practical implications of regulatory convergence – lessons from basel ii mary frances monroe...

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Practical Implications of Regulatory Convergence – Lessons from Basel II Mary Frances Monroe Division of Banking Supervision and Regulation Board of Governors of the Federal Reserve System Presentation to CPCU Society Symposium Boston, Massachusetts June 11, 2005

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Page 1: Practical Implications of Regulatory Convergence – Lessons from Basel II Mary Frances Monroe Division of Banking Supervision and Regulation Board of Governors

Practical Implications of Regulatory Convergence – Lessons from Basel II

Mary Frances MonroeDivision of Banking Supervision and RegulationBoard of Governors of the Federal Reserve System

Presentation to CPCU Society SymposiumBoston, MassachusettsJune 11, 2005

Page 2: Practical Implications of Regulatory Convergence – Lessons from Basel II Mary Frances Monroe Division of Banking Supervision and Regulation Board of Governors

Practical Implications of Regulatory Convergence –Goals of Basel II

Goals of Basel II:

Greater risk sensitivity – reliance on a bank’s internal assessments of capital adequacy

Suitability – reflect and support sound credit risk management practices

Incentive Compatibility – improve internal risk management practices and adapt to evolving markets and products

Competitive Equity – promote and enhance a level playing field across international boundaries

Page 3: Practical Implications of Regulatory Convergence – Lessons from Basel II Mary Frances Monroe Division of Banking Supervision and Regulation Board of Governors

Practical Implications of Regulatory Convergence –Goals of Basel II

Goals of Basel II (continued):

Safety and Soundness – ensure consistency with fundamental banking principles

Balance – attempts a reasonable trade-off between enhanced risk sensitivity and implementation burden

Non-cyclicality – capital charges should be relatively stable over the economic cycle

Aggregate capital level – roughly maintain the current amount of capital in the banking system

Page 4: Practical Implications of Regulatory Convergence – Lessons from Basel II Mary Frances Monroe Division of Banking Supervision and Regulation Board of Governors

Practical Implications of Regulatory Convergence –Overview of Basel II

Structure of Basel II:

Pillar I Minimum Capital Requirements

Credit Risk, Operational Risk, and Trading Book components

Importance of Qualifying Criteria for Advanced Approaches Importance of Corporate Governance Structure Importance of Validation

Page 5: Practical Implications of Regulatory Convergence – Lessons from Basel II Mary Frances Monroe Division of Banking Supervision and Regulation Board of Governors

Practical Implications of Regulatory Convergence –Overview of Basel II (continued)

Structure of Basel II:

Pillar II Supervisory Review:

Focus on risks not fully captured in Pillar 1, factors not taken into account under Pillar 1, and external factors

Four key principles

Pillar III Market Discipline/Disclosure:

Materiality

Frequency

Page 6: Practical Implications of Regulatory Convergence – Lessons from Basel II Mary Frances Monroe Division of Banking Supervision and Regulation Board of Governors

Practical Implications of Regulatory Convergence – Lessons from Basel II

Need to balance convergence with flexibility

Basel II goal of convergence of regulatory capital standards and measurement Reality is different national markets Necessitates degree of national discretion in implementation

Accord Implementation Group established to promote consistency in application of Basel II, especially where national discretion exists Address cross-border home-host issues Case studies have been conducted

Page 7: Practical Implications of Regulatory Convergence – Lessons from Basel II Mary Frances Monroe Division of Banking Supervision and Regulation Board of Governors

Practical Implications of Regulatory Convergence – Lessons from Basel II

Importance of Stress Testing and Scenario Analysis

Regulatory minimums are only a starting point

Models are imperfect Models may not capture all material risks Model assumptions/parameters may understate degree of risk Models may be based on backward-looking data

Taking stress conditions and scenarios into account involves both quantitative analysis and qualitative judgment with an enterprise-wide view

Page 8: Practical Implications of Regulatory Convergence – Lessons from Basel II Mary Frances Monroe Division of Banking Supervision and Regulation Board of Governors

Practical Implications of Regulatory Convergence – Lessons from Basel II

Need to supplement risk-based capital standards with other supervisory tools

Importance of leverage ratio

Need for mechanism for early intervention For U.S. banks, this is accomplished through prompt corrective

action Ability of bank to engage in certain activities or expand operations is

constrained if cushion above minimum capital standards is not maintained or bank is deemed to have engaged in unsafe and unsound practices

Page 9: Practical Implications of Regulatory Convergence – Lessons from Basel II Mary Frances Monroe Division of Banking Supervision and Regulation Board of Governors

Practical Implications of Regulatory Convergence – Lessons from Basel II

Importance of Enterprise-wide Risk Management

Risks transcend legal entity/line of business/functional boundaries

Need to consider impact of business line activities and risk-taking decisions on other parts of the organization

Consolidated supervisor must assess impact of different prudential supervision frameworks

Federal Reserve supervision has moved from historical analysis on legal entity basis to more forward-looking assessments of risk management and financial condition of consolidated organization

Page 10: Practical Implications of Regulatory Convergence – Lessons from Basel II Mary Frances Monroe Division of Banking Supervision and Regulation Board of Governors

Practical Implications of Regulatory Convergence – Lessons from Basel II

Importance of quantitative impact studies

QIS 4: U.S. regulators are faced with lower than expected capital levels and broad divergence across firms

Data limitations give rise to need to balance quantitative and qualitative approaches and rely more on the latter in the short term

Loss data collection exercise for operational risk indicates more robust operational risk data collection and increasingly sophisticated approaches to measuring risk

Page 11: Practical Implications of Regulatory Convergence – Lessons from Basel II Mary Frances Monroe Division of Banking Supervision and Regulation Board of Governors

Practical Implications of Regulatory Convergence –Beyond Basel II

Joint Basel/IOSCO Working Group on Trading Activities and Double Default

New option for treatment of counterparty credit risk

Limited recognition of double default

Improvements to the trading book capital regime Boundary between firms’ banking and trading books Prudent valuation guidance Capturing full range of risks of traded positions

Consistent approach to unsettled and failed trades

Page 12: Practical Implications of Regulatory Convergence – Lessons from Basel II Mary Frances Monroe Division of Banking Supervision and Regulation Board of Governors

Practical Implications of Regulatory Convergence –Beyond Basel II

Joint Forum Working Group on Liquidity Risk

Involves banking, securities, and insurance sectors

Focus: promotion of financial stability

Developing paper for publication later this year along three workstreams: Trends in liquidity risk management and supervision Stress testing and contingency funding plans Sources of liquidity risk (especially in stress environments)