The presentation reviews the recent Jamaican context as a backdrop for the evolution of capital adequacy standards by the Bank of Jamaica, the regulator of deposit taking institutions (DTI) and financial holding companies of financial conglomerates which contain a DTI.
The Evolution of Capital Adequacy Standards in Jamaica
1. CAPITAL ADEQUACY STANDARDS
THE EVOLUTION AND WHEREWE ARE...
Jide Lewis PhD, CFA, FRM
DivisionChief, FinancialInstitutions
Supervisory Division
2. INTRODUCTION
Capital adequacy is the statutory minimum reserves of capital which a bank or other
financial institution must have available.
Capital adequacy standards require financial institutions to maintain a defined level of
risk capital relative to the riskiness of the activities it undertakes.
Capital adequacy requirements:
• provides a buffer against bank losses;
• protects creditors in the event of bank failures; and
• creates disincentives for excessive risk taking.
7. INTRODUCTION
Jamaica's current capital adequacy framework for deposit taking institutions (DTIs) is
applicable on an individual basis to deposit-taking institutions and, in certain aspects, is
more conservative than the Basel standards.
For example:
In defining regulatory capital – Jamaica's framework requires the exclusion of retained earnings,
although allowed under the Basel Accords.
Jamaica has also long had a leverage ratio, a ratio the Basel Committee introduced for the first time
under the Basel III capital standard.
8.
9. SHORTCOMINGS OF THE INDIVIDUAL APPROACH
Facilitation of regulatory arbitrage;
No consideration of contagion risk across a financial group;
No contemplation of the adequacy of capital vis-à-vis group-wide risks; and
No consideration for the different primary risks of insurance entities.
11. CONSOLIDATED CAPITAL ADEQUACY
Consolidated capital requirements seek to ensure that risk exposures of financial
conglomerates are backed by adequate high quality, loss absorbing capital.
This framework includes a:
i. Leverage or primary ratio requirement, and
ii. Risk-based capital adequacy measure.
The framework also introduces the:
i. Computation of group-wide market (interest rate) risk exposure of the trading book, and
ii. Treatment of the capital adequacy and risk positions of insurance entities.
13. SCOPE OF APPLICATION
Sectoral regulatory capital requirements will remain applicable;
Consolidated capital adequacy ratios shall be computed for each licensee
on the following basis:
a. DTI at the standalone (“solo”) level;
b. DTI operating as an intermediate holding company; and
c. FHC on a consolidated basis
16. TREATMENT OF INSURANCE ENTITIES
Capital adequacy for insurance entities are included in the FHC’s group-
wide assessment of risk exposures and capital adequacy determinations at
the FHC and DTI intermediate group levels.
Risk exposures and capital adequacy requirements will be:
i. Submitted by the FHC to the Bank as will be prescribed;
ii. Validated and authenticated by the FSC or equivalent functional regulators in overseas jurisdictions;
iii. Applicable at the insurance entity level (on a solo basis), on a sectoral basis and at the consolidated
level.
17. TREATMENT OF INSURANCE ENTITIES
Pursuant to section 75 (1)(a) of the BSA, the FHC is obligated to bear the full
ownership risk of the insurance entity or sector in its group and recognizing
these risks on a group-wide basis.
FHCs should ensure that insurance companies forming part of financial
groups are adequately capitalized.
Relevant regulators will determine which insurance specific components of
capital are transferrable by the insurance entity, if necessary.
19. DETERMINATION OF CONSOLIDATED CAPITAL POSITIONS
The basis of measuring the numerator and denominator components of the
consolidated capital ratios for FHCs and DTIs on a consolidated basis will be
the same as for standalone DTIs with two exceptions:
The introduction of interest rate market risk exposure, and
Capital components, total assets, assets subject to risk adjustments and all other
denominator components are derived from the consolidated statement of financial
position.
20. INTRODUCTION OF MARKET RISK EXPOSURE
Total Risk = Credit Risk + Market Risk
Market Risk = General Market Risk + Specific Risk
General Market Risk = Interest Rate Risk + Currency Risk+ Equity Price Risk
+ Commodity Price Risk
Specific Risk = Instruments Exposed to Interest Rate Risk and Equity Price
Risk
22. DETERMINATION OF CONSOLIDTED CAPITAL POSITIONS
Primary Ratio (6%)
Consolidated Capital Base
_________________________
Consolidated Total Assets
Table 1: The Formula for Primary Ratio Calculation
23. DETERMINATION OF CONSOLIDTED CAPITAL POSITIONS
Capital Adequacy Ratio (10%)
Consolidated Regulatory Capital
______________________________________________________
[Consolidated risk-weighted on-balance sheet assets +
Aggregate group-wide risk-weighted off-balance sheet assets +
Aggregate group-wide risk-weighted funds management balances +
Aggregate group-wide foreign exchange risk exposures +
Aggregate group-wide market risk exposure]
Table 2: The Formula for the Capital Adequacy Ratio
26. GROUP-WIDE CAPITAL ADEQUACY ASSESSMENT
1. Calculate the regulatory capital requirement for each consolidated entity or sector in
the group.
2. Calculate the regulatory capital requirement for consolidated unregulated entities in the
group.
3. Compare each group member’s (including the insurance entity’s or sector’s) sectoral
capital level to its sectoral regulatory capital requirement and identify the capital
surplus or deficit present.
4. Evaluate the availability of freely transferable capital across entities, sectors or
jurisdictions.
27. GROUP-WIDE CAPITAL ADEQUACY ASSESSMENT
5. Aggregate the regulatory capital requirements of each consolidated regulated entity and
the capital requirementsfor consolidated unregulated entities.
6. Compare the aggregate regulatory capital requirements to the FHC’s consolidated
regulatory capital level.
7. Determine group-wide (including insurance) capital surplus or deficit.
8. Consider the need for the FHC to source or fund additional capital or provide capital
support for members of the group.
29. THE NEXT STEPS
Looking to the future, the Standards must be responsive to continual
financial innovation and developments in risk management practices.
The Bank of Jamaica will continue to build on its earlier initiatives by
focusing attention on the adoption of supervisory policies and systems that
will enable an inclusive and realistic approach of effecting Basel’s II and III.
Full implementation of the Basel II and III frameworks is expected by end-
December 2019 and end-December 2020 respectively.