Further clarity on leverage ratio requirements for European banks

Similar documents
Financial Institutions Ratings Crédit Agricole SA AT1 rating report

Financial Institutions Ratings Deutsche Bank AG AT1 rating report

Financial Institutions Ratings Danske Bank AT1 rating report

Nordea s New Structure and Domicile Plans: A Manageable Challenge

Sovereign risk weights: the big missing piece of Basel III

AT1 Capital Instruments

Italian Banks Asset Quality Still a problem but on an improving path. Marco Troiano, CFA

The Leverage Ratio. The Author. Background. Abstract. Basel III Framework. December Scott Warner

28 September 2018 Financial Institutions

A- STABLE. Totens Sparebank Issuer Rating Report. Totens Sparebank. Issuer Rating Report. Overview. Highlights. 30 October 2018 Financial Institutions

Spanish SME CLOs: Back in the Game

New package of banking reforms

Total Loss-absorbing Capacity (TLAC) Term Sheet

Swedish banks: brighter prospects as housing crash fears recede

Scope upgrades Austrian mortgage covered bonds issued by Bank Burgenland and Wüstenrot to AAA

Basel Committee on Banking Supervision. TLAC Quantitative Impact Study Report

CUMULATIVE IMPACT ASSESSMENT OF THE BASEL REFORM PACKAGE DATA AS OF DECEMBER 2015

Capital strength: the common equity tier 1 fully loaded ratio stood at 11.4% at 2015 year-end.

Isabelle Vaillant Director of Regulation. European Institute of Financial Regulation (EIFR) 23 Septembre 2016

Euro area financial regulation: where do we stand?

The EBA s views on the adoption of International Financial Reporting Standard 16 Leases (IFRS 16) Dear Mr Jean-Paul Gauzes,

Guidelines on the treatment of CVA risk under the supervisory review and evaluation process (SREP) 27 January 2016 Public Hearing, London

Akershus Energi AS Norway, Utilities

Process and next steps

Citigroup Global Markets Limited Pillar 3 Disclosures

The EBA after one year: achievements and challenges ahead

ANNEX 4 MAIN DOCUMENTS PUBLISHED 1 BY THE INTERNATIONAL SUPERVISORY FORA: FSB, BCBS, EBA, ESRB AND ECB IN THE FRAMEWORK OF FINANCIAL STABILITY

Rating Action: Moody's upgrades Permanent tsb's deposit and senior unsecured ratings; outlook stable Global Credit Research - 08 May 2015

ICAAP Q Saxo Bank A/S Saxo Bank Group

Georgian Beer Company JSC

Capital Management 4Q Saxo Bank A/S Saxo Bank Group

Alpha Bank Group Pillar III Disclosures Report for March 31, 2018

03 September 2018 Financial Institutions

30 August 2018 Financial Institutions

An update of regulatory developments and impact on banks regulatory compliance

TD BANK INTERNATIONAL S.A.

Alpha Bank Group Pillar III Disclosures Report for September 30, 2018

2016 European Union Stress Test Process: Methodology and practice

Basel Committee on Banking Supervision

How to ensure enough Loss Absorbing Capacity: From TLAC to MREL

The FRB s LTD, TLAC and Clean Holding Company Final Rules, Funding and European TLAC/MREL Developments

Basel III Pillar III DISCLOSURES REPORT

13 March 2018 Financial Institutions

Draft Technical Standards on criteria for MREL. 19 January 2015

Basel Committee on Banking Supervision

ICAAP Q Saxo Bank A/S Saxo Bank Group

Implementation of Capital Requirements in Emerging Markets

QUANTITATIVE UPDATE OF THE EBA MREL REPORT (DECEMBER 2016 DATA)

ICAAP Report Q3 2015

Swinging a Euro Area Bank into Resolution: If, When and How

Strengthening the European banking system Overview of the CRDIV. World Bank CFRR IFRS Seminar for banking supervisors 18 April 2012, Zagreb

Basel Committee on Banking Supervision. Twelfth progress report on adoption of the Basel regulatory framework

Introduction. Regulatory environment in Legal Context

RISK REPORT PILLAR

Standard Chartered PLC Pillar 3 Disclosures 30 September 2017

Subscriptions Stay informed

Public consultation. on a draft Addendum to the ECB Guide on options and discretions available in Union law. Explanatory memorandum

UBS Group AG (consolidated) regulatory information

Impact of the Capital Requirements Regulation (CRR) on the access to finance for business and long-term investments Executive Summary

EBA s role in promoting supervisory and regulatory convergence in the EU. Andrea Enria - EBA Chairman Helsinki 5 June rd FIN-FSA Conference

Public hearing EBA draft guidelines on Credit institutions credit risk management practices and accounting for expected credit losses

Pillar 3 Report. For the year ended 31 December Allied Irish Banks, p.l.c

Basel Committee on Banking Supervision. Ninth progress report on adoption of the Basel regulatory framework

BASEL III MONITORING EXERCISE RESULTS BASED ON DATA AS OF 30 June 2018

BERMUDA MONETARY AUTHORITY

Group Results for the nine-month period ended 30 September 2016

Press release Press enquiries:

Consultations by the FPC and PRA on changes to the UK leverage ratio framework relating to the treatment of claims on central banks

Results of the Basel III monitoring exercise based on data as of 31 December Table of contents

Basel III Pillar 3 Disclosures Report. For the Quarterly Period Ended June 30, 2016

The Goldman Sachs Group, Inc. PILLAR 3 DISCLOSURES

Basel III Pillar 3 Disclosures Report. For the Quarterly Period Ended June 30, 2017

Making Banks Resilient: Basel III Framework s Capital Composition, Buffers and Leverage

The Goldman Sachs Group, Inc. PILLAR 3 DISCLOSURES

SUPERVISORY POLICY STATEMENT (Class 1(1) and Class 1(2))

Regulatory disclosures Credit Suisse Group Credit Suisse (Bank) Credit Suisse (Bank) parent company Credit Suisse International

Basel III Pillar 3 disclosures

RETHINKING BANKING: FITTING YOUR BUSINESS MODEL TO REGULATORY CONSTRAINTS

TLAC STRATEGY UPDATE JANUARY 2017 FIXED INCOME INVESTORS PRESENTATION

Credit Opinion: Bank Nederlandse Gemeenten N.V.

Regulatory disclosures Credit Suisse Group Credit Suisse (Bank) Credit Suisse (Bank) parent company Credit Suisse International

Credit Opinion: EBS Ltd

Internal Capital Adequacy Assessment Process Saxo Bank Group

TSB Banking Group plc. Significant Subsidiary Disclosures. 31 December 2015

UBS Group AG And UBS AG Upgraded On Stable Business Model And Revenues; Outlooks Stable

Rating Action: Moody's changes outlook to positive on all ratings of Allied Irish Banks and assigns (P) Ba2 rating to holding company senior programme

2. Process for determining the solvency need The basis for capital management Risk identification... 4

MREL & TLAC A Market Perspective WORLD BANK CONFERENCE, VIENNA 12/13 DECEMBER 2016 FINSAC WORKSHOP ON BAIL-IN AND MREL

Information of Prudential Relevance Pillar III 3Q 2017

Santander UK plc Additional Capital and Risk Management Disclosures

AB SEB bankas Capital Adequacy and Risk Management Report (Pillar 3) 2017

FINAL REPORT ON GUIDELINES ON UNIFORM DISCLOSURE OF IFRS 9 TRANSITIONAL ARRANGEMENTS EBA/GL/2018/01 12/01/2018. Final report

Deutsche Bank Credit Overview

Key issues in Banking Regulation

Scope Investment Awards Kategorien, Methodik & Nominierung

Basel Pillar 3 Disclosures

Basel Committee on Banking Supervision

The Goldman Sachs Group, Inc. PILLAR 3 DISCLOSURES

Discussion Paper. Treatment of structural FX under Article 352(2) of the CRR EBA/DP/2017/ June 2017

Public hearing EBA Draft RTS on the methods of prudential consolidation under Article 18 of the CRR. London, 22 January 2018

Transcription:

25 April 2016 Financial Institutions Further clarity on leverage ratio requirements for European Further clarity on leverage ratio requirements for European On 15 April 2016, the EBA presented its draft report on the calibration of the leverage ratio under Article 511(3) of CRR. We review the status of leverage ratio implementation and consider where future requirements may end up, particularly for European global systemically important (G-SIBs). In Europe, the leverage ratio has been part of the Supervisory Review and Evaluation Process (SREP), therefore under Pillar 2, since 2013. CRD IV clarifies that should effectively manage the risk of excessive leverage referring to risks resulting from an institution's vulnerability due to leverage that may require unintended corrective measures, including the distressed selling of assets which might result in losses or in valuation adjustments to remaining assets. CRR requires to compute a leverage ratio, report it to their supervisors and from January 2015 to disclose it publicly. Analyst Pauline Lambert +44 20 3457 0444 p.lambert@scoperatings.com The EBA has been mandated to report on various aspects of the leverage ratio including (i) whether the leverage ratio should migrate to Pillar 1 and if so what the minimum level(s) should be taking into account business models and risk profiles; (ii) the interaction between the leverage ratio and RWA-based ratios and liquidity requirements as well as the impact on various segments of financial markets; and (iii) whether the leverage ratio is an appropriate tool for managing the risk of excessive leverage. Based on the results of its quantitative analysis, the EBA concluded that a 3% leverage ratio is generally consistent with the objective of a backstop measure which supplements risk-based capital requirements. Further, the potential impact of introducing a 3% leverage ratio requirement on the provision of financing by credit institutions is relatively moderate when put into the context of the overall size of the banking sector. For a sample of 246 entities across 20 countries the weighted average leverage ratio was 4.4%. In the public hearing mentioned above the EBA highlighted that its work was probably most useful for future supervisory practices. The EBA recognised the challenges in light of varying business models and risk profiles and that there may be unintended consequences in specific cases. It cautioned, however, that it would be difficult to design differentiated requirements without defeating the original purpose of the leverage ratio. By year-end 2016, the European Commission, considering the EBA s report on the impact and effectiveness of the leverage ratio, will present where appropriate a legislative proposal to introduce a Pillar 1 leverage ratio, with suitable level(s). In our view, there appears to be a good likelihood that systemically important in the EU will be subject to additional requirements, as is already the case in the EU for the UK and outside the EU for Switzerland and the US. Scope Ratings AG Suite 407 2 Angel Square London EC1V 1NY Phone +44 20 3457 0444 Headquarters Lennéstraße 5 10785 Berlin Phone +49 30 27891 0 Fax +49 30 27891 100 Service +49 30 27891 300 info@scoperatings.com www.scoperatings.com Bloomberg: SCOP 25 April 2016 1/6

Figure 1: Compliance by business model Preliminary conclusions from EBA draft report The EBA performed analysis on a sample of 246 credit institutions from 20 countries with June 2015 as a last reference date with data coming from the EU Voluntary QIS exercise. Institution-specific balance sheet data was used rather than aggregate data for assessing how institutions could comply with potential leverage ratio requirements. The simulation assumed a baseline scenario of 50% capital build-up and 50% exposure reduction. Based on the quantitative analysis, the EBA concluded that a 3% leverage ratio is generally consistent with the objective of a backstop measure which supplements riskbased capital requirements. For around a third of the analysed institutions, a Tier 1 leverage ratio of 3% would constitute a higher capital requirement than a risk-based Tier 1 capital requirement of 8.5%. Amongst the sample, the weighted average leverage ratio was 4.4% while the median was 5.5%. As shown in Figure 1, a 3% leverage ratio requirement would result in a Tier 1 shortfall of EUR 6.4bn, with public development and mortgage representing the bulk. This is not surprising given the generally low-risk nature of the activities of these institutions. Based on the size of institutions, the shortfall stemmed from non-g-siis (Figure 2). Source: EBA QIS (June 2015) Of note, the quantitative benchmarking results indicated that there is potentially elevated exposure to the risk of excessive leverage in the case of the largest and most complex institutions, in particular for those who operate the business model of a cross-border universal bank and at the same are G-SIIs. This provides support for current Basel proposals considering additional requirements for systemically important such as a higher minimum or a buffer requirement or having limits on how much Additonal Tier 1 (AT1) capital may be used to satisfy the requirement. More rigorous requirements already exist in the UK, Switzerland and the US, and we would not be surprised if systemically important in Europe were subject to additional requirements (further details below). In the EBA analysis, G-SIIs and cross-border universal displayed weighted average leverage ratios of 4.1% and 4.2%, respectively. 25 April 2016 2/6

Figure 2: Compliance by size of institution Source: EBA QIS (June 2015) The EBA also found that the potential impact of introducing a 3% leverage ratio requirement on the provision of financing by credit institutions was relatively moderate when put into the context of the overall size of the banking sector. The empirical results also revealed a very moderate increase in risk-taking at credit institutions which had a leverage ratio below 3% in 2010 (when Basel first introduced the measure). In addition, the leverage ratio was more sensitive to the economic cycle than risk-based capital requirements, and therefore potentially countercyclical. Based on further input from market participations, particularly qualitative considerations, the EBA will finalise its draft report over the next few months. The final report will be submitted to the European Commission by end July 2016 and be used as a basis for drafting potential leverage ratio legislation. 25 April 2016 3/6

Positioning of G-SIBs in Europe As shown in Figure 3, for the G-SIBs rated by Scope, leverage ratios as of year-end 2015 were comfortably above 3% and ranged from 3.5% to 6%. For many, there has been a marked improvement in the leverage position over the last year, often driven by active deleveraging and restructuring in particular, for those involved in investment banking activities. Figure 3: Selected G-SIBs: year-end 2015 BIS leverage ratios 7% 6% 5% 4% 3% 2% 1% Transitional Fully-loaded 0% Notes: Some report only transitional or fully-loaded figures. BBVA will no longer be considered a G-SIB from 2017. Source: Company data, Scope Ratings International developments In December 2010, the Basel Committee introduced the leverage ratio with the following objectives: (i) to restrict excess leverage in the banking sector as this can damage the broader financial system and the economy and (ii) to reinforce risk-based requirements with a simple, non-risk based backstop measure. In January 2016, members of the Committee s oversight body agreed on a Tier 1 definition of capital and a minimum level of 3% for the leverage ratio. As well, additional requirements for G-SIBs were discussed. In 2016, calibration of the Basel III leverage ratio will be finalized to allow sufficient time for implementation as a Pillar 1 minimum capital requirement by 1 January 2018. In April 2016, the Committee published a consultation document with proposed revisions to the Basel III leverage ratio framework informed by the monitoring process that has been in place since 2013 and market feedback. Among the areas subject to revision are the measurement of derivative exposures, the treatment of provisions, credit-conversion factors for off-balance sheet items and additional requirements for G-SIBs. Composition of leverage ratio The Basel III leverage ratio is defined as the capital measure divided by the exposure measure, with this ratio being expressed as a percentage: Leverage ratio = Capital measure / Exposure measure The capital measure is Tier 1 capital as defined under Basel III and consists of CET1 and AT1 capital subject to adjustments, deductions and transitional arrangements. 25 April 2016 4/6

The exposure measure comprises on-balance sheet exposures, derivative exposures, securities financing transaction (SFT) exposures and other off-balance sheet items (e.g. liquidity facilities, standby letters of credit and trade letters of credit). While exposures are not subject to risk-weights, different conversion factors apply to off-balance positions reflecting differences in the magnitude of their utilisation. Netting between assets and liabilities is generally not permitted although specific rules apply to SFTs (i.e. repurchase transactions, securities/commodities lending or borrowing transactions and margin lending transactions). Leverage ratio framework in UK UK G-SIBs and other major UK and building societies are subject to a minimum 3% leverage ratio requirement as well as a countercyclical leverage ratio buffer (set at 35% of the risk-weighted countercyclical buffer rate). As well, there is a supplementary leverage ratio buffer which is set at 35% of the corresponding risk-weighted systemic risk buffer rate this is being phased-in from 2016 to 2019 for G-SIBs and will be introduced in 2019 for other major domestic UK and building societies. For such as Barclays and HSBC, this translates into 2019 leverage ratio requirements close to 4%. Up to 25% of the minimum leverage ratio requirement of 3% can be met with high-trigger contingent capital (i.e. AT1 instruments with a trigger of at least 7%). The remainder as well as all leverage ratio buffers must be met with CET1 capital. Leverage ratio framework in Switzerland New capital rules for Swiss systemically relevant are expected to come into force as of 1 July 2016 with a four-year phase-in period. The proposed going concern capital requirements include a leverage ratio of 4.5% and a progressive buffer reflecting a bank s systemic importance. If the buffer is utilised, must take steps to restore it. For UBS and Credit Suisse, the progressive buffer is expected to be 0.5%, bringing the total going concern leverage ratio requirement to 5%. Of this, at least 3.5% must be met with CET1 capital and up to 1.5% may be met by high-trigger AT1 capital instruments. In addition, there would be a 5% gone-concern leverage ratio requirement. This requirement may be reduced by up to 2% if a bank takes measures to improve its resolvability. Leverage ratio framework in US From 1 January 2018, banking organisations subject to advanced approach risk-based capital rules must meet a minimum 3% leverage ratio. In addition, US bank holding companies that are G-SIBs (covered BHCs) are subject to a minimum 2% leverage buffer. If a covered BHC maintains a leverage buffer greater than 2%, it is not subject to limitations on distributions and discretionary bonus payments. Meanwhile, the insured depository institution subsidiaries of covered BHCs must maintain a leverage ratio of at least 6% to be considered well-capitalised. 25 April 2016 5/6

Scope Ratings AG Headquarters Berlin Lennéstraße 5 D-10785 Berlin Phone +49 30 27891 0 London Suite 407 2 Angel Square London EC1V 1NY Phone +44 20 3457 0444 Frankfurt am Main Rüsterstraße 1 D-60325 Frankfurt Phone +49 69 97944 754 Madrid Paseo de la Castellana 95 Edificio Torre Europa E-28046 Madrid Phone +34 914 186 973 Paris 21, Boulevard Haussmann F-75009 Paris Phone +33 1 53 43 29 89 info@scoperatings.com www.scoperatings.com Disclaimer 2016 Scope Corporation AG and all its subsidiaries including Scope Ratings AG, Scope Analysis GmbH, Scope Investor Services GmbH (collectively, Scope). All rights reserved. The information and data supporting Scope s ratings, rating reports, rating opinions and related research and credit opinions originate from sources Scope considers to be reliable and accurate. Scope cannot however independently verify the reliability and accuracy of the information and data. Scope s ratings, rating reports, rating opinions, or related research and credit opinions are provided as is without any representation or warranty of any kind. In no circumstance shall Scope or its directors, officers, employees and other representatives be liable to any party for any direct, indirect, incidental or otherwise dam-ages, expenses of any kind, or losses arising from any use of Scope s ratings, rating reports, rating opinions, related research or credit opinions. Ratings and other related credit opinions issued by Scope are, and have to be viewed by any party, as opinions on relative credit risk and not as a statement of fact or recommendation to purchase, hold or sell securities. Past performance does not necessarily predict future results. Any report issued by Scope is not a prospectus or similar document related to a debt security or issuing entity. Scope issues credit ratings and related research and opinions with the understanding and expectation that parties using them will assess independently the suitability of each security for investment or transaction purposes. Scope s credit ratings address relative credit risk, they do not address other risks such as market, liquidity, legal, or volatility. The information and data included herein is protected by copyright and other laws. To reproduce, transmit, transfer, disseminate, translate, resell, or store for subsequent use for any such purpose the information and data contained herein, contact Scope Ratings AG at Lennéstraße 5 D-10785 Berlin. 25 April 2016 6/6