John Kenneth Galbraith, famous Harvard Economist and the US Ambassador to India during J.F. Kennedy's Administration wrote. 'All Financial Crises are the result of Debt that, in one fashion or another, has become Dangero

CS Professional · Banking - Law and Practice · PYQS · June 2021
John Kenneth Galbraith, famous Harvard Economist and the US Ambassador to India during J.F. Kennedy's Administration wrote. 'All Financial Crises are the result of Debt that, in one fashion or another, has become Dangerously out of Scale'. This was clearly demonstrated in the Financial Crisis which took place in the US in 2008. Aggressive lending characterized by Sub-prime Housing Loans and excessive leverage in major Banks and Financial Institutions led to the most serious financial challenge since the Great Depression of 1930s. The Sub Prime Crisis had reportedly led to a total write off of 1.18 trillion Dollars. One has to understand the causes of the Financial Crisis and take appropriate measures to avoid its recurrence. In order to withstand such a shock in future, the Basel Committee on Banking Supervision (BCBS) has announced on 13th September, 2010, New Capital Rules as agreed by the global regulators. The new requirement, known as Basel-III, demands a substantial strengthening of existing capital requirements. This involves higher global Minimum Capital Standards for Banks. As cited above, Basel-III reforms are the response of BCBS to improve the Banking Sector's ability to absorb shocks arising from financial and economic stress, whatever the source, thus reducing the Risk of Spill over from the financial sector to the real economy. During the Pittsburgh Summit in September 2009, the G-20 leaders committed to strengthen the regulatory system for Banks and other Financial Firms and also act together to raise Capital Standards, to implement strong International Compensation Standards aimed at ending practices that lead to excessive risk-taking, to improve the Over-The-Counter Derivatives Market and to create more powerful tools to hold large global firms to account for the risks they take. For all these reforms, the leaders set for themselves strict and precise timetables. Consequently, the BCBS released comprehensive reform package entitled "Basel-III: A global regulatory framework for more resilient Banks and Banking Systems" (known as Basel III capital regulations) in December 2010. Basel-III reforms strengthen the Bank-level i.e. Micro prudential regulation, with the intention to raise the resilience of individual Banking Institutions in periods of stress. Besides, the reforms have a Macro prudential focus also, addressing system wide risks, which can build up across, the Banking Sector, as well as the pro-cyclical amplification of these risks over time. These new Global Regulatory and Supervisory Standards mainly seek to raise the Quality and level of Capital to ensure Banks are better able to absorb losses on both a going concern and a gone concern basis, increase the Risk coverage of the Capital framework, introduce Leverage Ratio to serve as a backdrop to the Risk-based Capital measure, raise the Standards for the Supervisory Review Process (Pillar-2) and Public Disclosures (Pillar-3) etc. The Macro prudential aspects of Basel-III are largely enshrined in the Capital Buffers. Both the Buffers i.e. the Capital Conservation Buffer and the Countercyclical Buffer are intended to protect the Banking Sector from periods of excess Credit Growth. Reserve Bank of India (RBI) issued Guidelines based on the Basel-III reforms on Capital Regulation on 2nd May, 2012, to the extent applicable to Banks Operating in India. Banks have started implementing the Guidelines from 1st April, 2013 in India in a phased manner. Banks are advised by RBI to report the CRAR as per Basel-II and Basel-III simultaneously in all their disclosures to the stakeholders. In this backdrop, you are required to give answers in the context of prevailing Banking Practices and various RBI Compliances to the following: How is Basel-III an improvement over Basel-II?

Answer & Explanation:

Basel-III represents an effort to fix the gaps and lacunae in Basel-II that came to light during the crisis as also to reflect other lessons of the crisis. What is important though is that Basel-III does not jettison Basel-II; on the contrary, it builds on the essence of Basel-II, the link between the risk profiles and capital requirements of individual banks. In that sense, Basel-III is not a negation, but an enhancement of Basel-II. The enhancements of Basel-III over Basel-II come primarily in four areas: Augmentation in the level and quality of capital; Introduction of liquidity standards; Modifications in provisioning norms; and Better and more comprehensive disclosures. Capital Requirement under Basel-II and Basel-III Calculation Particulars As a percentage of risk weighted Assets Basel-II Basel-III (as on January 01, 2019) A=(B+D) Minimum Total Capital 8.0 8.0 B Minimum Tier-1 Capital 4.0 6.0 C Minimum Common Equity Tier-1 Capital 2.0 4.5 D Maximum Tier-2 Capital (within Total Capital) 4.0 2.0 E Capital Conservation Buffer (CCB) - 2.5 F=C+E Minimum Common Equity Tier-1 Capital + CCB 2.0 7.0 G=A+E Minimum Total Capital + CCB 8.0 10.5 As can be seen from the comparative data in Table above, Basel-III requires higher and better quality capital. The minimum total capital remains unchanged at 8 per cent of Risk Weighted Assets (RWA). However, Basel-III introduces a Capital Conservation Buffer (CCB) of 2.5 per cent of RWA over and above the minimum capital requirement, raising the total capital requirement to 10.5 per cent against 8 per cent under Basel-II. This Buffer is intended to ensure that banks are able to absorb losses without breaching the minimum capital requirement, and are able to carry on business even in a downturn without deleveraging. This buffer is not part of the regulatory minimum. However, the level of the buffer will determine the dividend distributed to shareholders and the bonus paid to staff. There are also other prescriptions regarding the quality of capital within the minimum total so that capital is able to absorb losses, and calling upon taxpayers to bear the burden of bail out becomes absolutely the last resort. In addition to the Capital Conservation Buffer, Basel-III introduces another capital buffer the Countercyclical Capital Buffer in the range of 0-2.5 per cent of RWA which could be imposed on Banks during periods of excess credit growth. Also, there is a provision for a higher capital surcharge on systemically important banks. To mitigate the Risk of Banks building up excess leverage as happened under Basel-II, Basel-III institutes a Leverage Ratio as a backstop to the risk based capital requirement. The Basel Committee is contemplating a Minimum Tier-1 Leverage Ratio of 3 per cent which will eventually become a Pillar-I requirement as of January 01, 2018. Basel-II failed to demand adequate loss absorbing capital to cover market risk. To remedy this, Basel-III strengthens the counterparty Credit Risk framework in market risk instruments. This includes the use of stressed input parameters to determine the capital requirement for counterparty Credit Default risk. Besides, there is a new capital requirement known as Credit Valuation Adjustment (CVA) risk capital charge for Over-The-Counter (OTC) derivatives to protect Banks against the risk of decline in the credit quality of the counterparty. To mitigate Liquidity Risk, Basel-III addresses both potential short-term liquidity stress and longer-term structural liquidity mismatches in Banks' Balance Sheets. To cover short-term liquidity stress, Banks will be required to maintain sufficient high-quality unencumbered liquid assets to withstand any stressed funding scenario over a 30-days horizon as measured by the Liquidity Coverage Ratio (LCR). To mitigate liquidity mismatches in the longer term, banks will be mandated to maintain a Net Stable Funding Ratio (NSFR). The NSFR mandates a minimum amount of stable sources of funding relative to the liquidity profile of the assets, as well as the potential for Contingent liquidity needs arising from off-balance sheet commitments over a one-year horizon. In essence, the NSFR is aimed at encouraging Banks to exploit stable sources of funding. Provisioning Norms The Basel Committee is supporting the proposal for adoption of an "expected loss" based measure of provisioning which captures actual losses more transparently and is also less pro cyclical than the current "incurred loss" approach. The expected loss approach for provisioning will make financial reporting more useful for all stakeholders, including regulators and supervisors. Disclosure Requirements The disclosures made by banks are important for market participants to make informed decisions. One of the lessons of the crisis is that the disclosures made by Banks on their risky exposures and on regulatory capital were neither appropriate nor sufficiently transparent to afford any comparative analysis. To remedy this, Basel-III requires banks to disclose all relevant details, including any regulatory adjustments, as regards the composition of the regulatory capital of the bank.

Topics: Risk Management in Banks

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