This document discusses credit concentrations and the importance of identifying, monitoring, measuring, and controlling related risks. It provides examples of how loans can be grouped into pools based on similar risk characteristics and aggregated if certain conditions are met. The document also outlines house and portfolio limits established by the bank's board to control concentration risk and discusses the value of stress testing and robust management information systems in mitigating risk.

1. Concentrations of Credit
Analytical Overview

2. Introduction
• Credit extension is a primary source of revenue for Banks which risks earnings and
capital
• At the Heart is the “accurate identification of a borrower’s credit risk, the
assignment of a risk rating, and setting an adequate provision for loan loss”
• Illustration of FSG Bank risk rating scale mapped to that of rating agencies S&P
and Moody’s:
FSG AQR S&P Moody’s OCC/FDIC/FED
10 AAA Aaa
Pass
20 AA+
AA
AA-
A+
A
A-
Aa1
Aa2
Aa3
A1
A2
A3
30 BBB+ Baa1
60 CCC+ Caa1 Junk

3. Introduction_Cont’d
• However, Credit assessment also encompasses the management of
concentrations/pools of exposure, whose collective performance could
affect a Bank negatively.
• When therefore exposures in a pool are sensitive to the same economic,
financial, or business development, that sensitivity, once triggered could
cause all transactions to perform as though a single large exposure
• The Roles of the Bank with respect to Credit Concentrations then becomes
to:
a) Identify
b) Monitor
c) Measure
d) Control this risk related to Concentrations

4. What is key/Historic overview
• Understanding how the different exposures would work under stressed economic
situations is very key.
• In most instances in times past, concentrated exposures were booked during periods
of rapid economic expansion that were fueled partly by Bank Credit, frequently
including a weakening of underwriting Standards
• Below is a brief discussion of the 2009 Global Financial Crisis: a situation that
many believe would have been mitigated (in part) by Bank’s closely monitoring
various Credit profiles especially with respect to Real Estate Lending

5. 2009 Global Financial Crisis
• “Caused by Wide Spread failures in financial regulation and supervision…”
• The “Housing Bubble”_ Real Estate Markets typically involve longer boom
and bust periods. They are typically seen as an example of Speculative or
Credit Bubbles.
• Commercial Banks play a substantial role in Real Estate lending by advancing
Mortgages. These typically are easier to foreclose on owing to the availability
of tangible Collateral. However, in the event of a Crush like that of ‘09,
financial Institutions suffer a severe hit.
• The ‘09 Crisis, however, was controlled in large part by different Central Banks
advancing stimulus packages. This is a notion that aligns itself largely to the
Keynesian Economic school of thought that is briefly discussed below.

6. Keynesian theory: AD=C+G+I+(X-M)

7. What then?
• In order to avoid situations like these, governing bodies like the OCC have
expectations that Bank Boards implement Board approved policies appropriate to
the size and complexity of their portfolios coupled with risk management, loan
review, and audit oversight.
• This typically involves a long process, and a constant updating of various loan
portfolios in a bid to mitigate risk outcomes.
• In order to asses Credit risk therefore, assets can typically be categorized into
different pools in accordance with similar performance traits.

8. Examples of Pool classifications
Historically, the OCC has categorized pools of transactions that may perform similarly
(i.e., whose performance is positively correlated) as those that include credit exposures
that are:
• dependent on the same source of repayment (including guarantors).
• extended to independent borrowers who sell the same manufacturer’s product.
• extended to an industry or to economic sectors.
• purchased from a single-source.
• secured by a common debt or equity instrument.
• extended to other financial institutions including but not limited to due from
accounts, federal funds sold, investments, net current exposure of derivatives
contracts, and direct or indirect loans.
• originated within a geographic area that might also be dominated by one or a few
business enterprises.
• owed by a foreign government or related entities.

9. Illustration _ finding similarities
• Assuming you had the following exposures grouped into different pools. Even upon grouping them, it
would be very likely that you would have similarities arise within the pools. This could call for an even
further assessment/grouping as shown below:
• NB: Our exposures are 1, 2, 3, 4, 5, 6, 7, 8, 9
Pool A
Includes exposures 2,5,8
Pool B
Includes exposures 4,3
Pool C
Includes exposures 6,9
Pool D
Includes exposures 1,7
Pool E
Could Include exposures
in Pools C and D if
similarities established

10. Plug In: Aggregating Credit
• In the event that a common enterprise exists, loans from different borrowers can
typically be aggregated. This principle is fairly similar to the above discussed issue
of pool classifications (asset groupings). However, this is dependent on various
prior stipulated conditions. For FSG Bank, these include:
a) The “expected source of repayment” for two or more loans is the same
b) Funds are borrowed for the purpose of acquiring ≥ 50% of voting securities in an
acquisition to a related borrower
c) The borrowers are related through common control and are financially
interdependent or engaged in interdependent businesses

11. “Common Control”
This is presumed to exist when:
• One or more persons acting in concert directly or indirectly have the power to vote
20% of any class of voting securities, or
• One or more persons acting in concert control in any manner, the election of a
majority of the directors, trustees, or persons exercising similar functions, or
• Any other circumstances exist which indicate that one or more persons acting in
concert exercise a controlling influence over management or policies of the entity
(for example, a general partner).

12. “Financial Interdependence”
Financial Interdependence is said to exist when:
• Fifty percent or more of one borrower’s annual gross receipts or gross expenditures
are derived from or paid to one or more related persons through common control.
Gross receipts and expenditures are defined to include loans, dividends, capital
contributions and similar receipts or payments.

13. Other considerations
Loans are also to be aggregated under the circumstances described below even though
there is no common enterprise:
• Loans are always to be combined when loans to a second borrower are made for
the “tangible economic benefit” of a first borrower, whether or not a legal exposure
is provided in the loan documents.
• Loans to partnerships, joint ventures, and associations are always to be combined
with loans to members, except for limited partners or members whose partnership
or membership agreements provide that they are not to be held liable for the debt or
actions of the partnership, joint venture, or association.
• Loans are to be combined when funds are borrowed for the purpose of acquiring
any interest in a partnership, joint venture, or association, without regard to the
percentage interest to be owned after the acquisition.

14. House and Portfolio limits
Concentrations or aggregations of risk significantly increase the potential for volatility
in portfolio credit quality and earnings. In that respect, the Bank’s Board has
established the following limits:
House Limits AQR Limits
Exceptions to
House Limits
require approval at
the next highest
required level
(not to exceed
CLC)
10,20 $7.5MM
30 $6.0MM
40 $4.0MM
50 $2.0MM
60 $1.0MM
Aggregation of 10 largest borrowers: 100% of Tier 1 Capital

15. Limits _ cont’d
Aggregate relationships representing exceptions to the
House Limits above shall not exceed:
100% of Tier 1 Capital
Relationships with multiple entities having different AQR’s shall be subject to general
interpolation to determine the appropriate House Limit based on weighted AQR.
Industry, property type: 50-75% of Tier 1 Capital

16. Excluded from House Limits
• Obligations of, or obligations guaranteed by, the GOOD FAITH and CREDIT of the
United States of America, or any public body or municipal entity or any political
subdivision with taxing powers and representing general obligations rated “A” or
better thereof;
• Obligations which the Bank would be authorized to acquire without limit as
investment securities;
• Guarantees or commitments or agreements to take over or purchase made by any
department, bureau, board, commission or establishment of the United States of
America or any corporation owned directly or indirectly by the United States of
America; or
• Any obligation fully secured by either:
 Pledged cash on deposit with FSG, or
 Readily marketable securities within the possession or control of FSG and subject
to prudent margin maintenance requirements

17. The Value of Stress Testing

18. A Brief Discussion
• Stress Test can be defined as an “analysis conducted under unfavorable economic
scenarios which is designed to determine whether a Bank has enough Capital to
withstand the Impact of Adverse Developments.”_ Investopedia
• Key Issues focused on can include:
a) Credit Risk: The risk of loss of principal or loss of a financial reward stemming
from a borrower's failure to repay a loan or otherwise meet a contractual obligation
b) Market Risk: The possibility for an investor to experience losses due to factors that
affect the overall performance of the financial markets, and
c) Liquidity risk: The risk stemming from the lack of marketability of an investment
that cannot be bought or sold quickly enough to prevent or minimize a loss

19. Conclusion: MIS is valuable
• With respect to Mitigation of risk therefore, it is imperative that financial
institutions have Management Information Systems that they can greatly monitor in
a bid to safe guard themselves while providing quality services.
• Data quality is vital BUT so is the scope of data elements that are captured; these
should be proportional to the portfolio’s diversity and risk profile.

20. Sources cited:
• Comptroller’s Handbook Booklets
• OCC Issuances
• FSG Bank Loan Policy
• Investopedia
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