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    Bank Capital Requirements

    The Basel Rules

    Basel I: 1988Basel II: 2002

    Basel II: 2010

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    Overall Basel Framework

    Pillar 1: Minimum capital requirements Credit risk:

    Standardized approach Relies on bond rating agencies

    Internal ratings-based (IRB) approach

    Allows bank estimates of probability of default and loss givendefault

    Securitization framework

    Operational risk

    Market risk

    Pillar 2: Supervisory review process

    Pillar 3: Market discipline

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    Minimum Capital

    Requirements

    Equity protects the deposit insurer:

    E / A 8%

    Issues: Definition / character of E

    Are assets A a valid proxy for risk?

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    The Basel Formula

    Tier1 Capital Tier II Capital 8%12.5(Mkt.Risk Capital Op.Risk Capital) Risk W eightedAssets

    Risk Weights x OnBSAssetsRisk WeightedAssets

    Conv.Factor x Risk Wts x OffBSCommitments

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    Constituents of Capital

    Tier I Core Tier 1: Common stock and retained earnings

    Less: Goodwill

    Less: Deferred tax assets

    Less: Investments in nonconsolidated subsidiaries

    Core Tier 1 must be 4.5% of RWA

    Other Tier 1: Perpetual instruments junior to subordinateddebt Total Tier 1 must be 6.0% of RWA [8.0% for large banks]

    Tier II General loan loss reserves up to 1.25% RWA

    Subordinated debt up to 50% of Tier I Original term 5 yrs

    Amortized for remaining term < 5 yrs

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    Risk-Weighted Assets

    Off-balance-sheet items are given a

    balance-sheet equivalent using a credit

    conversion factor (CCF).

    All assets and CCF equivalents are thenmultiplied by a risk weight and summed:

    Face

    Amount

    CCF Risk

    Weight

    Risk

    Weighted

    Assets

    8% Capital

    Required for

    Credit Risk

    Home mortgage loan 1000 35% 350

    3-year loan commitment 1000 50% 100% 500

    2-year FX forward

    contract with AA-rated

    bank

    1000 5% 20% 10

    Total 3000 860 69

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    Standardized Corporates

    Rating:AAA to

    AA-A+ to A-

    BBB+ to

    BB-

    Below

    BB-Unrated

    Risk

    weight: 20% 50% 100% 150% 100%

    Basel

    Capital: 1.6% 4.0% 8.0% 12.0% 8.0%

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    Standardized Sovereign Risk

    Rating

    Agency:

    AAA to

    AA-

    A+

    to A-

    BBB+ to

    BBB-

    BB+

    to B-Below B-

    Unrated

    ECA

    Score:1 2 3 4 to 6 7

    RiskWeight:

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

    Banks

    Option 120% 50% 100% 100% 150% 100%

    Banks

    Option 220% 50% 50% 100% 150% 50%

    3m w/Option 2

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

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    Standardized Retail

    Exposures

    Risk weight = 75% provided:

    Individual or small business borrower

    Loans, not securities

    Sufficient diversification (e.g. all < 0.2%)

    Low value of exposures (e.g. all

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    Credit Conversion Factors (CCFs)

    for Off-Balance-Sheet Items

    Direct credit substitutes CCF = 100%

    NIFs, RUFs, CP backup CCF = 50%

    Performance bonds, bid bonds CCF = 50%

    Trade credit, CCF = 20%

    Loan commitments Unconditionally cancelable, CCF = 0%

    1 year, CCF = 20%

    > 1 year, CCF = 50%

    Securities lending or posting as collateral, CCF = 100%

    Forward FX contracts 1 year, CCF = 1.0%

    1-5 years, CCF = 5.0%

    > 5 years, CCF = 7.5%

    NB: These are CCFs from Basel I. Basel II encourages

    banks to set their own CCFs here, but many continue touse Basel I.

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    Forms of Credit Risk

    Mitigation

    Collateral Securities, receivables, inventories, real

    estate

    Agreement to net deposits against loanexposure

    Amount of collateral < amount of loan?

    Guarantees Sovereign or corporate (bank)

    Credit derivatives Full term, partial term

    Rating of counterparty

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    Credit Risk Mitigation

    E* = max{0, [E(1+He) C(1-Hc-Hfx)]}where:

    E* = exposure after risk mitigation

    E = current value of exposureHe = haircut appropriate to exposure

    C = current value of collateral

    Hc = haircut appropriate to collateralHfx = haircut appropriate to FXmismatch

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    Standardized Haircuts (%)

    Rating Maturity Sovereigns Others

    AAA to AA- 1 year 0.5 1

    AAA to AA- 1-5 years 2 4

    AAA to AA- > 5 years 4 8A+ to BBB- 1 year 1 2

    A+ to BBB- 1-5 years 3 6

    A+ to BBB- > 5 years 6 12

    BB+ to BB- All 15 15

    Equities, Gold 15 15

    Minor Equities 25 25

    Mutual Funds Highest Highest

    Cash 0 0

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    Examples of Mitigation

    100 of 5-year corporate loan rated BBB-with full guarantee by A rated corporation:

    E* = 100(1.06) 100(0.94) = 12 100 of 5-year corporate loan rated BBB-

    with collateral of 80 in equities:

    E* = 100(1.06) 80(0.85) = 38 100 of 5-year corporate loan rated BBB-

    with guarantee of A rated sovereign:E* = 100(1.06) 100(0.97) = 9

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    Ratings Issues

    Ratings are central to the Basel II

    standardized approach.

    But corrupted ratings were at the heart ofthe 2008-9 financial crisis.

    Basel III tries to backpedal:

    Banks should assess credit risks directly. If banks have a specific assessment they can

    use it.

    Bank supervisors should authorize ratings

    firms.

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    The Internal Ratings-Based

    Approach (IRB)

    The preferred direction is toward

    banks making their own credit

    assessments.

    But should regulators allow any

    internal model to be used in setting

    capital?

    The Internal Ratings-Based Approach

    (IRB) has two variants:

    Foundations Approach

    Advanced Measurement Approach

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    Banks Provide Numerical

    Parameters

    Numerous specific asset classes

    Estimates needed for each class of:

    probability of default (PD) loss given default (LGD)

    exposure at default (EAD)

    effective maturity (M)

    In the foundations approach, bankestimates PD only; in advancedmeasurement, all.

    F d ti A h

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    Foundations Approach:

    PD and Capital

    RequirementsProbability of Default Capital Requirement

    0.03% 1.4%

    0.10% 2.7%

    0.25% 4.3%

    0.50% 5.9%

    0.75% 7.1%

    1.00% 8.0%

    1.25% 8.7%

    1.50% 9.3%

    2.00% 10.3%

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    Further Elements of IRB

    Separate formulas and prescriptions for each assetclass.

    IRB system must assess both borrower andtransaction.

    Bank must have sufficient internal data and range ofexposures (favors large banks).

    Assessment must include subjective factors as wellas mathematical models.

    IRB system must be documented and frequently

    back-tested and reviewed by management. Bank must have independent credit function.

    Board must approve IRB system.

    Senior management must understand and usesystem.

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    But What Model to Use?

    Many are available KMV

    CreditMetrics

    Credit Risk+ Credit Portfolio View

    All of these are portfolio-specific The risk of any asset depends on the

    portfolio in which it is embedded.

    Should regulators allow banks to usetheir own models to set capital

    requirements?

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    The Basel II Design

    Design requirements: Regulatory model should be portfolio-

    invariant.

    It should depend on the banks PD andLGD estimates.

    Only one class of model meets these

    requirements: Single risk factor, like CAPM

    Infinitely diversified, also like CAPM

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    So: Second Best

    Basel supplies a universal model Key property: VaR contributions are

    incremental

    The idea is to capture systematic riskonly

    Banks supply the parameter values

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    Advanced Measurement

    Approach

    Correlation R = 0.12 * (1-e-50*PD) / (1-e-50)

    + 0.24 * [1 - (1-e-50*PD) / (1-e-50)]

    Term adjustment b = (0.08451 -

    0.05898*ln(PD))2

    Capital requirement:

    K = LGD*N[(1-R)-G(PD) +(R/(1-R))G(0.999)]

    * (1-1.5b)-1 * (1+(M-2.5)*b)

    Risk-weighted assets RWA = 12.5 * K * EAD

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    Securitization Framework

    Applies to actual and syntheticsecuritizations, independent of legalform.

    Low-rated or unrated first-lossexposures are to be deducted fromcapital, half from Tier 1 and half fromTier 2:

    Rating AAA toAA-

    A+ toA-

    BBB+ toBBB-

    BB+ toBB-

    B+ orunrated

    Risk

    Weight

    20% 50% 100% 350% Deduct

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    Operational Risk

    Risk of (financial) loss resulting from

    inadequate or failed internal processes,

    people and systems, or externalevents.

    Three approaches: Basic Indicator,

    Standardized, and AdvancedMeasurement.

    Banks encouraged to keep moving up

    this spectrum.

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    Basic Indicator Approach

    K = 15% of gross income

    RWA increased by 12.5*K

    Gross income = net interest income

    plus non-interest income (before lossprovisions, excluding securities salesor extraordinary gains and losses)

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    Standardized Approach

    Corporate finance 18%

    Sales & trading 18%

    Retail banking 12%

    Commercial banking 15%

    Payment & settlement 18%Agency services 15%

    Asset management 12%

    Retail brokerage 12%

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    Advanced Measurement Approach

    Independent operational risk

    management function, closely linked to

    daily operations of the bank.

    Regular reporting of operating loss

    exposures and outcomes.

    System must be documented and

    audited.

    Must use scenario analysis (stress

    testing).

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    Market Risk

    Additional capital is required (beyond

    that required for credit and operational

    risk) to cover the risk of market

    movements.

    This applies to interest rate exposures

    and equity exposures in the trading

    book only.

    Applies to foreign exchange risk and

    commodities price risk throughout the

    bank.

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    Foreign Exchange Risk

    Sum the net long exposures.

    Sum the net short exposures.

    Capital required for net foreign

    exchange risk = 8% of the larger ofthese two.

    RWA equivalent = 12.5x capital

    required.

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    Total Capital Requirement

    Compute capital for credit risk: Excluding debt & equity securities in

    trading book and all commodities.

    But including all credit counterparty riskon all over-the-counter derivatives.

    Add the capital for operational risk.

    Add capital for market risk.

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    Basel III

    Basel III supplements Basel II. Crisis-inspired changes:

    Redefinition of tier 1

    Increases in risk weightings forsecuritizations, trading book and counterpartyrisk

    Dividend restraints

    Overall leverage ratio: Tier I 3% (A + OBS)

    Capital buffers: 2.5% extra common equityTier I

    Liquidity requirements Liquidity coverage ratio

    Net stable funding ratio

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    BIS Basel III Documents

    A. Strengthening the global capitalframework

    1. Raising the quality, consistency and transparency of the capital base

    2. Enhancing risk

    coverage

    3. Supplementing the risk-based capital requirement with a leverage ratio

    4. Reducing procyclicality and promoting countercyclical buffers

    Cyclicality of the minimum requirement

    Forward looking

    provisioning

    Capital conservation

    Excess credit growth

    5. Addressing systemic risk and interconnectedness

    B. Introducing a global liquidity standard

    1. Liquidity Coverage

    Ratio

    2. Net Stable Funding

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    Quantitative Impact Study,

    12/10 263 banks from 23 jurisdictions were

    studied, including 94 large banks.

    In large banks, trading profitability is

    much reduced (ROAE MorganStanley est.):

    Tier 1

    before

    Tier I after Liquidity

    Coverage

    Stable

    Funding

    Large banks 11.1% 5.7% 83% 93%

    Smaller

    banks

    10.7% 7.8% 98% 103%

    Equities

    Basel II

    Equities

    Basel III

    Fixed

    Income

    Basel II

    Fixed

    Income

    Basel III

    2010 19.1% 16.5% 14.1% 8.3%

    2012 est. 21.3% 18.9% 16.1% 10.3%

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    Implementation Schedule