Beruflich Dokumente
Kultur Dokumente
BASEL-3 AN OVERVIEW
COMMERCIAL BANK MANAGEMENT
Submitted to:
Prof. Prakash Singh
Indian Institute of Management, Lucknow
Submitted by
CBM Sec-A Group-4
Ankita Prayag Singh
Kislay Upadhyay
Pamu Sai Jayachandra Rao
Priyank Agarwal
Sonu Sharma
Yash Gupta
PGP30184
PGP30202
PGP30213
PGP30217
PGP30228
PGP30238
Contents
1.
2.
3.
4.
5.
6. Difference between the RBI Regulations and the BASEL 3 Norms ................................................................... 12
7. Impact Of Basel 3 On Indian Banking System: Modelling The Loan Demand In India And The Impact Of These
Regulations Of The Indian Economy ..................................................................................................................... 13
7.1. BASEL III Capital Requirements: RBI .......................................................................................................... 13
7.2. Impact of BASEL III on Indian Banking ....................................................................................................... 13
8. Current Status of BASEL III Implementation in India ........................................................................................ 16
8.1. Banks Own Proactive Internal Approaches for Capital Adequacy Ratios .................................................. 16
9. References ........................................................................................................................................................ 17
To enhance safety by reducing the likelihood of individual failures that could spread
the adverse effects across national boundaries
To provide for a level playing field, so that banks in different countries would not
benefit from any competitive advantages due to subsidies from their governments,
such as lower capital ratios or other government support.
1.1 BASEL I
Basel I norms were introduced only in 1992, and that too in a phased manner over a period
of four years, however, RBI had introduced measures for managing liquidity risk, forex risk
and credit risk (through the Health Code Systems 1985-86) in the Indian banking system.
The Health Code system, inter alia, provided information regarding the health of individual
advances, the quality of the credit portfolio and the extent of advances causing concern in
relation to total advances. It was considered that this accord, Banks obliged to comply with
a minimum "risk asset ratio (RAR) requirement of 8%. A bank's RAR is derived by expressing
its (adjusted) regulatory capital, comprising so-called "Tier 1" and "Tier 2" capital, as a
percentage of risk-adjusted, on- and off-balance-sheet activities.
Thus, the accord was primarily focused on credit risk and appropriate risk-weighting of
assets. Later, The Committee refined the framework to address risks other than credit risk
and issued the so-called Market Risk Amendment to the Capital Accord (or Market Risk
Amendment), to take effect at the end of 1997. This was designed to incorporate within the
Accord a capital requirement for the market risks arising from banks exposures to foreign
exchange, traded debt securities, equities, commodities and options. An important aspect of
the Market Risk Amendment was that banks were, for the first time, allowed to use internal
models (value-at-risk models) rather than the standardized RAR approach as a basis for
measuring their market risk capital requirements, subject to strict quantitative and qualitative
standards.
Since Jan1998, RAR (%) = ACB / [TOWRA+ (12.5 * Market Risk Capital Charge)], subject to a
minimum of 8%.
Advantages of Basel I
Substantial increases in capital adequacy ratios of internationally active banks;
Relatively simple structure;
Worldwide adoption;
Increased competitive equality among internationally active banks;
Greater discipline in managing capital;
A benchmark for assessment by market participants.
Weaknesses of Basel I
Capital adequacy depends on credit risk, while other risks (e.g. market and
operational) are excluded from the analysis;
In credit risk assessment there is no difference between debtors of different credit
quality and rating;
Emphasis is on book values and not market values;
Inadequate assessment of risks and effects of the use of new financial instruments, as
well as risk mitigation techniques
1.2 BASEL II Accord
Market Discipline by effective disclosure to encourage safe and sound banking
Practices. In response of flaws and weakness of Basel I assessment regime and to
accommodate market developments and industry practices in the field of risk management,
the Committee issued a proposal for a new capital adequacy framework in 1999 to replace
Basel I. This led to the release of the Revised Capital Framework in June 2004, known as Basel
II.
Concerns with Basel I:
The voluntary nature of the agreement
The flawed methodology inherent in the "standardized" assessment approach;
The market distortions and concomitant induced resource misallocation; and
The potential danger of exacerbating global or regional "credit crunches".
Under Basel II, the revised framework comprised three mutually-reinforcing pillars, namely:
1) Minimum capital requirements, (with amendment in the standardized approach of
Basel I Accord);
2) Supervisory review of an institutions capital adequacy and internal assessment
process; and
3) Effective use of disclosure as a lever to strengthen market discipline and encourage
sound banking practices.
The credit risk component can be calculated in three different ways of varying degree
of sophistication, namely standardized approach, Foundation IRB, Advanced IRB.
For operational risk, there are three different approaches basic indicator approach
or BIA, standardized approach or STA, and the advanced measurement approach or
AMA.
For market risk the two approaches are Standardized approach and internal models
like VaR (value at risk).
Banks should have a process for assessing their overall capital adequacy in relation to
their risk profile and a strategy for maintaining their capital levels.
Supervisors should review and evaluate banks' internal capital adequacy assessments
and strategies, as well as their ability to monitor and ensure their compliance with
regulatory capital ratios.
Supervisors should expect banks to operate above the minimum regulatory capital
levels and should have the ability to require banks to hold capital in excess of the
minimum.
Supervisors should seek to intervene at an early stage to prevent capital from falling
below the minimum levels required to support the risk characteristics of a particular
bank, and should require rapid remedial action if capital is not maintained or restored.
Third Pillar:
This includes a set of specific qualitative and quantitative disclosures in four key areas:
Scope of application
Composition of capital
Risk exposure assessment and management processes
Capital adequacy
It even distinguishes between disclosure requirements (defined as core and supplementary
disclosure requirements), and strong recommendations. Core disclosures are defined as
those which convey vital information for all institutions and are important to the basic
operation of the market discipline; while supplementary disclosures are important for some,
but not all, institutions depending on the nature of their risk exposure, capital adequacy and
methods adopted to calculate the capital requirements.
Thus, the new framework was designed to improve the way regulatory capital requirements
reflect underlying risks and to better address the financial innovation that had occurred in
contemporary years. The changes aimed at rewarding and encouraging continued
improvements in risk measurement and control.
2. BASEL 3: Framework
Basel III aims to build robust capital base for financial institutions and ensure liquidity and
leverage ratios to withstand any future banking crises, thus ensuring financial stability.
The main pillars of the norms are explained below:
2.1 Capital Standards
The 4 different capital standards are:
1. Raising Capital Base: To ensure quality, consistency in definition across
jurisdictions and transparency in disclosure of capital base. Measures
suggested in this regard are:
a. Tier 1 Capital
b. Reminder of Tier 1 Capital
c. Innovative Hybrid Instruments
2. Enhancing Risk Coverage: To strengthen the risk coverage of capital framework.
Measures suggested in this regard are:
a. Introduction of stressed VaR capital requirement
b. Re-securitization in banking and trading books requiring higher capital
requirements
c. Additional Capital charge for mark-to-market losses related to credit valuation
adjustment risks
d. Strengthening standards for collateral management
3. Supplement Risk-Based Capital requirements with Leverage Measure: To
Tier 1 Capital
6.0%
8.5%
Total Capital
8.0%
10.5%
Although banks can use up their buffer capital, they are expected to immediately replenish the
same using their earnings in the following manner:
Common Equity Tier 1 (%)
4.5-5.125
5.125-5.75
5.75-6.375
6.375-7.00
>7.00
the asset values of financial institutions is also high. Therefore, the norms stipulate a scaling
up of the correlation factors while estimating volatility of asset values. This has also increased
the capital requirements.
2.5 Liquidity Standards
The liquidity framework aims to increase the resilience of banks to liquidity problems in the
market. 2 ratios have been proposed to monitor the long-term and short-term liquidities.
1.
2.
Leverage Ratio
Minimum Common Equity
Capital Ratio
Capital
Conservation
Buffer
Minimum Common Equity
Capital Ratio
+ Capital Conservation
Buffer
Minimum Tier 1 Capital
Minimum Total Capital
Minimum Total Capital
+ Capital Conservation
Buffer
Phase out of non-core
2012
Supervisory
Monitoring
5.13
%
5.75% 6.38% 7.00%
4.50
%
5.50% 6.00%
8.00
%
8.00% 8.00%
8.00
%
8.00% 8.00%
6.00
%
6.00% 6.00% 6.00%
8.00
%
8.00% 8.00% 8.00%
8.63
10.50
%
9.25% 9.88% %
Tier-1 Capital
or Tier-2 Capital
Introdu
ce
Minimu
m
Standar
d
Period
Begins
Introdu
ce
Minimu
m
Standar
d
Public Sector
26 67,466
83
72.8
Private Sector
20 13,452
16.6
20.2
Foreign Banks
41 323
0.4
7
Total
87 81,241
100
100
Thus, public sector banks (PSB) continue to dominate with 73% of market share of assets and
83% of branches.
4.3. Regional Rural Bank
The banks provide credit to the weaker sections of the rural areas, particularly the small and
marginal farmers, agricultural laborers, and small entrepreneurs. There are several
concessions enjoyed by the RRBs by RBI such as lower interest rates and refinancing facilities
from NABARD. The RRBs are under the control of NABARD. NABARD has the responsibility of
laying down the policies for the RRBs, to oversee their operations, provide refinance facilities,
to monitor their performance and to attend their problems.
4.4. Co-operative Banks
The co-operative banks are small-sized units which operate both in urban and non-urban
centers. They finance small borrowers in industrial and trade sectors besides professional and
salary classes. Regulated by the Reserve Bank of India, they are governed by the Banking
Regulations Act 1949 and banking laws (co-operative societies) act, 1965. The co-operative
banking structure in India is divided into following 5 components:
Primary Co-operative Credit Society
Central co-operative banks
State co-operative banks
Land development banks
Urban Co-operative Banks
4.5 Unscheduled Banks
Unscheduled Bank means a banking company as defined in clause (c) of section 5 of the
Banking Regulation Act, 1949, which is not a scheduled bank.
Thus, the banking system is dominated by commercial banks. Rural and urban co-operatives
banks have a relatively small share in the banking system. However, given their geographic
and demographic outreach, they play a key role in providing access to financial services to
low and middle income households in both rural and urban areas. Similarly, RRBs play a key
role in promoting financial inclusion. The Government is pursuing branch expansion and
capital infusion plans for the RRBs.
Types of
Risk
Covered
Main tools
of Risk
Manageme
nt
Basel 1
Credit Risk
Market Risk
Ways of
Simple but
Calculation
standard
of Risk
Weighted 4 major risk
Assets and
categories of
CRAR
assets and
risk weights
according to
it
Major
Contributio
n
Basel 2
Credit Risk,
Market Risk &
Operational Risk
Basel 3
Credit Risk
Market Risk
Operational Risk
Liquidity Risk
Counter Cycle Risk
1.CRAR
2.Supervisory Review
3.Market Discipline
4.Liquidity Coverage
Ratio
5.Counter
cycle
Buffer
6.Capital
Conservation
Buffer
7.Leverage Ratio
Same as Basel 2 but
additional capital for
Capital Conservation
& Contra Cyclical
Buffer
Liquidity
Risk
Management
Will help to build
capital during good
time, which can be
used in stressed
situation by Counter
Cycle Buffer
Introduction
of Capital
Conservation
Buffer
% of RWAs
5.5
2.5
8.0
1.5
7.0
2.0
9.0
11.5
Monitoring of Liquidity Standards under Basel III: Banks have been advised to meet the
following regulatory limits to satisfy their liquidity standards under Basel III framework:
Inter-Bank Liability (IBL) Limit: Currently, the IBL of the bank should not exceed 200% of the net
worth as of 31 March of the previous year. However, banks having a CRAR above 11.5% are
allowed to have a higher limit of 300%.
Call Money Borrowing Limit: Currently, as per RBI norms, the borrowings on the call money
market should not exceed 100% of the banks capital funds. However, during a fortnight, banks
can borrow 125% of their capital funds.
Call Money Lending Limit: Currently, as per RBI norms, the lending on the call money market
should not exceed 25% of the banks capital funds.
However, during a fortnight, banks can lend 50% of their capital funds. Thus, it can be seen
that the following are the 2 major differences between the BASEL III norms and the RBI
implementation guidelines:
1. The guidelines require banks to maintain a Minimum Total Capital (MTC) of 9%
against 8% (international) prescribed by the Basel Committee of Total Risk Weighted
assets. This has been decided by Indian regulator as a matter of prudence.
2. The RBI has set the minimum leverage ratio required at 4.5% instead of the 3%
stipulated by the Basel III norms. Since, Indian banks do not have a large exposure to
large derivative activities, this is not expected to have a large impact.
3. In terms of the liquidity requirements, the RBI currently also has the SLR and CRR
requirements due to which the liquidity requirements under the Basel III norms can
be met easily.
In case the implementation of BASEL III is not done properly there might be the existence of
arbitrage in the international markets. This could lead to disruption of global financial
stability.
Impact on Capital Standards in India:
Indian banks need to look for quality capital and also have to preserve the core capital as well
as use it to more efficiently in the backdrop of BASEL III requirements. Though Indian banks
are placed comfortably, they still need to phase out those instruments from their capital
which are disallowed under BASEL III. In view of the favorable economic conditions in the
coming years, a few of the banks can shore up their capital bases through issuance of equity,
but the non-performing banks may be required to raise additional equity capital to maintain
the required 7% requirements.
Impact on Loan Spreads
The purpose here is to find the impact of BASEL III norms on the loan spreads that can be
charged by Indian banks in the near term. The estimation supposes that the return on equity
(ROE) and the cost of debt, are unaffected with no change in other sources of income, and
with the same line of thought it is assumed that there is no reduction in operating expenses.
A raise in interest rate charged on bank loans is supposed to decrease the loan demand in the
country leading to a drop in investment and output.
2 approaches to study the impact of BASEL III norms on loan spreads have been carried out
be researchers. They are :a. Representative Bank Approach (Mervin King)
b. OECD Approach
The results of impact of increase capital ratio on the loan spread of SCBs is shown in the
following table:Increase in Capital Ratio
+1
+2
+3
+4
+5
+6
15.63
31.26
46.89
62.52
78.15
93.78
Now, if we assume that there is a decrease in RWAs, then its impact is as follows:-
+1
+2
+3
+4
+5
+6
22
32
42
50
59
68
15.01
30.02
45.03
60.02
75.05
90.06
Impact on Capital:
Under BASEL III Tier 1 capital will have to be the predominant form of regulatory capital. It
will be minimum 75% of the total capital of 8%. i.e. 50% of the total capital. Again, within Tier
1 capital, common equity will have to be the predominant form of capital. It will have to be
minimum 75% of the Tier 1 capital requirement of 6%, i.e. 4.5%, for the existing level of 2%.
It is evident that the meaning of predominant form of common equity in Tier 1 capital
portion in total capital as 50% under Basel 1 and 2 has undergone a change to 75% under
Basel 3, thus enhancing the overall level of high quality capital in the banks.
Furthermore, innovative features in non-equity capital instruments are no longer accepted in
BASEL III. As such, Tier 3 capital has been adequately brought to an end. The regulatory
adjustments or deductions from capital, which are currently applied at 50% to Tier 1 capital
and 50% to Tier 2 capital, will hence be 100% from the common equity Tier 1 Capital. Towards
improving market discipline, all elements of capital are supposed to be disclosed along with
a detailed reconciliation of reporting accounts. Thus the definition of capital in terms of
quality, quantity, consistency and transparency has improved under BASEL III. The average
Tier 1 capital ratio of Indian banks is around 10% with more than 85% comprising of common
equity. It is felt that Basel III regulations would affect the equity capital marginally.
Impact of Capital Standards:
Key Recommendations of BASEL
III
Possible Impact
Increased Quality of capital
Increased quantity of capital
Increase in credit
deployment
Introduction of
capital buffer
Increase in capital
requirements
Transition to upper
approaches of credit
risk
2
3
4
Impact on Tier 2
capital
Increase
Increase
Increase
Increase
Increase
Increase
Increase
Decrease
Decrease
Decrease
All the banks started reporting CAR ratio calculated as per BASEL-III norms from 201314
Regulatory requirement for CAR as per BASEL-III norms is minimum of 9%. All banks
are maintaining this minimum of 9%
Regulatory requirement for Tier I CAR is a minimum of 6.5% as per BASEL-III norms.
All 5 banks are maintaining this minimum of 6.5%
8.1. Banks Own Proactive Internal Approaches for Capital Adequacy Ratios
All banks have developed their own policies, methods and assessment techniques for proper
mapping of credit, operational, marker etc...type of risks in relation to projected business
growth. This is helping banks meet the regulatory requirements for capital adequacy ratios
by default. This is also mainly helping banks in proper assignment of capital and planning
which paves the way for expected growth. Technology based risk management systems are
also coming very handy for these risk assessment purposes. Adequacy of capital under stress
has also become integral part of banks Internal Capital Adequacy Assessment process (ICAAP).
The horizon for projections are typically for 2 to 3 years.
Thus banks identify, assess and manage comprehensively all risks that they are exposed to
through sound governance and control practices, robust risk management framework and an
elaborate process for capital calculation and planning.
Following are some of the risks being considered by banks during internal assessment
processes
Credit Risk, including residual risks
Credit Concentration Risk
Market Risk
Business Risk
Operational Risk
Strategic Risk
Interest Rate Risk in the Banking Book
Compliance Risk
Liquidity Risk
Reputation Risk
Intraday risk
Technology Risk
Model Risk
Counterparty Credit Risk
9. References
1. INTERNATIONAL BANKING REGULATION by Maximilian J.B. Hall and George G.
Kaufman, Dec 2002
2. A brief history of the Basel Committee, report by Bank For International Settlements,
Oct 2014
3. Financial Stability Report(Including Trend and Progress of Banking in India), RBI, Dec
2014
4. Banking Structure in India- Looking Ahead by Looking Back by Duvvuri Subbarao
5. Annual reports of SBI, UBI, HDFC, ICICI and Axis Bank for the year 2013-14
6. RBI Guidelines for implementation of Basel 3 norms-An overview.
www.allbankingsolutions.com/Banking-Tutor/Basel-iiiimplementationguidelines-RBI.htm
7. Comparison
of
Basel
II
and
III
norms.
http://www.allbankingsolutions.com/banking-tutor/basel-iii-accord-basel3- norms.shtml
8. Basel III: Implications for Indian Banking, Dr. Vigneshwara Swamy, IBS Hyderabad
9. https://www.princeton.edu/~hsshin/www/nr.pdf
10. http://www.narendramodi.in/capital-requirement-of-public-sector-banksraising-capital-from-public-markets-by-broad- basing-shareholding/
11. http://businesstoday.intoday.in/story/reserve-bank-of-india-rbi-tightens-rulesfor-nbfc/1/212188.html
http://www.businessstandard.com/article/finance/capital-raising-from-markets-by-govt-banksremains-a-challenge-rbi- 114122901091_1.html