Basel_III_-_Impact_on_Foreign_Banks_in_India.pdf

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    Basel III Impact onForeign Banks in India Discussion note

    May 2012

    www.pwc.com

    May 2012

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    PwC

    RBI guidelines on Basel III Key components

    Tighter definitionsfor regulatory

    capital

    Capital bufferrequirements

    Enhancedcounterparty credit

    risk controls

    Enhanced liquiditystandards

    Leverage ratio

    Redefined Core, Tier1, Tier 2 capital:Qualifying asset types arerestricted and tier isstructure is rationalized

    Public disclosure

    requirements: Banksmust reconcile regulatorycapital to auditedfinancial statements

    Higher levels ofcapital: Common equityrequirement increasedfrom 2% to 5.5%, plus a2.5% conservation. Tier 1capital ratio increased to

    8% Contingent capital:

    Banks must hold furtherdebt securities that canconvert to equity in timesof stress

    Capital conservationbuffer: Banks mustmaintain a buffer abovethe minimum capitalrequirements

    Countercyclical

    capital buffer: Banksmust maintain anadditional capital bufferduring times of excessivecredit growth

    Framework forcapital bufferreplenishment: Banksare constrained indistributing earnings if

    buffers under-funded

    Strengthenedcounterparty creditrisk management:Banks must includeStressed inputs, creditvaluation adjustments

    and wrong-way risk inrisk modelling andconduct robust back-testing

    Strengthenedcollateral mgmtstandards: Banks mustimprove collateraloperations and applylonger margining periods

    for derivatives exposures Incentives for central

    clearing of OTCProducts: Centrallycleared products aregiven low risk weightings

    Short-term liquiditycoverage ratio: Banksmust meet fundingobligations for 30 daysunder an acute liquiditystress scenario

    Long-term net stablefunding ratio: Banksmust hold adequatelonger-term stablefunding sources in termsof the liquidity profile oftheir assets

    Non-risk weightedmeasure of exposure:Banks must keep the ratioof Tier 1 capital to gross-exposures, including off-balance sheet exposures,

    at specific conversionrates, above 4.5%(current RBI guidelines)

    As RBI guidelines on Basel III impact heavily on capital, liquidity and overall leverage, they willnecessitate changes to the business and operational strategy of several banks

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    Capital Base Transitional arrangements : RBI guidelineson Basel III

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    Jan 1,2013

    Mar 31,2014

    Mar 31,2015

    Mar 31,2016

    Mar 31,2017

    Mar 31,2018

    Min Common Equity Tier 1 4.5% 5.0% 5.5% 5.5% 5.5% 5.5%

    Capital conservation buffer - - 0.625% 1.25% 1.875% 2.5%

    Min common equity + capconservation buffer

    4.5% 5.0% 6.125% 6.75% 7.375% 8.0%

    Minimum Tier 1 Capital 6.0% 6.5% 7.0% 7.0% 7.0% 7.0%

    Minimum Total Capital * 9.0% 9.0% 9.0% 9.0% 9.0% 9.0%

    Min Total Capital + capconservation buffer

    9.0% 9.0% 9.625% 10.25% 10.875% 11.5%

    Phase in of deductions fromCommon Equity Tier 1

    40% 40% 60% 80% 100% 100%

    Capital instruments that nolonger qualify as Tier 1 or Tier 2

    Phased out over 10 year period starting January 2013

    * The difference between the minimum total capital requirement of 9% and the Tier 1 requirement can bemet with Tier 2 and higher forms of capital.

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    RBI guidelines on Basel III Impact on foreign banks inIndia (1)

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    Common equity and retained earnings should be the predominant component of Tier 1capital instead of debt-like instruments, well above the current 50% rule

    Gradual phase-out of hybrid Tier 1 components including many of the step-up /innovative / SPV issued Tier 1 instruments used by banks

    Minimum common equity Tier 1:

    Increased from 2% to 5.5%

    Plus capital conservation buffer of 2.5%

    Bringing total common equity requirements to 8.0%

    Minimum total capital:

    Increased from 9.0% to 11.5% (including conservation buffer)

    To be phased in from 2013 to 2018

    Tighterdefinitions for

    regulatorycapital

    Capital conservation buffer of 2.5 % in addition to minimum capital requirements Counter-cyclical capital buffer being developed which is expected to be implementedby increases to the capital conservation buffer during periods of excessive creditgrowth. RBI will issue further guidelines on CC, this may lead to marginally additionalcapital requirement

    Capital bufferrequirements

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    RBI guidelines on Basel III Impact on foreign banks inIndia (2)

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    Improved counterparty risk management standards in the area of collateralmanagement and stress-testing

    Encouraging use of Central Counterparties (CCPs) for standardised derivatives

    Enhancedcounterpartycredit riskcontrols

    The liquidity coverage ratio will help ensure that banks have sufficient high-qualityliquid assets to withstand a stressed funding scenario specified by RBI

    For liquidity coverage ratio, assets get a liquidity based weightage varying from100% for government bonds and cash to 0%-50% for corporate bonds

    For net stable funding ratio, required and available funding amounts are determinedusing weighing factors, reflecting the stability of the funding available and theduration of the asset LCR & NSFR

    For net stable funding ratio, the weightage factors for assets vary from 0% and 5% forcash and government bonds, to 85% for retail loans and small business loans(remaining maturity < 1 year) and 100% for other assets

    Enhancedliquiditystandards

    The leverage ratio is implemented on a gross and un-weighted basis (banks totalassets including both on and off-balance sheet assets) as a proportion of the bankstotal capital. This does not take into account the risks related to the assets. Finalleverage ratio requirement would be prescribed by RBI after the parallel run takinginto account the prescriptions given by the Basel Committee

    Banks which at present have the leverage ratio below 4.5% may endeavor to bring itabove 4.5% as early as possible

    LeverageRatio

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