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Presentation to the CSRSA Conference June 13, 2006 by Peter Cheung, Manager Basel Implementation Division, OSFI
Contents
Overview of IRB Approval Process Key Supervisory Considerations Credit Data Reporting Overview Questions
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Contents
Overview of IRB Approval Process Key Supervisory Considerations Credit Data Reporting Overview Questions
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AIRB Banks submitted draft Rollout plans in Dec 2004. Formal Application date - Oct 31, 2005 Parallel run Nov 1, 2006 OSFI conditional approval of applications July 31, 2007 Accord Implementation - Nov 1, 2007
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Phase 1- Monitoring of implementation efforts (Nov/04 to Jan/06) Phase 2 - Formal application (Feb/06 to July/06) Phase 3 OSFI approval reviews (Aug/06 to July/07) Phase 4 Pillar 1 approval ( Aug/07 to Dec/07 or Feb/08) Phase 5 Ongoing monitoring (from Nov/07)
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Supervisory Activities:
Gap Meetings and status updates ongoing activity, focused on implementation progress against rollout plans, updates to extensions/waivers, changes to PMO & budgets RRS Specific Reviews (Examinations) - verification of self-assessments ( in coordination with IA work). Microlevel, specific sampling using criteria/standards focused on Minimum Requirements & Implementation Notes Review & monitoring of data submissions for accuracy, timeliness & completeness
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Contents
Overview of IRB Approval Process Key Supervisory Considerations Credit Data Reporting Overview Questions
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Domestic Use Test expectations are set out in OSFIs IRB Implementation Note Use Test is an entry condition for IRB approaches, viz.
IRB processes should be integrated with overall risk management Banks should use the most appropriate measure for the purpose at hand, however, banks must show an implementation consistent with IRB Banks can use point-in-time measures for capital planning and through-the-cycle measures for IRB, but both measures should be consistent with a underlying common model
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There are a number of individual elements related to use test that could potentially be considered:
Pricing
The use and application of risk-based pricing Conditional vs. unconditional PDs
Performance Measurement
Contract definition and incentive-compatibility
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Use expectation of individuals and groups should be commensurate with their respective role and responsibility Other perspectives of use test
Board and senior management oversight of IRB systems History of using processes, models, parameters
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Banks must have a robust system in place to validate the accuracy and consistency of rating systems, processes, and the estimation of all relevant risk components
Internal validation processes should be designed to provide an EFFECTIVE CHALLENGE to the outputs of internal rating systems
Risk quantification and validation remains a key implementation focus for banks and supervisors
The Accord Implementation Groups Validation Sub-Group (AIGV) is a forum for supervisors to promote IRB validation (and implied risk quantification) discussion and information exchange
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A flexible system that allows risk management to evolve and permits banks to answer new questions with old data
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Validation processes should create a mosaic of evidence by combining information from various sources (both quantitative and qualitative)
The effective challenge principle permits a range of possible approaches to structuring this work
Data limitations mean an increasing and necessary role for expert judgment (credit experts and quants are complements not substitutes!)
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Review and explanation of capital reporting requirements is key to managing expectations of different stakeholders
Parallel reporting is the first real opportunity for a meaningful dress-rehearsal of systems and processes that support capital computation Analysis of results is essential to promoting greater comfort with the outputs of Pillar 1 approaches recognizing and relating changes/differences to risk comparing capital drivers over time (and to QIS) continued track record, post-implementation
Conclusion on Self-Assessment
Approval Recommendation
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Contents
Overview of IRB Approval Process Key Supervisory Considerations Credit Data Reporting Overview Questions
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Background
OSFI presently collects supervisory data from banks for the following:
Financial Statements Credit Risk Market Risk Liquidity Capital Securitization
Basel II requirements for approval and ongoing on-site work and monitoring, resulted in revising the capital and credit risk data requirements. Allowed flexibility in the data requirements during the parallel run period Also provided flexibility in reporting requirements for domestic and international subsidiaries for capital and credit risk data.
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Portfolios that intend to report on the IRB Approach, begin reporting Oct 31st 2006
Portfolio Approach Internal Ratings Based Ready and Approved Expected by Nov 1, 2007
Begin reporting Oct 31, 2006 for 4 quarters (i.e., Q1, Q2, Q3 and Q4 of 2007) of meaningful dress rehearsal
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Initial focus is on the Deposit Taking Institutions adopting the Advanced Internal Ratings Based Approach although similar deliverables have been created for those that have adopted the Standardized Approach. CBA has received business and data definitions from OSFI. These documents are also available on the OSFI website.
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QUESTIONS?