14818 capital adequacy

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    7-1 McGraw-Hill/Irwin

    Capital Adequacy

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    Functions of Capital

    Absorb unanticipated losses and preserve confidence

    in the FI

    Protect uninsured depositors and other stakeholders

    Protect FI insurance funds and taxpayers

    Protect DI owners against increases in insurance

    premiums

    To acquire real investments in order to providefinancial services

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    Book Value Definition of Capital

    Also known as accounting net worth

    value of assets minus liabilities as found on the balancesheet.

    value of assets and liabilities at the time they wereplaced on the books or incurred by the firm, l

    losses are not recognized until the assets are sold orregulatory requirements force the firm to make balancesheet accounting adjustments

    In the case of credit risk, these adju

    stmentsu

    su

    ally occu

    rafter all attempts to collect or restructure the loans haveoccurred.

    In the case of interest rate risk, the change in interest rateswill not affect the recognized accounting value of the assetsor the liabilities.

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    Economic Definition of Capital

    difference between the market value of assets and the

    market value of liabilities

    The loss in value caused by credit risk and interest rate

    risk is borne first by the equity holders, and then by theliability holders

    With market value accounting, the adjustments to equity

    value are made simultaneously as the losses due to these

    risk elements occur. Thus, economic insolvency may berevealed before accounting value insolvency occurs

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    Market Value Accounting

    Market values produce a more accuratepicture of the FIs current financial position Stockholders can more easily see the effects of

    changes in interest rates on the FIs equity, and

    they can evaluate more clearly the liquidationvalue of a distressed FI.

    Arguments against market value accounting market values sometimes are difficult to estimate,

    particu

    larly for smallF

    Is with non-traded assets market value accounting can produce higher volatility in the earnings ofFIs. regulators may close an FI too quickly under the prompt corrective action

    requirements ofFDICIA.

    Argument for MV accountingasset securitization can be used as a means to

    determine value of even thinly traded assets.9-5

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    Leverage Ratio

    The leverage ratio is the ratio of book value ofcore capital divided by the book value of totalassets.

    L = Core capital/Assets

    Core capital is the book value of equity plus

    qualifying cumulative perpetual preferredstock plus minority interests in equityaccounts of consolidated subsidiaries.

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    Leverage Ratio Inadequate as Measure of

    Capital Adequacy

    No guarantee that the depositors are adequatelyprotected. In many cases of financial distress, theactual market value of equity is significantly

    negative by the time the leverage ratio reaches 2percent.

    Using total assets as the denominator does notconsider the different credit and interest rate

    risks of the individual assets. The ratio does not capture the contingent risk of

    the off-balance sheet activities of the FI.

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    Tier I and Tier II Capital

    Tier I capital

    most junior (subordinated) securities issued by thefirm equity and qualifying perpetual preferred stock.

    Tier II capital/ supplementary or secondary capital

    subordinated to deposits and the deposit insurer'sclaims include preferred stock with fixed maturities and long-term debt

    with minimum maturities over 5 years

    The amount of subordinated debt that can counttowards capital cannot exceed 50% of Tier I capital.

    loan loss reserves (up to maximum of 1.25% of risk-

    adju

    sted assets)9-8

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    FDIC Zones

    Zones Total RBC Tier I Leverage Ratio Regulatory

    action

    Well capitalized 10 6 5 None

    Adequately

    capitalized

    10 > RBC > 8 >4 >4 No brokered

    deposits

    Undercapitalized 8 > RBC > 6 4 > T I > 3 4 > LR > 3 several

    Significantly

    Undercapitalized

    6 > RBC > 2 3 > T I > 2 3 > LR > 2

    Critically

    Undercapitalized

    < 2 < 2 < 2

    9-9 McGraw-Hill/Irwin

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    Zone 3 Regulatory Action

    capital restoration plan required

    asset growth restricted,

    approval for acquisitions, branching, and newactivities required

    use of brokered deposits disallowed

    dividends and management fees suspended

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    Functions of Capital

    Zone 3 penalties

    mandatory recapitalization

    restrictions on deposit interest rate

    inter-affiliate transactions

    pay level of officers.

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    Zone 4 Regulatory Action

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    Functions of Capital

    Zone 3 and 4 penalties

    bank placed in receivorship within 90 days,

    payment on subordinated debt suspended

    other activities restricted at the discretion of

    the regulator.

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    Zone 5 Regu

    latory Action

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    Why use Leverage Ratio

    stringency of regulatory monitoring is increased

    bank can reduce its capital requirement by adjusting

    its portfolio

    leverage ratio test sets a minimum required capital

    level

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    Capital Requirements of the Basel Accord

    capital of banks must be measured as an average of

    credit-risk-adjusted total assets both on and off the

    balance sheet.

    The total risk-based capital ratio divides total capitalby the total of risk-adjusted assets.

    This ratio must be at least 8 percent for a bank to be

    considered adequately capitalized.

    at least 4 percent of the risk-based assets must be

    supported by core capital.

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    Basel I vs Basel II

    Basel I criticized since individual risk weights dependon broad borrower categories

    All corporate borrowers in 100% risk category

    Basle II widens differentiation of credit risks Refined to incorporate credit rating agency assessments

    Both have off-balance-sheet contingent guarantycontracts

    Conversion factorsu

    sed to convert into credit equ

    ivalentamountsamounts equivalent to an on-balance-sheetitem

    Conversion factors used depend on the guaranty type.

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    Category 1 (0% weight)

    Cash, Federal Reserve Bank balances, securities of the U.S.Treasury, OECD

    governments, and some U.S. agencies.

    Category 2 (20% weight) Cash items in the process of collection, U.S. and OECD interbank deposits

    and guaranteed claims.

    Some non-OECD bank and government deposits and securities

    General obligation municipal bonds.

    Some mortgage-backed secu

    rities, Claims collateralized by the U.S.Treasury and some other government securities.

    Category 3 (50% weight)

    Loans fully secured by first liens on one- to four-family residential

    properties.

    Other (revenue) municipal bonds.

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    RBC under Basel I

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    Category 4 (100% weight)

    All other on-balance-sheet assets not listed

    above, including loans to private entities and

    individuals, some claims on non-OECD

    governments and banks, real assets, and

    investments in subsidiaries.

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    RBC under Basel I

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    Category 1 (0% weight)

    Cash, Federal Reserve Bank balances, securities of the U.S.

    Treasury, OECD governments, some U.S. agencies, and

    loans to sovereigns with an S&P credit rating ofAA- or better.

    Category 2 (20% weight)

    Cash items in the process of collection.

    U.S. and OECD interbank deposits and guaranteed claims.

    Some non-OECD bank and government deposits and securities. General

    obligation municipal bonds. Some mortgage-backed securities. Claims collateralized by the U.S.

    Treasury and some other government securities.

    Loans to sovereigns with an S&P credit rating ofA+ to A-

    Loans to banks and corporates with an S&P credit rating ofAA- or better.

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    RBC under Basel II

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    Category 3 (50% weight) Loans fully secured by first liens on one- to four-family

    residential properties

    Other (revenue) municipal bonds.

    Loans to sovereigns with an S&P credit rating ofBBB+ toBBB-

    Loans to banks and corporates : S&P credit rating ofA+ toA-

    Category 4 (100% weight)

    Loans to sovereigns with an S&P credit rating ofBB+ to B- Loans to banks with a credit rating ofBBB+ to B-

    Loans to corporates with a credit rating ofBBB+ to BB-

    All other on-balance-sheet assets not listed above, includingloans to private entities and individuals, some claims onnon-OECD governments and banks, real assets, andinvestments in subsidiaries.9-19

    RBC under Basel II

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    Category 5 (150% weight)

    Loans to sovereigns, banks, and securities firms

    with an S&P credit rating below B-

    Loans to corporates with a credit rating below

    BB-

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    RBC under Basel II

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    Calculating On-balance Sheet RWA

    Assets assigned to five categories of credit riskexposure

    Dollar amount of assets in each category is multiplied

    by the appropriate risk weight 5 categories representing no risk to full credit risk

    Risk Weights are 0 percent, 20 percent, 50 percent, 100percent, and 150 percent, respectively

    The weighted dollar amounts of each category areadded together to get the total credit-risk-adjusted on-balance-sheet assets

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    Calculating Off-balance Sheet RWA

    Convert off-balance-sheet items to credit equivalent

    amounts of an on-balance-sheet item

    multiply the notional amounts by an appropriate

    conversion factor

    The converted amounts are then multiplied by the

    appropriate risk weights as if they were on-balance-

    sheet items.

    appropriate risk weights depend on the counterparty risk

    to off-balance-sheet activity

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    Conversion Factors for Off-Balance-Sheet,

    Contingent or Guaranty

    Contracts:

    B

    asel I andBasel II Sale and repurchase agreements and assets sold with

    recourse that are not included on the balance sheet(100%)

    Direct-credit su

    bstitu

    te standby letters of credit (100%) Performance-related standby letters of credit (50%)

    Unused portion of loan commitments with originalmaturity ofmore than one year (50%)*

    Commercial letters of credit (20%) Bankers acceptances conveyed (20%)

    Other loan commitments (10%)

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    Pillars ofBasel Accord (II)

    Pillar 1 :Maintain and update regulatory capital

    requirements for credit, market and operational risk.

    Pillar 2: Stress the continued importance of the

    regulatory evaluation process in addition to capitalrequirements.

    In particular ensuring that the bank has valid internal control

    procedures in place to measure and manage risk.

    Pillar 3: Promote disclosure of the institutions capitalstructure, risk exposure and capital adequacy.

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    Criticisms of Risk-based Capital Ratio

    1. Risk weight categories versus true credit risk.

    2. Risk weights based on rating agencies3. Portfolio aspects: Ignores credit risk portfolio

    diversification opportunities.

    4. DI Specialness

    1. May reduce incentives for banks to make loans.

    5. Excessive complexity

    6. Other risks: Interest Rate, Foreign Exchange, Liquidity

    7. Impact on capital requirements

    8. Competition and differences in standards

    9. Pillar 2 demands on regulators

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    Homework Assignment

    practice questions in handout

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