International regulatory framework for banks

Basel III

"Basel III" is a comprehensive set of reform measures, developed by the Basel Committee on Banking Supervision, to strengthen the regulation, supervision and risk management of the banking sector. These measures aim to: improve the banking sector's ability to absorb shocks arising from financial and economic stress, whatever the source improve risk management and governance strengthen banks' transparency and disclosures.

The reforms target: bank-level, or microprudential, regulation, which will help raise the resilience of individual banking institutions to periods of stress. macroprudential, system wide risks that can build up across the banking sector as well as the procyclical amplification of these risks over time.

Quality and level of capital Greater focus on common equity. The minimum will be raised to 4.5% of risk-weighted assets, after deductions. Capital loss absorption at the point of non-viability Contractual terms of capital instruments will include a clause that allows at the discretion of the relevant authority write-off or conversion to common shares if the bank is judged to be non-viable. This principle increases the contribution of the private sector to resolving future banking crises and thereby reduces moral hazard.

Capital conservation buffer Comprising common equity of 2.5% of risk-weighted assets, bringing the total common equity standard to 7%. Constraint on a banks discretionary distributions will be imposed when banks fall into the buffer range. Countercyclical buffer Imposed within a range of 0-2.5% comprising common equity, when authorities judge credit growth is resulting in an unacceptable

Securitisations Strengthens the capital treatment for certain complex securitisations. Requires banks to conduct more rigorous credit analyses of externally rated securitisation exposures. Trading book Significantly higher capital for trading and derivatives activities, as well as complex securitisations held in the trading book. Introduction of a stressed value-at-risk framework to help mitigate procyclicality. A capital charge for incremental risk that estimates the default and migration risks of unsecuritised credit products and takes liquidity into account.

Counterparty credit risk Substantial strengthening of the counterparty credit risk framework. Includes: more stringent requirements for measuring exposure; capital incentives for banks to use central counterparties for derivatives; and higher capital for inter-financial sector exposures. Bank exposures to central counterparties (CCPs) The Committee has proposed that trade exposures to a qualifying CCP will receive a 2% risk weight and default fund exposures to a qualifying CCP will be capitalised according to a risk-based method that consistently and simply estimates risk arising from such default fund.

Leverage ratio A non-risk-based leverage ratio that includes off-balance sheet exposures will serve as a backstop to the risk-based capital requirement. Also helps contain system wide build up of leverage.

Supplemental Pillar 2 requirements. Address firm-wide governance and risk management; capturing the risk of off-balance sheet exposures and securitisation activities; managing risk concentrations; providing incentives for banks to better manage risk and returns over the long term; sound compensation practices; valuation practices; stress testing; accounting standards for financial instruments; corporate governance; and supervisory colleges.

Revised Pillar 3 disclosures requirements The requirements introduced relate to securitisation exposures and sponsorship of off-balance sheet vehicles. Enhanced disclosures on the detail of the components of regulatory capital and their reconciliation to the reported accounts will be required, including a comprehensive explanation of how a bank calculates its regulatory

Liquidity coverage ratio The liquidity coverage ratio (LCR) will require banks to have sufficient high-quality liquid assets to withstand a 30-day stressed funding scenario that is specified by supervisors. Net stable funding ratio The net stable funding ratio (NSFR) is a longer-term structural ratio designed to address liquidity mismatches. It covers the entire balance sheet and provides incentives for banks to use stable

Principles for Sound Liquidity Risk Management and Supervision The Committees 2008 guidance Principles for Sound

Liquidity Risk Management and Supervision takes account of lessons learned during the crisis and is based on a fundamental review of sound practices for managing liquidity risk in banking organisations.

Supervisory monitoring The liquidity framework includes a common set of monitoring metrics to assist supervisors in identifying and analysing liquidity risk trends at both

 G20 Summit in Seoul endorsed the Basel Committee on Banking Supervision (BCBS) agreements on capital and liquidity (Basel 3). The G20 also endorsed the very long transitional periods for full implementation of the Basel 3 proposals. Despite the G20s objective of establishing a level playing field for banks, the reality is that countries are taking different paths over key issues like governance and remuneration, taxes and levies, the treatment of SIFIs, RRPs (or living wills), supervision, and even accounting and disclosure.

 This is partly driven by different starting points in terms of the impact on countries of the financial crisis, yet there remains underlying tension around the trade-off between safety within the financial system and its ability to support economic growth. The risk and regulatory reform agenda represented by Basel 3 needs also to be examined in light of the journey back towards financial stability. The prudential soundness of financial institutions is inextricably linked in a mutually reinforcing way to the macro-economic and fiscal soundness of the economies in which they operate.

 Despite the political agreement on the proposals at the G20, significant compromise was seen on the timeline for implementation as well as areas such as the treatment of Minority Interests, Deferred Tax Assets and the calibration of the leverage ratio which were the subject of intense debate between the BCBS and banks. Other key items, such as how to deal with SIFIs has been deferred for the French presidency to resolve.

Qualitative impacts of the proposals

Impact on individual banks Weaker banks crowded out Significant pressure on profitability and ROE Change in demand from short term to long term funding Legal entity reorganisation Impact on the financial system Reduced risk of a systemic banking crisis Reduced lending capacity Reduced investor appetite for bank debt and equity Inconsistent implementation of the Basel 3 proposals leading to international arbitrage

All elements of the capital ratio are affected by Basel 3

The enhanced capital ratios prescribed by the BCBS relate to the ratio of a firms eligible regulatory capital divided by a regulatory prescribed calculation of risk weighted assets. As set out in Figure 1, all three parts of this have changed putting more pressure on a firms compliance with the ratio. The capital ratio requirement has increased; the eligibility of capital has been tightened so reducing the amount of capital firms have to meet the required ratio; and the calculation of risk weighted assets has changed leading to an increase for many organisations.

All elements of the capital ratio are affected by Basel 3

Managing the potential increase to the RWA figure in the denominator is also crucial to mitigating the impact of Basel 3 on a firms portfolios. It is very difficult to estimate for each firm, but Figure 2 shows the possible percentage range of increases to the RWA arising from three of the key capital changes in Basel 3, tential RWA increase that many believe might occur.

 http://www.kpmg.com/BH/en/Documents/Bas el%203%20Pressure%20is%20building%E2%80%A6. pdf

Distribution
Distribution strategy Channels of distribution
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Distribution by channel
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Vertical Markets/Segments
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International
International distribution
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International pricing strategy Localization issues

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Success Metrics
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Schedule
18-month schedule highlights Timing
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