Risk Intelligence: The 21st Century Frontier of Market Efficiency CRITICAL SUCCESS FACTORS IN IMA IMPLEMENTATION PHILIPPE CARREL Mumbai, July 21st 2010 THE ROAD TO SYSTEMATIC RISKS Number of crisis over time appears to be rising 370 years of cyclical crises always resulted from decoupling the perception of current risk versus future value REGULATIONS AIM AT DE-RISKING VITAL ACTIVITIES Idiosyncratic risk stabilised through adjusted through risk adjusted capital reserves CAPITAL Credit Risk Weighted Assets + [12.5 x (Mkt Cap Charge + Ops Cap Charge)] Systematic risks through countercyclical prudential supervisory measures. BCBS 164 on strengthening resilience contains proposals for capital buffers to contain leverage and exposure IDIOSYNCRATIC RISK MANAGEMENT IS TO BALANCE THE CREATION OF VALUE WITH EXPOSURE TO RISK FACTORS Corporate Strategy Shareholders Funding Strategy Debt, Bond holders Risk Appetite • Exposure • Sensitivity • Maximum Loss Risk is a measure of sensitivity to factors of exposure under scenarios Managing risk is to align the firm’s exposure to the risk factors with its appetite for it MANAGED IN SILOS, RISK IS NECESSARILY AGGREGATED BY MODELS Banking Books Collateral Trading Books Markets Portfolios Economy Growth Country Operations Market Risks (ALM) Credit Risks (EL=PDx[1-LGD]) Market Risks (Haircut) Credit Risks (EAD) Market Risks (VaR) Credit Risks (CVaR, PFE) Operational Risks (PE x LGE) or OpVaR Net RWA Aggregated Loss Distribution EL VaR UL(i, j , a) =VaR( a) - EL(i, j ) confidence level A FOCUS ON LOW IMPACT HIGH FREQUENCY EVENTS REDUCES CAPITAL CHARGE… Probability of Loss Event Expected Losses VaR Stressed VaR Catastrophic Scenario Repetitive tail events Scope of Basle II Expected losses Outside the scope of Basle II Loss Impact Interval of confidence Outside the scope of B II But increases exposure to tail risks… ..and to system externalities. CREATE A CULTURE OF RISK MANAGEMENT – KEEP IT ALIVE Restore the balance Capital Efficiency / Risk to align Corporate Governance and Risk Appetite Support Regulatory Compliance with information on market behaviour in addition to statistical analysis Risk Intelligence No financial instrument is inherently risky Valuation and aggregation methodology (covariance) depend on the nature of tail events Crashes follow booms, but the future is not like the past RECONNECT SENSES TO CREATE A DNA BACKBONE Banking Books Risk Factors Markets Portfolios Economy Growth Country Operations Markets Portfolios Economy Growth Country Operations Valuations Trading Books Markets Portfolios Economy Growth Country Operations Counterparties RECONNECT THE BRAINS WITH THE NERVOUS SYSTEM Portfolio view of firmwide risks, limits and triggers Business Line Risk Mgr Net Exposure Sensitivity Max Loss Product Risk Mgr Regional Risk Mgr Portfolio Limits Sensitivity Limits Concentration Limits P/L Limits CAPITAL & LIQUIDITY SHOULD BE DRIVEN BY RISK INTELLIGENCE NOT ONLY RWA CREATING A RISK INTELLIGENT GOVERNANCE AND COMPLIANCE FRAMEWORK • Multiple vendor feed • Internal pricing feed 7 2 Cross-silo exposure from: • business lines • products Portfolio • regions 1 Intelligence • Exposure • Sensitivity • Max Loss Market Intelligence RISK FACTORS 4 Scenario 5 Simulations Global Risk Infrastructure Framework Reverse Stress Test 8 • Gaps • Concentrations Liquidity • Contingencies Intelligent Data 3 • Reference data • Counterparty data • Ratings Risk Intelligence Risk 5 6 Enterprise Risk Management Monitor Capital & Liquidity Strategy CREATING RISK INTELLIGENCE GOVERNANCE DRIVEN COMPLIANCE DRIVEN • Enterprise-wide aggregation (by risk factor) • Sensitivity analysis (portfolio and entity level) • Stress testing • Effective counterparty exposure • Expected Positive Exposure (EPEs) • Credit Value Adjustments (CVAs) • Liquidity Risk Management • Stress test ALM & gap analyses • Counterparty driven gap analyses • Collateral liquidity • Valuations of OBS exposure • Limit & Collateral Management • Net counterparty exposure • Risk concentration and sensitivity limits • Leverage ratios and OBS THE FALLACY OF MODERN FINANCE THEORY Modern finance theory leads to • Measuring expected return as a function of volatility (CAPM) • Diversifying risks through expectations of low covariance • Expressing tail event probabilities as a frequency of occurrence Rs = i + (Rm-i) + a Rs = Expected return on the security i = risk-free return Rm= Expected return on the market = Cov(s,m) Var(m) Expected return Efficient frontier a Mkt index b i 0 1 The act of (collectively) observing an area of financial safety makes it risky A. Persaud. Dec 2002 COVARIANCE RELIES ON INVESTORS’ BEHAVIOUR NOT ON HISTORICAL DATA Correlation Matrix Correlation Values Absolute Interval Weekly Color Codes Threshold1: List Setup Calculate Currency GBP= EUR= INR= JPY= CNY= XAU= CLc1 0.5 Hide If GBP= 1.0000 0.9050 0.4909 0.1027 0.2596 -0.7041 -0.2368 EUR= 0.9050 1.0000 0.3198 -0.0021 0.3808 -0.6835 -0.0901 INR= 0.4909 0.3198 1.0000 0.0066 0.0667 -0.6296 -0.8099 JPY= 0.1027 -0.0021 0.0066 1.0000 0.4666 -0.3922 0.1233 CNY= 0.2596 0.3808 0.0667 0.4666 1.0000 -0.4171 -0.0595 StartDate 02 Aug09 Threshold2: Correlation XAU= -0.7041 -0.6835 -0.6296 -0.3922 -0.4171 1.0000 0.3961 0 EndDate Threshold3: is above CLc1 -0.2368 -0.0901 -0.8099 0.1233 -0.0595 0.3961 1.0000 Variables are wrongly assumed to be independent 18 Jul10 -0.5 0.5 SPIRIT OF BASLE III (BCBS 164 on Strengthening Resilience) Quality and consistency of capital base T1 Equity only T2 5 year minimum maturity , hybrids phased out T3 abolished Enhanced risk coverage Stressed VaR (includes periods of stress) Credit Value Adjustment (CVA) to represent counterparty risk in market exposure Push on centralised clearing counterparties Wrong-Way risk Leverage ratio Ratio added to Pillar1 calculated with credit conversion factors Focus on off-balance sheet items Counter-cyclical measures Probability of Default (PD) and Exposure At Default (EAD) computed over long term Expected Loss (EL) to replace IAS39 Capital buffers to limit excess credit and leverage Global Liquidity Standard (BCBS 165) CREATING A RISK INTELLIGENT INDUSTRY GOVERNANCE DRIVEN COMPLIANCE DRIVEN Liquidity Dynamic gap analysis under scenarios Concentrations on funding sources Stress tests of exposure and collateral Counterparty Risks Concentrations and leverage Collateral and margin management (reflect concentrations) Market Risks Concentrations, root risk and indirect exposure Credit and liquidity risk priced in market risk Mark-to-volitilty, mark-to-liquidity Volatility and correlations Potential reverse impact of volatility and concentrations on correlations correlation and market depth ENHANCE TRANSPARENCY Market Duration class Coupon Participation Principal Protection Convertibility Path dependence Short/Medium/Long/Extended Fixed/Variable/Minimum guaranteed Multiple/Full/Partial/Variable None/Partial/Full Auto/Dynamic/Periodic/Synthetic Callable/Auto/Barriers Legal Supervisory body Regulatory Region Bank/Securities/Exchange/Others EU/US/Other OECD/Others • Attach risk-ratings to ALL instruments including OTC and funds • Rate financial risks, volatility, liquidity, transparency • Adapt valuation frequency to risk ratings (Mark-to-Risk) MONITOR BEHAVIOURS Price Risk Class A: Depth/Liquidity B: Quotation frequency C Typical Slippage D: Spread/Price Volatility E: News/Data Availability Rating 0 to 5 0 to 5 0 to 5 0 to 5 0 to 5 • Attach risk-ratings to ALL instruments including OTC and funds • Rate financial risks, volatility, liquidity, transparency • Adapt valuation frequency to risk ratings (Mark-to-Risk) RISK & LIQUIDITY CONCENTRATION BENCHMARKS Banks contribute foreign exchange claims in US$m by 1-Currency 2-Instrument type (fxswap, loan type, asset, liability) 3-Tenor (time bucket) 4-Volatility time bucket (if applicable) 5-Strike bucket (if applicable) 1 Regulators input scenario 1-Interest rates 2-Exchange rate 3-Volatility 4-Correlation Term Structure of Asset/Liabilities by currency 2 RISK AGGREGATOR o Aggregated views foreign exchange claims by time bucket o Gap analysis (Asset/Liability mismatch) o Sensitivity analysis (under scenarios) o Volatility concentration matrices o Strike/Barriers concentration matrices 3 o Central bank gets view of potential bubbles o Regulators can anticipate on funding issues per currency and instrument o Aggregated risk view in base currency o Banks can benchmark their funding risk against industry view. AGGREGATED TERM STRUCTURE OF MISMATCHES IN FOREIGN CURRENCIES Banks contribute foreign exchange claims in US$m by 1-Currency 2-Instrument type (fxswap, loan type, asset, liability) 3-Tenor (time bucket) 4-Volatility time bucket (if applicable) 5-Strike bucket (if applicable) 1 Regulators input scenario 1-Interest rates 2-Exchange rate 3-Volatility 4-Correlation Term Structure of Asset/Liabilities by currency 2 Thomson Reuters o Aggregated views foreign exchange claims by time bucket o Gap analysis (Asset/Liability mismatch) o Sensitivity analysis (under scenarios) o Volatility concentration matrices o Strike/Barriers concentration matrices 3 o Central bank gets view of potential bubbles o Regulators can anticipate on funding issues per currency and instrument o Aggregated risk view in GBP o Banks can benchmark their funding risk against industry view. • Allow an assessment of firms’ currency liquidity risks and their potential vulnerabilities to a drying up of certain currency swap markets VARIABLE CAPITAL ADEQUACY RATIOS & CROSS-SYSTEM SIMULATIONS SIMULATE SHOCKS Market Credit Liquidity Defaults MEASURE IMBALANCES Asset/Liab benchmarks Risk Risk concentrations concentrations ADJUST Identify Asset Bubble Assess Risks Liquidity Liquidity risk risk Basis Basis risk risk • Variable CAR • Pro/Counter Cyclical • Update instrument risk factors • Communicate policies • Recommandations COMMUNICATE Liquidity mismatches Industry representatives Regulators Policy makers Previsionists CONSULT • Combine modeling, human judgment and consensus based consultation • Adjust regulatory policies according to risk intelligence • Anticipate bubbles and eradicate systemic risk Risk Intelligence is the New Efficient Frontier Balancing shareholder value versus risk exposure depends on the firm’s assessment of its aggregate sensitivity to risk factors under changing conditions and on its ability to act upon it. Regulators’ insights depend on risk intelligence. Data Information Post Trade Analysis Analytics Collection Data Management • Equity Prices • Public Company Fundamentals • Beta • Duration • Single desk / portfolio • Unsophisticated • Pricing & Reference data • Valuation Risk • VaR • Binomial Model • Monte Carlo VaR • Evaluated Pricing • Risk Benchmarks • Risk Indices • Risk Ratings • Potential Future Exposure • Stress and Scenario Testing • Multi desk / portfolio • Static post-trade risk aggregation • Portfolio view of firm-wide risk • Dynamic aggregation of contextualized risk Risk measurements Insights Stress Tests & Reverse Risk Aggregation Risk Intelligence Value 21 Risk Intelligence: The 21st Century Frontier of Market Efficiency CRITICAL SUCCESS FACTORS IN IMA IMPLEMENTATION PHILIPPE CARREL Mumbai, July 21st 2010