Regulatory Risk Management evolves…
The Basel Committee of supranational supervision was put in place to ensure the stability of the financial system. The Basel Accords are the frameworks that essentially govern the risk taking actions of a bank. To that end, minimum regulatory capital standards are introduced that banks must adhere to. The Bank of International Settlements (BIS) established 1930, is the world’s oldest international financial consortium. with 60+ member central banks, representing countries from around the world that together make up about 95% of world GDP. BIS stewards and maintains the Basel standards in conjunction with member banks.
The goal of Basel Committee and the Financial Stability Board (FSB) guidelines are to strengthen the regulation, supervision and risk management of the banking sector by improving risk management and governance. These have taken on an increased focus to ensure that a repeat of financial crisis 2008 comes to pass again. Basel III (building upon Basel I and Basel II) also sets new criteria for financial transparency and disclosure by banking institutions.
Basel III – the last prominent version of the Basel standards published in 2012 (named for the town of Basel in Switzerland where the committee meets) prescribes enhanced measures for capital & liquidity adequacy and were developed by the Basel Committee on Banking Supervision with voluntary worldwide applicability. Basel III covers credit, market, and operational risks as well as liquidity risks. As this is known, BCBS 239 – guidelines do not just apply to the G-SIBs (the Globally Systemically Important Banks) but also to the D-SIBs (Domestic Systemically Important Banks).Any important financial institution deemed ‘too big to fail” needs to work with the regulators to develop a “set of supervisory expectations” that would guide risk data aggregation and reporting.
Basel III & other Risk Management topics were covered in these previous posts here and here.
Enter the FTRB (Fundamental Review of the Trading Book)…
In May 2012, the Basel Committee on Banking Supervision (BCBS) again issued a consultative document with an intention of revising the way capital was calculated for the trading book. These guidelines which can be found here in their final form  were repeatedly refined based on comments from various stakeholders & quantitative studies. In Jan 2016, a final version of this paper was released. These guidelines are now termed the Fundamental Review of the Trading Book (FRTB) or unofficially as some industry watchers have termed – Basel IV.
What is new with the FTRB …
The main changes the BCBS has made with the FRTB are –
- Changed Measure of Market Risk – The FRTB proposes a fundamental change to the measure of market risk. Market Risk will now be calculated and reported via Expected Shortfall (ES) as the new standard measure as opposed to the venerated (& long standing) Value At Risk (VaR). As opposed to the older method of VaR with a 99% confidence level, expected shortfall (ES) with a 97.5% confidence level is proposed. It is to be noted that for normal distributions, the two metrics should be the same however the ES is much superior at measuring the long tail. This is a recognition that in times of extreme economic stress, there is a tendency for multiple asset classes to move in unison. Consequently, under the ES method capital requirements are anticipated to be much higher.
- Model Creation & Approval – The FRTB also changes how models are approved & governed. Banks that want to use the IMA (Internal Model Approach) need to pass a set of rigorous tests so that they are not forced to used the Standard Rules approach (SA) for capital calculations. The fear is that the SA will increase capital requirements. The old IMA approach has now been revised and made more rigorous in a way that it enables supervisors to remove internal modeling permission for individual trading desks. This approach now enforces more consistent identification of material risk factors across banks, and constraints on hedging and diversification. All of this is now going to be done at a desk level instead of the entity level. FRTB moves the responsibility of showing compliant models, significant backtesting & PnL attribution to the desk level.
- Boundaries between the Regulatory Books – The FRTB also assigns explicit boundaries between the trading book (the instruments the bank intends to trade) and the bank book (the instruments held to maturity). These rules have been redefined in such a way that banks now have to contend with stringent rules for internal transfers between both. The regulatory motivation is to eliminate a given bank’s ability to designate individual positions as belonging to either book. Given the different accounting treatment for both, there is a feeling that bank’s were resorting to capital arbitrage with the goal of minimizing regulatory capital reserves. The FRTB also introduces more stringent reporting and data governance requirements for both which in conjunction with the well defined boundary between books. All of these changes should lead to a much better regulatory framework & also a revaluation of the structure of trading desks.
- Increased Data Sufficiency and Quality – The FRTB regulation also introduces Non-Modellable risk factors (NMRF). Risk factors are non modellabe if certain aspects that pertain to the availability and sufficiency of the data are an issue . Thus with the NMRF, Banks now need increased data sufficiency and quality requirements that go into the model itself. This is a key point, the ramifications of which we will discuss in the next section.
- The FRTB also upgrades its standardized approach to data structuring – with a new standardized approach (SBA) which is more sensitive to various risk factors across different asset classes as compared to the Basel II SA. Regulators now determine the sensitivities in the data. Approvals will also be granted at the desk level rather than at the entity level. The revised SA should provide a consistent way to measure risk across geographies and regions, giving regulatory a better way to compare and aggregate systemic risk. The sensitivities based approach should also allow banks to share a common infrastructure between the IMA approach and the SA approach. Thera are a set of buckets and risk factors that are prescribed by the regulator which instruments can then be mapped to.
- Models must be seeded with real and live transaction data – Fresh & current transactions will now need to be entered into the calculation of capital requirements as of the date on which they were conducted. Not only that, though reporting will take place at regular intervals, banks are now expected to manage market risks on a continuous basis -almost daily.
- Time Horizons for Calculation – There are also enhanced requirements for data granularity depending on the kind of asset. The FRTB does away with the generic 10 day time horizon for market variables in Basel II to time periods based on liquidity of these assets. It propose five different time horizons – 10 day, 20 day, 60 day, 120 day and 250 days.
Illustration: FRTB designated horizons for market variables (src – )
To Sum Up the FRTB…
The FRTB rules are now clear and they will have a profound effect on how market risk exposures are calculated. The FRTB clearly calls out the specific instruments in the trading book vs the banking book. With the new switch over to Expected Shortfall (ES) @ 97.5% over VaR @ 99% confidence levels – it should cause increased reserve requirements. Furthermore, the ES calculations will be done keeping liquidity considerations of the underlying instruments with a historical simulation approach ranging from 10 days to 250 days of stressed market conditions. Banks that use a pure IMA approach will now have to move to IMA plus the SA method.
The FRTB compels Banks to create unified teams from various departments – especially Risk, Finance, the Front Office (where trading desks sit) and Technology to address all of the above significant challenges of the regulation.
From a technology capabilities standpoint, the FRTB now presents banks with both a data volume, velocity and analysis challenge. The next post will examine the technology ramifications in detail.