
<p>May 2019 – Issue 4 </p><p><strong>Credit Journal </strong></p><p>Global Banking </p><p>Private Placement </p><p></p><ul style="display: flex;"><li style="flex:1"><strong>1</strong></li><li style="flex:1"><strong>2</strong></li><li style="flex:1"><strong>3</strong></li></ul><p></p><p>Banks </p><p></p><ul style="display: flex;"><li style="flex:1">Regulation </li><li style="flex:1">Non-Bank Financial </li></ul><p>Institutions </p><p></p><ul style="display: flex;"><li style="flex:1">PAGE 2 </li><li style="flex:1">PAGE 8 </li><li style="flex:1">PAGE 11 </li></ul><p></p><p></p><ul style="display: flex;"><li style="flex:1"><strong>6</strong></li><li style="flex:1"><strong>4</strong></li><li style="flex:1"><strong>5</strong></li></ul><p></p><p>News & Events </p><p>Meet the Analyst </p><p>Q&A with Kevin Duignan, Global Head of Financial Institutions Ratings </p><p>Global Focus </p><p>PAGE 20 </p><ul style="display: flex;"><li style="flex:1">PAGE 14 </li><li style="flex:1">PAGE 16 </li></ul><p></p><p>Welcome to <strong>Credit Journal </strong>– a curated compilation of Fitch Ratings’ in-depth research and commentary. This latest </p><p>edition takes a deep dive into banks and non-bank financial </p><p>institutions (NBFIs). With coverage of close to 3,000 banks, </p><p>securities firms, finance and leasing companies, financial </p><p>market infrastructure companies, business development companies (BDCs), and investment managers, we are a leading force in bank and NBFI ratings. </p><p>We hope this issue, as well as future ones, serve as reliable resources and help you make more informed investment decisions. We welcome comments for future issues, </p><p>including suggestions for topical or credit-specific research. </p><p>For our latest insights, please visit <strong>fitchratings.com </strong></p><p>Welcome </p><p>In this new edition of Fitch Ratings’ Credit Journal, I am pleased to share with you a snapshot of Fitch’s credit views in the Bank and Non-Bank Financial Institution (NBFI) sectors. </p><p>With heightened challenges of growth, stability, and risk at the end of the credit cycle, creditworthiness </p><p>considerations are a main focus for 2019, providing significant opportunity for us to convey value-added </p><p>opinions and publish insightful bank and NBFI research. </p><p>Covering close to 3,000 banks and NBFIs worldwide, we are proud to be a leading force in financial </p><p>institutions ratings, widely accepted by issuers, investors, and other debt capital markets participants. In 2018, we rated approximately $900 billion in bank and NBFI debt issuance globally and further developed our extensive relationships with global Financial Institution investors through ongoing collaboration. </p><p>Fitch has established itself as a leading voice in regulatory research, with consistent updates on the credit implications of supervisory initiatives, macro-prudential policies, conduct issues, and resolution outcomes, among other topics, some of which are included in this issue. </p><p>The recent introduction of ESG (Environmental, Social and Governance) Relevance Scores transparently and consistently displays the relevance of ESG elements to the credit rating decision. Although ESG risks </p><p>tend to have limited direct impact on bank ratings, nearly 20% of global financial institutions ratings are currently influenced by governance risk. As a result, this key initiative adds another dimension to Fitch’s offerings that will provide more comprehensive and robust commentary. </p><p>We very much welcome any feedback that you may have on our bank and NBFI ratings and research </p><p>offerings. If you have any suggestions on research topics that you would like us to cover, please do not </p><p>hesitate to reach out to us, as we are always eager to address topics that are of interest to our readers. </p><p><strong>Happy reading! Erwin van Lümich</strong>, CFA, </p><p>Head of Banks Business & Relationship Management </p><p>Sector Research </p><p>Sector Research </p><p>Banks Regulation Non-Bank Financial Institutions </p><p>Sector Research </p><p>leveraged loan market participants. Negative rating actions could be further exacerbated if the banks did </p><p>not adjust capital management practices to reflect </p><p>weakening market conditions. </p><p>Banks </p><p><strong>Leveraged Lending: Where is the Risk in the U.S. Banking System? </strong><br><strong>Online Bank Deposit Betas Trend Up as </strong></p><p><strong>Competition Intensifies </strong></p><p>U.S. banks are exposed to leveraged lending risk in four ways: as underwriters and distributors through the syndication process; as holders of these loans on </p><p>balance sheets; as providers of financing </p><p>to nonbank leveraged loan market participants active in this space; and as investors in CLOs. </p><p>Deposit betas for the largest U.S. online banks have steadily increased following a series of Federal Reserve interest rate hikes in 2017 and 2018. Deposit betas for traditional banks, while rising, continue to lag their online-only competitors. Traditional banks have had slower loan growth than online banks and already have a high proportion of their funding coming from deposits. </p><p>Leveraged loan risks to the U.S. banking system are manageable in the near term. Negative rating actions for banks would become more likely in the event of </p><p>a significant market disruption for institutions, with </p><p>large on-balance sheet leveraged loan portfolios and considerable outstanding credit lines to nonbank <br>We estimate that cumulative deposit betas for online banks ranged from 43%-61% from the point of the </p><p>Fed’s first rate hike in December 2015 through Q3 2018, with a median beta of 50%. Synchrony came </p><p>in at the low end of the range, while Sallie Mae was at the high end. Still, cumulative betas remain within expectations relative to assigned ratings. </p><p><strong>Consolidation to Continue for U.S. Regional Banks </strong></p><p>M&A activity in the U.S. banking sector could remain strong over the next 12-24 months for most banks. Although the majority of consolidation has been in the community bank and midsize bank space over the past decade, average deal sizes have risen almost every year since 2010. Recent sizable transactions indicate that M&A could be on the table for larger regional banks as well. </p><p>The announced merger of equals involving BB&T Corp. and SunTrust Banks, Inc. could serve as a template for further consolidation among regional banks looking to compete directly with the largest national banks. </p><p>However, the financial and strategic benefits associated with the deal are compelling and could prove difficult </p><p>to replicate. </p><p>Fitch Ratings | Global Banking – <strong>3 </strong></p><p>Sector Research </p><p><strong>Southern European Banks’ Funding Will </strong></p><p><strong>Benefit From TLTRO-III </strong></p><p>Asset Quality Review </p><p>The ECB’s new targeted longer-term refinancing operations (TLTRO-III) will reduce refinancing risks </p><p>and costs for Italian banks at a time when their access to wholesale markets is challenging, and will provide </p><p>funding flexibility to Spanish banks. The Italian and </p><p>Spanish banking sectors are the two largest takers of ECB funds in Europe. </p><p><em>Credit Stabilizes for U.S. Credit Card Issuers </em></p><p>Increases in net charge-offs (NCOs) and early stage </p><p>delinquencies continued to moderate for U.S. </p><p>credit card issuers in 3Q18, but the respite in credit </p><p>performance was partially driven by temporary factors. </p><p>Net charge-offs for general purpose and retail card </p><p>issuers increased 13bps and 10 bps on average, respectively, year over year. <br>The new series of two-year facilities also aims to </p><p>encourage lending as it is designed as a still relatively cheap source of funding for banks. In Italy, however, the cheap funding is likely to contribute to continued weak loan pricing and depressed net interest income. </p><p>TLTRO-III could also affect loan pricing in other markets, if take-up is significant. In other western European markets, we expect TLTRO-III take-up to be mostly </p><p>opportunistic, except in Greece and Cyprus, where there is a more structural need given the high cost of wholesale funding. </p><p><em>U.S. Auto Loan Credit Improves </em></p><p>The credit performance of U.S. auto loans strengthened </p><p>in 2018 with net charge-offs for the largest auto lenders declining year-over-year in 4Q18. Delinquency trends were more mixed among auto lenders in 4Q18 but </p><p>also declined on a year-over-year basis. We believe the </p><p>favorable credit performance in 2018 largely reflected </p><p>a stronger U.S. economic backdrop, but we expect weaker trends to emerge this year. </p><p><strong>Anti-Money Laundering Scrutiny </strong></p><p><strong>Catching Up with Nordic Banks </strong></p><p>Nordic banks’ cross-border operations in the Baltic region are under increasing scrutiny as EU authorities enforce stronger anti-money laundering (AML) regimes. The EU crackdown on money laundering should ultimately be positive for the European banking sector as it addresses past shortcomings and reduces litigation risk. </p><p>Investigations that reveal money laundering or governance failures may, however, cause reputational </p><p>damage for the banks directly affected and faltering investor confidence could spread to other </p><p>banks, particularly in banking systems with a high degree of wholesale funding, concentration, and interconnectedness. Banks would typically be subject to </p><p>negative rating action if fines, business restrictions, and </p><p>remediation actions more permanently weighed on </p><p>capitalization, franchise and funding profiles. Findings </p><p>Fitch Ratings | Global Banking – <strong>4 </strong></p><p>Sector Research </p><p>that reveal broad-based weaknesses or failings in risk management or governance could also lead to negative rating actions. </p><p>including the Royal Commission, that identified </p><p>shortcomings in conduct, governance, and compliance, and will all be engaged in remediation that could distract management from day-to-day business. These challenges come amid other near-term pressures on earnings from a generally tougher operating environment. </p><p><strong>Turkish Banks Have Notable Cushion Against Weaker Asset Quality </strong></p><p>The Turkish banking sector’s profitability and capital buffers still provide a significant cushion against a </p><p>potential marked deterioration in asset quality, driven by the weaker operating environment. We stressed the sector’s capital ratios over two years for a sharp rise in non-performing loans (NPLs), a weakening in </p><p>profitability and Turkish lira depreciation. These factors </p><p>constitute the key risks to solvency, in our view. <br>The four major banks–Australia and New Zealand Banking Group, Commonwealth Bank of Australia, National Australia Bank, and Westpac–have large market shares across most products in Australia and New Zealand, which support strong earnings and balance sheets, and help moderate risk appetite compared with </p><p>many international peers. However, it may be difficult </p><p>for the banks to exercise these advantages fully in an environment of increased public and regulatory scrutiny, as well as pressure to increase their focus on customers rather than shareholders. </p><p>Our analysis shows that loss-absorption buffers remain </p><p>solid, despite moderate erosion mainly due to the weaker lira. In only two of the six scenarios do sector capital ratios fall below required minimum levels. Capital ratios remain above these levels in the other scenarios, </p><p>but NPLs significantly above 10% would pressure solvency, and potentially ratings, depending on specific </p><p>banks’ resilience. </p><p><strong>Indian Banks Benefit from Lower </strong></p><p><strong>Slippages but Challenges Remain </strong></p><p>The Indian banking sector’s non-performing loan </p><p>(NPL) ratio improved in the first nine months of the financial year to March 2019 but slow NPL resolution </p><p>and weak capital are likely to keep the banks’ overall pace of recovery tepid. Lower fresh slippages and better recoveries were instrumental in lowering the Indian </p><p><strong>Conduct and Compliance Issues Weigh on Australian Banks </strong></p><p>Australia’s major banks will continue to face heightened regulatory scrutiny following recent public inquiries, </p><p>Fitch Ratings | Global Banking – <strong>5 </strong></p><p>Sector Research </p><p>banking sector’s gross NPL ratio to 10.8% during the </p><p>same period from 11.5% at March 2018. </p><p>global economy. This is balanced, however, by their leading domestic franchises, sound domestic asset quality on the back of a stable economy with forecasted GDP growth of 1.9% in 2019, low </p><p>unemployment, and satisfactory corporate profitability. </p><p>Fitch sees the banks as making progress in arresting the downward trend of net interest margins on domestic and overseas loans. <br>Indian banks, however, continue to face challenges on multiple fronts. The banking sector’s weak earnings, in </p><p>particular state-owned banks, and thin capital buffers, </p><p>remain at risk from aging provisions, which stem from </p><p>the slow resolution of the sector’s USD150 billion NPL stock. Overall credit costs, despite a decline in </p><p>percentage terms from previous years, remained high compared with most state banks’ weak pre-provision </p><p>profits. As a result, several state banks reported losses </p><p>while the common equity Tier 1 for nearly half of the 21 state banks was below the minimum 8% required by </p><p>fiscal 2020. </p><p>The mega banks’ search for loan growth overseas will </p><p>raise their overall risk profiles in 2019, while vulnerability </p><p>to credit and market risk could rise in line with seeking higher returns on foreign securities investments. We believe the banks will continue to balance risktaking and capital retention, but rapid expansion </p><p>without corresponding buffers would have negative </p><p>implications for the ratings </p><p><strong>Japan’s Mega Banks in Search for Profit; </strong></p><p><strong>Shift to Higher Risk Continues in 2019 </strong></p><p><strong>Slow Profit Growth at China Banks to Pressure Capitalization </strong></p><p>Japan’s “mega banks” are expected to face challenges from low domestic interest rates, rising foreigncurrency funding costs, competition and an uncertain </p><p>Latest financial results from Chinese banks show that their net profits continued to be weighed down by the </p><p>challenging operating environment, despite regulatory </p><p>efforts to support their profitability. Net profit growth </p><p>should be in the single digits in the medium term, and </p><p>this slow profit growth is likely to put Chinese banks’ </p><p>capitalization under pressure as growth in their risk- </p><p>weighted-assets continues to outpace that of net profit </p><p>and assets. We have a negative sector outlook on Chinese </p><p>banks, reflecting banks’ struggles to meet regulatory </p><p>requirements while sustaining adequate loan </p><p>expansion to support economic growth. Banks’ profit </p><p>growth in 2018 was also dragged down by higher </p><p>impairment charges, due to increased efforts to resolve </p><p>NPLs subsequent to tightened NPL recognition against overdue loans and also partly due to IFRS 9 adoption. </p><p>Fitch Ratings | Global Banking – <strong>6 </strong></p><p>Sector Research </p><p>Most Deals Involving Small Community Banks </p><p>($ Mil.) </p><ul style="display: flex;"><li style="flex:1">Assets $100 Mil.–$1 Bil. (RHS) </li><li style="flex:1">Assets > $1 Bil. (RHS) </li><li style="flex:1">Assets < $100 Mil. (RHS) </li><li style="flex:1">Assets per Bank (LHS) </li></ul><p></p><p></p><ul style="display: flex;"><li style="flex:1">12,000 </li><li style="flex:1">4</li></ul><p>3210<br>10,000 8,000 6,000 4,000 2,000 0</p><ul style="display: flex;"><li style="flex:1">2000 </li><li style="flex:1">2005 </li><li style="flex:1">2010 </li><li style="flex:1">2015 </li><li style="flex:1">2016 </li><li style="flex:1">2017 </li><li style="flex:1">3Q18 </li></ul><p></p><p>Source: Fitch Ratings, FDIC. </p><p>Indian Banks’ Gross NPL Ratio </p><p></p><ul style="display: flex;"><li style="flex:1">9MFY19 </li><li style="flex:1">FY18 </li><li style="flex:1">FY17 </li><li style="flex:1">(%) </li></ul><p></p><p>32 </p><p>24 16 <br>80</p><p></p><ul style="display: flex;"><li style="flex:1">Public banks (large) </li><li style="flex:1">Public banks (medium) </li><li style="flex:1">Private banks </li></ul><p></p><p>Source: Banks, Fitch; banks in each sub-category arranged in descending order of 9MFY19 gross NPL ratio. </p><p>9MFY= Nine-month fiscal year. </p><p>Fitch Ratings | Global Banking – <strong>7 </strong></p><p>Sector Research </p><p>financial crime. We have researched comprehensively </p><p>into anti-money laundering and sanction evasion, thus highlighting the implications for banks’ credit ratings. </p><p>Regulation </p><p>For banks, it is regulatory action which tends to lead to default-like situations, unlike other credit sectors. Our research cuts through the complexity, by providing primers on regulatory topics and regional compendium guides that highlight </p><p>–Monsur Hussein, Head of Bank Regulatory Research </p><p><strong>Global Bank Regulatory Outlook: Tighter Supervision, Focus on Pillar 2 and Macroprudential Policies, Conduct Risks </strong></p><p>With no new significant regulation expected in </p><p>2019, there’s a stable outlook for the global bank regulatory environment. Authorities within key banking </p><p>jurisdictions will focus on implementing in-flight </p><p>regulations and strong supervision. In developing </p><p>markets, financial stability topics may be prioritized over regulatory reforms, due to spill-over effects from U.S. </p><p>policy rates and U.S. dollar foreign-exchange liquidity concerns. </p><p>jurisdictional differences and key trends. </p><p>Significant post-crisis reforms to reduce bank failure </p><p>risk mean that sovereign support cannot be relied on for North American and Western European banks. </p><p>Alongside thorough analysis of banks’ financial credit </p><p>metrics, insights into the regulatory playbook and the </p><p>applicable legal tools are key. Our research reports </p><p>and commentary on bank resolution, including bail-in regime updates, enable market participants to keep up-to-date with changes in the regulatory and political environment, and to gauge the risk of bail-in on senior debt instruments. </p><p><strong>What to Watch </strong></p><p>• Regulatory guidelines and supervisory practice changes more likely than new rules <br>• U.S. regulatory roll-back that loosens standards for larger banks would be credit negative, but U.S. G-SIBs have been excluded from much of the proposed relief for midsize banks <br>The focus on capital rules that characterized the </p><p>early years after the financial crisis has shifted toward </p><p>supervision and conduct, and increasingly toward </p><p>Outlook Summary </p><p><strong>Global </strong></p><p><strong>NA </strong></p><p><strong>LATAM </strong></p><p>Tighter Stable </p><p></p><ul style="display: flex;"><li style="flex:1"><strong>WE </strong></li><li style="flex:1"><strong>CEE </strong></li></ul><p></p><p><strong>MEA </strong></p><p>Stable Stable Stable Stable Stable Tighter Tighter </p><p><strong>APAC </strong></p><p>Stable Tighter Stable Tighter Stable Tighter Tighter </p><p><strong>Capital Numerator </strong></p><p></p><ul style="display: flex;"><li style="flex:1">Stable </li><li style="flex:1">Looser </li></ul><p>Looser Looser Stable Looser Looser Stable <br>Stable Looser Looser Stable Looser Tighter Stable <br>Stable Stable Stable Stable Stable Tighter Stable </p><p><strong>Capital Denominator </strong>Stable <strong>Leverage Ratio </strong></p><p><strong>Macroprudential </strong></p><p><strong>Liquidity </strong></p><p>Looser Stable Stable Tighter Stable <br>Stable Stable Tighter Tighter Stable </p><p><strong>Supervision Resolution </strong></p><p>Source: Fitch Ratings </p><p>Fitch Ratings | Global Banking – <strong>8 </strong></p><p>Sector Research </p><p>• Supervisory tweaks to increase model RWAs, e.g., </p><p>input parameter floors, particularly for real estate and </p><p>high-risk exposures-more likely in APAC and EU than elsewhere </p><p>• An IFRS 9 Stage 2 significant increase in credit risk definitions that diverge from bank to bank, and </p><p>incorporation of restructured loans into Stage 3, which may vary loan provisions <br>• Scrutiny of regulatory arbitrage and “optimization” may lead to sudden ratio changes </p><p>• Financial and non-financial penalties and remedial </p><p>actions linked to conduct issues, e.g. anti-money laundering or sanctions evasions can take time to materialize </p><p><strong>ECJ Opens Door to Deposit Guarantee </strong></p><p><strong>Schemes for Failing Banks </strong></p><p>The European Court of Justice’s (ECJ) ruling that support from a private-sector deposit guarantee scheme did not constitute illegal state aid will make it easier to use these schemes to restructure failing banks. We believe that private deposit guarantee schemes could be an attractive way to deal with small failing banks. This is particularly the case as banks with total assets below EUR100 billion will not be subject to mandatory subordination requirements under EU Minimum Requirements for own funds and Eligible Liabilities rules. The ruling also served as a reminder that EU State Aid rules only apply where a public authority intervenes, or where it can be shown that the private body is under </p><p>the influence or control of the public authorities. </p><p><strong>IBOR Transition Gains Momentum, but </strong></p><p><strong>Key Risks Not Yet Addressed </strong></p><p>Substantial progress in recent months will better </p><p>prepare financial markets for the discontinuation of IBOR indices, but transition risks remain. Our ratings </p><p>address the payment of interest (and principal) in accordance with the underlying terms of an obligation </p><p>and would not be directly affected by transition from </p><p>one reference rate to another or any accompanying </p><p>Fitch Ratings | Global Banking – <strong>9 </strong></p><p>Sector Research </p><p>spread adjustment. However, elements of IBOR </p><p>transition could, if not appropriately addressed and managed, become rating relevant through operational costs, valuation, hedging, legal risks, and increased basis risk. <br>Basel Committee on Banking Supervision. The stepup is mainly due to a requirement for some EU banks </p><p>to reflect their history of operational risk losses as an </p><p>add-on when calculating how much capital to hold </p><p>for potential future losses. The impact is significant </p><p>because several banks’ recent history includes large </p><p>fines for misselling and other regulatory breaches. </p><p>Whether these risks crystallize will depend on further progress addressing these issues on a sector, issuer and </p><p>transaction basis. We believe the financial institutions </p><p>and securitization sectors are most exposed to transition challenges. </p><p><strong>CECL Implementation Expected to be Ratings Neutral to U.S. Financial Institutions </strong></p><p><strong>Operational Risk Capital May Rise for EU </strong></p><p><strong>Banks but Fall in the U.S. </strong></p><p>The pending implementation of the U.S. accounting standard for current expected credit loss (CECL) reserves by the Financial Accounting Standards Board is not expected to result in ratings actions on adoption. That said, CECL is expected to be more impactful for banks than NBFIs as banks will need to meet regulatory capital ratios post-CECL implementation, whereas NBFIs are not bound by similar regulatory constraints. </p>
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