Public Disclosure Authorized Analyzing Banking Risk A Framework for Assessing Corporate Governance and Risk Management THIRD EDITION blic Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized 48238 Hennie van Greuning Sonja Brajovic Bratanovic Analyzing Banking Risk A Framework for Assessing Corporate Governance and Risk Management Analyzing Banking Risk A Framework for Assessing Corporate Governance and Risk Management 3rd Edition Hennie van Greuning Sonja Brajovic Bratanovic WASHINGTON, D.C © 2009 The International Bank for Reconstruction and Development/THE WORLD BANK 1818 H Street, N.W Washington, D.C 20433 All rights reserved Manufactured in the United States of America First printing November 1999 Second edition April 2003 Th ird edition April 2009 The findings, interpretations, and conclusions expressed in this book are entirely those of the authors and should not be attributed in any manner to the World Bank, to its affi liated organizations, or to members of its Board of Executive Directors or the countries they represent The World Bank does not guarantee the accuracy of the data included in this publication and accepts no responsibility for any consequence of their use The material in this publication is copyrighted The World Bank encourages dissemination of its work and will normally grant permission to reproduce portions of the work promptly Permission to photocopy items for internal or personal use, for the internal or personal use of specific clients, or for educational classroom use is granted by the World Bank, provided that the appropriate fee is paid directly to the Copyright Clearance Center, Inc., 222 Rosewood Drive, Danvers, MA 01923, USA.; telephone 978-750-8400, fax 978-750-4470 Please contact the Copyright Clearance Center before photocopying items For permission to reprint individual articles or chapters, please fax a request with complete information to the Republication Department, Copyright Clearance Center, fax 978-750-4470 All other queries on rights and licenses should be addressed to the Office of the Publisher, World Bank, at the address above or faxed to 202-522-2422 Design services by EEI Communications ISBN 978-0-8213-7728-4 eISBN 978-0-8213-7898-4 DOI: 10.1596/978-0-8213-7728-4 Library of Congress Cataloging-in-Publication Data has been requested Contents Foreword to the Th ird Edition xiii Acknowledgments xv Overview of Banking Risks 1.1 Introduction: The Changing Bank Environment 1.2 Bank Exposure to Risk 1.3 Corporate Governance 1.4 Risk-Based Analysis of Banks 1.5 Analytical Tools Provided 1 10 A Framework for Risk Analysis 2.1 Financial Management 2.2 Why Banks Are Analyzed 2.3 Understanding the Environment in Which Banks Operate 2.4 The Importance of Quality Data 2.5 Risk-Based Analysis of Banks 2.6 Analytical Tools 2.7 Analytical Techniques 13 13 16 17 24 27 29 34 Corporate Governance 3.1 Corporate Governance Principles 3.2 Major Developments in Corporate Governance Principles 3.3 Regulatory Authorities: Establishing a Risk-Based Framework 3.4 Supervisory Authorities: Monitoring Risk Management 3.5 The Shareholders: Appointing the Right Policy Makers 3.6 The Board of Directors: Ultimate Responsibility for a Bank’s Affairs 3.7 Management: Responsibility for Bank Operations and the Implementation of Risk Management Policies 3.8 The Audit Committee and Internal Auditors: An Extension of the Board’s Risk Management Function 41 41 44 46 48 51 53 59 64 vi Analyzing Banking Risk 3.9 External Auditors: A Reassessment of the Traditional Approach of Auditing Banks 3.10 The Role of the General Public Annex 3A: National Initiatives to Improve Corporate Governance 66 67 71 Balance Sheet Structure 4.1 Introduction: Composition of the Balance Sheet 4.2 Bank Assets 4.3 Bank Liabilities 4.4 Equity and Other Items 4.5 Growth and Changes in the Balance Sheet 4.6 Risk Analysis of the Balance Sheet Structure and Growth 81 81 84 88 92 94 96 Income Statement Structure 5.1 Profitability 5.2 Income Statement Composition 5.3 Analyzing the Sources of Banking Income 5.4 Analyzing Quality of Earnings 5.5 Analysis of Profitability Indicators and Ratios 5.6 Assessing Internal Performance 101 101 103 107 109 113 118 Capital Adequacy 6.1 Introduction: The Characteristics and Functions of Capital 6.2 Capital Adequacy Standards and the Basel Accords 6.3 Constituents of Capital and Minimum Capital Requirements 6.4 Risk-Based Regulatory Capital Allocation: Pillar 6.5 Supervisory Review: Pillar 6.6 Market Discipline: Pillar 6.7 Management of Capital Adequacy 6.8 Analysis of a Bank’s Capital Adequacy Annex 6A: Credit Risk–Related Weight Assignments Under the Basel I Accord, Covered by Tier and Tier Capital Annex 6b: Calculation of the Capital Adequacy Ratio to Include Market Risk (Tier Capital) 121 122 123 127 131 143 145 146 147 Credit Risk Management 7.1 Establishing Policies for Managing Credit Risk 7.2 Regulatory Policies to Limit Exposures 7.3 Management Policies to Reduce Credit Risk 7.4 Analyzing Credit Risk 7.5 Asset Classification and Loan Loss Provisioning 7.6 Assessing Credit Risk Management Capacity 161 161 162 166 171 177 187 153 156 Content vii Liquidity Risk Management 8.1 The Need for Liquidity 8.2 Liquidity Management Policies 8.3 The Regulatory Environment 8.4 The Structure of Funding 8.5 Cash Flow Analysis 8.6 Volatility of Funding and Concentration of Deposits 8.7 Liquidity Risk Management Techniques 191 191 195 198 201 203 207 209 Managing Liquidity and Other Investment Portfolios 9.1 Nature of the Liquidity Portfolio 9.2 Investment Policy 9.3 Strategic Asset Allocation 9.4 Benchmark Portfolio 9.5 Eligible Instruments 9.6 Credit Risk 9.7 Market Risk 9.8 Active Management 9.9 Risk Budgets 9.10 Management Reporting 215 215 216 217 219 221 222 223 223 225 226 10 Market Risk Management 10.1 Sources of Market Risk: Selected Concepts 10.2 Measuring Interest Rate Sensitivity 10.3 Portfolio Risk Management 10.4 Market Risk Measurement: Value at Risk (VAR) as a Possible Tool 10.5 Risk and Performance Measurement 10.6 Stress Testing and Scenario Analysis 227 227 231 235 238 246 251 11 Currency Risk Management 11.1 Introduction: Origin and Components of Currency Risk 11.2 Policies for Currency Risk Management 11.3 Currency Risk Exposure and Business Strategy 11.4 Review of Currency Risk Management Procedures 255 255 257 264 268 12 Asset-Liability Management 12.1 Objective of Asset-Liability Management 12.2 Interest Rate Risk Management Responsibilities 12.3 Models for the Management of Interest Rate Risk in the Balance Sheet 12.4 The Impact of Changes in Forecast Yield Curves 277 277 280 282 290 viii 13 Analyzing Banking Risk Operational Risk Management in a Treasury Environment 13.1 Operational Risk Management and the Basel Committee Initiatives 13.2 A Framework for Managing and Reporting Operational Risk 13.3 Identification of Business Line Functions and Activities 13.4 Process Flows: Documenting the Manner in Which Functions Are Performed 13.5 Risk Assessment: Contribution of People, Processes, Systems, and External Events 13.6 Control Assessment 13.7 Key Indicators of Performance and Risk 13.8 Operational Risk Reporting: Analysis, Actions, and Accountability Annex 13A Overview of Functions and Activities in a Treasury Environment 293 294 300 306 14 Transparency and Data Quality 14.1 Introduction: The Importance of Useful Information 14.2 Transparency and Accountability 14.3 Transparency in Financial Statements 14.4 Disclosure in the Financial Statements of Banks 14.5 Application of Accounting Standards 339 339 341 343 347 352 15 A Risk-Based Approach to Bank Supervision 15.1 Introduction: The Bank Supervisory Process 15.2 Banking Risks and the Accountability of Regulatory/Supervisory Authorities 15.3 The Supervisory Process 15.4 Consolidated Supervision 15.5 Supervisory Cooperation with Internal and External Auditors 357 357 308 309 312 315 320 325 361 364 373 377 Appendixes A Questionnaire: Analytical Review of Banks 379 B Summary of Core Principles Evaluation 413 C Basel Core Principles for Effective Banking Supervision October 2006 417 Analyzing Banking Risk Table A.18 Potential Risk Analytics Reports Risk Area Title Reference Potential Reports – Details Frequency Daily Weekly Monthly Periodic Counterparty risk Market risk Liquidity risk Currency risk Performance measurement and analysis Table A.19 Example of Daily/Monthly Checklist of Portfolio Compliance Issues Date and Reviewer: Rule Laws Regulations Institutional Policies 3.1 Risk limits Institutional Guidelines 4.1 Investment Restrictions 4.2 Allowable Duration Range 4.3 Limit to Duration Range 4.4 Eligible Instruments 4.5 Issuer’s Credit Rating 4.6 Eligible Currency Operational Guidelines 5.1 Issuer Concentration 410 Reference Investment Short Management Calculation Reporting Interpretation Description Agreement of Guideline Tool of Measure Language Portfolio Reviewed Table A.20 Treasury Operations: Reporting (Funding & Investing) Reporting Area Title Reference Sub-Report Types Frequency Daily Weekly Monthly Periodic A Accounting Reports Financial reports Trial Balance / Balance Sheet / Income Statement / Trade details / Settlement entries Holdings reports Inventory / Asset allocations / Performance (return on investments) reports B Control Reports Systems-to-systems / Control accounts (suspense accounts) External reconciliations Custodian reconciliations / cash account maintained by internal treasury function Cash Control accounts with external banks / cash accounts with internal clients C Pricing Reports Source reports Reuters / Bloomberg / Brokers / Other pricing services Exception (Diagnostic) reports Unusual fluctuations / New instruments Valuation reports Fair value accounting (IAS 39) Analysis reports Trends D Operational Reports Transactional reports Cash flows / Resets / Deal volumes / Call volumes / Settlement reports Operational risk Analysis of trend impacts E Regulatory Reports Security commissioners 411 Central Bank Appendix A: Questionnaire: Analytical Review of Banks Internal reconciliations Appendix B Summary of Core Principles Evaluation Core Principle by Principle Assessment Name of country: Telephone number: Address of supervisory authority: Date completed: Fax number: Person(s) responsible for completion: E-mail address: EVALUATION ASSESSMENT RATINGS Compliant 2a Largely compliant and efforts to achieve compliance are underway 2b Largely compliant and efforts to achieve compliance are not underway 3a Materially noncompliant and efforts to achieve compliance are underway 3b Materially noncompliant and efforts to achieve compliance are not underway 4a Noncompliant and efforts to achieve compliance are underway 4b Noncompliant and efforts to achieve compliance are not underway Analyzing Banking Risk # 1(1) 1(2) 1(3) 1(4) 1(5) 1(6) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 414 Summarized Description of Core Principles Framework for supervisory authority: Clear responsibilities and objectives for each agency Each such agency should possess operational independence and adequate resources Suitable legal framework, including provisions relating to authorization of banking Enforcement powers to address compliance with laws as well as safety and soundness concerns Legal protection for supervisors Arrangements for confidential information sharing between supervisors Permissible activities must be clearly defined, and control of the use of the word “bank” Right to set licensing criteria re governance and business plan and reject applications—prior consent of home country supervisor Authority to review and reject proposals to transfer significant ownership or controlling interests Establish and review major acquisitions/ investment criteria by a bank and resulting structures re risks or hindering of effective supervision Set minimum capital adequacy requirements/components of capital (Basel minimums for internationals) Ensuring that banks have a comprehensive risk management strategy in place Independent evaluation of credit policies, practices, and procedures related to granting of loans/investments Satisfied re practices and procedures for loan evaluation—the quality of assets/ loan loss provisions and reserves Satisfied with information systems and limits to restrict large exposures to single or related borrowers Connected lending to related companies and individuals on an arm’s-length basis, effectively monitored, mitigate risks Identifying, monitoring, and controlling country risk and for maintaining reserves against such risks Accurately measure, monitor, and control market risks—specific limits and/or a capital charge Satisfied that banks have in place a liquidity management strategy Identify, assess, and monitor operational risk Effective systems identify, assess, and monitor interest rate risk Internal controls in place with regard to complexity of business—independent external audit Banks have adequate policies/ “know-your-customer” rules that promote high ethical and professional standards in the financial sector—to prevent money laundering Develop understanding Independent validation of supervisory information through on-site examinations or use of external auditors Regular contact with bank management and a thorough understanding of the institution’s operations Means of off-site analyzing prudential reports and statistical returns from banks on a solo and consolidated basis Banks maintain and publish financial statements that fairly reflect their condition using consistent accounting policies and practices providing a true and fair view of their financial condition on a regular basis Ability for timely remedial measures when banks commit prudential or regulatory violations, or where depositors are threatened in any other way, including ability to revoke the banking license Ability to supervise the banking group on a consolidated supervision basis Global consolidation and supervision over internationally active banking ventures Contact/information exchange with other supervisory authorities to ensure effective host country supervision Supervision of foreign establishments must require the same high standards as are required of domestic institutions and must have powers to share information needed by the home country supervisors Assessment n/a Appendix B: Summary of Core Principles Evaluation Example: Core Principle (1): An effective system of banking supervision will have clear responsibilities and objectives for each agency involved in the supervision of banks Essential criteria Additional criteria Laws are in place for banking, and for (each of) the agency (agencies) involved in banking supervision The responsibilities and objectives of each of the agencies are clearly defined The supervisory agency sets out objectives and is subject to regular review of its performance against its responsibilities and objectives through a transparent reporting and assessment process The laws and/or supporting regulations provide a framework of minimum prudential standards that banks must meet The supervisory agency ensures that information on the financial strength and performance of the industry under its jurisdiction is publicly available There is a defined mechanism for coordinating actions between agencies responsible for banking supervision and evidence that it is used in practice The supervisor participates in deciding when and how to effect the orderly resolution of a problem bank situation (which could include closure, assisting in restructuring, or merger with a stronger institution) Banking laws are updated as necessary to ensure that they remain effective and relevant to changing industry and regulatory practices Discussion Assessment The country is largely compliant with Core Principle (1) Efforts to achieve compliance are not underway 415 Appendix C Basel Core Principles for Effective Banking Supervision October 2006 The Basel Core Principles define 25 principles that are needed for a supervisory system to be effective Those principles are broadly categorized into seven groups: The objectives, independence, powers, transparency, and cooperation (Principle 1) Licensing and structure (Principles to 5) Prudential regulation and requirements (Principles to 18) Methods of ongoing banking supervision (Principles 19 to 21) Accounting and disclosure (Principle 22) Corrective and remedial powers of supervisors (Principle 23) Consolidated and cross-border banking supervision (Principles 24 and 25) Objectives, Independence, Powers, Transparency, and Cooperation Principle – Objectives, independence, powers, transparency, and cooperation An effective system of banking supervision will have clear responsibilities and objectives for each authority involved in the supervision of banks Each such authority should possess operational independence, transparent processes, sound governance, and adequate resources, and be accountable for Analyzing Banking Risk the discharge of its duties A suitable legal framework for banking supervision is also necessary, including provisions relating to authorization of banking establishments and their ongoing supervision, powers to address compliance with laws as well as safety and soundness concerns, and legal protection for supervisors Arrangements for sharing information between supervisors and protecting the confidentiality of such information should be in place Licensing and Structure Principle – Permissible activities: The permissible activities of institutions that are licensed and subject to supervision as banks must be clearly defined, and the use of the word “bank” in names should be controlled as far as possible Principle – Licensing criteria: The licensing authority must have the power to set criteria and reject applications for establishments that not meet the standards set The licensing process, at a minimum, should consist of an assessment of the ownership structure and governance of the bank and its wider group, including the fitness and propriety of board members and senior management; its strategic and operating plan; internal controls and risk management; and its projected financial condition, including its capital base Where the proposed owner or parent organization is a foreign bank, the prior consent of its home country supervisor should be obtained Principle – Transfer of significant ownership: The supervisor has the power to review and reject any proposals to transfer significant ownership or controlling interests held directly or indirectly in existing banks to other parties Principle – Major acquisitions: The supervisor has the power to review major acquisitions or investments by a bank, against prescribed criteria, including the establishment of cross-border operations, and confirming that corporate affi liations or structures not expose the bank to undue risks or hinder effective supervision Prudential Regulation and Requirements Principle – Capital adequacy: Supervisors must set prudent and appropriate minimum capital adequacy requirements for banks that reflect the risks that the bank undertakes, and must define the components of capital, bearing in mind its ability to absorb losses At least for internationally active banks, these 418 Appendix C: Basel Core Principles for Effective Banking Supervision requirements must not be less than those established in the applicable Basel requirement Principle – Risk management process: Supervisors must be satisfied that banks and banking groups have in place a comprehensive risk management process (including board and senior management oversight) to identify, evaluate, monitor, and control or mitigate all material risks and to assess their overall capital adequacy in relation to their risk profi le These processes should be commensurate with the size and complexity of the institution Principle – Credit risk: Supervisors must be satisfied that banks have a credit risk management process that takes into account the risk profile of the institution, with prudent policies and processes to identify, measure, monitor, and control credit risk (including counterparty risk) This would include the granting of loans and making of investments, the evaluation of the quality of such loans and investments, and the ongoing management of the loan and investment portfolios Principle – Problem assets, provisions, and reserves: Supervisors must be satisfied that banks establish and adhere to adequate policies and processes for managing problem assets and evaluating the adequacy of provisions and reserves Principle 10 – Large exposure limits: Supervisors must be satisfied that banks have policies and processes that enable management to identify and manage concentrations within the portfolio, and supervisors must set prudential limits to restrict bank exposures to single counterparties or groups of connected counterparties Principle 11 – Exposures to related parties: To prevent abuses arising from exposures (both on balance sheet and off balance sheet) to related parties and to address confl ict of interest, supervisors must have in place requirements that banks extend exposures to related companies and individuals on an arm’slength basis; these exposures are effectively monitored; appropriate steps are taken to control or mitigate the risks; and write-offs of such exposures are made according to standard policies and processes Principle 12 – Country and transfer risks: Supervisors must be satisfied that banks have adequate policies and processes for identifying, measuring, monitoring, and controlling country risk and transfer risk in their international 419 Analyzing Banking Risk lending and investment activities, and for maintaining adequate provisions and reserves against such risks Principle 13 – Market risks: Supervisors must be satisfied that banks have in place policies and processes that accurately identify, measure, monitor, and control market risks; supervisors should have powers to impose specific limits and/or a specific capital charge on market risk exposures, if warranted Principle 14 – Liquidity risk: Supervisors must be satisfied that banks have a liquidity management strategy that takes into account the risk profile of the institution, with prudent policies and processes to identify, measure, monitor, and control liquidity risk, and to manage liquidity on a day-to-day basis Supervisors require banks to have contingency plans for handling liquidity problems Principle 15 – Operational risk: Supervisors must be satisfied that banks have in place risk management policies and processes to identify, assess, monitor, and control and mitigate operational risk These policies and processes should be commensurate with the size and complexity of the bank Principle 16 – Interest rate risk in the banking book: Supervisors must be satisfied that banks have effective systems in place to identify, measure, monitor, and control interest rate risk in the banking book, including a welldefi ned strategy that has been approved by the board and implemented by senior management; these should be appropriate to the size and complexity of such risk Principle 17 – Internal control and audit: Supervisors must be satisfied that banks have in place internal controls that are adequate for the size and complexity of their business These should include clear arrangements for delegating authority and responsibility; separation of the functions that involve committing the bank, paying away its funds, and accounting for its assets and liabilities; reconciliation of these processes; safeguarding the bank’s assets; and appropriate independent internal audit and compliance functions to test adherence to these controls as well as applicable laws and regulations Principle 18 – Abuse of financial services: Supervisors must be satisfied that banks have adequate policies and processes in place, including strict “knowyour-customer” rules, that promote high ethical and professional standards in the financial sector and prevent the bank from being used, intentionally or unintentionally, for criminal activities 420 Appendix C: Basel Core Principles for Effective Banking Supervision Methods of Ongoing Banking Supervision Principle 19 – Supervisory approach: An effective banking supervisory system requires that supervisors develop and maintain a thorough understanding of the operations of individual banks and banking groups, and also of the banking system as a whole, focusing on safety and soundness and the stability of the banking system Principle 20 – Supervisory techniques: An effective banking supervisory system should consist of on-site and off-site supervision and regular contacts with bank management Principle 21 – Supervisory reporting: Supervisors must have a means of collecting, reviewing, and analyzing prudential reports and statistical returns from banks on both a solo and a consolidated basis, and a means of independent verification of these reports, through either on-site examinations or use of external experts Accounting and Disclosure Principle 22 – Accounting and disclosure: Supervisors must be satisfied that each bank maintains adequate records drawn up in accordance with accounting policies and practices that are widely accepted internationally, and publishes, on a regular basis, information that fairly reflects its financial condition and profitability Corrective and Remedial Powers of Supervisors Principle 23 – Corrective and remedial powers of supervisors: Supervisors must have at their disposal an adequate range of supervisory tools to bring about timely corrective actions This includes the ability, where appropriate, to revoke the banking license or to recommend its revocation Consolidated and Cross-Border Banking Supervision Principle 24 – Consolidated supervision: An essential element of banking supervision is that supervisors supervise the banking group on a consolidated basis, adequately monitoring and, as appropriate, applying prudential norms to all aspects of the business conducted by the group worldwide 421 Analyzing Banking Risk Principle 25 – Home-host relationships: Cross-border consolidated supervision requires cooperation and information exchange between home supervisors and the various other supervisors involved, primarily host banking supervisors Banking supervisors must require the local operations of foreign banks to be conducted to the same standards as those required of domestic institutions Basel Committee on Banking Supervision October 2006 422 Analyzing Banking Risk provides a comprehensive overview of topics focusing on assessment, analysis, and management of financial risks in banking The publication emphasizes risk-management principles and stresses that key players in the corporate governance process are accountable for managing the different dimensions of financial risk This third edition remains faithful to the objectives of the original publication (Analyzing Banking Risk) A significant new edition is the inclusion of chapters on the management of the treasury function Advances made by the Basel Committee on Banking Supervision are reflected in the chapters on capital adequacy, transparency, and banking supervision This publication should be of interest to a wide body of users of bank financial data The target audience includes persons responsible for the analysis of banks and for the senior management or organizations directing their efforts Since the publication provides an overview of the spectrum of corporate governance and risk management, it is not aimed at technical specialists of any particular risk management area Hennie van Greuning is currently an Adviser in the World Bank’s Treasury and has previously worked as a sector manager for financial sector operations in the Bank He has had a career as a partner in a major international accounting firm and as controller and head of bank supervision in a central bank Sonja Brajovic Bratanovic is a senior financial sector specialist in the World Bank She has had many years of experience in banking risk analysis and banking-sector reforms, in addition to a former career as a senior official in a central bank ISBN 978-0-8213-7728-4 THE WORLD BANK SKU 17728 ... Financial Assets and Liabilities under IAS 39 Financial Risk Disclosure Requirements under IFRS 7v Public Disclosures by Banks Stages of the Analytical Review Process Banking Risk Exposures Off-site Surveillance... and changes or trends in such risks Risk- based bank analysis also underscores the relevant institutional aspects Such aspects include the quality Chapter 1: Overview of Banking Risks and style of... requirements”) and that it has adequate procedures or systems to assess and hedge and provide against risks, such as asset classification and provisioning procedures and value-at -risk models for market