standardized measurement approach for operational risk...
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Standardized Measurement Approach for Operational RiskConsultative proposals
Caio Ferreira
Monetary and Capital Markets DepartmentInternational Monetary Fund
October 20, 2016
2016 Seminar for Senior Bank Supervisors from Emerging Economies
4
Changing Landscape
Pillar 1
Charges
Credit risk
Market risk
Operational risk
FIRB
AIRB
Internal Models
Standardized
Cred. Standardized
IMM Market Standardized
BIA
TSA / ASAAMA
6
Why Change the OpRisk Charge?
Op Risk Model
Internal Data
99.9 % of the loss distribution
External Data
Scenario Analysis
Internal controls
AMA : No Common Practice
7
Why Change the OpRisk Charge?
Standardized• Not risk sensitive• Counterintuitive results• Bad proxy (gross income)
8
Gross Income vs Business Indicator
Component Gross Income Business Indicator
(2014)
Business Indicator
(2016)
Interest, Lease and
Dividend
Interest Income –
Interest expense +
Dividend Income
Absolute value
(Interest Income –
Interest Expense)
Absolute value
(Interest Income –
Interest Expense) +
Absolute value (net
Lease) + Dividend
Income ; 3,5% NIM
cap
Services (Fee Income – Fee
Expense ) + (Other
Oper. Income – Other
Oper. Expense)
Fee Income + Fee
Expense + Other
Oper. Income + Other
Oper. Expense
Max (Fee Income;
Fee expense) +
Max(Other oper.
income; Other oper.
Expense); 10% cap of
the amount in excess
of the 50% fee share
of BI
Financial Net P&L on trading
book
Absolute value (Net
P&L on trading book)
+ Absolute value (Net
P&L on banking
book)
Absolute value (Net
P&L on trading book)
+ Absolute value (Net
P&L on banking
book)
9
Gross Income vs Business Indicator
Problems:• Impact on certain business models (e.g.
originate to distribute);- Solution: Max (Fee income; Fee Expenses)
• Overcapitalization of banks with high NIM;- Solution: NIM cap set to 3.5%
• Inconsistency in the “dividend income”;- Solution: include dividend income
10
Gross Income vs Business Indicator
Problems:• Overcapitalization of banks with high fee
revenues;- Solution: adjust the BI for banks with high share of
fees. Account for only 10% of the fees above threshold
• Leasing- Include explicitly leasing income and leasing expense
13
Loss Multiplier
Attempt to increase risk sensitivity
Loss Component= 7* Average Total Annual Loss+
7* Average Total Annual loss events above € 10 million+5* Average Total Annual Loss events above € 100 million
Average bank: Loss Component = BI
15
SMA Capital Charge
BI Component ; if bucket 1
SMA Capital =
110 Mln +(BI component – 110 Mln) * lossmultip ;
if bucket 2 – 5.
16
SMA Capital Charge
0
2000
4000
6000
8000
10000
12000
14000
0 5000 10000 15000 20000 25000 30000 35000 40000
loss/BI = 0.5
loss/BI=1
loss/BI = 2
Capital Charge
Business Indicator
17
Minimum Standards for Use of Loss Data
• 10 year observation period (5 during transition)• Map loss events into categories• References dates: occurrence; discovery; accounting• Criteria for assigning loss from centralized function• Recovery as independent event• Include direct charges and incurred costs• Grouped losses• …
18
Impact
On going calibration• Goal: no overall material increase• Banks on lower buckets likely to have reduction