Basel III
Overview…
 What is the Basel III framework relating to....


 Definitions of the three pillars and relationship among the
  three

 Significant methods of measurement of each one of them


 Challenges in implementation of these norms


 Indian scenario
What is "Basel III"
    A global regulatory standard on
     bank capital adequacy
     stress testing and
     market liquidity risk


    With a set of reform measures to
      improve
     Regulation
     supervision and
     risk management
Reasons for formulation of Basel
               III
          (failure of basel II)
 Reducing profitability of small banks and threat of
 takeover

 Lack of comprehensive approach to address risks


 Self-regulation in area of asset securitization


 Lack of safety


 Inability to strengthen the stability of financial
 system

 Failure to achieve large capital reductions
Aim
 To minimize the probability of recurrence of crises
 to greater extent

 To improve the banking sector's ability to absorb
 shocks arising from financial and economic
 stress.

 To improve risk management and governance


 To   strengthen     banks'    transparency     and
 disclosures.
Target
 Bank-level, or micro prudential, regulation, which
 will help raise the resilience of individual banking
 institutions to periods of stress.

 Macro prudential, system wide risks that can build
 up across the banking sector as well as the
 procyclical amplification of these risks over time.
Micro- prudential elements
To minimize the risk contained with individual
  institutions
The elements are:
 Definition of capital
 Enhancing risk coverage of capital
 leverage ratio
 International liquidity framework
Macro- prudential elements
 To take care of the issues relating to the systemic
  risk
The elements are:
 Leverage ratio
 Capital conservation buffer
 Countercyclical capital buffer
 Addressing the procyclicality of provisioning
  requirements
Cont’d
 Addressing interconnectedness
 Addressing the too- big to- fail problems
 Addressing reliance on external credit rating
 agencies.
Definition of the three pillars
Pillar 1- Minimum Capital
   Requirements
• calculate required capital
• Required capital based on
 Market risk
 Credit risk
 Operational risk
• Used to monitor funding concentration
Pillar 2- Supervisory Review
 Process
 Bank should have strong internal process
 Adequacy of capital based on risk evaluation
Pillar 3 – Enhanced Disclosure
 Provide market discipline
 Intends to provide information about banks
 exposure to risk
The relationship among the three
 Second pillar – supervisory review process to
  ensure the first pillar
        - intended to ensure that the banks have
  adequate capital
 Third pillar – compliments first and second pillar
        - a discipline followed by the bank such as
  disclosing capital structure, tier-i and tier-ii capital
  and approaches to assess the capital adequacy
  i.e. assessment of the first pillar.
 Model of commercial banks interpret first pillar as
  a closure threshold rather than bank’s asset
  allocation
Significant Methods of
    Measurement
The pillar is divided in three types of risk for which
  capital should be held.
 Credit Risk
 Operational risk
 Market risk
Credit Risk…
 Credit risk is the risk that those who owe you
  money will not pay you back.
 Historically credit risk is the larger risk banks run.


BIS II proposes three approaches by which a bank
  may calculate its required capital for credit risk.
 Standardized approach
 Internal rating based (IRB) advanced
 Internal rating based (IRB) foundation
Operational Risk…
 Operational risk is defined as the risk of loss
 resulting from inadequate or failed internal
 processes, people and systems or from external
 events.

Comparable to credit risk, BIS II proposes three
  methods for measuring operational risk.
 Basic indicator approach
 Standardized approach
 Advanced measurement approach (AMA)
Market Risk…
 Market risk is the risk of losses due to changes in
  the market price of an asset.
 Market risk will only have to be calculated for
  assets in the trading book.
 Foreign exchange rate risk and commodities risk
  are part of the market risk.
Two methods may be used:
 Standardized measurement method
 Internal models approach
Challenges in implementation of
        basel 3 norms
• The new and stricter regulations of the basel3
like higher capital requirements, the new liquidity
standard, the increased risk coverage, the new
leverage ratio or a combination of the different
requirements will be difficult to adopt by the banks

• Banks have to take a number of actions to meet
the various new regulatory ratios, restoring of data
,

• Banks must be able to calculate and report the
new   ratios.    Which     requires    the    huge
implementation effort.
Challenges of basel3
implementation:
Banks usually have 3 types of challenges

1. Functional challenges

2. Technical challenges

3. Organizational challenges
Functional challenges
•Developing specifications for the new regulatory
requirements, such as the mapping of positions (assets
and liabilities) to the new liquidity and funding
categories in the LCR and NSFR calculations.

•the specification of the new requirements for trading
book positions and within the CCR framework (e.g.
CVA) as well as adjustments of the limit systems with
regard to the new capital and liquidity ratios.

•Crucial is the integration of new regulatory
requirements into existing capital and risk management
as some measures to improve new ratios (e.g. liquidity
ratios) might have a negative effect on existing figures.
Technical challenges
•The technical challenges includes the availability of
data, data completeness, and data quality and data
consistency to calculate the new ratios.

• The financial reporting system with regard to the new
ratios and the creation of effective interfaces with the
existing risk management systems.
Operational challenges
 • The operational challenges includes stricter capital
 definition lowers banks’ available capital.   At the same
 time the risk weighted assets                 (RWA) for
 securitizations, trading book positions       and certain
 counterparty credit risk exposures are         significantly
 increased.

 • The stricter capital requirements, the introduction of
 the LCR and NSFR will force banks to rethink their
 liquidity position, and potentially require banks to
 increase their stock of high-quality liquid assets and to
 use more stable sources of funding.
•Basel III also introduces a non-risk based
leverage ratio of 3 percent. Group1 banks are
failed in maintaining the this leverage ratio

•The banks will experience increased pressure on
their Return on Equity (RoE) due to increased
capital and liquidity costs, which along with
increased RWAs will put pressure on margins
across all segments
Indian Scenario
Capital…
 Indian banks need to raise Rs 1.5 lakh crore to
  Rs 1.75 lakh crore as capital to meet the BASEL-
  III requirements.
 Can PSU banks mobilize this sort of capital?
        - Probably NO, The alternate to the
  government is either to reduce shareholding
  below 50% or slowdown PSU growth
 Can private banks raise this sort of money?
        - They probably can, because Rs 500 billion
  was raised in last 5 years
Problems for PSUs
 Capital adequacy ratio
       - has been stipulated at 9%, unchanged from
  what     the   regulator    requires   in    India
  currently, banks here will need to raise more
  money than under the current Basel II norms
  because several capital instruments cannot be
  included under the new definition.
Ex: Perpetual Bond
 Maintaining an 8% tier I capital ratio
 More additions to non-performing assets
 Unamortized expenditure on pension liabilities
The Indian economy is also expected to grow at
an annual growth rate of 8-9% for next 10 years
or so. This would undoubtedly necessitate a
considerable growth in bank capital.
Issues relating to SLR and LCR
….
   India, banks are statutorily required to hold
    minimum reserves of high-quality liquid assets at
    24% of net demand and time liabilities.
   The proportion of liquid assets in total assets of
    banks will increase substantially, if the SLR
    reserves are not reckoned towards the LCR
    (Liquidity coverage ratio) and banks are to meet
    the     entire    LCR    with   additional   liquid
    assets,      thereby   lowering     their  income
    significantly.
   RBI is examining to what extent the SLR
    requirements could be reckoned towards the
    liquidity requirement under Basel III.
Profitability ….
   Retail      banks will be affected least, though
      institutions with very low capital ratios may find
      themselves under significant pressure.
     Corporate banks will be affected primarily in
      specialized lending and trade finance.
     Investment banks will find several core
      businesses profoundly affected, particularly
      trading and securitization businesses.
     Balance sheet restructuring and business-model
      adjustments could potentially mitigate up to 40
      percent of Basel III’s RoE impact, on an average.
     Government banks may have to sacrifice growth
Cont’d…
  The    impact of credit requirements on the
   profitability of banks would depend upon sensitivity
   of lending rates to capital structure of banks and
   sensitivity of the credit growth to the lending rates.
  When banks with low core Tier I shore up their
   capital to around 9% required, their return on
   equity (RoE) could drop by 1-4%.
  Basel III will force banks to plough back a larger
   chunk of their profit into the balance sheet.
  Banks might have to rationalize dividend policies
   so that more profit could be retained and used as
   capital, indicating a lower dividend for the
   government.
Benefits of Implementation…
  Demonstrate   that the banking system is
  recovering well from the global financial crisis of
  2008 and has been developing the resilience to
  future shocks.

  Contribute  to a bank’s competitiveness by
  delivering better management insight into the
  business, allowing it to take advantage of future
  opportunities.

  Strengthen   the financial system of both
  developing and developed countries by
  addressing the weaknesses in the measurement
  of risk under Basel II framework revealed during
Cont’d…

  Delivers a much safer financial system with
   reduced probability of banking crises at affordable
   costs. The impact of costs is minimized through
   long phase-in.
  It is expected that as the proportion of equity in
   the capital structure of banks rises, it would
   reduce the incremental costs of raising further
   equity as well as non-common equity capital.
The Reserve Bank’s approach has been to
adopt Basel III capital and liquidity guidelines
with more conservatism and at a quicker
pace. The impact of these rules is not going to
be onerous and there will be considerable
advantage in adopting Basel III by our banks.

Basel iii Norms

  • 1.
  • 2.
    Overview…  What isthe Basel III framework relating to....  Definitions of the three pillars and relationship among the three  Significant methods of measurement of each one of them  Challenges in implementation of these norms  Indian scenario
  • 3.
    What is "BaselIII" A global regulatory standard on  bank capital adequacy  stress testing and  market liquidity risk With a set of reform measures to improve  Regulation  supervision and  risk management
  • 4.
    Reasons for formulationof Basel III (failure of basel II)
  • 5.
     Reducing profitabilityof small banks and threat of takeover  Lack of comprehensive approach to address risks  Self-regulation in area of asset securitization  Lack of safety  Inability to strengthen the stability of financial system  Failure to achieve large capital reductions
  • 6.
    Aim  To minimizethe probability of recurrence of crises to greater extent  To improve the banking sector's ability to absorb shocks arising from financial and economic stress.  To improve risk management and governance  To strengthen banks' transparency and disclosures.
  • 7.
    Target  Bank-level, ormicro prudential, regulation, which will help raise the resilience of individual banking institutions to periods of stress.  Macro prudential, system wide risks that can build up across the banking sector as well as the procyclical amplification of these risks over time.
  • 9.
    Micro- prudential elements Tominimize the risk contained with individual institutions The elements are:  Definition of capital  Enhancing risk coverage of capital  leverage ratio  International liquidity framework
  • 10.
    Macro- prudential elements To take care of the issues relating to the systemic risk The elements are:  Leverage ratio  Capital conservation buffer  Countercyclical capital buffer  Addressing the procyclicality of provisioning requirements
  • 11.
    Cont’d  Addressing interconnectedness Addressing the too- big to- fail problems  Addressing reliance on external credit rating agencies.
  • 12.
    Definition of thethree pillars
  • 13.
    Pillar 1- MinimumCapital Requirements • calculate required capital • Required capital based on  Market risk  Credit risk  Operational risk • Used to monitor funding concentration
  • 14.
    Pillar 2- SupervisoryReview Process  Bank should have strong internal process  Adequacy of capital based on risk evaluation
  • 15.
    Pillar 3 –Enhanced Disclosure  Provide market discipline  Intends to provide information about banks exposure to risk
  • 17.
    The relationship amongthe three  Second pillar – supervisory review process to ensure the first pillar - intended to ensure that the banks have adequate capital  Third pillar – compliments first and second pillar - a discipline followed by the bank such as disclosing capital structure, tier-i and tier-ii capital and approaches to assess the capital adequacy i.e. assessment of the first pillar.  Model of commercial banks interpret first pillar as a closure threshold rather than bank’s asset allocation
  • 18.
  • 19.
    The pillar isdivided in three types of risk for which capital should be held.  Credit Risk  Operational risk  Market risk
  • 20.
    Credit Risk…  Creditrisk is the risk that those who owe you money will not pay you back.  Historically credit risk is the larger risk banks run. BIS II proposes three approaches by which a bank may calculate its required capital for credit risk.  Standardized approach  Internal rating based (IRB) advanced  Internal rating based (IRB) foundation
  • 21.
    Operational Risk…  Operationalrisk is defined as the risk of loss resulting from inadequate or failed internal processes, people and systems or from external events. Comparable to credit risk, BIS II proposes three methods for measuring operational risk.  Basic indicator approach  Standardized approach  Advanced measurement approach (AMA)
  • 22.
    Market Risk…  Marketrisk is the risk of losses due to changes in the market price of an asset.  Market risk will only have to be calculated for assets in the trading book.  Foreign exchange rate risk and commodities risk are part of the market risk. Two methods may be used:  Standardized measurement method  Internal models approach
  • 23.
  • 24.
    • The newand stricter regulations of the basel3 like higher capital requirements, the new liquidity standard, the increased risk coverage, the new leverage ratio or a combination of the different requirements will be difficult to adopt by the banks • Banks have to take a number of actions to meet the various new regulatory ratios, restoring of data , • Banks must be able to calculate and report the new ratios. Which requires the huge implementation effort.
  • 25.
    Challenges of basel3 implementation: Banksusually have 3 types of challenges 1. Functional challenges 2. Technical challenges 3. Organizational challenges
  • 26.
    Functional challenges •Developing specificationsfor the new regulatory requirements, such as the mapping of positions (assets and liabilities) to the new liquidity and funding categories in the LCR and NSFR calculations. •the specification of the new requirements for trading book positions and within the CCR framework (e.g. CVA) as well as adjustments of the limit systems with regard to the new capital and liquidity ratios. •Crucial is the integration of new regulatory requirements into existing capital and risk management as some measures to improve new ratios (e.g. liquidity ratios) might have a negative effect on existing figures.
  • 27.
    Technical challenges •The technicalchallenges includes the availability of data, data completeness, and data quality and data consistency to calculate the new ratios. • The financial reporting system with regard to the new ratios and the creation of effective interfaces with the existing risk management systems.
  • 28.
    Operational challenges •The operational challenges includes stricter capital definition lowers banks’ available capital. At the same time the risk weighted assets (RWA) for securitizations, trading book positions and certain counterparty credit risk exposures are significantly increased. • The stricter capital requirements, the introduction of the LCR and NSFR will force banks to rethink their liquidity position, and potentially require banks to increase their stock of high-quality liquid assets and to use more stable sources of funding.
  • 29.
    •Basel III alsointroduces a non-risk based leverage ratio of 3 percent. Group1 banks are failed in maintaining the this leverage ratio •The banks will experience increased pressure on their Return on Equity (RoE) due to increased capital and liquidity costs, which along with increased RWAs will put pressure on margins across all segments
  • 30.
  • 31.
    Capital…  Indian banksneed to raise Rs 1.5 lakh crore to Rs 1.75 lakh crore as capital to meet the BASEL- III requirements.  Can PSU banks mobilize this sort of capital? - Probably NO, The alternate to the government is either to reduce shareholding below 50% or slowdown PSU growth  Can private banks raise this sort of money? - They probably can, because Rs 500 billion was raised in last 5 years
  • 32.
    Problems for PSUs Capital adequacy ratio - has been stipulated at 9%, unchanged from what the regulator requires in India currently, banks here will need to raise more money than under the current Basel II norms because several capital instruments cannot be included under the new definition. Ex: Perpetual Bond  Maintaining an 8% tier I capital ratio  More additions to non-performing assets  Unamortized expenditure on pension liabilities
  • 33.
    The Indian economyis also expected to grow at an annual growth rate of 8-9% for next 10 years or so. This would undoubtedly necessitate a considerable growth in bank capital.
  • 34.
    Issues relating toSLR and LCR ….  India, banks are statutorily required to hold minimum reserves of high-quality liquid assets at 24% of net demand and time liabilities.  The proportion of liquid assets in total assets of banks will increase substantially, if the SLR reserves are not reckoned towards the LCR (Liquidity coverage ratio) and banks are to meet the entire LCR with additional liquid assets, thereby lowering their income significantly.  RBI is examining to what extent the SLR requirements could be reckoned towards the liquidity requirement under Basel III.
  • 35.
    Profitability ….  Retail banks will be affected least, though institutions with very low capital ratios may find themselves under significant pressure.  Corporate banks will be affected primarily in specialized lending and trade finance.  Investment banks will find several core businesses profoundly affected, particularly trading and securitization businesses.  Balance sheet restructuring and business-model adjustments could potentially mitigate up to 40 percent of Basel III’s RoE impact, on an average.  Government banks may have to sacrifice growth
  • 36.
    Cont’d…  The impact of credit requirements on the profitability of banks would depend upon sensitivity of lending rates to capital structure of banks and sensitivity of the credit growth to the lending rates.  When banks with low core Tier I shore up their capital to around 9% required, their return on equity (RoE) could drop by 1-4%.  Basel III will force banks to plough back a larger chunk of their profit into the balance sheet.  Banks might have to rationalize dividend policies so that more profit could be retained and used as capital, indicating a lower dividend for the government.
  • 37.
    Benefits of Implementation…  Demonstrate that the banking system is recovering well from the global financial crisis of 2008 and has been developing the resilience to future shocks.  Contribute to a bank’s competitiveness by delivering better management insight into the business, allowing it to take advantage of future opportunities.  Strengthen the financial system of both developing and developed countries by addressing the weaknesses in the measurement of risk under Basel II framework revealed during
  • 38.
    Cont’d…  Deliversa much safer financial system with reduced probability of banking crises at affordable costs. The impact of costs is minimized through long phase-in.  It is expected that as the proportion of equity in the capital structure of banks rises, it would reduce the incremental costs of raising further equity as well as non-common equity capital.
  • 39.
    The Reserve Bank’sapproach has been to adopt Basel III capital and liquidity guidelines with more conservatism and at a quicker pace. The impact of these rules is not going to be onerous and there will be considerable advantage in adopting Basel III by our banks.