Documente Academic
Documente Profesional
Documente Cultură
In India, at present, there is a ‘three track’ approach for Basel compliance – the
commercial banks are Basel I compliant with respect to credit and market risks; the
urban cooperative banks maintain capital for credit risk as per Basel I and market
risk through surrogate charges; and the rural banks have capital adequacy norms
that are not on par with the Basel norms . The three track approach is justified by
the necessity to maintain varying degree of stringency across different types of
banks in India reflecting different levels of operational complexity and risk appetite.
The three track approach is also justified in order to ensure greater financial
inclusion and for an efficient credit delivery mechanism.
The notion of capital adequacy
Banks and other financial institutions are, in their basic form, mediators of money
accepting deposits from the public on one hand and issuing credit on the other.
Banks earn, again very basically, from a financial spread between the interest rate of
credit issued to that paid on deposits accepted. As any other corporation the net of a
bank's asset and liabilities is the bank's capital.
This capital plays a very significant role in assuring the soundness and viability of a
bank as it can be perceived as a cushion, of sorts, which absorbs various losses the
bank may have due to the risks involved in its operations.
Any company, when bankrupt, may cause heavy losses to its close economic
environment. But the companies that were in business with the bankrupt company
had, or should have had the ability to manage the risks in doing business with that
particular company and were compensated for that risks by profits generated
through that business.
When a bank goes bankrupt the general public, which had trusted the bank to be
conservative enough to keep the deposit side intact, suffers. The public has very
little in the way of tools to ensure and manage the risks in their dealings with banks
(other than carefully choosing their bank).
Risks are abundant in banks and include mainly the credit risk incurred in lending
activities of not being repaid by the lender but also significant market risks due to
the financial nature of the business and significant operational risks due to the
complexity of banks' operations.
Banks are also exposed to many other risks such as legal risks, liquidity risk,
business risk, reputational risk and endless others.
The regulation regarding capital adequacy issued by the BIS are known as Basel I
and Basel II and contain detailed requirements and guidance on capital adequacy.
Essentially, this guidance break down the bank's off and on balance sheet items and
translates these items into what are known as Risk Weighted Assets (RWA) where
each asset receives a certain weighting dependant on the risk associated with it.
For example, a US government bond will receive a negligible risk weight while credit
issued to a non-ranked company will be weighted as 100% risky asset. These risk
weighted assets are than summed to receive the total risk weighted assets of the
bank and are translated into a capital requirement accordingly.
The regulation is very detailed and includes requirements both on the risk weighted
asset side and the capital side. Banks cannot recognize, for example, any sort of
capital as regulatory capital for the purpose of demonstrating capital adequacy.
Banks are expected to have capital buffers which are excess capital a bank holds,
over the regulatory requirements, to withstand unexpected risks and scenarios.
The problem, as we've experienced, begins when banks get involved in business that
has not yet received proper regulatory treatment. This issue will always be an open
issue as regulators usually react to market developments, thus always lagging
behind.
Use
Capital adequacy ratio is the ratio which determines the capacity of the bank in
terms of meeting the time liabilities and other risk such as credit risk, operational
risk, etc. In the simplest formulation, a bank's capital is the "cushion" for potential
losses, which protect the bank's depositors or other lenders. Banking regulators in
most countries define and monitor CAR to protect depositors, thereby maintaining
confidence in the banking system.
Basel I was an international accord to set minimum levels of capital for banks,
building societies and other deposit taking institutions. It was designed to create a
level playing field for lenders from different countries and to ensure that lenders
were sufficiently well capitalized to protect depositors and the financial system.
The first Basel Accord is now being replaced by a new accord, Basel II. The new
accord is being introduced to keep pace with the increased sophistication of lenders'
operations and risk management and overcome some of the distortions caused by
the lack of granularity in Basel I. Lenders had been able under Basel I to reduce
required capital in ways that did not reflect lower real risk (in what has become
known as regulatory capital arbitrage). The intention is that Basel II will align
required minimum capital more closely with lenders' real risk profile.
What are the main differences between Basel I and Basel II?
Capital adequacy ratios ("CAR") are a measure of the amount of a bank's capital
expressed as a percentage of its risk weighted credit exposures.
CAR = Capital
Risk
Where Risk can either be weighted assets or the respective national regulator's
minimum total capital requirement. If using risk weighted assets,
CAR = T1 + T2 ≥ 10%.
a
The percent threshold (10% in this case, a common requirement for regulators
conforming to the Basel Accords) is set by the national banking regulator.
Two types of capital are measured: tier one capital (T1 above), which can absorb
losses without a bank being required to cease trading, and tier two capital (T2
above), which can absorb losses in the event of a winding-up and so provides a
lesser degree of protection to depositors.
Risk weighting
Since different types of assets have different risk profiles, CAR primarily adjusts for
assets that are less risky by allowing banks to "discount" lower-risk assets. The
specifics of CAR calculation vary from country to country, but general approaches
tend to be similar for countries that apply the Basel Accords. In the most basic
application, government debt is allowed a 0% "risk weighting" - that is, they are
subtracted from total assets for purposes of calculating the CAR.
Local regulations establish that cash and government bonds have a 0% risk
weighting, and residential mortgage loans have a 50% risk weighting. All other
types of assets (loans to customers) have a 100% risk weighting.
Bank "A" has assets totaling 100 units, consisting of:
Cash: 10 units.
Government bonds: 15 units.
Mortgage loans: 20 units.
Other loans: 50 units.
Other assets: 5 units.
Bank "A" has deposits of 95 units, all of which are deposits. By definition, equity is
equal to assets minus debt, or 5 units. Bank A's risk-weighted assets are calculated
as follows
Cash 10 * 0% = 0
Government bonds 15 * 0% = 0
Total risk
Weighted assets 65
Equity 5
CAR
7.69%
(Equity/RWA)
Even though Bank "A" would appear to have a debt-to-equity ratio of 95:5, or equity-
to-assets of only 5%, its CAR is substantially higher. It is considered less risky
because some of its assets are less risky than others.
Regulatory capital
In the Basel I accord bank capital was divided into two "tiers", each with some
subdivisions.
Tier 1 capital, the more important of the two, consists largely of shareholders' equity.
This is the amount paid up to originally purchase the stock (or shares) of the Bank
(not the amount those shares are currently trading for on the stock exchange),
retained profits and subtracting accumulated losses. In simple terms, if the original
stockholders contributed $100 to buy their stock and the Bank has made $10 in
profits each year since, paid out no dividends and made no losses, after 10 years the
Bank's tier one capital would be $200.
Regulators have since allowed several other instruments, other than common stock,
to count in tier one capital. These instruments are unique to each national regulator,
but are always close in nature to common stock. These are commonly referred to as
upper tier one capital. Tier 1 capital is the core measure of a bank's financial
strength from a regulator's point of view. It is composed of core capital, which
consists primarily of common stock and disclosed reserves (or retained earnings),
but may also include non-redeemable non-cumulative preferred stock.
Capital in this sense is related to, but different from, the accounting concept of
shareholders' equity. Both tier 1 and tier 2 capital were first defined in the Basel I
capital accord and remained substantially the same in the replacement Basel II
accord.
Each country's banking regulator, however, has some discretion over how differing
financial instruments may count in a capital calculation. This is appropriate, as the
legal framework varies in different legal systems.
The theoretical reason for holding capital is that it should provide protection against
unexpected losses. Note that this is not the same as expected losses which are
covered by provisions, reserves and current year profits.
The Tier 1 capital ratio is the ratio of a bank's core equity capital to its total assets.
The Tier 1 risk based capital ratio is the ratio of a bank's core (equity capital) to its
total risk-weighted assets. Risk-weighted assets are the total of all assets held by the
bank which are weighted for credit risk according to a formula determined by the
Regulator (usually the country's Central bank). Most central banks follow the Bank
for International Settlements (BIS) guidelines in setting formulae for asset risk
weights. Assets like cash and coins usually have zero risk weight, while debentures
might have a risk weight of 100%.
A good definition of Tier 1 capital is that it includes equity capital and disclosed
reserves, where equity capital includes instruments that can't be redeemed at the
option of the holder (meaning that the owner of the shares cannot decide on his
own that he wants to withdraw the money he invested and so cannot leave the bank
without the risk coverage). Reserves are held by the bank, and are thus money that
no one but the bank can have an influence on.
Tier 1 capital is also seen as a metric of a bank's ability to sustain future losses
Tier 2 capital is a measure of a bank's financial strength with regard to the second
most reliable form of financial capital, from a regulator's point of view. The forms of
banking capital were largely standardized in the Basel I accord, issued by the Basel
Committee on Banking Supervision and left untouched by the Basel II accord.
National regulators of most countries around the world have implemented these
standards in local legislation.
Undisclosed reserves are not common, but are accepted by some regulators where a
Bank has made a profit but this has not appeared in normal retained profits or in
general reserves. Most of the regulators do not allow this type of reserve because it
does not reflect a true and fair picture of the results.
Revaluation reserves
General provisions
A general provision is created when a company is aware that a loss may have
occurred but is not sure of the exact nature of that loss. Under pre-IFRS accounting
standards, general provisions were commonly created to provide for losses that
were expected in the future. As these did not represent incurred losses, regulators
tended to allow them to be counted as capital.
Hybrid instruments
Hybrids are instruments that have some characteristics of both debt and
shareholders' equity. Provided these are close to equity in nature, in that they are able
to take losses on the face value without triggering a liquidation of the Bank, they may
be counted as capital.
Subordinated-term debt
Subordinated-term debt is debt that is not redeemable (it cannot be called upon to
be repaid) for a set (usually long) term and ranks lower than (it will only be paid out
after) ordinary depositors of the bank.
Risk weighted assets - Fund Based: Risk weighted assets mean fund based assets
such as cash, loans, investments and other assets. Degrees of credit risk expressed
as percentage weights have been assigned by RBI to each such assets. A bank's assets
weighted according to credit risk. Some assets, such as debentures, are assigned a
higher risk than others, such as cash.
Non-funded (Off-Balance sheet) Items: Obligations that are contingent liabilities
of a bank, and thus do not appear on its balance sheet. The credit risk exposure at-
tached to off-balance sheet items has to be first calculated by multiplying the face
amount of each of the off-balance sheet items by the credit conversion factor. This
will then have to be again multiplied by the relevant weightage.
Reporting requirements:
Banks are also required to disclose in their balance sheet the quantum of Tier I and
Tier II capital fund, under disclosure norms.
An annual return has to be submitted by each bank indicating capital funds,
conversion of off-balance sheet/non-funded exposures, calculation of risk -weighted
assets, and calculations of capital to risk assets ratio,
Tier I capital
Tier II capital
Tier I capital is the most permanent and readily available support against
unexpected losses. It consists of-
Less:
Indian Banks
ICICI 17.7%
HDFC 15.69%
Axis 16.5%
Citibank 13.23%
Average 15.23%
Average 13.24%