V Leeladhar: Basel II Accord and its implications
Speech by Mr V Leeladhar, Deputy Governor of the Reserve Bank of India, at the Bankers' Club,
Mangalore, 11 March 2005.
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Ladies and gentlemen, it is my pleasure to share my thoughts with you on a subject which is currently
engaging the attention of the banking community, not just in India but worldwide. Let me first admit
upfront that although I am at the moment wearing the regulator's hat, yet I have been a commercial
banker for most part of my professional career. So, the banker in me still goads me to put myself in
bankers' shoes before evaluating any regulatory options. I can better appreciate some of nuances
from a practical stand point, and therefore shall try to put them more from a banker's perspective
rather than that of a regulator.
Managing risk is increasingly becoming the single most important issue for the regulators and financial
institutions. These institutions have over the years recognized the cost of ignoring risk. However,
growing research and improvements in information technology have improved the measurement and
management of risk. It's but natural therefore, capital adequacy of a bank has become an important
benchmark to assess its financial soundness and strength. The idea is that banks should be free to
engage in their asset-liability management as long as they are backed by a level of capital sufficient to
cushion their potential losses. In other words, capital requirement should be determined by the risk
profile of a bank.
The initial capital accord of 1988 was hugely successful with more than 100 countries accepting it as a
benchmark. One of the major reasons for the success of this framework was its being simple. It
brought in uniformity and attempted to make regulatory capital requirement consistent with the
economic capital. Reserve Bank of India introduced risk assets ratio system as a capital adequacy
measure in 1992, in line with the Basel accord of 1988, which takes into account the risk element in
various types of funded balance sheet items as well as non-funded off balance sheet exposures. In
fact, RBI norms on capital adequacy at 9% are more stringent than Basel Committee stipulation of 8%.
Shortcomings in the present accord
However, the present accord has been criticized as being inflexible due to its focus on primarily credit
risk and treating all types of borrowers under one risk category regardless of credit worthiness. The
major criticism against the existing accord stems from its
•
Broad brush approach - irrespective of quality of counter party or credit
•
Encouraging regulatory arbitrage by cherry picking
• Lack of incentives for credit risk mitigation techniques
•
Not covering operational risk
As time passed, some of the major international banks began using sophisticated models to measure
risk. This was when a need was felt to upgrade the Basel framework. Therefore, the Basel Committee
on Banking Supervision thought it desirable that the present accord is replaced by a more
risksensitive framework.
Three pillars
The new Basel Accord has its foundation on three mutually reinforcing pillars that allow banks and
bank supervisors to evaluate properly the various risks that banks face and realign regulatory capital
more closely with underlying risks. The first pillar is compatible with the credit risk, market risk and
operational risk. The regulatory capital will be focused on these three risks. The second pillar gives the
bank responsibility to exercise the best ways to manage the risk specific to that bank. Concurrently, it
also casts responsibility on the supervisors to review and validate banks' risk measurement models.
The third pillar on market discipline is used to leverage the influence that other market players can
bring. This is aimed at improving the transparency in banks and improve reporting.
Issues and Challenges
Having given you a brief overview of the current and proposed new framework, I shall now move on to
the implementation challenges for the banks especially in a developing country like India. Here, I
would skip the methodological details and technical nitty-gritty associated with the new accord, and
concentrate instead on more profound implications for the banking industry.
ISSUES AND CHALLENGES
While there is no second opinion regarding the purpose, necessity and usefulness of the proposed
new accord - the techniques and methods suggested in the consultative document would pose
considerable implementational challenges for the banks especially in a developing country like India.
Capital Requirement: The new norms will almost invariably increase capital requirement in all banks
across the board. Although capital requirement for credit risk may go down due to adoption of more
risk sensitive models - such advantage will be more than offset by additional capital charge for
operational risk and increased capital requirement for market risk. This partly explains the current
trend of consolidation in the banking industry.
Profitability: Competition among banks for highly rated corporates needing lower amount of capital
may exert pressure on already thinning interest spread. Further, huge implementation cost may also
impact profitability for smaller banks.
Risk Management Architecture: The new standards are an amalgam of international best practices
and call for introduction of advanced risk management system with wider application throughout the
organization. It would be a daunting task to create the required level of technological architecture and
human skill across the institution.
Rating Requirement: Although there are a few credit rating agencies in India, the level of rating
penetration is very low. A study revealed that in 1999, out of 9640 borrowers enjoying fund-based
working capital facilities from banks, only 300 were rated by major agencies. Further, rating is a
lagging indicator of the credit risk and the agencies have poor track record in this respect. There is a
possibility of rating blackmail through unsolicited rating. Moreover rating in India is restricted to issues
and not issuers. Encouraging rating of issuers would be a challenge.
Choice of Alternative Approaches: The new framework provides for alternative approaches for
computation of capital requirement of various risks. However, competitive advantage of IRB approach
may lead to domination of this approach among big banks. Banks adopting IRB approach will be more
sensitive than those adopting standardized approach. This may result in high-risk assets flowing to
banks on standardized approach, as they would require lesser capital for these assets than banks on
IRB approach. Hence, the system as a whole may maintain lower capital than warranted and become
more vulnerable. It is to be considered whether in our quest for perfect standards, we have lost the
only universally accepted standard.
Absence of Historical Database: Computation of probability of default, loss given default, migration
mapping and supervisory validation require creation of historical database, which is a time consuming
process and may require initial support from the supervisor.
Incentive to Remain Unrated: In case of unrated sovereigns, banks and corporates, the prescribed
risk weight is 100%, whereas in case of those entities with lowest ratting, the risk weight is 150%. This
may create incentive for the category of counterparties, which anticipate lower rating to remain
unrated.
Supervisory Framework: Implementation of Basel II norms will prove a challenging task for the bank
supervisors as well. Given the paucity of supervisory resources, there is a need to reorient the
resource deployment strategy. Supervisory cadre has to be properly trained for understanding of
critical issues for risk profiling of supervised entities and validating and guiding development of
complex IRB models.
Corporate Governance Issues: Basel II proposals underscore the interaction between sound risk
management practices and corporate good governance. The bank's board of directors has the
responsibility for setting the basic tolerance levels for various types of risk. It should also ensure that
management establishes a framework for assessing the risks, develop a system to relate risk to the
bank's capital levels and establish a method for monitoring compliance with internal policies.
National Discretion: Basel II norms set out a number of areas where national supervisor will need to
determine the specific definitions, approaches or thresholds that they wish to adopt in implementing
the proposals. The criteria used by supervisors in making these determinations should draw upon
domestic market practice and experience and be consistent with the objectives of Basel II norms.
Disclosure Regime: Pillar 3 purports to enforce market discipline through stricter disclosure
requirement. While admitting that such disclosure may be useful for supervisory authorities and rating
agencies, the expertise and ability of the general public to comprehend and interpret disclosed
information is open to question. Moreover, too much disclosure may cause information overload and
may even damage financial position of bank.
Disadvantage for Smaller Banks: The new framework is very complex and difficult to understand. It
calls for revamping the entire management information system and allocation of substantial resources.
Therefore, it may be out of reach for many smaller banks. As Moody's Investors Services puts it, "It is
unlikely that these banks will have the financial resources, intellectual capital, skills and large scale
commitment that larger competitors have to build sophisticated systems to allocate regulatory capital
optimally for both credit and operational risks."
Discriminatory against Developing Countries: Developing countries have high concentration of
lower rated borrowers. The calibration of IRB has lesser incentives to lend to such borrowers. This,
along with withdrawal of uniform risk weight of 0% on sovereign claims may result in overall reduction
in lending by internationally active banks in developing countries and increase their cost of borrowing.
External and Internal Auditors: The working Group set up by the Basel Committee to look into
implementational issues observed that supervisors may wish to involve third parties, such a external
auditors, internal auditors and consultants to assist them in carrying out some of the duties under
Basel II. The precondition is that there should be a suitably developed national accounting and
auditing standards and framework, which are in line with the best international practices. A minimum
qualifying criteria for firms should be those that have a dedicated financial services or banking division
that is properly researched and have proven ability to respond to training and upgrades required of its
own staff to complete the tasks adequately.
With the implementation of the new framework, internal auditors may become increasingly involved in
various processes, including validation and of the accuracy of the data inputs, review of activities
performed by credit functions and assessment of a bank's capital assessment process.
CONCLUSION
Implementation of Basel II has been described as a long journey rather than a destination by itself.
Undoubtedly, it would require commitment of substantial capital and human resources on the part of
both banks and the supervisors. RBI has decided to follow a consultative process while implementing
Basel II norms and move in a gradual, sequential and co-coordinated manner. For this purpose,
dialogue has already been initiated with the stakeholders. A steering committee comprising
representatives of banks and different supervisory and regulatory departments is taking stock of all
issues relating to its implementation. As envisaged by the Basel Committee, the accounting profession
too, will make a positive contribution in this respect to make Indian banking system stronger.