Sharing Tbc Experience On Credit Risk Under Icaap

Sharing TBC Bank experience on Credit Risk under ICAAP Agenda Overview Credit Risk Governance Credit Risk Management Credit Risk Stress test Way Forward TBC Bank at a Glance Key Facts About TBC Bank TBC Financial Highlights and Ratios (30 September 2013) No in Retail Deposits – 34% of market share as at 30 September 2013; A leading bank in the country with 27% and 25% market share of total customer loans and total assets respectively as at 30 September 2013; Number of customers: over 900k; Number of employees: c 4,000; Entered microfinance segment in May 2011 through acquiring Bank Constanta 59 / 109 USD million Total assets 4,015 2,412 Net loans 2,618 1,472 Customer deposits 2,614 1,570 689 414 Stockholders’ equity Presence in Azerbaijan-subsidiary TBC Kredit - non-banking credit organization Branches > >TBC / TBC&Constanta GEL million Financial Ratios ATMs > >TBC / TBC&Constanta 251 / 297 >> POS Terminals 3,295 ROaE (annualized) 18% Cost to income 52% Tier CAR (BIS) 23% Note: Exchange Rate Used: USD/GEL 6644 as at 30 September 2013 Loan Portfolio Composition by Business Segments – 30 Sep 2013 BB-/Stable (FC Long Term IDR) B1/Stable (Bank Deposits – Fgn Curr) B (FC Short Term IDR) Ba3 (Bank Deposits – Dom Curr) Affirmed on 14 June 2013 Affirmed on November 2012 Shareholder Structure Source: Market Shares are based on National Bank of Georgia and include Bank Constanta Note: Number of accounts and number of employees include Bank Constanta Two Founder Shareholders 26.70% European Bank for Reconstruction and Development (EBRD) 19.80% International Financial Corporation (IFC) 19.80% Deutsche Investitions-und Entwicklungsgesellschaft (DEG) 11.31% JP Morgan 4.96% Ashmore 4.20% Netherlands Development Finance Company (FMO) 5.26% Management and others 7.97% What is ICAAP >> Basel II/III Overview Regulatory Capital requirements of the bank will be defined in Accordance with Basel 2/3 requirements Components of Basel 2/3 Pillar Pillar Pillar Capital charge is calculated based on NBG regulation Banks Estimate its capital requirements Use stress tests to double check its solvency NBG approval is needed Banks need to disclose its capital calculations to interested parties  Basel II and III are recommendations on banking regulations published by the Basel Committee on Banking Supervision  National regulators decide to adhere to Basel committee regulations and set the requirements and timeline to the banks  The banks were required to be compliant with Pillar requirements by June 2014 and submit first ICAAP by September 2014 TBC Experience in Implementation Timeline >> Feb 2012 ICAAP Mar External consultant selection Apr High Level Gap analysis Credit review May Jun Jul Aug Detailed Gap Analysis Oct Nov Dec >> ICAAP implementation included: Main Benefits  Capital assessment and planning in accordance with the risk profile Major improvements in risk management including credit, operational, market and other risk management Significant changes in corporate governance both on the Supervisory and Management board level  Better capital management through better capital allocation practice In total:  Better understanding and management of the risk that banks face 25+ people from the banks side and two outsourcing companies including Ernst & Young were involved in the project >>  Enhanced corporate governance Main Challenges  Availability of high quality data  Development of adequate framework  Integration of the processes into day to day management Jan 2013 Implementation and Capital Calculation Summary >> Sep  Enhanced transparency in capital calculation and risk management resulting in enhanced trust from regulators and investors Feb Credit Risk Breakdown In million GEL Data as of Dec 2013 Risk Weighted Exposures Pillar Pillar Credit Risk 1.1 Credit Risk 3,380 3,380 1.2 FX Induced Credit Risk 1,272 437 1.3 Concentration Risk - 455 Market Risk 4 Operational Risk 344 81 Strategic risk - 67 Reputational risk - 67 Interest rate risk - 127 Total Risk Weighted Exposures 5,000 4,619   Compared to Pillar Pillar contains number of additional risks Credit risk remains significant part of both Pillar and Pillar Risk Weighted Assets 92% Agenda Credit Risk Under ICAAP Credit Risk Governance Credit Risk Management Credit Risk Stress test Way Forward Introduction to the Risk Management Function TBC considers its risk management function to be fundamental to its business >> Principles of Risk Management >>  TBC conducts its business with a view towards long-term sustainability  TBC pursues a strategy that excludes any involvement in transactions that could pose an unacceptable risk for TBC’s activities, development and reputation  The materiality of each risk to which TBC is exposed across the corresponding asset classes is mainly determined based on size of exposure, the current nature of processes and related controls  The more material a risk exposure is, the more efforts and resources are devoted to its analysis and more sophisticated approaches and complex methods are applied to its measurement  TBC either accepts exposure to a risk or hedges against it, depending on the type of risk  TBC’s accepts risk exposure according to the predefined risk appetite limits set by the Supervisory Board and Management Board Risk Management Process Risk Management Structure: Overview TBC conducts its risk management activities within the framework of its unified risk management system Supervisory Board Risk ethics and compliance committee Corporate Governance committee Credit committee Operational risk committee Loan approval committee Deputy CEO, CFO Financial risks Treasury Management Board ALCO CEO Remuneration Committee Problems Loans Committee Deputy CEO, CRO Underwriting Problem loans Corporate Credit risk Business SME Strategic risk Retail Retail Legal department Repossessed assets Internal audit Compliance department Risk management Operational risk Audit committee Information security Internal control Reputational risk AML Compliance Risk Management Structure: Principal Bodies Objective Supervisory board Principal Bodies Risk, ethics and compliance committee Management Board Responsibilities Credit committee Problem loans committee Underwriting Functions Overall risk management  TBC’s Data Quality goal isofeither to or errors and Support Monitor Ensures Ensure Is involved the the TBC's in quality maintenance Supervisory the portfolio applications theof Board credit of problem areduce approval balanced in portfolio process loan isthrough insupervisory portfolio correspondence as members all phases and the of of with Transform the strategic direction setassets byavoid the board and redundancies, as well as set up corrective and preventive controls to its collection correspondence the corresponding work TBC’s with risk and appetite loan of supervision actual approval risks committees of to risk the management predefined limits institute an effective hierarchy for its implementation achieve and maintain appropriate to business purposes data quality standards Commit TBCexistence to the highest standards of ethicalwith behavior  Ensure lending guidelines are legislation and Ensure TBC’s the of effective riskconsistent management system regulatory policies  Oversee TBC’s compliance function Risk Management  Reviews loan presentations ononcredit exposures prepared by thevia loan Advise the Supervisory Board high-level riskassessment related matters, Considers and makes decisions on: TBC’s overall strategy risk management strategy Is responsible for the timely identification and of credit  Approve Define strategic principles and critical processes of data management andTBC’s creditrisk analysts to ensure that  officers overseeing Review quality of strategy the TBC’s and loan management portfolio of riskrisks within risks andthe outlining mitigation actions regarding those thatTBC, (i) Manage planning of data control theproblem analysis is Risk complete;  the Approve TBC’s risk strategy also reviewing Maps plan; (i) asset recovery be reduced  should Define risk tolerance/appetite (ii) comprehensive information islevels gathered to assess the borrower's risk (ii) repossession or sale of collateral; Approve risk tolerance/appetite levels quality (iii) Define critical data as well requirement collection and recovery ofas allminimum written-off loans;  profile; Approve credit facilities to the borrowers in case themanagement aggregated Review and recommend Supervisory Board on risk (iii) Discuss industry trends Develops adequate tools and models for effective credit risk (iv)Monitor data quality all relevant risks are identified and adequately addressed and approval associated with5% loan recovery; liability of of thecosts borrower exceeds of the Bank'sand Basel capital policies (iv) Approve risk management policies management, such asstructured application (v) Manage of data control and behavioral scorecards and the loanexecution is properly restructuring of problem loans  rating Reviewmodels and recommend Supervisory Board credit portfolio forecasts  Approve credit portfolio forecasts and budgetsand review Develop an ethical culture within TBC Periodically and update Oversees the monitoring of Corporate Loans in Ensure timely reaction to process the developments on the SME market and budgets TBC’s Code of Ethics to discover in timelytesting manner any deterioration in a exposures  order Develops models forastress order to budget assess credit Review portfolio trends and actual in figures vs repayment  borrower's Review portfolio trendscapability and figures vs budget under various scenarios and actual make corresponding conclusions for  capital Monitor the compliance of TBC’s operations adequacy and provisioning purposes with the statutory Approve related parties’ loans legislation and internal policies Data Quality Management 10 A1 A Corporate and SME Loans – Rating model Rating models >>     Expert model was developed together with Ernst &Young during Basel II/III implementation project At present the model is applied for portfolio quality monitoring Given the expert origin, the model is carefully monitored for validity Once the model is validated, it will be used as a supporting tool in credit approval process, for limit setting and pricing purposes, for provisioning purposes Final grade consists of : Industry score (20%) Qualitative Borrower score (15%) Quantitative Borrower score (65%) Industry assessment Financial Stability Economic Volatility Demand Trend Barriers to Entry Sector Competition Access to Inputs Operational Gearing and Capital Intensive Qualitative criteria Company's position in the industry Organizational and managerial activity Company’s governance Finance, accounting and control Business reputation Relationship with the Bank 16 Quantitative criteria Evaluation of solvency Cover debt service through gross profit Effectiveness of operations Assessment of profitability Earnings volatility Dividends / Net income Coefficient of autonomy Valuating of client’s liquidity Rates of turnover A2 A Retail Loans - Credit Approval Process Retail SME Origination   Mortgage Loans, Consumer Loans, Car Loans   POS loans and Credit Cards Corporate Project analysis and review Applications originate in branches Loan officer gathers and reviews preliminary information and determines the type of credit facility that best meets the applicant's needs  POS loan are originated by merchants acting as TBC's agents or TBC staff located at the merchant Credit Cards originate in branches     Micro Decision Checks are made in internal and external databases (Credit Bureau, Public Registry, Civil Registry) Thorough analysis of credit application is conducted Collateral is appraised by internal appraiser’s group  Loan submitted to the centralized Retail loan approval committee POS loans and Credit Cards applications are assessed using application scoring model and credit bureau ratings Scoring is applied once the borrower meets the minimum requirements for the product, such as age, minimum income, and similar criteria  Automated Approval and Rejection zones are defined individually for products, based on performance of loans within these segments 17 A2 A Retail Loans - Credit Approval Process  Decision based on scorecards   TBC Bank has started assessing POS loans and Credit Cards applications using Scoring Model from 2008 and 2012 respectively Automated Approval and Rejection zones are defined individually for products, based on performance of loans within these segments Applications that fall in manual zone are assessed by Centralized operations management department Phone calls are undertaken to the work place and family members of the borrower in order to cross check the data provided by the borrower in the application 18 A2 A Retail Loans - Ratios Maximum portion of revenue, which can be applied to cover the loan PTI Net Revenue Amount (In case of dividends median of Revenues for the last twelve months) US Dollars < < < < >= 600 000 500 000 000 Revenue Share Standard Allowed 25% 30% 35% 40% 50% -40% 45% 50% 60% Loan Amount / Collateral Market Value (LTV) differs according to Collateral Types: LTV Debt Service Ratio Real Estate Car / Land 70% 60% (Borrower’s Family Total Revenue – Total Costs) / Monthly Installment >= 1.3 19 A2 A Retail Loans – Rating Model Rating models >>  Behavioural rating model for retail loans was developed by Experian in 2012 based on the Bank’s five years statistical data  In compliance with Basel regulation three models were developed for: (1) loans secured by real estate, (2) credit limits, and (3) other retail loans  For each segment the model is further differentiated according to the number of months on books of the loan: less than months on books and more than months on  Following variables are included in the model (with approximate weights) books Length of credit history Length of credit history Payment behaviour Information about payment overdues: current overdue days, maximum length of overdues in the last 12 months, etc Macroeconomic variables Refinance rate, GDP, etc Utilisation of facilities Frequency of credit limit usage, deposits, current balance of the loan amount, etc Data from application Gender, work experience, type of the client, etc 20 Agenda Overview Credit Risk Governance Credit Risk Management 3.1 Counterparty Default Risk 3.2 Concentration Risk 3.3 Currency Induced Credit Risk Credit Risk Stress test Way Forward 21 B Concentration Risk A Concentration management is a significant function of credit risk management Already Implemented The system is already established to identify, measure, monitor, and control credit risk concentrations TBC limits the level of credit risk it undertakes by placing limits on concentrations of: (i)single borrowers and groups of related borrowers; (ii) single industry and groups of "higher-risk" industries Under Development Process New methodology is under development for concentration risk management Credit concentration risk measurement process will be improved based on the Central Bank of Spain’s guidelines Reasons for selecting Spanish regulation:  Spain was strongly effected by the global financial crisis 2007-2012, the following global recession 2008-2012, and by the European sovereign debt crisis  The Spanish credit market is heavily dependent on mortgages in particular and on real estate in general  The Spanish simplified option is considered good regulatory practice and implemented in a similar form by several Eastern European regulators (i.e the Slovenian and the Serbian regulator)  The Spanish simplified option is consistent with the Basel standardized approach to credit risk measurement and results into concentration risk numbers that are easily comparable across the banking industry Two Types of Concentrations are managed: Single name and Sectoral concentration Concentration indexes will be calculated using Herfindahl-Hirshman Index (HHI) 22 B Concentration Risk A Individual Concentration Index Multiplier 0.10% 0% 0.15% 0.30% 0.60% 2% 7% 15% 1.20% 27% 2.40% 60% 4.80% 129% 9.60% 248% The surcharge should be applied to the capital requirements for credit risk relating to the borrowers included in the calculation of the individual concentration index (Σy) 42.80% 1071% Sectoral Concentration Sectoral Concentration Index Multiplier Number of industries assessed: All industries < ICS < 12 0% The sectoral concentration index (HHIS) of the credit portfolio is calculated as following: 12 < ICS < 15 15 < ICS < 20 20 < ICS < 25 2% 4% 6% 25 < ICS < 100 8% Single Name Concentration >> Number of Borrowers assessed: 1,000 Grouping method: Largest Borrowers or Group of Borrowers Individual Concentration Index x is the total direct exposure to the groups under the top 1,000 y is the direct exposure to the groups under the entire portfolio >> Σxi2 / (Σxi) * 100 x is the value of risk exposure to each economic sector The surcharge should be applied only to the capital requirements for credit risk relating to the exposures included in the calculation of the sectoral concentration index 23 B Concentration Risk A >> Limits In addition to HHI suggested by Central Bank of Spain TBC Bank will limit single name concentration risk, using top 1, 5, 10 and 20 borrowers exposures ratios Actual limits vs maximum limits will be communicated to the Management Board on a monthly basis and to RECC on a quarterly basis >> Stress Tests In addition the Bank will undertake concentration risk stress tests on a quarterly basis Under stress testing the Bank will assess what would be the loss of regulatory capital if the top 1, and borrowers default in the same time Results of stress test will be applied for credit risks monitoring purposes and will be communicated to the Management Board on a quarterly basis 24 Agenda Overview Credit Risk Governance Credit Risk Management 3.1 Counterparty Default Risk 3.2 Concentration Risk 3.3 Currency Induced Credit Risk Credit Risk Stress test Way Forward 25 C Foreign Currency Induced Credit Risk A 26 Agenda Overview Credit Risk Governance Credit Risk Management Credit Risk Stress test Way Forward 27 Stress Tests Enterprise Wide Stress Testing >> Stress-testing is performed to estimate potential losses in case of highly improbable but severe macroeconomic conditions and ensure sufficient capital is in place to withstand the stress Key actions  Stress-testing is performed quarterly or more frequently in case of a significant change in the market conditions  Following macroeconomic parameters are stressed: • • • • • GDP Growth -15% CPI Change -10% Unemployment 17% Exchange Rate 18% Real Estate Change 39%  Stress scenarios are defined based on (i) most severe GDP decline in Georgia and its peer countries during the last years and (ii) stress scenario provided by NBG   Yearly bases dependences and correlations are assessed between these macroeconomic variables and Bank’s losses Based on identified dependencies, potential credit losses are estimated for individual products and industries in case of stress scenario  The results of EWST are expressed as the amount of capital needed in order to withstand the full potential losses resulting from the specified stress events 28 Agenda Overview Credit Risk Governance Credit Risk Management Credit Risk Stress test Way Forward 29 Way Forward (Credit Risk Focus Under ICAAP) I Phase-Accomplished II Phase  Developed Risk Strategy that is in line with Bank’s business strategy  Further improving application scorecard for retail loans  Corporate customer rating model was introduced Existing rating model was updated in accordance with Basel requirements  Enhance overdue loans management process for retail loans  Implement Internal Rating Based approach for retail loans  Retail client rating model was introduced  Further improve business loans assessment model  Currency Induced Credit Risk (CICR) assessment was performed and respective model was developed  Improved Concentration risk management  Enterprise Wide stress test has been developed and performed  Enhanced corporate governance and credit risk management bodies  Introduced risk based audit planning compliant with Basel requirements  Introduced Economic capital framework that is the first step to risk adjusted performance appraisal 30 Results  More mature Credit Risk management  Better assessment of capital  Direct link from borrowers’ risk profile to capital charge