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A Fine Balance: The Role of Regulation in Furthering MSME Development Ewald Műller Director, Financial Analysis 20 June 2013 Qatar Financial Centre Regulatory Authority 1 PRESENTATION OVERVIEW • The Basel Framework • Credit risk and capital adequacy – Standardised approach versus Internal Risk Models – Credit risk mitigation • Other policy issues – MSME definitions – Taxation and other red tape – Encouraging / facilitating cash flow to MSMEs • UK, EU and other initiatives • Capacity building / support • Conclusion Qatar Financial Centre Regulatory Authority 2 EVOLUTION OF THE WORK OF THE BASEL COMMITTEE ON BANKING SUPERVISION Basel I - Market risk amendment Basel II Basel 2.5 Basel III - Amendment Qatar Financial Centre Regulatory Authority Issued July 1988 December 1996 Implemented December 1992 December 1997 June 2004 July 2009 December 2010 December 2007 December 2011 January 2013 – January 2019 January 2013 June 2011 3 THREE PILLARS OF BASEL II / III Pillar 1 Minimum capital requirements: Requirements based on market, credit and operational risk to: (a) reduce risk of failure by cushioning against losses, and (b) provide continuing access to financial markets to meet liquidity needs, and (c) provide incentives for prudent risk management Pillar 2 Supervisory Review: Qualitative supervision by regulators of internal bank risk control and capital assessment process, including ability to require banks to hold more capital than required under Pillar I Pillar 3 Market Discipline: Public disclosure and transparency requirements Qatar Financial Centre Regulatory Authority 4 KEY BUILDING BLOCKS OF BASEL III Increased Quantity / Quality of Capital Countercyclical Capital Buffer Conservation Capital Buffer Additional requirements for Global and Domestic Systemic Banks Global Liquidity Standards Leverage Ratio Qatar Financial Centre Regulatory Authority 5 IMPLEMENTATION OF BASEL III 2011 2012 2013 2014 2015 2016 2017 Parallel run 1 January 2013 – 1 January 2017 Leverage ratio Disclosure starts 1 January 2015 3.5% 4.0% 4.5% Capital Conservation Buffer Minimum common equity plus capital conservation buffer 3.5% Phase-in deductions from CET1 (including amounts exceeding the limit for DTAs, MSRs and financials) As of 1 Jan 2019 Migration to Pillar 1 Supervisory monitoring Minimum Common Equity Capital Ratio 2018 4.5% 4.5% 4.5% 4.5% 0.625% 1.25% 1.875% 2.5% 4.0% 4.5% 5.125% 5.75% 6.375% 7.0% 20% 40% 60% 80% 100% 100% Minimum Tier 1 Capital 4.5% 5.5% 6.0% 6.0% 6.0% 6.0% 6.0% Minimum Total Capital 8.0% 8.0% 8.0% 8.0% 8.0% 8.0% 8.0% Minimum Total Capital plus conservation buffer 8.0% 8.0% 8.0% 8.625% 9.25% 9.875% 10.5% Capital instruments that no longer qualify as non-core Tier 1 or Tier 2 capital Phased out over 10 year horizon beginning 2013 Liquidity coverage ratio Observation period begins Net stable funding ratio Observation period begins Qatar CentreEquity Regulatory CET1Financial = Common Tier Authority 1; DTAs = 60% 70% 80% 90% 100% Introduce minimum standard Deferred Tax Assets; MSRs = Mortgage Servicing Rights 6 BASEL COMMITTEE ON BANKING SUPERVISION – CURRENT AGENDA* Medium term agenda • Completing the crisis-related overhaul of the policy framework by end-2014, including: – – – – Leverage ratio Net stable funding ratio (NSFR) Securitisation framework, and Fundamental review of the trading book • • • • Boundary between banking and trading book Risk metrics to cover tail risks Market liquidity risk Quantitative Impact Study (QIS) * William Coen, Deputy Secretary General of the Basel Committee – 7th GCC Regulators’ Summit, Doha, 25 February 2013 Qatar Financial Centre Regulatory Authority 7 BASEL COMMITTEE ON BANKING SUPERVISION – CURRENT AGENDA Other work: • Simplicity and comparability: – Internal paper on a refined set of assessment criteria; and – External paper providing neutral analyses of the balance between simplicity, comparability and risk sensitivity in the Basel framework • Large exposures: – Definition – Limits – Split between domestic and foreign sovereigns Qatar Financial Centre Regulatory Authority 8 BASEL COMMITTEE ON BANKING SUPERVISION – CURRENT AGENDA New mandates: • Revising the standardised approaches for: – Credit risk – Operational risk – Interest rate risk in the banking book (IRRBB) Standards Implementation Group (SIG) workplan: • Enhancing the effectiveness of micro and macroprudential supervision Review of Basel III implementation: • The rationale, approach and next steps with regard to the three levels of the Regulatory Consistency Assessment Programme (RCAP) Qatar Financial Centre Regulatory Authority 9 CREDIT RISK Purpose • The purpose of these returns is to: – assess the quality and credit and counterparty risk associated with assets and off-balance sheet activities; – establish the level of provisioning against classified assets, including restructured credit; – analyse the nature and impact of credit risk mitigation techniques used; and – identify the concentration and distribution of credit risk assumed Qatar Financial Centre Regulatory Authority 10 CREDIT RISK Key issues • Use of credit ratings • Prescribed classification of loans and advances and resultant suspension of interest and raising of provisions – Special mention ˗̶ Sub-standard – Doubtful ˗̶ Loss • Provisions for reclassification of restructured credit (never better than Special Mention) • No prescribed general provision • Detailed provisions in respect of credit risk mitigation, including haircuts for security • Credit concentration reported in respect of large exposures, geographies and sectors • Capital “proxy” for branches – 15% of total assets Qatar Financial Centre Regulatory Authority 11 CAPITAL ADEQUACY Purpose To provide a summary and overview of the reporting bank’s exposure to and capital requirements in respect of credit risk, market risk and operational risk To provide a detailed analysis of the reporting bank’s exposure to credit risk, market and operational risk Qatar Financial Centre Regulatory Authority 12 CAPITAL ADEQUACY – SUMMARY INFORMATION – BR 600 • Capital requirements arising from credit, market and operational risk • Definitions of what constitutes common equity tier 1, additional tier 1 and Tier 2 capital • Base minimum required capital and reserve funds Common Equity Tier 1 Capital and Reserve Funds (CET1) Total Tier 1 Capital and Reserve Funds Total Capital and Reserve Funds 4.5% 6.0% 8.0% • Capital Conservation Buffer – proposed at 2.5% comprising of CET 1 Capital and Reserve Funds • Systemically important bank (SIB) capital charge, idiosyncratic bankspecific requirement and countercyclical buffer all at 0% currently Qatar Financial Centre Regulatory Authority 13 CAPITAL ADEQUACY - PRUDENTIAL NORMS Deductions and impairments: • Significant minority investments in banking, securities and other financial entities • Significant investments in commercial entities – Investments higher than 15% of the bank’s capital and reserves for individual significant investments in commercial entities and 60% of the bank’s capital for the aggregate of such investments. The amount to be deducted is the portion of the investment that exceeds the materiality level. Risk weightings: • Equity exposures that are not deducted from capital and are listed on a recognised exchange – risk weighted at 300% • Equity exposures that are not deducted from capital and are not listed on a recognised exchange – risk weighted at 400% Qatar Financial Centre Regulatory Authority 14 CAPITAL ADEQUACY - CREDIT RISK (BR 610) Standardised Approach/Simplified Standardised Approaches adopted Risk Weight Framework – broadly aligned to Basel Capital Framework. Items of national discretion aligned to QCB framework Recognised credit rating agencies – Moody’s; S&P; Fitch For corporates, where credit ratings are unavailable, banks are allowed to use 100% Risk Weighting Preferential treatment for claims on banks – Option 2 of Basel adopted subject to a floor of 20% Commercial Public Sector Entities (PSEs) treated as corporates, i.e. 100% Qatar Financial Centre Regulatory Authority 15 OTHER POLICY ISSUES • MSME definitions – South Africa has at least four – Enterprise Qatar developing definition for Qatar • Taxation and other red tape • Encouraging / facilitating cash flow to MSMEs – UK, EU and other initiatives – Capacity building / support Qatar Financial Centre Regulatory Authority 16 CONCLUSION • Constraints – Risk weighting and CRM constraints – Liquidity: LCR & NSFR • Policy coordination required • Clear and consistent definitions needed • Liquidity and operational support mechanisms essential Qatar Financial Centre Regulatory Authority 17 THANK YOU Qatar Financial Centre Regulatory Authority 18