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Briefing

Basel Accords

Critical Issues

Background:

Overview

In response to the 2007-2008 global financial crisis which highlighted a number of weaknesses of the Basel II framework, the Basel Committee for Banking Supervision (BCBS) proposed several reform measures, collectively known as Basel III, which build upon the Basel II requirements, focusing on strengthening the capital, supervision, risk management and risk disclosure of banks. Basel III reform measures were specifically aimed at addressing the causes leading to the 2007-2008 global financial crisis, as identified by the BCBS, such as excess liquidity, excess leverage, insufficient capitalization and inadequate liquidity buffers. In addition, the BCBS also recognized the systemic role of pro-cyclical deleveraging process and interconnectedness of financial institutions in exacerbating the adverse effects of the financial crisis, hence macro-prudential objectives were also taken into consideration under the Basel III framework.

Basel Accords

The Basel Accord, known as Basel I, which is not an enforceable treaty but a series of recommendations regarding capital measurement and standards, was first introduced by the BCBS in 1988. It was progressively adopted by all the BCBS member countries and other countries with internationally-active banks. In response to the new developments in the financial markets and considerable economic turbulence in the financial system since the introduction of Basel I, the BCBS embarked on a modernization of the bank capital framework in June 1999 and published the Basel II framework in June 2004. Since its introduction in 2004, Basel II has undergone several changes. The most recent enhancement to the Basel II framework was the strengthening of risk measurement related to securitizations and resecuritizations exposures, extending capital charges for banking books to trading books and more stringent method for computing market risk in July 2009, known as Basel 2.5.

Evolving from the Basel II framework, the Basel III framework retains the “three pillars” approach – minimum capital requirements under Pillar 1, supervisory review under Pillar 2 and market discipline under Pillar 3. Under Pillar 1, in addition to credit risk, market risk and operational risk, the Basel III framework requires banks to address liquidity risk through a liquidity framework.

For the calculation of credit risk capital charges under Basel II, which concentrates on risks from banking book activities, banks are allowed to use either a standardized approach, as prescribed by the BCBS based on external credit assessment (ie: recognized credit rating agencies), or an internal ratings-based approach, subject to approval of supervisors. Under Basel III, the BCBS had adopted several enhanced measures to strengthen the credit risk measurement, coverage, capital requirements and standards of risk management practices.

Market risk capital charges concentrate on risks from trading book activities. Similar to the credit risk capital charges, banks are allowed to use either a standardized approach or an internal model approach for the calculation. Based on the Basel Committee/ IOSCO Agreement in July 2005, the BCBS had further enhanced the Basel II market risk framework in July 2009 (known as Basel 2.5) and December 2009, by strengthening the risk measurement methodology on incremental risk (default and migration risk) and the associated capital charges on both securitized and unsecuritized products.

The operational risk under Basel II takes into account the risks of loss resulting from inadequate or failed internal processes, people and systems or from external events, these includes legal and regulatory risks, but exclude strategic and reputational risks. Banks are allowed to use one of the three methods for the calculation of capital charges under Basel II, representing a continuum of increasing sophistication and risk-sensitivity – (i) basic indicator approach; (ii) standardized approach; or (iii) advanced measurement approach (AMA). This approach continues to be relevant under the Basel III framework.

Recognizing the importance of sound liquidity management, the BCBS has introduced the measurement, standards and monitoring of liquidity risk under the Basel III framework. Under the liquidity framework, the BCBS specifies two minimum liquidity requirements – (i) the liquidity coverage ratio (LCR), a short-term liquidity ratio defined as the stock of high quality liquid assets over total net cash outflows over a 30-day period, of at least 100% and (ii) the net stable funding ratio (NSFR), which addresses structural maturity mismatches and is defined as the available amount of stable funding (such as equity or liabilities with a maturity horizon over one year) over the required amount of stable funding (such as encumbered, less liquid assets), of at least 100%.

Other Enhancements under Basel III

Tightening Definition of Capital

Basel III tightens the definition of capital by eliminating Tier 3 capital (originally used to cover market risk), harmonizing eligibility of Tier 2 capital instruments and de-recognizing innovative hybrid capital instruments with step-up clauses from the Tier 1 and Tier 2 capital base. Banks will ultimately be required to maintain a minimum 4.5% core Tier 1 ratio (up from 2%) and 6% Tier 1 ratio (up from 4%).

Counter-cyclical Measures

Basel III also introduces several measures aimed at addressing the pro-cyclical effects of the capital requirements, including a capital conservation buffer requirement (for all banks) and countercyclical capital buffer (to be implemented during periods of excessive credit growth, as determined by the national authorities).

Leverage Ratio

Another proposed counter-cyclical measure is the leverage ratio, defined as total capital (sum of Tier 1 and Tier 2 capital) over total exposure (sum of on-balance sheet and off-balance sheet exposure with credit conversion factor). This is to prevent excessive leverage during boom periods; post-crisis system-wide deleveraging often exacerbates the adverse effects of a downturn on asset valuations and macroeconomic stability.

Surcharge for Systemically-Important Financial Institutions (SIFIs)

Basel III requires an additional capital surcharge of 1-2.5%, to be met through common equity of the financial institutions that are deemed to be too big to fail.

Timeline for Implementation

The target date for full implementation of Basel III is January 1, 2019. The enhanced core Tier 1 ratio and total capital ratio will be phased-in between January 2013 and January 2015 while additional capital requirements from the capital conservation buffer will be phased-in between January 2016 and January 2019. The reform measures to the counterparty risk framework, including the extension of capital charges to the trading book, enhanced capital charges for counterparty credit risk and use of stressed-VAR for computation of market risk will be effective as of January 1, 2013. For the minimum liquidity requirements, the BCBS will introduce the final version of the LCR and NSFR requirements on January 1, 2015 and January 1, 2018 respectively, but the observation period will begin in January 2012. For the leverage ratio requirement, the BCBS will be testing a minimum Tier 1 leverage ratio of 3% from January 2013 to January 2017, with the final version to be introduced on January 1, 2018. The BCBS will also phase-in the SIFI capital surcharges between January 2016 and January 2019.

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Associated Readings

Analysis BIS Jan 16, 2009 Revisions to the Basel II market risk framework Analysis Bank for International Settlements June 2006 Basel II: International Convergence of Capital Measurement and Capital Standards: A Revised Framework - Comprehensive Version Analysis Fitch Ratings (free registration) Krishnan Ramadurai et al and Martin Hansen Apr 20, 2009 Basel II's Proposed Enhancements: Focus on Concentration Risk Analysis VoxEU Donato Masciandaro Jan 04, 2009 Basel 3: Supervising the credit giants with progressive capital ratios Analysis EDHEC Noël Amenc and Samuel Sender Dec 17, 2008 The Basel II reform that would have made most injections of public funds unnecessary Analysis Asset Securitization Report Nora Colomer Oct 20, 2008 Changes Loom for Basel II Blogs Research Recap / Oxford Analytica Jul 31, 2008 Basel II Fixes Fail to Grasp Full Scope of Banking Crisis Analysis Fitch Ratings Jul 22, 2008 A Review of Proposed Changes to the European Capital Requirements Directive: the Securitisation Aspects News Bloomberg Banks Fight Revised EU Capital Plan Touching Credit Derivatives Jul 17, 2008 Banks Fight Revised EU Capital Plan Touching Credit Derivatives Analysis Financial Times Gillian Tett Jun 02, 2008 Battered banks face regulators’ harder line on trading books Analysis Review of Banking and Financial Services Mary Fontaine, Jon Van Gorp, Rob Hugi and Babback Sabahi Jul 17, 2008 Synthetic Securitizations Under Basel I And Basel II Opinions Federal Reserve Board Governor Randall S. Kroszner May 14, 2008 Risk Management and Basel II Opinions Financial Times Nout Wellink Apr 10, 2008 Analysis Wall Street Journal Damian Paletta and Alistair MacDonald Mar 04, 2008 Mortgage Fallout Exposes Holes in New Bank-Risk Rules Opinions Financial Times George Kaufman and Harald Benink Feb 27, 2008 Analysis FitchRatings (free login) Bridget Gandy, Krishnan Ramadurai, Peter Tebbutt and Martin Oldham July 2006 Bank Securitisation: IFRS versus Basel II – Risk Transfer Revealed Analysis IMF Speech by Jaime Caruana at Institute of International Bankers' Seminar on Basel II Dec 21, 2007 Basel II and the recent market turbulence Analysis Vox Luigi Spaventa and Alberto Giovannini Nov 05, 2007 Subprime lessons: fix the information gap - Basel II did not prevent credit crisis Analysis Institutional Risk Analyst Christopher Whalen Oct 23, 2007 Basel II: Do Big Banks Need More Capital? Opinions Wall Street Journal David Wessel Aug 30, 2007 Blogs Maverecon Willem Buiter Sep 21, 2007 Basel II: back to the drawing board? Analysis Goldman Sachs Jun 2005 The Basel II Capital Accord (PowerPoint Presentation)