RBI’s 22nd Financial Stability Report –Part II

CA Divakar Vijayasarathy

Research CreditsGracelin LitaCA Jugal Gala

Legends usedAMC Asset Management Companies

BCBS Basel Committee on Banking Supervision

CRAR Capital-to-Risk weighted Assets Ratio

CP Commercial Paper

ECB European Central Bank

ECL Expected Credit Loss

EM Emerging Markets

FBs Foreign Banks

FDI Foreign Direct Investment

Fed US Federal Reserve

FII Foreign Institutional Investor

FSR Financial Stability Report

GDP Gross Domestic Market

HQLAs High Quality Liquid Assets

IASB International Accounting Standards Board

IEA International Energy Agency

LCR Liquidity Coverage Ratio

MFs Mutual Funds

MFI Micro Finance Institutions

MSME Micro, small and medium enterprises

NBFC Non Banking Finance Company

NCD Non-convertible debenture

NPA Non-Performing Assets

NPCI National Payments Corporation of India

OOI Other Operating Income

PBIDTA&OA Profit before Interest, depreciation, tax,amortization and other adjustments

PSBs Public Sector Banks

PSU Public Sector Undertakings

PVB Private Sector Banks

RBI Reserve Bank of India

SCBs Scheduled Commercial Banks

SD Standard Deviation

SDL State Development Loans

SMA Special Mention Account

USD United States Dollar

Presentation Schema

Outlook Macro Stress Tests for SCBs SUCBs and NBFCs

Interconnectedness and Contagion Analysis Regulatory Initiatives Conclusion

Outlook

Overview on 22nd Issue of FSR

In Part-I of the RBI’s 22nd FSR, global and domestic macro-economic developments and actualperformance of scheduled banks was discussed

In today’s session, state of the banking system factoring few stress scenarios and contagion effectsalong with various regulatory initiatives will be discussed

Macro Stress Tests for Scheduled Commercial Banks

Resilience Analysis- The resilience of Indian banking in the face of macroeconomic shocks was tested through macro-stress tests over a one year

horizon under a baseline and two adverse (medium and severe) scenarios.- Implications of regulatory forbearances was also factored in the estimation procedures

The stress tests indicate that the GNPA ratio of all SCBs mayincrease from 7.5% in September 2020 to 13.5% bySeptember 2021 under the baseline scenario and to 14.8%under the severely stressed scenario.

These GNPA projections are indicative of the possibleeconomic impairment latent in banks’ portfolios, withimplications for capital planning.

The system level CRAR is projected to drop from 15.6% inSeptember 2020 to 14.0% in September 2021 under thebaseline scenario and to 12.5% under the severe stressscenario

4/46 and 9/46 select SCBs may fail to meet the minimumcapital level by September 2021 under the baseline scenarioand severe stress scenario respectively, without factoring inany capital infusion by stakeholders

The common equity Tier I capital ratio may decline from 12.4%in Sep-2020 to 10.8% under baseline scenario and to 9.7%under the severe stress scenario in Sep-2021

Projection of SCB’s GNPA and CRAR Ratios

Top-Down Sensitivity Analysis

• A severe shock of 2 SD to the system level GNPA (i.e. the GNPA ratio of 46 select SCBs moves up from 7.6% to13.6%) would result in the system-level CRAR declining from 15.6% to 11.6%

• Bank-level stress test results: If a 2 SD shock is applied to the GNPA ratio, 14 banks with a share of 41.1% inSCBs’ total assets may fail to maintain the required CRAR

• The CRAR would fall below 7% for as many as 11 banks

Credit risk

• Stress tests on banks’ credit concentration with respect to their top individual stressed borrowers showed thatin the extreme scenario of the top three individual borrowers of respective banks failing to repay, the CRARs oftwo banks would fall below 9% and the majority of the banks would experience a reduction of only 10 t 20 bpsin their CRAR.

Credit Concentration Risk

Contd…Sectoral Credit Risk

Sensitivity analysis of bank-wise vulnerabilities due toexposure to sub-sectors within industry reveals varyingmagnitudes of increases in the GNPAs of banks indifferent sectors

A 2 SD shock to the basic metals and metal products andinfrastructure-energy segment, would reduce the systemlevel CRAR by 19 bps and 18 bps, respectively

In an extreme scenarioof a 55% drop in equityprices, the system-levelCRAR would decline by54 basis points

Equity risk

Interest Rate Risk • The market value of the investment portfolio subject to fair value for the sample SCBs stood at `20.9 lakh crore as on end-

September 2020, the highest quarterly balance since March 2017

• About 95% of the investments subjected to fair valuation were classified as available for sale (AFS)

• The sensitivity (PV01)* of the AFS portfolio increased vis-a-vis the June 2020 position at an aggregate level, with FBsregistering a 61.7% increase in PV01 in the quarter

• Robust profit booking across all bank groups was observed in the quarter ended September 2020, although on a lowerscale compared to the June 2020 quarter, possibly due to the rising yield curve movements across tenors

• PVBs and FBs had significant interest rate exposure in their held for trading (HFT) portfolios relative to their AFS books,although PVBs had reduced their PV01 exposure significantly

• An analysis of held-to-maturity (HTM) positions as of September 2020 across bank groups reveals that unrealised gains ofPSBs are almost evenly spread across SDLs and G-Secs while those of PVBs are concentrated in G-Secs

*PV01 is a measure of sensitivity of the absolute value of the portfolio to a one basis point change in the interest rate

Liquidity Risks and Stress Tests on DerivativesPortfolio

• Liquidity risk aims to capture the impact of a run on deposits and increase in demand for unutilised portions ofsanctioned/committed/guaranteed credit lines

• Using their HQLAs required for meeting day-to-day liquidity requirements, 45/46 banks in the sample willremain resilient in a scenario of sudden and unexpected withdrawals of around 15% of deposits, along with theutilisation of 75% of their committed credit lines

Liquidity risks

• The results reveal that while some FBs showed significant negative net mark-to-market (MTM) impacts as aproportion to CET 1 capital, the impact was largely muted in case of PSBs and PVBs

• The stress test results showed that the average net impact of interest rate shocks and exchange rate shocks arein the range of 2.5% of the total capital funds

Sensitivity analyses on derivative portfolios (sample of 20 banks)

Scheduled Primary (Urban) Cooperative Banks and Non-banking

Financial Companies

Performance of SUCBsAsset Quality and Capital Adequacy (at system-level)

Indicator March 2020 September 2020

GNPA Ratio 9.89% 10.36%

Provision Coverage Ratio 61.88% 65.13%

CRAR 9.70% 9.24%

Liquidity ratio 33.95% 34.45%

Stress Test: Credit Risk

• 4 SUCBs had CRARs below 9% even before theshock

• Under a 2SD shock (extreme scenario) to sub-standard assets*, CRAR would decline to 8.90% anda total of 7 SUCBs would fail to achieve the minimumCRAR requirement

• Under a 2SD shock to loss assets**, system levelCRAR declines to 7.51% and a total of 10 SUCBswould fail to maintain the minimum CRARrequirement.

Stress Test: Liquidity Risk

• Stress tests on liquidity carried outunder two scenarios viz., increase incash outflows in the 1 to 28 days’ timebucket by i) 50%, and ii) 100%, withcash inflows remaining unchanged,indicated that 18 and 30 SUCBs,respectively, would face liquidity stress

*Assets which has remained NPA for a period less than or equal to 12 months**Asset which is considered uncollectible and of such little value that its continuance as a bankable asset is not warrantedalthough there may be some salvage or recovery value - which is identified as such by the bank or auditors

Performance of NBFCs

• 4.4% in 2019-20 compared to 22% in 2018-19

Credit growth

• 5.3% in March 2019 to 6.3% in March 2020

Gross NPAs of NBFCs as % of total advances

• Under a high risk shock of 2 SD increase in the system level GNPA (GNPA of the sector increases from6.8% to 8.4%), it is observed that the capital adequacy of NBFCs remained above 15%

• Stress tests at the individual NBFC level indicated that under the baseline, medium and high riskscenarios, CRAR of 3.3%, 9.7% and 10.3% of NBFCs would fall below the minimum regulatoryrequirements

Stress Tests

Interconnectedness and Contagion Analysis

Network of the Financial System• SCBs, followed by NBFCs continued to have the largest bilateral exposures in the Indian financial system in

September 2020

• Among bank groups, PSBs had a net receivable position vis-à-vis the entire financial sector, which increasedduring the last one year.

• On the other hand, PVBs had a net payable position, which declined y-o-y.

• In terms of inter-sectoral exposures, AMC-MFs were the biggest fund providers in the system, followed byinsurance companies, while NBFCs were the biggest receiver of funds, followed by HFCs.

• AMC-MFs recorded a significant decline in their receivables from the financial system during the last one year,while the same increased for PSBs and insurance companies, who were the other major fund providers

Mutual Funds

- Income/debt-oriented schemes attracted the major share of the inflows (`1.2 lakh crore) whereas growth/equity-orientedschemes accounted for a relatively meagre amount (`2,496 crore)

- The mutual fund industry’s AUM increased by 10.9% at the end of November-2020- During April–September 2020, the number of folios of Systemic Investment Plans (SIPs)* increased by 22 lakh

*A systematic investment plan is an investment vehicle offered by many mutual funds to investors, allowing them toinvest small amounts periodically instead of lump sums

Inter-Bank Market

The share of fund-based inter-bank exposuresin the total assets of the banking systemdeclined during the first half of 2020-21(Rs.4.8 lakh crores to Rs.4 lakh crores), inkeeping with past trends, due to excessliquidity in the banking system.

Non-fund-based inter-bank exposuresdeclined marginally (Rs.1.2 lakh crore in Mar-2020 to Rs.1.1 lakh crore in Sep-2020)

PSBs remained the dominant players in theinter-bank market, although their sharecontinued to decline and stood below 50%during H1:2020- 21 while that of PVBs (33% to33.5%) and FBs grew (16.6% to 17.4%)

The degree of interconnectedness in thebanking system (SCBs), as measured by theconnectivity ratio, has edged up in September2020 after gradual decline over the last fewyears. (19.7% in March-2020 to 20.2% in Sep-2020)

Trends in Inter-Sectoral ExposureGross Receivables of AMC-MFs

Instrument-wise, AMC-MFs’ receivables saw a sharpincrease in the share of equity funding during H1:2020-21

Gross Receivables of Insurance companies

LT debt and equity accounted for almost all thereceivables of insurance companies

Gross Payables of AIFIs

These funds were provided mostly by the way of LT debt, LTdeposits and CD

Exposure to NBFCs and HFCs

- NBFCs obtained more than half of their funding fromSCBs, followed by AMC-MFs and insurance companies

- During H1:2020-21, the choice of instruments in theNBFC funding mix reflects an increasing preference forLT debt from SCBs which, inter alia, reflects thesupport through TLTRO

- HFCs’ borrowing profile was largely similar to that ofNBFCs, except that AIFIs played a significant role inproviding funds to HFCs

Contagion Analysis

Contagion analysis uses network technology to estimate the systemic importance of different banks.

A contagion analysis of the banking network based on the end-September 2020 position indicates that if the bank with themaximum capacity to cause contagion losses fails, it will cause a solvency loss of 2.5% of total Tier 1 capital of SCBs andliquidity loss of 0.5% of total HQLA of the banking system

The failure of a systemic NBFC can knock off 2.26% of the banking system’s total Tier 1 capital but it would not lead tofailure of any bank (it would be 5.92% in case of failure of a similar HFC)

The contagion impact of the failure of an institution is likely to be magnified if macroeconomic shocks result in distress in thebanking system in a generalised downturn in the economy

Initial capital loss due to macroeconomic shocks stood at 8.36%, 12.39%, and 17.25% of Tier 1 capital for baseline, mediumand severe stress scenarios, respectively.

The number of banks that fail to maintain Tier I adequacy ratio of 7% in the face of shocks ranged between three in thebaseline and five in the medium stress scenario to eight in severe stress scenario

Regulatory Initiatives

International Regulatory Developments

• The BCBS announced that banks could use their capital buffers during the crisis to absorb financial shocksand to support the real economy by lending to creditworthy households and businesses.

• It also encouraged supervisors to allow banks sufficient time to restore buffers, taking account of economicand market conditions as well as bank-specific circumstances

Capital

• The BCBS signaled that it was acceptable for banks to draw down their buffers of HQLA securities to meetunforeseen liquidity demands

• The ECB committed to allow banks to operate below the LCR until at least end-2021 without automaticallytriggering supervisory actions

Liquidity

• The IASB clarified that entities should opt for disclosures rather than applying their existing ECL methodologymechanically to borrowers in particular classes of financial instruments assuming significant increase incredit risk only due to moratorium

ECL Provisioning

• To manage potential vulnerabilities on customer identification due to increased use of online services, theFATF issued a paper recommending the inclusion of money-laundering measures in policy responses.

Operational risks

Initiatives from Indian Regulators

One-time loan restructuring for eligible borrowers

Emergency Credit Line Guarantee Scheme (1.0 and 2.0) under ‘Atma Nirbhar Bharat Abhiyan’ package.

Setting up of a SPV to purchase short-term papers from eligible NBFCs/HFCs, which could then utilise the proceeds toextinguish their existing liabilities. The special securities issued by the SPV were guaranteed by the Government of India andwould be purchased by the Reserve Bank.

Multi-lingual awareness campaigns on safe digital banking

Extension of deadline upto March 24, 2021 for suspension of initiation of the corporate insolvency resolution process(CIRP) of a corporate debtor for any default arising on or after March 25, 2020

Corporate Insolvency Resolution Process

- The manufacturing sector accounted for the largest share in the number of CIRPs admitted- Realisation by creditors under resolution plans in comparison to liquidation value stood at 185.2%, while the realisation

was 43.6% in comparison to their claims- Out of the CIRPs closed, nearly half yielded orders for liquidation

Other Regulatory Developments

• It recognises bilateral netting for all qualified financial contracts entered into between qualified financialmarket participants, and also ensures the enforceability of collateral associated with the contract

Bilateral Netting of Qualified Financial Contracts Act, 2020

• Launch of RTGS 24x7x365 from December 14, 2020. The RTGS presently handles around 6 lakhtransactions daily for a value of around `4 lakh crore across 237 participant banks with the average ticketsize of `57.96 lakh (November 2020)

• Work is being undertaken by NPCI to strengthen the international presence of RuPay cards and buildinter-regional partnerships to enhance foreign inward remittances to India using the UPI

• Supervisory Framework for payment system operators has been modified wherein the Central Bank aslaid down the point of arrival (PoA) and performance metrics (PM) to assess and monitor paymentsystems and participants

Payment and Settlement Systems

• The IBA as been tasked with working out the step-by-step transition plan with regard to LIBOR cessation

Libor Transition

Conclusion

Though the pandemic support packages have kept the financial system smoothly functioning, the same have to beunwound in a calibrated manner with minimal disruption to restore the prudential norms to pre-pandemic levels

Cushions in banks’ balance sheets will have to contend with the rollback of regulatory forbearances

In the non-bank space, the dominant positions occupied by mutual funds and insurance companies needs to be assessedagainst the fact that NBFCs and HFCs remain the largest borrowers, with systemic implications

Meanwhile, shrinking of the inter-bank market has reduced the risk of bank failure due to contagion effects

Challenges in LIBOR transition have to be handled properly by a robust framework

Thank You!

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