Nada Awad Rizkallah (pdf – 1.24 MB) - The Institute of International

Transcription

MENA Chief Risk Officer Forum 2014
Dubai, UAE - May 7-8, 2014
Capital Planning
A practical Approach in a Volatile Operating Environment
Nada Awad Rizkallah
Deputy GM, Chief Risk Officer
Group Credit Libanais, Lebanon
1
Table of Contents
1.
Overview on Lebanon Banking Sector
2.
Main Characteristics of Lebanon Banking Sector
3.
Basel III - New Capital Adequacy Requirements
4.
Capital Planning - Each Bank should set a Capital target
5.
Two Main Objectives - Capital Planning
6.
Basel Committee - Sound Capital Planning Process
7.
Capital Planning Model - Minimum Requirements (Basel III)
8.
Capital Planning Exercise - A Practical Approach
9.
Capital Planning Governance
10. Key Challenges to Consider
11. Capital Planning Outcome
12. Based on the Outcome. What should we do?
2
Despite the tough operating environment, Lebanese Banking sector reported healthy
growth in 2014:
• Total assets reached C/V USD 174 billion at year-end 2013, up by more than 8%
compared to levels reported in the previous year;
• The sector’s deposit base grew by C/V USD 11 billion in 2013 to reach C/V USD 137
billion, which represents 3 times the country’s GDP;
• Private-sector lending grew by 9% during 2013 to reach C/V USD 49 billion;
• Regulatory capital of Lebanese Banks reported at C/V USD 14 billion at year-end
2013, remains stable and is broken down as follows which highlights its high quality where its
main portion is considered as Core Tier 1 as per Basel III:
C/V USD 10 billion in Common Equity Tier 1;
C/V USD 3 billion in Additional Tier 1 Capital; and
C/V USD 1 billion in Tier 2 Capital.
• Lebanese Banks maintained profitability at healthy levels, reaching C/V USD 1.6 billion,
ROAA at 1.02% and ROAE: 11.79%.
3
Average Capital Adequacy Ratio (CAR) for the Lebanese Banking sector was reported
at 12.2% during the first half of 2013, while Leverage ratio average reported at 7% during
the same period.
Capital Adequacy Ratio of Alpha Banks* as at December 31, 2012:
* Lebanese Banks with Deposits exceeding C/V USD 2 billion
4
Tier 1 Ratio of Alpha Banks as at December 31, 2012:
Core Tier 1 Ratio of Alpha Banks as at December 31, 2012:
5
Main Characteristics of Lebanon
Banking Sector
The third installment of the Basel Accords (After Basel I and Basel II) was developed in response
to the deficiencies in financial regulation revealed by the late-2000s financial crisis.
Since Basel III is a structured reaction to the crisis, let’s start with contemplating the impact of
the crisis and the measures undertaken by the Lebanese Banking Sector, and how this system, to
a certain extent, avoided its severe repercussions.
1. Centralized Regulatory Authorities:
The Central Bank of Lebanon and the Banking Control Commission (BCC) are the only two
independent authorities in Lebanon that work side-by-side and coordinate their action. The
Association of Banks in Lebanon (ABL) has the role to effectively promote the interests and
public image of the Lebanese Banking sector.
2. Tight and Conservative CB Regulations on Banks:
•
•
•
At least 30% of the Banks’ assets should be held in cash;
Banks are not allowed to speculate in risky packages of bundled up debts;
Weak Banks were forced to merge with bigger ones.
3. No direct exposure to Toxic Assets:
•
All structured products should be approved by the Central Bank with maximum 5% of equity.
4. Too Big to Fail approach is inexistent:
•
Banks are equally supervised
6
Main Characteristics of Lebanon
Banking Sector
5. Well tested Lebanese Banking System:
•
Against internal and external wars, political instability and major assassinations. This
however induced Banks to follow a conservative approach in their investment strategies
6. No large exposures to Capital Markets:
•
•
•
Conditional financing of purchase of securities through margin lending:
Against collateral composed solely of the underlying financial instruments;
The Loan-to-Value ratio (LVR) (between 50% and 75%);
7. Regulatory (Lending/Investment) Concentration Limits:
•
•
On an individual obligor level;
On a country and group of countries level (as per their respective credit ratings).
8. Regulatory Credit Quality Limits.
•
Minimum issue/counterparty rating for investment/placements exposures set at BBB.
9. Restricted/Intolerable Investments in the Lebanese Banking Industry:
•
Banks are prohibited to carry out a short sale on financial instruments exposures.
10. Market Monopoly is not allowed:
•
Alpha Banks are prohibited from merging, thus no unfair competitive advantage.
11. Totally independent Supervisory Authorities from the Political Ones.
7
Basel III
New Capital Adequacy Requirements
The Basel Committee on Banking Supervision (BCBS) and its oversight body, the Group of
Governors and Heads of Supervision, developed a reform programme to address the lessons
of the 2006-2008 crisis.
The depth and severity of the crisis were amplified by weaknesses in the Banking sector
such as excessive leverage, inadequate and low-quality capital, and insufficient
liquidity buffers.
The crisis was exacerbated by a procyclical deleveraging process and the interconnectedness
of systemically important Banks. In response, the Committee’s new reforms seek 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.
The new global standards to address both firm-specific and broader, systemic risks have
been referred to as “Basel III”.
8
Basel III
1. Basel III Summary of Capital Requirements:
2011
2012
Minimum Total Capital Ratio
(Total Capital Base / RWA)
2013
2014
2015
2016
2017
2018
1-12019
8.00%
8.00%
8.00%
8.00%
8.00%
8.00%
8.00%
0.625%
1.25%
1.875%
2.50%
Capital Conservation Buffer
Minimum Total Capital Ratio
plus Conservation Buffer
8.00%
8.00%
8.00%
8.625%
9.25%
9.875%
10.50%
4.50%
5.50%
6.00%
6.00%
6.00%
6.00%
6.00%
Minimum Common Equity
Ratio (Common Equity / RWA)
3.50%
4.00%
4.50%
4.50%
4.50%
4.50%
4.50%
Minimum common Equity
Ratio plus Conservation
Buffer
3.50%
4.00%
4.50%
5.125%
5.75%
6.375%
7.00%
Minimum Tier 1 Capital
Ratio
(Tier 1 Capital / RWA)
Leverage Ratio
(Tier 1 Capital / Total Assets +
off-balance sheet assets)
Countercyclical Capital
Buffer
Supervisory
Monitoring
Parallel run 1 Jan 2013 - 1 Jan 2017
Disclosure starts 1 Jan 2015
Migration
to Pillar 1
0 - 2.5%
9
Basel III
2. Central Bank of Lebanon Summary of Requirements:
Capital Adequacy Ratios
Year 2013
Year 2014
Year 2015
10.5%
11.5%
9.5% +2% (CCB)
12%
9.5% +2.5% (CCB)
9.5%
7.5% +2% (CCB)
7%
5% +2% (CCB)
10%
7.5% +2.5% (CCB)
8%
5.5% +2.5% (CCB)
Minimum Capital Adequacy Ratio
(Total Capital Base / Risk Weighted
Assets)
Minimum Tier 1 Ratio
(Tier 1 Capital / Risk Weighted Assets)
Minimum Common Equity Ratio
(Common Equity / Total Assets)
8.5%
6%
10
Capital Planning
Each Bank should set a capital target
All Banks are affected by macroeconomic changes, which cannot be fully prevented only by
a sound risk culture and good risk management.
The worldwide financial crisis and Middle Eastern uncertainty have dramatically changed how
supervisory authorities, rating agencies and investors view Banks’ capitalization, in terms of:
a)Increased focus on Core Capital I/O the capital when assessing Banks’ ability to
survive;
b)Tighter regulations for Subordinated Debt as part of Tier 2 capital, including the
creation of any new capital products that facilitate conversions to equity or write-downs, in
times of financial stress;
c)More dynamic capital adequacy regulations, where various types of capital buffers to
be complied with over time are introduced; and
d)Increased focus on stress tests of the balance sheet as a tool to assess capital
requirements.
11
Two Main Objectives
a) Capital Optimization in terms of the management of the capital resources, ensuring
that they are coherent with shareholders’ requirements; and
b) Capital Allocation in terms of the ideal distribution of capital among the Business Lines,
type of products, local or foreign expansion plans, etc.
12
Basel Committee
Sound Capital Planning Process
On January 2014, the Basel Committee on Banking Supervision issued a paper entitled “A
Sound Capital Planning Process: Fundamental Elements” that presents sound
practices to encourage improvement in the capital planning processes of Banks required to
implement the Basel III framework.
The Basel Committee views capital planning as a needed complement to a strong
regulatory framework.
Sound capital planning is critical for determining the prudent amount, type and
composition of capital that is consistent with a longer-term strategy, in order
to reach business objectives, while also resisting to a stressful event.
The provision of better capital planning practices furthers the Basel Committee’s objective
of consistently implementing the Basel III framework, as a means of maintaining the
resilience of the global financial system.
New culture to be spread in the organization
13
Basel Committee
Four fundamental components of a sound capital planning process were elaborated:
1. Principle 1: Internal Control and Governance
Describes the importance of a formalized capital planning process administered through an
effective governance structure:
a) A capital planning process should reflect the input of different experts from across
the Bank, from Business, Risk, Finance, Foreign Entities and Treasury Divisions.
There should be a strong link between the capital planning, budgeting and
strategic planning processes. Expert staff to provide a view of the Bank’s current strategy,
the risks associated with that strategy and an assessment of how those risks contribute to
capital needs;
b) A capital planning process should be subject to regular independent validation;
c) Both Senior Management and the Board of Directors should be involved in the
capital planning process. Management Committee or ALCO should also evaluate the
capital planning;
d) The capital planning should be reviewed and approved annually at a minimum by the
Risk Committee and the Board of Directors; and
e) Capital planning to include actions required by the BOD e.g. confirm or change a
common stock dividend or common stock repurchase plan and/or issue regulatory capital
instruments.
14
Basel Committee
2. Principle 2 : Capital Policy and Risk Capture
Discusses the role of a capital policy in defining guidelines that Senior Management will rely
upon in making decisions about capital deployment or conservation.
a) BOD to appoint and hold a Management Team accountable for demonstrating that
adherence to a capital policy will allow the Bank to maintain ready access to
funding and meet its obligations to creditors;
b) Among the key metrics, the Bank may focus on the Common Equity Tier 1 ratio and
on ensuring that enough capital is retained to meet future requirements. Some of
the more common return measures to be employed include ROE, RORAC, and RAROC;
c) The Economic Capital can be also used also. A Bank using this practice aggregates
economic capital needs, adding any risk diversification benefits and capital
cushions;
d) Capital policies incorporate minimum thresholds monitored by Senior Management;
e) Monitoring framework to be in place including clear and transparent formal escalation
protocol for situations when a trigger or limit is approached and/or breached;
f) An expression of risk tolerance to be included, reviewed, approved by BOD annually;
g) Risks for which an explicit regulatory capital treatment is not present should be
captured, such as concentrated exposures, reputational risk and strategic risk; and
h) To establish clear links between capital and liquidity monitoring.
15
Basel Committee
3. Principle 3: Forward-looking View
Highlights the benefits of incorporating forward-looking measures about potential capital needs
into the Bank’s capital planning process.
a) Stress testing or scenario analyses are other key elements that provide a view as to how
the Bank’s capitalization could be jeopardized, in case of dramatic Bank-specific or economic
change;
b) Sound practice is supported by the repeatability of stress testing and the capability of
performing specific scenarios outside the normal stress testing procedures;
c) The impact of at least a baseline and a downturn scenario that incorporate a combination
of economic, market and bank-specific indicators should be assessed. Impact through
expected changes to the Bank’s revenue, loss, balance sheet, exposure measures and RWAs;
d) By not incorporating diversification effects into a stress testing, the Bank is presuming that
the impact of a scenario is additive and it would negatively affect all aspects of the Bank’s
business. This conservative assumption leads to greater prudence in capital
decisions; and
e) Banks reflect in their estimates actions that the Management Team could accept in
order to mitigate the impact of an economic downturn, such as potential changes in
business strategy, such as growth limits; reductions in staff and other operating expenses; or
16
capital actions, such as reductions in dividends or issuance of capital instruments.
Basel Committee
4. Principle 4: Management Framework for Preserving Capital
Summarizes the need for a formal management process to consider and prioritize a range of
actions to be taken in order to preserve capital:
a)Sound practice entails Senior Management and the BOD to ensure that the capital
policy and associated monitoring and escalation protocols remain relevant through
the risk reporting and stress testing framework;
b)They are responsible for prioritizing and quantifying the capital actions available to
them, to cushion against unexpected events.
c)Those actions include reductions in or cessation of common stock dividends, equity raises
and/or balance sheet reductions, disposition of capital markets inventory, monetizing business
units or reducing credit origination. ( eg. Divesting, disposal of FA, Preferred shares issue,
Profit re-capitalization, etc..)
d)Actions to maintain capital must be clearly defined in advance and management
process should allow for plans to be updated swiftly, to ensure better decisionmaking in changing circumstances.
17
Capital Planning Model
Minimum Requirements (Basel III)
a) Value Creation: Translates the final objectives of value creation for the stakeholders
and is used in support of operational and strategic decisions;
b) Healthy Mechanism: Provides a fair ground for competition among Departments
and Divisions and stimulates, at the same time, the collaboration among them;
c) Transparency: Model assumptions, design, and structure are readily apparent to
Senior Management and the Board of Directors;
d) Client Specific: Aligns with the specific requirements of the Bank and evolves
seamlessly as the Bank modifies requirements due to internal or/and regulatory changes;
e) Compliance: Becomes Integral part of the decision making process; and
f) Risk and Finance Integration: Supports both risk and accounting operations and
calculations, integrates risk and finance information and is able to provide risk-adjusted
performance measures.
18
Capital Planning Exercise
A Practical Approach
Overview:
a) Capital planning is crucial for the survival of Banks and leads Management to strategic
decisions;
b) The financial markets crisis emphasized the importance of effective capital planning;
c) A Bank’s capital planning process needs to incorporate rigorous, forward-looking stress
testing to indicate how much capital might be needed to absorb losses if large shocks occur;
d) Effective capital planning
process requires a Bank
to assess both the risks
to which it is exposed
and the Risk
Management processes in
place, evaluate its capital
adequacy, and consider
the potential impact on
earnings and capital from
economic downturns.
19
Structure:
• Covers 3-5 years
• Capital resources and Capital
resource requirements projected
forward
• Covers organic Balance Sheet
growth, expansion plans and
severe recession
• Assesses the impact on Capital
resource requirements and the
change in capital resources
• Management actions could reduce
capital requirements or increase
capital
• If Bank resorts to BOD or
shareholders’ , are they willing to
take those actions
Can the Bank continue to meet its
regulatory requirements based on its
Business Plan and Budget for the next
3-5 Years
Can the Bank continue to meet its
regulatory requirements throughout a
severe recession?
If the Bank resorts to BOD or
shareholders’ actions, has it considered
the difficulties associated with said
actions in a stressed environment? (eg.
Injection of common equity, capitalisation of
Retained Earnings, ROE, etc.
20
Capital Planning Governance
Capital management is an integral process, impacting a number of
organizational functions
a) BOD to decide the volume and types of risk that the Bank intends to take;
b) BOD to raise adequate and experienced resources to plan it;
c) BOD to agree with shareholders on a minimum target of return on capital consistent with
the risk borne by the Bank;
d) BOD to allocate the capital including any newly raised capital, to the Business Units;
e) Risk appetite to be set by the BOD and cascaded through the Bank by limits’ allocation;
f) Risk measurement to be undertaken by Risk Management and reported to decision makers;
g) Finance Division to produce planning and budgeting figures, which have to be supplemented
with the relevant risk estimates;
h) Stress tests applied to forecasts are a joint endeavor of Business Lines, Risk Management
and Finance Divisions;
i)
ALCO decides on actions to be taken as a result of forecasts; and
j)
Execution of capital management actions should be regularly reported by Senior
22
Management to ALCO, Risk Committee and BOD
Key Challenges to Consider
a) Robustness of underlying budgeting/planning process. Consider the strategy approved by
the BOD;
b) Appropriate time horizon (3-5 years);
c) Projecting the Entire Balance Sheet (Applying financial accounting principals);
d) Aggregation across the Business (Consolidate from Bank entity to Bank holding company);
e) Pillar 1 reg. capital + ICAAP + Basel III Buffers + Internal Buffers , if any;
f) Consistent with past Balance Sheet and RWA experience (historical outcome of Solvency
exercises. Eg.since 2007 in Lebanon). BUT should avoid mirroring historical extraordinary
items in the future e.g. 2008 financial crisis and the drastic decrease in Lebanese Banks
interbank placements, redirected to the Lebanese Sovereign;
g) Growth projections for existing entities (based on Balance Sheet/Income Statement Growth
and RWA experience);
h) Growth projections for potential subsidiaries and branches (eg. based on related Market
studies and Research and the Bank’s strategy);
i)
Arithmetic accuracy;
j)
Proper challenge, review and sign-off;
23
Key Challenges to Consider
i) Sufficient granularity of details, such as:
•
Components of available capital;
•
Endowment capital to be set aside for future foreign branches and subsidiaries;
•
Legal reserve requirements under each jurisdiction in which the Bank operates;
•
Proper treatment of dividends (distributed, partially retained, fully retained);
•
Different asset classes according to Basel II and BDL Basic Circular no. 115;
•
Different RWA classes and applicable Risk Weights;
•
Standard Credit Conversion Factors (CCFs) for OBS exposures;
•
NPL future provisioning policy which impacts Past Due Loans Capital requirements;
•
Segregation between the banking book (FVOCI, AC) and trading book (FVTPL);
•
Evolution of Gross Income which is key to computing future OR Capital requirements;
•
Preferential Treatment by the Supervisory authorities in which the Bank operates;
•
Any foreseen future extraordinary balance sheet items;
•
Potential risk of currency devaluation in countries where the Bank is or will be
present.
24
Capital Planning Outcome
Asset Composition (in C/V millions of USD)
Forecasting - Year 2014
CAPITAL PLANNING
Risk
Weight Group Level Subsidiary 1 Subsidiary 2 Group Level Subsidiary 1 Subsidiary 2 Group Level Subsidiary 1 Subsidiary 2
Other
Assets
OBS
NPLs
Lending Portfolio
Liquid Assets
Assets RWA Assets RWA Assets RWA Assets RWA Assets RWA Assets RWA Assets RWA Assets RWA Assets RWA
2,838
-
2,820
18
-
100
100
49
-
-
173
173
53
143
350
205
802
160
772
100
100
338
65
49
556
417
486
446
335
0
0
481
361
284
660
231
150
53
873
25
38
21
32
4
6
50%
300
150
300
150
-
11. Guarantees
50%
125
63
125
63
12. LCs
20%
52
10
52
10
13. Other Assets (Purchased
Cheques, Cash etc.)
100%
631
631
522
522
75
1. LBP Lebanese Sovereign Exp.
0%
2. FCY Lebanese Sovereign Exp.
100%
3. Other Sovereign Exposure
100%
160
160
49
4. Claims on Banks and FIs
20%
744
149
716
5. Exposure to Corporate clients
100%
6. Exposure to SMEs
75%
516
387
451
7. Retail Exposures
75%
446
335
8. Exposure in Residential
Mortgage Loans
35%
810
9. Past due loans
150%
10. Unutilized Exposures
14. Operational Risk
15. Market Risk
16. Total Risk Weighted Assets (Credit,
Market and Operational RWAs)
17. Total Balance Sheet (including OBS)
Trend Indicator 1: Avg. RWA % avg.
total assets
18. Total Deposits
Trend Indicator 2: Avg. net loans % avg.
deposits
-
1,605 1,605 1,505 1,505
1,100 1,100 1,000 1,000
3,060
-
3,041
-
20
-
111
111
53
-
-
186
186
57
154
388
78
865
173
832
111
111
365
72
54
600
450
524
481
361
0
0
518
389
306
712
249
166
58
942
27
40
23
34
4
7
-
323
162
323
162
-
-
-
135
67
135
67
0
0
56
11
56
11
75
660
660
543
543
83
1,731 1,731 1,623 1,623
1,186 1,186 1,078 1,078
3,299
-
3,278
-
22
-
123
123
57
-
-
166
430
86
123
123
393
80
60
518
389
0
0
330
767
269
184
65
29
44
24
37
5
7
-
349
174
349
174
-
-
-
-
145
73
145
73
-
-
0
0
60
12
60
12
0
0
83
712
712
585
585
92
92
1,866 1,866 1,750 1,750
1,279 1,279 1,163 1,163
-
25
30
20
25
5
5
27
33
22
27
6
6
30
36
24
30
7
7
-
4,965
4,368
598
5,334
4,749
514
5,753
5,121
570
-
9,352
8,667
862
10,124
9,374
968
10,917
10,108
1,074
-
53.09%
50.39%
69.28%
52.69%
50.66%
53.06%
52.70%
50.67%
53.06%
-
7,465
6,502
638
8,206
7,147
707
9,020
7,856
785
-
38.47%
39.33%
49.43%
37.74%
38.58%
49.43%
37.02%
37.84%
49.43%
Figures are illustrative and do not reflect any actual position
25
Capital Planning Outcome
Minimum
Regulatory
Ratios
Minimum
Regulatory Ratios
+ ICAAP + Cap.
Conservation
Buffer
CAR
10.50%
Tier 1 Ratio
Solvency Ratios
Common Equity Ratio
CL (Stand-Alone)
CLIB (Stand-Alone)
13.75%
14.36%
13.62%
16.60%
-
0.62
8.50%
11.75%
13.16%
12.25%
16.60%
-
-
6%
10.25%
11.14%
9.96%
16.60%
-
-
6.34%
5.56%
11.50%
-
-
3%
Minimum
Regulatory
Ratios
Minimum
Regulatory Ratios
+ ICAAP + Cap.
Conservation
Buffer
CAR
11.50%
Tier 1 Ratio
Common Equity Ratio
Deficiency below
Deficiency below
regulatory requirements +
regulatory requirements
ICAAP + Cap.
(In millions of USD)
Conservation Buffer
CL (Stand-Alone)
CLIB (Stand-Alone)
14.25%
13.98%
13.03%
20.99%
-
52.21
9.50%
12.25%
13.14%
12.09%
20.99%
-
1.77
7%
10.75%
11.27%
9.99%
20.99%
-
30.53
6.29%
5.52%
11.13%
-
-
3%
Minimum
Regulatory
Ratios
Minimum
Regulatory Ratios
+ ICAAP + Cap.
Conservation
Buffer
CAR
12%
Tier 1 Ratio
Common Equity Ratio
Leverage Ratio
CL Cons.
Leverage Ratio
Solvency Ratios
Deficiency below
Deficiency below
ICAAP + Cap.
Conservation Buffer
CL Cons.
Leverage Ratio
Solvency Ratios
Deficiency below
Deficiency below
ICAAP + Cap.
Conservation Buffer
CL Cons.
CL (Stand-Alone)
CLIB (Stand-Alone)
14.25%
13.59%
12.61%
20.50%
-
77.88
10%
12.25%
13.08%
12.03%
20.50%
-
4.99
8%
10.75%
11.34%
10.08%
20.50%
-
28.17
6.26%
5.49%
10.88%
-
-
3%
Figures are illustrative and do not reflect any actual position
26
Based on the Outcome.
What should we do?
a) Maintain a balance between the Solvency Ratios and the Return on Equity (ROE);
b) In cases where capital ratios fall below regulatory and acceptable levels… REACT:
Suspend potential future expansion, mainly where regulatory capital needed is relatively high;
•
Downsize a high risk portfolio;
•
Allocate capital more effectively by focusing on higher risk-based returns using RAROC;
•
Increase returns by decreasing past due loans;
•
Increase operational effectiveness.
•
Support Core Tier 1, by issuing common stock;
•
Support Core Tier 1, by retaining profits, imposing restrictions on dividends, shares buy-back;
•
Support Tier 1, by issuing non-cumulative perpetual preferred shares;
•
Support Tier 2, by issuing cumulative preferred shares; and
•
Support Tier 2, by issuing medium to long term subordinated debt.
Plan B
Plan A
•
c) In cases where capital ratios show a surplus… REACT:
•
Evaluate new initiatives/programs/investment opportunities to allocate excess of capital
(Interbank, Corporate, Consumer) and improve your ROE by optimizing utilization of capital.
27
Thank you
narizkallah@cl.com.lb
Also available on
28

Nada Awad Rizkallah (pdf – 1.24 MB) - The Institute of International

Transcription

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