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Basel II Impact on The Credit Worthiness of Norwegian Banks Per Törnqvist Associate Director, Financial Services Ratings January 17 2005 Basle II Imply Sweeping Changes Big Move Towards Self-Regulation and Own-Models • Regulators no longer prescribe • Regulators opine on banks’ own processes Ultimate Goal Is To Let Markets Decide Creditworthiness Make Capital Scheme More Inclusive of All Risks Make Capital Scheme More Risk Sensitive 7/17/2015 2 S&P remains clearly supportive … • Basel II an improvement because it better differentiates credit risk • Basel II reinforces existing trends towards more advanced credit risk management • Basel II will increase transparency 7/17/2015 3 S&P remains clearly supportive …but • Basel II is still the minimum amount of capital a regulator will require in order to allow a bank to operate. • The actual amount of capital in banking will continue to differ from the minimum requirement. 7/17/2015 4 What Is Capital? Capital levels are like credit enhancement levels. Composed of instruments intended to absorb losses. •Tier 1 capital: Tangible common equity plus up to 15% qualifying hybrid instruments •Tier 2 capital: Subordinated debt, excess hybrid instruments, loan loss reserves in excess of expected losses, up to .80% of Risk Weighted Assets •Tier 3 capital: Medium-term subordinated debt instruments that can be used to satisfy market risk capital requirements. •Total capital needs to be 8% of Risk Weighted assets: Tier 1 minimum is 4%. •Standard & Poor’s do not view all instruments the same way. 7/17/2015 5 What is Capital For? 1. To cover unexpected losses (UL): a function of term of loan and correlation 2. To grant management strategic freedom. (Acquisitions & investments) 3. Expected losses (EL) are to be covered by loan loss reserves: defined as PD x LGD for 1 year • Any shortfall in reserves is to be deducted 50% from Tier 1 and 50% from Tier 2 capital • Any surplus in reserves may be added to Tier 2 capital up to 8% of RWA The lower the quality of the asset, the greater the proportion of reserves relative to capital is required to support the asset. 7/17/2015 6 Overall Change in Capital Requirement 20 15 10 12% 6% 3% 5 % 0 -2% -5 -10 -15 -20 -22% -25 Standardized Source Basel Committee – Overview on QIS 3 IRB F Large Banks Small Banks Large Banks: T1 Capital >€3bn 7/17/2015 7 IRB A Impact on Capital Requirement % Change in K Requirements (Large Banks) 140 % 120 100 80 60 40 20 1 0 -20 Source Basel -40 Committee – Overview on QIS 3-60 12 3 Standardized Corporate SME Securitized assets 7/17/2015 -2 -14 -8 IRB F Sovereign Specialized Lending Overall Credit Risk 8 Bank Equity Operational Risk IRB A Retail Trading Book Overall Change What Bank Regulators Will Look For In Pillar 2 Banks must define capital adequacy at levels above the minimum in relation to risk profile and appetite in relation to stress tests performed Supervisors must: review risk governance at the corporate level review internal controls with respect to data and model quality be prepared to intervene early in cases of deterioration monitor adequacy of disclosure Supervisors and banks must design and review robustness of methods that deal with risks not covered in Pillar 1: interest rate risk concentrations of credit risk by borrower and industry strategic risk 7/17/2015 9 Likelihood of Changes Due to Basel II Depends on whether banks were arbitraging their capital regulations or already focused on economic capital model results Pricing issues will likely depend on market competitive conditions. And BIS II will create strong incentives for increased competition on certain risk types (e.g. secured lending, retail lending) Capital volatility will depend on conservatism of PD estimates and capital cushion maintained 7/17/2015 10 Potential Impact on Banks’ Business Basel II will reinforce trends already in place: Scientific portfolio risk management Increasing use of credit mitigators and risk transfer techniques Increased disclosure Underwriting then selling and trading corporate risk 7/17/2015 11 Potential Impact on Banks’ Strategy Shift to Retail Banking Banking 7/17/2015 Consolidation? Capital release by acquiring a bank and ‘converting’ it from the Standard Method to the IRB method Banks which cannot afford investments for the most advanced approaches may be priced out of certain markets Improved target identification due to disclosure 12 Potential Impact On Borrowers Difficult to predict: Some types of lending appear to benefit from Basel II: • retail lending • mortgage lending • SME credit Whereas others seem relatively disadvantaged: • Corporate lending • Specialized lending • Emerging markets lending But the discrimination will more likely be between quality borrowers and risky borrowers. 7/17/2015 13 What Could Change? Unintended Consequences of Basel II Nota bene: Not all lenders are subject to Basel II (hedge funds; insurance companies) More rational allocation and pricing of capital in the economy Lending margins will come under pressure for asset types that gain from BIS II. Higher risk commercial lending could be constrained by higher capital requirements. Shift in the relative price of equity capital and debt. Increased use of structured products such as covered bonds to isolate credit quality. Increased focus on risk adjusted returns beyond the financial services industry. Banks may prefer shorter-term lending Banks may experience capital relief Use reserves to satisfy capital for Expected Losses Use collateral to reduce capital Consumer loans get capital relief Commercial lenders and processing banks need higher capital Capital requirements (and willingness to lend) could be more volatile. 7/17/2015 14 … but Standard & Poor’s sees the imperfections of Basel II 1. Calibration issues 2. Operational risk elusive to measure 3. Pillar II: A heavy burden for regulators and consistency issue 4. Complex and expensive 7/17/2015 15 1. Calibration Issues • IRB formulas underestimate the level of required capital for certain business lines • Need for a Recessionary Scenario • A narrow definition of Credit Risk • Sufficient capital should be required to allow bank to continue to operate after it experiences losses • Remaining concerns on the Standardized Approach 7/17/2015 16 Default Rates Increase During a Recession Default Rates for Static Pools 1981 - 2003 Rating Category CCC B BB BBB A AA AAA 1-Year Avg. Rate 30.85 6.08 1.36 0.37 0.05 0.01 0.00 3-Year Avg. Rate 45.47 19.20 7.12 1.67 0.28 0.08 0.03 Minimum (3-Year) 9.09 8.16 1.25 0.00 0.00 0.00 0.00 Maximum (3-Year) 60.36 27.81 12.50 3.84 0.86 0.29 0.55 Source: Standard & Poor’s default statistics 7/17/2015 17 A Narrow Definition of Credit Risk • Interest- rate risk & concentration risk are not reflected in Pillar I but are allocated to supervisory review (Pillar II) « National Discretion » 7/17/2015 18 A Static Approach • Pillar I : capital aimed to cover worst-case losses and enable entity to pay off all liabilities • Operating banks, not static portfolios NEED FOR A MARGIN OF SAFETY! 7/17/2015 19 2. Operational Risk Elusive to Measure • Definition: excludes strategic and reputational risks • Gross income only a proxy for O.R. measure • Calibration: 12%? 15%? 20%? 100% ? • Over-reliance on models 7/17/2015 20 3. A Heavy Burden On Regulators • Validation & Supervision of Models – – – – – IRB Credit Risk Mitigation Stress Testing Operational Risk Securitization • Increased Power of Intervention • Designation of ECAIs Combined with IFRS and covered bonds and Solvency II and a new life insurance legislation!!! 7/17/2015 21 Consistent Supervisory Standards? • No standardization of the supervisory process in Basel II • Home host issues • Crucial areas left to national discretion (interest rate risk, concentration risk, business and strategic risk, stress testing, option 1 in SA) • Capital ratios may be LESS rather than MORE comparable across countries 7/17/2015 22 4. Complex and Expensive • Complex and rules-based approach • Over-reliance on models (Model Risk?) • Expensive: ~ €115 mn for large banks (*) (*) Source: Forrester research 7/17/2015 23 Impact of Basel II on Bank Ratings Choice of Approach Banks that choose Standardized Approach will not be penalized We expect smaller banks in mature markets to progressively shift to Advanced IRB This is likely to be accentuated in the Nordic region Much of IRB not applicable to emerging markets Level of Capital In theory, if a bank were to substantially reduce capital under Basel II, all else remaining the same, we could lower the rating In practice, we do not expect radical changes in capital policy – rather, changes will be gradual, as banks incrementally adapt to the Basel II principles 7/17/2015 Capital for mortgage loans should reflect risks other than credit risk: interest rate, funding, business risk, low margin profile 24