14818 capital adequacy
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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
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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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