Apply basel II in risk management in vietnam case study of asia commercial bank

MINISTRY OF EDUCATION AND TRAINING UNIVERSITY OF ECNOMICS HOCHIMINH CITY K - ĐỖ THỊ NGỌC SƯƠNG APPLY BASEL II IN RISK MANAGEMENT IN VIETNAM CASE STYDY OF ASIA COMMERCIAL BANK MAJOR: BANKING AND FINANCE MAJOR CODE: 60.31.12 MASTER THESIS SUPERVISOR ASSOCIATE PROFESSOR Dr TRƯƠNG TẤN THÀNH Faculty of Banking Ho Chi Minh City – 2010 -i- CERTIFICATE I certify that the substance of this thesis has not already been submitted for any degree and is not currently being submitted for any other degree or qualification I also certify that, to the best of my knowledge, any help received in preparing this thesis, and all sources used have been acknowledged in this thesis Signature: Do Thi Ngoc Suong Date: _ - ii - ACKNOWLEDGEMENTS I owe a debt of gratitude to many people who helped me complete this thesis I would like to acknowledge the help of all First of all I would like to express my deepest acknowledgement to my supervisor, Dr Truong Tan Thanh, for his valuable advice and recommendations I acknowledge Mr Tran Van Tam, his assistants from Credit Policy and Management Department of Asia commercial bank (ACB) with reference material I would particularly like to thank the following friend for her support related to material: Ms Ho Nguyen Thuy Duong from Asia commercial bank Finally, to my parents, I wish to extend my loving thanks for their encouragement - iii - ABSTRACT Vietnam has gradually integrated into the global economy after officially becoming a member of the world trade organization (WTO) at the end of 2006 Together with the process of economy liberalization, the priority of economic sectors is financial banking industry These opportunities help Vietnamese banks get favorable conditions in banking activities, but face with a lot of difficulties and show weaknesses Vietnamese banks can take advantage of capital, modern technology, management experience, and to develop the comparative advantage of Vietnamese banking to catch up with international competition and outreach foreign markets However, commercial banks will face more competitive pressure, shows poor performance (weak financial resources, small scale, low quality and efficiency, low professional skill in management, low technology, and high risk), especially are more prone to adverse impact of external shocks (economic crisis, war, etc.) This reflects weak capability in reducing risks As Governor Nguyen Van Giau said Monday (04/05/2009) in an interview published on the government website “The central bank would continue its efforts to keep the banking system secure and review banking and risk management regulations to comply with international standards”, after 23 banks around the world were taken over or went bankrupt in the first quarter 2009 This thesis examines a particular case of a joint-stock commercial bank in Vietnam to see the way they manage their risk: credit risk, operational risk and market risk Objectives of this thesis are: (1) To study the methods of risk management in Basel I and Basel II (2) To study the level of Basel I and Basel II application in risk management at ACB in participate and at Vietnamese commercial banks in general (3) To contribute some recommendations for the improvement of risk management at ACB and to expand for other commercial banks - iv - In terms of structure, the thesis has six chapters: Chapter reviews the research background, significance and scope of the study Chapter reviews literature of risk management in Basel I and Basel II Objectives of this chapter will provide a brief overview of the characteristic of the 1988 Basel I Capital Accord, touching on its limitations and the reasons that prompted its revision in to the new 2004 Basel II Capital Accord Chapter presents Asia Commercial Bank, a joint-stock commercial bank in Vietnam Chapter presents descriptive findings of risk management practices at ACB Objectives of this chapter are: (1) To observe the process of risk management at ACB for a period of time (from the beginning of 2006 until now) (2) To evaluate the capacity of ACB’s risk management Chapter presents the tendency in risk management of Asian banks in general, of Vietnamese banks in participate Finally, the thesis ends with Chapter This chapter will give some recommendations to improve its risk management system for ACB in participate, for Vietnamese banks in general -v- TABLE OF CONTENTS CERTIFICATE i ACKNOWLEDGEMENTS ii ABSTRACT iii TABLE OF CONTENTS v LISTS OF TABLES viii LIST OF FIGURES ix GLOSSARY OF TERMS AND ABBREVIATIONS xi CHAPTER ONE: INTRODUCTION TO THE STUDY 1.1 1.1.1 1.1.2 1.1.3 1.1.4 1.2 1.2.1 1.2.2 RESEARCH BACKGROUND Banking landscape Risk Risk management Benefits with the risk management RESEARCH PROBLEM Research questions Research objectives 1.3 METHODOLOGY 1.4 SIGNIFICANCE AND SCOPE OF THE STUDY 1.5 STRUCTURE OF THE STUDY CHAPTER TWO: LITERATEUR REVIEW 2.1 INTRODUCTION 2.2 OVERVIEW 2.2.1 2.2.2 2.2.3 Basel I Basel II 11 Innovations of Basel II in comparison to Basel I 14 2.3 THE STUDY OF APPLYING BASEL I AND BASEL II IN RISK MANAGEMENT 16 2.4 2.4.1 2.4.2 2.5 THE EFFECTS AND BENEFITS IN BASEL I AND BASEL II APPLICATION 18 The effects 18 The benefits 20 CONCLUSION 21 CHAPTER 3: ASIA COMMERCIAL BANK (ACB) 22 3.1 3.1.1 3.1.2 3.1.3 3.2 OVERVIEW OF ACB 22 Milestones 22 Growth path 24 ACB’s operations 27 ACB’S FINANCIAL PERFORMANCE 30 - vi 3.2.1 3.2.2 3.2.3 3.3 Profitability (%) 30 Liquidity 31 Charter capital, equity, secure capital ratio 31 CONCLUSION 32 CHAPTER 4: RISK MANAGEMENT AT ASIA COMMERCIAL BANK (ACB) 34 4.1 RISK MANAGEMENT OVERVIEW AT ACB 34 4.2 RISK ANALYSIS 36 4.2.1 Credit risk 36 4.2.1.1 Policy on credit risk 36 4.2.1.1.1 Observation of regulations and loan limits 36 4.2.1.1.2 Measures and outlook for loan quality 37 4.2.1.2 Analysis on credit risk 41 4.2.1.2.1 Observation of regulations and loan limits 41 4.2.1.2.2 Credit quality 43 4.2.1.3 ACB’s limitations in credit risk management 50 4.2.2 Market risk 50 4.2.2.1 Policy on market risk 50 4.2.2.2 Analysis on market risk 53 4.2.2.2.1 Observation of regulations and limits 53 4.2.2.2.2 Measure and outlook risk market 55 4.2.2.3 ACB’s limitations in market risk management 61 4.2.3 Operational risk 62 4.3 RISK MANAGEMENT DEVELOPMENTS AND COMPLIANCE 63 4.4 CONCLUSION 64 CHAPTER 5: TENDENCY IN RISK MANAGEMENT OF ASIAN BANKS IN GENERAL, OF VIETNAMESE BANKS IN PARTICIPATE 65 5.1 TENDENCY IN RISK MANAGEMENT OF ASIAN BANKS 65 5.1.1 Basel II Implementation schedule in Asia 65 5.1.2 Capital adequacy requirements in Asia 68 5.1.3 Challenges on risk management for Asia 70 5.1.3.1 Challenges on credit risk 70 5.1.3.2 Operational risk challenges 71 5.1.3.3 Challenges for regulators 72 5.1.4 The future of Basel II (Basel III) 72 5.2 TENDENCY IN RISK MANAGEMENT OF VIETNAMESE BANKS 73 5.2.1 Legal and regulations 73 5.2.2 Financial performance 76 5.2.2.1 Profitability 76 5.2.2.2 Liquidity 77 5.2.2.3 Efficiency 78 5.2.2.4 CAR 79 5.2.2.5 Asset Quality 80 5.2.3 Risk management 81 5.2.3.1 Bank for Investment and Development of Vietnam (BIDV) 81 5.2.3.2 TECHCOMBANK (TCB) 84 5.2.4 Rating of Moody's 88 5.2.5 Implementation challenges for Vietnamese bank system 88 5.2.5.1 Cost of implementation 88 5.2.5.2 Inadequate supervisory capacity 89 5.2.5.3 Accurate credit risk factor estimation and calibration across many different portfolios 89 5.2.5.4 A sound approach to operational risk 89 - vii 5.2.5.5 An efficient strategy for data gathering and management 90 5.2.5.6 An overarching economic capital framework for enterprise risk management 90 5.2.5.7 Approach-related challenges 90 5.2.4.7.1 Standardize Approach-related challenges 90 5.2.4.7.2 IRB Approach-related challenges 91 5.3 5.3.1 5.3.2 CONCLUSIONS 92 Asia 92 Vietnam 93 CHAPTER 6: RECOMMENDATIONS 95 6.1 STATE BANK OF VIETNAM (SBV) 95 6.2 JOINT-STOCK BANKS 96 6.3 ACB 98 6.4 IMPLICATION FOR FURTHER STUDY 100 BIBLIOGHAPHY 102 - viii - LISTS OF TABLES Table 1.1: Benefits with the risk management Table 2.1: Pillar 12 Table 2.2: Pillar 12 Table 2.3: Pillar 13 Table 2.4: Compare (IRB) between Basel I and Basel II 14 Table 2.5: Compare (standard) between Basel I and Basel II .15 Table 2.6: “Ripple Effect” of Basel II 19 Table 3.1: ACB’s products and service 25 Table 3.2: ACB’s business performance structure in 2009 .26 Table 3.3: ACB’s net income structure in 2008 and 2009 .26 Table 3.4: ACB’s growth orientations 26 Table 3.5: ACB’s subsidiaries (As of 31st December 2009) 28 Table 3.6: ACB’s profitability from 2004 to 2009 31 Table 3.7: ACB’s liquidity from 2004 to 2009 31 Table 3.8: ACB’s charter capital, equity, secure capital ratio from 2004 to 2009 32 Table 4.1: ACB’s observation of regulations and loan limits (As of 31st December 2009) 42 Table 4.2: ACB’s provision for loans from 2007 to 2009 43 Table 4.3: ACB’s daily reserves (As of 31st December 2009) 54 Table 4.4: ACB’s liquidity option (As of 31st December 2009) 54 Table 4.5: ACB’s components of tier and tier capitals, and risk weighted assets from 2007 to 2009 55 Table 4.6: ACB’s factors of market risk sensitivity (As of 31st December 2009) 58 Table 5.1: Approaches and options of Basel II in Asia 65 Table 5.2: Basel II implementation schedule in Asia 67 Table 5.3: Capital adequacy requirements in Asia 68 Table 5.4: The future of Basel II 72 Table 5.5: Vietnamese banks' rating of Moody's .88 - ix - LIST OF FIGURES Figure 1.1: The structure of risk Figure 2.1: The structure of the Basel II Framework .13 Figure 2.2: Basel II affects a variety of constituents, whose needs for information are interdependent 18 Figure 3.1: ACB’s business performance from 2004 to 2009 25 Figure 3.2: ACB’s organizational chart 27 Figure 3.3: ACB’s shareholder structure (As of 31st December 2009) 28 Figure 3.4: ACB’s branch network growth from 2004 to 2009 .29 Figure 3.5: ACB’s branches nationwide (As of 31st December 2009) 29 Figure 3.6: ACB’s human resource development from 2004 to 2009 30 Figure 3.7: ACB’s current ratio, ROE, ROA from 2004 to 2009 31 Figure 4.1: ACB’s organizational chart in risk management 34 Figure 4.3: ACB’s analysis by group from 2005 to 2009 44 Figure 4.4: ACB’s analysis by collateral from 2006 to 2009 45 Figure 4.5: ACB’s analysis by types of customers from 2004 to 2009 46 Figure 4.6: ACB’s analysis by types of loans from 2004 to 2009 47 Figure 4.7: ACB’s analysis by industry from 2004 to 2009 48 Figure 4.8: ACB’s analysis by contingencies and commitments from 2004 to 2009 48 Figure 4.9: ACB’s analysis by types of geography from 2004 to 2009 49 Figure 4.10: ACB’s analysis by types of maturity from 2004 to 2009 49 Figure 4.11: CAR of some commercial bank 57 Figure 4.12: ACB’s liquidity gap into relevant maturity grouping from 2006 to 2009 59 Figure 4.13: Group’s exposure to interest rate risk from 2007 to 2009 60 Figure 4.14: ACB’s exposure to foreign currency exchange rate risk from 2006 to 2009 61 Figure 5.1: Vietnamese banks' net interest margin from 2003 to 2008 76 Figure 5.2: Vietnamese banks' return on average total assets from 2003 to 2008 77 Figure 5.3: Vietnamese banks' loan to deposit ratios from 2003 to 2008 .78 Figure 5.4: Vietnamese banks' cost/income ratios from 2003 to 2008 79 Figure 5.5: Vietnamese banks' CAR from 2003 to 2008 79 Figure 5.6: Vietnamese banking system's asset quality from 2006 to 2008 80 5 and borrowing targets for 2009 were raised significantly The policy interest rate was also lowered rapidly - The policy stimulus helped the economy to stage a rebound in the second quarter of 2009 After dipping to 3.1% in the first three months, real GDP growth accelerated from April to record a first half gain of 3.9% - Following to Standard & Poor’s forecast and estimation for 2009 – 2012: Source: The report of Standard & Poor’s - Ratings Detail by Standard & Poor's Ratings Services, Vietnam is assessed as following: Source: The report of Standard & Poor’s - This credit rating reflects the country's low-income economy, developing financial system, and evolving policy framework These weaknesses increase the 6 vulnerability of the economy to severe shocks that could significantly increase the public financial burden Healthy economic growth prospects, reinforced by the government's persistent efforts in economic restructuring, partly offset these weaknesses A modest level of external indebtedness also supports the government's credit quality 4.2 - Overview of the Vietnamese banking system In its transition to a market-oriented economy, Vietnam had to fundamentally change the infrastructure of its economy In the case of its financial infrastructure, the period from 1988 to 1992 marked drastic changes, initiated by the structural shift from a mono-banking system to a two-tier banking system in 1988 Under the mono-banking system, one entity accounts for both central and commercial banking responsibilities; whereas, under the two-tier system, the central bank controls monetary policies, leaving the commercial banks to handle commercial banking activities - Under the two-tier system, the State Bank of Vietnam retained the responsibilities of the central bank, specifically responsibilities for monetary policies Commercial banking responsibilities were transferred to the two newly created state-owned commercial banks By creating a two-tier banking system, the government had hoped to create a competitive banking system that would respond more efficiently to the demand and supply of credit, thus creating a system of financial intermediaries capable of responding to the needs of individuals and businesses in a market oriented economy - From 1988 to the Asian Financial Crisis in 1997, the SBV proved adept at implementing interest rate policies to mobilize funds and control inflation During this period, interest rate control was the key ingredient in the monetary policies implemented by the SBV The commercial banks assess those monetary policies and economic conditions to determine the cost of borrowing and lending 7 - The reforms of the late 1980s and early 1990s have had a positive effect on Vietnam’s banking system, as evidence in the steady increase in deposits and a diversification in lending However, reforms have not gone far enough As unveiled by the Asian Financial Crisis, the two-tier banking system of Vietnam has proved inadequate in its role of the financial intermediary - In early 2008, as imbalances threaten to destabilize the economy, the SBV began to reassert direct control over interest rates in the country Prior to February 2008, commercial banks were free to set deposit and lending rates according to market conditions and their funding positions By May, however, they were required to set lending and deposit rates at no higher than 1.5x the SBV's prime interest rate From August, even inter-bank lending rates were similarly restricted With inflation showing signs of moderation and economic uncertainties rising, the SBV began using its new powers to engineer a reduction in borrowing costs The central bank began lowering its policy interest rates, from October 2008 when it peaked at 14%, to 7% by February 2009 At the same time, reserve requirements were also lowered to release more liquidity to the commercial banks The SBV also offered to buy back compulsory bills that it had earlier sold to banks to mop up excess liquidity in the money markets The relief to borrowers, however, is a lot less than one would expect, given the rapid easing of monetary policy - Banks had continued to be selective in making new loans in early 2009 In part, this reflected a more conservative attitude among lenders in a weak economic environment A number of banks were also constrained by balance sheets that had been weakened by the volatility of the past two years However, a domestic liquidity shortage was also an important reason for banks' reluctance to lend Banks continue to face difficulties attracting deposits at interest rates below the 10.5% ceiling implied by the SBV's 7% prime interest rate This is possibly related to still-high inflation expectations With their lending rates similarly restricted at the same level, banks face low positive or even negative margins on 8 their loans This naturally reduced their eagerness to lend As a result, bank lending grew by a relatively weak 2.67% in the first quarter of 2009 Only when the government's interest rate subsidy scheme began to show its impact in April did lending grow more robustly - By Moody’s, Vietnamese banks’ average rating is assessed as following: Source: Moodys (2009) 4.2.1 - Market share Competition in the market has been to some extent driven by the limited geographic diversification of the banks, which focuses primarily on the domestic market The operations of the domestic banks are highly concentrated in the Vietnamese market which is vulnerable to the cyclicality of a few economic sectors The Vietnamese banks’ operations remain concentrated in urban areas – namely Hanoi and Ho Chi Minh City Rural communities have little exposure to banking services This situation offers a large market to tap in the longer term Source: The report 2009 of Moody’s 9 - ACB's market share statistic Items ACB’s (As of 31st December Yoy growth 2009 balance 2009) (VND ACB Banking sector Deposits from market market share share as of 31/12/09 billion) ACB ACB compared to 134,502 47.52 26.98 6.60 end-2008 1.11 62,361 79.03 37.73 3.53 0.84 customers Outstanding loans to the economy Source: Internal reports of ACB 4.2.2 - Foreign strategic stakes in Vietnamese banks Given the strong interest of foreign investors, as well as the government’s willingness to sell its stakes in a number of state-owned entities, the foreign presence in the Vietnamese financial sector will rise In the medium term, if prices are right, investors are likely to buy the government’s shareholdings in the relevant banks Possible upcoming deals involve the equalization of BIDV and Mekong Housing Bank - Strategic tie-ups with global players – aimed at strengthening franchises and market positions – have been common, as illustrated by the table below: Source: The report 2009 of Moody’s 10 - The number of overseas institutions wanting stakes in local banks is also growing Such tie-ups aim to leverage the resulting synergies and each party’s respective expertise, creating a stronger healthier entity Foreign bank investments have contributed to the banks’ franchise development through improved risk management, better quality of service and greater product innovation Additionally, such investments have strengthened the sector by improving corporate governance and transparency - In the next 5-10 years, a further shake-up of the sector is inevitable Fewer and larger banks will help stabilize the financial system, as long as the mergers result in well-managed and profitable entities - Such developments would occur against the backdrop of stricter regulatory requirements from the SBV, growing competition, and the strengthening role of the banking sector The higher minimum capital requirement by 2010 could just be one of several factors pushing consolidation -1- APPENDIX 5: COMPARISON BETWEEN VIETNAM'S REGULATIONS AND BASEL I 5.1 Bank's own capital: BASEL I Components of capital Limits Minimum Tier ratio = 4% Tier (Core/NonHybrid) HT1 cannot exceed 15% of Total Tier VIETNAM'S REGULATIONS (CIRCULAR No 13/2010/TT-NHNN) - Ordinary shares/ common stock - Perpetual, noncumulative preference shares - Disclosed reserves (e.g Retained profit, General reseves) Deductions - From Tier 1: commercial advantages - From total capital: + Investments in unconsolidate d banking and Hybrid Tier - Perpetual, callable, financial (HT1) non-cumulative subsidiary preference shares companies + Investments in the capital of other banks and financial institutions (at the discretion of national authorities) Limits Minimum Tier ratio = 4% - Total Tier cannot exceed 100% of Tier Capital instruments (convertible bonds, preference shares or subordinated debt) must not exceed 50% of Tier capital Components of capital Tier Tier Deductions - Charter capital (paid-up - From Tier 1: capital and contributed + Commercial capital) advantages Reserve funds for + Any supplementing charter capital accumulated - Professional investment and losses development funds + Investments - Undistributed profits in the capital of other banks and - 50% of the additional value financial of fixed assets institutions - 40% of the additional value + Investments of investment securities which are - Financial reserve funds up controlling to 1.25% of total asset at risk stakes in - Convertible bonds or insurers or preference shares: securities + Minimum years initial or companies remaining term + Balance of -2- BASEL I Perpetual, cumulative preference shares - Undisclosed reserves Upper Tier - Revaluation reserves (a discount of 55%) - General provisions up to 1.25% of total asset at risk Total Tier cannot exceed 100% of Tier Lower Tier cannot exceed 50% of Tier - Dated subordinated debt Lower Tier - Dated preference shares VIETNAM'S REGULATIONS (CIRCULAR No 13/2010/TT-NHNN) investment in one entity in excess of 15% capital + Balance of investment in + Unsecured all entities in + Redeemable only with SBV excess of 40% approval capital (excl + Cumulative excess of 15% + Step-up allowed after capital years mentioned - Subordinated debt: above) + Minimum 10 years maturity - From total + Unsecured capital: + Cumulative + Any reduction + Redeemable before maturity in value of reonly with SBV approval value fixed + Step-up allowed after assets years + Any reduction in value investment securities of -3- Note: − Total Tier = Lower Tier + Upper Tier − Tier ratio = (Hybrid Tier + Core Tier 1)/RWA 5.2 Risk weighted assets (RWA) BASEL I RW Type 0% 20% Sovereign Banks PSE 50% Mortgage 100% Corporate Banks All others 150% OECD criteria OECD Non-OECD currency) VIETNAM'S REGULATIONS (CIRCULAR No 13/2010/TT-NHNN) Maturity criteria Type Sovereign (in domestic OECD MDB Non-OECD OECD Maturity < year Sovereign Banks PSE Maturity criteria OECD criteria OECD Non-OECD currency) (in domestic Non-OECD (in foreign currency) OECD Maturity < year Non-OECD OECD Secured with houses, land use rights or houses attached with land use rights of borrowers or with those assets which have been leased by borrowers but are allowed by their lessees to be used by lessors as mortgages during the lease term Corporate Maturity > year Banks All others Non-OECD No difine Loans granted to subsidiary, jointventure and associated companies Non-OECD Maturity > year -4- BASEL I RW Type OECD criteria VIETNAM'S REGULATIONS (CIRCULAR No 13/2010/TT-NHNN) Maturity criteria Type of the credit institution 250% No define - Loans granted for securities investment: - Loans granted to securities companies; - Loans granted for real estate business purposes The words in italic shows the diffirence between rules OECD criteria Maturity criteria 1 APPENDIX 6: SAMPLE MODELS 6.1 About building model, we can reference following models: Model Source: Basel Committee on Banking Supervision 2 Model Source: Kessler (2000) p.112/113 Model Source: Hussain (2000) p.210 3 Model Source: Shah (2001) p.14 Model Source: KPMG (2003) 6.2 - In summarizes, key minimum requirements need: Rating system design: + Separate borrower creditworthiness and transaction-specific dimensions + Meaningful distribution of exposures across grades + Plausible, consistent and detailed rating definitions, processes and criteria for assigning exposures to grades within a rating system 4 + Written documentation of rating system design, default and loss definitions etc - Risk rating system operations: + Independence of rating assignment process + All borrowers and facilities must be re-rated at least on an annual basis + Data collection and storage of key borrower and facility characteristics + Stress testing used in assessment of capital adequacy - Corporate governance and oversight: + All material aspects of rating and estimation processes to be approved by senior management and (all or a subset of) the Board of Directors + Independent credit risk control unit responsible for design/selection, implementation and performance of internal rating systems + Internal audit (or an equally independent function) to review the rating system and the credit function’s operations at least annually - Use of internal ratings: + Internal ratings and default/loss estimates to play an essential role in credit approval, risk management, internal capital allocation and corporate governance + Rating system broadly in line with minimum requirements for at least three years prior to qualification - Risk quantification: + PD estimates must be long-run average of one-year default rates (except for retail exposures) and must be based on at least a five-year observation period + Internal estimates must reflect all relevant, material and available data, and must be grounded in historical experience and empirical evidence + Specific reference definition of default and indications of inability to pay LGD and EAD estimation should incorporate cyclical variability when important for certain types of exposures, and must be based on a 5 minimum data observation period of at least seven years (five for retail exposures) + The risk-mitigating effect of guarantees and single-name credit derivatives can be used to adjust own estimates of PD or LGD, but the adjusted risk weight cannot be lower than that of a comparable, direct exposure to the guarantor + Minimum requirements (legal certainty, effective ness of monitoring, control and work-out systems, compliance with internal policies and procedures) for eligible purchased receivables making use of the topdown treatment of default risk and/or IRB treatment of dilution risk - Validation of internal estimates: Minimum operational and risk management requirements for recognition of additional (to those eligible under the Standardized Approach) collateral types, including leases ... study has the following objectives: a To study the literature of risk management in Basel I and Basel II and the experiences of some countries in process of applying Basel I and Basel II in risk. .. IN RISK MANAGEMENT OF ASIAN BANKS IN GENERAL, OF VIETNAMESE BANKS IN PARTICIPATE 65 5.1 TENDENCY IN RISK MANAGEMENT OF ASIAN BANKS 65 5.1.1 Basel II Implementation schedule in Asia ... methods of risk management in Basel I and Basel II (2) To study the level of Basel I and Basel II application in risk management at ACB in participate and at Vietnamese commercial banks in general