Risk Management in Bank
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Risk Management in Bank...
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RISK MANGEMENT IN BANK
SHRI RAM
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RISK MANGEMENT IN BANK
TABLE OF CONTENTS SR NO
TOPICS
1
INTRODUTION
2
3
4
5
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OBJECTIVES OF RISK MANAGEMENT
APPROACHES TO RISK MANAGEMENT
TYPES OF RISKS
PROCESS OF RISK MANAGEMENT
6
HOW RISK IS MANAGED
7
ASSET-LIABILITY MANAGEMENT
8
THE NEW BASEL ACCORD
9
VALUE-AT-RISK
10
INTEREST RATE RISK IN BANKS
11
CONCLUSION
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CHAPTER: - 1 INTRODUTION Peter L Bernstein in his celebrated book, Against the Gods- the Remarkable Story of Risk” stated that “in the Dark Age risk was always associated with God” as the mankind progressed and business and markets grew the art of risk management grew from primitive stages to modern day rocket science. Risk is an inherent component of our life, be it in business or our personal life. The one who is able to manage it properly emerge the winner. In simple terms, risk can be defined as any uncertainty about a future event that threatens the organization‟s ability to accomplish its mission. Business is a trade off between risk and return. The word risk may have different meanings to different users. To a lay man, it has connotations that one invariably associates with the games of gambling or reckless behaviors in life. In contrast, to an information age company however, taking risk is one of the most important critical success factors as it encourages innovation. Innovation demand trying of new things, and trying something new again calls for uncertainty where one dose not know whether one will succeed or fall. Therefore, it is said to be taking a risk. To some others risk or risk-based functioning is a favorite hobby. Those who fall in this category are termed as speculators. Thus, though risk in an inherent feature to take it. Having briefly discussed the overview of what risk is all about, let us now turn our focus towards the definition of risk. WHAT IS RISK? Recalling our earlier statements we can say that risk means different things to different people. For some, it is “financial” (exchange rate, interest-call money rates) and for others, “an event or commitment which has the potential to generate commercial liability or damage to the brand image”. Since risk is accepted in business as a trade off between reward and threat, it does mean that taking risk brings froth benefits or well. In other words, it is necessary to accept risk, if the desire is to reap the anticipated benefits. Risk in its pragmatic definition of risk is very pertinent today as the current business environment offers both challenges and opportunity to organization, which have to mange them to their competitive advantage. Page 3
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RISK MANAGEMENT Risk management is a discipline that deals with the possibility that some future event will cause them. The proper management of risk provides strategies, techniques, and an approach to recognize and confront any threat faced by an organization that seeks to fulfills it‟s mission. It is to be always borne in mind that the process of risk management does not aim at risk elimination, out enable the organization to bring its risk to manageable proportions while not severely affecting their income. This balancing act between the risk level and the level of profits earned, needs to be well-planned. Apart from bringing the risk to manageable extent, it is also to be ensured that in risk dose not get transformed in to any other undesirable risk. This transformation takes place „due to the inter-linkage present among the various risks. The focal point in managing any risk is to understand the nature of the transaction so as to unbundle the risks that it is exposed to. It sharp contract to our country, the discipline of risk management is a more popular subject in the western world. This is largely a result of the lesson from major cooperate failures, a telling and visible example being the baring collapse. In additions, there has been the introduction of regulatory requirements that expect organizations to have effective risk management practices. In India, whilst risk management is still in its infancy, there has been considerable debate on the need to introduce comprehensive risk management practices. RISK MNANGEMENT IN BANK Indian banking industry is going through a transformation process in it‟s transformational journey from the era of protected economy to the though world of market economy. Banks are expanding their operations, entering new market and trading in new assets types. The change in financial system product and structures has created new opportunity along with new risk. Risk management has become internal part of financial activity of bank and other market participates. There risk can‟t be ignored and either has to be managed by market participates as part of assetsliability management or hedge. Under their circumstances, creating an environment that promotes risk management assumes critical importance. This requires addressing certain policy and institutional issues in developing in India.
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First and foremost a well developed market, repo market constitutes an important prerequisite for the promotion of risk management practice among market participants. Regulatory gaps and overlaps in debt markets need to be sorted out quickly to facilities the repeal of the 1669 notification which will go a long way in aiding the process of ALM for banks. Indian conditions are suitable for introduction of credit default swap in India. It offers advantages of hedging credit risk without impairing the relationship with the borrowers. Forward, rate agreements and interest rate swaps enables user to lock into spreads. Then RBI has already permitted interest rates swaps. A major reason for lack of term money market is the obscene of the practice of ALM system among bank for identifying mismatches in carols time periods. The recent RBI guidelines to lend on a term and also offer two way quotes in the market. The advisory group on banking supervision constituted by RBI recommended greater orientation of banks management OECD principal of corporate governed recognizes the risk management as area of increasing importance for board which is related to corporate strategy.
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CHAPTER: - 2 OBJECTIVES OF RISK MANAGEMENT While discussing the basic objectives of a risk management function, one comes across two schools of thoughts. One speaks about managing risks, maximizing profitability and creating opportunity out of risks and the other concerns with minimizing risks or the loss associated with the business operations and thus protecting corporate assets. The management of an organization needs to consciously decide whether or not it wants to pursue risk management function to „mange‟ or „reduce‟ risks. Managing risks essentially is about striking the right balance between risks and controls and taking informed management decisions on opportunities and threats facing an organization. Bothe theses situations, i.e. over or under controlling risk are not desirable as the former means higher costs and the latter means possible exposure to risk. The process of mitigating or minimizing risks, on the other hand, means mitigating or minimizing all risks even if may also mean that the opportunities are not adequately exploited. In the context of the risk management function, identification and management of risk is more prominent in the financial services sector and less so in the consumer products industry.
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CHAPTER: - 3 APPROACHES TO RISK MANAGEMENT After the different types of risks are identified, the next step involves identifying the alternate approaches available for managing/ reducing the risks. The various approaches are described below:
Avoidance: The concept of risk is relevant if the bank is holding an asset/liability which is exposed to risk. Avoidance refers to not holding such an asset/liability as a means of avoiding the risk. Exchange risk can be avoided by not holding assets/liabilities denominated in foreign currencies. Business risk is avoided by not doing the business itself. This method can be adopted more as an exception than as a rule since any business activity necessitates holding of assets and liabilities. This approach has application when a bank is planning to decide exposure limits. For example, a bank may decide to avoid a particular industry say, Aquaculture or Poultry, while extending credit or it many decide not to lend to certain type of bank in the money market.
Loss control: Loss control measure is used in case of the risks which are not avoided. These risks might have been assumed either voluntary or because they cannot be avoided. The objective of these measures either to prevent a loss or to reduce the probability of loss. Insurance, for example, is a loss control measure. Introduction of system and procedures, internal or external audit help in controlling the losses arising out of personnel. Raising funds through floating rate interest bearing instruments can reduce the losses due to interest rate risk.
Separation: the scope for loss by concentrating an asset as a single location can be reduced by distributing it to different locations, assets which are needed for routine consumption can be placed at multiple locations so that loss in case of any accident can be minimized. However, does simultaneously increase the number of risk centers. Consider tow banks, one which has a wide network across the country and another which is confined to one state. An adverse economic scenario of the set latter more than the
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former. This is more conspectuses when one compares a cooperative bank with a commercial bank.
Combination: This reflects the old adage of not putting all the eggs in one basket. The risk of default is less when the financial assets are distributed over a number of issuer intend of locking them with a single issuer. It pays to have multiple supplier of raw material intend of relying on a sole supplier. A well-diversified company has a lower risk of experiencing a recession.
Transfer: Risk reduction can be achieved by transfer. The transfer can be of three types. In the first type, the risk can be transferred by transferring the asset/liability itself. For instance, the risk emanating by holding a property or a foreign currency security can be eliminated by transferring the same to another. The second type of transfer involves by transferring the risk without transferring the asset/liability. The exchange risk involved in holing a foreign currency asset/liability can be transferred to another by entering into a forward contract/currency swap. Similarly, the interest rate risk can be involves making a third party pay for the losses without actually transferring the risk. An insurance policy covering the third party risk is an example.
When a bank takes a policy to cover the losses incurred on account of misuse of lost credit cards, it is in effect finding someone to finance the losses while it still has the obligation to pay the Merchant Establishment. Except for the approach of avoidance, the bank can effectively adopt other since by avoiding risk the bank will not be making any profits. From the above discussion on risk, it is now evident that banks can neither do without profits nor risk. However, mere acceptances of risk to remain profitable dose not an ultimate danger that the bank itself may fail. The question that arises at this point is what should the bank do in order to take risk for greater returns and at the same time not end up in losses? Risk management is the solution to such a situation.
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CHAPTER 4 TYPES OF RISKS As per the RESERVE BANK OF INDIA guidelines issued in October 1999, there are three major types of risks encountered by the banks and these CREDIT RISK, MARKET RISK AND OPERATIONAL RISK. In the article, we will see what the components of these three major risks are. In August 2001, a discussion paper on move towards Risk based Supervision was published. Further, in September 2001 a guidance note on Credit Risk Management was sent to all the banks. Recently in March 2002, a guidance note on Market Risk Management was also circulated to all the banks and this was followed by a discussion paper on Country Risk released in May 2002. Risk is the potentiality that both the expected and unexpected events may have as adverse impact on the bank‟s capital or earnings. The expected loss is to be borne by the borrower and hence is taken care of by adequately pricing the products through risk premium and reserves created out of the earnings. It is the amount expected to be lost due to changes in credit quality resulting in default. Whereas, the unexpected loss on account of the individual exposure and the whole portfolio in entirety is to be borne by the bank itself and hence is to be taken care of by the capital. Thus, the expected losses are covered by reserves and provisions and the unexpected losses require capital allocation. Hence, the need for sufficient Capital Adequacy Ratio is felt. Each type of risk is measured to determine both the expected and unexpected losses using VaR (Value at Risk) or worst-case type analytical model.
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Types of Financial Risks
Financial Risks
Market Risk
Credit Risk
Operational Risk
[I] CREDIT RISKS:Credit risk or default risk may be defined as the potential that a bank borrower or counterparty will fail no meet its obligations in accordance with the agreed terms. Sources of credit risk exist throughout the activities of the bank, these are: 1.
Loans, which are the largest and most important sources of credit risk. Loans and advances
constitute nearly 65% of the total assets of the scheduled commercial banks in India at the end of any normal financial year. 2.
Investment (in non-SLR instruments), including certificate of deposits, commercial paper,
equity shares of PSUs and private corporate sector, brands / debentures / preference shares issued by PSUs and private corporate sector etc. The exposure to such investments in respect of the scheduled commercial banks of India may be 7-9% of the total assets as at the end of March of any normal financial year. 3
Off balance sheet activities / items. These item are not booked on the balance sheets and are
of a contingent nature, and hence carry a definite element of risk although they generate a fee income for the banks, Indian banks are presently exposed to the off-balance sheet item such as foreign exchange contracts, guarantees, acceptance etc. These, put together, constitute 6-7% of the total assets in respect of the scheduled commercial bank in India at the end of the March of any normal year. With further liberalization, banks are taking up new types of off-balance sheet exposures such as future, swaps, options, etc. Page 10
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4.
The remaining 25 to 30% of demand and time liabilities of the banks in locked up by way of
cash. Reserve Ratio (CRR) or Statutory Liquidity Ratio (SLR). Credit risk is generally made up of transaction risk or default risk and portfolio risk. Transaction risk arises from individual credit transactions of the bank at a micro-level and is evaluated through technical, financial and economic analyses of individual borrowers‟ Project. Whereas, portfolio risk arises out of the total credit exposures of the bank at a micro-level. Portfolio risk may be intrinsic, e.g. a particular group or type of customers or industry may have a higher risk profile as compared to the other group or types. Portfolio risk may also arise out of undue concentration to credits to single borrowers or counterparties, a group of connected borrowers or counterparties, particular industries / sectors, borrowers in a particular geographic location, etc. In the event that a particular group or industry experiences downturn, the entire portfolio may turn into nonperforming assets, at least at that pointed time.
The Bank considers rating of a borrower account as an important tool to manage the credit risk associated with any borrower and accordingly a ‟two dimensional credit rating system‟ was introduced in the Bank. Software driven rating / scoring models for different segments have been customized to suit the Bank‟s requirements. Credit Rating 1. Obligor Rating Financial Parameters Managerial Parameters Industrial Parameters Operational Parameters 2. Facility Rating (Collateral Securities) AAA
Lowest Risk
AA
Lower risk Page 11
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A
Low Risk
BBB
Moderate risk – Entry Level
BB
High risk
B
Higher risk
C
Highest risk
D
Absolute risk
E
Caution risk
CHALLENGES IN CREDIT RISK MANAGEMENT (CRM) Bank in emerging markets like India, face intense challenges in managing Credit Risk, These may be determined by factors external to the bank, such as:
Delay in production schedules/production difficulties of borrowers
Frequent instability in the business environment
Wide swings in commodity/equity prices, foreign exchange rates and interest rates
Legal framework less conductive to debt recovery, hence time consuming
Financial restrictions
Government policies and controls
Economic sanctions
Natural disasters, etc. These may be further aggravated by internal factor/deficiencies in the management of Credit
risk within the bank like
Deficiencies in loan policies / administration
Lack of portfolio concentration limits
Excessive centralization or decentralization of lending authority
Deficiencies in appraisal of financial position of the borrowers/borrowed units
Poor industry analysis
Infrequent customer contact Page 12
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Inadequate post-sanction surveillance
Lack of articulated loan review mechanism
Failure to improve collateral position as credit portfolio deteriorates
Absence of stringent asset classification and loan loss provisioning standards
Inadequate checks and balances in the credit management process, and
Failure to control and audit the credit process effectively
These deficiencies may lead to weaknesses in the loan portfolio of the Bank, like over Concentration of loans in one industry or sector, large portfolios of non-performing loans and credit losses. These may, in turn, lead to cash crunch and ultimately insolvency. The fact that the bank operating in an economic environment that poses formidable challenges for good credit management gives all the more reason to them to strengthen their credit risk management practices and sharpen their credit management skills, both pre-sanction and post-sanction.
CREDIT RISK ENVIROMENT A fundamental prerequisite for credit risk management is establishment of an appropriate credit risk environment. Banks should have a clear cut perspective on credit risk strategy and evolve suitable policies and procedures to implement it. These should be effectively discussed across various levels and then communicated throughout the organization for implementation. All relevant personnel should clearly understand the bank‟s approach to granting credit and should comply with the established policies, practices and procedures, relating to pre-sanction appraisal and post-sanction follow-up.
Internationally, the responsibility for designing and implementing credit risk management system (viz, identifying, measuring, monitoring and controlling credit risk), is vested with the top management of the banks. The Basel committee document has recommended that:
The board of directors should have the responsibility for approving and periodically reviewing the credit risk strategy and significant credit risk policies of the bank, The strategy should reflect the bank‟s tolerance for risk and the level of profitability the bank expect to Page 13
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achieve by creating a loan assets mix the carries various credit risk, within the tolerance level fixed by the board.
Senior management should have the responsibility for implementing the credit risk strategy approved by the board and developing the policies and procedures for identifying, measuring, monitoring and controlling credit risk, such policies and procedures should address credit risk in all the bank‟s activities and at both individual credit and portfolio levels.
Bank should identify and manage credit risk inherent in all products and actives. New Products and activities should be subject to close watch and adequate procedures and Controls should be in place before they are introduced or launched.
CREDIT RISK STRATEGY A credit risk strategy or plan established the objectives for guiding the bank‟s credit-granting Activities and its credit risk management functions. The strategies or directives:
Typically provide general parameters for the types of credits that the bank will offer and the types of customers that the bank will serve, as dictated by current strategic decision. In a particular year, the bank may like to concentrate on infrastructure finance, or may like to expand in the retail finance segment. These strategies should be formulated by the credit policy and credit administration Division, and faithfully implemented after getting approval form the board of the Bank, Similarly loan-concentration levels in particular industries or market segments should carefully be regulated and kept under constant watch.
Due attention should be given to the goals of credit quality, earnings and growth.
Ensure continuity in approach. These will need to take into account the cyclical patterns of the industry and economy and the resultant shifts in the overall composition and quality of the credit portfolio. These strategies should be viable in the long-run, and these, in turn;
Should be effectively communicated throughout the organization and feedback obtained to ensure that the massage and concepts have correctly registered at levels down the line
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Credit Risk Management of ICICI Credit risk, the most significant risk faced by ICICI Bank, is managed by the Credit Risk Compliance & Audit Department (CRC & AD) which evaluates risk at the transaction level as well as in the portfolio context. The industry analysts of the department monitor all major sectors and evolve a sectoral outlook, which is an important input to the portfolio planning process. The department has done detailed studies on default patterns of loans and prediction of defaults in the Indian context. Risk-based pricing of loans has been introduced. The functions of this department include: Review of Credit Origination & Monitoring Credit rating of companies/structures Default risk & loan pricing Review of industry sectors Review of large exposures in industries/ corporate groups/ companies Ensure Monitoring and follow-up by building appropriate systems such as CAS Design appropriate credit processes, operating policies & procedures Portfolio monitoring Methodology to measure portfolio risk Credit Risk Information System (CRIS) Focused attention to structured financing deals Pricing, New Product Approval Policy, Monitoring Monitor adherence to credit policies of RBI During the year, the department has been instrumental in reorienting the credit processes, including delegation of powers and creation of suitable control points in the credit delivery process with the objective of improving customer response time and enhancing the effectiveness of the asset creation and monitoring activities. Availability of information on a real time basis is an important requisite for sound risk management. To aid its interaction with the strategic business units, and provide real time information on credit risk, the CRC & AD has implemented a sophisticated information system, Page 15
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namely the Credit Risk Information System. In addition, the CRC & AD has designed a webbased system to render information on various aspects of the credit portfolio of ICICI Bank. [II] MARKET RISK:-
Traditionally, credit risk management was the primary challenge for banks. With progressive deregulation, market risk arising adverse changes in market variables, such as interest rate, foreign exchange rate, equity price and commodity price has become relatively more important. Even a small change in market variables causes substantial changes in income and economic value of banks.
MARKET RISK may be defined as the possibility of loss to a bank caused by the changes in the market variables. It is the risk that the value of on/off-balance sheet positions will be adversely affected by movements in equity and interest rate markets, currency exchange rates and commodity prices. Market risk is the risk to the bank‟s earnings and capital due to changes in the market level of interest rates or prices of securities, foreign exchange and equities, as well as the volatilities of those prices. Market Risk management provides a comprehensive and dynamic framework for measuring, monitoring and managing liquidity, interest rate, foreign exchange and equity as well as commodity price risk of a bank that needs to be closely integrated with the banks business strategy.
Scenario analysis and stress testing is yet another tool used to asses areas of potential problems in a given portfolio. Identification of future changes in economic conditions likeECONOMIC / INDUSTRY OVERTURNS. MARKET RISK EVENTS. LIQUIDITY CONDITIONS.
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That could have unfavorable effect on banks portfolio is a condition precedent for carrying out stress testing. As the underlying assumption keeps changing from time to time, output of the test should be reviewed periodically.
Market risk arises out of the dynamics of market forces, which, for the banking industry, may include interest rate fluctuations, maturity mismatches, exchange rate fluctuations, market competition in terms of services and products, changing customer preferences and requirements resulting in product obsolescene, coupled with changes national and international politicoeconomic scenario. These risks are like perils of the sea, which can be caused by any changetaking place anywhere in the national and international arena.
Market risks affect banks in two ways:
i.
The customer requirements are changing because of the changing economics scenario. Hence banks have to fine-tune/modify their products to make them customer friendly, otherwise the obsolescence of products will divert the customers to other banks thereby reducing the business and profits of the bank concerned.
ii.
The macro-economic changes in the national and international politico-economic
scenario affect the risk element in different business activities differently. This aspect has assumed greater importance in the modern age, because of the increasing integration of global markets.
Since both these aspects are dynamic in nature, with change being the only constant factor, market risks need to be monitored on a continuous basis and appropriate strategies evolved to keep these risks within manageable limits. Again, given that one can manage only what one can measure, measurement of risks on a continuous basis deserves immediate attention.
Market risk can be defined as the risk of losses in on and off balance sheet positions arising from adverse movement of market variables.
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Market Risk Management
Management of market risk should be the major concern of top management of banks. The Boards should clearly articulate market risk management policies, procedures, prudential risk limits, review mechanisms and reporting and auditing systems. The policies should address the bank‟s exposure on a consolidated basis and clearly articulate the risk measurement systems that capture all material sources of market risk and assess the effects on the bank. The operating prudential limits and the accountability of the line management should also be clearly defined. The Asset-Liability Management Committee (ALCO) should function as the top operational unit for managing the balance sheet within the performance/risk parameters laid down by the Board. The banks should also set up an independent Middle Office to track the magnitude of market risk on a real time basis. The Middle Office should comprise of experts in market risk management, economists, statisticians and general bankers and may be functionally placed directly under the ALCO. The Middle Office should also be separated from Treasury Department and should not be involved in the day to day management / ALCO / Treasury about adherence to prudential / risk parameters and also aggregrate the total market risk exposures assumed by the bank at any point of time.
MARKET RISK TAKES THE FORM OF:-
1) Liquidity Risk 2) Commodity Price Risk and 3) Equity Price Risk
A concise definition of each of the above Market Risk factors and how they are managed is described below: LIQUIDITY RISK/MATURITY GAP RISK:-
Liquidity Planning is an important facet of risk management framework in banks. Liquidity is the ability to efficiently accommodate deposit and other liability decreases, as well as, fund loan portfolio growth and the possible funding of off-balance sheet claims. A bank has Page 18
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adequate liquidity when sufficient funds can be raised, either by increasing liabilities or converting assets, promptly and at a reasonable cost. It encompass the potential sale of liquid assets and borrowings from money, capital and forex markets. Thus, liquidity should be considered as a defence mechanism from losses on fire sale of assets.
Liquidity risk is the potential inability of a bank to meet its payment obligations in a timely and cost effective manner. It arises when the bank is unable to generate cash to cope with a decline in deposits/liabilities or increase in assets. The cash flows are placed in different time buckets based on future behavior of assets, liabilities and 0ff-balance sheet items. LIQUIDITY may be defined as the ability to meet commitments and/or undertake new transactions. The most obvious form of liquidity risk is the inability to honor desired withdrawals and commitments, that is, the risk of cash shortages when it is needed which arises due to maturity mismatch. BANKING can also be described as a business of maturity transformation. Usually banks, lend for a longer period than for which they borrow. Therefore, they generally have a mismatched balance sheet in so far as their short-term liabilities are greater than short-term assets and long-term assets are greater than long term liabilities. i. Liquidity risk is measured by preparing a maturity profile of assets and liabilities, which enables the management to form a judgment on liquidity mismatch. As the basic problem for a bank is to ascertain whether it will be able to meet maturing obligations on the date they fall due, it must prepare a projected cash-flow statement and estimate the probability of facing any liquidity crisis. Liquidity measurement is quite a difficult task and can be measured through stock or cash flow approaches. The key ratios, adopted across the banking system are: the other methods of measuring liquidity risk are:_
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To manage liquidity risk, banks should keep the maturity profile of liabilities compatible with those of assets. The behavioral maturity profile of various components of on/off balance sheet items is being analyzed and variance analysis is been undertaken regularly. Efforts are also being made by some banks to track the impact of repayment of loans and premature closure of deposits to estimate realistically the cash flow profile. Banks are closely monitoring the mismatches in the category of 1-14 days and 1528 days time bands and tolerance levels on mismatches are being fixed for various maturities, depending on asset-liability profile, stand deposit base nature of cash flows, etc. Liquidity Risk means, the bank is not in a position to make its repayments, withdrawal, and other commitments in time. For EXAMPLE two Canadian banks, Northland Bank and Continental Bank of Canada suffered a run on deposits because of a credit crisis at Canadian commercial bank. Liquidity risk consists of FUNDING RISK, TIME RISK, and CALL RISK. The liquidity risk in banks manifest in different dimensions:
Funding Risk – It is the need to replace net outflows due to unanticipated withdrawals/non-renewal of deposits (wholesale and retail)
Time Risk – It is the need to compensate for non-receipt of expected inflows of funds, i.e. performing assets turning into non-performing assets; and
Call Risk – It happens due to crystallization of contingent liabilities and unable to undertake profitable business opportunities when desirable.
EQUITY PRICE RISK:Equity Price Risk is the risk of loss in value of the bank‟s equity investments and/or equity derivative instruments arising out of change in equity prices. Page 20
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COMMODITY PRICE RISK:The risk of loss in value of commodity held/traded by the bank, arising out of changes in prices, basis mismatch, forward price etc. [III] OPERATIONAL RISK:“Operational Risk is defined as the risk of direct or indirect loss resulting from inadequate or failed internal processes, people and system or from external events.” Generally, operational risk is defined as any risk, which is not categorized as market or credit risk, or the risk of loss arising from various types of human or technical error. It is also synonymous with settlement or payments risk and business interruption, administrative and legal risks. Operational risk has some form of link between credit and market risks. An operational problem with a business transaction could trigger a credit or market risk. Indeed, so significant has operational risk become that the bank for International Settlement (BIS) has proposed that, as of 2006, banks should be made to carry a Capital cushion against losses from this risk.
Managing operational risk is becoming an important feature of sound risk management practices in modern financial markets in the wake of phenomenal increase in the volume of transactions, high degree of structural changes and complex support systems. The most important type of operational risk involves breakdowns in internal controls and corporate governance. Such breakdowns can lead to financial loss through error, fraud, or failure to perform in a timely manner or cause the interest of the bank to be compromised. The objectives of Operational Risk Management is to reduce the expected operational losses that focuses on systematic removal of operational risk sources and uses a set of key risk indicators to measure and control risk on continuous basis. The ultimate objective of operational risk management is to enhance the shareholder‟s value by being ready for risk based capital allocation.
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There is no uniformity of approach in measurement of Operational Risk in the banking system at present The bank‟s operational risks can be classified into following six exposure classes
People
Process
Management
System
Business and
External
Bank has also identified 5 business lines viz…..
Corporate finance
Retail banking
Commercial banking
Payment and Settlement and
Trading and Sales (Treasury operations) also To each of this exposure classes within each business line are attached certain risk
categories under which the bank can incur losses or potential losses. Bank collected information at first instance for a 5 year period and is being updated on a six monthly basis June and December. These date help in qualifying the overall potential / actual loss on account of Operational Risk and initiate measure for plugging these risk areas. Bank may suitably at a latter date move to appropriate models for measuring and managing Operational Risk also after receipt of RBIs Guidance Note. MEASUREMENT There is no uniformity of approach in measurement of operational risk in the banking system. Besides, the existing methods are relatively simple and experimental, although some of the international banks have made considerable progress in developing more advanced techniques for allocating capital with regard to operational risk.
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Measuring operational risk requires both estimating the probability of an operational loss event and the potential size of the loss. It relies on risk factor that provides some indication of the likelihood of an operational loss event occurring. The process of operational risk assessment needs to address the likelihood (or frequency) of a particular operational risk occurring, the magnitude (or severity) of the effect of the operational risk on business objectives and the options available to manage and initiate actions to reduce/mitigate operational risk. The set of risk factors that measure risk in each business unit such as audit ratings, operational data such as volume, turnover and complexity and data on quality of operations such as error rate or measure of business risks such as revenue volatility, could be related to historical loss experience. Banks can also use different analytical or judgmental techniques to arrive at an overall operational risk level. Some of the international banks have already developed operational risk rating matrix, similar to bond credit rating. The operational risk assessment should be bank-wide basis and it should be reviewed at regular intervals. Banks, over a period, should develop internal systems to evaluate the risk profile and assign economic capital within the RAROC framework….. Indian Banks have so far not evolved any scientific methods for quantifying operational risk. In the absence any sophisticated models, banks could evolve simple benchmark based on an aggregate measure of business activity such as gross revenue, fee income, operating costs, managed assets or total assets adjusted for off-balance sheet exposures or a combination of these variables. At present, scientific measurement of operational risk has not been evolved. Hence, 20% charge on the Capital Funds is earmarked for operational risk. Operational Risk Management of ICICI ICICI Bank, like all large banks, is exposed to many types of operational risks. These include potential losses caused by events such as breakdown in information, communication, transaction processing and settlement systems/ procedures. The Audit Department, an integral part of the Risk Compliance & Audit Group, focuses on the operational risks within the organization. In recent times, there has been a shift in the audit focus from transactions to controls. Some examples of this paradigm shift are: Page 23
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Adherence to internal policies, procedures and documented processes Risk Based Audit Plan Widening of Treasury operations audit coverage Use of Computer Assisted Audit Techniques (CAATs) Information Systems Audit Plans to develop/ buy software to capture the workflow of the Audit Department The Audit Department conceptualized and put into operation a Risk Based Audit Plan during the year 1998-99. The Risk Based Audit Plan envisages allocation of audit resources in accordance with the risk constituents of ICICI Bank‟s business.
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CHAPTER: - 5 PROCESS OF RISK MANAGEMENT At the outset it is to be noted that risk management does not aim at risk reduction. Risk management enables the banks to bring their risk level to manageable proportions while not severely reducing their income. Thus, risk management enables the bank to take required level of exposures in order to meet its profit targets. This balancing act between the risk levels and profits need to be well-planned. Risk management basically is a five-step process which involves: (Draw a diagram) A. IDENTIFICATION OF RISK: Risk can be anything that can hinder the from meeting its targeted results. Each risk must be defined precisely in order to facilitate the identification of the same by the banking organizations. This will also enable the banks to have a fundamental understanding of the activities from which risks originate. This understanding will be essential to evaluate aspects related to the magnitude of the risks, the tenor and the implications they have on the accounting aspects. Unless the bank identifies and understand the nature of exposures involved in a transaction, it will not be able to manage them. Further, such unbundling also helps to bank in deciding which risk it will have to manage and which it would prefer to eliminate. The process of unbundling also helps a bank in pricing the risk. B. QUANTIFICATIN OF RISKS: by measuring the risk, the bank is indirectly quantifying the consequences of the decision taken. If risks are not quantified, the bank will neither be aware of the consequences of its decision nor will it be in a position to manage the risks. Thus, all risks to which the bank is exposed need to be quantified. Quantification of risks is a crucial task and accurate measurement of the same depends extensively on the information available. The quality of information coming from various branches, however, depends on the reporting system. The information provided needs to be further evaluated to ensure that there is an effective and ongoing flow of information. Technology and MIS pay a crucial role here. C. POLICY FORMATION: The next step will be developing a policy that gives the standard level of exposures that the bank will have to maintain in order to protect cash Page 25
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flows. Policy is a long-term framework to tackle risk and hence the frequency of changes taking place in it is very low. Setting policies for risk management will depend on the bank‟s objectives and its risk tolerance levels. The risk levels set by the bank neither should neither be too high that goes beyond the bank‟s capacity to manage it nor should it be too low that the profitability is affected. The bank should decide on a particular risk exposure level only if it aids in achieving the bank‟s objectives and also if it believe s that it has the capacity to manage the risk for a gain. If either of the conditions is not met, the bank will have to try and eliminate/minimize the risk. D. STRATEGY FORMULATION: A strategy is that which is developed to implement a policy. Clearly, a strategy will then be relatively for a shorter period. Given the exposure and volatilities, a strategy helps in managing these risks. Firstly, the possible options and the risks attached to them are examined in order to known the affect on each option on the cash flows and the earnings. With this information, a strategy will be developed to identify the sources of losses/gains and how efficiently the risks can be shifted to enhance profits while reducing the exposure. Strategy differ widely depending on the nature of exposure , the type of transaction, etc. and will also state the instruments that are to be used to manage exposure, tenors and counterparties. E. MONITERING RISK: laying down strategy will not less to risk management since risk profile cannot be static. Volatile circumstance may change the risk level of the investment and hence require the banks to restore the same to the set targets levels. For instance, the bank takes a long position on a loan of US $1mn. At an exchange rate so Rs.43.50, the risk which the bank is ready to take is up to Rs.0.10 variation. In absolute terms this will be Rs. 1 lakh. However, the exchange rate goes down by Rs. 0.15 due to which the loss to the bank is Rs. 1.5 lakh. This is beyond the target set by the bank. In such circumstances, the bank can take a long position in US $ if it believes that the rate will move up. And in case the rates are expected to go down further, it can either enter into a forward contract or exit from the long position taking up the loss. In either case the bank needs to have a view about the market regarding its future behavior. While this is the general process for managing any type of risk, by any business firm, for a bank, the risk management process primarily involves Asset-Liability Management (ALM). ALM is discussed elaborately in subsequent chapters. Page 26
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CHAPTER: - 6 HOW RISK IS MANAGED An independent Risk Management department is functioning for effective risk management enterprise wide. Risk is managed through following three Apex committees viz., (i) Credit Risk Management Committee (CRMC) (ii) Asset and Liability Management Committee (ALMC) and (iii) Operational Risk Management Committee (ORMC) These committees work within the overall guidelines and policies approved by the Risk Management Committee of the Board. The Bank has put in place various policies to manage the risk. To analyze the risk enterprise wide and with the objective of integrating all the risks of the Bank Integrated Risk Management Policy has also been put in place. The important risk policies comprise of Credit Risk Policy, Asset and Liability Management Policy, Operational Risk, Management Policy, Business Continuity Planning, Whistle Blower Policy and Policy on Corporate Governance. The risk management systems are in place to identify and analyze the risks at the early stage, set and maintain prudential limits and manage them to face the changing risk environment. Software driven rating mechanism is in place to confirm the rating to ensure credit quality. An entry level scoring system is also put in place. Loan Review Management Committee reviews the Loan Review Mechanism and Credit Audit functions periodically. In addition, Standard Assets Monitoring Committee reviews the Special Mention Accounts to initiate timely action to prevent slippage of standard assets to non-performing assets. The liquidity risk is managed through studying structural liquidity on a daily basis, which is being discussed in the Funds and Investments Committee and reviewed every month by ALMC .The interest rate risk is managed through monthly interest rate sensitivity statements monitored by ALMC. The mid offi ce, directly reporting to
Risk Management Department, monitors treasury transactions
independently.
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Operational risk is managed by integrating the operational risk management systems into day to day management processes and adopting various risk mitigating strategies. The risk perception in various products / procedures is critically analyzed. Stress tests are conducted periodically for the credit risk, liquidity risk and interest rate/exchange rate risk. Policy on Internal Capital Adequacy Assessment Process (ICAAP) is put in place whereby the Bank identifies/measures and allocates Capital for various residual risks identified under Pillar II on quarterly basis and is reviewed by the Board half yearly. The CRAR position of the Bank is reviewed by the Board on a half yearly basis and assessment for the next three years is also provided based on projected business position. In compliance with the Reserve Bank of India guidelines on Basel II – Pillar 3 – Market Discipline, the Bank has put in place a Disclosure Policy duly approved by the Board and the disclosures on Quarterly / Half-yearly / Annual basis as per the policy are made in the Bank‟s Website / Annual Report.
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CHAPTER: - 7 ASSET-LIABILITY MANAGEMENT Asset-liability management (ALM) is concerned with strategic b balance sheet management involving risks caused by changes in the interest rates, exchange rates and the liquidity position of the bank. While managing these risks forms the crux of ALM, credit risk and contingency risk also form a part of the ALM. The significance of ALM to the financial sector is further highlighted due to the dramatic changes that have occurred in recent years in the assets (use of funds) and liabilities (sources of funds) of banks. In India, the post-liberalization witnessed a rapid industrial growth, which has further stimulated the growth in the fund rising activates. With the rise in the demand for funds there has also been a remarkable shift in the futures of the sources and uses of funds of banks. Traditionally administrated rates were used to price the assets and liabilities of banks. However in the deregulated rates were used to price the assets and liabilities of banks. This led to discriminate pricing policy, and also highlighted the need to match the maturities of the assets and liabilities. The changes in the profile of the sources and uses of funds are reflected in the borrowers‟ profile, in the interest rate structure for deposits and advance etc. the developments that took places since liberalization led to a remarkable transition in the risk profile of the financial intermediaries led. The main reasons for the growing significance of ALM are:
Volatility
Products innovations
Regulatory environment
Management recognition
VOLATILITY: An increasing number of free economics are being witnessed in recent times with more and more nation globalizing their operations. Closely regulated markets are paving way of market-driven economics. Such deregulation has changed the dynamics of the financial markets. The vagaries of such free economic environment are reflected in the market, the exchanged rates and price levels. For a business which involves trading in money, rate fluctuations invariably affect the market value yields/costs of the assets/liabilities which further affect the market value of bank and it‟s Page 29
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Net Interest Income (NIL). Tacking this situation would have been a very easy task, in a set-up where the interest rate movements are known with accuracy and where the volatility in the exchange rates is considerably lower.
PRODUCT INNOVATION: The second reason for the growing importance of ALM is the rapid innovations taking place in the financial product of the bank. While some innovations came as passing fads, other has received tremendous response. In several cases, the same product has been repackaged with certain differences and offered by various banks. Whatever maybe the features of the products, most of them have an impact on the risk profile of the banks thereby enhancing the near for ALM. Consider the flexi-deposit facility banks are now offering for their term deposits.
Earlier, if a
depositor, who has a term deposit of Rs.1 Lake, was in need of funds, say rs.25, 000, before the date of maturity of the term deposit, then the depositor would go for a premature withdrawal of the term deposit of raise a loan. In order to discourage this, banks charge a penalty on the entire amount for premature withdrawal. This served as a disincentive for premature withdrawals and also reduced the risk for the bank. This enables the investor to withdraw the required amount before maturity since the burden of penalty is limited. However it will also enhance the risk of the bank. With a reduction in the penalty amount, the depositor would make a demand for the premature withdrawal at any time. To reduce the impact of the assets-liability mismatch that arise due to this early withdrawal of funds, the bank will have to raise a liability risk when there is sudden outflow of funds as well s interest rate risk since it may have to raise a liability at a higher cost.
REGULATORY ENVIRONMENT: In order to enable the banks to cope with the changing environment that has resulted due to the integration of the domestic markets with the international markets, the regulatory bodies of various financial markets have initiated a number of measures. These measures were taken with an objective to prevent major losses that may arise due to market vagaries one step in this direction was the increased focus on the management of the bank assets and liability. The RBI is also following this direction and has recently issued a framework for banks to develop ALM Page 30
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policies. In addition to this, there are various guidelines issued by the regular on the risk based capital to be maintained by the banks in order to tackle the credit risk.
MANAGEMENT RECOGNITION: All the above mentioned aspect forced the managements of the banks to give a serious thought about the management of the asset and liability. Managements have realized that it is just not sufficient to have very good retail deposits base. In addition to these, the banks should be in a position to relate and link the asset side with liability side. And this calls for efficient asset-liability management.
There is increasing awareness in the top management that banking is now a afferent game altogether because all the rules of the game have since been changed. PURPOSE OF ALM This enhanced level of importance to the ALM has led to a change in the nature of its functions. It is no longer a stand-alone analytical function. While there are macro- and microlevel objectives of ALM, it is however the micro-level objectives that hold the key for attaining the macro-level objectives. At the macro-level, ALM leads to the formulation of critical business policies. Efficient allocation of the capital and designing of product with appropriate pricing strategies. And at the macro-level, the objective function of the ALM is two-fold. They aim at profitability through price-matching whole ensuring liquidity by means of maturity matching. Price-matching basically aims to maintain speeds by ensuring that the deployment of liabilities will be at the rate higher than the cost. Similarly, liquidity is ensured by groping the assets/liabilities based on their maturing profiles. The gap is then assessed to identify the future financing requirement. This ensures liquidity. However, maintaining profitability by matching prices and ensuring liquidity by matching the maturity levels is not an easy task. ` MACRO- AND MICRO-LEVEL ALM Management of risks should be at two levels: macro-level and micro-level. The macrolevel risk management will involve providing a risk management framework for the bank and hence the decision makers will clearly comprise the bank‟s board and the top management. On the other hand, at the micro-level business decision taken by the business managers, but within
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the board framework laid at the macro-level. Consider the following illustration that distinguishes between the macro- and micro-level decisions for ALM:
Term loan for an aqua firm;
Investment in 10-year government paper;
Investment in the commercial paper issue of a company;
Acceptance of FCNR (B) deposit
At the macro-level the bank will have to decide on
Whether or not to land to the aquaculture industry and in case it decides to lend, then exposure level for lending;
Whether or not invest in a government paper/other securities having maturity, of say over 5 years and the limit that can be set for such investment;
Whether or not to invest in the CPs issued by a company having a rating of less than P1+; and
Lastly whether to accept FCNR (B) deposits and the limit for such acceptance.
Thus at the macro-level, broad guidelines will be given in order to enable day-to-day decision to be taken relating to individual proposals for investment and borrowing without the involvement of the top management. The board should clearly communicate to the business managers the acceptable level of risks in terms of parameters chosen. This macrolevel management of risk will be conducted by the Asset-Liability management committee (ALCO). ALSO shall not consider individual cases for decision –making. In the above instances, if the ALSO decides that the bank shall not extend any loan facility to aqua projects, shall not invest in securities having maturity greater than 5 years and in CPs of firms having a credit rating of less than P1+and shall not accept any FCNR (B) deposits, then the business managers should take decisions within this framework. Interest rate views of the bank and base its decision for future business strategy on this view. In respect of the funding policy, for instance, its responsibility would be to decide on source and mix of liability or sale of assets. Towards this end, it will have to develop a view on further direction of interest rate movements vs. retail deposits‟, money market vs. capital Page 32
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market funding, domestic vs. foreign currency funding etc. individual banks will have to decide the frequency for holding their ALSO meetings
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CHAPTER: - 8 THE NEW BASEL ACCORD Effective risk management strategies can be implemented by integrating effective bank level management, operational supervision and market discipline. It is also imperative for financial institutions to update their risk management practices in accordance with prevalent legislation and regulatory environment. With these aspects in mind, the Basel committee on Banking Supervision published the Capital Adequacy Accord, also known as the Basel Accord, in 1988. The Basel Accord defined the parameters of risk management and capital adequacy for Financial Service Providers (FSPs). With the growth in financial service sector, the committee felt the need to update the Accord in line with new developments. As a result, it proposed the New Basel Capital Accord, also known as Basel II, in June 1999. With its new risk-sensitive framework, Basel II aims to fill the gap left by the p[pervious Accord. Basel II was devised to improve the soundness of the financial system by aligning regulatory capital requirement to the underlying risks of the banking industry. It encourages banks to conduct better risk management and enhance market discipline. According to the committee, financial institutions should integrate Basel II in their operations by the year-end 2006. Efficient risk management, as outlined by Basel II, can be ensured by leveraging information technology. A Basel II implementation allows banker to adequately emphasize their own internal risk management methodologies. Bankers can also provide more incentive and options for risk management, thereby increasing flexibility of their systems. In addition to this, Basel II provides a variety of benefits to the banking system. These include enhanced risk management, efficient operations, and higher revenues to the banking community. Along with the increased benefits, Basel II has also laid down some control on the international banking system. This is primarily in the form of a higher capital requirement to underwrite management of risk and lace of infrastructural controls in many economies. The global acceptance for Basel II is not far and most banks across the world will soon come under the preview of this Accord Comparing the new Accord with the existing one. Page 34
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Existing Accord 1. Focus on single risk.
New Accord 1.
More emphasis on banks measure own internal
methodology,
supervisory
review
and
market
discipline. 2. One size fits all.
2. Flexibility, menu of approaches, incentive for better risk management.
3. Board brush structure.
3. More risk sensitivity.
After a series of revisions, Basel II has been finalized. A major part of it will be applicable by the end of 2006. During this intervening period, bank and supervisors must develop the necessary systems and processes to comply with the standards laid down by Basel II. For instance, financial institutions have to maintain a history of vital data sets built prior to the implementation date of Basel II. This will help them seamlessly “migrate” to Basel II. In addition, many countries have already started work on draft rules that would integrate Basel capital standards with their national capital regimes. The Basel II Accord aims to ensure effective risk management and security systems in the financial sector. It has undergone rigorous revisions before its framework has been finally frozen for implementation. THE BASEL II FRAMEWORK Basel II intends to provide more risk-sensitive approaches while maintaining the overall level of regulatory capital within the financial system. This can be achieved through its meticulously designed framework that consists of three mutually reinforcing pillars as summarized in below figure .1 Figure 1: The Three Pillar Architecture as defined by Basel II PILLAR
FOCUS AREA
First Pillar
Minimum Capital Requirements
Second Pillar
Supervisory Review Process
Third Pillar
Market Discipline
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PILLAR 1 MINIMUM CAPITAL REQUIREMENTS The first pillar is designed to help cover risks within a financial institution. It aims to set minimum capital requirements and defines the current amount of capital. The pillar also stress on defining the capital amount by qualifying risks such as Credit Risk, Operation Risk and Market Risk. MEASURING CREDIT RISK Credit Risk defines the minimum capital required to cover exposure to customers and counter parties. The Basel II framework provides a menu of approaches in respect of credit risk. They are: I. II.
Standard approach, Internal rating based(IRB) approach a. Foundation b. Advanced
I.
STANDARDIZED APPROACH: In this approach, the bank allocates a risk- weight to each of its assets and off-balance sheet positions. It then calculates a sum of risk-weighted asset values. A risk weight of 100% indicates that an exposure is included in calculation of assets at full value. The capital charge is equal to 8% of the assets value this approach, while remaining essentially the same as in the earlier Accord, however, includes a higher sensitivity to risk. As per the earlier Accord, individual risk weight was dependent on the category of borrowers such as sovereign nations or banks. In Basel II however, these weight can be defined by referring to a rating provided by an external credit assessment agency
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II.
INTERNAL RATING BASED APPROACH (IRB): In this approach, bank use their internal evaluation systems to assess a borrower‟s credit risk. The results, attained by this process, are translated into estimates of a potential future loss, thereby defining the basis of minimum capital requirements. The IRB approach supports the following methodologies for cooperate, sovereign and bank exposures:
FOUNDATION- Using this methodology, bank can estimate the risk of default or the Probability of Default (PD) associated with each borrowers. Additional risk factor such as Loss Given Default (LGD) and Exposure at Defaults (EAD) are standardized by supervisory rules that are laid down and monitored by regularizing authorities.
ADVANCED- This mythology allows banks with sufficient internal capital to assess additional risk factors. These factors include Exposure as Default (EAD), Loss given Default (LGD) and Maturity (M). It also allows bank to provide guarantees and credit derivatives on the risk of exposure. The ranges of risk in both these methodologies are more diverse than in standardized approach, resulting in greater risk sensitivity. MEASURING OPERATIONAL RISK In Basel II, the operational risk can be measured using the following three approaches: 1. BASIC INDICATOR APPROACH- This is a traditional approach, which links the capital charge for operational risk to a single operational parameters, such as percentage of this parameter, defined as the „Alpha Factor‟.
2. STANDARDIZED APPROACH- This approach is a variant of the Basic Indicator Approach. Here, the activities of a bank are divided into Page 37
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standard industry business lines, such as corporate banking, trade finance and many more. These business lines are then mapped by bank into their internal framework. A percentage of capital charge, knows as the „Beta Factor‟, is defined for each business line. The bank can calculate its capital charge for a business line by applying the Beta Factor to the indicator value for the business line. The total capital charge for the bank is calculated as the sum total of all capital charges for individual business lines.
3. INTERNAL MEASUREMENT APPROACH(IM)- this is the most sophisticated of all the approaches. Here, risk is measured using the bank‟s internal loss data. Typically, a bank collects data inputs for a specified set of business lines and risk types. These inputs include an operational risk indictor, data indicating the probability of a loss event, and the losses in case these events take place.
MEASUREING MARKET RISKS Market Risk determines the capital required to cover exposure to changes in market conditions- such as flections in interest rates, foreign exchange rates, equity prices, and commodity prices. The approaches to determine market risk are the same as those defined in earlier Accord BENEFITS OF THE FIRST PILLAR The first pillar aims to refine the measurement the framework set out in the1988 Accord by effectively reducing risk across the banking system. Different reporting system, which comply with objectives set by this pillar, will help track and report risk as they occur, thus eliminating them at the outset. It will be allow banks to set-up independent audit functions to scrutinize the possibilities of risks. The minimum capital requirement is expected to be reducing considerably for bank and other financial institutions. Furthermore, bank will support a complete alignment of regulatory, book and economic capital. Page 38
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PILLAR 2 SUPERVISORY AND REVIEW PROCESS The second pillar of Basel II intends to ensure the presence of sound processes at each bank. This pillar would also provided framework to assess the adequacy of the bank‟s capital, based on a thorough evaluation of its risks. The Basel II framework emphasizes the development of an internal capital assessment process by the bank management. Additionally, management should set targets for capital corresponding with the bank‟ risk profile and control environment. Regulatory and supervisory bodies (either the Central Bank or bodies set by the Central Bank or government, for regulation and control) will review the internal process. This is done so that an assessment of the bank‟s capital adequacy in reaction to its risk can be made. A point to note is that compliance with internal measurement methodologies, mitigation policies of credit risk, and securitization policies for minimum qualifying standards are subject to supervisory control. The supervisory authority will also be responsible for reviewing operations and processes in trading, Internet banking and security processing. BENEFITS OF THE SECOND PILLAR The implementation of the second pillar demand increased interaction between bank mangers and supervisory bodies. This increased level of interaction enhances the level of transparency within the organization. The second pillar helps achieve a higher level of security within the organization. A level of standardization and conformity is established across the enterprise. This in turn would help achieve higher returns with lower risk. PILLAR 3 MARKET DISCIPLINE The third pillar of the new framework attempt to boost market discipline through enhanced disclosure by bank. Basel II identifies the disclosure requirement and provides recommendation both on the defining method of calculating capital adequacy, and risk management strategies. Effective disclosures by bank help market participants understand the bank‟s risk profile and adequacy of its capital position, thereby facilitating market discipline. This strategy plays an important role in maintaining the confidence in a financial institution. Page 39
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A guidance paper presented in January 2000 has six board recommendations related to capital, risk exposure and capital adequacy. Based on these recommendations, the committee has laid down more specific quantitative and qualitative disclosure in key areas. These include the scope of application, composition of capital, risk exposure assessment and management processes, and capital adequacy. In general, it provides enhanced disclosure on risk and capital adequacy. BENEFITS OF THE THIRD PILLAR The third pillar of the Basel II framework helps to increase awareness of all the risk in the banking sector through a process of detailed disclosure. It also helps align economic capital data to book and risk capital data. Further, this pillar reveals the annual losses incurred by business lines and asset classes. This helps increase transparency. ORGANIZATIONS AFFECTED BY BASEL II All banks and financial institutions in the G10 countries intend to incorporate the Basel II Accord through local regulators. A high possibility of the earlier accord being replaced by Basel II in the other countries also exists. The European Union is the first adopter of this accord, and the recommendations of this accord are being integrated in to a new EU directive. In addition, the European Commission intends to apply this accord to all investments, businesses and credit institutions. The accord‟s adoption `in other continents like Australia, Asia and in North and South America would be phased. It would primarily depend on proposals submitted by the regulatory authorities on implementation of the accord. The accord‟s scope of application will include banks and enterprises involved in securitization and with long-term equity holding such as private equity and venture capital. It will also apply to the patent and subsidiary companies of banking group. Basel II will be applicable to organizations offering the following financial services:
Corporate finance,
Retail banking,
Asset management,
Trading and sales, Page 40
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Payments and settlements,
Commercial banking,
Retail brokerage,
Agency and custodial services.
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CHAPTER: - 9 VALUE-AT-RISK Value-at- Risk (VaR) is a category of risk measure that describes probabilistically the market risk of a trading portfolio. VaR is widely used by banks, securities firms, commodity and energy merchants, and other trading organizations. Such firm could track their portfolios‟ market risk by using historical volatility as a risk metric; calculate their portfolio‟s market value. For managing risk, institutions must know about risks while they are being taken. If a trader misjudges a portfolio, his employer needs to find it out it before a loss is incurred. VaR gives institutions the ability to do so. Unlike retrospective risk metrics, such a historical volatility, VaR is prospective. It qualitifies risk while it is being taken. Muck of the debate in recent times within banks focuses on the application of so called Value-atRisk (VaR) models. These models are designed to estimate, for a given trading portfolio, the maximum amount that a bank could lose over a specific time period with a given probability. In this way, they provide a summary measure of the risk exposure generated by a given portfolio. Though the VaR model can be developed to varying degrees of complexity, the simplest approach takes as its starting point the estimates of the sensitivity of each of the components of a portfolio to small price changes (for example, a one basis point change in interest rates or a one percent change in exchange rates). It then assumes that market price movements follow a particular statistical distribution (usually the normal or log-normal distribution). This simplifies the analysis by enabling a risk manger to use statistical theory to drawn inferences about potential losses with a given degree of statistical confidence. For example, on a given portfolio it might be possible to show that there is a 99% probability that a loss over any one week period will not exceed Rs. 1 million. Elaborations to basic VaR model can allow for correlation between different components of a portfolio by modeling the extent to which prices in different markets tend to move together; in this way, the method takes in to account possible effect of portfolio diversification. Still further elaborations permit the measurement of more difficult aspects of risk such as the liquidity of the instrument making up the portfolio. This might not be the case, however, for that part of the portfolio comprising relatively poorly traded securities. Standard VaR method takes no direct account of this although it can be indirectly taken into account by
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the choice of the portfolio holding period. The more illiquid the portfolio, the longer the holding period that should be applied and the more susceptible it will be to price changes. VaR method has a number of shortcomings in dealing with large price movements. It is recognized that the models do not address all types of risks, well, for example, risk associated with options where the number of extreme observations are at the tails of the distributions than is implied by the statistical theory of normal distributions. Further on average, the risk estimate based on a 95% confidence interval will be exceeded once every 20 trading days. Using a 99% confidence interval will be exceeded once every 20 trading days. Using a 99% confidence interval reduces the uncertainty but still suggests that estimates of risk will be exceeded on an average 2 or 3 times a year (assuming a normal distribution).Given below is schematic representation of how VaR measures work:
Take diagram from http://www.riskglossary.com/articles/linear_transfomation.htm
All practical VaR measures accept portfolio data and historical market data a inputs. They process these with a mapping procedure, inference procedure, and transformation procedure. Output comprises the value of a VaR metric. That value is the VaR measurement. Value-at-Risk (VaR), though is a powerful tool for assessing market risk, it must be remembered that, sometimes, it also poses a challenge. The power of VaR power is its generality. Unlike market risk metrics, which are applicable to only certain asset categories or certain sources of market risk, VaR is general. It is based on the probability distribution for a portfolio‟s market value. All liquid assets have uncertain market values, which can be characterized with probability distributions. All sources of market risk contribute to those probability distributions. Being applicable to all liquid assets and encompassing, at least in theory, all sources of market risk, VaR is an all-encompassing measure of market risk. As with its power, the challenge of VaR also stems from its generality. In order to measure market risk in a portfolio using VaR, some means must be found for determining the probability distribution of that portfolio‟s market value. Obviously, the more complex a portfolio is i.e., the more asset categories and sources of market risk it is exposed to the more challenging becomes task. Page 43
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CHATER: - 10 INTEREST RATE RISK IN BANKS The regulatory restriction on bank had greatly reduced many of the risks in the banking system. The deposit were taken in at mandatory rates and loaned out at legally established rates. Interest rate, therefore, remained unaffected by market pressures. The deregulation of the financial system in India has put in place a lot of operational freedom to the financial institution and the pricing of a major portion of assets and liabilities has been left to their commercial judgment. The earning of assets and the cost of liabilities are therefore closely related to interest rate volatility. Thus, on account of deregulation of interest rate, interest rate risk, a term totally unknown to the banking industry in India has suddenly becomes relevant. The bank have already identified interest rate risk sa a drag on their profitability and have started assessing the magnitude of interest rate risk embedded in their balance sheet. Interest rate risk is the exposure of a bank‟s financial condition to adverse movement in interest rate. In other words, interest rate risk refers to potential impact on Net Interest Income or Net interest margin or market Value of equity(MVE) caused by unexpected changes in interest rate. SOURCES OF INTEREST RATE RISK Military planner have a well-know saying :”knowing the nature of the enemy is winning half the battle“. Similarly, understanding the nature of interest rate risk is critical for its successful management. A proper analysis of the nature of interest rate risk helps in assessing its potential financial impact and evaluating the right management techniques. The following are the seven dimensions of the interest rate risk: 1. Gap or Mismatch or Reprising risk 2. Basis risk 3. Net Interest Position Risk 4. Yield curve risk 5. Embedded Option Risk 6. Price risk Page 44
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7. Reinvestment Risk
(1) GAPOR MISMATCH OR REPRICING RISK A Gap or Mismatch risk arise from holding assets and liabilities with different principal amount, maturity or reprising date, thereby creating exposure to unexpected changes in the level of interest rate. The gap is the difference between the amount of assets and liabilities on which the interest rate are reset or reprised during a given period. In other words, when assets and liabilities fall due for repricing in different periods that can create a mismatch. Such a mismatch or gap may lead to gain or loss depending upon how interest rate in the market tends to move.
(2) BASIS RISK In a perfectly matched gap position, there is no timing difference between the repricing dates and the magnitude of change in the deposit rates would be exactly matched by the magnitude of change in the loan rate. However, interest rate of two different instruments will seldom change by the same degree during a given period of time. The risk that the interest rate of the different assets and liabililties may change in different magnitudes is called basis risk. The following table shows how the basis risk occure: GAPSTATEMENT OF N BANK (INTEREST SENSITIVITY GAP POSITION -1-30 DAYS BUCKET) REPRICING
AMOUNT(RS.IN
REPRICING
AMOUNT(RS.IN
LIABILITIES
CRORES)
ASSETS
CRORES)
Saving bank
Call money
50
Cash Credit
40
50 Time Deposit 50 Total
90 100 Page 45
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NEGATIVE GAP
10
The bank ha s now a negative gap of Rs.10 crore. In case the interest rate falls by 1%, the bank will gain 10 lakhs per year assuming that the rise in interest will be uniformly applicable to all the item of assets and liabilities. But in real world interest rate on assets and liabilities do not change in proportions. Instead of falling in the magnitude, assume that when rate on call money leading falls by 1%. The rate on cash credit falls by 0.7%, the rate on savings bank fall by 0.5% and rate on time deposits fall by 0.4%. The undernoted calculation indicates that the bank‟s Net Interest Income would deteriorate rather than improve in terms of the assumption of gap management. 1. CALLMONEY
50*1%
=Rs.0.50 crore
2. CASH CREDIT
40*0.7%
= Rs.0.28 crore ---------------------
3. SAVINGS BANK
50*0.05%
4. TIME DEPOSITS
50*0.04%
(-) Rs. 0.78 crore
= Rs.0.28 crore = Rs.0.20 crore ---------------------
(+) Rs. 0.45 crore ----------------------
NET INTEREST POSTION INCOM
(-) Rs.0.33 crore -----------------------
Thus, the magnitude of change in the interest rate of various assets and liabilities as above seems more consistent with real world than the equal changes in all the rate. In the case, when the variation in interest rate causes the Net Interest Income to Expand, the bank has experienced a favorable basis shift and if the interest rate movement cause the NET Interest Income to contract, the basis has moved against the bank.
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(3) NET INTEREST POSITON RISK The bank‟s net interest position also exposes the bank to an additional interest rate risk. If a bank has more assets on which it earns interest than its liabilities on which it pays interest, interest rate risk arise when interest rate earned on assets changes while the cost of funding of the liabilities remained at 0%. Thus, the bank with a positive net interest position will experience a reduction in Net Interest Income as interest rate decline and expansions in Net Interest Income as interest tare rise. A large positive net interest position account for most of the profit generated by many financial institutions. (4) EMBEDDED OPTION RISK Large changes in the level of interest rate create another source of risk to bank profit encouraging prepayment of loan and bonds(with put or call option) and/ or withdrawal of deposits before their started maturity dates. In case where there is no penalty for prepayment of loan, the borrowers have a natural tendency to pay off their loans when a decline in interest rate occurs. In such cause, the bank will receive only a Lower Net Interest Income. Take the cause of a bank disbursed a 90 days loan at rate of 10% which is funded through a 90 days terms deposits at the rate of 8%. In case the rate of interest declines to 9% after 30 days and the borrower prepays his loan immediately, the bank receives only 200 basis points Net Interest Income for 30 days rather the anticipated 90days. In the remaining 60 days of the 90 days term, the Net Interest Income will be only 100basis point. When the interest rate rise, the Net Interest Income is exposed to the same embedded option risk in the liability side of the balance sheet as well. if there are no substantial penalties for premature withdrawal, the depositors will withdraw their term deposits before the contacted maturities so that the funds can be redeposit in new deposit accounts at a higher rate of interest. For example, if a 100 basis points rise in interest rate occurs 30 days after the deposit is fixed, the depositor would close the 90 days 8% deposit and open a new 90 term deposit at 9%. This action of the depositor will cause the bank‟s Net Interest Income declined by 100 basis point during the last days of the original 90 days term.sa interest rate rise and falls, the banks are exposed to some degree of risk as customers exercise the embedded options inherent in their loan and deposit contacts. The faster and higher the magnitude of changes in interest rate, the greater will be the embedded option risk to the bank‟s Net Interest Income. Page 47
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Most of the banks protect themselves from this risk by imposing penalties for prepayment of loan and premature withdrawal of deposits. however, most banks have found customer resist paying competitive strategy to attract additional business. (5) YIELD CURVE RISK As yield curve is a line on a graph plotting the yield of all maturities of a particular instrument. As the economy moves through business cycle, the yield curve changes rather frequently. At the intervention of reserve bank of India, the yield curve can be changed to the desired direction by altering the yields on Government Stocks of different maturities. To illustrate how a change in the shape of yield curve affect the bank‟s Net Interest Income, let us assume that a bank uses 3 year floating rate fixed deposits for funding 3 year floating rate loans (the deposits and loans are reprised at quarterly intervals). If the bank pays 100 basis point above the 8.50% 91 days treasury Bills rate to fixed deposits and changes 300 basis point above the 364 days treasury Bills rate of 9% on its loans, a Net Interest margin of 250 basis points is produced. If the yield curve turns inverted during the next reprising date with the91 days treasury Bills rate increasing to10% and 364 days treasury Bills rate remaining at 9% and spread relationship of deposits and loans to treasury Bill remains constant, PERIOD
91DAYS
364DAYS
TERM SPRED
INTEREST
TREASURY
TREASURY
SPRED
BILLS
BILLS
BETWEEN DEPOSITS AND LOANS
APRIL1999 8.75%
10.07%
1.32%
3.32%
9.24%
10.32%
1.08%
3.08%
9.46%
10.28%
0.82%
2.82%
9.16%
9.93%
0.77%
2.77%
JUNE1999
AUGEST1999
MARCH2000
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FEBRUARY2002 6.25%
6.42%
0.17%
2.17%
The Net Interest margin will be reduce to 100 basis point. Thus, the banker should base only the rate of a single instrument for pricing the assets and liabilities. The following table shows yield curve risk involved, as the spread between the two maturities of Treasury Bills narrowed: (6)PRICE RISK Price risk occurs when assets are sold before their stated maturity dates. In the financial market , bond price and bond yield are inversely related. For example, the price of 100 year 14% Government of India Stock will receive only lower price than originally paid for when coupon of stock of similarly maturity has gone up to 15% in the market. (7)REINVESTMENT RISK Uncertainty with regard to interest rate at which the future cash flowed can be reinvested is called as reinvestment risk. Suppose, a bank has a zero coupon deposits of Rs.10000 and it promises to double the amount within 7 years and user the funds for investing in a 7 year bond at an annual coupon of 12%. This intermediation generates a Net Interest Income of Rs.2017. In case, the interest rate falls to 5% after one years, the bank could reinvest the coupon cash flow only at 5% against the anticipation of reinvesting the coupon a fixed rate of 12%. Due to this reinvestment risk, the will not be able to repay the entire amount of deposits on maturity. The bond pricing formula assumes that all coupon payment are reinvested at the bond‟s yield to Maturity (YMT). If the interest rate increases over the life of a bond, coupons will be reinvested at higher yields thereby increasing the reinvestment income. The increase in reinvestment income will increase the realized yield of the bond. When the interest rate goes up, the bond price decrease but the bond‟s realized compound yield will increase due to higher coupon reinvestment income. On the other hand, when the interest rate declines the bond price increase resulting in a capital gain but the realized compound yield decrease because of lower coupon reinvestment income. Thus, price risk and reinvestment risk partially off-set one another. Page 49
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The sort term bonds have more reinvestment risk since proceeds of the bonds must be reinvested more and more times. Alternatively, long term bonds have more price risk. In order to reduce reinvestment risk, banks try to match the duration of their assets and liabilities and not their maturities. EFFCTS OF INTEREST RATE RISK Interest rate risk is the risk where changes in market interest rate might adversely affect a bank‟s financial condition. The immediate impact of changes in interest rate is on the Net Interest Income (NII). A long term impact of changes interest rate on the on the bank‟s net worth since the economic value of a bank‟s assets, liabilities and off-balance sheet positions get affected due to variation in market interest
rate . The interest rate risk when viewed from these two
perspectives is known as `earning perspective‟, respectively. DETAILS
TARGET VARIABLE
SHORT
LONG
TERM
TERMPERSPECTIVE
PERSPECTIVE
Net Interest Income(NII)
Market
Value
of
equity
(MVE) PERSPECTIVE
Accounting
Economic
TYPE OF MISMATCH
Tactical
Structural
FOCUS
Profit/loss
Balance Sheet Strength
ANALYTICAL
a)Gap Analysis
a)Duration Gap Analysis
TECHNIQUES
b)Simulation of NII
b)Simulation of MVE
c)Earnings at risk
c)Value at Risk Equity
(Source: Reserve Bank of India‟s Guidance Note on market Risk Management) MEASURING AND MANAGEMENT OF INTEREST RATE RISK The management of interest Rate Risk should be one of the critical components of market risk management in banks. The regulatory restriction in the past had greatly reduce many of the risk in the banking system. Deregulation of interest rate has, however, exposed them to the adverse impact of the interest rate risk. The Net Interest Income or interest margin of banks is dependent on the movements of interest rate. Any mismatch in the cash flows(fixed assets and liabilities) or reprising dates (floating assets or liabilities),expose bank‟s Net Interest Income or Net Interest Page 50
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Margin to variation. The earning of assets and the cost liabilities are now closely related to market interest rate volatility. Before risk can be managed, they must be indentified and quantified. Unless the quantum of risk inherent in a bank‟s balance sheet is measured, it is impossible to measure the degree of risk to which the bank is exposed. It is also equally impossible to develop effective risk management strategies/techniques without being able to understand the correct risk position of the bank. There are many analytical techniques to measure and hedge/manage interest rate risk. The most commonly used techniques are 1. Maturity Gap Analysis or Tradition Gap Analysis (to measure the interest rate sensitivity of earning ) 2. Duration Gap Analysis (to measure the interest rate sensitivity of capital) 3. Simulation 4. Value at Risk While these method highlight different facets of interest rate risk, many banks use them in combination, or use hybrid method that combine feature of all the techniques.
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CHAPTER:-11 CASE STUDY State Bank of India, London, United Kingdom case study- 1
The Client STATE BANK OF INDIA (SBI) is the largest bank in India with over 180 years of banking experience. Today, State Bank of India ranks among the top 25 commercial banks in Asia with assets exceeding US$60 billion. SBI operates worldwide through an extensive network of over 9000 offices including 50 overseas offices in 48 countries. The Bank has won the Technology Award 2005, from the „Banker‟, London. Until recently, SBI UK operation has been using the Misys-Equation banking application for its operations. This application runs on the IBM AS400 platform. Since 2001, IIL Risk Management has provided various IT related services to the Bank. The Problem SBI, UK‟s Treasury operations use the Reuters 3000 dealing system. Dealers negotiate and confirm various deals every day involving money market and forex trades. These deals were posted manually into the banking application. Manual posting carried with it the risk of error prone entries, missed out deals, lack of suitable and timely checks & verification and inability to ascertain accurately counter party dealing limits. The Bank required „straight through processing‟ from Reuters dealing server to the Misys-Equation platform to minimize operational risk. With an eye on future proofing the investment in the system it also desired that the solution be platform independent and therefore be based on „java‟ programming and be integrated with the Meridian middleware provided by Misys. In addition, they required counter party limits and exposures to be displayed back to the dealer on a separate screen by intelligently using the information from dealer initiated Reuter conversations with the counter party. Investigation of Page 52
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available products in the market place found that they contained many functionalities already catered for by the Reuter system and were not cost effective and used obsolete technologies. The Solution IIL Risk Management (IIL) developed for the bank a unique and cost effective solution to automate the entire process from capturing deals from Reuter dealing 3000 server to posting into the core banking application.
The solution integrates various technologies such as Microsoft Windows 2000 server, Access database, IBM MQ series, Misys Meridian middleware and IBM AS/400.
The process can be categorized as follows: • Electronic capture of deals via Reuter Ticket Output Feed (TOF). • Deal data processing with data validation and writing to database. • Deal data mapping, formatting and posting to Misys Equation using Meridian Middleware/IBM MQ Series. • Secure and user-friendly interface to monitor flow of deal data, correct any exceptions and review status of posting into Misys Equation. • Intelligent use of Reuters Current Interest Feed (CIF) to retrieve counter- party dealing limits and actual exposures from the Equation banking system and displaying the same back to the dealers.
All the above modules work closely with each other in terms of connectivity, request and response along with reliable audit trails. The Benefits The implemented solution reduced SBI, UK Treasury Department‟s workload considerably virtually eliminating the need for human intervention. Operational efficiency was greatly improved. Timely display of counter party dealing limits at both Group and Individual level and actual exposures enabled the dealers to know the exact „position‟ at any given time. This was an Page 53
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important technology based support for the Bank‟s efforts to minimize operational risk from manual interventions. Case Study - 2 Bank of Baroda, London, United Kingdom bank fo
The Client BANK OF BARODA has significant International presence with a network of 57 Offices in 19 countries including 38 branches of the bank and 17 branches of its seven subsidiaries besides 2 representative offices in Malaysia and China and a network of more than 2700 branches in India. In the U.K, since the 1990’s the bank has been using the Misys-Equation core banking application to support its activities at its London Main Office and other branches. This application runs on the IBM AS400 Operating platform. IIL Risk Management has been providing various IT related services to the bank. The Problem Bank of Baroda U.K conducts it's clearing through NatWest/Royal Bank of Scotland. The bank (main office and branches) receives all clearing information such as cheques, giro credits and direct debits from NatWest on a daily basis as printed statements along with the related instruments. The process involves classifying each payment and posting the resultant transactions into Misys Equation core banking product manually. Checks have to be made in respect of stopped cheque, blocked account, inactive account, closed account and incorrect accounts. Moreover, the account numbers held at NatWest do not exactly match with that in the Misys-Equation database. Manual entries were error prone requiring additional verification. This process therefore, called for considerable effort and use of human resources contributed to operational risk. The Solution IIL Risk Management has provided a solution to automate the entire process end to end with the Page 54
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necessary validations at every level of the data pass through. The objective being the reduction of manual effort to a minimum and improvement in the accuracy of posted transactions and operational efficiency.
The implemented solution integrates with electronic receipt of Agency Credit Clearing data from NatWest based on APACS (Association of Payment Clearing Services) standards 27 and 29, which define the specification of files exchanged between banks and their customers. Both Microsoft and IBM technologies are used with suitable data transfer methodology to IBM AS/400.
An MS Windows based front-end provides a user-friendly interface to process downloaded data from NatWest, carry out necessary checks to ensure data integrity and to transfer the data to AS/400.
IBM AS/400 operations menu guides the user to process the transferred data, categorizing the transactions as 'OK' to post and 'Exceptions' based on established business validation rules and to tally the credit/Debit totals with those from NatWest. The automatic mapping function enables correction of incorrect account numbers. All the Branches including the Main Office have access to menu options to view and correct the exceptions. A specially written automatic posting program handles the posting of accounting entries into Misys-Equation. The Benefits Implementation of the automated clearing system increased the speed of processing, drastically reduced manual errors, eliminated delays in posting customer accounting entries and kept up-todate individual customer accounts. The solution is centrally managed from the Head Office and use of the AS/400 platform on which the banking application runs, allows branches to handle their part of the data effectively while not worrying about uploading and managing their branch specific clearing data
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CHAPTER:-12 CONCLUSION The objective of risk management is not to prohibit or prevent risk taking, but to ensure that the risks are consciously taken with full knowledge, clear purpose and understanding so that it can be measured and mitigated. The purpose of managing risk is to prevent an institution from suffering unacceptable loss causing an institution to fail or materially damage its competitive position. Functions of risk management should actually be bank specific dictated by the size and quality of balance sheet, complexity of functions, technical/professional manpower and the status of MIS in place in that bank. There may not be one-size-fits-all risk management module for all the banks to be made applicable uniformity. As in the international practice, a committee approach may be adopted to manage various risks. Risk Management Committee, Credit Policy Committee, Asset Liability Management Committee, etc., are such committee that handles the risk management aspects. The effectiveness of risk management depends on efficient Management Information System, computerization and net working of the branch activities. An objective and reliable data base has to be built up for which bank has to analyse its own past performance data relating to loan defaults, trading losses, operational losses, etc., and come out with bench ,marks so as to prepare themselves for the future risk management activities. A large project involves certain risks, and that is true of banking projects. The Risk Management is an emerging area that aims to address the problem of identifying and managing the risks associated with the banking industry. The Risk Management helps banks in preventing problems even before they occur. In managing the risks, the Board of Directors and Senior Management will have to play an effective role by formulating clear and comprehensive policies.
The Risk Management System, which integrates:
Prudent risk limits, Page 56
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Sound risk management procedures and information systems,
Continuous risk monitoring and frequent reporting is said to be efficient one. The keen interest taken by the Reserve Bank of India in this context needs to be appreciated and supported at all levels.
Most of the risks arise as a result of mismatch of assets and liabilities. If the Assets of a bank exactly matched its liabilities of identical maturity, interest rate conditions, and currency, then liquidity risk, interest rate risk, and currency risk could have been avoided. However, in practice it is near impossible to have such a perfectly matched balance sheet. A banker therefore has, to keep different types of risk within acceptable limits. It requires the ability to forecast future changes in the environment and formulate suitable action plans to protect the net worth of the organization from the impact of these risks. It is by no means an easy task. If he is proved wrong in his judgment, the process of risk management may go haywire. Few would disagree with the statement that “being a banker is like being a country hound dog. If you stand still, you get kicked. If you run, they throw rocks at you”.
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