Basel II Implementation in BRAC Bank Limited
This study focus on risk based capital adequacy requirement of Bangladesh Bank
Bangladesh Bank (BB) is the governing body of all the commercial banks in this country. To be in line with the international standard for regulation of banking industry (Basel Accord), BB has introduced Risk Based Capital Adequacy guideline relating to Basel II. All banks have to follow this guideline and report to BB effective from 1st January, 2010. The guidelines are structured in three aspects or pillars: (1) banks should have minimum capital to guard against different kinds of risks (credit, market and operation risk); (2) assessing capital adequacy with risk profile of the bank and capital growth plan and (3) public disclosure of bank’s position on risk, capital and management.
The three main risks that a commercial bank faces are: Credit risk, Market risk and Operational risk. Credit risk is the risk that arises from the probability that the borrowers of the bank will not pay back. Market risk is the risk that puts the bank in adverse situation when interest rate, foreign exchange or equity price move in unfavorable direction.
Operational risk stems from the internal environment, occurring when internal processes, people or system fail. The banks can become resilient and fend off these risks with adequate capital. This is where the regulatory guidelines come to play. BB categorizes capital into three tiers. Tier 1 Capital, also known as the Core Capital, which are the top quality capital for the bank. The Components include: Paid up capital, general and statutory reserves, retained earnings, minority interest, non cumulative non put able preference shares, etc. Tier 2 Capital, also known as supplementary capital, supports Tier 1 capital.
Components include: general provision; revaluation reserves for Fixed Assets, Securities and equity investments; other preference shares and subordinated debt. Tier 3 Capital, also known as additional supplementary capital, whose components include: short term subordinated debt to solely guard against market risk. There are more specific guidelines for eligibility of the capital tiers. To measure adequacy; Capital Adequacy Ratio (CAR) is calculated with Risk Weighted Asset (RWA) on the basis of credit, market and operational risk.
Capital planning is an important part to face the risks of the bank. One of the measure or technique to assess the potential damage is stress testing. It is just a type of what-if analysis.
The financial situation of the bank is given some unfavorable “shocks” and potential worst case scenario is observed. BB provides reporting format for the banks.
Banks have to follow the regulatory rules; otherwise BB can impose penalty and/or punishment as per Bank Company Act of 1991.
BBL fulfilled all major requirements of Basel II in 2010. It has been maintaining a CAR ratio of above 10% requirement for the last two years. In June 2011 Basel II report to BB, BBL recorded CAR ratio of 11.9% on actual capital. According to the same report, it has a total eligible capital of nearly BDT 13,274 million and a Total RWA of nearly BDT 111,511 million whose 10% must be kept as capital, i.e. BDT 11,151 million. Thus BBL has a surplus of capital. Most of its Tier 1 capital is covered by paid up capital which is high quality and major part of its Tier 2 capital consists of subordinated debt. BBL can smoothly implement all the pillars of Basel II further if the impediments are removed. Data and reporting should be centralized; reasonable time should be given for report submission, unnecessary complex measures can be neglected to help banks adopt Basel II. Stress Test can be improved to show realistic results regarding Pillar 2.
Basel II has been enthusiastically adopted by all the scheduled banks. 28 out of 30 banks have adequate CAR ratio as on June, 2011. Even though banks of our country have less international market exposure, the Basel II international guideline will safeguard them in any unforeseen economic condition of home and abroad.
Objective of the report
The main objectives of the report are to cover the degree requirement of BRAC University, to know about the very important BB regulation of Basel II and enhance the knowledge by looking at BRAC Bank’s implementation of the regulatory requirement.
Scope of the report
This report only talks about Basel II implementation of BRAC Bank Limited. This report has been prepared using utmost caution, but the complexity of Basel II regulation is very well known. The report can be a primary reading for anyone who is new to banking industry or wants to know about regulatory requirement or someone who wants to study Basel II.
Under no circumstances can this report be the sole material or absolute alternative to the original BB requirement for anyone who wants to know the ins and outs of Basel II or work with Basel II regulation. For full knowledge of Basel II, the reader must refer back to “Guidelines on Risk Based Capital Adequacy (Revised Regulatory Capital Framework for banks in line with Basel II)”, the main text released by BB in December, 2010.
Overview of the Organization
BRAC Bank Limited is a full service scheduled commercial bank. It started its operation is 2001. The bank is primarily driven with a view of creating opportunities and pursuing market niches not traditionally meet by conventional banks. BRAC Bank has been motivated to provide “best-in-the-class” services to its diverse assortment of customers spread across the country under an on-line banking system. It is the market leader in SME loan portfolio in our country. The bank was enlisted in Dhaka Stock Exchange in 2007 and it now has a market capital of BDT 1,440 million, as on October 18, 2011 (DSE, 2011)1. It has 153 branches including SME service centers, nearly 7000 employees and operates through strong network of OMNIBUS ATM network.
Basel II: Capital Adequacy Framework
There are thousands of commercial banks in the world. These banks face a lot of risks everyday in many forms. Strong and well functioning banking industry is undoubtedly one of the main ingredients of a country’s growth. With this perspective, in 1975, Basel Committee on Banking Supervision (BCBS) was formed. Its secretariat office is at the Bank for International Settlements in Basel, Switzerland. Its main objectives were to understand the supervisory issues related to banks and improve the supervisory quality globally. BCBS committee members come from 27 countries and help come up with standard guidelines for banks to follow. It is not a body which can issue binding regulations; it is rather a forum where global best practice standards regarding risk management in banks are developed.
Most countries are implementing the committee’s policies and they are enforced through national laws and regulations in line with the recommended guidelines by BCBS. The committee issued recommendations on banking laws and regulations known as Basel Accord (Basel I of 1988) which addressed minimum capital requirement for commercial bank. The second installment of the accord came out in 2004 and is best known as Basel II (revised in 2006) which better addresses the issue of how banks and other depository institutions should handle their capital to guard against risks they face.
The main objectives of Basel II are:
- Ensuring that capital allocation is more risk sensitive;
- Enhance disclosure requirements which will allow market participants to assess the capital adequacy of an institution;
- Ensuring that credit risk, operational risk and market risk are quantified based on data and formal techniques;
- Attempting to align economic and regulatory capital more closely to reduce the scope for regulatory arbitrage.
Scope of Basel II regulatory requirement in Bangladesh
As BCBS does not have the authority to issue binding laws in any country, so in Bangladesh, the central bank- Bangladesh Bank (BB) issues the guidelines under section 13 and section 45 of “Bank Company Act -1991”. BB recognized the importance of Basel II and decided to implement the global standard guidelines for banking supervision. BB has made this requirement mandatory for all scheduled banks from January 01, 2010. The guidelines apply to banks on solo and consolidated basis. Solo basis means “the bank” only with all of its local and overseas branches. Consolidated basis means “the bank” and its subsidiaries, e.g. merchant banks, brokerage firms inclusive. In December 2010, Bangladesh Bank released the compulsory guidelines under the name- “Guidelines on Risk Based Capital Adequacy (Revised Regulatory Capital Framework for banks in line with Basel II)”.
Guard against Three Risks
BCBS identified three basic risks that banks face and they think adequate capital should be there to guard the bank against these risks.
Credit risk is the risk bank faces when its borrowers and/or counterparty do not fulfill their obligation towards the bank. Bank’s claim will include loans and advances to and deposits in local and foreign currency to other banks, central bank and other local and international institution which include International Monetary Fund (IMF), World Bank, Asian Development Bank (ADB), European Central Bank (ECB) and etc. Assets in non-bank financial institutions (NBFIs), corporate, retail and SME will also have to be counted. The maximum exposure to single borrower (person or institute) can be BDT 1 crore.
Market risk arises from on and off balance sheet exposure to debt securities, equity securities and foreign currency. The main concern is that the variables will move adversely and the bank will incur losses due to the loss of value of the securities. BB requires banks to maintain capital for interest rate movements, adverse price movements of equity securities, foreign exchange, repo-reverse repo transactions, interest rate derivatives, Forward Rate Agreements (FRA) and SWAPs (BB, 2010).
This risk is the risk of loss due to failed internal process, people and system or from external events. It also includes legal risk.
Pillar 1: Minimum Capital Requirement
Basel Committee and BB agree that some minimum capital must be maintained to make banks and depository institutions more risk sensitive and shock resilient. BB laid out guidelines about the capital that can be and should be counted in calculating Capital Adequacy Ratio (CAR).
Risk Based Capital Adequacy
BB did not give banks any specific amount of capital target. Banks have different mix in their loans and advances portfolio. HSBC Bangladesh has huge corporate loan portfolio whereas BRAC Bank Limited focuses heavily on SME loans. A one size fit all capital amount would not have been right. This is why a bank is supposed to weight its assets according to the risk it faces and maintain adequate capital to protect itself. The assets are weighted with risk factors and Total Risk Weighted Asset (RWA) is found. Minimum 10% of the RWA must be backed by Total Eligible Capital (Tier 1, 2 and 3 capitals) and minimum 5% of RWA must be backed by Core Capital.
Credit Risk Mitigation (CRM)
Banks use a number of tools to reduce their risk exposure to protect their loan portfolio. The tools or techniques can be considered in two heads: 1. Collateral for CRM and 2.Guarantee for CRM.
Banks are allowed to reduce their risk of counter party default by being in possession of eligible financial collateral (BB, 2010, pp.19)20. Eligible financial collateral include:
Cash (also Certificate of deposit, fixed deposit or comparable instrument)
Securities rated by recognized External Credit Assessment Institution (ECAI) as investment grade.
Debt securities not rated by ECAI but:
- Issued by a bank
- Listed on recognized exchange
- Classified as senior debt
Equities that are traded in Dhaka and Chittagong Stock Exchange (DSE and CSE).
Value will be calculated based on last six month’s daily average.
The eligibility criteria of the collateral are also mentioned by BB:
The bank should have the right to liquidate or take legal possession of it in a timely manner in the event of default or bankruptcy.
There must not be a material positive correlation between counterparty and issuer of collateral.
Banks must have clear and robust procedures for timely liquidation of collateral.
If the collateral is held by a custodian, bank must take steps to ensure that custodian segregates the collateral from its own assets.
Eligible guarantors for CRM are:
Sovereigns, sovereign entities and banks with a lower risk weight than the counterparty.
Guarantee provided by parent, subsidiary and affiliate companies when they have lower risk weight than the counterparty.
There are conditions that must be met by eligible guarantors:
- The guarantee must be clearly and explicitly referenced. It must be indisputable, irrevocable, and unconditional and should be obliged to pay back in timely manner in the event of default by the original party.
- When a guaranteed exposure is classified as nonperforming, the guarantee will no longer be considered as a risk mitigant.
- The bank should have the right to be paid by the guarantor, in case of default by the original party, without first taking legal steps against the original party.
Credit Risk Calculation Methodologies
Basel II allows three ways to calculate credit risk and any one can be followed. The first is the Standard Approach. It calls for the use of external credit rating by External Credit Assessment Institution (ECAI). The ECAI determined risk weights for counterparty will be used in credit risk calculation. ECAIs will also determine similar counterparty groups and apply standard risk weightings to those categories. The second way is Internal Ratings Based (IRB) approach. This approach allows banks to use their internal assessment of counterparty regarding the Probability of Default but requires them to use standard supervisory parameters regarding Exposure at Default and Loss Given Default. The final approach is the IRB Advanced approach. This approach allows banks to use their own internal assessment in determining Probability of Default and quantifying Exposure at Default and Loss Given Default (BBL, 2010).
Pillar 2: Supervisory Review Process (SRP)
The main theme of Pillar 2 is that (1) banks have to have a process to assess their own risk profile and calculate adequate capital and (2) they must have a strategy to maintain the level of adequate capital required in the future. Banks should also have SRP team which will manage all the risks a bank faces, develop and implement better risk management techniques.
Effective Oversight by Management
The supervisory process is a tool for the regulators to ensure adequate capital of banks to guard against risks. It also delegates responsibility to top management of the institutions to make certain of the implementation of the laws. The management must analyze their risks internally, make plan on capital and maintain proper internal control process. Supervisory review process will address:
- Risk that are not covered by Pillar 1 (risks other than credit, market and operation)
- External risk factors to the bank that are not captured by Pillar 1.
Management must take steps to plan for achieving proper capital target and to gradually use advance process of calculating RWA and CAR. The five main features of effective review process are:
- Board and senior management oversight
- Sound capital assessment
- Comprehensive assessment of risks
- Monitoring and reporting
- Internal control review
The SRP team is responsible for making and applying Internal Capital Adequacy Assessment Process (ICAAP). The ICAAP is an important part of Pillar 2 because it helps the bank in risk measurement and capital planning process. It is basically an internally created guideline regarding risk assessment and reporting process to be followed when considering the amount and type of capital the bank should maintain to support its business.
Supervisory Review Evaluation Process (SREP)
BB Basel II implementation cell reviews each bank’s supervisory review process. This cell evaluates the bank’s SRP and then arranges dialogue/ discussion session with that bank’s SRP team.
BB SREP team will analyze bank’s review process. BB expects banks to operate above minimum capital standards. BB, through SREP, will intervene at an early stage if they feel that the bank would falter in meeting minimum capital requirement. The frequency of meeting will depend on bank’s activities and the difference between capital requirement assessed by the bank and BB team. Usually, the SRP-SREP Dialogue takes place in BB once every year.
Stress testing is a kind of sensitivity analysis or “what-if-analysis” for banks. The purpose of this test program is to find out how shock absorbent a bank is. Basically, the test calls for changing a single variable at a time and observing what the result bring to the bank’s assets, profitability, liquidity and other measures. The variables are changed to test forward looking scenario a bank might face. This will measure the vulnerability and exposure to rare, exceptional but potential events.
The five different risk factors that are used in stress testing are:
- Interest rate
- Forced sale value of collateral
- Non-performing loan (NPL)
- Share price
- Foreign exchange rate
Stress test on liquidity must be done separately. The three levels of shocks are: Minor (e.g. only 1% change in interest rate), Moderate (e.g. a 3% change in interest rate) and Major (e.g. 5% or more change in interest rate).
After BB collects information from banks and finishes the dialogue, the bank and BB will set the total capital requirement for the bank corresponding to the risks they face.
Pillar 3: Market Discipline
This pillar is present in Basel II framework to complement the other two pillars. This pillar requires the bank to disclose information to public and be more transparent to the financial market and the participants. Current and potential stockholders, depositors and borrowers will want to know the bank’s strengths and potential loss of assets.
Banks must have a formal disclosure framework approved by the Board or CEO of the bank. The banks must follow the disclosure format provided by BB.
The disclosed information must be consistent to the audited financial statements. The information must be material and omission of important and relevant data must be avoided. Banks have to submit the data along with annual financial statements to BB by the end of March every year. Banks can disclose the Basel II information in their Annual Report and/or on their website. In case of Annual Report, a separate section must be utilized to report information. In case of website, the Basel II information must be provided in the home-page.
The historical information must be maintained in the website for 4 years. The components must be disclosed in tabular form and in quantitative and/or in qualitative form regarding the topics mentioned below:
- Scope of application
- Capital structure
- Capital adequacy
- Credit Risk
- Equities: disclosures for banking book positions
- Interest rate risk in the banking book (IRRBB)
- Market risk
- Operational risk
Basel III: Basic Proposition
Basel III is introduced in a situation when the global banking industry is in ruin. Thus, one may expect Basel III to be more rigorous in regulating and protecting the banks. It will move to fill in the deficiencies the banks have in their operation that are revealed by the latest global financial crisis. Banks will have to hold 4.5% of common equity in their capital.
The MCR on core capital is going up to 6% from 5% of Basel II. Basel III also introduces additional capital buffers, minimum 3% leverage ratio and two liquidity ratios (the Liquidity Coverage ratio and Net Stable Funding ratio).
Basel II implementation in BRAC Bank
In BRAC Bank, the implementation works started in 2009 and in 2010, the bank fulfilled all the major requirements of BB. In 2011, the bank has met all reporting requirements set by the central bank.
BBL has been successfully achieving the desired Capital Adequacy Ratio (CAR) since 2009. The management is fully aware about the guidelines of BB and prepared for implementing new Basel II accord. An implementation committee has been formed which is headed by the Head of Operations. Adequate training from home and abroad to the concerned staff on Basel II is given for better understanding and smooth implementation of Basel II. BRAC Bank also issued BDT 3 billion worth of bond to meet its Tier 2 Capital (Subordinated 25% convertible bond). A table below shows historical and current CAR ratio of BBL.
Impediments to Basel II adoption in BBL
In a developing country like ours, the banking industry is not big enough compared to that of the other developed countries. Our banking sector does not have excessive international exposure as well. Still BB believes that the supervision should be up to global standards.
Original Basel II accord is meant to oversee the banking industry as a whole which includes the banks in developed countries who deal with complex financial instruments. BB thus modified and simplified the policy to adapt it for our country scenario. Still it is one of the most complex yet important guidelines of BB.
Whenever some new policy and guidelines are implemented, people and institutions face various problems. Some of the internal and external problems that BBL faced while implementing Basel II are listed below:
Internal data and reports are not centralized. Some of the reporting parts are done by Finance Department and others are done by the Operational Risk Management (ORM). This issue raises problem in calculation of various ratios and measures.
There is no software specifically modified for Basel II reporting.
Bangladesh Bank’s report submission timeline is not helpful. Many of the reports are to be submitted on the same day but some of them have dependency on each other. In other words, unless the figures and values are calculated on some of the reports, the other reports cannot be prepared. BB wants to get the Quarterly reports within 30 days of quarter end and they are thinking to reduce it to 20 days!
Stress Test report under Pillar 2 is very impractical. This “What If Analysis” and its variables are too rare and extreme occurrences.
There are some unnecessary points and measures that are not very important for judging bank’s sustainability (e.g. Supervisory Haircut Weights, Herfindahl-Hirschman
Index (HHI) calculation for credit concentration, Environmental & Climate Change Risk assessment, and etc).
General discussion and analysis of Findings
Basel II became mandatory for all scheduled banks in Bangladesh since January 2010. It did not take long for the banks to adopt Pillar 1 of the policy. BRAC Bank has been maintaining a little over the minimum CAR ratio. This year is significant because BBL will submit full Basel report to BB with Pillar 2 requirements also. The problems in implementing the requirements in BBL should be mitigated as soon as possible for smooth adoption. Data should be centralized, a program or software should be in place to get the Basel reporting done and banks should be helped more by BB. It is still very early stage for BBL and other banks to fully implement all the policies. So BB can give banks more time to get accustomed to the reporting issues. BB should understand the report dependencies present in banks and should reschedule the report submission dates after candid discussion in SRP-SREP dialogue.
One of the most frequent reports related to Basel II is Stress Test. A report of such importance loses value when it is submitted so soon after the previous one because three months time is a small window to see material change in the variables. Even the variables are tested with unrealistic shocks keeping other variables constant. There are three types of shocks- minor, moderate and major. A combined shock should be applied to see realistic result of the bank’s sustainability rather than applying an extreme shock with keeping all other things constant. So stress test should be a “scenario analysis” rather than a “what if analysis”. It will become very complex but very realistic than current stress test measure.
Even though Banks are following the major guidelines from BB, it will still take 2-3 years to fully adopt the minor and advanced requirements of Basel II. Banks and BB are taking steps slowly to reach full implementation goal.
The international community is now recognizing the importance of effective supervision of banking industry because if this industry is left to act on its own, it can take down the global economy. Basel III is in the making where banks must follow stricter policies and report to the proper authority in more rigor and transparency. Basel II in our country is being followed with enthusiasm and BBL SRP team is gracefully taking every effort to implement Basel II in the bank. Theoretically the 10% CAR should be enough for banks to be shock resilient and fend off adverse business environment in Bangladesh. It remains to be seen in real world whether the adequate capital can save a bank or not. Still there is no harm in maintaining the eligible capital as per BB guidelines and be prepared for any economic disaster. Prevention is better than cure- a proverb the rest of the world is pondering about now.