This will in turn ultimately bring benefits to the consumers and the economy at large. Implementation challenges and considerations Ladies and Gentlemen, Given the complexity of Basel II, the ability to comply appears to be the main concern within the banking community. This is truly a major undertaking with respect to the IRB approaches or the internal rating based systems. The resources involved and data constraints are often cited as the two main challenges in implementing the IRB approach, particularly for banks in the emerging markets. At this stage, data on default and credit migration for certain market segments is too limited to facilitate any meaningful analysis. It is therefore recognized that some lead time would be needed for banking institutions to produce a robust and meaningful validation of internal estimates of probabilities of default and loss given default. However, this does not mean that banks should wait until all the requisite data is in place. Banks can initiate work to establish the framework for analytical functions. While the industry survey conducted by Bank Negara Malaysia revealed a strong preference among Malaysian banking institutions to adopt the IRB approach, many had indicated the need to further strengthen their business case and undertake more comprehensive gap and impact analysis. This is indeed a critical process. Of importance is to be able to extract the benefits out of the new accord. This would however, take time even for large and internationally active banking institutions that have made substantial enhancements over the years.

To support banks’ capacity to lend, MAS has implemented transitional measures till endSeptember 2021: Allowing banks to recognise 100% of regulatory loss allowance reserves as Tier 2 capital; and Reducing from 50% to 25% the amount of stable funding that banks must maintain on loans to individuals and businesses maturing in less than six months. MAS also provided guidance to financial institutions on estimating their loan loss allowances in the context of COVID-19: That in assessing COVID-19’s impact on future economic conditions, financial institutions should consider the government’s support measures in bolstering economic resilience; and That financial institutions need not maintain higher loan loss allowances solely because 8 / 15  BIS central bankers' speeches  COVID-19 relief measures were applied to certain loans. MAS provided room for insurance companies to rebalance their investment portfolios in the face of uncertainties in financial markets: By extending to end-2021 the transitional measure in the calculation of their financial resources under RBC 2. OPERATIONAL RESILIENCE OF FINANCIAL INSTITUTIONS  The financial sector has been operationally resilient, functioning with minimal disruption in the face of COVID-19. The financial industry has maintained a high level of customer service throughout the Circuit Breaker period, as well as Phases One and Two of the re-opening. They have also continued to seamlessly conduct their wholesale and international businesses. The industry’s operational resilience reflects sound business continuity planning and agile adjustments to work processes.