Revisions to the Standardised Approach for Credit Risk Gary Haylett General Manager Prudential

Similar documents
Proposed BCBS Standardized Approach for Credit Risk BANK, CORPORATE, RETAIL, AND OFF- BALANCE- SHEET EXPOSURES

Stand out for the right reasons Financial Services Risk and Regulation. Hot topic

Revisions to the Standardised Approach for credit risk

Basel III: Proposed Revisions to Standardized Approach to Credit Risk

24 June Dear Sir/Madam

Basel Committee on Banking Supervision. High-level summary of Basel III reforms

January 19, Basel III Capital Standards Requests for Clarification

Comments on the Basel Committee on Banking Supervision s Consultative Document Revisions to the Standardised Approach for credit risk

The Standardised Approach for Credit Risk November 2016

Basel Committee on Banking Supervision: Consultative Document: Revisions to the Standardised Approach for credit risk

Cambridge & Counties Bank (C&CB) January 2016

Regulation and Public Policies Basel III End Game

WBG Survey on proposed revisions to Basel II Finding

Basel III: Finalising post-crisis reforms

RE: Consultative Document, Simplified alternative to the standardised approach to market risk capital.

Comments on: The revised Standardised Approach to Market Risk - Update on revised Accord texts

Re: BCBS 269 consultative document on revisions to the securitisation framework

Summary of World Council s Comments

Second consultative document: Revisions to the Standardised Approach for credit risk

Basel Committee on Banking Supervision. Basel III: Finalising post-crisis reforms

Box C The Regulatory Capital Framework for Residential Mortgages

Basel II Implementation Update

Basel Committee on Banking Supervision Second consultative document on Revisions to the Standardised Approach for credit risk

In various tables, use of - indicates not meaningful or not applicable.

Basel II and Financial Stability: Singapore s Experience

INDIAN BANKS ASSOCIATION. Comments on BCBS Consultative document on Revisions to the Standardised Approach for Credit Risk

Basel II Pillar 3 disclosures

CONSULTATION DOCUMENT EXPLORATORY CONSULTATION ON THE FINALISATION OF BASEL III

Basel II Pillar 3 disclosures 6M 09

Responses to the EU Commissions exploratory consultation on the finalisation of Basel III

African Bank Holdings Limited and African Bank Limited

Call for advice to the EBA for the purposes of revising the own fund requirements for credit, operational, market and credit valuation adjustment risk

Basel Committee on Banking Supervision. Consultative Document. Overview of The New Basel Capital Accord. Issued for comment by 31 July 2003

African Bank Holdings Limited and African Bank Limited

BERMUDA MONETARY AUTHORITY GUIDELINES ON STRESS TESTING FOR THE BERMUDA BANKING SECTOR

The Revised Standardised Approach. October 19, 2015 Caio Ferreira

Deutsche Bank s response to the Basel Committee on Banking Supervision consultative document on the Fundamental Review of the Trading Book.

Basel II: New Zealand discretions for the internal ratings-based (IRB) approach to credit risk

Interim financial statements (unaudited)

BOM/BSD 18/March 2008 BANK OF MAURITIUS. Guideline on. Standardised Approach to Credit Risk

YBS response to the Basel Committee on Banking Supervision s consultation on the Revisions to the Standardised Approach for credit risk

NATURE AND EXTENT OF RISKS ARISING FROM FINANCIAL INSTRUMENTS Quantitative disclosures. Collateral and other credit enhancements pledged

Disclosure in terms of Regulation 43 relating to banks, issued under section 90 of the Banks Act, No. 94 of 1990, as amended.

Overall we are of the view that the second consultative document is an improvement compared to the first.

African Bank Holdings Limited and African Bank Limited

Lloyds Banking Group plc Half-Year Pillar 3 disclosures. 28 July 2016

The BBA is pleased to respond to this consultation on the net stable funding ratio. Please find below are comments on the key issues in the paper.

THE CENTRAL BANK OF THE BAHAMAS

Consultative Document on reducing variation in credit risk-weighted assets constraints on the use of internal model approaches

Quantitative Impact Study 3 Areas of National Discretion. For use by [NAME OF NATIONALITY] banks in completing the QIS 3 Questionnaire

BOM/BSD 18/March 2008 BANK OF MAURITIUS. Guideline on. Standardised Approach to Credit Risk

SUMITOMO MITSUI BANKING CORPORATION MALAYSIA BERHAD (Company No U) (Incorporated in Malaysia)

SUMITOMO MITSUI BANKING CORPORATION MALAYSIA BERHAD (Company No U) (Incorporated in Malaysia)

SUMITOMO MITSUI BANKING CORPORATION MALAYSIA BERHAD (Company No U) (Incorporated in Malaysia)

BERMUDA MONETARY AUTHORITY

The South African Bank of Athens Limited. PILLAR 3 REGULATORY REPORT December 2016

Santander UK plc Additional Capital and Risk Management Disclosures

Basel III: Finalising post-crisis reforms

Basel III Pillar 3 disclosures 2014

Basel Amended Proposals on Capital and Liquidity Requirements

Consultation Paper on the Areas of National Discretion

PILLAR 3 DISCLOSURE APS 330: PUBLIC DISCLOSURE

African Bank Holdings Limited and African Bank Limited. Annual Public Pillar III Disclosures

Basel Committee on Banking Supervision. Second Working Paper on Securitisation. Issued for comment by 20 December 2002

Secretariat of the Basel Committee on Banking Supervision. The New Basel Capital Accord: an explanatory note. January CEng

Pillar 3 Disclosure (UK)

BASEL COMMITTEE ON BANKING SUPERVISION. To Participants in Quantitative Impact Study 2.5

ANZ Basel II Pillar 3 disclosure December 2009 BASEL II PILLAR 3 IN ACCORDANCE WITH APS 330 QUARTER ENDED 31 DECEMBER 2009

Public disclosure of Prudential Information. as at 31st March 2009

Capital treatment for simple, transparent and comparable securitisations

Secretariat of the Basel Committee on Banking Supervision (BCBS) Bank for International Settlements CH-4002 Basel Switzerland

Refining the PRA s Pillar 2 capital framework

Policy Statement PS23/17 Internal Ratings Based (IRB) approach: clarifying PRA expectations. October 2017

(A.B.N ) APS

The New Capital Adequacy Framework Basel II

[Our comments on the questions of the Consultative Document]

BERMUDA MONETARY AUTHORITY

BASEL II PILLAR III DISCLOSURE

ZAG BANK BASEL PILLAR 3 AND OTHER REGULATORY DISCLOSURES. December 31, 2017

Deutscher Industrie- und Handelskammertag

Interim financial statements (unaudited) as at 30 September 2009

PILLAR III DISCLOSURE

Basel III Pillar 3. Capital Adequacy and Risks Disclosures as at 31 December 2017

BCBS Discussion Paper: Regulatory treatment of accounting provisions

Re: Comments on the second consultative document on revisions to the standardized approach for credit risk

November 28, Secretariat of the Financial Stability Board c/o Bank for International Settlements CH-4002, Basel, Switzerland

PRUDENTIAL DISCLOSURES JUNE 2018

Response to discussion paper of the Basel Committee on the regulatory treatment of sovereign exposures

Consultation Paper. Draft Guidelines EBA/CP/2018/03 17/04/2018

ZAG BANK BASEL PILLAR 3 DISCLOSURES. December 31, 2015

CAPITAL REQUIREMENTS DIRECTIVE PILLAR 3 DISCLOSURE DOCUMENT

CAPITAL REQUIREMENTS DIRECTIVE PILLAR 3 DISCLOSURE DOCUMENT 31 ST MARCH P a g e

APS 330 Capital Adequacy Public Disclosure of Prudential Information

PILLAR 3 DISCLOSURES QUARTERLY STATUTORY RETURN. 30 June 2018

(i) Pillar 1 Outlines the minimum regulatory capital that banking institutions must hold against the credit, market and operational risks assumed.

Final Report. Guidelines on specification of types of exposures to be associated with high risk under Article 128(3) of Regulation (EU) No 575/2013

Basel Committee on Banking Supervision. Consultative Document. Capital treatment for simple, transparent and comparable securitisations

The Goldman Sachs Group, Inc. PILLAR 3 DISCLOSURES

The Goldman Sachs Group, Inc. PILLAR 3 DISCLOSURES

Comments on the Consultative Document Regarding the Capital Treatment of Bank Exposures to Central Counterparties

Transcription:

09 March 2016 Secretariat of the Basel Committee on Banking Supervision Bank for International Settlements CH-4002 Basel Switzerland Doc Ref: Your ref: 2 nd consultative document Revisions to the Standardised Approach for Credit Risk Direct : +27 11 645-6708 E- : garyh@banking.org.za Dear Sir / Madam Revisions to the Standardised Approach for Credit Risk The Banking Association South Africa ( BASA ) appreciates this opportunity to comment on the Basel Committee on Banking Supervision (BCBS) 2nd consultative document Revisions to the Standardised Approach for Credit Risk which forms part of the Committee's broader review of the capital framework to balance simplicity and risk sensitivity, and to promote comparability by reducing variability in risk-weighted assets across banks and jurisdictions. We would like to thank the Committee for considering industry concerns relating to the limitations of removing all references to external ratings as proposed in the first consultative document and we support the revised proposal to use external ratings as part of the risk determination for certain exposures. Given the intention to use the revised standardised framework as a basis for capital floors, we emphasize the importance of completing an in-depth analysis to assess the appropriateness of the calibrations included in the proposal and thus we support the upcoming Basel monitoring exercise that will include QIS on credit risk. The inherent difficulty of developing a new framework for a Standardised Approach to Credit Risk is that there are so many moving parts to its calibration i.e. changing one aspect of the methodology influences other frameworks as well. As such, we implore the Committee to conduct a holistic assessment of these interactions needs to be undertaken with the industry before any reforms are finalised. Our response to the Committee s specific questions has been captured on Annexure A; We thank you for taking our comments into consideration, and we look forward to future discussions on these issues. Yours sincerely Gary Haylett General Manager Prudential

Page 2 ANNEXURE A Bank Exposure In jurisdictions that do not allow the use of ratings The wording used under the proposal for regulatory purposes (and for unrated for SCRA, the requirement for Grade exposures in all jurisdictions), banks would A classification i.e. counterparties classify exposures into three different buckets (A, that have adequate capacity to meet B and C) provided that certain minimum criteria their financial commitments are met. Due diligence could also result in the classification of an exposure into a higher-risk grade even if the minimum criteria of a lower risk grade are met - (including repayments of principal and interest) in a timely manner, for the projected life of the assets or exposures and irrespective of the Standardised Credit Risk Assessment Approach economic cycles and business (SCRA) conditions and exceed the published minimum regulatory requirements and buffers ; could be open to interpretation. - For improved comparability we suggest clearer guidance be provided on what would be deemed as adequate capacity Regulation requires that banks cap their external ratings at those of their sovereigns. The external sovereign rating for many emerging market economies is below investment grade. Under the new proposal, to the extent that a bank that has adequate capacity but is in a jurisdiction that allows the use of external ratings would have its ratings capped at the sovereign s below investment status (RW: 100-150%). - This will disadvantage jurisdictions that must apply the external rating methodology relative to jurisdictions that don t i.e. in a jurisdiction that does not allow external ratings a

Page 3 similar bank meeting the above requirements in terms of adequate capacity to repay, minimum regulatory requirements and buffers could be rated Grade A (RW:50%) as there is no cap applied. This seems misaligned Corporate Exposure In jurisdictions that allow the use of ratings for In jurisdictions that use of ratings regulatory purposes, ratings would be the primary for regulatory purposes, basis to determine risk weights for rated consideration should be given to the exposures. risk weight of a BBB corporate exposure. The risk weight of BBB (i.e., investment grade) corporate exposure is proposed at 100%, which is the same as BB (i.e., noninvestment grade). - As BBB is likely to have better credit quality than BB, we propose that the risk weight for BBB corporate exposure be revised to 75% in order to apply a more risk sensitive framework by differentiating between the external rating bands - Perhaps banks should perform independent internal due diligence analysis and not solely rely on agency ratings for credit decisionmaking purposes Retail Exposure Regulatory retail: retail exposures will be riskweighted The flat risk-weight of 75% for at 75%, unless the exposure is defaulted regulatory retail exposures should be revisited as we consider such a risk-weight punitive for good quality portfolios. - We recommend that a range of commonly recognised risk characteristics be established that

Page 4 identify lower-risk retail credit exposures. Other retail: exposures will be risk-weighted at 100%, unless secured by real estate The risk sensitivity of regulatory retail exposures such as vehicle financing could be increased by considering standard risk drivers such as proportion of loan repaid, product type etc. Exposures Secured by Residential Real Estate The LTV ratio is the amount of the loan divided by the value of the property. The value of the property will be maintained at the value measured at origination unless national supervisors elect to require banks to revise the property value downward In terms of the calculation of LTV keeping the value of the property constant as at origination may be inaccurate and the proposed capital requirement would be overly conservative, particularly in emerging markets with strong growth in real estate market valuations When the prospects for repayment and recovery on the exposure materially depend on the cash flows generated by the property securing the loan rather than on the underlying capacity of the borrower to repay the debt from other source exposure will be risk-weighted between 70% - 120% To ensure greater consistency, comparability, and applicability on both a national and international basis it would be clearer from an implementation perspective if a materiality threshold were specified for both Residential and Commercial real estate Under the current Standardised Approach the RW for all exposures secured by mortgages on residential property is currently 35%. We are concerned about the proposed level of increase in capital requirements for residential mortgages where repayments are materially dependent on cash flows generated

Page 5 by the property i.e. IPRE to 70% - 120%. - In some emerging markets the majority of urban market employees source housing through rentals. The higher capital requirements could have negative consequential effect on the socio-economic objective of improving housing availability. - We suggest including conditions which, if met, would allow the use of the lower regular mortgage risk weights for high quality IPRE lending. We also note that unsecured retail exposures are risk-weighted at 75%, however, secured loans for Buy-to-Let with an LTV of 80% are risk-weighted at 90%, which does seem counterintuitive Risk weight add-on for exposures with currency mismatch Banks would apply a 50% risk weight add-on to unhedged exposures with currency mismatch, where unhedged exposure is defined as an exposure to a borrower that has no natural or financial hedge against the foreign exchange risk arising from the currency mismatch In a number of jurisdictions, it is common practice for the lending currency to differ from the currency of the borrower s main source of income where that income is effectively indexed to the lending currency (though collected in the local currency). It would therefore be an overly conservative assessment of the risk profile if a 50% add-on were applied. - We believe requiring currency mismatch add-on for corporates is not appropriate. Such risk is already incorporated in the external rating and is supported by the bank's own credit assessment and due diligence.

Page 6 - It is proposed that the add-on only be applied if an effective hedge cannot be demonstrated