The Basel ii
Accord
From the Basel ii Compliance Professionals Association (BCPA)
the largest association of Basel ii Professionals in the
world
11. The Committee also
wishes to highlight the need for banks and supervisors
to give appropriate attention to the second (supervisory
review) and third (market discipline) pillars of the
revised Framework.
It is critical that the
minimum capital requirements of the first pillar be
accompanied by a robust implementation of the second,
including efforts by banks to assess their capital
adequacy and by supervisors to review such assessments.
In addition, the disclosures provided under the third
pillar of this Framework will be essential in ensuring
that market discipline is an effective complement to the
other two pillars.
12. The Committee is
aware that interactions between regulatory and
accounting approaches at both the national and
international level can have significant consequences
for the comparability of the resulting measures of
capital adequacy and for the costs associated with the
implementation of these approaches.
The Committee believes
that its decisions with respect to unexpected and
expected losses represent a major step forward
in this regard.
The Committee and its
members intend to continue playing a pro-active role in
the dialogue with accounting authorities in an effort to
reduce, wherever possible, inappropriate disparities
between regulatory and accounting standards.
13. The revised
Framework presented here reflects several significant
changes relative o the Committee’s most recent
consultative proposal in April 2003.
A number of these changes
have already been described in the Committee’s press
statements of October 2003, January 2004 and May 2004.
These include the
changes
in the approach to the treatment of expected losses (EL)
and unexpected losses (UL) and to the treatment of
securitisation exposures.
In addition to these, changes
in the treatments of credit risk mitigation
and qualifying revolving retail exposures, among
others, are also being incorporated.
The Committee also has
sought to clarify its expectations regarding the need
for banks using the advanced IRB approach to incorporate
the effects arising from economic downturns into their
loss-given-default (LGD) parameters.
14. The Committee believes
it is important to reiterate its objectives regarding
the overall level of minimum
capital requirements.
These are to broadly
maintain the aggregate level of such requirements, while
also providing incentives to adopt the more advanced
risk-sensitive approaches of the revised Framework.
To attain the objective,
the Committee applies a scaling factor to the
risk-weighted asset amounts for credit risk under the
IRB approach.
The current best estimate
of the scaling factor using quantitative impact study
data is 1.06.
National authorities will
continue to monitor capital requirements during the
implementation period of the revised Framework.
Moreover, the Committee
will monitor national experiences with the revised
Framework.
15. The Committee has
designed the revised Framework to be a more
forward-looking approach to capital adequacy
supervision, one that has the capacity to evolve with
time.
This evolution
is necessary to ensure that the
Framework keeps pace with market developments and
advances in risk management practices, and the Committee
intends to monitor these developments and to make
revisions when necessary.
In this regard, the
Committee has benefited greatly from its frequent
interactions with industry participants and looks
forward to enhanced opportunities for dialogue.
The Committee also intends
to keep the industry apprised of its future work agenda.
16. In July 2005,
the
Committee published additional guidance in the document
The Application of Basel II to Trading Activities and
the Treatment of Double Default Effects.
That guidance
was developed jointly with the International
Organization of Securities Commissions (IOSCO) and
demonstrates the capacity of the revised Framework to
evolve with time.
It refined the treatments
of counterparty credit risk, double default effects,
short term maturity adjustment and failed transactions,
and improved the trading book regime.*
*
The additional guidance does not modify the definition
of trading book set forth in the revised Framework.
Rather, it focuses on policies and procedures that banks
must have in place to book exposures in their trading
book.
However, it is the Committee’s view that, at the present
time, open equity stakes in hedge funds, private equity
investments and real estate holdings do not meet the
definition of trading book, owing to significant
constraints on the ability of banks to liquidate these
positions and value them reliably on a daily basis.
17. One area where the
Committee intends to undertake additional work of a
longer term nature is in relation to the
definition of eligible capital.
One motivation for this is
the fact that the changes in the treatment of expected
and unexpected losses and related changes in the
treatment of provisions in the Framework set out here
generally tend to reduce Tier 1
capital requirements relative to total capital
requirements.
Moreover, converging on a
uniform international capital standard under this
Framework will ultimately require the identification of
an agreed set of capital instruments that are available
to absorb unanticipated losses on a going-concern basis.
The Committee announced
its intention to review the
definition of capital as a follow-up to the
revised approach to Tier 1 eligibility as announced in
its October 1998 press release, “Instruments eligible
for inclusion in Tier 1 capital”.
It will explore further
issues surrounding the definition of regulatory capital,
but does not intend to propose changes as a result of
this longer-term review prior to the implementation of
the revised Framework set out in this document.
In the meantime, the
Committee will continue its efforts to ensure the
consistent application of its 1998 decisions regarding
the composition of regulatory capital across
jurisdictions.
18. The Committee also
seeks to continue to engage the banking industry in a
discussion of prevailing
risk management practices, including those practices
aiming to produce quantified measures of risk and
economic capital.
Over the last decade, a
number of banking organisations
have invested resources in modelling the credit
risk arising from their significant business operations.
Such models are intended
to assist banks in quantifying, aggregating and managing
credit risk across geographic and
product lines.
While the Framework
presented in this document stops short of allowing the
results of such credit risk models to be used for
regulatory capital purposes, the Committee recognises
the importance of continued active dialogue regarding
both the performance of such models and their
comparability across banks.
Moreover, the Committee
believes that a successful implementation of the revised
Framework will provide banks and supervisors with
critical experience necessary to address such
challenges.
The Committee understands that the IRB approach represents a point on the continuum
between purely regulatory measures of credit risk and an
approach that builds more fully on internal credit risk
models.
In principle, further
movements along that continuum are foreseeable,
subject to an ability to address
adequately concerns about reliability, comparability,
validation, and competitive equity.
In the meantime, the
Committee believes that additional attention to the
results of internal credit risk models in the
supervisory review process and in banks’ disclosures
will be highly beneficial for the accumulation of
information on the relevant issues.
19. This document is
divided into four parts.
The first part, scope of application, details how
the capital requirements are to be applied within a
banking group.
Calculation of the minimum capital
requirements for credit risk, operational risk, and
market risk are provided in part two.
The third and
fourth parts outline expectations concerning
supervisory review and market discipline, respectively.
19(i). This comprehensive
version of the revised Framework incorporates the
additional guidance set forth in the Committee’s paper
The Application of Basel II to Trading Activities and
the Treatment of Double Default Effects (July 2005), the
Amendment to the Capital Accord to Incorporate Market
Risks (January 1996) as well as elements of the 1988
Accord that remain in effect.
This version is primarily
aimed at providing banks with a comprehensive view of
international solvency standards. It does not contain
any new elements.
Each of the individual
documents incorporated into this text (i.e. the 1988
Accord, the Amendment to the Capital Accord to
Incorporate Market Risks, and The Application of Basel
II to Trading Activities and the Treatment of Double
Default Effects) will remain available on a stand-alone
basis.
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