Professional Documents
Culture Documents
Session 2 Lecture Slides
Session 2 Lecture Slides
External Stakeholder
Requirements
Session 2
Overview of Banking Regulation
and the Basel Accords
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Current Landscape of U.S.
Banking Regulation
National Banks State Banks
• Chartered by the U.S. gov’t • Chartered by a state gov’t
– Includes Federal Savings and – State and federal regulation
Loan and Federal Savings banks – NYSDFS
– Must be part of Federal
Reserve System (FRS)
• Federal regulator is Federal
Reserve Bank (FRB) ‐ part of
Federal Reserve System
• Regulated by the Office of
the Comptroller of the
Currency (OCC) • Federal regulator for other
banks is FDIC
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Federal Reserve System
• Consists of Central Bank and 12 Federal
Reserve district banks
• Board of Governors: 7 members, appointed by
president
• Main role:
– Control monetary policy, money supply, reserve
requirements, adjustments in discount rates
– regulate commercial banks, oversees operation of
12 districts
– www.federalreserve.gov
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Other U.S. Banking Regulatory Bits
• Credit Unions: Non profit financial institutions
– “Earnings” used to raise rates on deposits
– Regulated by National Credit Union Administration
• All banks with Federal Deposit Insurance
subject to FDIC oversight
– Capital ratios and solvency
• OCC regulates federal branches of foreign
banks
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Current Landscape of European
Union (EU) Banking Regulation
• National banking supervisors regulate banks
based on country of domicile
• European Banking Authority (EBA) – Jan. 1,
2011
– Single set of harmonized prudential rules
– Convergence of supervisory practices
– Assess risks/vulnerabilities in EU banking sector
Summary of Banking Regulators
Jurisdiction Regulator
Global BCBS
EBA/National
EU
Supervisors
US – National Charter OCC
State Bank
US – State Charter/Other
Regulator/FDIC
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Basel Committee on
Banking Supervision (BCBS)
Background on BCBS
• Initially formed in 1974 as a forum for
cooperation on regulatory matters
– Meetings at Bank for International Settlements
(BIS) in Basel, Switzerland 3‐4 times per year
– https://www.bis.org
• Initially just the central bankers of the G10
– Membership now from 28 jurisdictions
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BCBS Objectives and Authority
• Formulates supervisory standards/guidelines
– Recommends sound practices
• No legal force
– Expect timely and efficient implementation from
individual countries
– Began monitoring implementation in 2012
Basel Accords
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Basel Background
• Introduced in 1988 and expanded multiple
times since then
• Strengthen soundness and stability of the
international banking system
• Diminish existing sources of competitive
inequality among international banks
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Objectives of Basel
• Enhance risk management
• Increase stability of financial markets
• Improve banking industry’s ability to absorb
macro‐economic shocks
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Discussion Questions
• Q1. What is the importance of capital to a bank? Why is the leverage ratio important?
•
• Q3. What are the differences between the banking and trading book?
•
• Q4. From a banking perspective, how does the interest rate risk differ from the
market risk?
•
• Q5. Basel 3 expanded the concepts of RWA from Basel 2. Why do they treat assets
differently?
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Three Pillars of Basel
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Pillar One
Minimum Capital and
Liquidity Requirements
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Measuring Capital Adequacy
Cooke Ratio Definition
• Cooke Ratio = C/RWA, where
C = Capital, and
RWA = Risk weighted assets
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Defining Capital
Tier 1 and Tier 2
Tier 1 Capital Tier 2 Capital
• “Going concern” • “Gone concern”
– Allow bank to continue – Help ensure depositors and
operations/avoid insolvency creditors repaid on insolvency
• Common Equity Tier 1 • Key examples are hybrid
– Common equity and retained securities and subordinated
earnings the primary forms debt
• Other Tier 1
– E.g. Noncumulative perpetual
preferred shares
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Common Equity Tier 1
• Most subordinated/first tier to absorb losses
• Has no maturity, right to be redeemed, coupon,
priority rights, security interest
• Wholly discretionary distributions from distributable
items (e.g. earnings)
• Shown as equity on balance sheet
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Other Tier 1 Criteria
• Issued and paid in • Callable by bank
– 5 year minimum
• Subordinated to – Supervisor approval
depositors and general – No expectation of call
creditors of the bank
• Distributions/coupons
– Distributable items only
• Not secured, enhanced
– Not credit sensitive
or guaranteed
– Cancellable at bank
discretion w/o effect
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Tier 2 Capital Examples
• Hybrid security and subordinated debt
• Asset revaluation reserves
• Undisclosed reserves
• General provision/loan loss reserves
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Minimum Capital
Requirements at Each Tier
• Common Equity Tier 1: 4.5% of RWA
• Total Tier 1: 6% of RWA
• Tier 1 + Tier 2: 8% of RWA
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Measuring Risk Weighted Assets
And the Business Involved
Risk Category Book of Business
• Credit Risk ====== • Banking Book
• Market Risk ====== • Trading Book
• Operational Risk === • Total Book
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Splitting the Bank’s Business
Banking Book Trading Book
• Held to maturity • Short‐term profit from price
changes
– Brokering/market making
• Accounted at historical cost
– Hedging other positions
• Shown at market value
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Banking vs. Trading
Book Boundary
• Prevent gaming the capital rules between books
• Prescribed list of trading book instruments
– Deviations subject to regulatory approval
• Strict limits on movements between the books
– Capital reductions from transfers held as additional
fixed charge per time of transfer
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Credit Risk
Measurement Alternatives
• Standardized Approach (SA)
– Risk weights based on asset class and credit ratings
• Internal Rating‐Based Foundation (IRFB)
– Internal estimate of probability of default (PD)
– Other model parameters use standard values
• Internal Rating‐Based Advanced (IRBA)
– All model parameters internally estimated
– Banks need to pass a use test for IRB components
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Market Risk
Measurement Alternatives
• Standardized Measurement Method (SMM)
– Decompose trading book assets into base factors
• E.g. interest rate, equity, currency
– Apply defined “shocks” to each factor
– Calculate impacts to determine RWA
• Internal Model Approach (IMA)
– Use of own model to calculate RWA
– Subject to regulatory approval
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Features of Internal
Model Approval Process
• Approvals/disapprovals on trading desk basis
• Model validation tests
– Demonstrate that model risk factors capture
income statement attribution
– Back‐test that risk factors explain historical results
• Risk factors used must be supported by
sufficient data
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Credit Valuation Adjustment (CVA)
• Risk of changes in the credit spread of a
counterparty from worsening credit quality
• Charge applies to all “Over the Counter” (OTC)
derivative trades
• Market value of counterparty credit risk
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Operational Risk Measurement
• Basic Indicator Approach (BIA)
– Same percentage of gross income for all business
• The Standardized Approach (TSA)
– Percentage of gross income where percentage
varies across eight business lines
• Advanced Measurement Approaches
– Statistical model based on internal data
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Capital Conservation
Buffer
• Applies at all times outside financial stress
– 0.625% of RWA in 2016, rising linearly to 2.5% in
2019 and later
– Satisfied only by Common Equity Tier 1 capital
• If total capital below minimum + capital
conservation buffer
– Restrictions on dividends and share repurchases
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Countercyclical
Buffer
• Up to an additional 2.5% of RWA
– Satisfied only by Common Equity Tier 1 capital
• Applies when ratio of Credit to Gross Domestic
Product (GDP) exceeds trend line
• Objective is to smooth the credit cycle
– Encourage lending during bad times/constrain
lending during good times 31
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Summary of Basel 3 Capital
Requirements*
Capital Source Minimum % Minimum %
of RWA in of RWA in
2016 2019
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Systemically Important Banks (SIB’s)
• Deemed “too big to fail”
• Identified based on five categories
• Require additional capital: 1% ‐ 3.5% CET1
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SIB Identification Criteria
• Size • Complexity
• Interconnectedness • Cross‐jurisdictional
activity
• Substitutability/financial
institution infrastructure
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Leverage and Liquidity Ratios
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Leverage Ratio
• Prevent build‐up of excessive on and off
balance sheet leverage
Leverage Ratio = (Tier 1 Capital)/(Total exposures) ≥ 3%
• Total exposures = On and off balance sheet assets
– No risk weight adjustments or credit conversions
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Liquidity Coverage Ratio (LCR)
• Test short‐term resilience of liquidity profile
under stress conditions
HQLA
LCR 100 %
NCOF
• HQLA = High quality liquid assets
• NCOF = Net cash outflows over next 30 days
– Floored at 25% of gross cash outflows
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HQLA Requirements
Fundamental Characteristics Market‐Based Characteristics
• Low credit and market risk • Active and sizable market
• Valuation ease and certainty • Market maker presence
• Low correlation with risky • Low market concentration
assets
• Flight to quality
• Exchange listed
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LCR Stress Scenarios
• Retail deposit run‐off • Unscheduled Line of
Credit draws
• Partial loss of funding
capacity or short‐term • Reputation risk
financing impacting share price
• Three notch bank • Collateral value
downgrade downgrade
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Net Stable Funding Ratio (NSFR)
• Test longer‐term resilience of bank liquidity
AASF
NSFR 100 %
RASF
• AASF = Available amount of stable funding
• RASF = Required amount of stable funding
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Available and Required
Stable Funding
• Available stable funding
– Regulatory capital LESS Tier 2 instruments
maturing within one year PLUS
– Other liabilities with scaling factors from 0%‐100%
• Required stable funding
– Risk weighted assets PLUS
– Off‐balance sheet exposures
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Pillar 2: Internal Controls
and Supervisory Review
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Summary of Pillar 2
• Banks must have internal models and systems
– Develop internal capital adequacy assessment
process (“ICAAP”)
– Own view of capital needs given risk profile
• Regulators not satisfied with the bank view
– Require the bank to hold additional capital
– Require the bank to mitigate existing risks
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Risk Areas Covered by Pillar 2
• Risks not fully captured by Pillar 1
– e.g. Concentration risk
• Risks not covered by Pillar 1
– e.g. Interest rate risk
• External risks (e.g. Business cycle)
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Supervisory Review
Process (SRP) Principles
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SRP Principle 1
• Banks must have a process for evaluating all
key risks and associated capital requirements
– Includes a capital management process
• Capital targets set consistent with risk
appetite set by Board
– Should factor in business cycle considerations
– Subject to periodic independent review
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SRP Principle 2
• Supervisors should review/evaluate bank’s
– Capital, risk assessments and strategies
– Compliance with regulatory capital requirements
– Risk reporting and responses to changes in risk
• Supervisors should take appropriate action if
not satisfied in their review
– Require additional capital or risk reduction
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SRP Principle 3
• Supervisors should expect banks to hold more
than minimum capital levels
– And have authority to require more
• Pillar 1 does not cover all risks
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Why Banks Should Target Higher
Than Minimum Capital Ratios
• Higher rating from credit rating agencies
• Unexpected shifts in business cycle
• May be more costly to raise capital when
needed than to keep a buffer
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SRP Principle 4
• Supervisors should intervene early and require
immediate action on capital deficiencies
– Intensified monitoring
– Dividend payment restrictions
– Require a capital adequacy restoration plan
– Require the bank to immediately raise capital
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Regulatory Monitoring
of Banks via “CAMELS”
• Rating assessment during annual exams
– C = Capital ratio (capital adequacy)
– A = Asset Quality (capacity, collateral, condition)
– M = Management (bank managers and
administrative skills and internal controls)
– E = Earnings (return on assets)
– L = Liquidity
– S = Sensitivity (to market risk / interest rates)
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CAMELS Scoring and Enforcement
• Supervisory authorities assign a score on a scale from
1 (best) – 5 (worst)
– Average score less than 2 = high‐quality
– >3 = less than satisfactory institutions with a need for
higher attention
• Regulators can enter into Enforcement Actions with
entities
– for violations of laws / regulations
– unsound practices / oversight omissions
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Pillar 3: Market Discipline
• Allows market participants to assess a bank’s
– Risk exposures and assessment processes
– Capital management and adequacy
• Encourages market pressure for better bank
risk management
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Pillar 3 Required Disclosures
Risk Management and Balance Sheet
• Overview of risk management, renumeration,
key prudential metrics, and RWA
• Linkages between financial statements and
regulatory exposures
• Composition of capital and total loss
absorbing capacity
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Pillar 3 Required Disclosures
Key Regulatory Ratios
• Macroprudential supervisory measures
• Leverage ratio
• Liquidity ratios
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Pillar 3 Required Disclosures
Exposures by Risk Source
• Credit risk • Market risk
• Counterparty credit risk • Interest rate risk in the
banking book
• Securitization
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Further Strengthening
of ERM for Banks
• Passage of Dodd‐Frank
– Comprehensive Capital Analysis and Review (CCAR)
– Stress Tests
– Enhanced Prudential Standards
• i.e. Establish US Risk committee
– Derivative Reporting (more transparency)
– Volcker Rule (limits on proprietary trading)
• More in session 5
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