Basel 4: The way ahead Credit Risk - IRB approach Closing in on consistency? April 2018 kpmg.com/basel4 The way ahead 2 Contents 01 Introduction The revised standards published by the Basel Committee in December 1 / Introduction 2 2017 included new rules regarding the 2 / Impact on banks’ capital ratios 3 use of the Internal Ratings Based (IRB) 3 / Additional impacts 6 approach for the calculation of risk weighted credit exposures. 4 / How KPMG can help 7 5 / The finer details 8 While these changes to IRB are not as severe as some banks had feared, they represent a further erosion of the benefits of internal models and need careful consideration by banks who either have IRB approval or are considering applying for it. The Basel 4 revisions arrive in an environment already awash with regulatory and supervisory activity. In particular, the ‘excess variability’ in risk weights caused by internal modelling has been a key driver for a suite of European Banking Authority (EBA) Regulatory Technical Standards and Guidelines as well as the ECB TRIM (Targeted Review of Internal Models) initiative. Figure 1: Selected events and regulatory activities affecting the IRB approach Basel Committee agree European Parliament Basel Committee Implementation Introduction of the overall design of the and Council publish the publish the final revisions date for the Basel IRB in Basel 2. capital and liquidity reform CRR and CRD IV, which to the Basel 3 standards Committee revisions package, now referred to transpose Basel 3 into (informally known as to the IRB framework. as “Basel 3”. EU law. “Basel 4”). 2004 2011 2013 2016 2017 2022 ECB start the Targeted Review of EBA start development and publication of a suite of Guidelines Internal Models (TRIM) project in 2016, and Regulatory Technical Standards (several of which relate to which is expected to conclude in 2019. internal models), including: Objectives: to reduce inconsistencies – Regulatory Technical Standards on the assessment and unwarranted variability when using methodology for the IRB approach internal models, and to harmonize practices in relation to specific topics. – Guidelines on PD, LGD estimation and the treatment of defaulted exposures – Discussion paper on the Future of the IRB approach. © 2018 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated. All rights reserved. The way ahead 3 02 Impact on banks’ capital ratios The main revisions to the IRB framework are: – Restrictions on the IRB approach – the minimum PD (floor) has increased from 0.03 Advanced-IRB approach is no longer allowed percent to 0.05 percent, and LGD floors set for exposures to banks and other financial for different collateral types. Similarly new PD institutions, or for corporates belonging to a and LGD floors are in place for retail exposures group with total consolidated annual revenues (for QRRE2 revolvers the PD floor is increased greater than €500 million (note that Foundation- to 0.1 percent). AIRB is still allowed for these exposures). Further, no IRB approach is allowed for equity These changes, in particular the restriction on the 1 exposures . IRB approach and the introduction of parameter floors, will have a direct impact on Pillar 1 capital – Risk Weighted Asset (RWA) calculation – requirements. removal of the 1.06 scaling factor used in the calculation of Risk Weighted Assets for credit Data from the 2017 EBA Transparency exercise risk exposures. show a wide range of IRB usage across countries, with overall risk weights aligned (inversely) to the – Risk parameter floors – introductiont of PD, level of usage. LGD, EAD and CCF floors for corporate and retail exposures. For corporate exposures the Figure 2: Proportion of Credit Risk exposures under the IRB approach and average credit risk weight (June 2017) 100% Average risk weight 80% % of exposure covered by IRB 60% 40% 20% 0% Italy Spain Ireland France Greece Austria Finland Sweden Average Germany Belgium Netherlands United Kingdom Source: KPMG 1. The prohibition on the use of the IRB approach for equity exposures will be subject to a five-year linear phase-in arrangement starting from 2022, unless supervisory authorities require complete phase-in immediately in 2022. 2. Qualifying Revolving Retail Exposure, for example credit cards © 2018 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated. All rights reserved. The way ahead 4 Including the Basel Committee revisions to the Standardised Approach to Credit Risk and the new output floor2 in addition to the revisions to the IRB approach, KPMG experts estimate that over three quarters of European banks would see a fall in their CET 1 capital ratio (see Figure 3, where each point represents an IRB bank in the EBA Transparency data sample). Figure 3: CET 1 ratio impacts for European IRB banks (Credit Risk changes and output floor) 35% 30% CET 1 ratio worsens 25% 20% Image required 15% Original CET 1 ratio Original 10% 5% CET 1 ratio improves 0% 0% 5% 10% 15% 20% 25% 30% 35% New CET 1 ratio This analysis also shows that Swedish and Danish banks would, on average, be the most heavily affected. In particular Sweden has a number of banks with a high degree of exposure to residential mortgage loans where the use of internal models and low historic default rates has resulted in risk weights significantly lower than in other counties. Under the output floor this leads to a major depletion in CET 1 ratio - however as these banks are currently well capitalised there should still remain headroom over regulatory requirements. Figure 4: Indicative effects of the changes to Credit Risk and Output floor 600 500 400 300 200 3. No assumption has been made in this 100 analysis regarding risk types other Average basis point reduction in CET 1 ratio basis point reduction Average than Credit (for example Market Risk or Operational Risk). As such, this 0 does not represent the “true” impact Italy of applying the output floor, rather a Spain France Ireland Finland Greece Austria Sweden proxy-floor based only on credit risk. Belgium Germany Netherlands United Kingdom Across other countries the impact is not as severe. There are several countries where the credit risk changes have negligible impact on CET1 capital ratios. In some of these cases this is due to limited use of the IRB approach, while in other countries there is less of a divergence between modelled and standardised risk weights (in which case the effect of the floor is mitigated). © 2018 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated. All rights reserved. The way ahead 5 Overall, there appear to be limited capital impacts Figure 5: Restrictions on the use of the IRB approach for most banks as a result of restrictions on the IRB approach and the new Total Credit Risk exposure for EBA IRB parameter floors. European reporting sample (all The restrictions on the IRB approaches): €28.5 trillion approach (no A-IRB for banks or large corporates, and no IRB for equities) affect only a small proportion of banks’ total exposures. of exposures are on As shown above the changes 65% the IRB approach. 35% to Credit Risk under Basel 4 are expected, on average, The following exposures will be affected by are on the to increase a bank’s capital restrictions on the IRB approach: Standardised requirements once the approach output floor is applied. So 3 purely on the basis of own 16% 6% 0.4% funds requirements there Corporates Banks Equity may be less incentive to use (Exc. SME/8L) the IRB approach. However the difference between average risk weights on the IRB and Standardised approaches still leaves scope 10% 3% Total proportion of exposures for capital benefits from more affected by IRB restrictions is advanced approaches. A-IRB A-IRB expected to be limited While more subjective, the increased granularity of risk measurement that accompanies the IRB approach Meanwhile, the incremental change in risk can also help the business 0-10% weights from moving fromA-IRB to F-IRB understand and manage its may also be quite limited for some banks credit risk more effectively. Corporates with annual revenue > €500m Risk weight comparison (estimated based on Pillar 3 data) F-IRB Banks A-IRB F-IRB Corporates (exc. SME/SL) A-IRB 0% 0% 50% 100% Source: KPMG analysis of EBA Transparency data and Pillar 3 disclosure reports 4. These percentages are based on the entire sample of exposures, i.e. both IRB and Standardised. © 2018 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated. All rights reserved. The way ahead 6 Product offering and pricing 03 Additional The relative attractiveness of different credit products will shift based on the associated cost of capital. It is unlikely that the Basel 4 IRB changes by themselves would lead to a reduction in lending, as such portfolio decisions are influenced by a wider impacts dynamic of profitability, costs and market positioning. Some banks may look to reprice risk and gradually rebalance their portfolio composition, particularly since the increased sensitivity of risk weights under the new Standardised Approach Beyond the quantitative impacts would have impacts for both Standardised Approach banks as well as those using IRB. outlined above, it is expected that the Basel 4 changes will force banks to re-examine the Controls and governance distribution of exposures across The revised calculation of Pillar 1 capital requirements for credit types of credit, and the set up of risk will require appropriate control procedures and governance, their data and systems.