Basel II -A

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    .

    State Bank of Pakistan

    Basel Capital Accord

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    Basel Capital Accord

    State Bank of Pakistan

    Background

    1. Bank for International Settlements Based in Basel and created in 1930, the BIS is the worlds oldest international

    financial institution

    Its mission is to foster cooperation among central banks and other agencies in

    pursuit of monetary and financial stability

    Fosters regulatory and supervisory convergence across jurisdictions and financial

    sectors

    2. Basel Committee on Banking Supervision Voluntary Association

    No formal supra-national authority Output series of Broad supervisory guidelines and Statements of best practices

    Desired outcome: Convergence in Standard

    3. Most Significant guidelines of BCBS is Capital AdequacyStandards commonly known as Basel I & Basel II

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    A Standard for the Measurement of Risks in Banks,

    and for the Allocation of Capital to cover those risks

    Published by the Basel Committee on BankingSupervision

    Basel Capital Accord

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    Why Capital requirement for banks

    Unexpected

    loss

    Expected

    Loss

    Probabil

    ity

    Amount

    Extreme Loss

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    Background Basel-I

    State Bank of Pakistan

    Basel I or Capital Accord 1988o The First ever internationally accepted standard for minimum capital

    requirement for Banks

    o Though meant for G-10 countries, accepted and adopted by most of theeconomies.

    o Prescribe a simple framework for the calculation of minimum capitalrequirement for banks.

    Capital (Asset X Risk Weight) X 8%

    Broadly defined risk weights on the basis of asset class : 0, 20, 50, 100% For instance

    CashBalance with Banks

    Mortgage Finance

    0%20%

    50%

    Loans to private firms 100%

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    Capital > 8%

    Risk weighted assets

    The Basic Formula

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    Background Basel-I

    Bank

    Risk

    Weights Risk Weighted Assets

    Assets A B C A B CCash 10 5 35 0% 0 0 0

    Balance with other Banks 65 45 20 20% 13 9 4

    Investments

    Government Securities 110 200 70 0% 0 0 0Private sector debentures, Bonds, PTCs etc. 30 30 80 100% 30 30 80

    Other Investments 10 0 40 100% 10 0 40

    Advances

    Federal Government 80 10 50 0% 0 0 0

    Private Sector 200 170 100 100% 200 170 100

    Secured against mortgage of residential or commercial property 20 80 40 50% 10 40 20

    Consumer Financing 80 100 200 100% 80 100 200

    Other Assets 45 10 15 100% 45 10 15

    Total Assets 650 650 650 388 359 459

    Capital Requirements 10% of RWA 39 36 46

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    Basel II - Overview

    Weaknesses of Basel I Did not assess capital adequacy in relation to a banks true risk profile

    Broad-brushed risk weighting structure does not differentiate high risk orlow risk transactions within an asset class

    Created an incentive to take some highest quality assets off the balancesheet

    Covered only credit risk across bank and market risks only in trading book(Interest rate risk in banking book, credit concentration risk, etc were ignored and operational risk assumed to

    be covered in credit risk capital charge)

    Despite these weaknesses remained global standard for almost a decade

    Firm X

    Weak Financial positionRating BB

    Firm Y

    Strong Financial position

    Rated AAA

    Both assigned

    100% risk Weight

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    Basel II - Overview

    Greater Risk SensitivityBroad Brush

    Menu of ApproachesOne Size Fits All

    Three PillarsFocus on Single

    Measure (Capital)

    2005: Basel II1988: Basel I

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    Basel IIScope of Application

    State Bank of Pakistan

    10

    Diversified Financial Group

    Holding Company

    InternationallyActive Bank

    Internationally

    Active Bank

    Internationally

    Active Bank

    Domestic

    Bank

    Securities

    Firm

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    Basel IIOverall framework

    State Bank of Pakistan

    Three Mutually Reinforcing Pillars

    Pillar 3: Market

    Discipline

    Pillar 2: Supervisory

    Review Process

    Pillar 1: Minimum

    Capital Requirement

    Definition of CapitalRisk Weighted Assets

    Credit Risk Market RiskOperational Risk

    Internal

    Rating Based

    Basic Indicator

    Approach

    Standardized

    ApproachAMA

    Standardized

    Approach

    Internal Model

    Based Approach

    Supplementary

    Capital

    Core Capital

    Standardized

    Approach

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    Basel IIPillar 1 Capital Charge for Credit Risk

    Each exposure is assigned a risk weight pursuant to the risk assessmentof External Rating agency

    Least sophisticated capital calculations; generally highest capital burdens

    Standardised Approach

    Foundation IRB Approach

    Advanced IRB Approach

    Risk weights are calculated using a standard formula. Input parameters

    to the formula known as risk components are

    probability of default (PD) loss given default (LGD), exposure at default (EAD) and maturity (M).

    More risk sensitive capital requirements

    Same as FIRB Approach except the risk components are to be calculatedby the banks themselves

    Most risk-sensitive (although not always lowest) capital requirements

    Transition to Advanced IRB status only with robust internal riskmanagement systems and data

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    Basel IIMajor changes

    Credit Risk + Market Risk + Operational Risk.

    Total CapitalCapital Ratio =

    8% Minimum CAR

    Unchanged

    New Risk CapitalCharge

    DefinitionUnchanged

    No

    ChangeRWA Calculation

    Revised

    Major change is the calculation of risk weighted assets for credit risk

    Besides Basel II prescribes a framework for risk management and

    allocation of capital against other risks

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    Basel IIPillar 1 Minimum Capital Requirement

    Definition of Capital (unchanged)

    Tier 1 : Core Capital Equity

    Disclosed reserves

    Instruments eligible under October 1998 press release

    Tier 2 : Supplementary Capital (limited to 100% Tier 1) Undisclosed reserves

    Revaluation reserves

    General provisions/general loan loss reserves

    Hybrid instruments

    Subordinated debt ( lower tier 2)

    Tier 3 : ( for market risk) short term subordinated debt

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    Based upon ECAIs long-term domestic rating for

    domestic and foreign currency obligations.

    Credit

    Assessment

    AAA

    to

    AA-

    A+

    to

    A-

    BBB+

    to

    BBB -

    BB+

    to

    B-

    Below

    B-

    Un -rated

    Risk

    weighting

    0% 20% 50% 100% 150% 100%

    Claims on Sovereigns

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    At national discretion, supervisors may allow the use of

    ratings from Export Credit Agencies

    Available for a far greater number of sovereigns.

    ECA Risk

    Score

    1 2 3 4 to 6 7

    Risk

    Weighting

    0% 20% 50% 100% 150%

    Claims on Sovereigns

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    National Discretion : Preferential treatment (e.g. 0%risk weight ) can apply to

    Exposures in domestic currencies to a banks ownsovereign (and central bank ) under the condition that

    exposures are also funded in national currency

    Preconditions for the own sovereigni. Claim on the own sovereign

    ii. Exposure denominated in domestic currency

    iii. Exposure funded in domestic currency

    Claims on Sovereigns

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    Bank in Pakistan, exposure to Government of Pakistan,

    denominated and funded in Pak Rupees

    Pak. Rs. Pak. Rs. Pak.Rs.

    Gov. 100

    Other 600

    US$ 200

    Cap. 100

    Liab. 200

    US$ 600

    Gov. $ 100

    Other 600

    US$ 200

    Cap. 100

    Liab. 200

    US$ 600

    Gov. $ 100

    Other 600

    US$ 200

    Cap. 100

    US$ 800

    Preferential treatment for

    government claim

    Yes

    Preferential treatment for

    government claim

    No

    Preferential treatment for

    government claim

    No

    Preferential Treatment: Example

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    Other supervisors may also permit their banks to applythe same risk weighting (i.e. if Pakistan applies 0%,

    Hong Kong can follow)

    Bank in Hong Kong

    Assets Liabilities

    Gov. of Pakistan 500 Pak.Rs.

    Other assets 1,200 HK$

    Capital 300 HK $

    Liabilities 500 Pak.Rs.

    Liabilities 900 HK $

    Preferential Treatment: Example

    Claims on central banks , BIS, ECB, IMF will receive the lowest risk weight

    applicable to sovereigns

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    Two optionssupervisors must apply one

    option to all banks in their jurisdiction

    No unrated claim may receive a risk weight

    less than that of its sovereign.

    Claims on Banks

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    Banks are assigned a RW one category less favorable than that of its

    country of incorporation.

    RW cap at 100% except in countries rated below B-, in which case the

    RW is 150%.

    Credit

    Assessment of

    Sovereign

    AAA

    to

    AA-

    A +

    to

    A-

    BBB+

    to

    BBB-

    BB+

    to B-

    Below

    B-

    Unrated

    Sovereign RW 0% 20% 50% 100% 150% 100%

    Bank Risk

    Weight

    20% 50% 100% 100% 150% 100%

    Claims on Banks including securities firms: Option 1

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    Based upon the credit assessment of the bank itself.At national discretion a preferential treatment exists for

    claims of 3 months or less (original maturity), subject to a

    floor of 20%. Not available to banks rated below B-.

    Credit Assessment

    of banks

    AAA

    to

    AA-

    A + to

    A -

    BBB+

    to

    BBB-

    BB+

    to

    B-

    Below B- Unrated

    Risk Weight 20% 50% 50% 100% 150% 50%

    Risk Weight ST

    claim

    20% 20% 20% 50% 150% 20%

    Claims on Banks including securities firms: :Option 2

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    Risk weighted similar to banks under option 2

    0 % risk weight is possible ( as determined by the Basel

    Committee) for MDBs

    o Majority of the external assessments are AAA;

    o Shareholder structure is significantly comprised of

    sovereigns with long term issuer credit assessment of

    AA or better;

    o Strong shareholder support (i.e. amount of capital ,

    amount of callable capital);

    o Adequate level of capital and liquidity

    Claims on MDBs

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    Generally treated as a claim on a bank (if using

    option 2 , the ST preferential treatment is not

    available to PSEs)

    At national discretion may be treated as a claim

    on the sovereign in the jurisdiction where

    establishedExample : categorization of PSEs by revenue

    raising power

    Claims on PSEs

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    Based upon comments received from the industry, a 50%RW was added and expansion of 150% RW.

    No unrated claim can receive a RW less than the sovereignRW.

    CreditAssessment AAAto

    AA-

    A+to A- BBB +to BB- BelowBB- Un-rated

    Risk Weight 20% 50% 100% 150% 100%

    Claims on Corporate

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    Risk weight for unrated corporates(100%) is a floor.

    Low rated ( below BB- ) corporates that

    give up their rating in order that the bankcan have a 100 % capital charge will affectthe quality of the un rated borrowerpool;thus a higher RW (higher than 100%)may be necessary.

    Claims on Corporate

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    At national discretion supervisory authorities maypermit banks to risk weight all corporate claims at100 % without regard to external ratings.

    Where this discretion is exercised by supervisor,itmust ensure that banks apply a single consistentapproach i.e to use ratings wherever available or

    not at all.

    Claims on Corporate

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    New lower risk weight for retail portfolio,e.g 35% for residential mortgages

    Past due mortgage loans are weighted at 100%

    75 % for other retail ( 100 %)

    Aggregate exposure to one counterpart cannot exceed0.2% of the overall regulatory retail portfolio

    The banks total exposure to the firm must be less than

    Euro 1 million Past Due claims do not qualify for this preferential

    treatment

    Rules for Retail

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    The unsecured portion of any loan (other thanqualifying residential mortgages loan ) that is pastdue for more than 90 days, net of specific provisions ,

    will be risk weighted as follows:Where specific provisions are less than 20 % ofoutstanding loan amount : risk weight 150 %

    Where specific provisions are no less than 20 % of

    outstanding loan amount : risk weight 100 %Where specific provisions are no less than 50 % ofoutstanding loan amount : risk weight 100 % ,howevermay be reduced to 50 % with supervisory discretion.

    Past Due Exposures

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    All other assets will continue at 100 %

    National Supervisor may decide to applya 150% or higher risk weight to high riskassets (venture capital , private equity)

    Other Claims

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    Off balance-sheet itemscurrent framework willremain in place with a few exceptions Credit conversion for ST commitments (upto one year)

    will be 20 %: over one year 50% . A 0 % RW can be applied if the commitment is

    unconditionally cancelable.

    100% conversion factor applied to repo-styletransactions.

    For short term self liquidating trade letters of credit , a20% CCF will be applied to both issuing and confirmingbanks.

    Other Risk weight issues

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    ECAI must be recognized by the supervisor.ECAIs may be recognized on a limited basis (i.e. typeof claim or jurisdiction).

    Process for recognizing ECAIs must be disclosed.

    Eligibility critieria- Objectivity - Independence- International access - disclosure

    (transparency)

    - resources - credibility

    External Credit Assessment Inst. (ECAI)

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    Mapping Process:- responsibility of the supervisor to map ratings to

    RW in an objective manner;

    - process for mapping must be disclosed bysupervisor;- disclosure by banks of ECAI used by type of claim

    and % of RWA that are based on the assessmentof each ECAI.

    Multiple assessments:- 2 ratingsuse the one resulting in a higher RW;- Multiple ratingsuse the two that correspond to

    the lowest RW and choose the higher RW of thetwo.

    Implementation considerations

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    if a high-quality (maps to a better than unrated RW)issue rating is available from another issue of the sameissuer, it may be used provided that the banks claimranks pari pasu or is more senior; otherwise the claimshould be treated as unrated;If there is an issuer rating, it will typically apply to

    senior claims; consequently, only senior claims can usethe issuer assessment; otherwise, the claim should betreated as unrated.Issue or issuer low quality assessmentuse this rating.

    Issuer versus issue assessment if there is no issuerating available for the banks particular investment:

    Implementation considerations

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    if a high-quality (maps to a better than unrated RW)issue rating is available from another issue of the sameissuer, it may be used provided that the banks claimranks pari pasu or is more senior; otherwise the claimshould be treated as unrated;If there is an issuer rating, it will typically apply tosenior claims; consequently, only senior claims can usethe issuer assessment; otherwise, the claim should betreated as unrated.Issue or issuer low quality assessmentuse this rating.

    Issuer versus issue assessment if there is no issuerating available for the banks particular investment:

    Implementation considerations

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    External assessments from one entity in thecorporate group cannot be used to RW otherentities in the same group.

    Unsolicited ratings- Generally should not be used- At national discretion, they may be used

    - Supervisor should be aware of pressure

    by the ECAI applied to the corporate toobtain a rating- Benefits could widen ratings coverage

    Implementation considerations

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    Supervisors should disclose process for recognizing

    ECAIs

    Supervisors may choose to disclose list ofrecognized ECAIs

    Aim: transparent process for recognizing ECAIs

    Disclosure for supervsiors

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    Banks must disclose

    Credit assessment institution(s) they use

    Mapping process

    Percentage of risk weighted assets mapped into

    single grades

    Disclosure for Banks

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    Grade 1 2 3 4 5 6 7

    Rating AA

    A

    AA A BBB BB+ BB- B

    R W % 20 20 50 100 100 100 150

    % assets 15 10 20 25 15 10 5

    Example

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    Rules for Equity Exposure

    40

    Co

    mpany

    Source: Text

    Basel I

    Equity Exposure

    Non-consolequity

    Type ofExposure

    Risk Weight

    100%

    Standardised bank risk weights

    Corporates

    Banks

    100%*

    100%

    * CRD has preferentialtreatment vs. Basel IIAccord; supervisors mayincrease to 150% for venturecapital and private equityinvestments ( 80)

    PD/LGDModel**

    Securitiesfirms 100%

    92%***

    81%***

    264%

    32%***

    82%***

    195%***

    120%***

    ** Inputs: average ratingagency PDs, LGD of 90%,supervisory value for EADand M of 5.

    DaimlerChrysler

    Siemens

    Fresenius Med. Care

    GE

    Sony

    Vivendi Universal

    Bertlesmann

    290%

    290%

    290%

    290%

    290%

    290%

    290%

    Basel II

    For banking book exposures.National supervisors mayexempt from IRB treatmentfor up to ten years particularequity exposures held atpublication date of Basel IIaccord ( 267)

    Simple Model* Rating

    A3/BBB

    Aa3/AA-

    Ba1/BB+

    Aaa/AAA

    A1/A

    Baa3/BBB-

    Baa1/BBB+

    *** Under Basel II ( 353) a floorrisk weight of 200% appliesto listed equities

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    Basel IIPillar 1 Capital Charge for Credit Risk

    Standardized Approach - Risk Weighting Scheme (Past Due)Provision less than 20%

    of Outstanding amount

    Provision more than

    20% but less than

    50% of Outstanding

    amount

    Provision no less

    than 50% of

    Outstanding amount

    All except retail 150% 100% 50%

    Retail 150%

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    Collateralized TransactionA transaction where:

    the bank has a credit exposure or potential credit exposureto a counter party; AND

    the exposure is hedged in whole or in part by collateralposted by a counter party or by a third party on behalf of

    the counter party.

    As a general rule, no transaction should receive a

    RW higher than an unsecured claim.

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    No capital relief if the following conditions are notmet.

    Legal certainty: All documentation used in the collateralized transactions must

    be binding on all parties and legally enforceable in all relevant

    jurisdictions. Legal opinion on enforceability should be obtained and

    updated.

    Legal mechanism must ensure that the bank has clear rightsover the collateral and may liquidate or take legal possessionsof it in the event of default, insolvency, or bankruptcy of thecounter party.

    Banks must take all steps necessary to fulfill local requirementsfor obtaining and maintaining an enforceable security interest.

    l

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    Basel II - Pillar 1 Capital Charge for Credit Risk

    Standardized Approach - Risk Mitigation

    Eligible Collaterals1. Cash/ Cash Equivalent

    2. Debt Securities (Rated)

    3. Debt securities (Unrated) subject to following conditions:

    Issued by a bank; and Listed on a recognized exchange; and

    Qualify as senior debt; and

    All other rated issues by the issuing bank are rated at least BBB- or A3/ P3; and

    The lending bank has no information to suggest that the issue justifies a rating below BBB- or A3/ P3;and

    4. Equities included in a main index

    5. Listed Undertakings in Collective Investments in Transferable Securities (UCITS)/Mutual funds

    Additionally in Comprehensive approach followings are also recognized

    Equity not included in a main index, but listed on a recognized exchange

    UCITS/ mutual funds which include such equities

    B l II

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    Basel II - Pillar 1 Capital Charge for Credit Risk

    1. Simple approach: Same as in Basel I, However allows only liquid collaterals eligible.

    It follows a substitution mechanism whereby the value of eligible collateral isdeducted from exposure amount and risk weight is to be calculated on

    residual amount developed for banks that only engage to a limited extent in collateralized

    transactions

    Standardized Approach - Risk Mitigation

    Example loan: 100, collateral: 80 bonds,

    risk weight of borrower: 100%

    risk weight of bond: 50% (A rated)

    risk weighted assets of covered portion: 80 x 50% = 40

    risk weighted assets of uncovered portion: 20 x 100% = 20

    total risk weighted assets: 40 + 20= 60

    B l II

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    Basel II - Pillar 1 Capital Charge for Credit Risk

    Standardized Approach - Risk Mitigation

    2. Comprehensive Approach:focuses on the cash value of the collateral taking into accountprice volatility

    The exposure amount after risk mitigation is calculated as follows,

    Using standard supervisory or own estimates haircutsE* = max {0, [E x (1 + He)C x (1HcHfx)]}where:E* = the exposure value after risk mitigation

    E = current value of the exposureHe = haircut appropriate to the exposureC = the current value of the collateral receivedHc = haircut appropriate to the collateralHfx = haircut for currency mismatch

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    HaircutsWill depend on type of exposure/ collateral,rating,remaining maturity, and frequency of mark- to- marketand re-margining

    1. Standard supervisory haircuts

    Fixed by Basel Committee2. Own- estimate haircuts Based on banks internal estimates of market price and FX

    volatilities Permission will be conditional on the satisfaction of minimum

    qualitative and quantitative standards.

    Comprehensive Approach

    B l II

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    Basel II - Pillar 1 Capital Charge for Credit Risk

    Standardized Approach - Risk Mitigation

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    Type Minimum HoldingPeriod

    Condition

    Repo StyleTransactions

    5 days Daily

    remargining

    Other CapitalMarket Transactions

    10 days Daily

    remargining

    Secured Lending 20 days Daily

    RevaluationH = HM

    TM

    NR + (TM-1)

    Comprehensive Approach

    Hm = haircut for the min holding period

    Nr = no of days between remargining

    Tm = min holding period for the type of transaction

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    Collateral only recognized if original maturity more than a

    year and residual maturity of more than 3 months.

    Maturity mismatch not allowed in simple approach

    When there is a maturity mismatch following adjustment is

    required in collateral value:

    Pa = P x (t-0.25)/(T-0.25)

    Where Pa = value of collateral after maturity mismatch adjustment

    P = value of collateral

    t= min( T, residual maturity of collateral in years)

    T = min (5, residual maturity of exposures in years)

    Maturity Mismatch

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    Currency MismatchWhere the credit protection is denominated in a currency

    different from that in which the exposure is denominated i.e.

    there is a currency mismatch the amount of the exposure

    deemed to be protected will be reduced by the application of a

    haircutHFX, i.e.

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    2. Own- estimate haircuts (Continued)

    Quantitative Criteria

    99 th percentile one- tailed confidence interval is to be used

    The minimum holding period will depend on the type oftransaction and the frequency of remargining or MTM

    Banks must take into account the illiquidity of lower- quality assetsby adjusting holding period upwards and should identify wherehistorical data may understate potential volatility.

    The choice of historical observation period for calculating haircuts

    shall be a minimum of one year. Banks should update their data sets at least once every 3 months

    and reassess them whenever market prices are subject tomaterial changes.

    Comprehensive Approach

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    2. Own- estimate haircuts (Continued)

    Qualitative Criteria

    The estimated volatility data (and holding period) must be usedon the day- to- day risk management process of the bank.

    Banks should have robust processes in place for ensuringcompliance with internal policies, controls and proceduresconcerning the operation of risk measurement system.

    The risk management system should be used in conjunction withinternal exposure limits.

    An independent review of the risk management system shouldbe carried out regularly at the banks own internal auditing

    process (ideallyat least once a year).

    Comprehensive Approach

    Basel II Overall framework

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    Basel IIOverall framework

    State Bank of Pakistan

    Three Mutually Reinforcing Pillars

    Pillar 3: Market

    Discipline

    Pillar 2: Supervisory

    Review Process

    Pillar 1: Minimum

    Capital Requirement

    Definition of CapitalRisk Weighted Assets

    Credit Risk Market RiskOperational Risk

    Internal

    Rating Based Approach

    (IRB)

    Basic Indicator

    Approach

    Standardized

    ApproachAMA

    Standardized

    Approach

    Internal Model

    Based Approach

    Supplementary

    Capital

    Core Capital

    tandardized

    Approach

    I t l R ti B d A h

    B i C t

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    Internal Rating Based ApproachBasic Concept

    State Bank of Pakistan

    Credit rating is a symbolic representation of the risk

    profile of an obligor or an exposure

    Moodys DR S&P DR

    Aaa 0% AAA 0%

    Aa .01% AA .01%

    A .02% A .06%

    Baa .11% BBB .23%

    Ba .6% BB 1%

    Caa 2.73% B 4.57%

    Ca-c 10.50% CCC 25.59%

    Probability of Default (PD)

    Loss Given Default (LGD)

    Exposure at Default (EAD)

    I t l R ti B d A h

    B i C t

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    Internal Rating Based ApproachBasic Concept

    State Bank of Pakistan

    Expected

    Loss (EL)

    Unexpected

    Loss at 99%(UL)

    Unexpected loss

    beyond 99%

    Probability

    Amount

    EL = PD x LGD x EAD

    I t l R ti B d A h

    B i C t

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    Internal Rating Based ApproachBasic Concept

    State Bank of Pakistan

    Borrower default if the value of its assetsfalls below its obligation or a default

    threshold

    There relationship between distance todefault and PD can be described by

    normal distribution function.

    1 Yr

    Distribution of

    asset value at

    horizon

    Asset

    Value

    Today

    EDF

    Time

    Value

    Default PointDistance-to-Default =3 Standard deviations

    Asset Volatility

    (1 Std Dev)

    B l II

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    Basel II - Pillar 1 Capital Charge for Credit Risk

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    Internal Rating Based Approach

    The capital requirement is calculated on the basis of risk assessed by the bankitself

    The risk Assessment is based on internal risk rating of exposures which are used to

    calculate following inputs parameters called risk components

    Borrower risk: Probability of default (PD)

    Transaction risk: Loss given default (LGD)

    Exposure: Exposure at default (EAD)

    I t l R ti B d A h

    B i C t

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    Internal Rating Based ApproachBasic Concept

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    The appropriate default threshold for average conditions is determined byapplying the inverse normal distribution function to the average PD

    Further , the required appropriately conservative value of the systematic riskfactor can be derived by applying the inverse of the normal distribution function to

    the predetermined supervisory confidence level.

    A correlation-weighted sum of the default threshold and the conservative value ofthe systematic factor yields a conditional (or downturn) default threshold.

    In a second step, the conditional default threshold is used as an input into theoriginal Merton model and is put forward in order to derive a conditional PD.

    Mechanics of the IRB approach

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    Mechanics of the IRB approach

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    Calculation of Provisions

    maximum of 1.25% of total Risk Weighted Assets.

    Total Provisions = specific + general provisionprovision (equity)

    Expected loss to be calculated for

    1. assets subject to IRB Approach

    2. Equity Exposure subject to PD LGD Approach

    3. Equities subject to PD/LGD Approach

    4. Specialized lending using supervisory slotting criteria for IRB

    5. HVCRE

    Expected Loss = PD x LGD x EAD

    Mechanics of the IRB approach

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    Mechanics of the IRB approach

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    Expected lossall provisions

    If there is surplus, it can be part of tier 2 subject to a maxof 0.6% of RWA

    If there is a deficit it will deducted 50% from tier 1 and50% from tier 2

    EL for equity exposures to be deducted 50% from tier 1and 50% from tier 2

    Partial Adoption of IRB: provisions should be calculatedon pro rata basis

    Mechanics of the IRB approach

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    Mechanics of the IRB approach

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    Categorization of exposures

    Corporate

    Sovereign

    Bank

    Retail

    Equity.

    1. Project Finance2. Object Finance

    3. Commodities Finance4. Income Producing Real Estate

    5. High Volatile Commercial Real

    Estate

    1. Residential Mortgage

    2. Qualifying Retail Exposure3. Other Retails

    Mechanics of the IRB approach Types

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    Mechanics of the IRB approach- Types

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    1. Foundation IRBbanks provide their own estimates of PD and rely on

    supervisory estimates for other risk components.

    2. Advanced IRBbanks provide more of their own estimates of PD, LGD

    and EAD, and their own calculation of M, subject to

    meeting minimum standards.

    For both the foundation and advanced approaches,

    banks must always use the risk-weight functions

    Mechanics of the IRB approach

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    Mechanics of the IRB approach

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    Adoption of the IRB approach across asset classes1. Once a bank adopts an IRB approach for part of its holdings

    2. supervisors may allow banks to adopt a phased rollout of the IRB

    approach across the banking group. The phased rollout includes

    a. adoption of IRB across asset classes within the samebusiness unit (or in the case of retail exposures across

    individual sub-classes)

    b. adoption of IRB across business units in the samebanking group and

    c. move from the foundation approach to the advanced

    approach for certain risk components.

    Rules for corporate sovereign and bank exposures

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    Rules for corporate, sovereign, and bank exposures

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    Formula for derivation of risk-weighted assets

    Firm-size adjustment for small- and medium-sized entities (SME)

    Rules for Assets subject to double Default

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    Rules for Assets subject to double Default

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    Formula for derivation of risk-weighted assets

    Specialized Lending

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    Specialized Lending

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    Mapping of Supervisory categories with ECAIs

    50% 70%

    70% 95%

    Rules for Equity Exposures

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    Rules for Equity Exposures

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    1. Market-based approach

    Simple risk weight method

    Internal models method

    2. PD/LGD approach

    Similar to risk weight calculation for corporate subject following

    conditions

    LGD floor is kept at 90%

    For long term equity holdings the risk weight floor will be100%

    For short term holding the same floor is 200% for publically

    traded and 300% for non traded equity holdings.

    300% 400%

    200% 300%

    Rules for Retail Exposures

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    Rules for Retail Exposures

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    Residential mortgage exposures

    Qualifying revolving retail exposures

    Other retail exposures

    IRB approach- Risk Components Revisited

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    IRB approach- Risk Components Revisited

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    1. Probability of Default (PD)Measured in percentage over a time horizon of 1 year

    a. Actual Default Observed

    b. Mapping with the ECAIs

    c. Statistical Model

    IRB approach- Risk Components Revisited

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    IRB approach- Risk Components Revisited

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    2. Loss Given DefaultThe percentage of exposure that bank will loose in case of default.

    Sub-ordinate 75%

    Unsecured = 45%

    In addition to comprehensive approach following collaterals are also eligible

    3. Exposure at Default

    IRB approach- Risk Components Revisited

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    IRB approach- Risk Components Revisited

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    Loan in cash of 1000, with a remaining maturity of 5 years, to a corporate with an

    internal grade of 3 (pd .05). The loan is secured by debt securities issued by a bank with

    an external rating of AA. The debt securities have a remaining maturity of 7 years and amarket value of USD 500. Additional collateral, in the form of commercial real estate,

    with a market value of 500 and a mortgage lending value of 300 secures the loan.

    IRB Approach Minimum Requirement

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    IRB Approach Minimum Requirement

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    Rating system designThe term ratingsystem comprises all of the methods, processes,

    controls, and data collection and IT systems that support the

    assessment of credit risk, the assignment of internal risk ratings, and

    the quantification of default and loss estimates

    Perceived and measured risk must increase as credit quality

    declines from one grade to the next

    A bank must define risk of each grade and the criteria used todistinguish that level of credit risk

    IRB Approach Minimum Requirement

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    IRB Approach Minimum Requirement

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    Rating dimensions-corporate, sovereign and bank exposuresA qualifying IRB rating system must have two separate and distinct dimensions:

    the risk of borrower default

    transaction-specific factors.

    foundation IRB banks, this requirement can be fulfilled by the

    existence of a facility dimension, which reflects both borrower and

    transaction-specific factors. Where a rating dimension reflects ELand does not separately quantify LGD, the supervisory estimates of

    LGD must be used.

    IRB Approach Minimum Requirement

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    IRB Approach Minimum Requirement

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    Rating dimensions-Retail exposures

    1. must be oriented to both borrower and transaction risk2. Banks must assign each retail exposure for IRB purposes into a particular

    pool. Each pool gives a meaningful differentiation of risk

    3. For each pool, banks must estimate PD, LGD, and EAD.

    4. Multiple pools may share identical PD, LGD and EAD estimates.

    5. At a minimum, banks should consider the following risk drivers whenassigning exposures to a pool:

    Borrower risk characteristics (e.g. borrower type, demographics such as

    age/occupation);

    Transaction risk characteristics, including product and/or collateraltypes (e.g. Loan to value measures, seasoning, guarantees; and seniority

    (first vs. second lien)).

    Delinquency of exposure: Banks are expected to separately identify

    exposures that are delinquent and those that are not.

    IRB Approach Minimum Requirement

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    IRB Approach Minimum Requirement

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    Rating structure

    1. Standards for corporate, sovereign, and bank exposuresA bank must have a meaningful distribution of exposures across grades with no

    excessive concentrations, on both its borrower-rating and its facility-rating

    scales.

    must have a minimum of seven borrower grades for non-defaulted

    borrowers and one for those that have defaulted.

    Banks using the supervisory slotting criteria for the SL asset classes must

    have at least four grades for non-defaulted borrowers, and one for

    defaulted borrowers.

    There is no specific minimum number of facility grades

    2. Standards for Retail exposures

    For each pool identified, the bank must be able to provide quantitative measures of

    loss characteristics (PD, LGD, and EAD) for that pool.

    IRB Approach Minimum Requirement

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    IRB Approach Minimum Requirement

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    Rating assignment horizon

    Although the time horizon used in PD estimation is one year,banks are expected to use a longer time horizon in assigning

    ratings.

    rating must represent the borrowers ability and willingness to

    contractually perform despite adverse economic conditions or the

    occurrence of unexpected events.

    Use of models The burden is on the bank to satisfy that a model or procedure has good predictive

    power

    The bank must have in place a process for vetting data the judgment must take into account all relevant and material information not

    considered by the mode

    The bank must have procedures for human review of model-based rating

    assignments.

    The bank must have a regular cycle of model validation

    IRB Approach Minimum Requirement

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    IRB Approach Minimum Requirement

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    Documentation of rating system design

    Banks must document in writing their rating systems design andoperational details

    If statistical models are used, the bank must document their

    methodologies

    outline of the theory, assumptions and/or mathematical and

    empirical basis of the assignment of estimates of

    Establish a rigorous statistical process

    Indicate any circumstances under which the model does not

    work

    Use of a model obtained from a third-party vendor that claimsproprietary technology is not a justification for exemption

    from documentation

    IRB Approach Minimum Requirement

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    IRB Approach Minimum Requirement

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    Risk rating system operations

    Coverage of ratings

    Integrity of rating process

    Overrides

    Data maintenance

    Stress tests used in assessment of capital adequacy

    Corporate governance and oversight

    Use of internal ratings

    Risk quantification

    Basel II - Pillar 1 Capital Charge for Credit Risk

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    Basel II Pillar 1 Capital Charge for Credit Risk

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    Internal Rating Based Approach

    Basel II prescribes a risk weight function which gives capital requirement & RWAusing the risk components

    Example: Risk Weight Function & other formulas for Corporate Sovereign and BankExposures

    Correlation (R) = 0.12 x (1-exp(-50xPD))/(1-exp(-50))+0.24 x [1-(1-exp(-

    50xPD)/(1-exp(-50))]Capital Requirement (K) = LGD x N[(1-R)^-0.05 x G(PD) + (R/(1-R)^0.5 x G(0.999)]PD x

    LGD] x(1-1.5 x b)^-1 x (1+(M-2.5) x b)

    Risk-weighted assets (RWA) = K x 12.5 x EAD

    Similar formulas with slight modifications are for other exposure types (Retail, SMEs etc) The difference between FIRB & AIRB is the calculation of Risk Components PD, LGD

    Foundation IRB Only PD to be calculated by bank Risk components LGD & EAD

    Advanced IRB All Risk components to be calculated by bank itself

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    State Bank of Pakistan

    Capital Charge For Market Risk

    Basel IIOverall framework

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    Three Mutually Reinforcing Pillars

    Pillar 3: Market

    Discipline

    Pillar 2: Supervisory

    Review Process

    Pillar 1: Minimum

    Capital Requirement

    Definition of CapitalRisk Weighted Assets

    Credit Risk Market RiskOperational Risk

    Internal

    Rating Based Approach

    (IRB)

    Basic Indicator

    Approach

    Standardized

    ApproachAMA

    Standardized

    Approach

    Internal Model

    Based Approach

    Supplementary

    Capital

    Core Capital

    tandardized

    Approach

    Capital Charge For Market Risk

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    p g

    Definition:

    Market risk is the risk of loss in on and off-balance

    sheet positions due to adverse movement of market

    factors. Consequently it encompass;

    Interest rate risk

    Equity Price Risk

    Foreign Exchange risk &

    Commodity price risk.

    Capital Required = Sum of Capital Charge for all these 4 Risk sub categories

    Tier 3 Capital

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    p

    State Bank of Pakistan

    Short term subordinated debt with a minimum

    maturity of 2 years is allowed to be tier 3 capital.

    It shall be exclusively for market risk

    Shall be limited to 250% of tier 1 that is availableto support market risk i.e. at least 28.5% of capitalrequirement against Market Risk has to be metfrom tier 1.

    Tier 2 elements may be substituted for tier 3provided tier 3 capital will be limited to 250% oftier 1 that is required to support market risk.

    Calculation of CAR (Cont..)

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    State Bank of Pakistan

    The first step is to calculate risk weighted assets (for credit risk)

    Then,

    The second step is to calculate risk weighted assets subject to market risk capitalcharge. The methodology provides calculation of market risk capital chargedirectly. So in order to ensure consistency assuming this capital charge is 8% ofrisk weighted assets, it is multiplied by 12.5 to obtain risk weighted assets for

    market risk. Then overall CAR is,CAR ( credit risk) =

    Tier 1 + Tier 2

    Risk weighted assets

    CAR ( overall ) =

    Tier 1 + Tier 2 + Tier 3

    RWA( credit) + RWA( Market)

    Min 28.5% of

    Capital chargeFor market risk

    To be covered

    By tier 2

    >250% of tier 1

    i.e. 72% of

    Capital charge

    For market risk

    Charge.

    two broad methodologies for calculation of risk charge

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    State Bank of Pakistan

    1. Standardized Approach.

    2. Internal Model Based Approach

    Banks are allowed to adopt any of the two methodologies subject

    to approval of national supervisory authority. However the laterrequire certain preconditions such as bank have proper riskmanagement framework, models being used to measure risk haveproven track record and bank regularly conducts stress tests etc.

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    State Bank of Pakistan

    The capital requirement against interest rate risk apply

    only on trading book positions

    The minimum capital for IRR is sum of two separately

    calculated charges i.e.

    Specific Risk. Apply to each security position whether it is

    short or long (basically to cover credit risk)

    General Market risk. It is the capital requirement onportfolio basis, where long and short positions can be

    offset subject to certain conditions

    Capital charge for IRR - Specific Risk

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    State Bank of Pakistan

    Government

    qualifying

    other

    0.00%

    0.25% (residual term to finalmaturity 6 months or less)

    1.00% (residual term to finalmaturity between 6 and 24months)

    1.60% (residual term to finalmaturity exceeding 24 months)

    8.00%.

    The specific risk charge is graduated in five broadcategories as follows:

    Capital charge for IRR general Market Risk

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    p g g

    All debt securities and other sources of interest rateexposures including derivatives are slotted into amaturity ladder comprising of thirteen time bands

    The general market risk is the sum of

    a. A small portion of matched position in each time band(vertical disallowance)

    b. A larger portion of the matched position across differenttime bands (horizontal disallowance)

    c. The net short or long position in the whole trading book

    Capital charge for IRR general Market Risk

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    Before calculating net positions within timebands or across time bands all long and shortpositions are multiplied with certain sensitivityweights. There are two methodologies to do so

    1.Maturity method, wherein these sensitivitynumbers are predefined

    2.Duration method wherein these sensitivityweights are duration of the asset calculated onthe bases of assumed change in yield prescribedby Basel I.

    Maturity method

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    State Bank of Pakistan

    y

    Coupon 3% or more Coupon less than 3% Weights %

    1 month or less 1 month or less 0

    1 to 3 months 1 to 3 months 0.2

    3 to 6 months 3 to 6 months 0.4

    6 to 12 months 6 to 12 months 0.7

    1 to 2 years 1 to 2 years 1.25

    2 to 3 years 2 years2 to 3 years 1.75

    3 to 4 years 3 to 4 years 2.25

    4 to 5 years 4 to 5 years 2.75

    5 to 7 years 4 to 5 years 3.25

    7 to 10 years 5 to 7 years 3.75

    Duration Method

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    Example IRR-General market Risk

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    Example IRR General market Risk

    Suppose a bank has following positions in its trading portfolio;

    A 4% government bond having market value 15 million and residual maturityof 6 months.

    A 3% qualifying bond having market value 12 million, residual maturity 2months.

    An interest rate swap, Rs 150 million, bank receives floating rate interest andpays fixed next fixing after 9 months, residual life of swap 8 years.

    An interest rate swap with face value Rs 30 million and residual maturity 2.5years. Bank receives fixed at 7% and pays floating rate of 5.5%. Next repricing

    after 4 months.

    A nine versus fifteen, Forward Rate Agreement sold on 6 months KIBOR withnominal amount Rs 20 million and settlement date after nine months.

    Example (Cont..)Zone 1 Zone 2 Zone 3

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    Time

    Band0-1 1-3 3-6 6-12 1-2 2-3 3-4 4-5 5-7 7-10 10-15 15-20 Over 20

    Position +12 -30 +150 +20 +30 +15 -150

    -20

    Weights

    %0 0.2 0.4 0.7 1.25 1.75 2.25 2.75 3.25 3.75 4.5 5.25 6

    Weighted

    positions

    0.024 -0.12 1.05

    -0.14

    0.25 0.525 0.488 -5.625

    Vertical

    Disallowance

    0.14 x

    10%=0.014

    Position

    AfterV D0.024 -0.12 0.91 0.25 0.525 0.488 -5.625

    H.D 1 = 0.12 x 40% = 0.048 0.488 X 40% = 0.195

    position 0.814 0.775 -5.137

    H D 2 0.814 = 0.775 x 40% = 0.31 Remaining Position = - 4.362

    H D 3 0.814 X 100% = 0.814 Remaining position = - 3.548

    Capital Required = V. D +H. D + overall open position

    Capital Charge for Equity Price risk

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    The instruments covered include common stocks,

    convertible securities that behave like equities, andcommitments to buy or sell equity securities. The Capitalrequirement is sum of

    1.specific risk capital charge that is against individual stock/security

    (netting not allowed) which will be 4%2.General market risk is calculated on portfolio basis i.e. net positionin a market which shall be 8%

    Both calculated on market value of positions. Further theAsset subject to this capital requirement shall be given 0%Risk weight while calculating credit risk capital charge.

    Capital charge for Foreign Exchange Risk.

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    Capital charge for Foreign Exchange Risk.

    The capital charge for foreign exchange risk apply to FCYexposures throughout banks balance sheet.

    It is simply 8% of the overall net open position of the bank

    The calculation of open position is the same as prescribed inF.E manual.

    Howevera.Banks that have foreign currency business, defined as the greater of thesum of its gross long positions and the sum of its gross short positions inall foreign currencies, does not exceed 100% of eligible capital andb. their overall net open position does not exceed 2% of eligible capital

    are exempted from holding capital against F.E risk.

    Internal Model Based Approach.

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    1

    2

    - 1

    - 2

    Time (days)

    Suppose portfolio of a single asset. The price volatility of asset over past hundred days

    is as plotted below.

    Internal Model Based Approach

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    If Assets Value is 60 million and 5% of times the

    return are below 3% ThanOne day VaR at 95% confidence level

    = 60 x 3% = 1.8 m

    - 4 - 3 - 2 - 1 0 1 2 3 4

    No

    of

    Occurrences

    Daily Return

    5% of area

    Internal Model Based Approach

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    Banks that are allowed by their supervisory agency touse internal models to calculate capital requirementshould hold capital

    Equivalent to previous day var amount or

    Average of past 60 days var multiplied by aconstant factor (minimum 3) whichever is higher.

    VaR is required to be calculate at 99% confidencelevel at 10 day time horizon.

    Internal Model Based Approach

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    Quantitative Standards

    VaR is computed on daily basis

    Confidence interval 99%,

    Bank can use any model

    Stress testing

    External validation

    Internal Model Based Approach

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    1. Qualitative standards e.g Board and senior management oversight

    Independent risk control unit

    Routine and rigorous stress testing

    Independent review of the risk measurement

    system

    Basel II - Pillar 1 Capital Charge for Operational Risk

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    Defined as risk of loss from inadequate or failed internal processes, people andsystems, or from external events

    Examples of risks covered

    Internal and external fraud

    Legal risks

    Damages to customers

    Losses arising out of labour, health and safety, diversity, personal injury, etc.

    Damage to physical assets

    Business interruption

    Examples of risks not covered

    Reputational risk

    Strategic errors

    Basel II - Pillar 1 Capital Charge for Operational Risk

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    Basic Indicator Approach

    15% ofbanks average annual gross income over previous three years

    Standardised Approach

    Capital charge for each of 8 business lines calculated against average annual gross income for

    business line times:

    18% for corporate finance

    18% for trading and sales

    12% for retail banking

    15% for commercial banking

    18% for payment and settlement

    15% for agency services

    12% for asset management

    12% for retail brokerage

    Advanced Measurement Approach

    Calculated on basis of internal operational risk management system approved by national

    regulator

    Basel IIPillar II Supervisory Review Process

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    Four key principles of supervisory review

    Principle 1: Banks should have process for assessing overall capital adequacy in relation to riskprofile and strategy for maintaining capital levels. Five main features of rigorous process:

    Board and senior management oversight

    Sound capital assessment

    Comprehensive risk analysis (credit risk, operational risk, market risk, interest rate risk in

    banking book, liquidity risk, other risk)

    Monitoring and reporting

    Internal control review

    Principle 2: Supervisors should review and evaluate banks internal capital adequacy assessments

    and strategies, as well as ability to monitor and ensure compliance with ratios. Supervisors should

    take appropriate action if not satisfied.

    Principle 3: Supervisors should expect banks to operate above minimum ratios and should have

    ability to require banks to hold capital in excess of minimum

    Principle 4: Supervisors should seek to intervene at early stage and require rapid remedial action

    Basel IIPillar II Supervisory Review Process

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    Specific issues Interest rate risk in banking book: Basel II treats interest rate risk under Second Pillar of

    supervisory review (rather than First Pillar of regulatory capital) due to differences in methods

    banks use to handle risk

    Credit risk: Supervisory review is appropriate to regulate stress tests under IRB approach,

    definition of default used to determine PD and/or LGD and EAD, residual risk, credit

    concentration risk and operational risk

    Other issues Supervisory transparency and accountability: Supervisors should make publicly

    available criteria used in review ofbanks internal capital assessments

    Enhanced cross-border communication and cooperation: Basel Committee supportspragmatic provision of close and continuous dialogue between industry participants

    and supervisors, as well as between supervisors (without changing legal

    responsibilities of national regulators).

    Basel IIPillar III Market Discipline

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    Impose market discipline on banks by requiring disclosure of key information relevant to

    banks risks and capital

    Why Enhanced Disclosure? Complements regulatory capital requirements and the supervisory review

    process

    Reliable and timely information allowing well founded counterparty riskassessments

    Provides banks with an incentives to maintain a strong capital base

    Enhance role of market participants in encouraging banks to hold adequate

    levels of capital

    General Disclosure PrincipleBanks should have a formal disclosure policy approved by the board of directors . In

    addition , banks should implement a process for assessing the appropriateness of their

    disclosures , including validation and frequency of them.

    Basel II - Overview

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    Disclosure Requirements

    Attached to the use of a particular methodology or instrument

    Pre-condition for the use of some methodologies

    Internal ratings-based approach

    Asset securitization

    Recognition of external credit assessment institutions

    Types of Disclosures Qualitative

    Quantitative