Shamshad Akhtar: Pakistan - changing risk management paradigm -
perspective of the regulator
Speech by Dr Shamshad Akhtar, Governor of the State Bank of Pakistan, at the ACCA Conference
"CFOs: The Opportunities and Challenges Ahead", Karachi, 13 March 2007.
* * *
A paradigm shift has taken place in the banking sector of Pakistan in recent years. Today, the sector is
relatively more robust, market based and highly profitable than it was ever before. The new paradigm
has emerged largely as a result of the flexible monetary management, adoption of market oriented
banking sector policies, transfer of ownership both in private and foreign hands, clean up and
resolution of banks' loan portfolios, and strengthening of regulatory and supervisory standards. In this
session, I will discuss the (i) overall risks Pakistani banks face as a result of the changing economic
and banking paradigm, (ii) identify the role bank regulations and supervision play in risk management,
(iii) share perspectives on the key risks facing Pakistani banks and briefly touch on the emerging
trends, and (iv) highlight central bank and banking industry's initiatives to strengthen the banks and
system-wide risk management.
Emerging challenges and risks from changing paradigm
Most critical among this is recognition:
•
First, that Pakistani banks like other emerging economies have benefited from
macroeconomic stability and resilience of the economy, there is ample evidence that
emerging economies, including Pakistan, are more significantly prone and exposed to
shocks than developed countries.
•
Second, Pakistani banks are today faced with new forms of risks which have altered the
nature and type of risk they are exposed to - aside from standard corporate assets whose
credit risks is changing with the size and complexities of businesses, banks are now
engaging in diverse businesses and sectors and are now extending their exposure to
household sector and growth in bank trading books has increased exposure to market risk -
a recent phenomena in Pakistan. Concurrently, banks' overall risk profile is also affected by
the complex interdependencies now emerging because of cross ownership of financial
institutions and corporate sector.
•
Third, that enhanced risk exposures can, however, be well managed given that today world
is more informed about what drives exogenous and endogenous shocks and how to
effectively deal with them through improved measurement, management and mitigation of a
wide array of risks i.e. macroeconomic risks, credit risk, liquidity risk, market risks, solvency
risks and operational risks.
• Fourth, bulk of banks now being under private ownership can no longer count on taxpayer
funds to rescue them and recognition that uncompetitive institutions have to be prepared to
exit or to fast restructure.
Existing regulatory and supervisory framework - principles and approaches
As a regulator, SBP has established a comprehensive and well balanced regulatory and supervisory
system to inculcate a culture of sound risk management within banks. Simultaneously SBP's
capacities have been enhanced to effectively regulate and supervise banks and assess system wide
risks, both on a quarterly and annual basis. Generally, banking regulations have been designed
keeping in perspective Pakistan's economic and political realities, prevailing banking practices, and
environment for legal recourse and property registry systems all of which constitute integral elements
of the risk management infrastructure. Regulatory framework offers guidance on risk measurement
and management and its tools. After being overhauled in 2004, the regulatory framework currently
enforced has a good blend of conservatism and prescription while allowing for flexibility and
pragmatism to relax exposures when banks have developed effective capacities and systems to
mitigate risks.
The main elements of regulatory framework are to;
(i) Encourage establishment of well capitalized banks - all banks are expected to meet the
minimum capital requirements of $100 million by 2009. The requirement for capital has
facilitated gradual consolidation and emergence of stronger banks, while allowing banks to
take greater risk exposures to the extent that a set of regulations are linked to the equity
base of banks. Currently, 8 banks are fully complying with these requirements and others are
striving to accelerate compliance,
(ii) Encourage banks to contain risk exposures. For instance, both the individual or group
exposure is linked to borrowers' capacity as well as bank's equity base. Similarly, banks
have to contain their trading books through a set of regulations that define the exposure to
investment and lending in stock market (Prudential Regulation R-6),
(iii) While encouraging sector diversification through a set of development oriented prudential
regulations for agriculture, small and medium enterprises and microfinance etc., the
regulations are by and large advocating better risk management and controls to help
diversify and extend bank's outreach,
(iv) Encourage financial stability through guidelines on corporate governance, anti-money
laundering, risk management, internal controls, stress testing, on country risk
management, information technology security etc,
(v) Encourage financial innovation while keeping in perspective bank's capacity to manage
risks. Keeping in view the role derivatives play in risk management, SBP formulated
Financial Derivatives Business Regulation (FDBR 2004). SBP grants Authorized
Derivative Dealer (ADD) status to banks that has been assessed to have adequate systems
and expertise to conduct derivatives business. Banks which are now allowed to sell
derivatives not only to hedge for their customers' interest rate and foreign exchange risks,
but take on for the management of the risks in their own books, and
(vi) Enhancement of Disclosure requirements: The SBP in collaboration with the ICAP and
the commercial banks has facilitated adoption of International Accounting standards (IAS) by
the banks. In 2006, SBP revised the reporting formats for banks to incorporate the significant
regulatory developments as well as modifications in the International Financial Reporting
Standards (IFRS). With these changes, the quality of disclosure in the Annual Accounts of
Pakistani banks has become at par with international best practices.
To ensure effective enforcement of regulations, besides day to day oversight, SBP has substantially
enhanced its on-site inspection and off-site surveillance capacity. Regular onsite inspections of all
financial institution provide an assessment of FIs/banks overall financial condition, evaluate its
management and Board performance and check compliance with legal and regulatory requirements.
Keeping in view the developments taking place in the financial sector, increase in its size and
complexity and introduction of new and innovative financial products, State Bank inspection is also
updating its tools and methodologies. We have already realized that going forward specialized skills
will be required to assess and evaluate areas like consumer financing, Islamic Banking, treasury,
foreign exchange, information technology etc. We have also identified other critical areas for our
supervisory focus like Basel II, Anti Money Laundering, internal risk models etc. and capacity building
initiatives are being taken in these areas.
In line with practices of regulators, SBP has introduced IRAF (Institution Risk Assessment
Framework). It offers a composite rating drawing from offsite and onsite feedback, findings of
management of banks on board, to establish their rating regarding their compliance with standards,
codes and guidelines issued by SBP. IRAF once fully operational will make the supervisory process an
all-inclusive and comprehensive exercise which includes information from SBP, Board and
Management as well as market vigilance regarding the health of banks.
Perspective on key risks facing Pakistani banks
Like all other regulators, SBP is encouraging banks to strengthen their risk assessment capability and
testing their capacity to withstand shocks under different scenarios. SBP offers its perspective on
system wide risks publicly through its Financial Sector Assessment Report and Quarterly Banking
Surveillance Reports. The findings of these reports confirm that thus far banks risks are diversified and
managed in line with the banking regulations. An analysis of trends in different types of risk would offer
better appreciation and perspective on changes in banks' risk profile:
Credit risk: In Pakistani banks, credit operations remain the main source of banks income and have
been supported by strong economic activity. Given its size, credit operations are a primary source of
risk. Supported by growth in businesses and gradual improvement in internal credit reviews, on
balance credit risk have been well managed. The net NPLs to net loan ratio have declined in the last
few years and fell to 1.8% by September 2006.
In recent years, the macroeconomic environment has been supportive of the growth of banking
systems but the growing fiscal imbalance and the external imbalances have enhanced domestic
demand pressures. While the vulnerabilities of banking system have been well managed, the shocks
arising from external sources can be a cause of concern. Exposure to perceived risks arise from the (i)
structural problems facing the real sector whose resolution is critical to maintain the momentum in
credit operations, and (ii) high domestic asset prices given high interest rates, equity prices and
property prices.
Underlying the credit growth is altering risk exposures which need to be well tracked to ensure their
effective risk management. There is a broader concern that the growing domestic demand have
impact on bank asset quality and the growing exposure of household sector to consumer financing
could have their attendant risks. Consumer finance has risen from 2.4% in 2002 to 14.3% by
September 2006 and number of borrowers of consumer finance from 0.25 million to 2.6 million,
respectively.
Thus far credit risks on the banking books associated with some assets has been limited. For
instance, the housing finance is barely $1 billion (or 2.3% of total loan outstanding) and mortgage
business non-existent.
Market risk: Banks market risk exposure largely stems from the interest rate risk as the equity price
and exchange rate risks are not substantial given their exposure in balance sheet is limited. Interest
rate risk emanates from movements in interest rates, which are determined both by the liquidity
available and its response to short term rates and the future expectations of economy, the longer term
yield curve. Interest rates in Pakistan have remained volatile in line with demand pressures during the
past few years. After the 9/11, initially growth in liquidity resulted in fall in interest rates and by August
2003 the interest rates reached lowest levels and the differential between the interest rates on Rupee
and Dollar squeezed. Low interest rates added to the revaluation gains especially for those banks
which were holding longer term fixed investment securities and carrying positive duration GAP.
Subsequently, interest rates rose with the building up of inflationary pressures. Consequently, banks
with significant interest rate exposures had to bear the risks related to their positions. The impact of
these trends was manageable as banks were able to hedge their positions in response to the SBP
clear monetary policy signals.
To evolve better risk management, SBP has allowed derivatives to hedge the open positions of the
banks. With the increased knowledge, and realizing the importance of managing the interest rate risks,
large banks have established systems and models to better assess and manage interest rate risks.
Banks use different quantitative techniques, like VaR models, to assess the risk of loss focusing on tail
events. Under the guidance of SBP, they recognize the duration of their assets and liabilities and
conduct appropriate sensitivity analysis. With these analytical tools, banks have better understanding
of their interest rate risk profile and accordingly better management of such risk exposures. However,
banks need to move to more broad based and refined risk management systems so as to capture the
right risks at right time. Independently, SBP reviews market risk profile and the mismatches in the
assets and liabilities of banks, which generally remain with in the acceptable limits.
Liquidity risk: Banks need to be equipped to deal with the changing monetary stance which shapes
the overall liquidity trends and the FIs/banks own transactional requirements and repayment of
shortterm borrowings. In the modern financial markets, banks have to manage their liquidity through
money-market operations which offer a range of options and at any given point has ready providers
and buyers of liquidity. In case of temporary liquidity squeeze banks can resort to discount window
operation, and in situation where it threatens bank solvency they can resort to the lender of the last
resort facility.
As highlighted above, from 1999-2003 banks liquidity position was comfortable supported by easy
monetary policy. With the growing monetary tightening the central bank has focused on strengthening
its capacities for liquidity forecasting and management and conducted effective OMOs to ease or
tighten liquidity pressures. In general banks have contained their liquidity risks, but liquidity position of
banks has been tightened as evident from rising loans to deposits ratio at 73.2% with some banks
reporting above these averages. Liquidity risks can, however, be effectively managed if banks address
the fundamental problem of maturity mismatches stemming largely because of bank's unwillingness to
extend their deposit tenor which has limited bank's capacity to lend long too.
Operational risk: Growth in business did stress the individual and system wide financial
infrastructure. However, industry is launching initiatives to strengthen its operational capacities by
augmenting its systems and processes & adapting information technology solution and outsourcing.
Growing wave of mergers and acquisitions leading to conforming business practices have introduced
fresh complexity in the operational processes and procedures of the financial institutions. Besides,
introduction of new risk management processes and products and hedging strategies, which although
reduce credit and market risk but may create additional operational risks, which are on the rising
trends. SBP is encouraging banks to adopt best practices to manage their operational risks and has
issued guidelines on the areas of Business Continuity Plan, Internal Control, and IT Security.
Operational risk was not effectively recognized and captured under the Basel I framework and as such
there was no capital charge specifically prescribed for operational risk. Revised Basel Capital Accord
(called Basel II), recognizes and defines the operational risks and its dimension and has prescribed
capital charge for it to be calculated based on the gross income of the bank. Under Basic Indicator
approach (BIA), capital charge for operational risk is a fixed percentage of average positive annual
gross income of the bank over the past three years. Whereas, under the standardized approach all the
business activities of the banks will be divided into eight business lines: corporate finance, trading &
sales, retail banking, commercial banking, payment & settlement, agency services, asset
management, and retail brokerage. The capital charge for each business line is based on gross
income from that line, and ranges from 12% to 18% of the average gross income of last three years
Despite increasing attention to operational risk, little systematic information exists on the extent and
impact of operational risk as the losses can result from a complex confluence of events, making it
difficult to predict or model contingencies. The biggest challenge for Pakistani banks is the availability
of relevant and accurate data within the affordable cost to develop robust and solid operational risk
measurement systems for quantification of expected and unexpected losses resulting from people,
systems, internal process, procedures and external events.
Major initiatives underway to strengthen risk management of banking industry
Besides being a regulatory tool for capital adequacy, the new Basel II accord encompasses a
comprehensive risk management system. The basic philosophy that the capital should be
commensurate with the level of risks has a lot of merit. There is a direct incentive to be more
discerning in identifying risk differentials among a set of opportunities and going about managing
these risks in a prudent manner. Efficient utilization of capital is the prime goal of Pillar I (MCR) of the
accord. Once the Basel framework is in place, banks with superior risk management skills would be
able to get a competitive advantage over their counterparts.
Recognizing this, Pakistan's roadmap for implementation of Basel II Accord advocates that banks
adopt the standardized approach from January 2008 - progress on this front varies from bank to
banks. Bank's ability to move towards Basel II would require them to address a number of challenges.
There is, among others, need for;
(i) Collective action to encourage corporate sector to become credit rated; as in absence of
recognized credit rating of borrowers, banks would end up allocating more capital than
warranted and this would render them uncompetitive,
(ii) Development of allied and support infrastructure that facilitates the process e.g. the internal
control and IT systems within the banks is absolutely imperative if the framework is to
succeed,
(iii) Presently the Basel II framework requires banks to apply a capital charge of 15% of average
positive gross income of last three years for operational risk (under BIA) there is a need to
clearly distinguish between a strong versus weak operational risk environment,
(iv) Availability of historical data, for the purpose of carrying out quantitative analysis, and
(v) Intensive capacity building of industry and SBP.
To discuss these and other challenges SBP has set up a working group to first assess the current
state of preparedness of the industry on a standard and agreed template for Basel II compliance and
identify joint collaborative action to facilitate smooth transition. Developing rating industry and
encouraging entry of raters which have been identified under Basel Accord-II would be critical for an
effective implementation of Basel II for Pakistani Banks. SBP would have to draw its own
understanding and linkages with the raters to ensure it is applying standards for weighing risks
effectively across industry.
SBP is in the process of developing a "Banking Supervision Risk Assessment Model" (BSRA)
which will help SBP to better quantify the credit and market risks of the individual banks in terms of
"Value at Risk" and forecast banks' position under various stress scenarios on a quarterly basis. BSRA
model would use information from the Data warehouse (data received through Reporting Chart of
Accounts (ROCA)) for market risk and electronic Credit Information Bureau (eCIB) for credit risk. For
operational risk, key risk indicators (e.g. frauds, systems breakdown etc) would be identified and
captured and processing would be carried out after a sufficient database is maintained. Once fully
implemented and live, the risk assessment model will help Banking Supervision Department to
strengthen its surveillance system through monitoring and measuring the risk profiles of the individual
banks, even under stressed scenarios. The model will also help BSD to understand and monitor the
credit and market risk appetite of the individual banks and proactively take corrective measures, if
required.
Conclusion
The changing economic and banking paradigm has increased the complexities and risk facing banks.
While the industry has been bracing up to face the changing risk paradigms which have included not
only enhanced exposures to corporate sector but now banks are extending their outreach to
household sector, SME and microfinance whose exposures need to be better managed through
effective risk management. SBP has adopted sound regulations and proactive supervision to ensure
effective surveillance of banks and is advising banks to manage their risks prudently. Despite the
growth and diversity in businesses and emerging macroeconomic pressures, banking system has
shown a degree of resilience. Results from latest stress tests for all Banks for Third Quarter of 2006
while applying different credit and market shocks to calibrate its impact on solvency i.e. the capital
adequacy ratio of the banks indicates that after shock CAR of all banks remain above 11%. Like in
previous years, credit risk weight remains high and is assigned bulk of the capital, while market risk is
confined to largely interest rate risk with equity risk now being an emerging phenomenon. The liquidity
shocks do reflect a decline in liquidity coverage ratio of varying order among different institutions - a
5-10% decline in the liquid liabilities would lower liquidity coverage ratio by 3-7%.
In the short term, while banks would have to continue effective risk management through better
assessment of credit and market risks, but going forward in anticipation of Basel -II Accord, more
fundamental changes in approaches and methodologies of both individual categories of risk is
required and extending its reach to operational risk which is currently not accounted for. SBP will
continue with its close consultations with the banking industry to get aligned with the international
regulatory standards and solve the challenges arising out of these standards jointly with the industry in
a congenial environment.