2. Agenda
Anatomy of Risk
What is Credit Risk
Historical Perspective for Management of Cr
Risk at Indian Fin Institutions
Why Credit Risk Management
Task of Credit Risk Department
Risk Management Process/ Cycle
Building Blocks of Credit Risk Management
Dinesh Mahabal 2
3. 3
Anatomy of Risk
What is Risk?
Risk is the potential / probability for loss, either
directly through loss of earnings or capital or
indirectly through the imposition of constrains on
organization's ability to meet its business
objectives.
RBI definition
“Risk is defined as the probability of the
unexpected happenings- the probability of
suffering a loss”. (Ref. RBI Guidance Note dated
12th October 2002)
Dinesh Mahabal
4. Anatomy of Risk
Banks during the process of financial intermediation are
confronted with various kinds of financial and non-financial risks
viz. credit, interest rate, foreign exchange rate, liquidity, equity
price, commodity price, legal, regulatory, reputational,
operational etc. These risks are highly interdependent and
events that affect one area of risk can have ramifications for a
range of other risk categories.
Banks, therefore; attach considerable importance to improve
the ability to implement the “Risk Cycle” functions consisting of
four parameters i.e. identify, measure, monitor and control
(IMMC) the overall level of risks undertaken.
Dinesh Mahabal 4
5. Anatomy of Risk
Lending function in particular involves a number of risks such as
interest rate, forex and country risks in addition to the basic
risk related to creditworthiness of the counterparty.
Credit risk or default risk involves inability or unwillingness of a
customer or counterparty to meet commitments in relation to
lending, trading, hedging, settlement and other financial
transactions. The Credit Risk is generally made up of transaction
risk or default risk and portfolio risk.
The portfolio risk in turn comprises intrinsic and concentration
risk. The credit risk of a bank’s portfolio depends on both
external and internal factors.
Dinesh Mahabal 5
6. Types of Risks for a Financial Company
Market Risk:
1. Liquidity, 2. Interest Rate, 3. Currency/Forex, 4.
Equity Price & 5. Commodity Price
Operational Risk:
The risk of loss resulting from inadequate or failed internal processes,
people and systems or from external events {includes legal risk but
specifically excludes strategic (adverse business decisions) and
reputational (risk of negative public opinion) risk}
People, Process, Management, Systems, Business and External
Credit Risk: Transaction- Default, Delayed
Repayment, Downgrade Portfolio- Intrinsic,
concentration
6
Dinesh Mahabal
7. Market Risk
1. Liquidity is the ability to efficiently accommodate deposit and other liability
decreases, as well as, fund growth in loan portfolio and the possible funding of off-balance
sheet claimsThe liquidity risk manifests in three dimensions viz.
a) Funding Risk – need to replace net outflows due to unanticipated withdrawals / non-renewal
of deposits
b) Time Risk – need to compensate for non-receipt of expected inflows of funds i.e.
performing assets turning into NPA
c) Call Risk – due to crystallization of contingent liabilities and unable to undertake
profitable business opportunities when desired.
2. Interest Rate Risk: Risk arising due to the changes in the interest rates on assets and
or liabilities which may be due to re-pricing, embedded options, basis risk or yield curve
risk
a) Gap or mismatch risk:- arises out of holding assets / liabilities and off-balance
sheet items with different principle amounts, maturity dates or repricing dates
thereby causing exposures to unexpected changes in ROI
b) Basis risks arises when interest on assets and liability are fixed on different basis
such as interest on loans is linked to LIBOR and rate on deposits is linked with bank
rate or call money market rates
c) Re-pricing risk:- arises due to the changes in rate of interest on the date of
maturity of an asset or liability. In such a case even if the period of re-pricing is the
same, change in interest rate may be in different directions.
d) Embedded options are the options available to the depositors for repayment of
deposits and borrowers to repay the loan before maturity
Dinesh Mahabal 7
8. Market Risk
3. Currency/ Forex Risk :Three dimensional classification of Currency
Risk exposure covers:
Transaction Exposure i.e. exposure on account of foreign currency
receipts (i.e. exports, etc.) or payments (i.e. imports, etc.). Adverse
movements of concerned foreign currency against domestic currency
involve loss of domestic funds. For example: depreciation of foreign
currency against domestic currency in an export transaction and
appreciation of foreign currency against domestic currency in an import
transaction.
Translation Exposure / Accounting Exposure i.e. conversion of foreign
currency into domestic currency periodically for the purpose of
Statement of Accounts. Adverse movements will have their ultimate
effect on bottom-line and/or Balance Sheet ‘footing’.
Economic Exposure i.e. adverse movements affecting competitive edge
with eventual repercussions on the bottom-line of the organization.
4. Equity Risk arises out of exposure to capital market instruments.
Banks directly invest as also extend credit facilities, both fund-based and
non-funded, to their constituents (including Share Brokers) to enable them
to participate in capital markets by way of purchase/sale transactions. In
the process, Banks expose themselves through market risks associated
with capital exposures
Dinesh Mahabal 8
9. Market Risk
5. Commodity Price Risk:
Any physical product such as agricultural products, metals, minerals, oil,
gas, etc. available for trading in an organized market can be treated as
‘Commodity’ from risk management angle. Gold is treated as a foreign
currency (under BASEL Committee guidelines) & hence the same is not
classified under Commodity.
Commodity of Trading is mainly prevalent in developed countries, with the
availability of derivatives of hedge risk involved in commodity price
fluctuations.However, Indian Banks hardly take up exposures in commodity
trading.
Commodity market often suffers from liquidity element.
Commodity prices are very closely linked with seasonality in supply-demand position.
Equilibrium prices are set up by inventory levels.
Arising out of the aforesaid dominant aspects, following risk attributes are taken into
account in the evaluation of Commodity exposures:
Risk of price movement in spot prices.
Risk of price differential movement in the Commodities – different but related.
Risk of change in cost o financing.
Time spread risk and Option Risk.
Dinesh Mahabal 9
10. Operational Risk
To understand what operational risk is, it is useful to consider the
standard “event types” provided by Basel and some actual losses
(Impact) that have occurred in each Event Type & the cause/s thereof
as follows:-
Dinesh Mahabal 10
12. 12
Risk Profiles break up
Risk Profiles of an Financial
10
Organisation (%)
5 7
18 60
Credit Risk
Mkt. Risk
Liq. Risk
Op. Risk
Other Risks
Dinesh Mahabal
13. What is Credit Risk?
As per RBI’s Guidance Note of Oct’02, “Credit risk is defined as
the possibility of losses associated with diminution in the
credit quality of borrowers or counterparties”..Thus, these
losses, associated with changes in credit quality, could arise due
to default (single or joint) or due to deterioration in credit
quality.
– Default risk - obligor fails to service debt obligations
– Recovery risk – recovery post default is uncertain
– Spread risk – credit quality of obligor changes leading to a
fall in the value of the loan
– Concentration risk – over exposure to a an individual obligor,
group or industry
– Correlation risk - concentration based on common risk
factors between different borrowers, industries or sectors
which may lead to simultaneous default.
Dinesh Mahabal 13
15. Credit Risk in Financial Transactions
Direct Lending: Interest / Installments not repaid/
15
funds will not be available
Guarantees or Letters of Credit: funds will not be
forthcoming from the Guarantor upon crystallization
of the liability
Treasury products: series of payments due from the
counterparty cease or are not forthcoming
Trading: securities settlement is not effected
Cross border exposure: free transfer of currency is
restricted or ceases
Dinesh Mahabal
16. 16
Historical Perspective of Indian
Practices in Credit Risk Management
Traditional ratio analysis and post mortem of
balance sheet
Collateral based lending – Often it is defensive
approach leading to a false sense of “security”
Risk vs. return analysis – not fully adequate
Credit limits on exposures - regulatory limits
insufficient
Nepotism
Risk vs. capacity to absorb risk in terms of capital
base and capital adequacy ratio
Dinesh Mahabal
17. 17
Why should Banks be concerned with Credit
Risk?
Market Realities
Structural increase in NPAs
Concentrations in loan portfolios
Capital market growth producing a “Winner’s Curse” effect i.e. winner
ending up with overpayment or getting less value for the spent.
Competitive margins despite decline in avg. quality of loans
Declining and volatile values of Collateral
Growth of Off-balance sheet derivatives and Securitization products
Changing Regulatory Environments
RBI endorsement of Risk based Capital Requirements
as per BIS regulations
Risk Based Supervision
Dinesh Mahabal
18. Importance of Credit Risk Management
Improves Bank Competitiveness and
Performance
Shareholder Value Creation / Increase (
RAROC & Economic Capital concepts) Value
Creation : transaction management & active portfolio
management
Value Preservation : portfolio management
Capital Optimization
Thus, Improve Risk Adjusted Returns for all
stakeholders
Regulatory Compliance (Basel II / III)
Dinesh Mahabal 18
19. 19
Why should Banks be concerned with
Credit Risk?
Skewed nature of loan returns
Loan returns are highly asymmetric since there is limited
upside
If borrower’s credit quality improves - no benefit to
lending bank since the borrower can refinance his loan at a
lower rate
If borrower’s credit quality declines - bank is not
compensated for taking the additional risk since loan price
is not revised
If borrower defaults - accrued interest is reversed and
any new payments are towards principal
If borrower becomes NPA - minimal recovery
Dinesh Mahabal
20. Why Credit Risk Management?
Recent Complexities Emergence : Seven Reasons to
follow best Credit Risk Management Practices as a
consequence of LPG (Liberalization, Privatization &
Globalization) phenomenon
1. Globalization:- Leading to opening up of the
economy to the outside world, thus becoming
vulnerable to economic problems in the countries
across the world.
2. Deregulation:-Business area expansion. Banks
20
introduced new products/ services
Dinesh Mahabal
21. 21
Why Credit Risk Management?
3. Severe Competition: pressure on
margins, competitive pricing is the
need.
4. Sophistication of existing products
and additions of new complex
products.
5. Advances in Technology: increase in
volume and speed.
Dinesh Mahabal
22. 22
Why Credit Risk Management?
6. Regulatory Developments:- New Laws,
Rules and Regulations, Capital
Adequacy Norms, Basel –II Guidelines
7. Business Transformation:-
Organizational changes, new activities,
expansion in operations.
Dinesh Mahabal
23. The Task for Credit Risk Department
Segmentation of the credit portfolio (in terms of risk
but not size)
Model Requirements (for risk assessments)
Data requirements
Credit risk reporting requirements for regulatory /
control and decision-making purposes at various levels
Policy requirements for credit risk (credit process &
practices, monitoring & portfolio management etc.)
Align Risk Strategy & Business Strategy
Dinesh Mahabal 23
24. The Task for Credit Risk Department
Take informed credit decisions;
Set provisioning and reserve requirements;
Establish minimum pricing levels at which credit exposures to an
obligor may be undertaken / extended (Base Rate)
Price credit risky instruments and facilities (Credit Spread);
Measure the regulatory capital charge –Standardized and IRB
Approaches;
Measure the economic capital;
Calculate risk adjusted performance measures such as RAROC
(adopt it as a common language).
Dinesh Mahabal 24
25. Risk Management Process
It is imperative that banks have a robust credit risk
management system which is sensitive and responsive
to the factors present in banking transactions.
The effective management of credit risk is a critical
component of comprehensive risk management and is
essential for the long term success of any banking
organisation.
Credit risk management encompasses identification,
measurement, monitoring and control of the credit
risk exposures
Dinesh Mahabal 25
26. Risk Management Process
• Identify the Risks: Name and Define
• Measure the Risks: Size, Timing, Probability
• Monitor the Risks: Identify significant changes in
risk profile or controls
• Manage / Control the Risks: Avoiding, Mitigating,
Off-setting, diversifying
• Again Go to Step 1
Dinesh Mahabal 26
27. 27
Risk Management Process
Identify
Monitor
Measure
Control RISK
Dinesh Mahabal
28. Credit Approval & Risk Management Process
The whole Process can be divided in to Four
Parts:
Risk Analysis (Identification)
Risk Control
Risk Management
- Front Office
- Back office
- Credit Audit
- Inspection & Audit
Dinesh Mahabal 28
29. Risk Analysis
Segmentation of Borrower (Retail, Corporate-
Centralized/ Unit Level Processing)
Source of Cash Flow (Object Finance, Project
Finance)
Credit Appraisal (Pre Sanction Inspection,
Validation of Data/ Documents, Carry out
Rating (Industry, Business, Financial,
Management), Adherence to Financial
Benchmark, Collateral Valuation and Risk
Assessment)
Dinesh Mahabal 29
30. Risk Analysis
Credit Approval Committee (Based on
Amount and Rating- Multi Tier
Approval)
Sanction (Amount and Rating- Multi
Tier Sanction , Pricing based on Risk
Rating)
Post Sanction Review by Next Higher
Authority
Dinesh Mahabal 30
31. Risk Control
Single/ Group Borrower Exposure
Substantial Exposure
Exposure to Term Loan ( 3 years and
above Residual Maturity)
Industry/ Sector Exposure Limit
Sensitive Sector Limit (Capital Market,
Real Estate, NBFC/Leasing & Hire
Purchase)
Dinesh Mahabal 31
33. Risk Control
Rating wise Probability of Default
Off balance sheet Exposure
Country Wise Exposure
Higher level prior approval for additional
exposure in sensitive sectors
Each Approval Committee has to have
cap on account/amount per sitting.
Dinesh Mahabal 33
34. Risk Management
Front Office:
KYC Norms, Defaulters List
Approval acceptance of offer letter
Documentation and its validation
Post Sanction Inspection
Approval for Disbursement
End use of Funds
Insurance
Dinesh Mahabal 34
35. Risk Management
Periodical inspection (unit and collateral ),
Stock and Book Debt Inspection by External
Auditors
Transaction Monitoring (End use, DP limit,
cash transaction, sales transaction)
Identifying potential weak accounts by early
warning signals ( excess drawing, delayed
payment of obligations, adverse signals in
particular industry, return of cheques,
inadequate transaction)
Monthly monitoring – multi tier
Annual Review (Rating and Exposure wise)
MIS maintenance
Dinesh Mahabal 35
36. Risk Management
Back Office
Generating/Updating Industry reports/scores (annually,
half yearly)
Preparing trigger reports
Independent rating validation
Migration of rating and PD estimation (Measurement of
risk)
Portfolio reviews
Risk Control Monitoring
Quality Assurance (Policy Reviews, Appraisal
Methodology)
Training and Upgradation of Skills of Employees
Dinesh Mahabal 36
37. Risk Management
Credit Audit
Recommend corrective action to improve credit
quality
Done within 6 months of sanction
Inspection & Audit
External
Concurrent Audit at Unit level at select branches
Concurrent Audit for specific accounts
Internal
Risk Based Internal Audit
Inspection by controlling office at non-concurrent
audit units.
Dinesh Mahabal 37
38. OBJECIVES OF RISK MANAGEMENT SYSTEM
The three long term objectives :
1. To make use of CREDIT RATING as the
tool for Credit Risk Management (e.g.
decision making,pricing, Asset Quality).
2. Arriving at a single number VALUE at
RISK figure for the bank and allocation of
capital to the business units to arrive at
RAROC and judge the performance of
business units based on RAROC.
3. Risk Management should not be treated
merely a compliance function but be used
as a business opDinpesho Mahrabtalunity. 38
39. Risk Management Best Practices
Integrated
Best Risk
Management
Practices
Best
Practices
Infrastructure
Best
Practices
Policies
Best
Practices
Methodologies
Dinesh Mahabal 39
40. Integrated Best Risk Management
Practices
Limit Management (Monitor, Identify and
Avoid)
Risk Analysis (Stress Testing, Scenario
Analysis, Market VaR, Credit VaR)
RAROC ( Pricing, Capital Allocation)
Active Portfolio Management
Dinesh Mahabal 40
42. Identification of Risk
Identification of various risk elements
in the given process and define the
same
Dinesh Mahabal 42
43. 43
Measurement & Monitoring of Credit Risk
Every obligor and facility must be assigned a risk
rating.
Mechanism to price facilities depending on risk
grading.
Banks should ensure consistent standards for loan
origination documentation etc.
Banks should have a consistent approach towards
early problem recognition, classification of problem
exposures and remedial action.
Dinesh Mahabal
44. 44
Measurement & Monitoring of Credit Risk
Banks should maintain a diversified portfolio of risk
assets
Banks should set Credit Risk limits like borrower limit
industry limits etc.
Banks to report comprehensive set of credit risk data
into independent risk system.
Systems to be put in place for monitoring financial
performance of customers and for controlling
outstanding within limits.
Dinesh Mahabal
45. 45
Measurement & Monitoring of Credit Risk
Conservative provisioning policy for NPA
advances.
Thus the following procedure is to be
followed towards managing the risk involved
in credit:-
Carefully formulated scheme of lending powers.
Setting-up Prudential Limits
Measurement of risk through credit rating
Dinesh Mahabal
46. Building Blocks of Credit Risk Management
An effective credit risk management
framework comprises of the following
distinct building blocks:
a) Policy and Strategy
b) Organisational Structure
c) Operations/ Systems
Dinesh Mahabal 46
47. Building Blocks of Credit Risk Management
Policy and Strategy
The Board of Directors/ Highest level
committee of each bank/ organisation
should be responsible for approving and
periodically reviewing the credit risk
strategy and significant credit risk
policies
Dinesh Mahabal 47
48. Building Blocks of Credit Risk Management
Credit Risk Policy
Every bank should have a credit risk policy document
approved by the Board. The document should include
risk identification, risk measurement, risk grading/
aggregation techniques, reporting and risk control/
mitigation techniques, documentation, legal issues and
management of problem loans.
Credit risk policies should also define target markets,
risk acceptance criteria, credit approval authority,
credit origination/ maintenance procedures and
guidelines for portfolio management.
Dinesh Mahabal 48
49. Building Blocks of Credit Risk Management
Credit Risk Policy
The credit risk policies approved by the Board should
be communicated to branches/controlling offices. All
dealing officials should clearly understand the bank’s
approach for credit sanction and should be held
accountable for complying with established policies
and procedures.
Senior management of a bank shall be responsible for
implementing the credit risk policy approved by the
Board.
Dinesh Mahabal 49
50. Building Blocks of Credit Risk Management
Credit Risk Strategy
Each bank should develop, with the approval of its Board, its own
credit risk strategy or plan that establishes the objectives
guiding the bank’s credit-granting activities and adopt necessary
policies/ procedures for conducting such activities. This
strategy should spell out clearly the organisation’s credit
appetite and the acceptable level of risk-reward trade-off for
its activities.
The strategy would, therefore, include a statement of the
bank’s willingness to grant loans based on the type of economic
activity, geographical location, currency, market, maturity and
anticipated profitability. This would necessarily translate into
the identification of target markets and business sectors,
preferred levels of diversification and concentration, the cost
of capital in granting credit and the cost of bad debts
Dinesh Mahabal 50
51. Building Blocks of Credit Risk Management
Credit Risk Strategy
The credit risk strategy should provide continuity in
approach as also take into account the cyclical
aspects of the economy and the resulting shifts in
the composition/ quality of the overall credit
portfolio. This strategy should be viable in the long
run and through various credit cycles.
Senior management of a bank shall be responsible for
implementing the credit risk strategy approved by
the Board
Dinesh Mahabal 51
52. Building Blocks of Credit Risk Management
Organisational Structure
Sound organizational structure is sine qua non
for successful implementation of an effective
credit risk management system.
The organizational structure for credit risk
management should have the basic feature of
Independence and arm’s length dealings within
the organisation.
Dinesh Mahabal 52
53. Building Blocks of Credit Risk Management
Operations / Systems
Banks should have in place an appropriate credit administration,
credit risk measurement and monitoring processes. The credit
administration process typically involves the following phases:
Relationship management phase i.e. business development
Transaction management phase covers risk assessment, loan
pricing, structuring the facilities, internal approvals,
documentation, loan administration, on going monitoring and risk
measurement.
Portfolio management phase entails monitoring of the
portfolio at a macro level and the management of problem
loans.
Dinesh Mahabal 53
54. Lessons Learned
Risk Appetite says
“Take risks: if you win, you will be happy;
if you lose, you will be wise”
Dinesh Mahabal 54