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    Banking, Financial Services & Insurance

    The Journal of

    Compliance

    Risk &

    Opportunity

    VOL V Issue 9July 2011

    Technical Computing

    in Risk Management

    Basel III:

    Celent Report

    HDFC Bank Upgrades to

    TCS BaNCS Treasury 5.0

    FINANCIAL STABILITYRBI Publishes its Third Report

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    J u l y 2 0 1 1

    Editors

    Note

    Financial stability had begun receiving global attention at the turn of the millennium,

    when the Financial Stability Forum was founded in 1999 by the G7. Ten years later, in

    2009 it was expanded by G20 and renamed as Financial Stability Board. In 2010, 27

    member states of the European Union established The European Financial StabilityFacility to ensure financial stability in Europe. In the US, The Office of Financial Stability

    was created by the Emergency Economic Stabilization Act of 2008, and The Financial

    Stability Oversight Council was created by the DoddFrank Act 2010. The Reserve Bank

    of India has been concerned with stability of the financial sector so far. But, the

    emergence of financial conglomerates on one hand, and products such as unit-linked

    insurance on the other, gave rise to inter-regulatory disputes over span of controlthe

    SEBI IRDA spat is still fresh in the memory of Indian financial sector.

    The post crisis focus on establishing an institutional mechanism for coordination among

    regulators and the Government has culminated in the establishment of the Financial

    Stability and Development Council (FSDC) in December 2010 to be chaired by the Union

    Finance Minister. Still, the role of the RBI as systemic regulator has not diminished, as

    is exemplified by its release of third Financial Stability Report last month, the gist of

    which forms the cover story of this issue.

    A detailed discussion of how to build software to estimate a credit value-at-risk (VaR)

    measure for a bond portfolio is another highlight of this issue. Launch of a new version

    of treasury solution by TCS and an automated regulatory reporting system for banks to

    meet the RBI guidelines, are also covered in this issue.

    Finsight MediaTF-07, Suner Complex

    Harinagar Crossing, Gotri Road

    Vadodara 390 021

    Tel: +91-265-6533475

    Email: [email protected]

    Website: www.finsight-media.com

    Publisher

    T S Chandrasekaran

    [email protected]

    Editor

    Hari Misra

    [email protected]

    Advertising

    Amita [email protected]

    Production

    Sanket Vohra

    [email protected]

    Design

    Chandrakant Kokje

    Copyright Finsight Media.All rights reserved. Neither this publication nor

    any part of it may be reproduced, stored in a

    retrieval system, or transmitted in any form or

    by any means, electronic, mechanical,

    photocopying, recording or otherwise, without

    the prior written permission of Finsight Media.

    Published monthly.

    MAHENG/2006/19566.

    Compliance Risk and Opportunity

    Published by T S Chandrasekaran

    Bldg. No. A-4, Flat No. 2-B,

    Sujata Co-Op. Society, Bund Garden,

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    Spectrum Offset, D-2/4, Satyam Estate,

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    Price Per Copy: INR 50Annual subscription: INR 600

    Hari Misra

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    HDFC Bank Upgrades to 6

    TCS BaNCS Treasury 5.0

    iCREATE Launches Automated 8

    Regulatory Reporting Solution

    for Banks

    FINANCIAL STABILITY 10RBI Publishes its Third Report

    Technical Computing 14

    in Risk Management

    Basel III 20Navigating Business and Risk Technology

    Architecture Decisions

    in brief 23

    ONE SIZE DOESNT FIT ALL 25Risky Business for Hedge Funds When Selectinga Business-Critical System

    in brief 26

    CONTENTS

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  • 8/2/2019 CRO-July-11

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    COMPLIANCE, RISK & OPPORTUNITY6

    J u l y 2 0 1 1

    TCS Financial Solutions, a

    strategic business unit of Tata

    Consultancy Services (TCS) has

    recently launched TCS BaNCS

    Treasury 5.0.

    HDFC Bank, which had

    implemented TCS treasury

    solution in 2008, has upgraded to

    the new version. We had found

    the features of quick go-to-market

    with interfaces and facilitation for

    Sarbanes Oxley compliance, mostuseful for our bank, recalls Harish

    Shetty, executive vice president,

    IT, HDFC Bank. As an existing

    customer of TCS BaNCS Treasury

    solution, he lists the personalised

    single workspace feature along

    with browser based platform

    agnostic SOA-ready Java EE

    architecture features of the latest

    version, features in the recently

    released version 5.0, which made

    him to go for the upgrade.

    Apart from HDFC Bank, two other

    banks have opted to upgrade to

    the new version, informs NG

    Subramaniam, president, TCS

    Financial Solutions declining to

    name them. We are in advanced

    stage of discussions with other

    clients to enable them to upgrade,

    he says.

    TCS BaNCS Treasury 5.0 is an

    integrated solution whichsupports multi-entity, multi-

    currency, multi-asset class system

    with process coverage for front-,

    mid- and back-office operations.

    One of the key enhancements in

    Treasury 5.0 is the five-layered

    hierarchical portfolio structure,

    which aligns to the desk, book

    and folder organisation in a

    treasury, informs Subramaniam.

    This layered approach helps a

    treasurer with added transparencyin identifying the source of risk

    and revenue. This is further

    strengthened by intuitive position

    transfer capabilities from sales

    desks to the market desks, who in

    turn are the real position owners,

    he elaborates. The mid- and back-

    office have always been a strong

    area for us. With real-time

    analytics, blotters and

    comprehensive position keeping

    in 5.0, we have taken a taken a

    significant upstream move into

    the front office, he adds.

    According to Subramaniam, other

    enhancements include an openframework for derivative

    structures and strategies and the

    ability for market curve

    management. Through the

    former, a number of derivative

    structures and strategies can be

    created on the fly, or standardised

    for future use. Traders can quickly

    cobble up a strategy, price it and

    then execute the same with the

    counterpart. The ability to source

    market information has beenexpanded to cover synthetic curve

    generation, advanced features as

    bootstrapping, various curve

    fitting techniques and the ability

    to value a position or deal using

    multiple curves based on

    purposes such as from the front-

    office perspective or the back-

    office accounting perspective, he

    says.

    The personalised single

    workspace which Shetty likes,

    provides the user with a capabilityto configure and personalise

    screen layouts. This enables users

    to execute a days operation

    without navigating through a

    maze of menus. TCS BaNCS

    Treasury 5.0 is an SOA ready,

    browser-based solution with Java

    EE architecture. The platform

    agnosticism helps achieve a lower

    total cost of ownership (TCO)

    while giving the institution various

    options for hardware and

    database platforms, asserts

    Subramaniam.

    What were the key drivers for the

    new version? The Treasury and

    Capital Markets space is a highly

    volatile one in terms of new

    instruments, structures,

    regulatory frameworks, risk

    measurement techniques,

    observes Subramaniam. Our

    product strategy is tightly aligned

    with sales and marketingstrategies. The teams constantly

    interact with customers, analysts,

    industry bodies to provide

    directions to the roadmap. The

    personalised single workspace

    and SOA ready platform agnostic

    architecture are directions which

    we took from our customer

    forums at the backdrop of SIBOS

    events held every year, while the

    recent regulatory activism has

    helped us formulate the desk-book-folder approach and rich

    HDFC Bank Upgrades to

    TCS BaNCS Treasury 5.0

    Harish Shetty

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    COMPLIANCE, RISK & OPPORTUNITY 7

    analytics. The hierarchical desk-

    book-folder alignment using the

    layered portfolio definition is a

    key element in our product

    differentiation, says Subramaniam.

    With increasing regulatory

    oversight, it is imperative for

    banks to ensure transparency,

    which TCS BaNCS Treasury

    provides. Banks are able to review

    their performance, exposure, and

    risk profile in real time, monitor

    pre- and post-trade compliance

    results, all with the backdrop of arobust audit trail capturing every

    action in the system. Further, the

    comprehensive five-layered

    portfolio structure provides a

    logical demarcation of proprietary

    trading and client trading

    activities. The risks and revenue

    recognition is also based along

    with the portfolio structure,

    explains Subramaniam.

    BaNCS Treasury 5.0 enjoys the

    execution capabilities of the

    supplier with its solution centres

    dotted round the globe to ensure

    the nearness to the client for

    support. In the near-term, the

    Middle East (inclusive of Turkey) is

    a target for us. We are taking a

    focused approach towards this

    market in terms of additional

    support for Islamic products

    and processes, informs

    Subramaniam.

    Outlining the roadmap for the

    product for the next two-three

    years Subramaniam says that

    tremendous potential is emerging

    in the arena of Cloud Computing.

    Standardised functions such as

    settlements, confirmations,

    among others, can be placed on

    the cloud to allow multiple

    tenants to utilise standard

    functions. Secondly, the solution

    will be iPad ready, which isanother important step for us.

    HDFC Bank uses point solutions

    for derivative pricing, liquidity risk

    management etc in addition to

    BaNCS Treasury. It also uses a

    third party system for managing

    market risk. But for limit

    monitoring, we use this solution,

    says Shetty.

    Commenting on pros and cons of

    using a set of best-of-breed point

    solutions against using an

    integrated solution, especially in

    case of treasury solutions, Shetty

    says that while best-of-breedpoint solutions do provide rich

    functionality; integration,

    standardisation, support

    availability, reduced straight-

    through-processing capabilities

    and vendor management pose a

    challenge.

    An integrated solution provides

    better integration across asset

    classes, front-to-back integration,

    and standardised messaging with

    enterprise systems. There is a

    single vendor to manage. But, for

    an integrated solution time to

    market is a challenge, he says.

    However, Subramaniam opines

    that with regulators permitting

    new asset classes, an integrated

    solution will be preferred over

    point-solutions despite pros and

    cons attached to each.

    .

    Commenting on the replacementmarket for treasury solutions in

    India, Subramaniam says that with

    Indian banks expanding overseas

    there will be a growing need for a

    multi-entity solution. Regulatory

    compliance, such as impending

    IFRS convergence in India will call

    for an overhaul of the existing

    treasury systems, especially, on

    the front of IAS 39, among others.

    With India taking steps towards

    full convertibility, the existingdual currency systems of Indian

    treasuries have to transform to

    multi-currency systems and that

    will call for a major overhaul

    across systems.

    We also see a potential in the

    corporate segment in India. India-

    based MNCs are in need of a

    specialised treasury system with

    hedge management capabilities

    over and above the generic ERP

    coverage, he emphasises.

    In the evolving regulatory

    framework, which activity will

    become more profitable-

    managing banks own treasury or

    offering treasury products tocorporates? The objective of

    managing bank's own treasury is

    more to protect core income,

    while offering treasury products

    to customers is to generate the

    profits, explains Shetty. Both are

    equally important, he says.

    Among his wish-list from a future

    treasury solution are: offering on

    cloud, trading on iPad/mobile

    devices and better integrationwith other systems.

    J u l y 2 0 1 1

    NG Subramaniam

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    Bangalore-headquartered iCreate

    Software launched its reporting

    solution Biz$core to enable banks

    comply with automated data flow

    guidelines outlined in the

    approach paper of Reserve Bank

    of India (RBI) published in

    November 2010 to enhance data

    quality, ensure data integrity,

    accuracy and timely reporting. The

    paper was prepared by a coregroup consisting of experts from

    banks, RBI, Institute for

    Development and Research in

    Banking Technology (IDRBT) and

    Indian Banks Association (IBA).

    The paper suggests the

    methodology to be adopted by

    banks to classify themselves into

    a cluster based on its technology

    and process dimensions. Banks

    are required, in the first phase, to

    ensure seamless flow of data from

    their transaction server to their

    management information system

    (MIS) server and automatically

    generate all returns from the MIS

    server, without any manual

    intervention. In the second phase,

    RBI plans to introduce a system

    for the flow of data from the MIS

    server of banks in a straight

    through process. Banks have been

    given sufficient time for

    completing the first phase of the

    project.

    Vivek Subramanyam, CEO, iCreate

    Software spells out the details of

    this solution in an exclusive

    interview with CRO. Here are the

    edited excerpts:

    CRO:Main concern of regulators

    worldwide, RBI included, is

    transparency in regulatory

    reporting. How does iCreates

    Biz$core solution ensure thistransparency?

    Vivek:Regulators worldwide seek

    transparent and accurate

    reporting, which translates to

    automated straight-through

    reporting without any manual

    intervention. This requires

    technology solutions which can

    automatically collate data from

    multiple banking transactional

    systems and transform it into

    reports that the regulator requires

    periodically, and automatically

    transmit these to the regulator.

    Such a solution would ensure

    transparency and accuracy.

    Our Biz$core is a packaged

    business intelligence and analytics

    solutions built specifically for

    banks. One of the Biz$core

    components is a central bank

    reporting solution that would help

    banks achieve exactly that. In the

    Indian context, this solution is

    called Biz$core RBI ADF

    (Automated Data flow) Solution.

    This solution is an extensible and

    comprehensive regulatoryreporting solution with advanced

    features such as pre-built RBI

    returns, in-built workflows,

    automated returns submissions

    supporting XBRL, XML and XLS,

    business configurations, reference

    data management, data lineage

    and metadata management,

    adjustments and audit trail.

    The solution also has the

    additional strategic advantage ofhelping a bank jumpstart its

    business intelligence and analytics

    initiative. The compliance solution

    that is built around Biz$core can

    very easily be scaled and

    extended to be an enterprise

    business intelligence solution

    given Biz$cores modular

    approach and thus can transform

    to becoming a strategic decision

    support ecosystem for the bank in

    addition to helping them comply

    with RBI reporting requirements.

    CRO:How does your solution

    automatically gather data from

    multiple systems of the bank?

    How much customisation does the

    solution require to get data from

    all such systems?

    Vivek:Biz$core comes with a data

    integration framework where

    predefined adapters exist that are

    transaction system aware. Wehave productised the process of

    connecting to and accessing data

    from typical banking transactional

    systems such as core banking,

    treasury, GL, credit cards, trade

    finance, etc. This data integration

    framework drastically reduces the

    time it takes to have Biz$core up

    and running in a bank. Typical

    transaction systems come in

    various versions and have some

    level of bank specificcustomisations as well. To that

    COMPLIANCE, RISK & OPPORTUNITY8

    J u l y 2 0 1 1

    iCREATE Launches Automated

    Regulatory Reporting Solution for

    Banks

    Vivek Subramanyam

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    J u l y 2 0 1 1

    COMPLIANCE, RISK & OPPORTUNITY 9

    extent, there is a need to

    customise the data adapter

    framework to fit in at each bank.

    However, Biz$core ensures that

    the data integration is achieved

    easily and in around 30 to 40

    percent of the time it would take

    using traditional methods.

    CRO:How much time would a

    typical bank require to become

    fully operational on this solution?

    Vivek:Though RBI has defined a

    framework for each Bank toassess their maturity and based

    on that a timeframe is prescribed

    by when the solution needs to go

    live. Independent of this, our

    solution has different deployment

    flavours available based on the

    maturity of each bank. Depending

    on whether a bank has a data

    warehouse or not, the bank has

    data that needs some focus on

    data quality or not and some

    other parameters, we have three

    implementation approaches and

    the right choice of implementation

    approach would need to be made

    for each banks specific context.

    Keeping the above variations in

    mind, some banks could have the

    solution up and running in as

    little as 8 weeks while for some it

    could take around 24 weeks.

    CRO: How does the bank extend

    this solution to include future RBI

    reporting requirements?

    Vivek:Banks have different

    choices available for them to

    become RBI ADF compliant. They

    could build such a solution in-

    house or outsource the

    development of a bespoke

    application to a system integrator

    or they could choose a product

    like Biz$core. Each choice has its

    own implication in terms of

    effectiveness, lead time, cost andquality.

    With the Biz$core solution, in

    addition to the advantages stated

    above, banks would be future

    proofing their RBI ADF solution.

    RBIs regulatory compliance

    requirements would continuously

    evolve and the solution deployed

    would need to be changed to

    ensure that banks keep up with

    the changes in requirements. With

    a productised solution, banks

    need not have to worry about this

    scenario. We will be tracking the

    compliance requirements closely

    and will be releasing upgrades tothe product that ensure that this

    is up-to-date and this makes it

    extremely hassle-free for a bank

    when it comes to dealing with and

    staying on top of ever changing

    regulatory requirements from the

    central bank.

    CRO:What would be needed to be

    done if a bank replaces any of its

    back office point solution?

    Vivek:Irrespective of changes to

    a banks back office solutions, our

    solution would continue to be

    relevant, with minimal changes.

    This is because the product has a

    data model defined specific to the

    solution and which expects

    specific sets of data from specific

    systems at a certain periodicity.

    For example, when System A is

    being replaced by System B, the

    effort that will need to be put in

    would be to start sourcing all thedata that was earlier being

    sourced from A to B now.

    Integration with B is relatively easy

    again considering the robust

    nature of Biz$cores data

    integration framework.

    CRO:Has the solution been

    audited for compliance

    requirements?

    Vivek:One way to audit the

    solution would be to run thesystem on historical data and

    compare the output with the

    reports that were actually

    submitted at that time. This would

    need to be done as part of each

    implementation at every bank.

    Other than this, there are no

    specific audits or certifications

    needed for such a solution,

    currently. As and when clarity

    emerges around the need for such

    a solution to be audited or

    certified, we would be ensuring

    that the solution definitely gets

    certified.

    CRO:Did you partner with any

    bank for developing this solution?

    Vivek: No, we developed this

    independently and did not partner

    with any bank to build this. But

    we did build a team of bankers

    and ex-bankers who have

    significant experience in

    compliance area to help us define,

    architect and build the solution.

    CRO:Which platform does it use?

    Vivek:The Biz$core technology at

    a high level comprises of three

    components. We have OEM-ed

    industry leading and award

    winning technology around

    BI/OLAP, data integration

    platform, and built our solution

    embedding these. From a

    customer standpoint, this is

    abstracted and they just need to

    buy our product alone and all thetechnology needed to power the

    solution will be part of the

    Biz$core license. One flavour of

    our product uses industry leading

    platforms Microstrategy and

    Informatica and this flavour is

    platform and database

    independent. Another flavour of

    our product is built around the

    best-in-class Microsoft platform.

    Depending on the preference of

    each customer, we deploy theflavour of the solution.

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    COMPLIANCE, RISK & OPPORTUNITY10

    The first FSR was released in

    March 2010 and the second in

    December 2010. According to RBI,

    now onwards FSRs will be released

    bi-annually in June and December

    every year. In his foreword to the

    report, Dr D Subbarao, governor,

    RBI observes: Ensuring financialstability cannot be a formulaic

    rule-based task. The endeavour

    for the policy makers should be to

    not get trapped in commoditised

    ideas, reductive categories and

    prepackaged narratives.

    The FSR is divided into five

    chapters on macroeconomic

    outlook, financial markets,

    financial institutions, financial

    sector policies and infrastructure,and macro-financial stress testing.

    Macroeconomic developments

    The global risk scenario has

    improved during the last six

    months, though there are signs of

    a slowdown in growth during

    2011 in most countries, including

    some of the developingeconomies in Asia. The main

    factors affecting the global growth

    are: high food, commodity and

    energy prices, steps towards fiscal

    consolidation, sovereign debt

    problems in the Euro area and

    high level of government debt in

    some advanced economies. Also,

    the main underlying factors

    behind global imbalances remain

    largely unaddressed, increasing

    the uncertainty in global recovery.The sovereign debt crisis in

    countries like Greece, Portugal,

    and Ireland is posing serious

    challenges for the stability in the

    entire Euro area. The increasingly

    high levels of government debt in

    other advanced countries are also

    adding to the uncertainty around

    the fiscal consolidation and itsimpact on international financial

    markets. Although the Emerging

    Market Economies (EMEs) have

    more comfortable fiscal space and

    better growth prospects, there are

    still significant risks on the fiscal

    front, given the complex inter-play

    between growth and inflation.

    The slackening of global recovery,

    high oil and commodity prices,

    deceleration in domesticindustrial growth, uncertainty

    FINANCIAL STABILITYRBI Publishes its Third Report

    This article is a gist of the third Financial Stability Report (FSR) published by the Reserve Bank of India (RBI)

    last month, presenting its assessment of the health of Indian financial sector. The 70-page report, which

    contains 9 boxes highlighting a concept each, 125 charts, 11 tables, and an annexure on stress testing

    methodologies, can be accessed by interested readers at

    http://www.rbi.org.in/scripts/PublicationReportDetails.aspx?UrlPage=&ID=635--Ed.

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    COMPLIANCE, RISK & OPPORTUNITY 11

    about continuation of strong

    growth in agricultural sector and

    impact of monetary policy actions

    pose downside risks to India's

    Gross Domestic Product (GDP)

    growth during 2011-12. The

    slowdown in growth momentum

    may affect the quality of the

    assets of financial sector. The

    international prices of food,

    energy and commodities are

    expected to remain high during

    2011-12. Although there has been

    some decline recently in

    international oil prices, this maynot help in inflation management

    as complete pass-through of

    previous escalations is still to be

    affected. Inflation is likely to face

    upward pressure from higher

    subsidy expenditure of the

    government and rise in wages and

    raw material prices. Housing

    prices have undergone some

    correction but continue to stay

    firm. Gold prices continue to

    increase on the back of strong

    demand.

    Recent growth in India's exports

    may off-set, at least partially, the

    expected increase in the import

    bill due to elevated oil and

    commodity prices. There does not

    seem to be an impending

    pressure on the financing of CAD.

    However, going ahead, as the

    advanced economies exit from the

    accommodative monetary policy,

    there could be some slowdown incapital inflows. In the wake of

    high international commodity and

    oil prices, the budgetary

    projections of deficits for 2011-12

    are expected to come under

    pressure. Management of

    government expenditure,

    especially subsidies bill, will pose

    challenges to the process of fiscal

    consolidation. This could be

    further accentuated by a tempered

    growth adversely impacting therevenue collections.

    Financial markets

    During the last six months, global

    financial markets have been

    resilient, overcoming a short

    phase of heightened volatility

    caused by the earthquake in Japan

    and political tensions in Libya and

    other parts of the Middle East and

    North Africa (MENA). The

    forecasted value for Financial

    Stress Indicator (FSI) for India, a

    measure to capture the severity of

    contemporaneous developments

    as they occur in different marketsegments and the banking sector,

    suggests benign conditions in the

    near term.

    The sovereign debt crisis is

    threatening to affect some of the

    bigger economies even as the

    high deficit and debt levels in

    Advanced Economies (AEs) like US,

    UK and Japan could exert further

    pressure on their sovereign rating

    outlook. The low economic growth

    combined with the high levels of

    debt in these countries is

    adversely impacting market

    sentiments. Continued concerns

    regarding sovereign risk could

    raise the funding costs of the

    financial sector and have a

    negative impact on its balance

    sheet. Evolving regulatory changes

    will require financial institutions

    to raise fresh capital even as they

    face a wall of refinancing at a time

    when sovereigns in AEs also havehigh borrowing programs. The

    sustained demand and growth in

    EMEs are providing strong

    impetus to commodity prices but

    the increasing financialisation of

    commodity markets might be

    adding to the volatility in

    commodity prices. It could also

    result in an increased correlation

    between financial and commodity

    markets, thereby facilitating faster

    transmission of shocks acrossmarkets.

    In spite of a sharp turnaround in

    Government cash balances with

    the Reserve Bank during the

    current financial year, liquidity in

    the system remained in a deficit

    mode reflecting an increase in

    liquidity requirements of the

    economy. The increase is mainly

    attributable to strong credit

    demand and high level of currency

    in circulation. However, the

    overnight call rates have remained

    range-bound. The collateralised

    markets continued to remain the

    predominant money marketsegment of the money market.

    The government bond yields

    hardened across all maturities.

    The increase was more

    pronounced in the short end

    resulting in a flattening of the

    yield curve. Rupee has remained

    range-bound, reflecting a

    relatively balanced external

    account and the general weakness

    experienced by the US dollar

    during the period.

    Availability of alternative channels

    of funding has reduced the

    dependence of firms on domestic

    bank credit over the years. Rising

    domestic yields are widening the

    interest rate differentials vis--vis

    AEs, resulting in a greater access

    to External Commercial

    Borrowings (ECB) by Indian firms.

    This trend is causing a build-up of

    currency mismatches in their

    balance sheets. During the periodfrom 2005 to 2008, large

    amounts were raised through

    Foreign Currency Convertible

    Bonds (FCCBs) by many Indian

    companies with elevated

    conversion premia. Most of them

    are nearing maturity by March

    2013. Estimates show that a very

    large proportion of these FCCBs

    may not get converted into equity

    thus requiring their refinancing at

    the much higher interest ratesprevalent today.

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    COMPLIANCE, RISK & OPPORTUNITY12

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    During 2010, Indian capital

    markets received a significant

    amount of net portfolio capital

    flows. These flows tend to be

    more volatile, though their impact

    on the domestic macroeconomic

    situation so far has been limited.

    While equity markets in India have

    undergone some downward

    correction with Foreign

    Institutional Investors (FIIs) pulling

    money out, the bond markets

    have seen incremental flows on

    account of attractive yields and

    the recent enhancement of limitsfor FII investment in corporate and

    government bonds. An internal

    study points to tendency of the

    portfolio capital flows to be 'auto-

    correlated' thus implying 'herd

    behaviour', both in good times as

    well as during times of stress.

    Program trading systems in

    Indian stock markets

    Encouraging the use of

    Algorithmic trading and High

    Frequency Trading (HFT) adds to

    the efficiency and liquidity of

    markets but carries some risks

    too. Indian securities markets

    have withstood systemic events in

    the past, without any major

    disruption. Even as facilities like

    Smart Order Routing (SOR) are

    introduced in Indian stock

    exchanges, events like 'flash

    crashes' witnessed in US equity

    markets in May 2010, need to beguarded against.

    Banks

    The recovery in economic growth

    during 2010-11 has been

    accompanied by a strong credit

    growth and slight decline in Non

    Performing Assets (NPAs). The

    banking sector balance sheet

    increased by 19 percent during

    the year ended March 31, 2011,spurred by a robust growth of

    22.6 percent in credit off take.

    The growth in deposit

    mobilisation, at around 18

    percent did not keep pace with

    the growth in credit, the gap

    being funded through an

    increasing share of market

    borrowings. This increased

    reliance on borrowed funds raised

    concerns about the liquidity

    position of banks arising from

    growing maturity mismatches, in

    conjunction with a reduction in

    the share of liquid assets in total

    assets.

    Asset quality improved mainly on

    the back of the credit growth

    which outpaced the growth in

    NPAs. The write-offs of NPAs by

    banks to cleanse their balance

    sheets also helped in achieving a

    lower gross NPA ratio. The

    contribution to the credit growth

    was disproportionately high for

    three sectors retail, commercial

    real estate and infrastructure. As

    each of these sectors have a

    peculiar set of asset quality

    propositions, the brisk growth in

    exposure seen during 2010-11

    poses some concerns. The asset

    quality under the priority sector

    lending, especially agriculture,

    deteriorated at a faster rate as

    compared to the overall asset

    quality. The system level CRAR

    under Basel-II norms stood at 14.3

    percent as at end March 2011

    which was well above theregulatory minimum of 9 percent.

    There was, however, a slight

    decline over the CRAR of 14.5

    percent as at end March 2010,

    largely due to robust credit off

    take. All the bank groups had

    CRAR above 12 percent as at end

    March 2011 under Basel-II norms.

    An increase in NII facilitated

    growth of around 20 percent in

    aggregate net profit of thebanking system, even with an

    almost stagnant non-interest

    income and increase in risk

    provisions. The public sector

    banks registered a lower growth

    in profits mainly due to

    reduction in trading profits,

    increase in provisions towards

    staff expenses (including those for

    pension liabilities) and towards

    impaired assets. Going ahead,

    with hardening interest rates and

    the imminent increase in cost of

    funds, the credit growth is

    expected to slow down, which

    could adversely affect theprofitability. The hike in savings

    account interest rate,

    amortisations of pension liabilities

    and potentially enhanced

    provisioning requirements for

    NPAs may also impact

    profitability.

    Basel II and III

    Indian banks, at the aggregate

    level, remain adequately

    capitalised at present. The

    progress towards the advanced

    approaches under Basel II remains

    on a firm footing, amidst some

    challenges. The main

    implementation issues for the

    migration relate to constraints of

    data, tools, methodologies and

    necessary skills for quantification

    and modelling of risks. As the

    phase-in period for Basel III

    measures commences in 2013,

    the banks will need to gearthemselves for the demanding

    data and analytical requirements

    for the revised liquidity

    framework. The position in

    respect of capital remains

    comfortable though some

    individual banks may need capital

    infusions which could pose some

    difficulties if the sluggish

    performance of the equity markets

    persists. The capital needs of

    banks will also be impacted dueto the unamortised portion of

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    COMPLIANCE, RISK & OPPORTUNITY 13

    pension liabilities to be absorbed

    by April 01, 2013 on migration to

    International Financial Reporting

    Standards (IFRS). The calibration

    of the countercyclical buffers

    proposed under Basel III will

    require accurate assessment as to

    whether the credit growth is

    excessive and/or is leading to the

    build-up of systemic risks. The

    commonly used indicators,

    including the ratio of credit to

    GDP, may not be suitable for India

    and a combination of qualitative

    judgment and quantitativeindicators may be the way forward

    for assessing the requirement for,

    extent of and timing of imposition

    and removal of the buffer.

    An analytical framework to assess

    the network of the Indian banking

    system reveals that the system is

    substantially connected and

    clustered. This intertwined nature

    of the banking system in any

    system could leave it vulnerable to

    domino effects in case of

    idiosyncratic failure of one or

    more banks. While the contagion

    impact is relatively contained due

    to regulatory limits on interbank

    exposures, there remains need for

    continuous monitoring of the

    interconnectivities in the financial

    system to identify build up of

    risks /excesses in the system and

    to guide policy action to address

    the same.

    Financial market infrastructure

    The operational performance of

    the payment and settlement

    infrastructure in India continued

    to be robust though vulnerabilities

    could emerge from the high

    degree of integration and inter-

    relationships among systems,

    processes and institutions

    involved in various segments of

    the payment and settlementsystems. The benefits from

    synergies arising out of such

    interdependencies comes bundled

    with risks as stress on

    credit/liquidity aspects in one

    segment/institution/process may

    affect the other parts of the

    settlement system due to the

    cross-linkages.

    The management of liquidity risks

    faced by the CCPs entails

    addressing vulnerabilities arising

    from the quality and range of

    collateral, quantum of margins

    and model risks. There arevulnerabilities in the Indian

    context arising from dependence

    on committed backup liquidity for

    funds and securities from financial

    institutions for completion of the

    settlement process (in the case of

    Clearing Corporation of India

    Limited, ie CCIL) and exposures to

    the banking sector as collateral is

    accepted the form of bank

    deposits, bank guarantees, etc.

    The risks of the failure of a CCP,

    however unlikely, need to be

    addressed given the potential

    collateral damage from such an

    event. There are, however, no

    easy solutions given the moral

    hazard concerns which the

    provision of central bank liquidity

    for CCPs entails.The OTC markets

    in India with their skewed

    participation structures need

    greater attention towards

    standardisation and introductionof central clearing even as some

    segments face low volumes

    making it difficult to mandate

    guaranteed clearing for these

    markets. The existing reporting

    arrangements for OTC markets

    encompass foreign exchange,

    interest rate, government

    securities, corporate bonds and

    money market instruments. There

    is a need for consolidation and

    building on the existing reportingarrangements of CCIL while

    ensuring that the governance

    issues emanating from CCIL

    acting as both, a trade repository

    as well as a CCP, are addressed.

    Stress testing

    Two new stress testing tools were

    added to the set of techniques

    used in the previous FSR.

    Banking Stability Measures in the

    form of Banking System's Portfolio

    Multivariate Density (BSMD)

    approach for analysing financial

    stability from differentcombinations of distress

    dependencies infers that during

    the periods of crisis, the systemic

    risks rise faster than individual

    risks. Vector Autoregression (VAR)

    approach for judging the

    resilience of banking sector on

    various macroeconomic shocks by

    capturing the interaction among

    macroeconomic variables and

    banks' stability variables, shows

    that interest rate had the most

    significant (negative) impact on

    slippage ratio of the banks.

    The resilience of the projected

    balance sheets of the commercial

    banks was studied through stress

    testing, in respect of credit risk,

    interest rate risk and liquidity risk.

    Under stress conditions based on

    NPA shocks, the profitability of

    the banks was seen to be affected

    significantly though the capital

    adequacy position appeared to bereasonably resilient. The study

    indicates that some banks may

    face extreme liquidity constraints,

    under severe stress scenario.

    Overall, the results of the macro-

    stress tests using different

    scenarios, suggested that the

    banking sector would be able to

    withstand macroeconomic shocks

    though the prevailing inflation

    and interest rate situation is

    expected to have an adverseeffect on asset quality of banks.

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    COMPLIANCE, RISK & OPPORTUNITY14

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    As the importance of enterprise-

    wide risk management systems

    increases, it is useful to review the

    value of integrated technical

    computing platforms that offer

    development of custom analytics,

    flexible deployment and

    distributed computing

    capabilities. This article builds on

    a credit risk case study (an

    abridged version is available as aweb case study [2]), to highlight

    themes relating to integration,

    deployment and distributed

    computing for risk platforms.

    A credit VaR example on an

    integrated platform

    Throughout this section, we

    review the example specified in

    the web case-study, highlighting

    specific workflow and integration

    aspects in it. We assume the

    persona of a fictional risk

    management team that needs to

    estimate a credit value-at-risk

    (VaR) measure for a bond

    portfolio. From a computational

    perspective, the team needs to

    assign internal credit ratings for

    all issuers, they need to estimate

    transition probabilities and other

    risk parameters, and they need to

    estimate a loss distribution to

    determine the credit VaR.Operationally, the team needs to

    Read in data from databases,

    flat files, and spreadsheets;

    Clean and preprocess data;

    Share results and discuss

    inputs and outputs with other

    members of the team;

    Test different models andassumptions;

    Automate a workflow to reduce

    waste whenever data, models or

    assumptions change; and

    Have web- or spreadsheet-

    based front-ends for final

    reports.

    In the case study, we demonstrate

    how the team can use a particular

    functional programmingenvironment such as MATLAB, as

    an integrated technical computing

    platform to perform these tasks.

    An integrated platform here

    means a unified platform where

    different teams can share

    analyses, data and models; but

    also can integrate with existing

    data warehouses, with other

    computational engines, and many

    front-end interfaces

    (spreadsheets, web browsers,

    etc.). We use the term technical

    computing to emphasise a key

    philosophy of using numerical and

    scientific coding to build and

    customise analytics and models.

    To help implement the in-house

    credit rating system, the team

    uses a database with a long list of

    observations of financial ratios

    and corresponding credit ratings.

    The database contains the same

    financial ratios as in Altmans z-score [1], with the ratings

    assigned by a consultant. They

    use the information in the

    database to train a classifier,

    where given financial ratios of

    companies are used as

    predictors, and the credit rating

    is the response. The team is not

    interested in a credit score in the

    case study (as in [1]). They want

    to link the financial ratios directly

    to credit ratings, both becausetheir final goal is to use the

    ratings for the credit VaR

    estimation, but also because they

    have no credit score information

    in their historical database, just

    credit ratings. In the case study,

    the team fits a simple regression

    model first, but then tries a

    sophisticated statistical learning

    tool, bagged decision trees, a

    decision-tree-based classifier

    (more on this later). The classifierperforms considerably better than

    the regression model in the web

    case study. The classifier can then

    assign ratings to new issuers or

    update ratings of issuers already

    present in the portfolio. The team

    might have considered other

    tools, say discriminant analysis (as

    in Altmans original work [1]). A

    credit committee may also review

    and approve some or all credit

    ratings. Though reduced in scope,

    the workflow in the case study

    illustrates the convenience of

    working on a platform that lets

    users read data from multiple

    data sources, and ideally offers

    ready-to-use validated (and openly

    viewable) algorithms to perform

    certain tasks.

    Regarding the estimation of risk

    parameters, the case study

    specifically details the estimation

    of historical transitionprobabilities. This emphasises the

    collaboration between team

    members that determine the

    credit ratings, and those who use

    them later to estimate historical

    transition probabilities. Indeed,

    the time series of credit ratings

    assigned using, for example, the

    credit rating models described

    above, is the main input for the

    estimation of historical transition

    probabilities. When using thesame platform, analysts across

    Technical Computing

    in Risk Management

    Steve Wilcockson and Michael Weidman

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    benefits of a framework for

    sharing results with others in the

    company; see Figure 1. The final

    step leads us to consider

    deployment.

    The need for flexible deployment

    Beyond the workflow elements

    illustrated in the case study, there

    are advantages offered by the

    integrated technical computing

    platform. These engage other

    areas of the institution accessing

    data and calculation enginesdeveloped by the risk

    management team.

    Take the credit ratings, for

    example. Credit ratings assigned

    by an automated classifier may

    require review or approval from a

    credit committee, especially for

    large transactions. To make things

    efficient, the automated

    classification tool could be

    deployed using a web server.

    Credit committee members can

    open a web browser, enter

    information of a new customer, or

    extract information about an

    existing customer whose rating is

    under review, and get a

    comprehensive report on the

    automated rating and other

    relevant information.

    The classifier in the case study for

    example could report more than

    one possible rating for an issuer,complemented with a

    classification score, a measure of

    the certainty of the classifier

    about each possible rating. Once

    the committee determines the

    credit rating, they can use the

    same web application to enter the

    new credit rating into the system.

    Both the committee and the credit

    rating team get consistent

    financial ratio information fromthe same database, work with the

    COMPLIANCE, RISK & OPPORTUNITY 15

    J u l y 2 0 1 1

    teams can more easily shareinformation. Upstream updates

    are picked up downstream with

    greater ease and efficiency (as

    compared to having to export

    datasets, transfer files, etc.). The

    primary output is a single

    transition matrix, an input for a

    third team simulating credit-rating

    migrations. We will revisit other

    outputs of interest for other parts

    of the institution later.

    For the estimation of the credit

    VaR, the fictional team uses a

    standard simulation-based

    approach. The methodology

    consists of generating credit

    rating migrations over the time

    horizon, one year in the case

    study, and valuing the portfolio

    under each simulated scenario.

    Credit-rating downgrades cause a

    bond to lose value; upgrades have

    the opposite effect. Thus, there is

    a portfolio value for eachscenario. When simulating a large

    number of scenarios, say, 10,000,

    one gets a simulated empirical

    distribution of the possible values

    of the portfolio, helping estimate

    the expected loss and the credit

    VaR of the portfolio.

    In the case study, we use readily

    available tools and functions to

    implement the simulation, and

    determine how to estimate thecredit VaR. Rather than

    elaborating on the technicalmethodology, let us emphasise

    some workflow issues. First, team

    members need information on the

    actual bond portfolio, loaded from

    a spreadsheet, but it could be

    loaded from any data source.

    They also use as inputs parameter

    estimates obtained by other team

    members, such as transition

    probabilities.

    The results of the simulation,

    namely expected loss and credit

    VaR of the portfolio, need to be

    shared with other areas of the

    institution. In the case study, a

    front-end spreadsheet not only

    contains the results, but also

    allows a user to run a simulation.

    The link between the spreadsheet

    and the simulation engine is

    created with a few simple steps.

    We will discuss additional use

    cases of reporting and

    deployment in the followingsection.

    Despite the somewhat linear

    workflow (first determine credit

    ratings, then estimate transition

    probabilities, then estimate credit

    VaR), the case study highlights

    certain advantages of integrated

    platforms, specifically the comfort

    of reading in data from different

    data sources, the convenience of

    sharing intermediate informationbetween team members, and the

    Figure 1. Schematic diagram of the case study.

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    COMPLIANCE, RISK & OPPORTUNITY16

    J u l y 2 0 1 1

    same, up-to-date automated

    classifier, and as soon as the

    committee enters a new rating

    into the system, this new piece of

    information is available to the

    credit rating team.

    For smaller transactions, credit

    committee review may not be

    required, so the automated credit

    rating may suffice. In this case,

    account executives may have

    access to the same web form, or a

    limited version of it, and assign a

    credit rating automatically to newor existing customers.

    Regarding estimated risk

    parameters, such as transition

    probabilities, the situation is

    similar. Departments elsewhere,

    other than the team supporting

    the credit VaR engine, can benefit

    from access to risk parameters.

    Regulatory reporting, for example,

    will benefit from periodic updates

    on key risk parameters. Their

    workflow can be more efficient

    and less error-prone if they can

    run a report using a custom

    application interface providing on-

    the-fly analytics, instead of

    receiving periodic e-mails with file

    attachments. Better still, report

    generation could be exploited to

    automate the generation of

    regulatory reports a necessary

    update upstream can propagate

    downstream with a few clicks.

    There is no need for painful cut

    and paste. New regulatory

    requirements can be added, as

    needed, in the report generation

    tool, thus reducing human

    intervention leaving more time for

    analysis and communication.

    Others may benefit from thecredit VaR engine, perhaps the

    aforementioned regulatory

    reporting team, senior

    management performing what-if

    analyses, or a portfolio manager

    considering a new, large

    transaction wanting to understand

    its impact on the portfolios credit

    VaR. A deployed application where

    the portfolio manager can load

    the portfolio information and

    scenario test with the proposed

    transaction at the click of a button

    using up-to-date risk parameters

    is a valuable capability.

    Figure 2 extends Figure 1 to

    include other areas that might

    utilise the same integrated

    platform by means of flexible

    deployment.Not only are all of

    these solutions possible, many

    customers are already

    implementing them (see, for

    example 7). It is certainly a long

    term investment, but is

    worthwhile as such infrastructures

    facilitate traceability, easy

    customisation and allow

    institutions to evolve their risk

    architectures.

    The value of distributedcomputing

    A valuable addition to the

    integrated platform is a

    distributed computing

    infrastructure. It can help speed

    up computation, add robustness

    to models and estimates, and

    provide greater accuracy to model

    output.

    Let us return to the development

    of an automated credit rating tool.

    The team in the case study chose

    a sophisticated statistical-learning

    tool, bagged decision trees, as the

    automated credit rating tool. The

    team tries this technique because

    it is readily available and easy to

    use, but it also outperforms their

    alternative simple regression

    model.

    Bagged decision trees can be a

    very robust predictor. Bagging(and we will get a little technical

    here) is an acronym for bootstrap

    aggregation, and bootstrap is

    used in the statistical sense

    (randomly sampling with

    replacement from a dataset). To

    fit the bagged decision trees,

    many bootstrap replicas of the

    dataset are generated, and one

    decision tree, a classifying tool of

    its own, is grown on each replica.

    A bootstrap replica is created byrandomly selecting N observations

    Figure 2. Extended diagram with deployed applications

    and multiple users.

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    COMPLIANCE, RISK & OPPORTUNITY 17

    with replacement out of the N

    original observations in the

    dataset. To find the predicted

    rating for a new observation, one

    prediction is made with each

    individual tree, and the rating

    assigned to the new observation

    is the rating predicted by the

    largest proportion of individual

    trees.

    Beyond the technicalities, the

    underlying principle is relatively

    simple: This is a substantial what-

    if analysis. How would a differentdataset influence my model or my

    estimates? Repeat this many

    times, perhaps focusing on the

    variabilities of estimated

    parameters or the predictions of

    fitted models. Alternatively, you

    may want to forecast, as with

    bagged decision trees, taking a

    range of fitted models into

    consideration, and make a final

    forecast by averaging predicted

    values, or by taking the valuemost often predicted by individual

    models, or any other reasonable

    aggregation procedure.

    You might also want to measure

    the prediction error, the main goal

    of a related procedure called

    cross validation. This can make

    your predictions more robust, less

    sensitive to a particular dataset,

    and to better understand their

    potential variability when the datachanges (4) and (6).

    An important characteristic is that

    the what-if analysis can be

    performed in parallel. By design,

    each what-if scenario is

    independent, and the individual

    models can be distributed. Many

    off-the-shelf models (such as the

    bagged decision trees in the case

    study) have built-in support for

    distributed computing. However,

    many statistical algorithms

    applied in risk management can

    benefit from distributed

    computing, adding model

    robustness and speeding upcomputations.

    Two common, obvious uses of

    distributed computing include

    speeding up computations over a

    large portfolio, and running

    Monte-Carlo simulations. In the

    former, different segments of a

    portfolio can be evaluated on

    separate processors. Different

    scenarios of a Monte-Carlo

    simulation can be generated andused on different computational

    nodes. However, parallelism and

    distributed computing does not

    always speed up code that can

    conceptually be executed in

    parallel.

    When using programming

    languages, code optimisation

    usually through profiling should

    be a first port-of-call. Code

    optimisation can improveexecution time, by orders of

    magnitude in some cases. After

    the serial code is optimised,

    distributed computing

    considerations arise, for example,

    the communication overhead of

    sending a job to a different node

    and retrieving the outputs. In a

    simulation, for instance, it may be

    worth running a large group of

    scenarios per node, and the

    communication cost may be

    reduced by generating the

    scenarios inside the same node

    instead of creating scenarios in

    one lab and sending to another.Ideally, your platform should

    handle simpler parallelisation

    instances for you, but give you

    tools to handle jobs and

    schedules when necessary.

    Another, less obvious benefit of

    distributed computing is in

    evaluating the accuracy of the

    results. Monte-Carlo simulations

    are random experiments. If one

    gets a credit VaR of, say, 8.1472

    percent of the portfolio value, how

    confident are we in its accuracy? If

    we repeated the simulation, might

    the new estimate be closer to 9

    percent? The larger the number of

    scenarios, the lower the variability

    of the results; but the variability

    never disappears. So, how many

    scenarios are necessary to achieve

    a desired accuracy level?

    One way to measure the variability

    of results is by repeating thesimulation many times (say 100

    times), using different numbers of

    scenarios (say, 10,000, then

    100,000, then 1 million, etc.). You

    can then measure the range of

    variation for each number of

    scenarios (eg, with a standard

    deviation, or a percentile interval)

    and determine when the range is

    within the desired accuracy level.

    This is an example of a two-levelsimulation. In the outer level, we

    J u l y 2 0 1 1

    When using programming languages, code

    optimisation usually through profiling should

    be a first port-of-call. Code optimisation can

    improve execution time, by orders of magnitude in

    some cases.

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    COMPLIANCE, RISK & OPPORTUNITY18

    repeatedly run simulations to get

    many observations of the credit

    VaR and estimate its variability. In

    the inner level, a simulation is run

    to get one particular estimate of

    the credit VaR. This is relatively

    simple case of a two-level or

    nested simulation, solved

    efficiently in a distributed

    environment. Implementation

    variations can help further. The

    literature on two-level or nested

    simulations can suggest other

    approaches and some more

    complex cases (see, eg, 3 or 5).

    When discussing deployment

    earlier, we presented isolated

    examples of users requesting

    information, generating reports,

    or running ad-hoc analyses on-

    demand. In reality, of course,

    many users across the institution

    perform these tasks at the same

    time, as illustrated in Figure 2.

    Distributed computing too can

    help. Different portfolio

    managers, may be in different

    geographies, may want to run VaR

    analyses several times a day. If

    the platform is integrated with a

    cluster or cloud, jobs can run

    simultaneously. It is possible from

    a single platform to support

    multiple custom uses. Where this

    works well, it can streamline an

    institutions operations.

    Final remarks

    Referencing a credit risk case

    study, we have reviewed some

    aspects of enterprise-wide risk

    management systems that benefit

    from an integrated technical

    computing platform. We

    suggested that flexibility of

    deployment is a key component of

    such a platform, as it facilitates

    easy incorporation of custom

    analytics components into a riskframework. We also highlighted

    the importance of distributed

    computing capabilities in an

    integrated enterprise-wide risk

    management system, and how it

    could be utilised by analysts,

    managers and developers.

    References

    1. Altman, E., Financial Ratios,

    Discriminant Analysis and the

    Prediction of Corporate

    Bankruptcy, Journal of Finance,

    Vol. 23, No. 4, (Sep., 1968), pp.

    589-609.

    2 Credit Risk Modeling with

    MATLAB, available on demand at

    http://www.mathworks.com/

    company/events/webinars/

    wbnr49601.html.

    3 Gordy, M., and S. Juneja,

    Nested Simulation in Portfolio

    Risk Measurement, Finance and

    Economics Discussion Series 2008-

    21, Federal Reserve Board,

    Washington, DC, 2008.

    4 Hastie, T., R. Tibshirani, and J.

    Friedman, The Elements of

    Statistical Learning, second

    edition, Springer, 2009.

    5 Lan, H., B. Nelson, and J. Staum,

    Two-Level Simulation for Risk

    Management, Proceedings of the

    2007 INFORMS Simulation Society

    Research Workshop, 2007.

    6 Martinez, W., and A. Martinez,Computational Statistics

    Handbook with MATLAB, second

    edition, Chapman & Hall / CRC,

    2008.

    7 UniCredit Bank Austria

    Develops and Rapidly Deploys a

    Consistent, Enterprise-Wide

    Market Data Engine, MathWorks,

    User Story, 2009. Web:

    http://www.mathworks.com/

    computational-finance/userstories.html?file=45641.

    J u l y 2 0 1 1

    Biography

    Steve Wilcockson has worked forMathWorks for 14 years. He is

    Industry Manager for Financial

    Services with global accountability,

    ensuring industry trends in risk,

    trading, insurance, portfolio

    management, econometrics and

    valation are effectively incorporated

    into our development process. Steve

    holds degrees from the University of

    Cambridge and University of British

    Columbia.

    Biography

    Michael Weidman joined MathWorks

    in 2007, working in the Application

    Engineering Team on computational

    finance applications. He is B A in

    Physics from Harvard University and

    has completed Part III of the

    Mathematical Tripos from DAMTP at

    the University of Cambridge.

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    COMPLIANCE, RISK & OPPORTUNITY 19

    J u l y 2 0 1 1

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    COMPLIANCE, RISK & OPPORTUNITY20

    J u l y 2 0 1 1

    Against a backdrop of growing

    uncertainty in global creditconditions and sustainable

    growth, the financial services

    landscape continues to evolve

    rapidly. Post-financial crisis

    responses continue to be

    characterised by issuance and

    implementation of numerous

    complex and formidable array of

    banking reforms, with Basel III

    being one piece of the jigsaw,

    albeit one of the most significant

    pieces.

    The report reveals that Basel III

    solvency and liquidity regulations

    will represent the largest driver of

    changing industry economics for

    the banking world for this decade.

    With bank capital requirements

    becoming increasingly onerous

    and additive as more types of

    risks and capital buffers have to

    be taken into account, it is

    expected that this will eventually

    have a negative impact on overallinvestment banking return on

    equity (RoE) by 3 to 5 percent.

    As firms navigate this regulatory

    chessboard of options and rules,

    they need to bear in mind

    business and risk management

    imperatives. Increasingly, risk

    resources (capital, liquidity, and

    talent) are expected to remain key

    items. The industry is likely to

    move towards a more integratedoperating model involving the

    risk, finance, and treasury

    functions.

    It is imperative for firms to chart

    out a risk technology roadmap by

    sound guiding principles and

    lessons learned from previous

    Basel II and risk technology

    implementation to navigate this

    transition from a strategic

    business and technology

    perspective.

    Basel banking regulations

    Looking back, surging forward

    Basel III essentially stems from the

    resolve by the Bank of

    International Settlements (BIS)

    Basel Committee to safeguard

    financial stability and address thegaps in Basel IIgaps that were

    exposed by the credit crisis.

    Figure 1 highlights the evolution

    of the Basel framework and a

    summary of what each version

    entails.

    First-wave firms that have

    executed their Basel II

    programmes and implemented

    their IT systems in a sustainable

    manner are likely to find an easier

    path to Basel III. Conversely, firms

    that have taken inappropriate

    shortcuts or selected an

    incomplete solution for Basel II

    may face an uphill battle to pull

    Basel IIINavigating Business and Risk Technology Architecture Decisions

    Cubillas Ding

    Celent, a member of Oliver Wyman Group, recently added Basel III: Navigating Business and Risk

    Technology Architecture Decisions report to their series of Basel III and risk offering. Released last month,

    the report reveals that recent Basel III regulations on bank capital requirements will represent one of the

    largest drivers of industry economics for the banking world in this coming decade. Celent examines the key

    elements required by banks to ensure a sufficient level of preparedness by comparing the current and

    emerging Basel regimes. The report also provides recommendations for firms to navigate this transition

    from a strategic business and technology perspective. This is a heavily abridged version of the 34 page

    report which contains 11 figures and 4 tables. Interested readers may find more details at

    http://celent.com/node/28834.

    Figure 1: The Basel Capital Chessboard

    Source: Celent

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    COMPLIANCE, RISK & OPPORTUNITY 21

    all that is required together in a

    coherent manner for Basel III.

    Integrated risk management

    solution suites are emerging to

    support not only regulatory

    aspects but also advanced

    capabilities. Table 1 presents a list

    of Basel II and Basel III risk

    solution vendors based on the

    market research conducted by

    Celent.

    Business Imperatives

    From a business perspective, toensure a sufficient level of

    preparedness at this early

    juncture, financial institutions can

    look to address a number of

    issues. First, banks need to

    execute a comprehensive health

    check of their risk

    infrastructuremaking significant

    changes to their risk data,

    models, and analytics frameworks.

    The issues that must be

    addressed include:

    The definition and treatment of

    additional risk factors to be

    captured in the valuation and

    risk engines;

    Risk model adjustments to

    enhance back-testing

    capabilities; and

    Risk analytics, potentially

    upgrading the internal

    dashboards and setting moreforward-looking metrics to

    improve capital forecasting.

    Once the comprehensive risk

    framework is designed, they

    should draw out a clear mapping

    of trading and banking risk

    capitalto understand capital hot

    spots and utilisation by business

    line, desk, and product. Thirdly,

    banks must ensure that board-

    level risk reporting andoversight are connectedacross

    the firm. Accurate, timely, and

    comprehensive reports will help

    the risk committee to evaluate the

    current and projected risks that

    institution may be exposed to,including stressed conditions.

    This will allow the management to

    collectively manage risks, as well

    as provide assurance of a

    comprehensive risk framework

    across the lending, trading, and

    investment value chain.

    Lastly, banks need to redefine

    the strategic portfolio of

    businessesin the light of

    changing industry economics asdefined by Basel IIIs new

    provisions. The changes to trading

    risk capital are likely to have

    knock-on effects throughout the

    mechanisms used to run and steer

    the bank. This would requirebanks to discipline all businesses,

    especially corporate derivatives,

    based on which client segments

    they target.

    Technology imperatives

    From a technology perspective,

    considerations for architectural

    capabilities should bear in mind

    established guiding principles,

    emerging requirements, and bestpractice capabilities from a firm

    J u l y 2 0 1 1

    Table 1: Basel II / Basel III Risk Solution Vendors (Representative)

    Source: Celent Analysis

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    COMPLIANCE, RISK & OPPORTUNITY22

    wide perspective rather than a

    departmental standpoint.

    Celent observes number of

    instances based on enterprise risk

    technology initiatives in line withan end-state architecture. We

    discuss these briefly below.

    Design-in robust

    reconciliations applications in

    order to support

    comprehensive data quality

    processes and measures.

    Aim for a regulatory capital

    calculator that facilitates

    seamless migration betweenvarious Basel regimes.

    Strengthen the firms model

    management framework by

    building a streamlined process

    that can deliver robust quality

    control around the entire model

    lifecycle.

    Ensure that integrated stress

    and scenario analysis

    capabilities effectively

    undergird a scenario-based

    planning framework.

    Design and implement a

    management scorecard of

    health indicators to dynamically

    link complete risk and finance

    data. A robust general riskframework and in time

    reporting will result in effective

    firm wide governance.

    Adopting right technology for

    liquidity management.

    Databases, aggregation, andmiddleware need to

    increasingly support a dynamic

    or near real time flow of data

    that can give a live snapshot

    of the state of affairs.

    In the long run, the emerging

    best practice capability is to

    achieve a unified/aligned risk

    and finance data model. This

    includes consolidating

    fragmented risk, finance, andtreasury applications along with

    J u l y 2 0 1 1

    Table 2: Selection ConsiderationsBasel Risk Management Applications

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    be charted and planned at an

    early stage. Banks, particularly,

    will need to assess various

    architecture options considering

    how the risk management

    function will operate in the next

    five years and also to what extent

    each option will facilitate

    increasing collaboration between

    strategic planning, treasury,

    capital management, finance, and

    risk groups.

    Overall, firms need to have a clear

    view of what ambitions it wants toachieve before building, selecting,

    or blending Basel toolsets. This

    will involve designing a risk IT

    architecture which delineates

    policies, rules, guidelines, and

    standards for the technical layers

    to support the evolutionary path

    towards end game risk

    management capabilities.

    COMPLIANCE, RISK & OPPORTUNITY 23

    J u l y 2 0 1 1

    designing a single risk and

    financial performance view of

    the customer.

    Financial institutions which have

    yet to make investments need to

    exercise caution to ensure that

    their Basel II / Basel III and

    broader risk software purchases

    and projects benefit from the

    hindsight provided by early

    adopters. Table 2 points out the

    key considerations that firms need

    to assess before structuring their

    Basel risk managementframework, which will also help

    them in selecting the right

    technology and solution vendors.

    Road ahead

    In order to avoid costly mistakes

    and dead ends, an institutions

    risk technology roadmap should

    Biography

    Cubillas Ding is a research director inCelent's securities and investments

    practice and is based in the firm's

    London office. His expertise lies in

    global financial markets, securities IT

    strategy, and ERM.

    Before joining Celent, Ding was a

    senior analyst at Datamonitor. Prior to

    this role he held positions at Euro

    RSCG Circle as a business

    consultant, at Hewlett Packard

    European Labs & Direct Marketing

    Association as a lead research

    analyst, and at Accenture's Financial

    Services Group as a consultant.

    Ding received a master's degree in

    international business from the

    University of Bristol and a B Sc in

    computer science from Monash

    University in Australia.

    Capgemini, a consulting, technology and outsourcing services

    provider, through its Financial Services global business unit, and

    Murex, a front, middle, back-office and capital markets risk

    management specialist, have signed a global partnership. With

    revenues of more than 1.6 billion in the financial services sector,

    and over 17,000 experts worldwide, Capgemini is pursuing its

    development strategy in capital markets activities through

    partnerships. This responds to a sharply increasing demand from

    financial institutions for the industrialisation and package

    development of their IT systems. This global agreement positions

    Capgemini as a reference integrator in financial package services. It

    provides a significant enhancement of the technical and functional

    skills for Capgemini consultants, in the Murex package suite.

    Building on over 25 years of successful presence in capital markets,

    Murex has developed competence in the design and implementation

    of integrated trading, risk management and processing solutions for

    top financial institutions, clearing houses, corporations and utilities

    located across the globe. Its 200 clients range from leading market

    makers to large-sized or medium-sized buy-side and sell-side

    institutions. Over 36,000 users rely on MX.3, the latest Murex

    platform. Implementations powered by the MXpress approach

    leverage the wealth of business content accumulated by Murex over

    the two decades through pre-packaged components of the platform

    while offering an accelerated process of delivery. The implementationstrategy of Murex products is centered around certified partnerships.

    in brief

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    COMPLIANCE, RISK & OPPORTUNITY24

    J u l y 2 0 1 1

    Author: Dr Anil K Khandelwal

    Publisher: Sage Publications India Pvt Ltd,

    B1/1-1 Mohan Cooperative industrial Area,

    Mathura Road, New Delhi-110044, India.

    Website: www.sagepublications.com

    Published in 2011

    Pages: 403

    Dare to LeadThe Transformation of Bank of Baroda

    BOOK REVIEW

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    COMPLIANCE, RISK & OPPORTUNITY 25

    J u l y 2 0 1 1

    The most effective way for Hedge

    Funds to mitigate selection risk

    when deciding on business-critical

    systems would be a miraculous

    ability to time-travel. If only a

    Fund could have the foresight to

    anticipate the future needs of the

    company and resultant gaps in

    tomorrows software solutions.

    How about being able to look

    forward to a time when thesystem will be truly entrenched

    within your business, having that

    aha moment and realising the

    impact and pain of having to

    switch to a different platform or

    to prematurely upgrade the

    existing one to support business

    growth and new strategies.

    Conversely, the ability to travel

    back in time to when you made a

    particular decision, to recognise

    exactly why you made that choice,

    and be able to defend it on the

    strength of a well-documented

    procurement process with buy-in

    from key stakeholders would

    prove invaluable for offensive and

    defensive reasons. Not a bad

    super-power to have as far as

    supernatural abilities go.

    When Hedge Funds shop for

    business-critical systems, the first

    step in mitigating selection risk

    should be to conduct a thoroughevaluation of requirements. This

    analysis typically breaks down into

    four key categories namely

    functionality, operational

    efficiency, ability to integrate with

    third-party applications and

    counterparties, and ability to meet

    local reporting and regulatory

    obligations.

    To help properly prepare for the

    system evaluation step, it is bestto assume vendors all too often

    over-promise and under-deliver. In

    order to debunk their we do

    everything myth, requirements

    are best framed within an

    evaluation matrix, specifying

    desired systems components

    weighted by priority, and then

    considered in respect to what is

    supplied out-of-the-box. It

    sounds simple, but ensuring that

    these prioritised requirements aresufficiently addressed,

    maintained, and adaptive is

    fundamentally important, and

    provides the necessary flexibility

    as business needs change. Follow-

    through is called for here --

    theres no point in framing this all

    out if theres no intention to stick

    with a disciplined due diligence

    process from beginning to

    decision to implementation to

    production.

    Naturally, this process must

    involve key stakeholders from

    across the business functions

    representing technology,

    operations, and accounting all of

    whom will have their own set of

    priorities. By considering their

    different views to identify key

    requirements as well as potential

    issues, the Hedge Fund will create

    a more complete picture of

    present needs, making it easier topredict future firm-wide concerns

    while also helping to identify and

    mind the gaps. Employing the

    services of a consultative third

    party can also add value,

    providing an arbitrational and

    objective view that takes much of

    the emotion out of the process.

    The benefit of this type of

    approach is the ability to address

    risk concerns across functional

    areas while promoting increasedoperational efficiencies, better

    workflow and systems integration,

    and enhanced reporting delivery.

    Once the requirements have been

    framed and documented and the

    potential best-fit solutions

    identified, the next step is to

    engage and interact with

    prospective systems providers.

    Any gaps in vendor solutions

    must be identified, and build-outversus buy options should be

    considered to address these

    limitations. There are typically two

    delivery options on-premise

    software or hosted

    (SaaS)/managed services (aka

    BPO). The latter can provide a

    pragmatic alternative in scenarios

    where it is preferable for staff

    expertise to remain with the

    outsource provider. Discussions

    with the system providers must

    also cover implementation

    considerations including any

    required data conversions, the

    capacity and capabilities for

    customising the system, and

    service levels especially for

    production support.

    After all is said and done, the

    total cost of the system will be

    much more than the acquisition

    and initial implementation costs,

    especially if you do not have aholistic, forward-thinking

    approach that considers what is

    needed as the business scales.

    Indeed, the final piece to the

    selection risk puzzle is TCO (total

    cost of ownership).

    Certainly, it is necessary to be

    wary of systems pitched as the

    low-cost alternative, recognising

    that TCO entails both the

    acquisition of the platform andthe ongoing cost of maintenance,

    ONE SIZE DOESNT FIT ALLRisky Business for Hedge Funds When Selecting

    a Business-Critical SystemBrian Roberti

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    quickly confronted with Excels

    limitations in handling the

    complexities of financial securities

    and the requirements of an

    enterprise class solution and too

    often wait to make a change until

    the Fund reaches a critical point

    where the system falls over,

    becomes too unwieldy or simply

    does not have what is required to

    adequately support business

    operations, not to mention

    compliance and regulatory

    requirements. Typically the deeper

    and farther one goes with asystem, the greater and more

    painful are the switching costs. If

    managed poorly, it can even put

    business-critical processes in

    jeopardy.

    Therefore, it is advisable to take a

    consultative, thoughtful approach

    when making the initial system

    decision. When it comes to the

    risky but necessary business of

    system selection, your starting

    point has a huge impact on the

    path you may ultimately travel and

    consequently where your business

    has the potential to go. There is

    no one size fits all.

    COMPLIANCE, RISK & OPPORTUNITY26

    J u l y 2 0 1 1

    support and future upgrades. The

    former can literally be crushed by

    the latter, particularly if the

    system proves inflexible and

    unable to adapt to the ever-

    evolving business and regulatory

    environment.

    As internal and external pressures

    exert the need for change in

    systems over time, the solution

    employed will need to be revisited

    and customised to the firms

    unique business objectives and

    exposure to various aspects ofrisk. There are clear benefits to

    having a system that can be

    tailored, at least to some extent,

    by the power users versus having

    to deploy IT resources that a firm

    may or may not have dependent

    on their size and make-up.

    Hedge Funds need to look to the

    future when undertaking the

    initial analyses of and decisions

    based upon system risk. There is

    a lot to be said for the use of

    simple tools to get a job done. On

    the flip side, Hedge Funds that

    have launched using Excel as their

    cornerstone system are all too

    Biography

    Brian Roberti is director, sales and

    marketing at G2 Systems.He has held

    sales leadership positions at several

    financial technology firms offering

    automated trading platforms and

    services. He successfully grew the

    sales team at EdgeTrade an

    agency-only broker and provider of

    electronic trading and execution

    services and helped the firm achieve

    its aggressive revenue growth targets

    and exit strategy.

    Prior to that, he worked for 10 years

    at Advent Software, a leading

    provider of investment management

    software, where he served in a

    number of market-