61

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Abbreviations
ASF Available Stable Funding

BCBS Basel Committee on Banking Supervision

CIU Collective Investment Undertaking

CCP Central Counterparty

CCR Counterparty Credit Risk

CEM Current Exposure Method

CET1 Common Equity Tier 1

CRD Capital Requirements Directive

CVA Credit Valuation Adjustment

EBA European Banking Authority

EPE Expected Positive Exposure

FSB Financial Stability Board

FY Financial Year

G-SIBs Global Systemically Important Banks

IMM Internal Model Method

LCR Liquidity Coverage Ratio

MDA Maximum Distributable Amount

NSFR Net Stable Funding Ratio

OTC Over-the-Counter

PD Probability of Default

PSE Public Sector Entity

RSF Required Stable Funding

RW Risk-Weight

SIBs Systemically Important Banks

SIFIs Systemically Important Financial Institutions

SM Standardized Method

SME Small and Medium-Size Entity

SSPE Securitization Special Purpose Entity

VaR Value-at-Risk

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1
Introduction

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7
Recent financial crises have demonstrated numerous
weaknesses in the global regulatory framework and
in banks’ risk management practices. In response,
regulatory authorities have considered various measures
to increase the stability of the financial markets and
prevent future negative impact on the economy. One
major focus is on strengthening global capital and
liquidity rules.

Basel III addresses this, with the goal Definition of capital Enhanced risk coverage/
of improving the banking sector’s Counterparty Credit Risk
Introduction of a new definition
ability to absorb shocks arising from
of capital to increase the quality, The reforms to the Basel II framework
financial and economic stress. In
consistency and transparency of by the BCBS in 2009 and the
December 2010 the Basel Committee
the capital base. As the recent crisis amendments made in the European
on Banking Supervision (BCBS)
demonstrated that credit losses and Capital Requirements Directive
published the Basel III documents
write-downs come out of retained III (CRD III)2 increased capital
“Basel III: A global regulatory
earnings, which is part of banks’ requirements for the trading book
framework for more resilient banks and
tangible common equity base, under and complex securitization positions
banking systems” (a revised version
Basel III common equity (i.e., common and introduced stressed value-at-risk
was published in June 2011) and “Basel
shares and retained earnings) must be capital requirements and higher capital
III: International framework for liquidity
the predominant form of Tier 1 capital. requirements for re-securitizations
risk measurement, standards and
Further, the reform package removes for both in the banking and trading
monitoring.”
the existing inconsistency in the book. Basel III now adds the following
With this reform package, the BCBS definition of capital by harmonizing reforms: calculation of the capital
aims to improve risk management deductions of capital and by increasing requirements for counterparty credit
and governance as well as strengthen transparency through disclosure risk (CCR) based on stressed inputs;
banks’ transparency and disclosure. requirements. introduction of a capital charge for
Basel III is also designed to strengthen potential mark-to-market losses (i.e.,
the resolution of systemically credit valuation risk); strengthening
significant cross-border banks. standards for collateral management
It covers primarily the following and initial margining; higher capital
aspects1: requirements for OTC derivatives
exposures; raising CCR management
standards.

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Leverage ratio Global liquidity standard This handbook provides a detailed
overview of the major changes of
Introduction of a leverage ratio as A new liquidity standard is introduced
Basel III corresponding to the EU rules.
a supplementary measure to the to achieve two objectives. The first
It focuses on aspects related to banks.
risk-based framework of Basel II. The objective, pursued by the Liquidity
Amendments regarding supervisory
objective is to constrain the build-up Coverage Ratio (LCR), is to promote
authorities in the context of enhanced
of leverage and avoid destabilizing short-term resilience of a bank’s
supervision are not covered in detail.
deleveraging processes. liquidity risk profile by ensuring that
The status of topics currently under
it has sufficient high quality liquid
discussion is included here, as are
Reducing procyclicality and assets to survive a stress scenario
differences between the EU rules
lasting one month. The second
promoting countercyclical buffers and the Basel III documents from
objective is to promote resilience over
the BCBS.
Introduction of measures to make the longer term by creating additional
banks more resilient to procyclical incentives for a bank to fund its The enhancements of the capital
dynamics and avoid the destabilizing activities with more stable sources framework within “Basel 2.5” (CRD
effects experienced in the last crisis. of funding. The Net Stable Funding II and CRD III in the EU), which are
The main objectives of these measures Ratio (NSFR), with a time horizon of already in force or become applicable
are: dampen any excess cyclicality one year, should provide a sustainable beginning in 2012 are not within
of the minimum capital requirement; maturity structure of assets and the scope of this manual. Nor are
promote more forward-looking liabilities. Basel III also introduces a the challenges banks face with
provisions; conserve capital to build common set of monitoring tools. The the implementation of the Basel III
buffers at individual banks and in new requirements complement the requirements.5
the banking sector that can be used “Principles for Sound Liquidity Risk
in periods of stress testing; achieve Management and Supervision”3 which
the broader macro-prudential goal of are included in the CRD II.4 The CRD
protecting the banking sector from II requirements, implemented into
periods of excess credit growth. national law by the EU Member States,
became effective December 31, 2010.

Figure 1: From Basel 2.5 to Basel III

“Basel 2.5” “Basel III”


Legal basis (EU) • CRD (2009/111/ • CRD (2010/76/ • "CRD IV“ (package of two legal instruments: directive
EC) published in the EU) published in the and regulation)
Official Journal (Nov. Official Journal (Dec.
2009) (CRD II) 2010) (CRD III)
Status • Transposed into • Partially • "Basel III“ published by the BCBS in Dec. 2010 (rev.
European/ national law transposed into version of capital framework June 2011)
national national law
• Directive and Regulation published by the European
implementation
Commission in July 2011; discussed by Parliament and
Council in autumn 2011/beginning of 2012
• Directive: to be translated into national law till Dec.
31, 2012; Regulation: no national translation required
Coming into • Dec. 31, 2010 • Dec. 31, 2011 • Jan. 1, 2013 (with transition periods till 2019)
force

Topics • Large exposures • Re-securitization Regulation evrcitiD


• Securitization • Disclosure • Definition of capital • Capital buffers
•H  ybrid capital securitization risks • Enhanced governance
• Liquidity risk
instruments • Trading book • Sanctions
• Counterparty credit risk
• L iquidity risk • Remuneration • Enhanced supervision
• Leverage ratio
management policies
• Single rule book
•C  ross border
(through Regulation)
supervision

Source: Accenture

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Basel II and the reform packages of are implemented through a Directive.
“Basel 2.5” are implemented through Following the European legislative
directives in the EU (CRD, CRD II, process, the next step is for the legal
CRD III). That is, the rules need to documents published by the European
be transposed into national law Commission (the proposed Regulations
with several options and discretions and Directives) to be discussed within
at the national level. Basel III is the European Parliament and Council.
introduced through two different
legal instruments.6 Most of the key Despite the single rule book, Member
topics, such as the new definition of States will retain some flexibility in
capital and the new liquidity ratios, specific areas which are summarized
are implemented through a Regulation in Table 1:
(a directly applicable legal act, with
no further national implementation
needed). The objective is to create a
level playing field (single rule book).
Other aspects, including capital
buffers and enhanced governance,

Table 1: Flexibility of Member States within the single rule book

Type of Measure Compatible with Single Rule


Book?
EU Macro-prudential Measures
Pillar 1
Does not preclude the measure Power for the Commission to tighten Measure is embedded in the Single
being specifically targeted to certain the requirements temporarily across Rule Book. It uniformly applies to all
regional exposures the board for specific activities and institutions across Europe that have
exposures. Special urgency procedure the type of exposure concerned.
is possible for swift response to
macro-prudential developments.

National Measures
Capital requirements for real estate Special procedure in the Regulation Measure is embedded in the Single
lending under which Member States can both Rule Book. The requirements set by
raise capital requirements and tighten country A apply also to institutions in
loan-to-value limits for loans secured country B that do business in A.
by commercial and/or residential
property.
Countercyclical buffer Member States can set an additional Measure is embedded in the Single
buffer requirement to dampen excess Rule Book. The requirements set by
lending growth more generally. This is country A apply also to institutions in
to protect the economy/banking sector country B that do business in A. This
from any other structural variables "reciprocity" is mandatory only up to
and from the exposure of the banking 2.5%.
sector to risk factors related to
financial stability.
Pillar 2
"Pillar 2" measures National supervisors can impose a Measures are included in the Directive.
wide range of measures, including They must be justified in terms of
additional capital requirements, on particular risks of a given institution
individual institutions or groups of or group of institutions, including risks
institutions to address higher-than- pertaining to a particular region or
normal risk. sector. Further convergence of such
measures will be sought over time.

Source: CRD IV – Frequently Asked questions (July 2011), European Commission found at EUROPA - Press Releases - CRD IV – Frequently Asked Questions

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11
2
Definition of capital and
capital buffers

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13
2.1 New definition of capital
The financial crisis showed that not The own funds requirements under instruments that are currently used
all institutions did hold sufficient Basel III are the following (as a but do not meet the new rules. They
capital and that the capital was percentage of risk-weighted assets, are phased out over a 10-year period
sometimes of poor quality and not RWA): beginning in 2013 (10% a year). While
available to absorb losses as they the proposals of the BCBS require that
materialized. Basel III introduces • CET 1 capital ratio of 4.5%; these instruments were issued prior
– based on the amendments made • Tier 1 capital ratio of 6%; to the date of agreement of the new
under the CRD II with regard to hybrid rules by Basel (September 12, 2010),
capital instruments – a new definition • Total capital ratio of 8%. instruments issued after this cut off
of capital to increase the quality, Total capital ratio will remain 8% of date would need to comply with the
consistency and transparency of the RWA. CET 1 capital ratio increases new rules or would not be recognized
capital base. It also requires higher from 2% to 4.5%. Additional Tier 1 as capital as of January 1, 2013. The
capital ratios. Key elements of the capital ratio is 1.5%, leading to a Tier proposals of the EU Regulation set the
revision include7: 1 capital ratio of 6%. The importance cut off date "as the date of adoption
of Tier 2 capital decreases by reducing of the proposal by the Commission,
• Raise quality and quantity of Tier 1 when the Commission as a College
the ratio to 2% of RWA.
capital; agreed to legally implement Basel
• Simplification and reduction of Tier Apart from these changes, Basel III III in the EU. Setting a cut off date
2 capital; will introduce two new capital buffers: prior to this policy decision would
a capital conservation buffer of neither be legitimate nor legally
• Elimination of Tier 3 capital; 2.5% and a countercyclical buffer of sound, as it would apply the new rules
• More stringent criteria for each 0-2.5% depending on macroeconomic retroactively.”8
instrument; circumstances (see section 2.6 for a
detailed description of the buffers). For The latest proposals from the BCBS
• Harmonization of regulatory both buffers, an extra cushion of CET follow a principles-based approach
adjustments; 1 capital needs to be held leading to a in regard to capital, with the focus
• Enhanced disclosure requirements; CET 1 capital ratio of up to 9.5%. on the substance of the capital
instruments. They also ensure that the
• Introduction of a new limit system Additional capital surcharges between new rules are capable of being applied
for the capital elements. 1% and 2.5% (extra cushion of CET to the highest-quality capital items
1 capital) for systemically important of non-joint stock companies, such as
According to the new definition, financial institutions (SIFIs) – cooperative banks. Through a set of
capital comprises the following depending on the systemic importance principles, the EU standard specifies
elements: of the institution – are currently in in greater detail the application
discussion. of the new definition of capital to
• Going-concern capital (Tier 1
instruments issued by non-joint
capital); On top of these own funds stock companies to ensure they hold
- Common Equity Tier 1 capital (CET 1 requirements, supervisory authorities comparable levels of high quality Tier
capital): Common equity (i.e., common may require extra capital to cover 1 capital. Like the BCBS proposals,
shares and retained earnings) must be other risks following Pillar 2 (as it is it imposes 14 strict criteria that
the predominant form of Tier 1 capital also under the current framework). instruments need to meet.

- Additional Tier 1 capital Basel III foresees a transition period


before the new capital requirements
• Gone-concern capital (Tier 2 capital). apply in full. The going concern
(Tier 1) capital requirements will
While going-concern capital (Tier be implemented gradually between
1) should allow an institution to 2013 and 2015; the capital buffers
continue its activities and help prevent between 2016 and 2019. The new
insolvency, gone-concern capital (Tier prudential adjustments will be
2) would help ensure that depositors introduced gradually, 20% a year
and senior creditors can be repaid if from 2014, reaching 100% in 2018.
the institution fails. Grandfathering provisions over 10
years would also apply to capital

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Figure 2: Capital requirements Basel II/Basel 2.5 vs. Basel III

16%
SIBs capital surcharge
14% (in discussion)

12% Countercyclical capital buffer–


extra cushion of CET 1
10% Capital conservation buffer–
extra cushion of CET 1
8%
Tier 3 capital
Lower Tier 2 capital–
Tier 2 capital–
6% max. 50% Tier 1 capital
max. 100% of
Tier 1 capital Upper Tier 2 capital
4% Total capital
Max. 50% of Tier 1 capital innovative
Tier 1 capital hybrid capital max. 15% of Tier 1 capital
2%

0%
Basel ll/Basel 2.5 Basel III

CET 1 capital (certain Tier 1 items) SIBs surcharge (in discussion 1-2.5%) Countercyclical capital buffer (0-2.5%)
Tier 2 capital Additional Tier 1 capital (hybrid capital)
Capital conservation buffer Tier 3 capital

Source: Accenture, based on Basel III – Leitfaden zu den neuen Eigenkapital- und Liquidititätsregeln für Banken (2011), Bundesbank and CRD IV – Frequently Asked Questions
(2011), European Commission.
Note: The treatment of hybrid capital instruments was amended within the CRD II (harmonization of the eligibility criteria and limits of hybrid capital instruments); further
amendments follow within Basel III.

Figure 3: Phase-in arrangements Basel III capital requirements

14%

12% 2.5%
1.875%
10% 1.25%
0.625% 1.875% 2.5%
0.625% 1.25%
8%
2.5% 2.0% 2.0% 2.0% 2.0% 2.0%
4.0% 3.5%
6%
1.5% 1.5% 1.5% 1.5% 1.5%
1.5%
4% 1.0%
2.0%
2% 4.0% 4.5% 4.5% 4.5% 4.5% 4.5%
3.5%
2.0%
0%
Until 2012 2013 2014 2015 2016 2017 2018 From 2019

CET 1 capital Additional Tier 1 capital Tier 2 capital


Capital conservation buffer Countercyclical capital buffer
Source: New proposals on capital requirements (July 2011), European Commission.

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2.2 Components of capital
2.2.1 Common Equity The European Banking Authority f) The principal amount of the
(EBA) has the mandate to develop instruments may not be reduced
Tier 1 capital draft regulatory technical standards or repaid, except in either of the
A key aspect of the stricter definition to specify the points previously following cases:
of capital is that Common Equity mentioned. These include features
that could cause the condition of an i) The liquidation of the institution;
Tier 1 (CET 1) instruments – mainly
common shares (or comparable institution to be weakened as a going ii) Discretionary repurchases of the
instruments) and retained earnings concern during periods of market instruments or other discretionary
– must be the predominant form stress. means of reducing capital, where
of Tier 1 capital. According to the the institution has received the prior
According to Article 26 of the
proposed EU Regulation, CET 1 items consent of the competent authority
proposed EU Regulation, capital
consist of the following:9 in accordance with Article 72 of the
instruments need to meet all of the
proposed EU Regulation;
a) Capital instruments, provided the following conditions to qualify as
conditions laid down in Article 26 of CET 1 items:10 g) The provisions governing the
the proposed EU Regulation are met; instruments do not indicate expressly
a) The instruments are issued or implicitly that the principal amount
b) Share premium accounts related to directly by the institution with the of the instruments would or might
the instruments referred to in point a; prior approval of the owners of be reduced or repaid other than in
the institution or, where permitted the liquidation of the institution, and
c) Retained earnings; under applicable national law, the the institution does not otherwise
management body of the institution; provide such an indication prior to or
d) Accumulated other comprehensive
at issuance of the instruments, except
income; b) The instruments are paid up and in the case of instruments referred
their purchase is not funded directly or to in Article 25 of the proposed EU
e) Other reserves;
indirectly by the institution; Regulation, where the refusal by the
f) Funds for general banking risk. institution to redeem such instruments
c) The instruments meet all the
is prohibited under applicable
CET 1 items of mutuals, cooperative following conditions as regards their
national law;
societies or similar institutions classification:
include capital instruments by an h) The instruments meet the following
i) They qualify as capital within the
institution under its statutory terms conditions as regards distributions:
meaning of Article 22 of Directive
provided the following conditions are
86/635/EEC; i) There are no preferential
met:
ii) They are classified as equity distributions, including in relation
a) The institution is of a type that to other Common Equity Tier 1
within the meaning of the applicable
is defined under applicable national instruments, and the terms governing
accounting standard;
law and which competent authorities the instruments do not provide
consider to qualify as a mutual, iii) They are classified as equity capital preferential rights to payment of
cooperative society or a similar for the purposes of determining distributions;
institution; balance sheet insolvency, where
applicable under national insolvency ii) Distributions to holders of the
b) The conditions laid down in law; instruments may be paid only out of
Articles 26 and 27 of the proposed EU distributable items;
d) The instruments are clearly and
Regulation are met; iii) The conditions governing the
separately disclosed on the balance
sheet in the financial statements of instruments do not include a cap or
c) The instrument does not possess
the institution; other restriction on the maximum level
features that could cause the
of distributions, except in the case
condition of the institution to be
e) The instruments are perpetual; of the instruments referred to in
weakened as a going concern during
Article 25 of the proposed EU
periods of market stress.
Regulation;

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iv) The level of distributions is not m) The instruments are not subject
determined on the basis of the amount to any arrangement, contractual or
for which the instruments were otherwise, that enhances the seniority
purchased at issuance, and is not of claims under the instruments in
otherwise determined on this basis, insolvency or liquidation.
except in the case of the instruments
referred to in Article 25 of the Capital instruments issued by
proposed EU Regulation; mutuals, cooperative societies and
similar institutions need to meet
v) The conditions governing the the conditions mentioned in Article
instruments do not include any 26 of the proposed EU Regulation
obligation for the institution to make (see above) as well as the following
distributions to their holders and the conditions as with respect to the
institution is not otherwise subject to redemption of the capital instruments
such an obligation; to qualify as CET 1 instruments:
vi) Non-payment of distributions does
not constitute an event of default of a) Except where prohibited under
the institution; applicable national law, the institution
shall be able to refuse the redemption
i) Compared to all the capital of the instruments;
instruments issued by the institution,
the instruments absorb the first b) Where the refusal by the institution
and proportionately greatest share of the redemption of instruments is
of losses as they occur, and each prohibited under applicable national
instrument absorbs losses to the same law, the provisions governing the
degree as all other Common Equity Tier instruments shall give the institution
1 instruments; the ability to limit their redemption;

j) The instruments rank below all other c) Refusal to redeem the instruments,
claims in the event of insolvency or or the limitation of the redemption of
liquidation of the institution; the instruments where applicable, may
not constitute an event of default of
k) The instruments entitle their owners the institution.
to a claim on the residual assets of
the institution, which, in the event of The EU also addresses the topic of
its liquidation and after the payment “silent partnership,” pointing out that
of all senior claims, is proportionate it is a generic term covering capital
to the amount of such instruments instruments with widely varying
issued and is not fixed or subject to a characteristics (e.g., in terms of ability
cap, except in the case of the capital to absorb losses). Whether or not silent
instruments referred to in Article 25 of partnership would qualify as a CET 1
the proposed EU Regulation; item depends on the characteristics
of the instrument. The items must be
l) The instruments are not secured, or of extremely high quality and able to
guaranteed by any of the following: absorb losses fully as they occur.11
i) The institution or its subsidiaries;
The CET 1 capital should include
ii) The parent institution or its CET 1 items after the application of
subsidiaries; regulatory adjustments, deductions
iii) The parent financial holding and exemptions and alternatives.
company or its subsidiaries;
iv) The mixed activity holding
company or its subsidiaries;
v) The mixed financial holding
company and its subsidiaries;
vi) Any undertaking that has close
links with the entities referred to in
points (i) to (v);

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2.2.2 Additional Tier 1 g) The instruments are perpetual and m) The instruments do not contribute
the provisions governing them include to a determination that the liabilities
capital no incentive for the institution to of an institution exceed its assets,
Additional Tier 1 instruments include: redeem them; where such a determination
a) instruments where the below- constitutes a test of insolvency under
h) Where the provisions governing applicable national law;
mentioned conditions of Article 49 of
the instruments include one or more
the proposed EU Regulation are met;
call options, the option to call may be n) The provisions governing the
and b) the share premium accounts
exercised at the sole discretion of the instruments require the principal
related to these instruments.
issuer; amount of the instruments to be
According to Article 49 of the written down, or the instruments to be
i) The instruments may be called, converted to CET 1 instruments, upon
proposed EU Regulation, capital
redeemed or repurchased only where the occurrence of a trigger event;
instruments need to meet all of the
the conditions laid down in Article
following conditions to qualify as
72 of the proposed EU Regulation are o) The provisions governing the
additional Tier 1 capital items:
met, and not before five years after instruments include no feature that
a) The instruments are issued and the date of issuance; could hinder the recapitalization of the
paid up; institution;
j) The provisions governing the
b) The instruments are not purchased instruments do not indicate explicitly p) Where the instruments are not
by any of the following: or implicitly that the instruments issued directly by the institution or
would or might be called, redeemed by an operating entity within the
i) The institution or its subsidiaries; or repurchased and the institution consolidation pursuant to prudent
does not otherwise provide such an consolidation (Chapter 2 of Title II of
ii) An undertaking in which the
indication; Part One), the parent institution, the
institution has participation in the
parent financial holding company, or
form of ownership, direct or by way of k) The institution does not indicate the mixed activity holding company,
control, of 20% or more of the voting explicitly or implicitly that the the proceeds are immediately available
rights or capital of that undertaking; competent authority would consent to without limitation in a form that
c) The purchase of the instruments is a request to call, redeem or repurchase satisfies the conditions laid down in
not funded directly or indirectly by the the instruments; this paragraph to any of the following:
institution;
l) Distributions under the instruments i) The institution;
d) The instruments rank below Tier meet the following conditions:
2 instruments in the event of the ii) An operating entity within the
insolvency of the institution; i) They are paid out of distributable consolidation pursuant to Chapter 2 of
items; Title II of Part One;
e) The instruments are not secured, or ii) The level of distributions made on
guaranteed by any of the following: iii) The parent institution;
the instruments will not be modified
based on the credit standing of the iv) The parent financial holding
i) The institution or its subsidiaries;
institution, its parent institution or company;
ii) The parent institution or its parent financial holding company or
v) The mixed activity holding company.
subsidiaries; mixed activity holding company;
The EU standard12 requires that all
iii) The parent financial holding iii) The provisions governing the
capital instruments recognized in the
company or its subsidiaries; instruments give the institution full
Additional Tier 1 capital are written
discretion at all times to cancel the
iv) The mixed activity holding down or converted into Common
distributions on the instruments for
company or its subsidiaries; Equity Tier 1 instruments when the
an unlimited period and on a non-
CET 1 capital ratio falls below 5.125%
v) The mixed financial holding cumulative basis, and the institution
(contingent capital). Contingent capital
company and its subsidiaries; may use such cancelled payments
not fulfilling these requirements
without restriction to meet its
vi) Any undertaking that has close will not be recognized as
obligations as they fall due;
links with entities referred to in points regulatory capital.
(i) to (v); iv) Cancellation of distributions does
not constitute an event of default of
f) The instruments are not subject
the institution;
to any arrangement, contractual or
otherwise, that enhances the seniority v) The cancellation of distributions
of the claim under the instruments in imposes no restrictions on the
insolvency or liquidation; institution;

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Regarding hybrid capital instruments, According to Article 60 of the j) The instruments may be called,
the EU standard builds upon the proposed EU Regulation, instruments redeemed or repurchased only where
amendments made under the CRD need to fulfill the following conditions the conditions laid down in Article
II concerning the quality of such to qualify as Tier 2 capital: 72 of the proposed EU Regulation are
instruments, introducing stricter met, and not before five years after
eligibility criteria for inclusion in a) The instruments are issued and fully the date of issuance;
Additional Tier 1 capital. Hybrid capital paid-up;
k) The provisions governing the
instruments need to absorb losses by
b) The instruments are not purchased instruments do not indicate or suggest
being written down or converted into
by any of the following: that the instruments would or might
CET 1 instruments when CET 1 capital
be redeemed or repurchased other
ratio falls below 5.125%. Hybrid
i) The institution or its subsidiaries; than at maturity and the institution
capital instruments with an incentive
does not otherwise provide such an
to redeem, which are currently limited ii) An undertaking in which the
indication or suggestion;
to 15% of the Tier 1 capital base (see institution has participation in the
CRD II), will be phased out under form of ownership, direct or by way of l) The provisions governing the
Basel III. control, of 20% or more of the voting instruments do not give the holder
rights or capital of that undertaking; the right to accelerate the future
The Additional Tier 1 capital base scheduled payment of interest or
consists of the corresponding c) The purchase of the instruments is
principal, other than in the insolvency
instruments after deductions. not funded directly or indirectly by the
or liquidation of the institution;
institution;
m) The level of interest or dividend
d) The claim on the principal amount
2.2.3 Tier 2 capital of the instruments under the
payments due on the instruments will
not be modified based on the credit
The new definition of capital provisions governing the instruments
standing of the institution, its parent
rationalizes Tier 2 capital by is wholly subordinated to claims of all
institution or parent financial holding
eliminating Upper Tier 2 from the non-subordinated creditors;
company or mixed activity holding
capital structure. It also introduces e) The instruments are not secured, or company;
harmonized and strict eligibility guaranteed by any of the following:
criteria. Under Basel III, Tier 2 capital n) Where the instruments are not
ensures loss absorption in case of i) The institution or its subsidiaries; issued directly by the institution or
liquidation (gone-concern). by an operating entity within the
ii) The parent institution or its
consolidation pursuant to prudent
subsidiaries;
Tier 2 capital includes the following consolidation (Chapter 2 of Title II of
items: iii) The parent financial holding Part One), the parent institution, the
company or its subsidiaries; parent financial holding company, or
a) Capital instruments, where the the mixed activity holding company,
iv) The mixed activity holding
conditions laid down in Article 60 are the proceeds are immediately available
company or its subsidiaries;
met; without limitation in a form that
v) The mixed financial holding satisfies the conditions laid down in
b) The share premium accounts related company and its subsidiaries; this paragraph to any of the following:
to the instruments referred to in point
(a); vi) Any undertaking that has close i) The institution;
links with entities referred to in points
c) For institutions calculating risk- (i) to (v); ii) An operating entity within the
weighted exposure amounts in consolidation pursuant to Chapter 2 of
f) The instruments are not subject
accordance with the Standardized Title II of Part One;
to any arrangement that otherwise
Approach, general credit risk enhances the seniority of the claim
adjustments, gross-of-tax effects, of iii) The parent institution;
under the instruments;
up to 1.25% of risk-weighted exposure
g) The instruments have an original iv) The parent financial holding
amounts calculated in accordance
maturity of at least five years; company;
with the Standardized Approach;
h) The provisions governing the v) The mixed activity holding company.
d) For institutions calculating risk- instruments do not include any
weighted exposure amounts under incentive for them to be redeemed by The Tier 2 capital base consists of
the Internal Ratings Based approach the institution; the corresponding instruments after
(IRB), positive amounts, gross-of-tax deductions.
effects, resulting from the calculation i) Where the instruments include one
laid down in Article 154 and 155 up or more call options, the options are
to 0.6% of risk-weighted exposure exercisable at the sole discretion of
amounts calculated under the IRB the issuer;
approach.

19
2.3 Prudential filters and deductions

2.3.1 Prudential filters


The Basel III standard harmonizes
regulatory adjustments (i.e., deductions
from capital and prudential filters)
which will generally be applied at the
level of CET 1 capital or its equivalent
in the case of non-joint stock
companies in the future.

Table 2: Prudential filters Basel III

Regulatory Adjustments
Item Description
Prudential filters
Securitized assets An institution shall exclude from any element of own funds any increase in its
equity under the applicable accounting standard that results from securitized
assets.
Cash flow hedges and changes in the The fair value reserves related to gains or losses on cash flow hedges of
value of own liabilities financial instruments that are not valued at fair value, including projected
cash flows; and gains or losses on liabilities of the institution that are valued
at fair value that result from changes in the credit standing of the institution
should not be included in any element of own funds.
Additional value adjustments Institutions shall apply the requirements for prudent valuation specified
in the proposed Regulation to all their assets measured at fair value when
calculating the amount of their own funds and shall deduct from CET 1
capital the amount of any additional value adjustments necessary.
Unrealized gains and losses measured Institutions shall generally not make adjustments to remove from their own
at fair value funds unrealized gains or losses on their assets or liabilities measured at fair
value.
Source: New proposals on capital requirements (July 2011), European Commission found at http://ec.europa.eu/internal_market/bank/regcapital/index_en.htm

20
2.3.2 Deductions from CET 1 capital
Table 3: Deduction from CET 1 capital in Basel III
Regulatory Adjustments
Item Description
Deductions from CET 1 capital
Losses for current fiscal year
Intangible assets Institutions shall determine the intangible assets to be deducted in accordance
with the following:
(a) the amount to be deducted shall be reduced by the amount of associated
deferred tax liabilities that would be extinguished if the intangible assets became
impaired or were derecognized under the relevant accounting standard;
(b) the amount to be deducted shall include goodwill included in the valuation of
significant investments of the institution.
Deferred tax assets Deferred tax assets that rely on future profitability according to Article 35 of the
proposed EU Regulation.
Deferred tax assets that do not rely on future profitability according to Article 36
of the proposed EU Regulation.
Negative expected losses IRB banks should deduct negative amounts resulting from the calculation of
expected loss (see Article 37 of the EU proposed Regulation).
Benefit pension fund assets Benefit pension fund assets should be deducted according to Article 38 of the
proposed EU Regulation.
Direct and indirect holding of CET 1 Direct and indirect holdings by an institution of own CET1 instruments, including
items own CET 1 instruments that an institution is under an actual or contingent
obligation to purchase by virtue of an existing contractual obligation (see Article
39 of the proposed EU Regulation).
Holdings of CET 1 items of entities Holdings of the CET 1 instruments of relevant entities where those entities have
with reciprocal cross holding a reciprocal cross holding with the institution that the competent authority
considers to have been designed to inflate artificially the own funds of the
institution (see Article 41 of the proposed EU Regulation).
Not-significant investments in relevant The applicable amount of direct and indirect holdings by the institution of CET 1
entities instruments of relevant entities where the institution does not have a significant
investment in those entities (see Article 43 of the proposed EU Regulation).
Significant investments in relevant The applicable amount of direct and indirect holdings by the institution of the
entities CET 1 instruments of relevant entities where the institution has a significant
investment (e.g., the institution owns more than 10% of the CET 1 instruments
issued by that entity) in those entities (see Article 40 of the proposed EU
Regulation).
Amount that exceed Additional Tier 1 The amount of items required to be deducted from Additional Tier 1 items that
capital exceed the Additional Tier 1 capital of the institution.
Alternative to risk-weight of 1.250% The exposure amount of the specified items (e.g., qualifying holdings outside the
financial sector) which qualify for a risk-weight of 1.250%, where the institution
deducts that exposure amount from CET 1 capital as an alternative to applying a
risk-weight of 1.250%.
Tax charge Any tax charge relating to CET 1 items foreseeable at the moment of its
calculation, except where the institution suitably adjusts the amount of CET 1
items insofar as such tax charges reduce the amount up to which those items may
be applied to cover risks or losses.
Source: New proposals on capital requirements (July 2011), European Commission found at http://ec.europa.eu/internal_market/bank/regcapital/index_en.htm

21
2.3.3 Exemptions from 2.3.4 Deductions from Additional Tier 1 capital
and alternatives to Table 4: Deduction from Additional Tier 1 capital in Basel III
deduction from CET 1
Regulatory Adjustments
items
Item Description
The following items, which in
aggregate are equal to or less than Deductions from Additional
15% of the CET 1 capital of the Tier 1 capital
institution (after adjustments), may Direct and indirect holding Direct and indirect holdings by an institution of
not be deducted from CET 1 capital: of Additional Tier 1 items own Additional Tier 1 instruments, including own
Additional Tier 1 instruments that an institution
• Deferred tax assets that are
could be obliged to purchase as a result of
dependent on future profitability and
existing contractual obligations (see Article 54 of
arise from temporary differences,
the proposed EU Regulation).
and in aggregate are equal to or less
than 10% of the CET 1 items of the Holdings of Additional Tier Holdings of the Additional Tier 1 instruments of
institution (after adjustments); 1 items of entities with relevant entities with which the institution has
reciprocal cross holding reciprocal cross holdings that the competent
• Significant investments in a relevant authority considers to have been designed to
entity,13 the direct and indirect inflate artificially the own funds of the institution
holdings of that institution of the (see Article 55 of the proposed EU Regulation).
CET 1 instruments of those entities
that in aggregate are equal to or less Not-significant investments Direct and indirect holdings of the Additional
than 10% of the CET 1 items of the in relevant entities Tier 1 instruments of relevant entities, where an
institution (after adjustments). institution does not have a significant investment
in those entities (see Article 57 of the proposed
Instruments that are not deducted EU Regulation).
shall be assigned a risk-weight of
Significant investments in Direct and indirect holdings by the institution
250%.
relevant entities of the Additional Tier 1 instruments of relevant
The EU standard allows alternatives to entities where the institution has a significant
the deduction of significant holdings investment in those entities, excluding
of institutions in the CET 1 instruments underwriting positions held for five working days
of other financial entities like or fewer.
insurance undertakings, reinsurance Amount that exceeds Tier The amount of items required to be deducted
undertakings and insurance holding 2 capital from Tier 2 items that exceed the Tier 2 capital of
companies included in the scope of the institution.
consolidated supervision (Article
46 of the proposed EU Regulation). Tax charge Any tax charge relating to Additional Tier 1 items
The European Commission justifies foreseeable at the moment of its calculation,
this aspect with the so-called except where the institution suitably adjusts the
“bancassurance” business model amount of Additional Tier 1 items insofar as such
which is a key feature of the EU tax charges reduce the amount up to which those
banking landscape, i.e., groups that items may be applied to cover risks or losses.
contain significant banking/investment Source: New proposals on capital requirements (July 2011), European Commission found at http://ec.europa.eu/
businesses and insurance businesses.14 internal_market/bank/regcapital/index_en.htm

Further, the standard permits mutuals,


cooperative societies or similar
institutions not to deduct significant
and not-significant holdings in another
such institution or in its central
or regional credit institution if the
specified conditions are met (see
chapter 2.5).

22
2.3.5 Deductions from Tier 2 items
Table 5: Deduction from Additional Tier 2 capital in Basel III

Regulatory Adjustments
Item Description
Deductions from Tier 2 capital
Direct and indirect holding of Tier 2 Direct and indirect holdings by an institution of own Tier 2 instruments, including
items own Tier 2 instruments that an institution could be obliged to purchase as a result
of existing contractual obligations.
Holdings of Additional Tier 2 items of Holdings of the Tier 2 instruments of relevant entities with which the institution
entities with reciprocal cross holding has reciprocal cross holdings that the competent authority considers to have been
designed to inflate artificially the own funds of the institution (see Article 65 of
the proposed EU Regulation).
Not-significant investments in relevant The applicable amount determined in accordance with Article 67 of direct and
entities indirect holdings of the Tier 2 instruments of relevant entities, where an institution
does not have a significant investment in those entities.
Significant investments in relevant Direct and indirect holdings by the institution of the Tier 2 instruments of relevant
entities entities where the institution has a significant investment in those entities,
excluding underwriting positions held for fewer than 5 working days.

Source: New proposals on capital requirements (July 2011), European Commission found at http://ec.europa.eu/internal_market/bank/regcapital/index_en.htm

23
2.4 Minority interests 2.5
2.4.1 Minority interests
that qualify for inclusion
2.4.2 Qualifying
Additional Tier 1, Tier
Institutional
in consolidated CET 1
capital
1, Tier 2 capital and
qualifying own funds
networks
Minority interest includes CET 1 Qualifying Additional Tier 1, Tier 1, The EU standard allows mutuals,
instruments, the related retained Tier 2 capital and qualifying own cooperative societies or similar
earnings and share premium accounts funds include the minority interest, institutions not to deduct significant
of a subsidiary where the following Additional Tier 1, Tier 1 or Tier 2 and not-significant holdings in another
conditions are met: instruments, as applicable, plus the such institution or in its central
related retained earnings and share or regional credit institution if the
a) The subsidiary is one of the premium accounts, of a subsidiary following conditions are met:
following: where the following conditions
i) An institution; are met: i) Where the holding is in a central
or regional credit institution, the
ii) An undertaking that is subject by a) The subsidiary is one of the institution with that holding is
virtue of applicable national law to following: associated with that central or
the requirements of the proposed EU regional credit institution in a
i) An institution;
Regulation and proposed Directive; network subject to legal or statutory
ii) An undertaking that is subject by provisions and the central or regional
b) The subsidiary is included fully in
virtue of applicable national law to credit institution is responsible, under
the consolidation;
the requirements of the proposed EU those provisions, for cash-clearing
c) Those CET 1 instruments are owned Regulation and proposed Directive; operations within that network;
by persons other than the undertakings
b) The subsidiary is included fully in
included in the consolidation. ii) The institutions fall within the same
the consolidation;
institutional protection scheme;
Minority interests that are funded
d) Those instruments are owned by
directly or indirectly, through a iii) The competent authorities have
persons other than the undertakings
special-purpose entity or otherwise, by granted the permission referred to in
included in the consolidation.
the parent institution, parent financial Article 108(7);15
holding company, mixed activity Additional Tier 1 and Tier 2 capital
holding company or their subsidiaries issued by special-purpose entities iv) The conditions laid down in Article
shall not qualify as consolidated CET 1 may be included only if the conditions 108(7) are satisfied;
capital. specified in Article 78 of the proposed
EU Regulation are met. v) The institution draws up and
Institutions should determine the reports to the competent authorities
amount of minority interests of a Institutions should determine the the consolidated balance sheet
subsidiary included in the consolidated amount of qualifying Tier 1 capital referred to in point (e) of Article
CET 1 capital according to Article 79 of a subsidiary that is included in 108(7) no less frequently than own
of the proposed EU Regulation. the consolidated Tier 1 capital and funds requirements are required to be
consolidated Additional Tier 1 capital reported under Article 95.
according to Articles 80-81 of the
proposed EU Regulation. The amount A regional credit institution may
of qualifying own funds of a subsidiary not deduct holdings in its central or
that is included in consolidated own another regional credit institution
funds and in consolidated Tier 2 if the conditions mentioned above
capital shall be determined according are met.
to Article 82 and 83 respectively of
the proposed EU Regulation.

24
2.6 Capital buffers
Basel III introduces two capital buffers calculate the MDA depends on how The designated authority that is
in addition to the capital requirements: much an institution is dropping below responsible for setting the buffer
a capital conservation buffer and a the requirement and ranges from 0% should calculate a buffer guide based
countercyclical capital buffer. While (first/lowest quartile) to 60% (fourth/ on a deviation of the ratio of credit-
the definition of capital is treated highest quartile).17 to-GDP from its long-term trend on
in the proposed EU Regulation, the a quarterly basis. An increase of the
capital buffers are discussed in the Further, the affected institutions countercyclical capital buffer should
corresponding proposed Directive should prepare a capital conservation generally be communicated 12 months
requiring national transposition.16 plan and submit it to the competent in advance. A decrease of the buffer
authorities including the following: could be applicable immediately. The
estimates of income and expenditure designated authority should give an
2.6.1 Capital and a forecast balance sheet; indicative (not binding) period during
measures to increase the capital ratios
conservation buffer of the institution; and a plan and
which no increase in the buffer is
expected.
The capital conservation buffer, 2.5% timeframe for the increase of own
of RWA and to be met with CET 1 funds with the objective of meeting International institutions need to
capital, applies at all times and it is fully the combined buffer requirement. calculate the institution-specific
intended to ensure that institutions countercyclical capital buffer which
are able to absorb losses in stress The capital conservation buffer partly consists of the weighted average
periods lasting for a number of solves the regulatory paradox after of the countercyclical buffer rates
years. Considering the 4.5% CET 1 which higher minimum capital should that apply in the jurisdictions where
capital ratio, institutions must hold not be used to absorb losses falling the relevant credit exposures of the
7.0% CET 1 capital on an individual below the minimum requirements, institution are located (based on the
and consolidated basis at all times. leading to a withdrawal of the own funds requirements for credit
Institutions are expected to build up banking license. With the introduced risk).
the capital in good economic times. capital buffers and the associated

2.7 Enhanced
distribution constraints falling below
In case institutions fail to meet fully the requirements, a “softer” regulatory
the “combined buffer requirement” tool is introduced.18
(i.e., the total CET 1 capital required to
meet the requirement for the capital
conservation buffer extended by an 2.6.2 Countercyclical disclosure
institution-specific countercyclical capital buffer
capital buffer), distribution constraints
on CET 1 capital are imposed. CET The countercyclical capital buffer is requirements
1 capital should thereby include the introduced to “achieve the broader
following items: macro-prudential goal of protecting The proposed EU Regulation includes
the banking sector and the real improved disclosure requirements
a) A payment of cash dividends; economy from the system-wide regarding the capital endowment
risks stemming from the boom-bust and own funds of institutions. The
b) A distribution of fully or partly evolution in aggregate credit growth purpose is to strengthen market
paid bonus shares or other capital and more generally from any other discipline and enhance financial
instruments; structural variables and from the stability. The corresponding technical
exposure of the banking sector to standards to specify uniform formats,
c) A redemption or purchase by an any other risk factors related to risks frequencies, etc., are to be developed
institution of its own shares or other to financial stability.”19 The level of by the European Banking Authority
specified capital instruments; this buffer is set by each Member and submitted to the European
State, ranges between 0% and 2.5% Commission by January 1, 2013.
d) A repayment of amounts paid up
of RWA 20 and has to be met by CET 1
in connection with specified capital
capital.21 The buffer is required during
instruments;
periods of excessive credit growth and
e) A distribution of items referred to in it is released in an economic downturn.
points (b) to (e) of Article 24(1) of that
In cases where institutions fail to meet
Regulation.
fully the countercyclical capital buffer
Falling below the combined buffer requirements, capital distribution
requirement, institutions have to constraints are imposed (see above).
calculate the “Maximum Distributable
Amount” (MDA). The factor to

25
3
Counterparty Credit Risk

26
27
Basel III strengthens the requirements for the All other banks must calculate a
standardized CVA risk capital charge.
management and capitalization of counterparty credit Within this method – it is based on the
risk (CCR). It includes an additional capital charge for bond equivalent approach – portfolio
own funds requirements for CVA risk
possible losses associated with deterioration in the for each counterparty have to be
creditworthiness of counterparties or increased risk- calculated using the given formula.

weights on exposures to large financial institutions. The The calculation of the aggregate CCR
and CVA risk capital charges depends
new framework also enhances incentives for clearing on the methods used by banks.
over-the-counter (OTC) instruments through central
• For banks with IMM approval and
counterparties (CCP).22 market-risk internal-models approval
for the specific interest-rate risk of

3.1 Effective 3.2 Credit bonds, the total CCR capital charge is
the sum of the following components:
i) The higher of (a) its IMM capital
Expected valuation charge based on current parameter
calibrations for EAD and (b) its IMM

Positive adjustment
capital charge based on stressed
parameter calibrations for EAD;

ii) The advanced CVA risk capital

Exposure In addition to the default risk capital


requirements for CCR, Basel III
introduces an additional capital charge
charge calculated with the internal
models.

For banks using an Internal Model to cover the risk of mark-to-market • For banks with IMM approval and
Method (IMM) to calculate CCR losses on the expected counterparty without Specific-Risk VaR approval for
regulatory capital, Basel III requires risk (Credit Valuation Adjustment, CVA) bonds, the total CCR capital charge is
determining the default risk capital to OTC derivatives. The calculation the sum of the following components:
charge by using the greater of the of the CVA charge depends on the
portfolio-level capital charge (not method banks use to determine the i) The higher of (a) its IMM capital
including CVA charge) based on capital charge for CCR and specific- charge based on current parameter
Effective Expected Positive Exposure interest rate risk. Transactions with calibrations for EAD and (b) its IMM
(EEPE) using current market data a central counterparty (CCP) and capital charge based on stressed
and the one based on EEPE using a securities financing transactions (SFT) parameter calibrations for EAD;
stress calibration. The greater of the need not be considered. ii) The standardized CVA risk capital
EEPEs should not be applied on a charge.
counterparty-by-counterparty basis, Banks with IMM approval for CCR
but on a total portfolio level. • For all other banks, the total CCR
risk and approval to use the market
capital charge is the sum of the
risk internal models approach for the
following components:
specific-interest rate risk of bonds must
calculate the additional capital charge i) The sum over all counterparties of
by modeling the impact of changes in the Current Exposure Method (CEM)
the counterparty’s credit spread on or Standardized Method (SM)-based
the CVAs of all OTC derivatives using capital charge (depending on the
the internal VaR model for bonds. This bank’s CCR approach);
VaR model is restricted to changes in
the counterparties’ credit spreads and ii) The standardized CVA risk capital
does not model the sensitivity of CVA charge.
to changes in other market factors such
as changes in the value of the reference
asset, commodity, currency or interest
rate of a derivative. The CVA risk capital
charge consists of both general and
specific credit spread risks, including
Stressed VaR but excluding incremental
risk charge (IRC).

28
3.3 Wrong Regulation consider institutions as
“large” if the total assets, on the
level of that individual firm or on the
3.6 Enhanced
way risk consolidated level of the group, are
greater than or equal to EUR 70 billion
threshold. The Basel III document by
CCR
In addition to the consideration
of general wrong way risk – stress
testing and scenario analysis must
the BCBS includes a threshold of US
$100 billion. management
be designed to identify such risks
– Basel III introduces an explicit
Pillar 1 capital charge for specific
Depending on the probability of
default of the institution, the
introduction of this multiplier
requirements
wrong way risk. Banks are exposed increases the risk-weight by Basel III strengthens not only the
to specific wrong way risk if future approximately 20% to 35%. A detailed CCR measurement but also the CCR
exposure to a specific counterparty calculation is provided in the appendix management by requiring institutions
is highly, positively correlated with of this handbook. to establish and maintain a CCR
the counterparty’s probability of management framework consisting of:
default. Banks must “have procedures
a) Policies, processes and systems
3.5 Central
in place to identify, monitor and
control cases of specific wrong way to ensure the identification,
risk, beginning at the inception of a measurement, management, approval

counter-
trade and continuing through the life and internal reporting
of the trade. To calculate the CCR of CCR;
capital charge, the instruments for
b) Procedures for ensuring that those

parties
which there exists a legal connection
between the counterparty and the policies, processes and systems are
underlying issuer, and for which complied with.
specific wrong way risk has been The new capital framework also The framework should ensure that
identified, are not considered to enhances incentives for clearing institutions comply with the following
be in the same netting set as other instruments through central principles:
transactions with the counterparty. counterparties (CCP) by applying lower
Furthermore, for single-name own funds requirements relative to a) It does not undertake business with
credit default swaps where a legal OTC transactions. Also, the additional a counterparty without assessing its
connection exists between the CVA capital charge does not apply creditworthiness;
counterparty and the underlying issuer, to exposures towards eligible CCPs.
and where specific wrong way risk b) It takes due account of settlement
It should be noted that several
has been identified, EAD counterparty and pre-settlement credit risk;
conditions need to be fulfilled to
exposure equals the full expected classify as CCP. c) It manages such risks as
loss in the remaining fair value of the comprehensively and practicable at the
underlying instruments assuming the While so far there is no capital counterparty level by aggregating CCR
underlying issuer is in liquidation.”23 charge for derivatives with a CCP the exposures with other credit exposures
proposed EU Regulation introduces and at the firm-wide level.
own funds requirements for trade

3.4 Asset exposures. According to this an


institution has to apply a risk-weight
of 2% to the exposure values of all
Basel III also includes new
requirements for CCR back testing
and stress testing. Banks must have

value its trade exposures with CCPs. An


exposure value of zero can be used in
cases where the posted collaterals to a
a comprehensive stress testing
program including regular execution,
single- and multi-factor tests, trade

correlation CCP or a clearing member bankruptcy


are remote events, or if the CCP, the
clearing member or one or more of the
coverage and internal control. In
addition, new requirements for
collateral management and policies
Basel III increases the risk-weights other clients of the clearing member are stipulated. The regulatory floor for
(RW) on exposures to financial becomes insolvent. the margin period of risk will increase,
institutions relative to the non- depending on the counterparty
financial corporate sector in the IRB In addition to institutions acting as portfolio and historic margin
approach. The correlation coefficient clearing members, they have to hold call failures.
in the IRB formula is increased own funds to cover the exposures
by 25% for all exposures to large arising from their contributions
regulated financial entities and to to the default fund of a CCP, the
all unregulated financial entities.24 corresponding methodology is
In effect, a multiplier of 1.25 is specified in Article 298 of the
introduced. The proposals of the EU proposed EU Regulation.
29
4
Leverage ratio

30
31
4.1 Definition and calibration
To prevent an excessive build-up arithmetic mean of the monthly for various types of institutions. Based
of leverage on institutions’ balance leverage ratios over a quarter.27 on the EBA report, final adjustments
sheets, Basel III introduces a non-risk- of the ratio would be made in the first
based leverage ratio to supplement For the numerator of the ratio (capital half of 2017. The EBA would develop
the risk-based capital framework of measure), the Tier 1 capital should drafts of technical standards to
Basel II. This new regulatory tool is not be considered. The denominator determine the contents and format of
intended to be a binding instrument at (exposure measure) should be the the uniform reporting template.
this stage but as an “additional feature sum of the exposure values of all
that can be applied on individual assets and off-balance sheet items Within the disclosure requirements,
banks at the discretion of supervisory not deducted from the calculation of the following information should be
authorities with a view to migrating Tier 1 capital. For off-balance-sheet reported:
to a binding ('Pillar one') measure in items, a specific credit risk adjustment
2018, based on appropriate review and of 10% generally applies for undrawn a) The leverage ratio;
calibration.”25 Reporting requirements credit facilities, (this may be cancelled
unconditionally at any time without b) A breakdown of the total exposure
from January 1, 2013 would allow a
notice), and 100% for all other off- measure;
corresponding review and decision
on its introduction as a binding balance-sheet items.28
c) A description of the processes
requirement in 2018. Starting in 2015, used to manage the risk of excessive
publication of the leverage ratio by the At this time a leverage ratio of 3%
is proposed. By October 31, 2016, leverage;
institutions is proposed.26
the EBA will report to the European
d) A description of the factors that
The leverage ratio should be calculated Commission among others on whether
had an impact on the leverage ratio
by dividing an institution’s capital 3% would be an appropriate level for a
during the period to which the
measure by the total exposure Tier 1 capital-based leverage ratio and
disclosed leverage ratio refers.
(expressed as a percentage). The ratio whether the leverage ratio should be
should be calculated as the simple the same for all institutions or differ

Figure 4: Leverage Ratio within Basel III

Tier 1 capital • Exposure measure generally follows


Leverage Ratio = ≥ 3% accounting measure
Total exposure • Credit risk adjustement for
off-balance-sheet items:
- Generally 100%
- 10% for unconditionally
cancellable commitments
Calculation
Simple arithmetic mean of the monthly leverage ratio over the quarter
Scope of application
Solo, consolidated and sub-consolidated level
Disclosure
Disclosure of the key elements of the leverage ratio under Pillar 3
Introduction
Planned for Jan. 1, 2018
Transition period
• Jan. 1, 2011: Start supervisory monitoring period (development of templates)
• Jan. 1, 2013 – Jan. 1, 2017: Parallel run (leverage ratio and its components will be tracked, including its behavior relative to
the risk based requirement)
• Jan. 1, 2015: Disclosure of the leverage ratio by banks
• First half of 2017: Final adjustments
• Jan. 1, 2018: Migration to Pillar 1 treatment
Source: Accenture

32
33
5
Global liquidity standard

34
35
Basel III includes a new liquidity standard introducing
two liquidity ratios. The Liquidity Coverage Ratio (LCR)
is introduced to improve the short-term resilience of
the liquidity risk profile of institutions, requiring them
to hold a buffer of “high quality” liquid assets to match
net liquidity outflows during a 30-day period of stress.
The Net Stable Funding Ratio (NSFR) is designed to
promote resilience over the longer term by requiring
institutions to fund their activities with more stable
sources of funding on an ongoing structural basis.

Further, EBA will develop draft It should be noted that institutions


implementation technical standards are not only expected to meet the
regarding liquidity monitoring metrics new standards but also to adhere
which should allow competent to the Principles for Sound Liquidity
authorities to obtain a comprehensive Risk Management and Supervision.29
view of the liquidity risk profiles of These principles provide guidance on
institutions. The Basel III document the risk management and supervision
from the BCBS contains a number of of liquidity and funding risk and have
monitoring tools which are presented been considered in the context of the
in section 5.3. CRD II. The following figure gives an
overview of the relevant topics.

Figure 5: Liquidity risk management (LRM) framework

Governance
• Liquidity risk tolerance
• Responsibility senior management
Liquidity risk • Pricing of liquidity costs
management framework Measurement and management
• Liquidity risk management (LRM) process
• Group-wide perspective
• Funding strategy
Governance Measurement • Intraday liquidity positions
and management • Collateral positions
• Stress testing
• Contingency funding plan
• High quality liquid assets

Public disclosure
• Disclosure
Public disclosure Role of
Role of supervisors
supervisors • Assessment LRM framework
• Monitoring
• Effective/timely intervention
• Communication with other supervisors
Fundamental principle for the management Fundamental principle
and supervision of liquidity risk • A bank should establish a robust liquidity risk management
framework that ensures it maintains sufficient liquidity

Source: Accenture

36
5.1 Liquidity Coverage Ratio
The Liquidity Coverage Ratio (LCR) to stringent conditions – waive the competent authorities on a daily
requires institutions to hold a the application to a consolidated basis.
sufficient buffer of “high quality” requirement.31
liquid assets to cover net liquidity The LCR should be reported on a
outflows during a 30-day period of To meet the requirement, institutions monthly basis. Competent authorities
stress. The stock of high quality liquid shall “at all times hold liquid assets, may authorize a lower reporting
assets (numerator) should include the sum of the values of which frequency on the basis of the
assets of high credit and liquidity equals, or is greater than, the liquidity individual situation of an institution.
quality. The stress scenario that is outflows less the liquidity inflows Competent authorities might also
used to determine the net cash under stressed conditions so as to require institutions with significant
outflows (denominator) reflects ensure that institutions maintain levels liquidity risk in a foreign currency to
both institution-specific and of liquidity buffers which are adequate report these items separately.
systemic shocks.30 to face any possible imbalance
between liquidity inflows and outflows
The LCR will be introduced by 2015 under stressed conditions over a short
after an observation period to avoid period of time. Institutions shall not
possible unintended consequences. count double liquidity inflows and
From 2013 on, there is a general liquid assets.”32
requirement for banks to keep
appropriate liquidity coverage. If an institution does not meet the
requirements, it is asked to notify the
According to the proposed EU competent authorities and submit
Regulation, the LCR will in principle a plan for the timely restoration of
apply at the level of every individual compliance with the LCR requirement.
institution (with legal personality). Until the institution has restored
Competent authorities may – subject compliance, it must report the items to

Figure 6: Liquidity Coverage Ratio (LCR)

High quality liquid assets Institutions have to ensure that they have
LCR = ≥ 100% at all times sufficient high quality liquid
Total net liquidity outflows assets to survive an acute stress scenario
lasting for 30 days
over 30-day time period

Introduction
Jan. 1, 2015; observation period starting Jan. 1, 2013
Scope of application
Level of individual institution (with legal personality)
Reporting
Monthly with the operational capacity to increase the frequency to weekly or even daily in stressed situations
Disclosure
Disclosure of LCR under Pillar 3

Source: Accenture

37
5.1.1. Definition of high- a) assets that are issued by a credit c) Their price can be determined by a
institution unless they fulfill one of the formula that is easy to calculate based
quality liquid assets following conditions: on publicly available inputs and does
The following items should qualify as not depend on strong assumptions as
i) They are bonds eligible for treatment is typically the case for structured or
liquid assets:
as covered bonds; exotic products;
a) Cash and deposits held with ii) They are bonds as defined in Article
central banks to the extent that these d) They are listed on a recognized
52(4) of Directive 2009/65/EC33 other
deposits can be withdrawn in times exchange;
than those referred to in (i);
of stress;
iii) The credit institution has been e) They are tradable on active outright
b) Transferable assets that are of set up and is sponsored by a Member sale or repurchase agreement markets
extremely high liquidity and State central or regional government with a large and diverse number of
credit quality; and the asset is guaranteed by market participants, a high trading
that government and used to fund volume and market breadth and depth.
c) Transferable assets representing promotional loans granted on a
claims on or guaranteed by the central non-competitive, not-for-profit basis Items have to fulfill several operational
government of a Member State or a in order to promote its public policy requirements to be considered as high-
third country if the institution incurs a objectives; quality liquid assets:
liquidity risk in that Member State or
b) Assets issued by any of a) They are appropriately diversified;
third country that it covers by holding
the following:
those liquid assets; b) “Level 1 assets” should not be less
i) An investment firm; than 60% of the liquid assets (see
d) Transferable assets that are of high above);
liquidity and credit quality. ii) An insurance undertaking;
iii) A financial holding company; c) They are legally and practically
As an operational requirement, items readily available at any time during
listed in points a, b and c (also called iv) A mixed-activity holding company; the next 30 days to be liquidated via
“level 1 assets”) should not be less v) Any other entity that performs outright sale or repurchase agreements
than 60% of the liquid assets of an one or more of the activities listed in order to meet obligations
institution. Such items owed and due in Annex I of the Directive as its coming due;
or callable within 30 calendar days main business (e.g., financial leasing; d) The liquid assets are controlled by a
shall not count towards 60% unless acceptance of deposits and other liquidity management function;
the assets have been obtained against mutual recognition).
collateral that qualifies under points e) A portion of the liquid assets is
a, b or c. The items shall fulfill the following periodically and at least annually
conditions to qualify as high quality liquidated via outright sale or
Regarding the definition of “high” liquid assets: repurchase agreements for the
and “extremely high” liquidity and following purposes:
credit quality of transferable assets, a) They are not issued by the
institution itself or its parent or i) To test the access to the market for
EBA will work on a uniform definition
subsidiary institutions or another these assets,
until December 31, 2013, considering
the following criteria: minimum trade subsidiary of its parent institutions or
parent financial holding company; ii) To test the effectiveness of its
volume of the assets; credit quality processes for the liquidation of assets,
steps; average volume traded and
b) They are eligible collateral in normal
average trade size; remaining time iii) To test the usability of the assets,
times for intraday liquidity needs
to maturity. Until then, institutions
and overnight liquidity facilities of a iv) To minimize the risk of negative
themselves should identify the
central bank in a Member State or, signaling during a period of stress;
corresponding transferable assets that
if the liquid assets are held to meet
are of high or extremely high liquidity
liquidity outflows in the currency of
and credit quality.
a third country, of the central bank of
Institutions should not consider the that third country;
following items as high quality
liquid assets:

38
f) Price risks associated with the The value of the liquid assets shall
assets may be hedged but the liquid be the market value, subject to
assets are subject to appropriate appropriate haircuts. For level 2 assets
internal arrangements that ensure that the haircut shall not be less than 15%.
they will not be used in other ongoing If institutions hedge the price risk,
operations, including: they should take into account the
cash flow resulting from the potential
i) Hedging or other trading strategies;
close-out of the hedge. Shares or units
ii) Providing credit enhancements in in CIUs should be subject to haircuts,
structured transactions; looking through to the underlying
assets. The haircuts range from 0%
iii) To cover operational costs; to 20%.

g) The denomination of the liquid


assets is consistent with the
distribution by currency of liquidity
outflows after the deduction of
capped inflows.

Figure 7: LCR: High quality liquid assets

High quality liquid assets


LCR = ≥ 100%
Total net liquidity outflows
over 30-day time period

High quality liquid assets


Conditions high quality liquid assets (e.g.,)
• Not issued by the institution or parent/subsidiary
• Eligibility as collateral in normal times for intraday liquidity needs and overnight liquidity facilities of a Central Bank
• Listed on a recognized exchange
Operational requirements (e.g.,)
• Appropriate diversification
• Assets are legally and practically readily available at any time during the next 30 days
• Liquid assets are controlled by a liquidity management function
High quality liquid assets items
• “Level 1 assets” (cash; transferable assets of extremely high liquidity and credit quality): min. 60% of liquid assets; market
value; no haircut
• “Level 2 assets“ (transferable assets that are of high liquidity and credit quality): max. 40% of liquid assets; market value;
haircut of min. 15%

Source: Accenture

39
5.1.2. Definition of net ii) held in a transactional account, sector entity of the Member State
including accounts to which salaries in which the credit institution was
liquidity outflows are regularly credited; authorized.
The denominator of the LCR consists
of the net liquidity outflows over 10% of other retail deposits;34 iv) For liabilities resulting from
a 30-day period of stress. They are b) For other liabilities that come due, deposits that have to be maintained:
calculated as the liquidity inflows can be called for payout, or entail an
minus the outflows, whereas the implicit expectation of the provider of (a) By the depositor in order to obtain
inflows are limited to 75% of liquidity the funding that the institution would clearing, custody or cash management
outflows. repay the liability during the next 30 services from the institution;
days, the following percentages should (b) In the context of common task
The liquidity outflows are calculated be used to calculate liquidity outflows: sharing within an institutional
by multiplying the assets with the
i) 0% of the liabilities resulting protection scheme or as a legal or
specified “run off” factors; the inflows,
from the institution’s own operating statutory minimum deposit by another
by multiplying the assets with the
expenses; entity being a member of the same
specified inflow factor.
institutional protection scheme;
ii) 0% of liabilities resulting from 5% in case of point a) to the extent to
5.1.2.1 Liquidity outflows secured lending and capital-
Liquidity outflows are calculated as which they are covered by a Deposit
market-driven transactions which Guarantee Scheme or an equivalent
the sum of the following items: are collateralized with high quality deposit guarantee scheme in a third
liquid assets (up to the value of the country, and by 25% otherwise;
a) 5% of retail deposits that are
liquid assets); 100% of the remaining
covered by a Deposit Guarantee v) 75% of liabilities resulting from
liabilities;
Scheme and the depositor is either: deposits by clients that are not
iii) 25% of liabilities resulting from financial customers
i) Part of an established relationship
secured lending and capital-market-
making withdrawal highly unlikely; vi) 100% of payables and receivables
driven transactions if the assets would
not qualify as liquid assets, the lender expected over the 30-day horizon
is the central bank or another public from the contracts listed in Annex
II into account on a net basis across
counterparties;
Figure 8: LCR: Net liquidity outflows vii) 100% of other liabilities.

High quality liquid assets c) Collateral other than “level 1” assets


LCR = ≥ 100% which is posted by the institution for
Total net liquidity outflows contracts listed in Annex II shall be
over 30-day time period subject to an additional outflow of
15% of the market value of assets for
“level 2” assets and 20% of the market
Net liquidity outflows = value of other assets;
Liquidity outflows – Min (Liquidity inflows; 75% of liquidity outflows)
d) Outflows from credit and liquidity
Net liquidity outflows facilities that qualify as medium or
Liquidity outflows minus liquidity inflows in the stress scenario medium-to-low risk, which shall be
The scenario includes firm-specific and systemic factors determined as a percentage of the
Calculation liquidity outflows maximum amount that can be drawn
Multiplication of the items with the respective “run off“ factor during the next 30 days. The maximum
amount should be multiplied by:
Calculation liquidity inflows
Multiplication of the items with the specified inflow factor; i) 5% if the facilities qualify for
inflows are capped at 75% of the outflows the retail exposure class under the
Source: Accenture
standardized or IRB approaches for
credit risk;

40
ii) 10% if they do not qualify for inflows should be taken into account counterparties and shall be multiplied
retail exposure; have been provided in full with the following exceptions: by 100% of a net amount receivable.
to clients that are not financial
customers; have not been provided for a) Monies due from customers that Institutions should not consider
the purpose of replacing funding of the are not financial customers shall be inflows from any of the liquid
client in situations when the client is reduced by 50% (this does not apply assets (as specified in the proposed
unable to obtain funding requirements to monies due from secured lending Regulation) other than payments due
in the financial markets; and capital-market-driven transactions on the assets that are not reflected in
that are collateralized by “level 1” and the market value of the asset.
iii) 100% applies in particular to (a) “level 2” assets);
liquidity facilities that the institution Further inflows from new issuance of
has granted to securitization special b) Monies due from secured any obligations should not be taken
purpose entity (SSPEs); and (b) lending and capital-market-driven into account.
arrangements under which the transactions, if they are collateralized
institution is required to buy or swap by liquid assets, shall not be taken into Institutions shall take into account
assets from an SSPE. account up to the value net of haircuts liquidity inflows which are to be
of the liquid assets but shall be taken received in third countries where
e) Additional outflows in period of into account in full for the remaining there are transfer restrictions or which
stress.35 monies due; are denominated in non-convertible
currencies only to the extent that they
5.1.2.2 Liquidity inflows c) Monies due that the institution correspond to outflows in the third
Institutions should measure liquidity owing those monies treats, any country or currency in question.
inflows over the next 30 days. They undrawn credit or liquidity facilities
are limited to 75% of the liquidity and any other commitments received
outflows and should include only shall not be taken into account.
contractual inflows from exposures
that are not past due and for which Payables and receivables expected
the bank has no reason to expect non- over the 30-day horizon from the
performance within 30 days. Liquidity contracts listed in Annex II shall
be reflected on a net basis across

Figure 9: LCR: High quality liquid assets and net liquidity outflows

Liquidity Coverage Ratio

High quality liquid assets


LCR = ≥ 100%
Total net liquidity outflows
over 30-day time period

High quality liquid assets


• “Level 1” assets
Cash; transferable assets of extremely high liquidity and credit quality (min. 60% of liquid assets)
• “Level 2” assets
Transferable assets that are of high liquidity and credit quality: max. 40% of liquid assets; market value;
haircut of min. 15%
≥ 100%
Liquidity outflows Liquidity inflows
• Retail deposits (5-10%) • Monies due from non financial customer (50%)
• Other liabilities coming due during next • Secured lending and capital market driven
30 days (0-100%) transactions (0%-100%)
• Collateral other than “level 1” assets • Undrawn credit and liquidity facilities (0%)
(15-20%) • Specified payables and receivables expected over
• Credit and liquidity facilities (5-100%) the 30 day horizon (100%)
• Liquid assets (0%)
• New issuance of obligations (0%)
Source: Accenture

41
5.2 Net Stable Funding Ratio
The Net Stable Funding Ratio (NSFR) The items shall be presented in the i) Any other assets;
requires institutions to maintain a following five time blocks according to
j) Undrawn credit facilities that qualify
sound funding structure over one year maturity date or the earliest date they
as 'medium risk' or 'medium/low risk'.
in an extended firm-specific stress can be contractually called:
scenario. Assets currently funded and Where applicable, all items shall
any contingent obligations to fund a) Within 3 months; be reported in the five time blocks
must be matched to a certain extent b) Between 3 and 6 months; described above.
by sources of stable funding. The
minimum requirement described in c) Between 6 and 9 months; The proposed EU Regulation does not
more detail below is to be introduced include any “available stable funding
d) Between 9 and 12 months;
by January 1, 2018. There is an factors” (ASF factors) or “required
observation period until then. e) After 12 months. stable funding factors” (RSF factors),
The denominator of the NSFR includes i.e., factors by which the available
The reporting frequency for the LCR the items requiring stable funding. or required stable funding items
should not be less than monthly. The Institutions shall report the following must be multiplied to calculate the
NSFR should be reported not less items to competent authorities in corresponding value. Neither at this
than quarterly. Competent authorities order to allow an assessment of the time is it stated whether the NSFR
are allowed to authorize a lower need for stable funding: should be “>” or “≥” 100%.36
reporting frequency on the basis of the
individual situation of an institution. a) Liquid assets, broken down by To give an overview of the current
asset type; discussion regarding ASF and RSF
The numerator of the NSFR includes factors, the following figures represent
the stable sources of funding. The b) Securities and money market the proposals from the Basel III
following items shall be reported to instruments not included in (a); document of the BCBS.37
competent authorities separately in c) Equity securities of non-financial
order to allow an assessment of the entities listed on a major index in a
availability of stable funding: recognized exchange;
a) Own funds; d) Other equity securities;
b) The following items not included in e) Gold;
the own funds:
f) Other precious metals;
i) Retail deposits as defined in the
g) Non-renewable loans and
Regulation;
receivables, and separately, those the
ii) Deposits that fulfill certain borrowers of which are:
conditions; i) Natural persons other than
commercial sole proprietor and
iii) All funding obtained from financial partnerships and deposits placed by
customers; small and medium-size enterprises
where the aggregate deposit placed
iv) Funding from secured lending as
by that client or group of connected
specified in the Regulation;
clients is less than 1 million EUR;
v) Liabilities resulting from covered
ii) Sovereigns, central banks and PSEs;
bonds;
iii) Clients not referred to in (i) and (ii)
vi) Other liabilities resulting from
other than financial customers;
securities issued;
iv) Any other borrowers;
vii) Any other liabilities.
h) Derivatives receivables;

42
Figure 10: Net Stable Funding Ratio

Available stable funding Institutions are required to maintain a


NSFR = ≥ 100% sound funding structure over one year
Required stable funding in an extended firm-specific stress
scenario

Introduction
Jan. 1, 2018; under observation until then
Scope of application
Level of individual institution (with legal personality)
Reporting
Quarterly
Disclosure
Disclosure of NSFR under Pillar 3
Source: Accenture

Figure 11: NSFR: Available stable funding

Source: Accenture
Note: Based on Basel III document from Basel Committee on Banking Supervision

43
Figure 12: NSFR: Required stable funding

Available stable funding


NSFR = ≥ 100%
Required stable funding

Required stable funding


Items - RSF factor 0%
• Cash
• Unencumbered short-term unsecured instruments and transactions with outstanding maturities < 1 year
• Unencumbered securities with stated remaining maturities < 1 year with no embedded options
• Unencumbered securities held where the institution has an offsetting reverse repurchase transaction
• Unencumbered loans to financial entities with effective remaining maturities < 1 year that are not renewable and for which
the lender has an irrevocable right to call
Items - RSF factor 5%
• Unencumbered marketable securities with residual maturities of one year or greater representing claims on or claims
guaranteed by sovereigns, central banks, BIS, IMF, EC, non-central government PSEs or multilateral development banks that
are assigned a 0% risk-weight under the Basel II standardized approach, provided that active repo or sale-markets exist for
these securities
Items - RSF factor 20%
• Unencumbered corporate bonds or covered bonds rated AA- or higher with residual maturities ≥ 1 year satisfying all of the
conditions for Level 2 assets in the LCR
• Unencumbered marketable securities with residual maturities ≥ 1 year representing claims on or claims guaranteed by
sovereigns, central banks, non-central government PSEs that are assigned a 20% risk-weight under the Basel II standardized
approach, provided that they meet all of the conditions for Level 2 assets in the LCR
Items - RSF factor 50%
• Gold
• Unencumbered equity securities, not issued by financial institutions or their affiliates, listed on a recognized exchange and
included in a large cap market index
• Unencumbered corporate bonds and covered bonds that are central bank eligible and are not issued by financial institutions
Items - RSF factor 65%
• Unencumbered residential mortgages of any maturity that would qualify for the 35% or lower risk-weight under Basel II
Standardized Approach
• Other unencumbered loans, excluding loans to financial institutions, with a remaining maturity of one year or greater, that
would qualify for the 35% or lower risk-weight under Basel II Standardized Approach for credit risk
Items - RSF factor 85%
• Unencumbered loans to retail customers and SME (as defined in the LCR) having a remaining maturity < 1 year
Items - RSF factor 100%
• All other assets not included in the above categories

Source: Accenture
Note: Based on Basel III document from Basel Committee on Banking Supervision

44
5.3 Monitoring tools
A further objective of Basel III Concentration of funding Market-related monitoring
is to strengthen and promote
global consistency in liquidity
Different ratios/figures 39 to help tools
identify sources of wholesale funding Early warning indicators based
risk supervision. According to the
that are of such significance that their on high-frequency market data
proposed EU Regulation, EBA shall
withdrawal could trigger liquidity with little or no time lag (market
develop draft implementing technical
problems. wide information; information on
standards regarding additional
liquidity monitoring metrics that allow the financial sector; bank-specific
competent authorities to obtain a Available unencumbered information).
comprehensive view of the liquidity assets
profile of institutions.
Available unencumbered assets
In the Basel III document of the BCBS, that are marketable as collateral in
the following monitoring tools or secondary markets and/or eligible for
metrics are proposed.38 central banks’ standing facilities.

Contractual maturity LCR by significant currency


mismatch Foreign Currency LCR = Stock of high-
quality liquid assets in each significant
Contractual cash and security inflows
currency/total net cash outflows
and outflows from all on-and off-
over a 30-day time period in each
balance sheet items, mapped to
significant currency.40
defined time bands based on their
respective maturities.

5.4 Institutional networks


For institutional networks, the Basel b) NSFR: As previously mentioned,
III framework includes the following the proposed EU Regulation does
special treatments relating to the not include any specific ASF and
calculation of the LCR and NSFR. RSF factors. According to the BCBS
document for liabilities versus financial
a) LCR: For calculating liquidity institutions there should generally
outflows, generally a “run off” be applied an ASF factor of 0%
factor of 100% should be applied for when calculating the available stable
unsecured wholesale funding. In case funding. These are not recognized as
of common task sharing within an stable sources of funding. A possible
institutional protection scheme or as a exception to this treatment is for
legal or statutory minimum deposit by stable deposits from cooperative
another entity being a member of the banks that are required by law to be
same institutional protection scheme, placed at the central organization
a factor of 25% can be used by the and are legally constrained within
centralized institution. the cooperative bank network as
“minimum deposit requirements.”
For deposits held at the centralized These deposits shall be assigned an
institution in a cooperative banking ASF factor of 75% or 50% depending
network that are assumed to stay on whether the depositor is a retail
at the centralized institution, the or SME client or a non-financial
depositing bank should not count corporate client.
any inflow for these funds. They will
receive a 0% inflow rate (by the
depositing bank).

45
6
Enhanced governance
and sanctions

46
47
6.1 Enhanced 6.2 Sanctions
governance With the proposed Directive, the
divergent and not-always-appropriate
national sanctioning regimes for
Among other deficiencies, the key violations of the CRD would
recent financial crisis demonstrated be harmonized. At this point, in
shortcomings in corporate governance some Member States the levels of
arrangements in the financial services administrative pecuniary sanctions are
industry, contributing to excessive too low and thus are an insufficient
risk-taking. According to the Basel deterrent, or the actual application of
Committee on Banking Supervision sanctions differs in Member States.43
and the EU Commission in many
cases risk oversight by boards was With the new rules, effective,
inadequate, often due to insufficient proportionate and deterrent sanctions
time commitment, inadequate would be imposed to ensure
technical knowledge or insufficient compliance with the CRD rules. For
diversity in board composition. Boards the European Commission, the most
were often not sufficiently involved appropriate options to achieve that
in the overall risk strategy or did objective would be a combination of
not spend sufficient time discussing the following:
risk issues, as risk management was
considered a low priority compared • Minimum common rules on the type
to other concerns. In addition, the of administrative sanctions available
risk management function has not to competent authorities;
been given appropriate weight in the • Minimum common rules on
decision-making process.41 maximum level of pecuniary
administrative sanctions;
With the proposed Directive,42 the
non-binding nature of most of the • List of key factors to be taken
corporate governance principles which into account when determining the
contributed to the lack of compliance administrative sanctions;
with these principles should be • Obligation to provide for the
transformed into binding regulations. application of administrative sanctions
This should help avoid excessive risk to both individuals and credit
taking. The strengthening of the institutions;
corporate governance framework
requires: • Publication of sanctions as a
general rule.
• Increasing the effectiveness of risk
oversight by boards;

• Improving the status of the risk


management function; and

• Ensuring effective monitoring by


supervisors of risk governance.

The table on page 49 provides a


summarized overview of the options
on corporate governance.

48
Table 6: Options on corporate governance

Improve time commitment of board • Require credit institutions to disclose the number of mandates of board members
members • Require board members to spend sufficient time exercizing their duties
• Limit the maximum number of mandates a board member may hold at the same
time

Improve expertise of board members • Require disclosure of the recruitment policy and the actual expertise and skills of
board members
• Specify skills and expertise that board members must possess individually and
collectively
• Require that board members receive appropriate induction and continuous
training
• Mandatory nomination committee

Counterbalance management • Prohibit cumulating mandates of chairman and chief executive officer in the
dominance same credit institution

Improve diversity in boards' • Require disclosure of internal policy on diversity


composition • Benchmarking different practices at national and European level
• Require diversity as one of the criteria of boards' composition
• Require credit institutions to establish a diversity policy

Improve ownership by boards of risk • Require a declaration on the adequacy of risk management systems
strategy • Require a risk statement stating credit institution's approach to risk

Improve priority given by boards to • Require disclosure of policy and practice with regard to discussion and analysis
risk issues of risk issues during board meetings
• Require that boards devote sufficient time to risk issues
• Mandatory risk committee at board level

Improve the information flow to • Require disclosure of policy and practice with regard to the information flow on
boards on risk risk to the board
• Require boards to determine the content, format and frequency of risk
information it should receive
• Require that the risk management function report directly to the board

Improve the standing and the • Require disclosure of the standing and authority of risk management function
authority of the risk management • Require an independent risk management function
function
• Require an independent chief risk officer
• Require that chief risk officer have appropriate status and authority
• Require that removal of the chief risk officer is subject to prior approval by
the board

Ensure efficient monitoring of risk • Require that corporate governance is part of supervisory review
governance by supervisors • Require that the suitability of board members is subject to specific supervisory
review
• Require supervisors to review agendas and supporting documents for meetings of
the board

Source: Executive Summary of the Impact Assessment. Accompanying the document Directive of the European Parliament
and the Council (July 2011), European Commission.

49
7
Other topics

50
51
7.1 Systemically Important Financial
Institutions
The treatment of systemically indicators are chosen to reflect The BCBS is of the view that the
important financial institutions (SIFIs) the different aspects of what magnitude of the discussed additional
– systemically important banks (SIBs) generates negative externalities loss absorbency depends on the
are a part of them – is currently under and makes a bank critical for the assessment and the bucket where it
discussion at the Financial Stability stability of the financial system.”46 resides. A capital surcharge between
Board (FSB) and the Basel Committee The indicators reflect the size, the 1% and 2.5% - to be met with CET1
on Banking Supervision (BCBS). The interconnectedness, lack of readily capital – is currently proposed and it
objective is to reduce the probability available substitutes for the service should be implemented through an
of failure of G-SIBs44 by increasing provided, global (cross jurisdictional) extension of the capital conservation
their going-concern loss absorbency activity and the complexity of banks buffer. It should be phased in along
and reducing the extent or impact of and should be assigned with an with the capital conservation and
failure of G-SIBs, by improving global equal weight of 20% (see Appendix). countercyclical buffer, i.e., between
recovery and resolution frameworks. The assessment is conducted with 2016 and year-end 2018, becoming
In July 2011 a consultation paper consolidated group data.47 fully effective on January 1, 2019.
was published by the BCBS dealing
with the assessment methodology The indicator-based measurement
and additional loss absorbency approach can be supported by
requirements for such institutions.45 supervisory judgment based on certain
principles. The BCBS also identified
For assessing which banks should be several ancillary indicators which can
considered as G-SIB, an indicator- support the supervisory judgment
based measurement approach (see Appendix).
is proposed where the “selected

52
7.2
Overreliance 7.3 Small
on external and Medium- 7.4 Basel I
ratings Sized Entity limit
A further objective of the proposed Basel II allows a preferential risk- With Basel II a limit was introduced
Directive is to reduce the overreliance weight for SMEs compared to other requiring that institutions have capital
of institutions and investors on corporates. This beneficial treatment no lower than 80% of the capital
external credit ratings, i.e., on ratings will continue under Basel III. that would have been required under
issued by credit rating agencies. This Basel I. This limit expired at the end of
goal can be reached by: A more preferential treatment, 2009 but was reinstated until the end
i.e., lower risk-weights for small of 2011 by the Directive 2010/76/EC
a) Requiring that all banks' investment and medium-sized entities (SMEs) (CRD III). The proposed EU Regulation
decisions are based not only on compared to the current status as concerning Basel III reinstates it until
external ratings but also on their own suggested from different countries 2015.50
internal credit opinion; and with a SME-based economy, would
require a revision to the international
b) That banks with a material number Basel framework. According to the
of exposures in a given portfolio proposed EU Regulation, EBA should
develop internal ratings for that analyze and report by September 2012
portfolio instead of relying on external on the current risk-weights, taking into
ratings for the calculation of their consideration a scenario for a possible
capital requirements.48 reduction by one-third compared to
the current situation.49

53
8

Conclusion

54
55
In response to the serious nature of the recent financial
crisis, several measures at the micro and macro level
are being considered to increase the stability of the
financial markets. One major focus is strengthening
global capital and liquidity rules through Basel III. In
December 2010, the BCBS published the corresponding
Basel III documents (a revised version of the capital
framework was published in June 2011).

In the EU, Basel III will be implemented NSFR). Also included are increased
mainly through a Regulation, i.e., requirements for systemically
the rules are directly applicable at important financial institutions and
the national level. The European strengthening corporate governance.
Commission published the
proposed Regulation as well as the Even though some of the requirements
supplementary Directive in July 2011. are still under discussion and need to
These legal instruments are now be specified (e.g., the concrete ASF-
being discussed within the European and RSF-factors within the NSFR) and
Parliament and Council. The new rules others might be recalibrated based
would apply as of January 1, 2013, on the quantitative impact analysis
with varying transition periods. (e.g., leverage ratio), banks at this
time clearly must deal with wide-
Key aspects of Basel III are: a stricter ranging regulatory changes that will
definition of capital to increase the impact their business models and
quality, consistency and transparency funding strategies as well as capital
of the capital base; introduction of and liquidity costs. At the same time,
capital buffers; increased capital pressure continues to mount from a
requirements for CCR; introduction market expecting banks to fulfill or
of a leverage ratio to supplement even exceed the new requirements
the risk-based framework of Basel II; before the regulatory deadline.
and a new global liquidity standard
introducing two new ratios which
banks need to fulfill (LCR and

56
Bibliography
Basel III and Its Consequences. http://www.bundesbank.de/download/
Confronting a New Regulatory bankenaufsicht/pdf/basel3_leitfaden.
Environment; (2011), Accenture pdf
found at http://www.accenture.
com/SiteCollectionDocuments/ New proposals on capital requirements
PDF/Accenture_Basel_III_and_its_ (July 2010), European Commission
Consequences.pdf found at http://ec.europa.eu/internal_
market/bank/regcapital/index_en.htm
Principles for Sound Liquidity Risk
Management and Supervision Directive 2010/76/EU of the European
(September 2008), Basel Committee Parliament and of the Council of
on Banking Supervision (hereafter November 24, 2010 amending
BCBS) of the Bank for International Directives 2006/48/EC and 2006/49/
Settlements (hereafter ‘BIS’) found at EC as regards capital requirements
http://www.bis.org/publ/bcbs144.pdf for the trading book and for re-
securitisations, and the supervisory
Basel III: A global regulatory review of remuneration policies
framework for more resilient banks (November 2010), European Parliament
and banking systems (December 2010; and Council, found at http://eur-lex.
rev. June 2011), BCBS found at http:// europa.eu/LexUriServ/LexUriServ.do?ur
www.bis.org/publ/bcbs189.pdf i=OJ:L:2010:329:0003:0035:EN:PDF

Basel International framework for Directive 2010/76/EU of the European


liquidity risk measurement, standards Parliament and of the Council of
and monitoring. (December 2010), September 16, 2009 amending
BCBS found at http://www.bis.org/ Directives 2006/48/EC, 2006/49/
publ/bcbs188.pdf EC and 2007/64/EC as regards banks
affiliated to central institutions,
Global systemically important banks: certain own funds items, large
Assessment methodology and the exposures, supervisory arrangements,
additional loss absorbency requirement and crisis management (September
(July 2011), BCBS, Consultative 2009), European Parliament and
Document found at http://www.bis. Council found at http://eur-lex.europa.
org/publ/bcbs201.pdf eu/LexUriServ/LexUriServ.do?uri=OJ:L:
2009:302:0097:0119:EN:PDF
Basel III – Leitfaden zu den neuen
Eigenkapital- und Liquiditätsregeln für
Banken (2011), Deutsche Bundesbank;

57
Appendix
Basel III Summary Table
Table 7: Basel III Summary Table

Basel Committee on Banking Supervision reforms - Basel III


Strengthens micro-prudential regulation and supervision, and adds a macro-prudential overlay that includes capital buffers.

Capital Framework
Pillar 1

Capital Risk coverage Containing leverage

All Banks
Quality and level of capital Securitisations Leverage ratio
Greater focus on common equity. The Strengthens the capital treatment for A non-risk-based leverage ratio that
minimum will be raised to 4.5% of certain complex securitisations. Requires includes off-balance sheet exposures
risk-weighted assets, after deductions. banks to conduct more rigorous credit will serve as a backstop to the
analyses of externally rated securitisation risk-based capital requirement. Also
Capital conservation buffer exposures. helps contain system wide build up of
Comprising common equity of 2.5% of leverage.
risk-weighted assets, bringing the total Trading book
common equity standard to 7%. Constraint Significantly higher capital for trading and
on a bank’s discretionary distributions will derivatives activities, as well as complex
be imposed when banks fall into the buffer securitisations held in the trading book.
range. Introduction of a stressed value-at-risk
framework to help mitigate procyclicality.
Countercyclical buffer
Imposed within a range of 0-2.5% compris- Counterparty credit risk
ing common equity, when authorities judge Substantial strengthening of the counter-
credit growth is resulting in an unaccept- party credit risk framework. Includes: more
able build up of systematic risk. stringent requirements for measuring
exposure; capital incentives for banks to
use central counterparties for derivatives;
and higher capital for inter-financial sector
exposures.

SIFIs
In addition to meeting the Basel III requirements, global systemically important financial institutions (SIFIs) must have higher loss absorbency
capacity to reflect the greater risks that they pose to the financial system. The Committee has developed a methodology that includes both
quantitative indicators and qualitative elements to identify global SIFIs. The additional loss absorbency requirements are to be met with a
progressive Common Equity Tier 1 (CET1) capital requirement ranging from 1% to 2.5%, depending on a bank’s systemic importance. A
consultative document was submitted to the Financial Stability Board, which is coordinating the overall set of measures to reduce the moral
hazard posed by global SIFIs.

Source: BCBS (2011): http://www.bis.org/bcbs/basel3/b3summarytable.pdf

58
Liquidity
Pillar 2 Pillar 3

Risk management Market Global liquidity standard and


and supervision discipline supervisory monitoring

Supplemental Pillar 2 requirements. Revised Pillar 3 disclosures requirements Liquidity coverage ratio
Address firm-wide governance and risk The requirements introduced relate to The liquidity coverage ratio (LCR) will
management; capturing the risk of securitisation exposures and sponsorship require banks to have sufficient high-
off-balance sheet exposures and of off-balance sheet vehicles. Enhanced quality liquid assets to withstand a
securitisation activities; managing risk disclosures on the detail of the 30-day stressed funding scenario that is
concentrations; providing incentives for components of regulatory capital and specified by supervisors.
banks to better manage risk and returns their reconciliation to the reported Net stable funding ratio
over the long term; sound compensation accounts will be required, including a The net stable funding ratio (NSFR) is a
practices; valuation practices; stress comprehensive explanation of how a longer-term structural ratio designed to
testing; accounting standards for bank calculates its regulatory capital address liquidity mismatches. It covers the
financial instruments; corporate ratios. entire balance sheet and provides
governance; and supervisory colleges. incentives for banks to use stable sources
of funding.
Principles for Sound Liquidity Risk
Management and Supervision
The Committee’s 2008 guidance entitled
Principles for Sound Liquidity Risk
Management and Supervision takes
account of lessons learned during the
crisis and is based on a fundamental
review of sound practices for managing
liquidity risk in banking organisations.
Supervisory monitoring
The liquidity framework includes a
common set of monitoring metrics to
assist supervisors in identifying and
analysing liquidity risk trends at both the
bank and system-wide level.

59
Asset Value Correlation: Risk-Weight for large financial
institutions Basel II vs. Basel III
Figure 13: AVC: Risk-Weights for large financial institutions – Basel II vs. Basel III

Risk-weight

180%

160%

140%
Basel III
120%
Basel II
100%

80%

60%

40%

20%

0%
0.03% 0.2% 0.4% 0.6% 0.8% 1% 1.2% 1.4% 1.6% 1.8% 2% 2.2% 2.4%
0.1% 0.3% 0.5% 0.7% 0.9% 1.1% 1.3% 1.5% 1.7% 1.9% 2.1% 2.3% 2.5%

Source: Accenture

Table 8: AVC: Risk-Weights for large financial institutions – Basel II vs. Basel III

PD RW Basel II RW Basel III Increase RW


0.03% 15.31% 20.84% 36.09%
0.10% 31.43% 42.47% 35.12%
0.20% 46.53% 62.22% 33.74%
0.30% 57.64% 76.44% 32.60%
0.40% 66.48% 87.52% 31.64%
0.50% 73.79% 96.52% 30.81%
0.60% 79.98% 104.03% 30.07%
0.70% 85.33% 110.43% 29.41%
0.80% 90.01% 115.94% 28.81%
0.90% 94.15% 120.77% 28.27%
1.00% 97.86% 125.03% 27.77%
1.10% 101.19% 128.82% 27.30%
1.20% 104.23% 132.24% 26.88%
1.30% 107.00% 135.34% 26.48%
1.40% 109.56% 138.16% 26.10%
1.50% 111.93% 140.76% 25.76%
1.60% 114.14% 143.16% 25.43%
1.70% 116.20% 145.39% 25.12%
1.80% 118.15% 147.49% 24.83%
1.90% 119.99% 149.46% 24.55%
2.00% 121.75% 151.32% 24.29%
2.10% 123.42% 153.09% 24.04%
2.20% 125.02% 154.78% 23.81%
2.30% 126.56% 156.40% 23.58%
2.40% 128.05% 157.97% 23.37%
2.50% 129.48% 159.48% 23.16%

Source: Accenture

60
Indicator-based measurement approach G-SIBS

Table 9: Indicator-based measurement approach G-SIBS

Indicator-based Measurement Approach


Category (and weighting) Individual Indicator Indicator Weighting
Cross-jurisdictional activity (20%) Cross-jurisdictional claims 10%
Cross-jurisdictional liabilities 10%
Size (20%) Total exposures as defined for use in the Basel III leverage 20%
ratio
Interconnectedness (20%) Intra-financial system assets 6.67%
Intra-financial system liabilities 6.67%
Wholesale funding ratio 6.67%
Substitutability (20%) Assets under custody 6.67%
Payments cleared and settled through payment systems 6.67%
Values of underwritten transactions in debt and equity 6.67%
markets
Complexity (20%) OTC derivatives notional value 6.67%
Level 3 assets 6.67%
Trading book value and available for sale value 6.67%

Source: Global systemically important banks: Assessment methodology and the additional loss absorbency requirement (July 2011), BCBS, Consultative Document

Table 10: Ancillary indicators for assessment G-SIBS

List of Standardized Ancillary Indicators


Category Individual Indicator

Cross-jurisdictional activity (20%) Non-domestic revenue as a proportion of total revenue


Cross-jurisdictional claims and liabilities as a proportion of total assets and
liabilities
Size Gross or net revenue
Equity market capitalization
Substitutability Degree of market participation:
1. Gross mark-to-market value of repo, reverse repo and securities lending
transactions
2. Gross mark-to-market OTC derivatives transactions
Complexity Number of jurisdictions

Source: Global systemically important banks: Assessment methodology and the additional loss absorbency requirement (July 2011), BCBS, Consultative Document.

61
Footnotes
1. Basel III: A global regulatory framework 12. Proposed EU Regulation [Proposal for a credit institutions, insurance undertakings
for more resilient banks and banking Regulation of the European Parliament and and investment firms in a financial
systems (December 2010; rev. June 2011), of the Council on prudential requirements conglomerate; p. 12.
Basel Committee on Banking Supervision for credit institutions and investment
(hereafter “BCBS”) of the Bank for firms] (European Commission, July 2011). 20. Calibrated in increments of 0.25
International Settlements (hereafter percentage points, or multiples of .25.
“BIS”) found at http://www.bis.org/bcbs/ 13. Relevant entities according to the
EU proposed Regulation are: (a) another 21. The directive allows also a buffer
basel3/compilation.htm and International
institution; (b) a financial institution; (c) an beyond 2.5 if justified.
framework for liquidity risk measurement,
standards and monitoring (December insurance undertaking; (d) a third country
22. Basel III: A global regulatory
2010), BCBS. The appendix of this insurance undertaking; (e) a reinsurance
framework for more resilient banks and
handbook contains a Basel III summary undertaking; (f) a third country
banking systems (December 2010; rev.
table from BCBS. reinsurance undertaking; (g) a financial
June 2011), BCBS as well as New proposals
undertaking; (h) a mixed activity insurance
on capital requirements (July 2011),
2. European Capital Requirements holding company; (i) an undertaking
European Commission found at http://
Directive III (2010/76/EU). excluded from the scope of Directive. See
ec.europa.eu/internal_market/bank/
New proposals on capital requirements
3. Principles for Sound Liquidity Risk regcapital/index_en.htm.
(July 2011), European Commission found at
Management and Supervision (June 2008), http://ec.europa.eu/internal_market/bank/ 23. Basel III: A global regulatory
BCBS. regcapital/index_en.htm. framework for more resilient banks and
4. European Capital Requirements banking systems (December 2010; rev.
14. See European Commission (2011): CRD
Directive III (2009/111/EC). June 2011), BCBS, p. 38.
IV – Frequently Asked Questions (http://
europa.eu/rapid/pressReleasesAction.do?re 24. According to the proposed EU
5. For Basel III implementation challenges
ference=MEMO/11/527&format=HTML&ag Regulation [Proposal for a Regulation
see: Basel III and Its Consequences.
ed=0&language=EN&guiLanguage=en). of the European Parliament and of the
Confronting a New Regulatory
Environment (2011), Accenture Council on prudential requirements for
15. Article 108(7) of the proposed EU
found at http://www.accenture.com/ credit institutions and investment firms]
Regulation [Proposal for a Regulation
SiteCollectionDocuments/PDF/Accenture_ unregulated financial entity means any
of the European Parliament and of the
Basel_III_and_its_Consequences.pdf. other entity that is not a regulated entity
Council on prudential requirements for
but performs one or more of the listed
credit institutions and investment firms]
6. New proposals on capital requirements activities.
deals with the calculation of risk-weighted
(July 2011), European Commission found at
exposure amounts with regard to 25. European Commission (2011):
http://ec.europa.eu/internal_market/bank/
counterparties with which the institution Proposal for a Directive of the European
regcapital/index_en.htm.
has entered into an institutional protection Parliament and of the Council on the
7. New proposals on capital requirements scheme that is a contractual or statutory access to the activity of credit institutions
(July 2011), European Commission found at liability arrangement which protects those and the prudential supervision of credit
http://ec.europa.eu/internal_market/bank/ institutions and in particular ensures their institutions and investment firms and
regcapital/index_en.htm. liquidity and solvency to avoid bankruptcy amending Directive 2002/87/EC of the
in case it becomes necessary. European Parliament and of the Council
8. European Commission (2011): CRD IV – on the supplementary supervision of
Frequently Asked Questions, p. 15 (http:// 16. For the following explanations see
credit institutions, insurance undertakings
europa.eu/rapid/pressReleasesAction.do?re New proposals on capital requirements
and investment firms in a financial
ference=MEMO/11/527&format=HTML&ag (July 2011), European Commission found at
conglomerate; p. 15.
ed=0&language=EN&guiLanguage=en). http://ec.europa.eu/internal_market/bank/
regcapital/index_en.htm. 26. For the following descriptions see New
9. For the following descriptions see New proposals on capital requirements (July
proposals on capital requirements (July 17. For more details about the calculation
2011), European Commission found at
2011), European Commission found at see Article 131 of the proposed EU
http://ec.europa.eu/internal_market/bank/
;http://ec.europa.eu/internal_market/bank/ Directive.
regcapital/index_en.htm.
regcapital/index_en.htm
18. See also Bundesbank (May 2011): Basel
27. During the period from Jan. 1, 2013
10. Article 26 of the proposed EU III – Leitfaden zu den neuen Eigenkapital-
to Dec. 31, 2017 competent authorities
Regulation [Proposal for a Regulation und Liquidititätsregeln für Banken.
may permit institutions to calculate the
of the European Parliament and of the end-of-quarter leverage ratio where
19. European Commission (2011): Proposal
Council on prudential requirements for they consider that institutions may not
for a Directive of the European Parliament
credit institutions and investment firms] have data of sufficiently good quality
and of the Council on the access to
(European Commission, July 2011). to calculate a leverage ratio that is an
the activity of credit institutions and
the prudential supervision of credit arithmetic mean of the monthly leverage
11. European Commission (2011): CRD IV –
institutions and investment firms and ratios over a quarter.
Frequently Asked Questions.
amending Directive 2002/87/EC of the
28. For explicitly mentioned off-balance-
European Parliament and of the Council
sheet items, there are exceptions to this
on the supplementary supervision of
treatment.

62
29. Principles for Sound Liquidity Risk 41. For the following descriptions 49. New proposals on capital requirements
Management and Supervision (September see European Commission (2011) – (July 2011), European Commission found at
2008), BCBS. Commission Staff Working Paper: http://ec.europa.eu/internal_market/bank/
Executive Summary of the Impact regcapital/index_en.htm.
30. For the following descriptions see New Assessment. Accompanying the document
proposals on capital requirements (July Directive of the European Parliament and 50. See European Commission (July
2011), European Commission found at the Council on the access to the activity 2011): New proposals on capital
http://ec.europa.eu/internal_market/bank/ of credit institutions and the prudential requirements;http://ec.europa.eu/internal_
regcapital/index_en.htm supervision of credit institutions and market/bank/regcapital/index_en.htm.
investment firms and amending Directive
31. See Article 7(1) of the proposed
2002/87/EC of the European Parliament
Regulation; for cross border institutions
and of the Council on the supplementary
also Article 7(2).
supervision of credit institutions, insurance
32. Article 401 of the proposed Regulation. undertakings and investment firms in a
financial conglomerate (http://ec.europa.
33. Bonds are issued by a credit institution eu/internal_market/bank/docs/regcapital/
which has its registered office in a CRD4_reform/executive_summary_IA_
Member State and is subject by law to directive_en.pdf).
special public supervision designed to
protect bond-holders [Directive 2009/65/ 42. See New proposals on capital
EC of the European Parliament and requirements (July 2011), European
the Council, http://eur-lex.europa.eu/ Commission found at http://ec.europa.
LexUriServ/LexUriServ.do?uri=OJ:L:2009:3 eu/internal_market/bank/regcapital/
02:0032:0096:en:PDF). index_en.htm.

34. According to the proposed EU 43. For the following descriptions


Regulation [Proposal for a Regulation see European Commission (2011) –
of the European Parliament and of the Commission Staff Working Paper:
Council on prudential requirements for Executive Summary of the Impact
credit institutions and investment firms] Assessment. Accompanying the document
retail deposit means a liability to a natural Directive of the European Parliament and
person or to a small and medium sized the Council on the access to the activity
enterprise where the aggregate liability to of credit institutions and the prudential
such clients or group of connected clients supervision of credit institutions and
is less than 1 million EUR. investment firms and amending Directive
2002/87/EC of the European Parliament
35. See Article 408(2) of the proposed and of the Council on the supplementary
EU Regulation [Proposal for a Regulation supervision of credit institutions, insurance
of the European Parliament and of the undertakings and investment firms in a
Council on prudential requirements for financial conglomerate (http://ec.europa.
credit institutions and investment firms]. eu/internal_market/bank/docs/regcapital/
CRD4_reform/executive_summary_IA_
36. In the Basel III document from the directive_en.pdf).
Basel Committee on Banking Supervision
“> 100%" is proposed. 44. Global systemically important banks.

37. Basel III: International framework for 45. See hereto and for the following
liquidity risk measurement, standards and descriptions Global systemically important
monitoring (December 2010), BCBS. banks: Assessment methodology and the
additional loss absorbency requirement
38. Basel III: International framework for (July 2011), BCBS, Consultative Document.
liquidity risk measurement, standards and
monitoring (December 2010), BCBS. 46. Global systemically important
banks: Assessment methodology and the
39. Metrics suggested: a) Funding additional loss absorbency requirement
liabilities sourced from each significant (July 2011), BCBS, Consultative Document,
counterparty/ the bank's balance sheet p. 3.
total; b) Funding liabilities sourced from
each significant product/instrument/ 47. For more details see Global
the bank's balance sheet total; c) List of systemically important banks: Assessment
asset and liability amounts by significant methodology and the additional loss
currency. absorbency requirement (July 2011), BCBS,
Consultative Document.
40. Note: Amount of total net foreign
exchange cash outflows should be net of 48. See CRD IV – Frequently Asked
foreign exchange hedges. Questions (2011), European Commission.

63
Contact
Michael Auer Georg von Pfoestl
Michael is executive principal – Georg is senior manager – Accenture
Accenture Risk Management, Munich, Risk Management. Based in Vienna,
responsible for German-speaking Georg has 8 years of experience in the
markets. Michael has 18 years of area of risk management with a focus
industry and consulting experience on credit and liquidity risk, regulatory
in financial services and risk matters and Risk-Weighted Assets
management across Europe working optimization. With his experience as
with global institutions to transform a banking inspector at the Austrian
their business and risk capabilities. National Bank, his pragmatic
His extensive experience in risk knowledge from working with regional
management – mainly in the areas of and international financial institutions
market, credit and operational risk, risk across German-speaking markets
and regulatory matters and operating and his technical skills pertaining
models helps executives and their to Basel II and Basel III regulatory
multinational firms become high- requirements, he guides companies on
performance businesses. their journey to high performance.

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