Tag Archive for: Basel III

Top 3 articles third quarter of 2017

| 10-10-2017 | treasuryXL |

The fourth quarter of 2017 has started, time to look back on the last three months.
Which topics are interesting and attract visitors?
These are the three most read articles of the third quarter of 2017.

 

 

1. Saving on FX deals often neglected but potentially a pot of gold

Written on 28-08-2017 by Patrick Kunz
Doing business internationally often means dealing with foreign currency (FX). This poses a risk as the exchange rate changes daily, basically every second. To mitigate this risk a company can hedge the position via FX deals (discussed in a previous article). But what are the costs of those deals to companies?

Read the full article

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2. PSD2 – update and new developments

Written on 17-08-2017 by François de Witte
Early 2017, I published a post about PSD2, a lot of opportunities, but also big challenges. Now half a year later, I would like to update you on some developments in this area. PSD2 still needs to be transposed in the national legal system of all the member countries, and according to my knowledge several countries, including Belgium, have not yet released the draft laws. This creates quite some uncertainty in the market, as there will be several country-specific specifications. Hence one can expect that Fintech’s and other TPPs might already have started their certification application in countries that already enacted PSD2 in their local legislation.

Read the full article

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3. Impact of Basel III on notional cash pooling

Written on 17-01-2017 by Arnoud Doornbos (A golden oldie!)
Since the start of the financial crisis a growing need for more bank independency with companies has arisen. Bank counterparty risk became an issue. A large cash management bank announced in 2015 to stop their transactional banking services for continental Europe. What will happen with current cash pools running with banks in the UK? Increased regulations (Basel III) may stop certain banking products.
All types of events where companies feel a growing need for more bank independency.

Read the full article

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Basel III and the impact on cost of hedging

| 30-3-2017 | Arnoud Doornbos | Treasury Services |

Corporates will save hedging costs and administrative costs significantly if they shift their hedging activities to exchanges such as CME (Chicago Mercantile Exchange).
In the summer of 2007 a large number of defaults on U.S. mortgage loans did arise. The banks were hit hard by the global domino effect that resulted. A major financial crisis which was followed by an economic crisis led to a revision of the capital requirements of Basel I and Basel II.

New Basel III

The core of Basel III is that many banks have to hold more capital and liquidity to their outstanding investments than they used to in the past. The rules are implemented as from 2013 and should eventually be fully effective in 2019.

Basel III will be a huge challenge for banks in the coming years. The impact on the pricing of financial products and transactions between banks and their clients will be significant.
Since July 2008, the Basel Committee for Banking Supervision has been working on Basel III for all banks worldwide. The European Commission has introduced three Capital Requirements Directives which contains concrete actions and requirements in terms of risk, capital and liquidity management within a bank. The new requirements, part of Basel III, aim to improve the quality and level of capital reserves of banks.

The capital requirements of certain products have increased and banks are encouraged to create additional capital buffers during good economic times so that they are better positioned to absorb losses during periods of economic stress.

Impact of Basel III on liquidity management

Besides sharpening the capital requirements Basel III has a major impact on liquidity management. The new liquidity standards are based on a stress test. In addition Basel III also introduces new long-term liquidity standards that reduce the mismatch between the maturities of assets and liabilities.
Banks will have to increase their reserves sharply in the coming years. Previously, banks only had to keep 2 % capital to their outstanding investments. Now with Basel III this capital requirement has been increased to 7 % (4.5 % hard buffer and an additional 2.5 % margin in bad times) . As a result banks will probably not distribute their profits in the coming years but will add to their capital buffers. Furthermore many banks will have to issue new shares in order to attract extra money in order to meet the new demands.

Counterparty risk

Within Basel III it has been determined that capital must be held for the credit risk on a counterparty a bank is exposed to in OTC derivatives or equity financing transactions. In addition, market participants are encouraged to take one central counterparty (clearing houses) for OTC derivatives. Any time a bank takes a risk against another party the probability of default exists. To offset this concern, and to support on-going stability within the interbank market, banks have long emphasized the importance of measuring and managing counterparty risk. Now banks have becomes noticeably less comfortable trading with other counterparties including other banks.

The recent deterioration in credit ratings that has hit many U.S. and European banks has led to a heightened sensitivity over counterparty risk. These apprehensions may not be voiced directly, but they become evident when front office trades that would have cleared in the past, no longer do because credit lines have been reduced. There is increasing focus on limiting exposures, even among global banks. And that is starting to affect the way we do business.
CVA (Credit Valuations Adjustment) desks have grown in popularity, as banks seek more effective ways to manage and aggregate counterparty credit risk.
The market has changed now in terms of how counterparty credit risk was calculated. Now, no client is assumed to be truly risk free. Different prices are now expected for different clients on that same interest rate swap, depending on variables including the client’s rating and the overall direction of existing trades between both parties.
On all new interest rate, FX, equity, or credit derivatives, CVA desks price the marginal counterparty risk for inclusion into the overall price charged to the client. CVA is a highly complex calculation.

CVA looks at default through the spread of the counterparty. A swap facing a single B credit that trades at 1200 in CDS is going to be charged a lot more than the same swap facing a AA counterparty. The CDS spread is normally a core input of CVA pricing.

What we see in practice is that in the manual process, the CVA desk team of a bank often passes along suggestions to the salesperson for improving the credit risk in a trade and enabling the sales person to offer the trade at a lower credit price. Examples of that would include improving the collateral agreement with a client, or inserting a break clause.
In the traditional CVA approach, a bank accepts a new trade, takes a fee and uses that fee to buy good hedges for all the risks in that trade. These hedges should eliminate all of the bank’s risk, but this is not necessarily the case once Basel III is taken into account.

Basel III does not recognize all types of hedges that the bank might want to use. Therefore the regulatory capital for certain trades will not be zero, even if the bank has used the full CVA fee to hedge all its risks.
The first impact Basel III has on CVA desks is on pricing. Pre-deal pricing needs to be reviewed to ensure the costs of imposed regulatory capital are covered. If not, additional pricing may need to be added. And the decision on which risks are efficient to hedge also becomes affected not just by strategic or business reasons, but also by the regulatory capital impact.
As part of Basel III’s updated regulatory capital guidelines, a new element has been added: V@R on CVA. Regulators have specified very precisely how the underlying CVA must be calculated for this charge. Banks will therefore need to decide whether to adjust their pricing and balance sheet CVA to match the Basel III rules, or to use different CVA calculations for pricing and regulatory purposes.

EMIR / Dodd-Frank

The Dodd-Frank / EMIR financial reform bill gives a new set of derivatives rules that either will clean up the market or send the world spiraling off the deep end. The truth is probably somewhere in between. The crux of the derivatives regulation is the requirements that standardized swaps be centrally cleared and traded on a Swap Execution Facility, or SEF. This moves derivatives from bilateral agreements between bank and client to centrally cleared products where credit risk is no longer bank-held, but is centralized in a clearinghouse where daily margin is managed. Once clearing is in place, customers no longer are locked into a single dealer, long and short positions can be netted, and SEFs can begin to match buyers and sellers without having to worry about the credit lines of each counterparty or dealer.

This will begin the migration of the derivatives business from a principal-based OTC market toward an agency-based bid/offer SEF market.

Treasury Services’ analysis:

  • Hedging is penalized decreasing the liquidity in the markets leading to increased costs to hedge financial risks for corporations. This is further emphasized by the penalization of the interbank markets through requirement of more capital, and additional constraints on liquidity on interbank transactions.
  • There will also be an increase in administration costs for corporates costs due to EMIR.
  • Corporate credit by banks is penalized: More capital is required in general. For back-up facilities on commercial paper programs it is required that banks will have to have 100% of liquid assets whilst these facilities are fully undrawn. The cost of carry will obviously be invoiced to the client. The ability of the bank to borrow long term will determine the availability of back-up facilities.
  • Restrictions in maturity mismatch (including for repayments) are introduced. This may mean that the risk of borrowing short term to finance long term investments will be transferred to the corporate sector.

The advantages of the OTC market compared to exchanges has become questionable. High cost savings can be achieved by shifting your hedging activities to exchanges such as Chicago Mercantile Exchange (CME).
Shifting hedging activities to an exchange such as CME requires changes in your risk management function. This supplies the possibility to bring the cost of hedging back in your control.

 

Arnoud Doornbos

Associate Partner

Treasury Seminars in Antwerp and Montfoort – a short summary of two successful events

| 15-3-2017 | Treasury Services | PowertoPay | sponsored content |

The last two Thursdays, the PowertoPay, SWIFT and TreasuryServices Treasury Seminar was held in Montfoort and Antwerp. We’re happy to say that it was a success! We got a lot of positive feedback during and after the seminars. Both had the same content but were hosted on two different days. The first one was held in Antwerp, Belgium on the 2nd of March in an old monastery (Elzenveld). The second one was held in Montfoort, The Netherlands on the 9th of March in the Heeren of Montfoort. 

During the seminar several treasury topics were highlighted. After a short opening speech by Bas Huisman, co-founder of PowertoPay, we started with a presentation about the importance of bank independency. Arnoud Doornbos from Treasury Services was talking about financial history lessons but also the current financial situation that makes it really important for companies to look into bank independent solutions.
After that Rob Rühl from Next Markets presented his view of the influences of Brexit on the Dutch and Belgian economy.
Next was a presentation by Hans de Vries, PowertoPay consultant, telling about the end of Notional Pooling and Basel III. He also presented the Payment Hub of PowertoPay and how this is beneficial for companies.
After this Jan Vermeer from TreasuryServices talked about bank independent cash pooling through software, something TreasuryServices developed for companies who wish to operate much less dependent on their banks if it comes to cash management.
Last but definitely not least, we had a client case presented by Michel Steenbergen from DIF. He informed everyone about how the two solutions mentioned above come together in practice. DIF uses a combination of PowertoPay’s Payment Hub  and TreasuryMetrics from Treasury Services and created a perfect solution for their complex cash management processes. After both of the seminars we had a drink and some food with the participants.

Our Treasury Seminar was a great opportunity to inform everyone about the current situation of the financial world and how to participate in changes that are occurring. Being bank independent is becoming increasingly important because of the fast development of financial technologies and changing laws. What we see lately is that components of banking products and services are being redeveloped by the FinTech Industry. These FinTech solutions are smarter, faster and better. As a result we now see that different FinTech companies work together. Individual Fintech products often turn out to be complementary to each other. FinTech companies now recognize that collaboration with other FinTech companies leads to high growth and a better product range.

PowertoPay –  Claire van Ingen

Treasury Services BV – Arnoud Doornbos

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Making the most of excess cash: The optimal balance between safety, availability and profitability

| 9-3-2017 | Pieter de Kiewit | TreasuryXL|

We came across this article from our expert Pieter de Kiewit in co-operation with a candidate on De Kiewit Treasurer Search and thought it interesting enough to share it with you.

To get inflation to its target of close to 2%, the ECB has launched an unprecedented package of measures. It cuts borrowing costs, expanded its QE programme and reduced bank deposit rate into negative territory. Interest rates are expected to remain at present low levels for an extended period of time. Great for those who need to borrow money, but depressing for the return on savings or excess cash.

Many commercial banks effectively already charge a negative interest rate on checkable deposits. They charge fees in excess of interest payments (if any). The new Basel rules may involve certain costs or risks, some banks may choose to pass these to their customers. Regulatory shift will have wide-reaching implications on cash pooling, cash deposits (distinction between operating and excess cash deposits) and Money Market Funds (liquidity fee and redemption gates will be imposed). The Basel Committee postponed the meeting scheduled for Jan. 8 on new capital standards. The good news is that it will take some time (2018/2019) before new regulations become fully operational.

Many companies now hold larger cash balances due to their growing sensitivity to the economic cycle and continued need for operational funding. Excess cash is a luxury and isn’t always a problem. However, keeping it on the book is often not the answer for a company’s long term health. Excessive non-earning cash balances create opportunity costs and decrease the rate of return on equity and the firm’s value.

What are your options after minimizing the cash balance in non-interest-bearing accounts? Each business has its own goals and financial outlook. The best thing to do with excess cash is manage it appropriately in line with strategic objectives and for the best risk-adjusted return possible, without sacrificing liquidity. You can sit on it, use it to buy property or assets, or invest it in commercial paper, money market funds, other mutual funds, bonds or stocks—or some combination of these things. Whatever you may choose, the process of investing excess cash should be integrated in overall cash management, with the same fundamental principles of keeping risk low and having the right amount of cash on hand for short-term and long-term needs.
Companies tend to have very low appetites for risk when it comes to investments. It’s not their business. Their primary objective is capital preservation and maintaining liquidity, and yield is third on the priority list.

Are you looking for investment solutions spanning a range of currencies, risk levels and durations, designed to suit specific operating, reserve and strategic cash management needs? Whatever your investment goals may be, a treasurer might be able to assist you in making the right decision with your excess liquidity. If hiring a treasurer is one step to far for your organisation, you might want to consider a Flex Treasurer. TreasuryXL can bring you in contact with treasury professionas of different disciplines.

Pieter de Kiewit

 

 

Pieter de Kiewit

Owner at Treasurer Search

 

Managing treasury risk: Credit Risk (Part V)

| 23-2-2017 | Lionel Pavey |

 

There are lots of discussions concerning risk, but let us start by trying to define what we mean by risk. In my fifth article I will focus on credit risk. Many companies have very significant credit needs and this needs to be formally addressed with a credit analysis procedure in place. In my former articles I dealt with risk management, interest rate risk, foreign exchange risk and commodity risk. See the complete list at the end of today’s article.

Credit Risk

Credit Risk occurs when there is a risk of default from money that has been lent to a borrower, or funds that have been invested.
The risk can be caused by:

  • Trade credit extend to a client, who does not pay
  • Inability to make a payment on a loan
  • A company going bankrupt
  • An insurance company not paying under a policy
  • A bank becoming insolvent
  • A company not paying wages to employees
  • A government defaulting

Main categories

The main categories of credit risk are:

Default risk
Counterparty risk
Sovereign risk
Legal risk
Concentration risk

Default risk:
occurs due to the default on monies owed either from lending or investment. The counterparty could be unable to repay. Sometimes they could also be unwilling to repay. The default risk is therefore on 100% of the outstanding balance, unless some form of recovery (be it full or partial) was possible.

Counterparty risk:
occurs when counterparties have to perform an action on a contractual commitment.
This can happen at both the time of settlement and also before settlement, but after entering a contract. Since the start of the financial crisis settlement risk is a major factor for banks. If at settlement a counterparty fails to meet its obligation, this can potentially lead to large losses and, eventually, to a systemic risk as you are therefore unable to meet your own obligations. A default before settlement can be alleviated by substituting a new contract though this could occur at prices far less favourable.

Sovereign risk:
entails the political, legal and regulatory exposures arising from international trade and cross border transactions. It can relate to a government failing in its obligation to repay or to new laws that prohibit free movement of funds – exchange control. Any contracts entered into with nondomestic counterparties should be analysed for the embedded sovereign risks and potential political instability.

Legal risk:
can occur if the counterparty is not legally allowed to enter into certain trades – especially derivative trades. We see in the media stories of companies that have experienced difficulties with derivatives leading to losses and court cases are started to either enforce or negate the contract. Also special purpose vehicles are formed purely to enter into certain transactions like securitisation issues. These are companies with no staff, fixed abode, or assets other than the underlying collateral of the issue.

Concentration risk:
arises from lack of diversification. Too many loans from 1 or 2 banks, too many products purchased from 1 or 2 suppliers, too much revenue generated by 1 or 2 customers. This risk is a bit of a paradox as many companies become successful through concentrating their resources in key niche areas, whilst having to diversify their underlying risk at the same time.

Measures

There are, of course, measures that can be undertaken to identify and minimize these potential losses.

The first approach is counterparty ratings. Certain criteria can be examined – credit rating agencies, examination of financial statements, good knowledge of the counterparty, political, geographical (are they situated next to a volcano?) and legal status.

Notional exposure reveals the full amount outstanding with a counterparty – all the money that could potentially be lost.

Aggregate exposure netts the exposure with a counterparty between monies to be received and monies to be paid.

Clear picture of the replacement costs – the costs involved to replace the existing transaction with a new counterparty.

Techniques of measurement

Measurement of credit risk requires quantitative techniques to measure and model the risks.  An example would be Basel III that places a regulatory framework on banks to ensure adequate capital ratios. Eventually the techniques being used will trickle down to commercial companies. This should result in the creation of risk tools that are more sophisticated and improvements of the techniques used to report and measure risk.

However, as the financial crisis has clearly shown, over-reliance on sophisticated computer models appeared to lead to false comfort with the results generated by the modelling systems. This was caused by underestimating the risks in new financial products and the great assumption that is always prevalent in economic theory – people behave rationally at all times! Any model is a snapshot of the world and can only contain a few variables that are perceived as critical. All others are discarded to ensure that the model can work quickly and efficiently.

Lionel Pavey

 

 

Lionel Pavey

Cash Management and Treasury Specialist

 

 

 

More articles of this series:

Managing treasury risk: Risk management

Managing treasury risk: Interest rate risk 

Managing treasury risk: Foreign exchange risk

Managing treasury risk: Commodity Risk

 

Impact of Basel III on Notional Cash Pooling

|17-1-2017 | Arnoud Doornbos |

afbeelding

 

Since the start of the financial crisis a growing need for more bank independency with companies has arisen. Bank counterparty risk became an issue. A large cash management bank announced in 2015 to stop their transactional banking services for continental Europe. What will happen with current cash pools running with banks in the UK? Increased regulations (Basel III) may stop certain banking products.
All types of events where companies feel a growing need for more bank independency.

Basel III

In the coming years, banks have to prepare themselves for compliance with the new Basel III rules on financial institutions.
The financial crisis of 2008 brought the shortcomings of Basel II to light. The capital requirements for banks were found to be insufficient and banks were running risks which were not identified by Basel II.
Therefore the focus of Basel III is to restore previous mistakes and adding requirements to both the quality and composition of the capital held by banks and liquidity position and governance to manage the risks.

Effective liquidity management is a way to look for “Idle” cash. An increasing number of companies therefore choose for notional pooling as it enables them to gain more insight into their (global) financial position and in order to optimize the interest income on their accounts.
Simultaneously Basel III imposes stricter requirements on offsetting balances (credit and debit), and this brings notional pooling possibly into danger. The question is what impact the introduction of Basel III has to notional pooling services offered by banks.

Notional Pooling

Notional pooling is a mechanism for calculating interest on the combined credit and debit balances of accounts that a corporate parent chooses to cluster together, without actually transferring any funds between the accounts. It is ideal for companies with decentralized organizations that want to allow some autonomy to their subsidiaries, including their control over bank accounts.

Treasury Services- without notional pooling

Benefits of notional pooling

The use of notional pooling has increased tremendously in recent years. At the moment it is a commonly used structure to concentrate balances and maximize the interest income on bank accounts. In addition it will provide companies with an increased understanding of their financial position and the company is therefore able to manage their money more effectively. Another commonly used technique is physical pooling (zero balancing) where the money from the participating accounts is transferred via a physical transfer to a higher-level account. The difference between them is that with notional pooling the money shall be paid only virtual and with physical pooling a physical transfer of money takes place. By using physical pooling through physical money transfer, internal debt positions will be created. Notional pooling and physical pooling can also be combined in an overlay structure.

Liquidity management

Basel III introduces a number of new financial ratios that aim to strengthen the capital base of banks.
One of the most significant ratios is the liquidity coverage ratio which banks are required to hold in high-quality liquid assets (cash money or assets which can be sold on the market quickly). This liquidity coverage ratio shows how far banks are able to withstand sufficiently a ‘crisis’ on cash flows for a period of thirty days. Moreover, the new law increases the capital requirements for banks and make these requirements more risk-weighted than before. The requirements are also countercyclical, intended to encourage banks to build up more capital in economic good times.
Liquidity management is gaining popularity by two simultaneous developments. On the one hand, credit is a less attractive source of profit for banks, which enforced banks to shift their focus to activities without capital requirements. On the other hand, companies need to make optimal use of internal cash as bank financing is becoming increasingly difficult. Notional pooling offers the option to concentrate the balances at several (international) accounts and optimize the interest.

Uncertain future for notional pooling

Basel III does not always allow that liquidity ratios are calculated by means of netting the outstanding balances of accounts in the notional pool. This means that banks must calculate their ratios based on the gross value of individual accounts. To cover the negative positions in the notional pool banks need to hold more liquidity. The negative position is seen as overdraft, which is associated with unattractive Risk Weighted Asset (RWA) for the bank. The conditions for reducing this RWA vary by bank and are depending also on the central bank of an individual country. To prevent that banks are required to hold a higher amount of risk capital they must be in possession of a legal right of offset. However, the process to obtain this right involves a lot of time and high costs (both for the bank and the company) and requires the necessary legal and tax knowledge. First, the law in the jurisdiction of each participant of the notional pool must allow compensation in the event of bankruptcy. In addition each participant of the notional pool must sign a paper that allow them to guarantee for other participants. Finally, the company must demonstrate that netting has occurred periodically.

Regarding the future of notional pooling, there are a number of scenarios to think of when it comes to the continuation of this service by banks:

  • Banks will only allow entities in the notional pool if there is an enforceable right of compensation;
  • Banks will charge the higher costs related to notional pooling to the companies;
  • Banks offer notional pooling selectively based on the creditworthiness of the company.

If banks decide to increase the price for notional pooling, it is likely that companies will go for alternatives for their cash management activities (e.g. physical pooling). Therefore it is advisable to contact your bank regarding notional pooling, so you are not faced with unnecessary surprises.

Treasury Services monitors the developments in the Basel III framework closely and combines its expertise in the areas of Payments, Treasury and Risk in order to provide its customers the best advice.
The Treasury Services Cash Management Scan analyses the impact of Basel III on your current cash pools and will explain how to manage this in the future.

Bank independent Cash Pooling

Treasury Services has developed a solution to set up cash pooling structures completely independent from banks through software. This creates significant additional savings and advantages compared to a cash pooling solution with banks.

The bank independent cash pooling allows companies to pool different bank accounts with different banks in different countries.

The advantages are:

Treasury Services advantages Cash pooling tool

The solution we have developed is a complete solution. It does not only consist of a software solution, but also proposed changes for policies and processes, and we investigated the legal and fiscal constraints.

For  more information please refer to this link.

 

arnoud-doornbos

 

Arnoud Doornbos

Partner at Treasury Services

 

 

 

Update: Bankregulering 2016

| 11-07-2016 | Michiel van den Broek |

basel

 

Alhoewel de grootste financiële crisis ooit al weer acht jaar is geleden, overspoelen toezichthouders de bankensector nog steeds met nieuwe regulering. In dit artikel vindt u een overzicht van een aantal nieuwe maatregelen en voorstellen, officieus bekend als Bazel’s Akkoord 4.

Achtergrond Bankentoezicht: BIS Ratio en Leverage Ratio

De kern van het bankentoezicht bestaat uit adviezen van het Basel Committee of Banking Supervision, beter bekend als het Bazel’s Comité, dat is opgezet in 1975 op initiatief van de Bank of International Settlements (BIS). Deze eisen betreffen hoofdzakelijk kapitaalbuffers om onverwachte verliezen op te kunnen vangen.

Tot 2008 zijn deze buffers alleen gebaseerd op ingeschatte risico’s die zijn omgerekend naar risico-equivalenten: de Risk Weighted Assets (RWA). Deze zogenaamde BIS Ratio is onderdeel van Bazel akkoord II pijler 1 van 2007, vereist een minimum kapitaalbuffer van 8% van RWA,.

Omdat het inschatten van risico’s een subjectieve component bevat, is er in Bazel III akkoord van 2010 een aanvullende kapitaaleis bepaald die ingaat per 1 januari 2018: de Leverage Ratio. Deze Leverage Ratio houdt in dat banken minimaal 3% kernkapitaal moeten aanhouden gerelateerd aan het balanstotaal zonder risicoweging, inclusief ongebruikte kredietlijnen en garanties. Onze regering heeft de woede bij Nederlandse grootbanken opgewekt door een hogere Leverage Ratio van 4% te eisen. Als u verder leest zult u begrijpen dat nieuwe regelgeving deze woede inmiddels heeft ‘ingehaald’.

Aanpassen Standaardmethode RWA Kredietrisico

In december 2015 heeft het Bazel’s Comité in document d347 nieuwe voorstellen gedaan ter aanpassing van de RWA bepaling bij kredietverlening via de standaardmethode. Bij deze voorstellen zijn vooral de volgende twee aanpassingen belangrijk.

In de eerste plaats moeten banken bij kredietverlening de risicoweging onderbouwen via een eigen onderzoek, een ‘due dilligence’. Deze aanpassing leidt tot extra lastendruk voor de kredietafdelingen van banken.

Ten tweede zal bij onroerendgoedfinanciering niet meer het betalingsgedrag van de klant bepalend zijn voor het kapitaalbeslag, maar de hoogte van het krediet ten opzichte van de waarde van het onroerend goed, oftewel ‘Loan To Value’ (LTV). Omdat Nederlandse grote banken internationaal gezien zeer grote hypotheekportefeuilles hebben, waarvan een groot deel met een hoge LTV, zal deze aanpassing tot een substantiële extra kapitaalverhoging leiden zijn in vergelijking tot buitenlandse concurrenten.

Aanpassen Standaardmethode RWA Operationeel risico

Banken kunnen aanzienlijke verliezen lijden als gevolg van fouten, fraude en haperende automatisering. De kapitaaleisen voor deze operationele risico’s zijn tot op heden gebaseerd op de omzet en / of het renteresultaat. Het is niet zo moeilijk om een vraagteken bij te zetten bij deze werkwijze. Immers, waarom zou er minder kapitaal voor operationele risico’s moeten zijn als de omzet lager is?

In oktober 2014 is via voorstel bcbs291 een nieuwe standaardmethode aangekondigd waarbij het kapitaal voor operationeel risico wordt berekend via een coëfficiënt die afhangt van de hoogte van een Business Indicator (BI). Deze BI is bepaald via een voorgeschreven model met als input drie elementen: (1) Interest, (2) Services en (3) Financial.

Hiernaast is in voorstel d355 van maart 2016 aangekondigd dat banken in de toekomst hun eigen modellen, de Advanced Measurement Approach (AMA), niet meer mogen gebruiken ter berekening van het kapitaalbeslag voor operationeel risico’s.

Mijn inschatting is dat in de toekomst alle kapitaaleisen gebaseerd zullen zijn op door de toezichthouder voorgeschreven standaardmethoden en dat het gebruik van door banken ontwikkelde eigen modellen niet meer is toegestaan, zoals de bij grote banken populaire Internal Rating Based (IRB) modellen voor kredietrisicoweging.

Nieuwe kapitaaleisen van FSB en EBA: TLAC en MREL

De Financial Stability Board (FSB) en European Banking Authority (EBA) hebben in 2015 aanvullende kapitaaleisen gesteld om de financiële stabiliteit van banken te verhogen. Deze voorstellen bevatten 2 elementen: (1) meer kapitaal en (2) een bail-in schuldklasse.

De FSB kapitaaleis betreft Total Loss Absorbing Capacity (TLAC) en is van toepassing op de 30 grootste systeembanken ter wereld, de Global Systematically Important Banks (G-SIB’s). TLAC is onderdeel van de toezichtpijler 1 van de Bazel III kapitaaleisen. De invoering van TLAC vindt plaats in twee fases. Per 1 januari 2019 moeten G-SIB’s tenminste 16% RWA kapitaal aanhouden, exclusief het kernkapitaal voor Capital Conservation en G-SIB’s, alsmede een Leverage Ratio van minimaal 6%. Per 1 januari 2022 zijn de minima 18% RWA en 6,75% Leverage. Ook moet tenminste 33,3% van het TLAC kapitaal bestaan uit componenten die niet tot het kernvermogen (Core Equity Tier 1 – CET 1) behoren.

De EBA heeft gelijksoortige eisen gesteld voor alle Europese banken, de Minimum Requirement for own funds and Eligible Liabilities (MREL). Zowel TLAC als MREL zijn ontstaan om overheidssteun bij een bankroet zoveel mogelijk te voorkomen. Om te vermijden dat TLAC en MREL tot tegenstrijdige en stapelende regelgeving leidt, is de algemene verwachting dat de TLAC kapitaaleisen zullen worden geïntegreerd in MREL bij de evaluatie door de EBA eind 2016.

Een belangrijk verschil met TLAC, is dat MREL behoort tot toezichtpijler 2 van de Bazel III kapitaaleisen, hetgeen betekent dat nationale toezichthouders per bank beoordelen hoeveel extra kapitaal vereist is boven de pijler 1 buffers. MREL zal per Europees land nog in nader te bepalen wetgeving moeten worden geïmplementeerd. Hoe deze wetgeving met betrekking tot de bail-in schuldklasse uitwerkt zal per land kunnen verschillen. Zo zijn in Italië een groot deel van de achtergestelde schuldtitels in particulier bezit. Italiaanse politici zullen waarschijnlijk willen vermijden dat zij de electorale rekening zullen moeten betalen als een bank omvalt en dus particulieren buiten de bail-in schuldklasse proberen te houden.

Ondertussen ontstaat er al meer duidelijkheid voor beleggers doordat er inmiddels op de kapitaalmarkt een nieuwe klasse van bail-in schuldtitels wordt aangeboden. Een recent voorbeeld van deze nieuwe klasse is de emissie van Senior Resolution Notes door de Deense bank Nykredit’s.

Ten slotte

Afsluitend constateer ik dat historisch gezien er een herhaling van zetten gaande is. Net als na de implosie van het financiële systeem volgend op de beurskrach van 1929, draaien ook nu toezichthouders de duimschroeven weer stevig aan bij banken. Het is te hopen dat de les nu definitief is geleerd: een te vergaand geliberaliseerde bankensector leidt tot financiële en economische misère.

 

Michiel van den Broek - foto

 

Michiel van den Broek

Owner of Hecht Consult