Basel ii Accord 109 to 128

D. The standardised approach ─ credit risk mitigation
1. Overarching issues
 
(i) Introduction
 
109. Banks use a number of techniques to mitigate the credit risks to which they are
exposed. For example, exposures may be collateralised by first priority claims, in whole or in
part with cash or securities, a loan exposure may be guaranteed by a third party, or a bank
may buy a credit derivative to offset various forms of credit risk.
 
Additionally banks may agree to net loans owed to them against deposits from the same counterparty.
 
110. Where these techniques meet the requirements for legal certainty as described in
paragraph 117 and 118 below, the revised approach to CRM allows a wider range of credit
risk mitigants to be recognised for regulatory capital purposes than is permitted under the
1988 Accord.
 
(ii) General remarks
 
111. The framework set out in this Section II is applicable to the banking book exposures
in the standardised approach.
 
For the treatment of CRM in the IRB approach, see Section III.
 
112. The comprehensive approach for the treatment of collateral (see paragraphs 130 to
138 and 145 to 181) will also be applied to calculate the counterparty risk charges for OTC
derivatives and repo-style transactions booked in the trading book.
 
113. No transaction in which CRM techniques are used should receive a higher capital
requirement than an otherwise identical transaction where such techniques are not used.
 
114. The effects of CRM will not be double counted. Therefore, no additional supervisory
recognition of CRM for regulatory capital purposes will be granted on claims for which an
issue-specific rating is used that already reflects that CRM.
 
As stated in paragraph 100 of the section on the standardised approach, principal-only ratings will also not be allowed within the framework of CRM.
 
115. While the use of CRM techniques reduces or transfers credit risk, it simultaneously
may increase other risks (residual risks). Residual risks include legal, operational, liquidity
and market risks.
 
Therefore, it is imperative that banks employ robust procedures and processes to control these risks, including strategy; consideration of the underlying credit; valuation; policies and procedures; systems; control of roll-off risks; and management of concentration risk arising from the bank’s use of CRM techniques and its interaction with the bank’s overall credit risk profile.
 
Where these risks are not adequately controlled, supervisors may impose additional capital charges or take other supervisory actions as outlined in Pillar 2.
 
116. The Pillar 3 requirements must also be observed for banks to obtain capital relief in
respect of any CRM techniques.
 
(iii) Legal certainty
 
117. In order for banks to obtain capital relief for any use of CRM techniques, the
following minimum standards for legal documentation must be met.
 
118. All documentation used in collateralised transactions and for documenting onbalance
sheet netting, guarantees and credit derivatives must be binding on all parties and
legally enforceable in all relevant jurisdictions.
 
Banks must have conducted sufficient legal review to verify this and have a well founded legal basis to reach this conclusion, and undertake such further review as necessary to ensure continuing enforceability.
 
2. Overview of Credit Risk Mitigation Techniques (38)
 
(i) Collateralised transactions
 
(38) See Annex 10 for an overview of methodologies for the capital treatment of transactions secured by financial
collateral under the standardised and IRB approaches.
 
119. A collateralised transaction is one in which:
banks have a credit exposure or potential credit exposure; and
that credit exposure or potential credit exposure is hedged in whole or in part by
collateral posted by a counterparty (39) or by a third party on behalf of the counterparty.
39 In this section “counterparty” is used to denote a party to whom a bank has an on- or off-balance sheet credit exposure or a potential credit exposure. That exposure may, for example, take the form of a loan of cash or securities (where the counterparty would traditionally be called the borrower), of securities posted as collateral, of a commitment or of exposure under an OTC derivatives contract.
 
120. Where banks take eligible financial collateral (e.g. cash or securities, more
specifically defined in paragraphs 145 and 146 below), they are allowed to reduce their credit
exposure to a counterparty when calculating their capital requirements to take account of the risk mitigating effect of the collateral.
 
Overall framework and minimum conditions
 
121. Banks may opt for either the simple approach, which, similar to the 1988 Accord,
substitutes the risk weighting of the collateral for the risk weighting of the counterparty for the collateralised portion of the exposure (generally subject to a 20% floor), or for the
comprehensive approach, which allows fuller offset of collateral against exposures, by
effectively reducing the exposure amount by the value ascribed to the collateral.
 
Banks may operate under either, but not both, approaches in the banking book, but only under the comprehensive approach in the trading book. Partial collateralisation is recognised in both approaches. Mismatches in the maturity of the underlying exposure and the collateral will only be allowed under the comprehensive approach.
 
122. However, before capital relief will be granted in respect of any form of collateral, the
standards set out below in paragraphs 123 to 126 must be met under either approach.
 
123. In addition to the general requirements for legal certainty set out in paragraphs 117
and 118, the legal mechanism by which collateral is pledged or transferred must ensure that
the bank has the right to liquidate or take legal possession of it, in a timely manner, in the
event of the default, insolvency or bankruptcy (or one or more otherwise-defined credit
events set out in the transaction documentation) of the counterparty (and, where applicable,
of the custodian holding the collateral).
 
Furthermore banks must take all steps necessary to fulfil those requirements under the law applicable to the bank’s interest in the collateral for obtaining and maintaining an enforceable security interest, e.g. by registering it with a registrar, or for exercising a right to net or set off in relation to title transfer collateral.
 
124. In order for collateral to provide protection, the credit quality of the counterparty and
the value of the collateral must not have a material positive correlation. For example,
securities issued by the counterparty ─ or by any related group entity ─ would provide little
protection and so would be ineligible.
 
125. Banks must have clear and robust procedures for the timely liquidation of collateral
to ensure that any legal conditions required for declaring the default of the counterparty and
liquidating the collateral are observed, and that collateral can be liquidated promptly.
 
126. Where the collateral is held by a custodian, banks must take reasonable steps to
ensure that the custodian segregates the collateral from its own assets.
 
127. A capital requirement will be applied to a bank on either side of the collateralised
transaction: for example, both repos and reverse repos will be subject to capital requirements. Likewise, both sides of a securities lending and borrowing transaction will be
subject to explicit capital charges, as will the posting of securities in connection with a
derivative exposure or other borrowing.
 
128. Where a bank, acting as an agent, arranges a repo-style transaction (i.e. repurchase/reverse repurchase and securities lending/borrowing transactions) between
a customer and a third party and provides a guarantee to the customer that the third party
will perform on its obligations, then the risk to the bank is the same as if the bank had
entered into the transaction as a principal. In such circumstances, a bank will be required to
calculate capital requirements as if it were itself the principal.
   
 

 

 

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