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CAIIB – Super-Notes © M S Ahluwalia Sirf Business Supervisory Review Module D: Balance Sheet Management

CAIIB Super Notes: Bank Financial Management: Module D: Balance Sheet Management: Supervisory Review

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Page 2: CAIIB Super Notes: Bank Financial Management: Module D: Balance Sheet Management: Supervisory Review

CAIIB – Super-Notes © M S Ahluwalia Sirf Business

CAIIB – SUPER NOTES

Bank Financial Management: Supervisory Review

Page 3: CAIIB Super Notes: Bank Financial Management: Module D: Balance Sheet Management: Supervisory Review

CAIIB – Super-Notes © M S Ahluwalia Sirf Business

Contents

Coverage:

1. Introduction

2. Supervisory Review Process

Page 4: CAIIB Super Notes: Bank Financial Management: Module D: Balance Sheet Management: Supervisory Review

CAIIB – Super-Notes © M S Ahluwalia Sirf Business

INTRODUCTION

1.

Page 5: CAIIB Super Notes: Bank Financial Management: Module D: Balance Sheet Management: Supervisory Review

CAIIB – Super-Notes © M S Ahluwalia Sirf Business

Objective of SRP

• To ensure that banks have adequate capital to support all the

risks in their business as also to encourage them to develop

and use better risk management techniques for monitoring

and managing their risks.

Page 6: CAIIB Super Notes: Bank Financial Management: Module D: Balance Sheet Management: Supervisory Review

CAIIB – Super-Notes © M S Ahluwalia Sirf Business

Aspects to be addressed

Risks that are not fully captured by the

minimum capital ratio prescribed under Pillar I

Risks that are not fully captured by the

minimum capital ratio prescribed under Pillar I

Risks that are not at all taken into account by

Pillar I

Risks that are not at all taken into account by

Pillar I

Factors External to the bank

Factors External to the bank

Page 7: CAIIB Super Notes: Bank Financial Management: Module D: Balance Sheet Management: Supervisory Review

CAIIB – Super-Notes © M S Ahluwalia Sirf Business

Risks not fully captured in the regulatory CRAR

Interest Rate risk in the Banking Book

Interest Rate risk in the Banking Book

Credit Concentration Risk

Credit Concentration Risk

Liquidity Risk Liquidity Risk Settlement Risk Settlement Risk

Reputational Risk Reputational Risk Strategic Risk Strategic Risk Risk of under-estimation of credit risk under the Standardised Approach

Risk of under-estimation of credit risk under the Standardised Approach

“Model Risk” i.e., the risk of under estimation of credit risk under the

IRB Approach

“Model Risk” i.e., the risk of under estimation of credit risk under the

IRB Approach

Risk of weakness in the credit-risk mitigants

Risk of weakness in the credit-risk mitigants

Residual risk of securitisation etc.

Residual risk of securitisation etc.

Page 8: CAIIB Super Notes: Bank Financial Management: Module D: Balance Sheet Management: Supervisory Review

CAIIB – Super-Notes © M S Ahluwalia Sirf Business

Risks and SRP

• Considering the risks that are not fully captured banks should have

their own assessment of various risk exposures through a well

defined internal process

• Adequate cushion should be maintained for such risks

• ICAAP document should include:

– Capital Adequacy Assessment

– Projections of Capital requirement for the ensuing year

– Plans and strategies for meeting the Capital Requirement

• The ICAAP document should be approved by the board

Page 9: CAIIB Super Notes: Bank Financial Management: Module D: Balance Sheet Management: Supervisory Review

CAIIB – Super-Notes © M S Ahluwalia Sirf Business

SUPERVISORY REVIEW PROCESS

2.

Page 10: CAIIB Super Notes: Bank Financial Management: Module D: Balance Sheet Management: Supervisory Review

CAIIB – Super-Notes © M S Ahluwalia Sirf Business

4 Key Principles

1. Bank should have a process for assessing their overall capital adequacy in relation to

their risk profile and a strategy for maintaining their capital levels

2. Supervisors should review and evaluate the banks’ internal capital adequacy

assessments and strategies, as well as the ability to monitor and ensure their

compliance with the regulatory capital ratios. Supervisors should take appropriate

supervisory action if they are not satisfied with the result of this process.

3. Supervisors should expect banks to operate above the minimum regulatory capital

ratios and should have the ability to require the banks to hold capital in excess of the

minimum.

4. Supervisors should seek to intervene at an early stage to prevent capital from falling

below the minimum levels required to support the risk characteristics of a particular

bank and should require rapid remedial action if capital is not maintained or restored.

Page 11: CAIIB Super Notes: Bank Financial Management: Module D: Balance Sheet Management: Supervisory Review

CAIIB – Super-Notes © M S Ahluwalia Sirf Business

Bank’s Responsibilities

1. Should have in place:

1. Process for assessing the overall capital adequacy in relation to their

risk profile

2. Strategy for maintaining their capital levels

(Principle 1)

2. Should operate above the minimum regulatory capital ratios

(Principle 3)

Page 12: CAIIB Super Notes: Bank Financial Management: Module D: Balance Sheet Management: Supervisory Review

CAIIB – Super-Notes © M S Ahluwalia Sirf Business

Supervisor’s Responsibilities

1. Should review and evaluate the bank’s ICAAP (Principle 2)

2. Should take appropriate action if not satisfied with the results of this process (Principle 2)

3. Should review and evaluate a bank’s compliance with the regulatory capital ratios (Principle 2)

4. Should have the ability to require banks to hold capital in excess of the minimum (Principle 3)

5. Should seek to intervene at an early stage to prevent capital from falling below the

minimum levels (Principle 4)

6. Should require rapid remedial action if capital is not maintained or restored (Principle 4)

Page 13: CAIIB Super Notes: Bank Financial Management: Module D: Balance Sheet Management: Supervisory Review

CAIIB – Super-Notes © M S Ahluwalia Sirf Business

ICAAP

• Internal Capital Adequacy Assessment Process

• Comprises bank’s procedures and measures designed to

ensure the following:

a) Appropriate identification and measurement of risks

b) Appropriate level of internal capital in relation to the bank’s risk

profile

c) Application and further development of suitable risk management

systems in the bank

Page 14: CAIIB Super Notes: Bank Financial Management: Module D: Balance Sheet Management: Supervisory Review

CAIIB – Super-Notes © M S Ahluwalia Sirf Business

SREP

• Supervisory Review and Evaluation Process

• Review and evaluation process which covers all the processes

and measures defined in the principles. These include:

– Review and evaluation of the Bank’s ICAAP

– Conducting an independent assessment of the bank’s risk profile

– Taking appropriate measures and other supervisory actions as and

where required

Page 15: CAIIB Super Notes: Bank Financial Management: Module D: Balance Sheet Management: Supervisory Review

CAIIB – Super-Notes © M S Ahluwalia Sirf Business

Structural Aspects of ICAAP

• Every bank to have an ICAAP

• Should be board-approved

• Yearly review of the ICAAP outcomes by the board

• Should be proportional to the nature, scope, scale and the

degree of complexity in the bank’s business operations

(Simple, Moderately Complex)

• Regular independent review and validation

Page 16: CAIIB Super Notes: Bank Financial Management: Module D: Balance Sheet Management: Supervisory Review

CAIIB – Super-Notes © M S Ahluwalia Sirf Business

ICAAP

• To be a:

– Forward Looking Process

– Risk Based Process

• To include Stress Tests and Scenario Analyses

– Quantitative and Qualitative Approaches

– Risk aggregation and Diversification Effects

Page 17: CAIIB Super Notes: Bank Financial Management: Module D: Balance Sheet Management: Supervisory Review

CAIIB – Super-Notes © M S Ahluwalia Sirf Business

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