12
Risk Management and Basel II

12.1 INTRODUCTION

Basel II is primarily a set of guidelines (framework) for the supervision of capital. Most banks use an internal rating-based (IRB) approach to determine credit risk based on borrowers’ probability of default. During economic downturn losses on defaults are often greater than normal. Many banks seek to assess loss given default (LGD) on an exposure-byexposure basis (risk on a loan-by-loan basis). Most banks do not as yet assess risks on a portfolio basis.
In the banking world, there is a variety of practice with respect to the risk rating process, ranging from systems almost purely driven by statistical models, like credit scoring, to those based almost exclusively upon judgement. Generally three broad process categories can be discerned, according to the degree to which the risk rating is a product of mathematical models or of decisions of judgement (Grupo Santander 2000):
• ‘Statistical-based processes’
• ‘Constrained expert-based judgement processes’
• ‘Expert-based judgement processes’.
Credit risk is the risk of loss from the failure of a borrower to meet debt servicing and other payment obligations on a timely basis. Because there are many types of borrowers (individuals, small businesses, large businesses, sovereign governments and projects using project finance) and many types of facilities, credit risk takes many forms. However, there is a clear consensus that the credit risk associated with a loan depends on:
• credit exposure
• maturity
• default probability during that period and
• likely severity of loss if default occurs.
* Reproduced by permission of A. Merna.
In order to measure the credit risk, financial institutions have to estimate adequately:
• the probability of default (PD) related to the borrower
• the loss given default (LGD) related to the facility.
It is considered by many practitioners that the most appropriate way to estimate PD and LGD is to start with external data and adapt it progressively to the financial institution’s needs and environment.
For corporate lending, most rating systems are based on quantitative and qualitative evaluation. More and more financial institutions adopt a two-tier rating system. Firstly, a borrower risk rating linked to the probability of default concept. Secondly, a facility risk rating linked to the loss given default concept. Facility risk rating (FRR) depends on the seniority of the facility and the quality of the securities.
At this stage the links between risk rating, provisioning and capital charges are discussed.
The pricing is calculated as follow:
P = CM + O + CMR + S
where:
P = Pricing
CM = Cost of fund
O = Overhead cost (generally includes all cost related to credit management but excludes specific overhead cost related to facilities and monitoring that are supported by fees)
CMR = Cost of maintaining credit risk based on PD and LGD, and
S = Desired net spread as determined by top management of the financial institution.
The cost of fund is the total of cost of debt and cost of capital. The cost of debt is the borrowing cost paid to acquire fund on the market, such as client’s deposits or borrowing from other financial institutions. The cost of capital is the rate of return required by shareholders, which should be risk adjusted return on capital.
The cost of fund depends on reserve requirement, diversity and availability of funding channels, the base lending rate and the risk related to the financial institution. It needs to be assigned to lending activities.
In the financial world, to correctly price loans and other credit products is paramount to the lender’s success. If a financial institution prices its loans too low in relation to the risk associated with the loans, its financial strength will deteriorate and this could affect its survival over time. At the opposite end, if the financial institution prices its loans too high, its competitiveness will deteriorate which would also affect its survival over time.
This chapter outlines the principles behind risk pricing and corporate lending. The concepts of probability of default, loss given default, provisioning, capital charges, pricing and cost of funds, the risk rating system and the methodology to apply the risk rating system are also discussed.

12.2 RISK RATING SYSTEM (RRS)

Hempel and Simonson (1999) state:
Most banksuse a riskrating system to measure the risk of their loans because Most banks use a risk rating system to measure the risk of their loans because risk rating forces the loan personnel to quantify the risk perceived in their loans.
RRSs are based on both quantitative and qualitative evaluation. The final decision is often based on an amalgam of many different items. The systems can be based on general considerations and on experience, but seldom on mathematical modelling. They also often rely on the judgement of the ratings evaluators.
Globally, more and more commercial banks and other financial institutions adopt a two-tier rating system as a requirement of the Basel Committee on Banking Supervision (2004). The system is composed of a borrower risk rating (BRR) linked to the probability of default concept and a facility risk rating linked to the loss given default concept. FRR depends on the seniority of the facility and the quality of the security.
Worldwide, the key issue for financial institutions is obtaining the right information and reliable data on borrowers or the borrowers’ exposure. The credit analyst must assess the information available (data collection) in order to assess the risk. This is why analysts require experience and expertise to identify both reliable and unreliable data. Similarly it is difficult to rely on an automatic scoring system for larger borrowers.

12.2.1 Concept of Probability of Default

Credit risk exists in every credit engagement, and credit loss expenses must be expected as an inherent cost of doing business. Estimating PD is the first step in the process of calculating the probability of loss. The key element in PD estimation is the definition of default. The Basel Committee on Banking Supervision defined (New Basle Accord, 2004, p. 80):
A default is considered to have occurred with regard to a particular obligor when either or both of the two following events have taken place:
The bank considers that the obligor is unlikely to pay its credit obligations to the banking group in full, without recourse by the bank to actions such as realising security (if held). The elements to be taken as indications of unlikeliness to pay security (if held). The elements to be taken as indications of unlikeliness to pay include:
The bank puts the credit obligation on non-accrued status.
The bank makes a charge-off or account-specific provision resulting from a significant perceived decline in credit quality subsequent to the bank taking on the exposure.
The bank sells the credit obligation at a material credit-related economic loss.
The bank consents to a distressed restructuring of the credit obligation where this is likely to result in a diminished financial obligation caused by the material forgiveness, or postponement of principal, interest or (where relevant) fees.
The bank has filed for the obligor’s bankruptcy or a similar order in respect of the obligor’s credit obligation to the banking group.
The obligor has sought or has been placed in bankruptcy or similar protection where this would avoid or delay repayment of the credit obligation to the banking group.
The obligor is past due more than 90 days on any material credit obligation to the banking group. Overdrafts will be considered as being past due once the customer has breached an advised limit or been advised of a smaller than current outsanding.
The easiest method of PD estimation is based on historical data, where estimates are made for each rating grade. This data could be built internally and/or taken from external sources. However, for a specific internal RRS, it is preferable for a financial institution to build its own database that corresponds to its environment and specific market involvement. The PD does not include a loss component but only the number of defaults within a given time period. Basel II requires estimating one year PDs based on long maturity average (minimum five years).
The formula is:
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12.2.2 Concept of Loss Given Default (LGD)

LGD is usually defined (Basel Committee on Banking Supervision 2004) as the ratio of losses to exposure at default. Once a default event has occurred, loss given default shall normally include three types of losses:
• the loss of principle
• the carrying costs of non-performing loans, for example interest income foregone and
• workout expenses (collections, legal).
LGD is not attributed to the borrower but to the facility. The loss is linked to the maturity of the facility (seniority) and the security that supports the loan.
Most financial institutions adopt the dual method to estimate LGD. For acceptable (from very low to moderate) risk rates, they attribute to each security and to each maturity a LGD estimate based on historical data. Basel II requires estimating one year LGD based on long maturity average (minimum seven years).
For high and very high risks, LGD becomes specific and usually takes into consideration:
• realisation value of the security that supports the loan (RVG)
• workout expenses including legal fees and collections (W)
• outstanding balance of maturity loans or the approved amount of credit lines (OL) and
• carrying costs of non-performing loans such as interest income foregone (CC).
The formula can be expressed either in:
• in absolute terms: LGD = (OL + W + CC) − RVG or
• in percentage terms: LGD = ((OL + W + CC) − RVG)/OL 100%.
In order to keep LGD estimates up to date, financial institutions should monitor the value of the collateral on regular intervals, at minimum once a year. More frequent monitoring is suggested where the market is subject to significant changes in conditions or hysteresis in the currency markets. A qualified analyst could evaluate the collateral when market news indicates that the value of the collateral may decline materially relative to general market prices or when a credit event, such as default, occurs.

12.2.3 Database

It is important for a financial institution to start building a database in order to estimate PD and LGD adequately. This database should correspond to BRR (PD) and FRR (LGD). Except for major banks in the global market, most financial institutions do not have data categorised by risk rates. They usually rely on external data such as Moody’s or Standard & Poor to estimate their PD and LGD. Most financial institutions build internal databases so as to be more precise with their future estimation. In general, the longer the period and the bigger the customer number the database covers, the better the estimation of PD and LGD. In particular, if the database records the evolution of at least one complete economy cycle including recession in a local market, it will provide representative information for the institution.

12.3 BORROWER RISK RATING SYSTEM AND PROBABILITY OF DEFAULT

Analysing a borrower’s risk means estimating the likelihood that this borrower will default on its obligation over a specified period.
The rating process includes quantitative, qualitative and legal analyses. The quantitative analysis is mainly based on the client’s financial report. The credit analyst should analyse the financial strength of the borrower in order to determine if cash flow is sufficient to cover its global debt. Then the asset’s quality and the liquidity position of the borrower are analysed in order to determine whether or not the borrower’s organisation could survive in an unexpected difficult situation such as economic recession (robust finance).
The qualitative analysis is mainly about the quality of management, the organisation’s competitiveness within its own industry and its vulnerability to changes in technology, labour relations and regulatory changes. Regarding the industry, the analyst should take into account the environment and characteristics of the industry to which the borrower belongs, and the position of the borrower within this industry. The analyst should also consider the macro-economic situation and its eventual impact on the client. Finally, the analyst should identify the authenticity and legality of the establishment of the borrower through a legal analysis.

12.3.1 Facility Risk Rating and Loss Given Default

After identifying the borrower’s risk, the analyst should assess the facility risk. The way the facility will be structured depends to a large extent on the borrower’s risk. The facility risk rating depends on the maturity of the facility and the quality of the security to support the loan. In project financings by using project finance the facility risk rating will be determined by the strengths of the revenue generation streams since there will be no or limited recourse to the borrower’s assets.
It should be borne in mind that a strong security (or collateral) does not improve the borrower rating since it has no (or very low) impact on the probability of default. Therefore, if the BRR is not acceptable as per the financial institution’s policy, no security could deter a reject decision. The only exception to this rule is the cash collateral where the loan is fully secured by a cash deposit or equivalent. However, security serves only as a mitigating factor given the BRR is acceptable.
The maturity of the facility also contributes to the FRR, i.e. the longer the maturity the riskier it becomes.

12.3.2 Expected Loss

The expected loss (EL) is therefore:
EL = PD × EAD × LGD
PD = Probability of default
EAD = Exposure at default – the outstanding balance of maturity loans or the approved amount of line of credit (revolving)
LGD = Loss given default
The manner by which the EAD (exposure at default) is assessed is closely related to the nature of the loan facilities. For a term loan, a financial institution might calculate its EAD as the outstanding balance on the loan at the time of default. If the financial institution has extended a line of credit to a firm but none of the line has yet been drawn down, the immediate EAD is zero, but this doesn’t reflect the fact that the firm has the right to draw on the line of credit. Indeed, if the firm gets into financial distress, it can be expected to draw down on the line of credit prior to any bankruptcy. A simple solution is for the bank to consider its EAD to be equal to the total line of credit.

12.4 RISK RATING AND PROVISIONING

Basel II requires total provisions to be equal to total expected losses. This means that provisions are made to cover expected losses (EL). For every FRR there is an EL attached to it. Therefore, financial institutions should make provisions corresponding to the EL attached to each FRR.
In the case of a lack of reliable data on expected losses, financial institutions normally take two types of provisioning: general and specific. Specific provisions are made for losses recognised at the balance sheet date. A loss is recognised when the financial institution considers that the creditworthiness of a borrower has undergone such deterioration that the financial institution no longer expects to recover the loan advance in full. Regarding general provisions, they should be for advances already impaired but not yet identified as such. In order to protect the financial institution’s capital base from the damage of these losses, the financial institution shall pre-set proper provisioning proceeds as the ‘buffer’, which is usually from the interest income of each loan.

12.4.1 Risk Rating and Capital Charges

The management of a financial institution will usually take its capital as the financial resources available to absorb unexpected losses (UL). The increasing competition on the financial market exposes financial institutions to increasing risk. Thus, the capital becomes more important as a buffer against losses. The more risk a financial institution takes, the more capital it will need. This is described as risk-adjusted capital. For Basel I, the risk-adjusted capital ratio (RACR) is calculated as follows:
RACR = Capital/Risk-adjusted assets ≥ 8%
Risk-adjusted assets are calculated by applying risk-based weights to specific assets and summing the results.
Nowadays, Basel II (Basel Committee on Banking Supervision 2004) adopts more or less the same philosophy but introduces a new risk factor, the operational risk. The equation now becomes:
RACR = Capital/(Operational risk + Market risk + Credit risk) ≥ 8%
In both cases capital has to be adjusted to risk taken by the financial institution. This means that for each risk rate, a certain percentage of capital should be assigned as risk weight. For example, the capital required for BRR 1 is 20%, for BRR 2 is 25% and for BRR 10 is 90%.
This concept considerably affects the pricing. The cost of funds included in the pricing is defined as the total cost of debt and cost of capital. The cost of capital is the rate of return required by shareholders. The capital is a buffer against losses. Therefore the return on capital should be risk adjusted return on capital (RAROC).
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Expected losses represent expected losses from defaulting loans; capital is simply held as a buffer against losses and is presumably invested in some free risk instrument. Therefore we should reflect the extra income from that investment.
In project finance initiative (PFI) projects, for example, in a project scoring 3 on a 1 to 7 grading (which is usually the case) for every drawn pound, a pound has to be put away, and for every undrawn pound loaned 75 pence has to be put away. Previous to Basel II for every pound drawn, a pound had to be put away and for every undrawn pound loaned, 50 pence had to be put away. This was usually across the board irrespective of whether the loan was lending to junk or safer assets such as PFI projects. In effect PFI assets were discriminated against.
Although for Credit Grade 3, as cited in the above example, the undrawn is 25 pence more under Basel II, it is the corporate lending that suffers since the PD/LGD is much higher for corporate lending since you may only get back 12 pence in the pound under a default situation.

12.5 RISK RATING AND PRICING

After the risks have been identified and the decision to grant the credit has been made, it remains to integrate the credit decision to the pricing system. The pricing has to take into consideration the cost of maintaining credit risk (CMR). CMR represents the expected loss and the accompanying cost of carrying such losses for each type of borrower and facility. According to Hempel and Simonson (1999):
P = CM + O + CMR + S
where:
P = Pricing
CM = Cost of funds
O = Overhead costs (generally includes all cost related to credit management but excludes specific overhead cost related to facilities and monitoring that are supported by fees)
CMR = Cost of maintaining credit risk based on PD and LGD
S = Desired net spread as determined by top management of the financial institution
The cost of the fund is the total of cost of debt and the cost of capital. The cost of debt is the borrowing cost paid to acquire the fund on the market such as client’s deposits or borrowings from other financial institutions. The cost of capital is the rate of return required by shareholders. Considering the capital is expected to work as the buffer against unexpected losses, the return on capital should be risk-adjusted return on capital.
The cost of the fund depends on reserve requirement, diversity and availability of funding channels, the base lending rate and finally the risk related to the financial institution itself. Northern Rock recently got into financial difficulties because interbank loans margins increased due to liquidity issues (uncertainty in the market). The cost of borrowing increased dramatically and the bank had to rely on the Bank of England to resolve the short-term cash flow issues. It is important to note that Northern Rock is a profitable organisation; further enhancing the importance of cash flow management.

12.5.1 Interest Rate and Fees

Generally, the income of a financial institution from a loan is composed of two parts: interest and commitment fees. Interest is the primary revenue source.
Commitment fees on loan facilities are usually the secondary income resource for a financial institution. They are supposed to cover specific overhead costs related to facilities and monitoring.

12.5.2 Managing Liabilities and the Cost of Funds

The cost to a financial institution to attract funds in the money market will be justified according to the risk profile of the financial institution’s credit assets portfolio. Many banks attempt to measure their profitability by credit product lines; these being small business, large enterprises and consumers. Each credit product line will be deemed as a profit centre with its own balance sheet and income statement. Therefore, the financial institution’s management shall assign a cost of fund to each of the credit product lines, which is called ‘internal transfer price’ including all costs in relation to raising funds on the money market such as interest and administrative costs, desired return on equity and overhead cost related to general credit management (senior management, risk management and portfolio management). The specific overhead cost related to facilities and monitoring is usually supported by fees, and therefore not included.
This internal transfer pricing is usually calculated by the treasury department in a bank. Hempel and Simonson (1999) summarised that most banks use a matched maturity framework that assigns rates by identifying the effective maturity of assets and assigning a rate obtained from a liability of the same maturity.

12.6 METHODOLOGY OF RRS AND RISK PRICING

A typical risk rating system (RRS) will assign both a BRR to each borrower or a group of borrowers and a FRR to each available facility. An RRS is designed to express the risk of loss in a credit facility and then to price this risk loss.
A good RRS should offer a carefully designed, structured and documented set of steps for the assessment of each rating. Therefore, an RRS should incorporate a comprehensive and standardised grid analysis. The goal is to generate accurate and consistent RRS, and also to integrate professional judgement to the rating process. Normally, a risk rating methodology (RRM) initiates a BRR that identifies the expected PD of that borrower (or group) in repaying its obligations in the normal course of business. Then, the RRS identifies the risk of loss by assigning an FRR to each credit facility granted to a borrower. RRS quantifies the quality of individual facilities, credits and portfolios. If an RRS is accurately and consistently applied, they provide a common understanding of risk levels and allow for active portfolio management. An RRS also provides the initial basis for capital charges used in various pricing models. It can also assist in establishing loan reserves. In order to keep the rating system consistent with the credit migration, the definition of every rating has to be reviewed at least once a year.
Table 12.1 BRR rating sheet
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12.6.1 Example of a Risk Rating System

12. 6.1.1 BRR – borrower Risk Rating

• A risk rate is assigned to each customer and should be reviewed at the frequency decided by the BRR rate (a higher rate implies more frequent reviews) (Table 12.1).
• It is based on a scoring system from 0 to 100. This scoring system is based on both qualitative and quantitative evaluation.
• New customers’ loan requests should only be accepted with a BRR not worse than 5.

12.6.1.2 Review Process and Early Warning Signals

Like most of the rating systems, the above model adopts the point-intime approach. It means that BRR is established according to borrower’s current condition. This condition could change at any time. The review process is the adequate answer to update the BRR rating. The review frequency and review date are based on the RRS – the higher the risk (BRR), the more frequent the review.
In addition, a clear early warning signal process is incorporated in the model. The early warning signal process is the tool that helps the financial institution to track risk profile changes of the borrower between two reviews. Many studies have confirmed that a high percentage of avoidable losses might have been reduced or avoided had early warning signals been recognised and heeded, and remedial action been initiated in a timely manner.

12.6.1.3 Facility Risk Rating

PD is estimated on 5 year basis. That is why there is no adjustment to make for the medium term (MT). Rates should be upgraded by 1 for short term (ST), and degraded by 1 for long term (LT). Example: if the FRR is originally 5, with ST it becomes 4 and for LT it becomes 6 (Table 12.2).
In the case of multiple collaterals being provided for one facility, the credit analyst should score the higher rate if, at least, one collateral is within the percentage financing parameters. Otherwise it should score the lowest rate.
Table 12.2 FRR rating sheet
075
076

12.7 GRID ANALYSIS OR STANDARDISING THE RISK ANALYSIS

Almost every bank has developed their own grid analysis tool as per their specific conditions. In this chapter, a very basic but clear analysis model ‘CAMP’ is discussed which is a very good analysis tool for banks in developing countries.
For every customer credit analysis, the financial institution needs to recognise the importance of the quality of the financial information initially provided. The information provided must always fully satisfy the quality, adequacy and reliability of the financial statement. The size and reputation of the accounting firm shall be inline with the size and complexities of the borrower and its financial statement.
Then, the credit analyst can analyse the borrower via the ‘CAMP’ model. CAMP refers to Cash (financial analysis), administration (management), market, and production. The analyst shall evaluate the borrower on these four aspects and compute a score. The resulting score will fall into a BRR rating range. The analysis should also be done according to the industry and current trend. The scoring can be distributed as follows:
• Cash counts for 60% of the scoring:
• Liquidity position – 10%
• Financial structure – 10%
• Debt servicing capacity – 25%
• Loan structure and covenants – 10%
• Others – 5%
• Management for 15%:
• Market for 15%
• Production for 10%.
Based on the BRR rating, the analyst can estimate the LGD based on the facility structure, collateral arrangement and the tenor of the loan.

12.7.1 Risk Pricing Based on RRS – Sample Calculation

As seen previously the pricing (P) is calculated as follow:
P = CM + O + CMR + S
Examples:
Company X is rated BRR ‘4’ and has three loans:
1. A short maturity loan of $10 millions collateralised by receivables estimated at $16 millions.
2. A medium maturity loan of $20 millions collateralised by commercial mortgage estimated at $45 millions.
3. A long maturity loan of $20 millions collateralised by equipments estimated at $40 millions.
BRR ‘4’ = PD of 1.2%
1. Short maturity loan: Receivables = FRR ‘6’; adjustment for the maturity: FRR becomes ‘5’; % financing is 62.5% (within parameters); LGD = 50%.
Pricing should be: P = CM + (1.2% * 50%) + S = CM + O + 0.60% + S
2. Medium maturity loan: Commercial mortgage = FRR ‘4’; no adjustment for the maturity; % financing 44% (within parameters); LGD = 40%.
Pricing should be: P = CM + (1.2% * 40%) + S = CM + O + 0.48% + S
3. Medium maturity loan: Equipment = FRR ‘5’; adjustment for the long maturity: FRR becomes ‘6’; % financing is 50% (within parameters); LGD = 60%.
Pricing should be: P = CM + (1.2% * 60%) + S = CM + O + 0.72% + S
As a condition to approve the above three facilities, the credit officer will require the relevant bank loan officer to add 0.6%, 0.48% and 0.72% respectively into the facility rate as the contribution to the bank’s ‘cushion’ against the expected loss from its loan portfolio, or to deduct the risk margin from the bank’s profits forecast over these facilities in order to have a risk-adjusted return rate.

12.8 REGULATION IN OPERATIONAL RISK MANAGEMENT

Managing risk and compliance has become an area of major spend in most financial institutions.
The two main regulations in operational risk management have been the Basel Accord which has evolved over time to the new Basel II and the Sarbanes-Oxley Act of 2002. Together they are dominating headlines and giving a lot of compliance headaches to financial institutions, especially US banks. Some critics have questioned whether the two are in conflict.

12.8.1 Basel II

The Basel Committee on banking supervision notes that management of specific operational risks is not a new practice; it has always been important for banks to try to prevent fraud, maintain the integrity of internal controls and reduce errors in transaction processing. However, what is relatively new is the view of operational risk management as a comprehensive practice comparable to the management of credit and market risk in principle, if not always in form.
The committee defines operational risk as the risk of direct or indirect loss resulting from inadequate or failed internal processes, people and systems or from external events. This includes legal risk but excludes strategic and reputation risks, although a significant operational loss can affect the reputation of an organisation.
In mid 2004, after a protracted period of consultations, the Basel Committee finally released its definitive proposals on capital charges for operational risk under Basel II. In its proposals it allows internationally active banks to calculate regulatory capital using their own internal models. It therefore has moved away from its original focus on quantitative techniques. It now concentrates on qualitative standards for operational risk management (ORM) systems.
Under Basel II, financial institutions must implement an operational risk management system with an independent operational risk management function responsible for developing and implementing ‘strategies, methodologies and risk reporting systems to identify, measure, monitor and control/mitigate operational risk’ (Basel Committee on Banking Supervision 2004). To comply with these requirements the ORM system must also be capable of being validated or reviewed regularly by internal and/or external auditors and be seen to ‘have and maintain rigorous procedures’.
The Basel II Accord provides three methods for calculating operational risk capital charges:
• the basic indicator approach
• the standardised approach
• the advanced measurement approach (AMA).
Basel II prescribes two major criteria for assessing risks using AMA. For each business line/risk type, a bank will have to provide an exposure indicator (EI), probability of loss event (PE) and loss given event (LGE). Salcanda-Kachale (2007) states that one good thing about the AMA approach is that a bank can use its own internal loss data to show the regulators that – thanks to sound risk management – it should benefit from a further reduced charge. This reduction, though, will be subject to a floor for at least the first two years.
To qualify to use the AMA approach to calculate operational risk under Basel II, a bank must meet stringent ‘qualitative standards’ (Basel Committee on Banking Supervision 2004) those being:
• an independent operational risk management function
• an operational risk measurement system that is closely integrated into the day-to-day risk management processes of the bank
• regular reporting of operational risk exposures to business units, senior management and the board, with procedures for appropriate action
• The operational risk management system must be well documented
• regular reviews of the operational risk management processes/systems by internal and external auditors
• validation of the operational risk measurement system by external auditors and/or supervisory authorities, in particular, making sure that data flows and processes are transparent and accessible.
To qualify to use the AMA approach, Basel also states that a bank’s measurement system must also be capable of supporting an allocation of economic capital for operational risk across business lines in a manner that creates incentives to improve business line operational risk management.
The accord also provides three methods of calculating reserve requirements:
• Firms may use what regulators enforce, that is: holding up to 12% of gross revenues in reserves-a burden on working capital efficiency.
• They can allocate a different percentage of reserves by segregating their lines of business based on the type of activity.
• They can use the Active Management Approach (AMA), which motivates them to proactively manage operational risk in return for reduced reserves.
Firms are required to analyse their historical losses and other key risk indicators on a regular basis, justify their level of controls, and develop a model for assessing the correct amount of reserves. Although compliance was expected to be by the end of 2006, the real deadline was before that date. Approval under AMA requires three years of historicalloss data and up to two years of running a parallel model to prove to regulators that effective risk management is tightly in place.
There are issues raised on the lack of clear direction in developing approaches to managing operational risk and for supervisors in standardising these approaches.
Patrick McConnell (2004) outlines some of the questions arising due to the lack of clarity, including:
• What would a conceptually sound ORM system look like?
• How can regulators compare one bank’s ORM system with another and how can operational risk charges be compared?
• What can a bank use to allocate economic capital across its business units to satisfy the Basel qualitative standards for being integrated into the day to day risk management processes of the bank?
Spielman (2004) contends that Basel II faces many obstacles in the US, as well as other areas of the globe. Questions on the capital charges, and the methodology used to derive them, are growing more persistent. There is the ‘home-host’ issue over regulatory co-operation and trust that does not appear to be going away soon. In addition, he reports three specific concerns for US financial institutions:
Regulatory Clarity – the main U.S. regulators have disagreed over Basel II’s approach to capital charges and methodologies, which have made the waters murky. An agreement was reached which initially subjects only the top ten US internationally active banks to Basel II.
Cost – cost estimates on implementing the Basel II AMA approach could be formidable. In addition, Sarbanes-Oxley has taken centre stage in the US. ‘SOX’, as it is affectionately known, is a US law and carries stiff legal consequences (fines and prison) for non-compliance. It is rooted in a widely accepted self-assessment methodology (COSO). Monies that previously were ear-marked for operational risk are in some cases going to ensure SOX compliance.
Focus – Basel II has experienced delays, which has left some waiting for the final recommendations in order to fully comprehend the impact it will have on their institution. To the Basel Committee’s credit, these delays have helped them obtain industry feedback, resulting in improved recommendations.
However, Spielman counterargues that regardless of the Basel II challenges, it has been monumental in energising operational risk management efforts around the globe, and that the issues, though formidable, will be worked out as more people develop practical methodologies that make sense to their businesses and regulators.
Spielman continues to argue that, whether financial institutions agree with Basel II or not, they would be hard pressed to dispute the benefits of some key components of the AMA, which improve how they manage their institutions. For example, self-assessment is a proven vehicle to building a better risk management culture that helps facilitate transparency from top to bottom. Most business managers will see the value of gaining a greater understanding of how their people, processes, technology and other risk may impede their business goals. Tracking losses and non-financial events that can impact business goals is a great indicator of control effectiveness, and can trigger questions about when trends start to shift in the wrong direction. Audit is essential to the process, and considering audit’s input helps to present a balanced view of risk.

12.9 SUMMARY

This chapter has outlined the basic concepts in credit risk management and introduced the most commonly used risk evaluation tool, the risk rating system. Based on the application of the RRS, a simple loan pricing model was discussed. The need to address the requirements of Basel II in terms of PD/LGD to the risks associated with a loan are paramount to the banking industry.
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