The Large Exposures Framework
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1 The Large Exposures Framework Marcel Bluhm Hong Kong Monetary Authority Risk.net Seminar Hong Kong, 6 December 2018
2 Overview Excessive large exposures to single/connected counterparties cause micro- and macroprudential risks: Johnson Matthey Bankers; Korean Financial Crisis. Large exposures regulation has been developed as a tool for limiting the maximum loss a bank could face in the event of a sudden counterparty failure to a level that does not endanger the bank s solvency. Marcel Bluhm (HKMA) Large Exposures Framework 1 / 31
3 Agenda Current Rules Design of the New Framework Calculation of Exposures Look-Through Approach Connected Counterparties Credit Risk Mitigation Hong Kong-Specific Implementation Marcel Bluhm (HKMA) Large Exposures Framework 2 / 31
4 Agenda Current Rules Design of the New Framework Calculation of Exposures Look-Through Approach Connected Counterparties Credit Risk Mitigation Hong Kong-Specific Implementation Marcel Bluhm (HKMA) Large Exposures Framework 2 / 31
5 Current Rules: BCBS (1991) s Key Elements Include all forms of lending, incl. off-balance sheet; Inclusion of related counterparties; 25% limit (of total capital); Sound internal control and audit; Lower limits for connected lending; Monitoring of clustered loan books; Attention to sectoral and geographical concentrations. However, considerable variation in application of 1991 principles across globe led the BCBS to develop the new large exposure standards of Marcel Bluhm (HKMA) Large Exposures Framework 3 / 31
6 Agenda Current Rules Design of the New Framework Calculation of Exposures Look-Through Approach Connected Counterparties Credit Risk Mitigation Hong Kong-Specific Implementation Marcel Bluhm (HKMA) Large Exposures Framework 4 / 31
7 Design of the New Framework: Key Characteristics New global minimum standard; Simple backstop approach; Focus on default risk; Limit: Relevant exposures Tier 1 capital 25% (inter-g-sib: 15%); Implementation by 1 January 2019; Close alignment to capital rules: all exposures captured in scope... Marcel Bluhm (HKMA) Large Exposures Framework 5 / 31
8 Design of the New Framework: Scope All internationally active banks; Banking book, trading book and off-balance sheet positions; Covers all exposures from single and connected counterparties (No other types of concentrations such as geographical, sectoral, or intra-group) of which large exposures must be reported... Marcel Bluhm (HKMA) Large Exposures Framework 6 / 31
9 Design of the New Framework: Reporting Requirements All exposures 10% of Tier 1 capital; Incl. exempted exposures; Incl. pre-crm exposures; 20 largest exposures. Marcel Bluhm (HKMA) Large Exposures Framework 7 / 31
10 Agenda Current Rules Design of the New Framework Calculation of Exposures Look-Through Approach Connected Counterparties Credit Risk Mitigation Hong Kong-Specific Implementation Marcel Bluhm (HKMA) Large Exposures Framework 8 / 31
11 Calculation of Exposures All exposures captured under capital framework included, however, some exemptions from the limit: Sovereign exposures; Intra-group exposures (HK: only internal limits required); QCCPs (clearing-related exposures); Currencies and commodities (no default risk); Intraday interbank exposures. Exposures can be divided into those featuring counterparty credit risk (CCR) and those that do not (Non-CCR)... Marcel Bluhm (HKMA) Large Exposures Framework 9 / 31
12 Calculation of Exposures: CCR Exposures Exposures from CCR treated similarly in banking and trading books; CCR only relevant for: derivative contracts (SA-CCR); and SFTs (revised comprehensive approach with supervisory haircuts/currently applied method); Marcel Bluhm (HKMA) Large Exposures Framework 10 / 31
13 Calculation of Exposures: Non-CCR Exposures For non-ccr exposures, calculation methods may differ depending on whether exposures are booked in banking or trading books. On-balance sheet banking book positions: book value; Traditional off-balance sheet banking book positions: standardised approach for credit risk (credit-equivalent amount=notional x CCF); 1 Trading book straight debt instruments and equity: market value; Trading book derivative contracts (other than options): decomposition. Specific treatments apply for some positions which can be in banking or trading books... 1 CCFs floored at 10%. Marcel Bluhm (HKMA) Large Exposures Framework 11 / 31
14 Calculation of Exposures: Non-CCR Exposures Securities underlying SFTs (borrower): book value; Options: jump-to-default; QCCP: non-clearing related exposures (e.g. a loan): book value; Covered bonds: 20% of notional (HK: 30%); Investment structures: look-through approach... Marcel Bluhm (HKMA) Large Exposures Framework 12 / 31
15 Agenda Current Rules Design of the New Framework Calculation of Exposures Look-Through Approach Connected Counterparties Credit Risk Mitigation Hong Kong-Specific Implementation Marcel Bluhm (HKMA) Large Exposures Framework 13 / 31
16 Look-Through: Granularity Test Marcel Bluhm (HKMA) Large Exposures Framework 14 / 31
17 Look-Through Approach Marcel Bluhm (HKMA) Large Exposures Framework 15 / 31
18 Look-Through Approach How to identify connected (linked) counterparties? Marcel Bluhm (HKMA) Large Exposures Framework 16 / 31
19 Agenda Current Rules Design of the New Framework Calculation of Exposures Look-Through Approach Connected Counterparties Credit Risk Mitigation Hong Kong-Specific Implementation Marcel Bluhm (HKMA) Large Exposures Framework 17 / 31
20 Connected Counterparties Exposures to a group of counterparties with specific relationship/dependencies, such that, were one counterparty to fail, all counterparties would very likely fail, require special attention (e.g. Apple and Foxconn); Such a group of connected counterparties must be treated as a single risk (counterparty); Sum of exposures to all individual entities grouped is subject to large exposures limit and regulatory reporting requirements. 2 criteria for grouping counterparties... Marcel Bluhm (HKMA) Large Exposures Framework 18 / 31
21 Connected Counterparties: Establishing Links Group counterparties if at least one of the following criteria is satisfied: Control relationship: one of the counterparties, directly or indirectly, has control over the other(s) (e.g. >50% of voting rights); Economic (inter)dependence: Financial difficulties would likely spread among counterparties (e.g. >50% of production sold to other counterparty, without easy replacement options); Banks need to actively search for economic (inter)dependence if exposure to individual counterparty >5% of Tier 1 capital. Marcel Bluhm (HKMA) Large Exposures Framework 19 / 31
22 Connected Counterparties: Establishing Links Economic (inter)dependence and control criteria may lead to chains of linked counterparties; Where two (or more) entities that are outside the scope of the sovereign exemption are controlled by or economically dependent on an entity that falls within the scope of the sovereign exemption, and are otherwise not connected, those entities need not be deemed to constitute a group of connected counterparties (e.g. Central Huijin Investment Ltd.); HKMA will provide AIs with code of practice. Marcel Bluhm (HKMA) Large Exposures Framework 20 / 31
23 Agenda Current Rules Design of the New Framework Calculation of Exposures Look-Through Approach Connected Counterparties Credit Risk Mitigation Hong Kong-Specific Implementation Marcel Bluhm (HKMA) Large Exposures Framework 21 / 31
24 Credit Risk Mitigation: Compulsory Shifting When a bank reduces exposure to the original counterparty due to an eligible CRM technique, it must recognise a similar exposure to the CRM provider. Compulsory exposure shifting to CRM protection provider is conservative: assumes double default; Compulsory exposure shifting does not exist for all instruments with risk-mitigating effect, such as a put option. 3 eligible categories of risk mitigants... Marcel Bluhm (HKMA) Large Exposures Framework 22 / 31
25 Credit Risk Mitigation: 3 Categories Risk mitigants result in different reductions of exposure to original counterparty: 1 Unfunded credit protection (reduction by value of protected portion) guarantee; credit derivatives; 2 On-balance sheet netting (loan exposure reduced by deposits if legal netting agreement; s.t. FX haircuts); 3 Financial collateral (reduction by market value of collateral) simple approach; comprehensive approach (s.t. required haircuts). Cases of put option and CDS deserve special attention... Marcel Bluhm (HKMA) Large Exposures Framework 23 / 31
26 Credit Risk Mitigation: CRM vs. Put Option Original exposure: bond A (value A); protection provider B. CRM: protected exposure is shifted from A to B; Put option with value (V) and strike (S): - reduce exposure to A by S-V; - increase exposure to B (option seller) by SA-CCR-implied amount. Marcel Bluhm (HKMA) Large Exposures Framework 24 / 31
27 Credit Risk Mitigation: Special Case of CDS Exposure to underlying is reduced by CDS-protected amount; Exposure to issuer (2 cases) increases by: 1 the amount by which the exposure to underlying is reduced ( normal case ); 2 CCR exposure calculated by SA-CCR for a CDS ( special case ) if: (i) CDS is held in the trading book and, (ii) either CDS provider or reference entity of the CDS is not a financial entity. Marcel Bluhm (HKMA) Large Exposures Framework 25 / 31
28 Agenda Current Rules Design of the New Framework Calculation of Exposures Look-Through Approach Connected Counterparties Credit Risk Mitigation Hong Kong-Specific Implementation Marcel Bluhm (HKMA) Large Exposures Framework 26 / 31
29 Hong Kong-Specific Implementation Implementation date 1 July 2019 (grace period of 6 months); Special CRM approach for Category B AIs; Adaptation for interbank exposures arising from IPO process; Internal limits for intra-group exposures; Covered bond exposure 30% of notional value; Sovereign exposures... Marcel Bluhm (HKMA) Large Exposures Framework 27 / 31
30 HK-Specific Implementation: Sovereign Exposures Fully exempted by Basel (and BELR); But HKMA will use marginal risk weight add-on approach (under BCR) with exemptions for HK, PRC and U.S. sovereigns: Marcel Bluhm (HKMA) Large Exposures Framework 28 / 31
31 HK-Specific Implementation: What Happened so Far? CP 16.01: Exposure Limits, March 2016; Soft consultation on detailed proposals in May 2018; Statutory consultation on draft rules in October 2018; Statutory consultation on draft Code of Practice in October 2018 Gazetted draft rules in November 2018; Submission to LegCo in November 2018; Marcel Bluhm (HKMA) Large Exposures Framework 29 / 31
32 HK-Specific Implementation: Way Forward To revise SPMs; To revise banking returns; May consider industry briefing. Marcel Bluhm (HKMA) Large Exposures Framework 30 / 31
33 Contact Hong Kong Monetary Authority Dr. Marcel Bluhm Manager in R&D Division of Banking Policy Department 55/F, Two International Finance Centre 8 Finance Street, Central HONG KONG Phone: mbluhm@hkma.gov.hk Marcel Bluhm (HKMA) Large Exposures Framework 31 / 31
34 Decomposition of Derivatives Market value says nothing about maximum loss; E.g. future to buy NIKKEI225 index in 3 months is decomposed into: Long position in the NIKKEI225 index; Short position in a 3-month Japanese Government bond; Short position in Government bond from decomposition disregarded under large exposures framework; Long position in NIKKEI225 index position may require look through approach... Marcel Bluhm Large Exposures Framework
35 Calculation of Option Exposure Exposure value is based on change in option price that would result from default of underlying. Marcel Bluhm Large Exposures Framework
36 Credit Risk Mitigation: Guarantee Marcel Bluhm Large Exposures Framework
37 Credit Risk Mitigation: Guarantee Marcel Bluhm Large Exposures Framework
38 Credit Risk Mitigation: Guarantee Marcel Bluhm Large Exposures Framework
39 Credit Risk Mitigation: Guarantee Credit risk mitigation can lead to high concentrations! Marcel Bluhm Large Exposures Framework
40 Credit Risk Mitigation: Comprehensive Approach E = max{0, E (1 + He) C (1 Hc Hfx)} with E the original exposure reduced by financial collateral. Example: E = max{0, 100 ( ) 100 ( )} E = = 27 Only supervisory haircuts can be used. Marcel Bluhm Large Exposures Framework
41 Connected Counterparties: From KYC to KYCC Source: statista, Business Insider If Apple defaults, many suppliers would likely be in serious trouble... Marcel Bluhm Large Exposures Framework
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