basel 2 to basel 3 - proposed changes and required amendments
TRANSCRIPT
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
1/24
Basel 2 to Basel 3
Proposed Changes and Required Amendments
Basel 2 to Basel 3 -
Proposed Changes and
Required Amendments
13th July 2011
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
2/24
Amendments to Basel 2 Page 1
Amendments to Basel 2(taken from the 3 July 2009 Basel 2 papers)
The changes listed below are to be brought into effect by 31.12.2011 in the
EU and G20 countries. Subsidiaries of Bahraini banks in these countries willbe obliged to comply with these measures even if their head offices do not.
Trading Book
New stressed VaR requirement (for one year period) for banks usingVaR models in the trading book
New incremental risk capital charge (default & migration risk) for IRBbanks
Capital charges used in the banking book must be applied to securitisedproducts in the trading book to avoid regulatory arbitrage (see page 6 ofJuly doc)
Removal of concessionary 4% RW treatment for liquid anddiversified portfolios
Complex Securitisations
Resecuritisations obtain higher risk weights in the banking bookSecuritisation Resecuritisations
AAA 20% 40%
A+ to A- 50% 100%
BBB+ to BBB- 100% 225%
BB+ to BB- 350% 650%B+ to unrated Deduction Deduction
No self-guarantees allowed to improve credit ratings of securitiesguaranteed by the bank itself when such securities are held on the
banks own books
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
3/24
Amendments to Basel 2 Page 2
Operational criteria must be applied before banks may use above riskweights in the Basel 2 securitisation framework. Otherwise all holdingsof securitisations must be deducted from capital
Standard 50% CCF for liquidity facilities in the securitisationframework (no more concessionary risk weights)
Enhanced Pillar Two requirements for ICAAPs and internal controls
generally
This means the need for new Pillar 2 modules in the Rulebook (theCBB drafted a module called SR in 2008, but this was never released)
Enhanced Pillar Three requirements
Enhanced disclosures for securitisations and credit risk mitigants
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
4/24
Basel 3 changes Page 1
Basel 3 changes(Paragraph references from December 2010 Basel paper)
1. Capital Ratio
Tier One (6% of total RWAs)paragraphs 50, 53
A. Minimum common equity 4.5% of total RWAs (by 1.1.2015) after
all deductions below (including unaudited/audited losses or audited
profits for current period plus all eligible reserves). Paragraph 52
There are tougher requirements for Common Equity: Common shares only and must be recognised as equity by
accounting standards
Most subordinated claim, not fixed or capped Perpetual and never repaid outside liquidation No features that encourage buy-backs, redemption or
cancellation
Distributions not contractually capped or linked to amountpaid in
No obligatory or preferential payment of dividend (which cancreate a technical event of default)
Issued and paid up Unsecured, unguaranteed Only issued with explicit shareholders approval May include share premium, retained earnings and p&l
Deductions from common equity (full deduction by 1.1.2018)
Intangibles (paragraph 67) Investments in own shares (paragraph 78) Any outstanding Tier 1 instruments that do not meet the definition
of common equity (w.e.f. 1.1.2013)
Minority interests in financial subsidiaries (see section G) Deferred tax assets (paragraphs 69 & 70) Mortgage servicing rights
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
5/24
Basel 3 changes Page 2
Cash flow hedge reserves for items not fair valued (paragraphs 11,71 & 72)
Any shortfall of provisions to expected losses under IRB(paragraph 73)
Gains on sales due to securitisation transactions (paragraph 74) Unrealised gains arising from changes in the fair value of liabilities
caused by changes in the banks own credit risk/rating(paragraph 75)
Defined pension fund assets and liabilities (paragraph 76) Reciprocal cross shareholdings in the capital of financial and
insurance entities (paragraph 79)
Investments in the capital of other financial and insurance entitieswhere the bank owns < 10% of the issued common share capital ofthat entity (applies to both trading and banking book). If the
aggregate of all holdings listed above exceed 10% of the bankscommon equity (after applying all other deductions), then the
amount exceeding 10% of the concerned banks capital (of suchholdings) must be deducted applying a corresponding deduction
approach (i.e. common equity from common equity, tier two fromtier two). Amounts below the 10% threshold will continue to be
risk-weighted (paragraph 80 & 81)
Investments in the capital of other financial institutions andinsurance companies where the bank owns > 10% of the issuedcommon capital of the entity (applies to trading and banking book).
All such investments must be deducted (paragraphs 84 86) afterabove deductions where the aggregate of such investments exceeds
15% ofa bankscommon equity. There must be full disclosure ofthese deductions. Any (remaining) holdings below 15% of capital
will be weighted at 250% (paragraph 89).
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
6/24
Basel 3 changes Page 3
B. Net Common Equity
Amount A after all deductions above
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
7/24
Basel 3 changes Page 4
C. Additional Going Concern Capital paragraph 54 and 13J anuary 2011 Annex
There are enhanced criteria for classification as additionalGoingConcern Capital
Issued & paid up Subordinated to depositors, general creditors and subordinated
debt
Not secured or guaranteed Perpetual and no step-ups or other incentives to redeem Callable only at initiative of issuer after minimum 5 years,
subject to prior supervisory approval
Documentation should not create the expectation of a call by theissuer
Call cannot be made without bank concurrently replacing capitalwithout issuance of capital of same or better quality, and capitalmust be well above minimum required capital level
Coupon payments must be discretionary Cancellation of payments must not constitute an event of default Cancellation of payments must not put restrictions on the bank Dividend only payable out of distributable items No credit sensitive dividend payment features Must be convertible at the option of the supervisory authority to
common equity or to be written down in value (e.g. by reducing
the amount repaid at call point), or contain a write-down feature
which allocates losses to the instrument before tax payers are
exposed to loss* (see bullet point below)
Issuer and connected counterparties may not have purchased theinstrument, nor can the bank have funded the purchase of the
instrument
No compensation features if other similar instruments aresubsequently issued at a lower price
Proceeds must be immediately available without limitation(e.g. from an SPV that is part of the consolidated group)
May include share premium
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
8/24
Basel 3 changes Page 5
The convertibility feature above must be supported by a law (not adirective) that the instrument must be written off/down or fullyabsorb losses before tax payers (i.e. the Government) are exposed
to loss. Furthermore, there must be a peer group review to confirm
that such laws are in place and both the bank and the regulator (inissuing documents) disclose that these instruments are loss-bearing.
Only common stock may be issued to instrument holders (i.e. nopayment of cash or other compensation may be given) if a
trigger event (see bullet point below) occurs.
The bank must have all approvals to issue common equity to theamount required should a trigger event occur.
A trigger event is the earlier of: (1) a decision that a write-off(without which the bank would be unviable) is necessary, as
determined by the supervisor; or (2) the decision to make apublic sector injection of capital (or equivalent support) withoutwhich the bank would have become unviable (as determined by
the supervisor).
Deduct investment in own shares. Deduct holdings of such instruments issued by other financial and
insurance entities which do not exceed 10% of the investees
capital, but which in aggregate exceed 10% of the concerned bankscapital (paragraph 80).
All instruments issued after 1 January 2013 must meet the abovecriteria to be included in regulatory capital. Instruments issuedprior to 1 January 2013 that do not meet the criteria above will be
phased out from 1 January 2013 (90% cap in 2013, reducing by10% per annum). Instruments with early calls or step-ups will not
generally be recognised as regulatory capital.
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
9/24
Basel 3 changes Page 6
D. Total Tier One Capital
Item B plus item C
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
10/24
Basel 3 changes Page 7
E. Tier Two Capital (i.e. gone concern capital)
paragraphs 57 & 58 and 13 January Annex
There are simplified and tougher requirements for Tier 2:
Issued and paid in Subordinated to depositors and general creditors Unsecured and not guaranteed Minimum maturity of 5 years with straight line amortisation over last
five years to maturity
No redemption incentives Callable only at the initiative of issuer after minimum of five years Early calls subject to prior supervisory approval No expectation of early calls to be created by the documentation Calls may not be exercised unless capital of the same or better quality is
issued concurrently and the issuer demonstrates its capital is well above
minimum required
Investors may not accelerate the repayment of payments (except inbankruptcy or liquidation)
No credit sensitive dividend feature The issuer and its related parties may not have purchased or funded the
purchase of the instrument
Proceeds must be immediately available without limitation(where raised by an SPV that is part of the consolidated group)
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
11/24
Basel 3 changes Page 8
Interim unaudited profits for the current period will still be allowed Expected loss approach to provisioning still under review, but general
provisions up to 1.25% of credit risk weighted assets (i.e. not including
operational risk or market risk charges)paragraphs 60
61
Includes stock surplus (i.e. premium) Deduct holdings of own Tier 2 capital Must be convertible at the option of the supervisory authority to
common equity or to be written down in value (e.g. by reducing theamount repaid at call point), or contain a write-down feature which
allocates losses to the instrument before tax payers are exposed to loss*
(see bullet point below)
The convertibility feature above must be supported by a law (not adirective) that the instrument must be written off/down or fully absorblosses before tax payers (i.e. the Government) are exposed to loss.
Furthermore, there must be a peer group review to confirm that suchlaws are in place and both the bank and the regulator (in issuing
documents) disclose that these instruments are loss-bearing. Only
common stock may be issued to instrument holders (i.e. no payment of
cash or other compensation may be given) if a trigger event (seebullet point below) occurs. The bank must have all approvals to issue
common equity to the amount required should a trigger event occur.
A trigger event is the earlier of: (1) a decision that a write-off (withoutwhich the bank would be unviable) is necessary, as determined by the
supervisor; or (2) the decision to make a public sector injection ofcapital (or equivalent support) without which the bank would have
become unviable (as determined by the supervisor).
All instruments issued after 1 January 2013 must meet the above criteriato be included in regulatory capital. Instruments issued prior to 1
January 2013 that do not meet the criteria above will be phased outfrom 1 January 2013 (90% cap in 2013, reducing by 10% per annum).
Instruments with early calls or step-ups will not generally be recognisedas regulatory capital.
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
12/24
Basel 3 changes Page 9
Tier Three
(Abolished).
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
13/24
Basel 3 changes Page 10
F. Total Capital (w.e.f. 1.1.2015)
This is the sum of D and E above. Banks must have a Minimum ratioof 8%, of which 6% must be Tier One. Remaining 2% can be met by
Tier 2 (paragraph 50)
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
14/24
Basel 3 changes Page 11
G. Minority Interests (paragraph 62)
Minority interests in the common equity Tier One of a fullyconsolidated subsidiary may receive recognition in Common Equity
Tier One if:
The instruments meet all the criteria for common equity The subsidiary is a bank (i.e. not an SPV) The subsidiary has a surplus above its minimum Tier One capital
requirements
The surplus is added after deducting: a) the lower of the requiredminimum common equity Tier One plus its capital conservation
buffer; or the proportion of consolidated minimum common equityTier One plus the capital conservation buffer that relates to the
subsidiary; and b) the amount of surplus Common Equity Tier Oneattributable to the minority shareholders.
Minority interests attributable to other Tier One and Tier Two Capital
instruments will be allowed under similar conditions (see paragraphs63 and 64).
Capital issued by SPVs can be included in consolidated AdditionalTier One and Tier Two capital, but not in Common Equity
(paragraph 65).
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
15/24
Basel 3 changes Page 12
H. Countercyclical Buffers (0-2.5% of RWAs)
The size of the Buffer is set by the regulator and must take account ofmacroeconomic environment in which the bank(s) operate. This maymean that wholesale banks and retail banks will legitimately have
different buffers
Although each jurisdiction must decide for itself on the extent of thebuffer, there are references and principles to follow (FSD of the CBB
will have to be involved to apply individual buffers or the CBB maysimply impose an industry wide percentage)
The buffer is a function of the weighted average of capital buffer add-ons applied in each jurisdiction where the bank has exposure(this process could potentially be very complex for some banks)
The countercyclical buffer would increase the 2.5% capital conservationbuffer (see next page) by up to an additional 2.5% during periods ofexcessive credit growth
Buffer can be released when the released capital would absorb losses inthe system that pare a threat to financial stability
Banks will be forced to conserve earnings where the buffer is belowthat required by the supervisor(paragraph 147)
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
16/24
Basel 3 changes Page 13
J. Capital Conservation Buffer (2.5% of RWAs)
Capital in excess of minimum to be used in times of stress (2.5% - mustbe common equity)
Constraint on dividends, share buybacks and bonuses (subject to 100%conservation ratio (paragraph 131) if CET1 below 5.125% and sliding
conservation scale up to 7% CET1 ratio)
Phased in from 1.1.2016 to 1.1.2019
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
17/24
Basel 3 changes Page 14
K. New Risk Weightings
A 1,250% Risk Weight will apply for the following items:
Securitisation (and resecuritisations) exposures B+ or below Certain Equity exposures under the PD/LGD approach Non-payment/delivery on non Delivery versus payment transactions Significant investments in commercial entities (above 15% of capital
base)paragraph 90
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
18/24
Basel 3 changes Page 15
2. Leverage Ratio
Based on Tier One Capital only (but subject to review)
Off-balance sheet items subject to uniform 10% CCF All derivatives will be subject to Basel 2 netting plus PFE Minimum 3% ratio (w.e.f. 1.1.2018)i.e.
Tier One Capital .
Unweighted on-balance sheet + 10% off-balance sheet assets
Disclosure of the leverage ratio will start w.e.f. 1.1.2015 Calculation will be on an average basis over the reporting quarter
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
19/24
Basel 3 changes Page 16
3. Counterparty credit risk(paragraph 98 onward)
Stressed inputs to be used
Elements of counterparty risk charges are related to MTM losses as aresult of the fall in the creditworthiness of a counterparty
Collateral and margining requirements strengthened Increase in risk weights on financial institutions An additional capital charge (the CVA)
These changes only apply to banks using the internal model method.
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
20/24
Basel 3 changes Page 17
4. Liquidity
Liquidity Coverage Ratio 30 day stressed funding scenario set bysupervisor dictates level of high quality liquid assets to be held at all
times (w.e.f. 1.1.2015)
Net Stable Funding Ratio (w.e.f. 1.1.2018)
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
21/24
Basel 3 changes Page 18
5. New Disclosure Requirements (paragraph 9193)
Full reconciliation of all regulatory capital elements to the balance sheet
Separate disclosure of all regulatory adjustments Disclosure of all capital limits and minima Description of main features of capital instruments Disclosure of Equity Tier One ratio as well as other capital ratios
(Tier One, Total)
Any transitional provisions
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
22/24
Summary of Basel 3 Page 1
Summary of Basel 3
1. Raise Quality of Capital Base
Raise Quality of Common Equity (2013). Abolish Innovative Instruments from Tier One and only allow
Going Concern/Loss Participating Tier One instruments (2013).
Additional deductions from Tier One (2014 onward). Simplify and toughen Tier Two Capital (2013). Only limited inclusion of non-equity elements in Tier One.
2. Enhanced capital charges for securitisation and off-balance sheet
exposures (December 2011)
July 2009 securitisation and trading book requirements. New counterparty credit risk charges and requirements.
3. New 3% Leverage Ratio (2015)
Based on Tier One Capital only. Will include off-balance sheet exposures at 10% CCF.
4. New Liquidity Standards
Liquidity Coverage Ratio (2015). Net Stable Funding Ratio (2018).
5. New Capital Buffers
Capital conservation buffer (2.5% of RWAs starting 2016 2019).
Countercyclical buffer (0-2.5% of RWAsno set date). Also forward looking provisioning may play a role (expected loss
approach to be explored).
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
23/24
Revised Basel 3 Page 1
Revised Basel 3
Capital Components and Capital Adequacy Calculation
Step-by-step
The items below the revised components of eligible regulatory capital.
1. Common Equity plus disclosed reserves (using new criteria in17/12/2009 Basel Paper) including unaudited or audited losses and
including audited profits for the current periodunrealised gains to be
included at 45% as previously or at CBB discretion
2. Regulatory Deductions from Common Equity:a) Deduction of minority interests in subsidiaries (no longer
included in Common Equityassume worst case).
b) Deduction of goodwill and all other intangibles.c) Deduction of any deferred tax assets (should normally only apply
to foreign subsidiaries).
d) Deduction of any investments in own shares (treasury stock), anyown share purchases funded by the bank (e.g. employee stockincentive programs).
e) Deduction of investments in the capital of financial institutions (including banking and insurance and investment business
institutions). This deduction will include all holdings ofcommon equity in other financial institutions which are less
than 10% of the concerned financial institutions capital (above a10% threshold for the reporting bank). The full amount of such
holdings (above the 10% own funds threshold) must be deductedfrom the reporting banks common equity. Secondly, the holdings
of all common stock in all other financial institutions above 10% of
the investees capital must be aggregated (after performingthe above deduction). Where the aggregate of any such
holdings exceeds 15% of the reporting banks common equity,
then the amount over 15% of the reporting banks common equity
-
7/28/2019 Basel 2 to Basel 3 - Proposed Changes and Required Amendments
24/24
R i d B l 3 P 2
must be deducted. Note that these deductions will apply
irrespective of the location of the exposure in the trading book or inthe banking book.
3. Common Equity after regulatory deductions (Item 1 less item 2)4. Additional Going Concern Capital (using new criteria for most
banks this should be a zero item, but certain preference shares or other
loss-bearing instruments may be included here subject to the new Basellimits)
5. Total Tier One Capital (Item 3 plus item 4 but subject to cap)6. Tier Two Capital (subject to 2% cap and using new conditions)7. Total Eligible Capital (Item 5 plus item 6)8. Risk-Weighted Assets
Calculate total risk weighted assets for the banking book, the tradingbook and operational risk as under existing PIR/Rulebook
requirements, but note that all significant investments in commercialentities above 15% of capital base must be risk-weighted at 1,250%.
Assume no grandfathering of concessions.
9. Calculation of Capital RatiosCalculate the following ratios:
a) Common Equity Capital Ratio (Item 3 divided by item 8)b) Tier One Capital Ratio (Item 5 divided by item 8)c) Total Capital Ratio (item 7 divided by item 8)
For the solo capital adequacy calculation, all shareholdings in subsidiariesmust be deducted from common equity in addition to the deductions made in
item 2e) above. Also all risk-weighted assets of subsidiaries for items 7 and
8 above must be deducted from the risk-weighted asset base of the reportingbank, prior to calculation of the solo capital ratios.