PRMIA- HYDERABAD CHAPTER Uniting Risk Professionals Worldwide Financial Stability B. YERRAM RAJU REGIONAL DIRECTOR This presentation is based on the RBI Report on Financial Stability enclosed to the RBI Bulletin April 2010. 1 When and Why think of Stability?- The Crisis and Consequential instability? Uniting Risk Professionals Worldwide • The crisis started in summer 2007 with lightning failure of Lehman Brothers, Washington Mutual Funds and 3 Iceland Banks. • Mistrust and fear spread among Banks. • Four Risk environmental factors still being probed: – Financial Risk valuation models/methods – Risk Control Functions – Risk limiting strategies and – Bonus Culture. A Perspective on the Indian Approach on the Financial Policy Making Uniting Risk Professionals Worldwide • Prudential policy framework for banks addressing: – Leverage, liquidity, and counterparty concentration – Recognition of NBFCs as systemically important and extension of regulatory perimeter – An Active Capital Account management framework – Explicit regulation of key OTC derivative markets. • Despite relatively low exposure to global markets, the contagion impact of any global shocks not ruled out. 3 Healthy Banking sector Uniting Risk Professionals Worldwide •Tighter regulatory standards on capital, liquidity and leverage for banks; •Unregulated systematically important financial entities (NBFCs, Coops) brought under regulatory oversight •Addressing systemic risks arising from interconnectedness among financial sector entities •Regulating financial markets from a systemic risk perspective. 4 Key underpinnings Uniting Risk Professionals Worldwide •Ensuring that – the process of being away from disintermediation is genuine – A clear, transparent capture of the risks within the prudential framework exists in the treatment of NBFCs •Credit quality robust •Share of low cost current and savings account deposits (CASA) is high •Banks are required to hold a minimum percentage of their liabilities in risk free government securities. 5 Uniting Risk Professionals Worldwide •“Maintenance of financial stability involves trade-offs and raises a number of challenges.” (Financial Stability Report, RBI, April 2010) 6 What is Financial Stability Uniting Risk Professionals Worldwide •It is “a situation in which the financial sector provides critical services to the real economy without any discontinuity.” •Absence of financial instability: ‘containment of the likelihood of failure of individual financial firms or any systemic stress and thereby limiting the associated costs to the economy.’ •Arresting the possible consequence of ‘unknown unknowns’ and realising the limitations of modeling apparatus and stress testing exercises. 7 Financial Stability Board Uniting Risk Professionals Worldwide • Set up by G-20 in the aftermath of recession. • Mandated to – Assess vulnerabilities affecting the global financial system – Identify and review the regulatory, supervisory and related actions needed to address them and their outcomes; – Promote coordination and information exchange among the authorities responsible for FS – Monitor and advise market development and their implications for regulatory policy; – Advise and monitor best practices – Undertake joint strategic reviews of policy development work on developing international standards – Set guidelines for and support establishment of supervisory colleges – Support contingency planning for cross-border crisis management – Collaborate with the IMF to conduct Early Warning System – Undertake any other tasks members may seek to perform. 8 Central Banks and FS-Key Aspects Uniting Risk Professionals Worldwide • Supervision of individual firms from a systemic perspective • Greater involvement of central banks where it is found wanting in supervision of systemically important entities • A collegial body of government/central bank/regulators • Reorientation of regulatory mandates of all regulators to also take into account a systemic perspective. • Monetary stability supports sound investment and sustainable growth leading to FS 9 Principal Perspectives of FS Uniting Risk Professionals Worldwide •FS has critical influence on price stability and sustained growth •FS facilitates efficient transmission of monetary policy actions •From the regulatory and supervisory angle, FS safeguards the depositors’ interests and ensures stability of the financial system. 10 Capital Account Uniting Risk Professionals Worldwide Buttressed through the imposition of prudential safeguards in respect of access of foreign entities to the domestic debt markets and on forex borrowings by domestic corporates. (Cap on FII investments in Corporate (US$15bn) and Government (US$5bn) bonds. 11 Liquidity Management Exposure Norms for Commercial Banks Uniting Risk Professionals Worldwide Exposure to Limit 1, Single borrower 15% of capital fund (Additional 5% on infrastructural component) 40% of capital fund (Additional 10% on infrastructure exposure) 10% on capital fund 15% on capital fund 20% on capital fund 2. Group Borrowers 3. NBFC 4. NBFC-AFC 5. Indian Joint venture /wholly owned subsidiaries abroad/overseas step down subsidiaries of Indian corporates 12 Liquidity Management (contd) Exposure Norms for Commercial Banks Exposure to 6. Capital Market Exposure (a) Banks holding shares in any Co. Uniting Risk Professionals Worldwide (b) (c) (d) (e) (f) Banks’ aggregate exposure (solo basis) Group basis Banks’ direct exposure (solo) Banks’ direct exposure (group) Gross holding of capital among banks/FIIs Source: RBI FSR-2010 p 8 Limit The lesser of 30% of paid up share capital of the Co., or 30% of the paid up cap of banks 40% of its net worth 40% of its consolidated net worth 20% of net worth 20% of net worth 10% of capital fund 13 What made us distinct? • The counter-cyclical regulations applied ahead of the global crisis helped us cushion against systemic instability. Uniting Risk Professionals Worldwide • Significant reduction in risk and rebound in market activity • Pressures on banking sector liquidity during the crisis together with extraordinary measures taken led to shortening of the maturity profile of bank liabilities • Banks facing large refinancing needs in the following years • Management of funding risks skillfully • More stable customer deposits • Sovereign and corporate CDS spreads broadly stabilised in Q2-2009 • Corrections in equity prices in Emerging Market economies witnessed largely declines in the range of 30-67 percent. • Gains started only in the Q3-2009 • Stimulus measures significantly increased global liquidity. • Forex markets – RBI’s presence in the market helped manage volatility –Forward Premia in Indian forex markets lower than the rate dictated by interest differential. Regulatory Counter-cyclical Measures Date Uniting Risk Professionals Worldwide Capital Mkt Housing Other Retail Comm Real Estate NBFC-ND-SI Risk wt Provision Risk Wt Provision Risk Wt Provision Risk wt Provision Risk Wt Provision Dec 04 100 0.25 75 0.25 125 0.25 100 0.25 100 0.25 Jul 05 125 0.25 75 0.25 125 0.25 125 0.25 100 0.25 Nov 05 125 0.40 75 0.40 125 0.40 125 0.40 100 0.40 May-06 125 1.0 75 1.0 125 1.0 150 1.0 100 0.40 Jan-07 125 2.0 75 1.0 125 2.0 150 2.0 125 2.00 May- 07 125 2.0 50-75 1.0 125 2.0 150 2.0 125 2.00 May-08 125 2.0 50100 1.0 125 2.0 150 2.0 125 2.00 Nov- 08 125 0.40 50100 0.40 125 0.40 100 0.40 125 0.40 Nov-09 125 0.40 50100 0.40 125 0.40 100 1.00 100 0.40 15 GDP Outlook Uniting Risk Professionals Worldwide • Increasing business cycle correlation between developed and developing economies that enabled India’s current and capital a/c flows more than doubled from les than half of the country’s GDP in 1991 to over 100% of GDP in the last two years. • Indian economy continued to be driven largely by domestic demand notwithstanding increasing globalization. • Overall macro economic conditions affected by adverse shocks in farm sector growth – deficient monsoon;associated drought and flood in certain parts of the country; decline in kharif production of food grains and oil seeds. GDP Outlook Contd.. Uniting Risk Professionals Worldwide • Tangible recovery since April 2009 in industry and services • Upward bias strengthened due to – Recovery in industry & core infrastructure – Upturn in business & consumer confidence reflected in revival of consumption and investment demand – Revival in exports and capital flows – Recovery in stock market – Higher resource mobilization thru public issues and private placements • RBI’s growth forecast revised to 7.5% in 09-10 Exit Process had begun Uniting Risk Professionals Worldwide •SLR restored to 25% - on May 26 reduced to 24.5% to provide more liquidity in the wake of 3-G cash requirements of Telecom Companies. •Export Credit refinance back to 15% •Non-standard refinance facilities to commercial banks discontinued •Jan 2010- CRR hiked by 75 basis points to 5.75% •Repo and Reverse Repo hiked by 25 basis points. 18 Key Fiscal Indicators (Centre and States) (per cent to GDP) Year Uniting Risk Professionals Worldwide 2003-04 2004-05 2005-06 2006-07 2007-08 2008-09 RE 2009-10 BE Primary Deficit Revenue Deficit Gross Fiscal Deficit Outstanding Liabilities 2.1 1.3 1.0 0.0 -1.1 3.4 4.3 5.8 3.5 2.7 1.3 0.2 4.1 5.1 8.5 7.2 6.5 5.4 4.1 8.5 9.7 81.1 78.6 77.2 74.3 72.0 71.6 73.2 RE: Revised Estimates. BE: Budget Estimates. NOTE: Negative sign indicates surplus. Source: Budget Documents. 19 Movements in Monetary Policy Instruments and BPLRs Phase Uniting Risk Professionals Worldwide Monetary Tightening Phase Monetary Easing Phase (Mar 2004 – Sep 2008) (Sep 2008 – Nov 2009) CRR 450 (-)400 Repo Rate 300 (-)425 Reverse Repo Rate 150 (-)275 Public Sector Banks 325-350 (-)125 – (-)275 Private Banks 225 – 375 (-)100 – (-)125 Foreign Banks 100 – (-)150 (+)50 – 0 Bench mark Prime Lending rates Source: RBI Report of the Working Group on Benchmark Prime Lending Rate, October 2009 20 Liquidity ratios Liquidity Ratios Uniting Risk Professionals Worldwide Mar05 Mar06 Mar07 Mar08 Mar09 Sep09 Dec09 1 (Volatile Liabilities – Temporary assets)/ (Earning Assets Temporary Assets) – (%) 34.7 38.4 41.4 43.9 43.9 45.7 45.1 2 Core Deposits/Total Assets – (%) 53.8 53.9 52.2 49.3 48.4 51.0 52.0 3 (Loans + Mandatory CRR + Mandatory SLR + Fixed Assets)/Total Assets – (%) 75.0 79.9 83.4 85.9 79.6 81.4 83.3 4 [Loans +Mandatory CRR + Mandatory SLR + Fixed Assets]/Core Deposits 1.4 1.5 1.6 1.7 1.6 1.6 1.6 5 Temporary Assets/Total Assets – (%) 28.8 30.3 43.4 52.0 47.6 39.9 40.0 6 Temporary Assets/Volatile Liabilities 0.54 0.53 0.65 0.71 0.69 0.61 0.61 Source: RBI Supervisory Returns 21 Liquidity Ratios Uniting Risk Professionals Worldwide NO Ratio Components Significance 1 (Volatile liabilities – Temporary Assets)/(Earnin g Assets – Temporary Assets) Volatile Liabilities: (Deposits + borrowing bills payable upto 1 year) Letters of credit – full outstanding ComponentWise CCF of other contingent credit and commitments Swap funds (buy/sell) upto one year Measures the extent to which hot money supports bank’s basic earning assets. Since the numerator represents shortterm, interest sensitive funds, a high and positive number implies some risk of illiquidity. As per extant norms, 15 per cent of current deposits (CA) and 10 per cent of savings deposits (SA) are to be treated as volatile and shown in 114 days time bucket; remainder in 1-3 years bucket. Hence CASA deposits reported by banks as payable within one year are included under volatile liabilities Borrowings include from RBI, call, other institutions and refinance Temporary assets: Cash Excess CRR balances with RBI Balances with banks Bills purchased/discounted upto 1 year Investments upto one year Swap funds (sell/buy) upto one year Earning Assets: Total assets – (Fixed assets + Balances in current accounts with other banks + Other assets excl. leasing + Intangible assets) 22 No Ratio Components Significance 2 Core deposits/Total Assets Core deposits: All deposits (including CASA) above I year + net worth Total Assets: Balance sheet footing Measures the extent to which assets are funded through stable deposit base. 3 (Loans + mandatory SLR + mandatory CRR + Fixed Assets)/Total Assets Gross Advances Required SLR Required CRR Fixed assets Loans including mandatory cash reserves and statutory liquidity investments are least liquid and hence a high ratio signifies the degree of ‘illiquidity’ embedded in the balance sheet. 4 (Loans + mandatory SLR + mandatory CRR + Fixed Assets)/Core deposits Advances Required SLR Required CRR Fixed assets Measure the extent to which illiquid assets are financed out of core deposits. Greater than 1 (purchased liquidity) Less than 1 (stored liquidity) Uniting Risk Professionals Worldwide 23 Uniting Risk Professionals Worldwide No Ratio Components Significance 5 Temporary Assets/Total Assets Measures the extent of available liquid assets. A higher ratio could impinge on the asset utilisation of banking system in terms of opportunity cost of holding liquidity 6 Temporary Assets/Volatile Assets Measures the cover of liquid investments relative to volatile liabilities. A ratio of less than 1 indicates the possibility of a liquidity problem. 7 Volatile liabilities/Total Assets 8 (Market value of Non – SLR Securities + Excess SLR Securities) / (Book Value of Non – SLR Securities + Excess SLR Securities) Item 5 divided by item 6 Measures the extent to which volatile liabilities fund the balance sheet. Measures the market value of non – SLR securities and excess SLR securities relative to their book value. A ratio exceeding 1 reflects that a bank stands to gain if it sells off its saleable portfolio Source: Report of the Committee on Financial Sector Assessment. 24 Rating Outlook of Banks (Long term Instrument) Uniting Risk Professionals Worldwide (hybrid Instruments) Rating as on March 31,2009 Rating as on November 30,2009 No. of Banks assessed 25 26 Positive 01 - Stable 19 25 Negative 05 1 Rating as on March 31,2009 Rating as on November 30,2009 25 25 - 01 Stable 18 23 Negative 07 1 No. of Banks assessed Positive Source:CRISIL 25 Uniting Risk Professionals Worldwide Banks assessed Long Term rating Positive Stable Negative Rating as on March 31,2009 Rating as on November 30’2009 27 0 24 3 28 3 20 5 Note: The numbers pertain to long – term instruments only (both national and international), Hybrid ratings where assigned, carry a lower rating but the same outlook as the bank’s long – term rating. Source: Fitch 26 Different Regulatory Norms of UCBs Tier I bank Tier II bank Definition Deposits less than Rs.100 crore Other cooperative banks NPA norm 180 days loan delinquency norm for loan accounts till March 2009 90 days loan delinquency Asset classification norm The 12 month period for classification of a substandard asset in doubtful category is effective from April 1, 2009 The 12 month period for classification of a substandard asset in doubtful category has been effective from April 1, 2005 Provisioning Norms Standard Assets:0.25% Standard Asset: 0.25% to 0.40%depending on loan category. Fresh accretion Doubtful Asset for more than three years March 31,2007 – 50% March 31,2008 – 60% March 31,2009 – 75% March 31,2010 – 100% Doubtful assets outstanding for more than three years 100% from March 31,2007 Uniting Risk Professionals Worldwide Source: Reserve Bank of India 27 Deposits Advances and Investments of SUCBs (Growth per cent) Mar 2008 over Mar 2007 Uniting Risk Professionals Worldwide Total Assets Capital &Reserves Deposits Borrowings SLR Investments Non SLR Investments Gross loans & Advances 17.2 29.8 19.7 7.9 17.0 39.5 16.1 Sep 2008 over Sep 2007 14.9 17.5 16.6 -2.5 12.8 23.9 18.8 Mar 2009 over Mar 2008 13.2 25.9 13.6 15.2 13.3 19.9 13.7 Source: RBI on Trends and Progress 28 Major Sources of Funds of NBFCs – ND - SI Source of Fund Uniting Risk Professionals Worldwide 1. 2. 3. 4. 5. March 2008 (Percentage to total liabilities) March 2009 (Percentage to total liabilities) 21.7 4.9 19.8 5.4 14.1 28.3 4.5 18.5 2.8 15.2 Debentures Commercial Paper Borrowing from Banks and Fis Inter – corporate Loans Others Source: RBI Report on Trend & Progress of Banks. 29 Uniting Risk Professionals Worldwide S. No Approach The earliest date of making application by banks to the RBI a. b. c. d. Internal Models Approach (IMA) for Market Risk The Standardised Approach (TSA) for Operational Risk Advanced Measurement Approach (AMA) for Operational Risk Internal Ratings – Based (IRB) Approaches for Credit Risk (Foundation – as well as Advanced IRB) April April April April 1, 1, 1, 1, 2010 2010 2012 2012 Likely date of approval by the RBI March 31, 2011 September 30, 2010 March 31, 2014 March 31, 2014 Source: Reserve Bank of India 30 Macro Economic Environment Uniting Risk Professionals Worldwide • Global activity contraction of 0.8% in 2009 expected to recover by about 3.9% in 2010 (IMF-World Economic Outlook Jan) • Global inflation remained subdued slipped into negative territory • Anaemic aggregate demand, sharp decline in oil prices since mid 2008 • Major corrections of agricultural commodity prices and metals • Decline in capacity utilization • Transfer of financial risks to sovereign balance sheets and higher public debt levels added to financial stability risks and complicated the stimulus-exit process 31 Soren Ramdhan Research Findings • Financial Crisis started in summer 2007 with the lightning failure of Lehman Bros and Washington Mutual Funds and 3 Iceland Banks • It spread mistrust and fear among Banks and FIs • Four Risk Environmental Factors still being probed: Uniting Risk Professionals Worldwide – – – – Financial Risk valuation models/methods Risk Control Functions Risk limiting strategies and Bonus culture • Empirical evidence shows that financial risk performance was related with the factors: financial risk valuation models/methods and risk control functions. The factor risk control functions with the financial risk performance have a stronger relation than the factor financial risk valuation models/methods with financial risk performance. • Remarkably, no evidence is found to support the relation between financial risk performance and the factors: risk-limiting strategies and bonus culture. • Financial institutions can achieve better financial risk performance by emphasizing more on the risk environmental conditions related with financial risk valuation models/methods and risk control functions. Introduction (1) Background/sc ope Root of the financial Scope of the Financial crisis research Risk Underestimated crisis environmental financial risk Started in conditions 2007 Risk Perfectly environmental estimated Uniting Risk conditions financial risk Professionals Worldwide Risk environmental factors Researc h objectiv e MRQ1 14-3-2016 Financial risk performance To identify the relation between financial risk performance of the last years and risk environmental factors influencing the performance. What were the risk environmental factors behind the financial risk performance? 33 Introduction (1) Need Uniting Risk Professionals Worldwide Challeng e Perspecti ve Opportun ity 14-3-2016 Reason Effective financial risk management in the future. Learning from the past can be a solution for the future To identify the significant REC’s. Risk practitioners, it is their performance. To re-engineer the risk matrix and spread risk culture seamlessly integrating with the Business of the organization 34 Introduction (2) The research model and questions To what extent was financial risk performance To what extent was financial risk per related with financial risk valuation models/methods? related with risk control functions? The independent variables The risk environmental Financial factorsrisk valuation models Uniting and Risk methods Professionals Risk Worldwide control functions Risk-limiting strategies H0 1 H0 2 H0 3 The dependent variable Financial risk performance (Estimated financial risk) H0 Bonus culture 4 To what extent was financial risk perf related with risk-limiting strategies? To what extent was financial risk performance related with bonus culture? 14-3-2016 35 Conclusions Financial risk performance (FRP) was related with financial risk valuation models/methods. The beta of 0.331 is the extent of the relation Uniting Risk Professionals Worldwide FRP was related with risk control functions (highest significant predictor). The beta of 0.381 is the extent of the relation. FRP was not related with risk-limiting strategies. FRP was not related with bonus culture Overall risk management failed due to: 1) Underdeveloped financial risk valuation models/methods, 2) Poor performance of risk control functions The determinants of FRP are RISK DRIVERS 14-3-2016 related with the following 13 REC’s: Data, market variables, qualitative valuation methods, tail loss, stress test, and group-wide risk, system risk, solvability and integrity, strategic risk decision, dayto-day operational risk activities, and traders’ risk-36 awareness. Recommendations (1) Uniting Risk Professionals Worldwide Financial institutions must emphasize more on the risk drivers related with the (13) REC’s by ensuring proper governance around the risk drivers. Regulators must extend their control activities among the risk drivers related with the (13) REC’s to ensure that a proper governance is applied among FI’s Management of Risk Evaluation Controls holds the key 14-3-2016 © Soerinder Ramadhin 37 Uniting Risk Professionals Worldwide Thank You Hyderabad@prmia.org