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Ankur srivastava
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The chief merit of the reform process is that the reform measures were
undertaken and implemented gradually and cautiously.
The first phase of the banking sectors is complete and the second
generation reforms are under way.
The second generation reforms are those that did not form part of the
first generation reforms but needed to be prioritized in the agenda for the
next decade. Many of the important recommendations of the
Narasimham committee II have been accepted and are under
implementation.
Ankur srivastava
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Ankur srivastava
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Ankur srivastava
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Ankur srivastava
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contt
Decreasing the emphasis laid on directed credit and phasing out the
concessional rate of interest to priority sector.
Deregulation of the entry norms for the private sector banks and
foreign banks.
Permitting public and private sector banks to access the capital market.
Setting up the asset reconstruction fund.
Constituting the special debt recovery tribunals.
Freedom to appoint chief executive and officers of the banks.
Changes in the constitutions of the board.
Bringing NBFCs under the ambit of regulatory framework.
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Capital adequacy
Capital adequacy ratio to be raised from 8% to 10% by 2002.
100% of fixed income portfolio marked-to-market by 2001 (up from
70%).
5% market risk weight for fixed income securities and open foreign
exchange position limits (no market weights previously).
Commercial risk weight (100%) to government guaranteed advances
(previously treated as risk free).
Ankur srivastava
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Asset quality
Banks should aim to reduce gross non-performing assets to 3% and net
NPAs to 0% by 2002.
90 days overdue norm to be applied for cash-based income recognition
(down from 180 days).
Government-guaranteed irregular accounts to be classified as NPA &
provided for.
Asset Reconstruction Company to take on NPA of weak banks against
issue of risk-free bonds.
Directed credit obligations to be reduced from 40% to 10%.
Mandatory general provisions of 1% of standard assets and specific
provision to be made tax-deductible.
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Ankur srivastava
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Industry structure
Only two categories of financial sector players to emerge: banks and
non-bank finance companies; DFI to covert to banks or remain nonbanking companies.
Mergers to be driven by market and business considerations, not
imposed by regulators.
Weak banks to convert to narrow banks, restructure, or close down if
proven unviable.
Entry of new private sector banks and foreign banks to continue.
Banks to be given greater functional autonomy, and minimum
government shareholding to be reduced to 33% from 55% for the SBI
and 51% for other public sector banks.
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Legal amendments
Broad range of legal reforms to facilitate recovery of problem loans.
Introduction of laws governing electronic funds transfer.
Amendments in the Banking Regulation Act, the Nationalization Act
and the State Bank of India Act to allow greater autonomy, higher private
sector shareholding, and so on.
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Prudential Regulation
There are two modes for bank regulation:
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Economic regulation:
This model calls for:
Imposing constraints on interest rates,
Tightening entry norms, and directed lending.
In the pre-reform era, the RBI regulated banks through economic
regulation. However, the empirical evidences indicated that this
model hampered the productivity and efficiency of the banking
system. Hence, the RBI adopted prudential regulation.
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Prudential regulation
Prudential regulatory model calls for imposing the regulatory capital
level to maintain the health of banks and the soundness of the financial
system. It allows greater play for market forces than economic regulatory
model.
The RBI issued prudential norms based on the recommendations of the
Narasimham committee report.
The major objective of prudential norms was to ensure:
Financial safety,
Financial soundness,
Solvency
of banks.
These norms strive to ensure that banks conduct their business activities
as prudent entities, i.e., not indulging in excessive risk taking and
violating regulations in pursuit of profit.
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Ankur srivastava
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Banks will have to disclose any shortfall in their capital to depositors and
all stakeholders.
In order to provide additional options to banks for raising capital funds,
the Reserve bank allowed them in January 2006 to issue instruments
such as:
a.Innovative perpetual debt instruments eligible for inclusion as tier I
capital,
b.Debt capital instruments eligible for inclusions as Upper Tier II capital,
c.Perpetual non-cumulative preference shares eligible for inclusion as
Tier II capital, and
d.Redeemable cumulative preference shares eligible for inclusion as Tier
II capital.
Ankur srivastava
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Ankur srivastava
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Ankur srivastava
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Ankur srivastava
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The RBI stipulates a CAR of 9% for all banks and a CAR below this
stipulation indicates the inadequacy of a banks capital, compared to its
assets (largely loan advanced and investments) weighted against the risk
they carry. In other words, the capital for these banks does not match up
to the risk profile of their advances.
Ankur srivastava
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These norms (1988) helped to arrest the erosion of the banks capital
ratios. However, they were not found to be adequate due to their
perceived rigidities. Moreover, the financial markets, financial
intermediaries, business of banking, risk management practices, and
supervisory approaches have undergone significant changes.
These baseline capital adequacy norms were found to be inadequate as
they almost entirely addressed credit risk. In response to the same, the
BCBS brought out their Consultative paper on New Capital Adequacy
Framework in June 1999 and a second revision in January 2001 after an
informed public debate. The new rules have been effective from 2005.
The BCBS announced the establishment of an Accord Implementation
Group.
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The New Basel Accord is based on three mutually reinforcing pillars that
allow banks and supervisors to evaluate properly the various risks that
the banks face.
The Basel II Accord is based on three pillars:
Minimum Capital Requirement
Supervisory review process &
Market discipline
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Minimum Capital
Requirements
Supervisory
Review Process
Credit risk
Operational risk
Supervisors review
Market risk
Market Discipline
Enhanced disclosure
Supervisory
Review
Market
Discipline
Focus on
Advanced
internal
methods for
capabilities
capital
Supervisors to
allocation
review banks
Capital charge
internal
for operational
assessment
risk
and strategies
Focus on
disclosure
40
Framework
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Credit Mitigation
Risks
Trading Book
Market Risk
Banking Book
Operational
Other Risks
Other
Total capital
= Banks capital ratio
Credit risk + Market risk + Operational risk
(minimum 9%)
Total Capital
Credit Risk
Market Risk
Operational Risk
The risk of loss resulting from inadequate or failed internal processes, people
and systems or from external events
* The revisions affect the denominator of the capital ratio - with more sophisticated measures for credit risk, and introducing an explicit capital charge for operational
risk
Minimum
Capital
Requirement
Foundation approach
Advanced approach
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Sovereigns
Banks
Corporates
Retail
NPA
Standardized Approach
Pillar 1 Credit Risk stipulates three levels of increasing sophistication. The more sophisticated
approaches allow a bank to use its internal models to calculate its regulatory capital. Banks who move
up the ladder are rewarded by a reduced capital charge
Advanced Internal
Ratings Based
Approach
Foundation Internal
Ratings
Based Approach
Standardized
Approach
Standardized Approach
Standardized Approach:
New Risk Weights (January 2001)
Assessment
Claim
AAA to A+ to A- BBB+ to
AASovereigns
Banks
BBB-
BB- (B-)
(B-)
0%
20%
50%
100%
150%
100%
Option 11
20%
50%
100%
100%
150%
100%
Option 22
20%
50%3
100%3
150%
20%
50%
(100%)
100%
150%
Corporates
1
50%3
100%
50% 3
100%
Risk weighting based on risk weighting of sovereign in which the bank is incorporated.
Claims on banks .of a short original maturity, for example less than six months, would
receive a weighting that is one category more favourable than the usual risk weight on
the banks claims
3
Approach:
Three elements:
Risk Components [PD, LGD, EAD]
Risk Weight conversion function
Minimum requirements for the management of policy
and processes
Emphasis on full compliance
EL (Expected Loss) = PDxLGDxEAD
Definitions;
PD = Probability of default
LGD = Loss given default
EAD = Exposure at default
Note: BIS is Proposing 75% for unused commitments
EL = Expected Loss
Basel II definition
Cont
Includes both internal and external event risk
Legal risk is also included, but reputational risk
not included
Direct losses are included, but indirect losses
(opportunity costs) are not
Examples
KBIA = [ (GI*) ] / n,
Where
KBIA = the capital charge under the Basic Indicator Approach.
GI = annual gross income, where positive, over the
previous three
years
=
15% set by the Committee, relating the industry-wide level of required
capital to the industry-wide level of the indicator.
n=
Gross income = Net profit (+) Provisions & Contingencies (+) operating
expenses (Schedule 16) (-) profit on sale of HTM investments (-) income from
insurance (-) extraordinary / irregular item of income (+) loss on sale of HTM
investments.
Advantages/ Disadvantages
Strength:
Simplicity
Limitations:
Blunt charge, not risk-sensitive:
One size fits all
Risk does not increase linearly with gross income
ADVANTAGE
Credit Risk
Operational Risk
Yes
Yes
Difficult1
Known
Known
Unknown
Context
dependency
Low
Medium
High
Data frequency
High
Medium
Low
Good
Reasonable
Low
Backtesting difficult to
perform over short term
Usage issues
Instability of underlying
price volatility;
Correlation instability in
stressed markets
Summary
Quantifiable
exposure
Exposure
measure
Portfolio
completeness
Risk assessment
Accuracy
Testing
Ankur srivastava
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09212803190
The four basic and complementary principles on which the Pillar 2 rests
are:
a.A bank should have a process for assessing its overall capital adequacy
in relation to its risk profile as well as a strategy for maintaining its
capital levels;
b.Supervisors should review and evaluate a banks internal capital
adequacy assessment and strategy as well as its compliance with
regulatory capital ratios;
c.Supervisors expect banks to operate above the minimum regulatory
capital ratios and should have the ability to require banks to hold capital
in excess of the minimum; and
d.Supervisors should seek to intervene at an early stage to prevent capital
from dipping below prudential levels.
Ankur srivastava
srivankur@rediffmail.com
09212803190
Ankur srivastava
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09212803190
srivankur@rediffmail.com
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Basel I
Basel II
One-size-fits- all
Table 1: Comparison of Basel I and Basel II standards Source: The new Basel
capital accord: an explanatory note, BIS
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09212803190