Capital Adequacy Standards for Primary Dealers - ആർബിഐ - Reserve Bank of India
Capital Adequacy Standards for Primary Dealers
IDMC.PDRS.PDC.3/03.64.00/2000-01
December 11, 2000
To all Primary Dealers in the Government securities market
Dear Sirs,
Capital Adequacy Standards for Primary Dealers
Please refer to letter D.O.IDMC.NO.PDRS/3361/03.64.00/99-2000 dated April 11, 2000 addressed to the then Chairman, Primary Dealers Association of India, forwarding a copy of the draft Capital Adequacy standards for the comments of the Primary Dealers and working out the capital charges as on March 31, 2000 on a trial basis, by them. The reports on trial basis have since been received from the PDs and examined at our end. Taking into account the trial returns and the comments/suggestions received from the PDAI, certain individual PDs as also from the other related Departments of RBI, the Capital Adequacy standards have, as set out here, been finalised.
2. The `Guidelines on Capital Adequacy Standards for Primary Dealers’ are enclosed. It has been decided to operationalise the revised Standards with effect from September 30, 2000. Accordingly, the PDs should work out the capital charges on their portfolio as on September 30, 2000 in accordance with the guidelines set out in the enclosed Note and, along with a copy each of their Risk Management system and the framework for working out the Value at Risk, submit to us before December 30, 2000. The Primary Dealers should, hence forth, submit the return on a quarterly basis i.e. as at March 31, June 30, September 30 and December 31 before 15th of the month following the quarter. Each return should be accompanied by the Back Testing results. While the report of the External Auditors as envisaged at Para B.5 (Attachment II) may be submitted along with the return as on March 31, the PDs should immediately report to us in case their Risk Management system and/or the VaR framework undergoes any material change that would effect the capital charges.
3. For meeting the market risk capital charges, the Tier – III Capital has specifically been introduced in accordance with international norms. The PDs may consider issuing Tier – III Capital for meeting the market risk capital requirements. The characteristics of the Tier – III Capital, the instruments, tenor and terms and conditions that need to be fulfilled for considering it as eligible for capital adequacy requirement are detailed in Attachment – I.
4. It may also be noted that the Basle Committee on Banking Supervision is engaged in a comprehensive review/revision of the existing Capital Adequacy Accord. The document is presently under consultative process among the subscribing member countries. Since such international practices are being worked out in conjunction with the IOSCO (International Organisation of Securities Commissions) i.e. the federation of regulators for securities firms etc., the capital adequacy standards for PDs set out in the present Note would be reviewed from time to time in the light of the Basle Committee/IOSCO developments and revised as considered warranted.
5. Primary Dealers who are not able to work out the capital charges as per the internal risk model (VaR) based method or whose VaR framework is not satisfactory, should maintain minimum capital of 7 (seven) per cent on their securities portfolio, exclusively for market risk i.e. in addition to the capital for credit and counter party risk.
6. Please acknowledge receipt.
Yours faithfully,
(Usha Thorat)
Chief General Manager –in- Charge
Encl :
Capital Adequacy Standards for Primary Dealers
The system of Primary Dealers in Government Securities Market was introduced in 1995. The operations of the PDs are guided by the "Guidelines to Primary Dealers in Government Securities Market". The PDs are also entities registered with RBI under the RBI (NBFC) Regulations. At the time of introduction of the system, besides fixing a minimum absolute capital requirement, the PDs were enjoined to adhere to the capital adequacy standards prescribed for NBFCs. Notional risk weights towards the position risk on Government securities were also indicated in addition.
The focus of the RBI (NBFC) Regulations is on the deposit acceptance function. PDs, however, are entities engaged in securities business, predominantly in Government securities and meet their funding needs in the money markets. The major risk they face therefore, is the interest rate risk. The application of capital adequacy guidelines prescribed for NBFCs under RBI (NBFC) Regulations in toto to the Primary Dealers therefore necessitated reconsideration. The firming up of the views in international financial/securities markets with regard to the capital towards market risk, has also speeded up the introduction of focussed capital adequacy standards for PDs. In the existing guidelines, capital requirement for market risk is captured by stipulating different weights for securities of different maturities and then making the CRAR requirement under the NBFC Regulations applicable. It is now felt necessary to review the system and introduce capital adequacy standards for market risk in accordance with international best practices.
The present Note contains the capital adequacy standards to be adopted and maintained by the Primary Dealers.
1. CAPITAL FUNDS
Explanations :
- "Tier-I Capital" would mean paid-up capital, statutory reserves and other disclosed free reserves. Investment in subsidiaries where applicable, intangible assets, losses in current accounting period and losses brought forward from previous accounting periods will be deducted from the Tier I capital.
- "Tier-II capital" includes the following :-
- preference shares other than those which are compulsorily convertible into equity;
- revaluation reserves at discounted rate of fifty five percent;
- general provisions and loss reserves to the extent these are not attributable to actual diminution in value or identifiable potential loss in any specific asset and are available to meet unexpected losses, up to the extent of one and one fourth (1.25) percent of total risk weighted assets;
- hybrid debt capital instruments; and
- subordinated debt
- ``Tier – III Capital’’ is the capital issued to meet market risk capital charge in accordance with the criteria laid down in Attachment I
- "subordinated debt " means a fully paid up capital instrument, which is unsecured and subordinated to the claims of other creditors, is free of restrictive clauses and is not redeemable at the instance of the holder or without the consent of the Reserve Bank. The book value of such instrument shall be subjected to discounting as provided hereunder :
Remaining Maturity of the instrument | Rate of discount | |
(i) | Upto one year | 100% |
(ii) | More than one year but upto two years | 80% |
(iii) | More than two years but upto three years | 60% |
(iv) | More than three years but upto four years | 40% |
(v) | More than four years but upto five years | 20% |
Subordinated debt instruments at discounted value will be limited to fifty per cent of Tier I capital.
- The total of Tiers -`II’ and `III’ Capital taken for working out the Total Capital Funds should not exceed 100 per cent of the ‘Tier-I" Capital.
- The contracts for purchase of securities, entered into in terms of the `same day sale of Govt. securities by the successful auction participants’ permitted by RBI and outstanding as on the date of calculation/preparation of the capital charges/return, should also be included in the asset portfolio and capital charges thereon calculated.
Note : In case any PD is having substantial interest/ (as defined for NBFCs) exposure by way of loans and advances not related to business relationship in other Group companies, such amounts will be deducted from its Tier I capital.
The capital adequacy requirements are segregated into three Sections: Section A deals with Credit Risk and B with Market Risk and Section C gives the Summation.
Section-A : CREDIT RISK
(a) Risk weights for on-Balance Sheet assets
Explanations :
(1) All the on-balance sheet items are assigned percentage weights as per degree of credit risk. The value of each asset/item is to be multiplied by the relevant risk weight to arrive at risk adjusted value of the asset, as detailed below. The aggregate of the Risk Weighted Assets will be taken into account for reckoning the minimum capital ratio.
Nature of asset/item | Percentage weight | |||
(i) | Cash balances and balances in Current | 0 | ||
Account with RBI | ||||
(ii) | Amounts lent in call/notice money market/ | 20 | ||
Other money market instruments of banks/ | ||||
FIs including CDs and balances in Current | ||||
account with banks | ||||
(iii) | Investments | |||
(a) | `Government’/‘Approved’ securities | 0 | ||
[other than at (e) below] | ||||
(b) | Fixed Deposits, Bonds of banks and Fis | 20 | ||
(as specified by DBOD) | ||||
(c) | Bonds issued by banks/Financial Institutions | 100 | ||
as Tier II capital (as specified by DBOD) | ||||
| ||||
(d) | Shares of all Companies and | 100 | ||
debentures/bonds/Commercial | ||||
Paper of Companies other than in (b) | ||||
above/units of mutual funds | ||||
(e) | Securities of Public Sector Undertakings | 20 | ||
guaranteed by Government but issued | ||||
outside the market borrowing programme | ||||
(f) | Securities of and other claims on | 100 | ||
Primary Dealers including rediscounting of | ||||
bills discounted by other PDs | ||||
(g) | Bills discounted by banks/FIs that are | 20 | ||
rediscounted | ||||
(iv) | Current assets | |||
(a) | Inter-corporate deposits | 100 | ||
(b) | Loans to staf | 100 | ||
(c) | Other secured loans and advances | |||
considered good | 100 | |||
(d) | Bills purchased/discounted | 100 | ||
(e) | Others (to be specified) | 100 | ||
(v) | Fixed Assets (net of depreciation) | |||
(a) | Assets leased out (net book value) | 100 | ||
(b) | Fixed Assets | 100 | ||
| ||||
(vi) | Other assets | |||
(a) | Income tax deducted at | |||
source (net of provision) | 0 | |||
(b) | Advance tax paid (net of provision) | 0 | ||
(c) | Interest accrued on Government securities | 0 | ||
(d) | Others (to be specified and risk weight | x | ||
indicated as per counter party) | ||||
Notes: | (1) | Netting may be done only in respect of assets where provisions for depreciation or for bad and doubtful debts have been made. |
(2) | Assets which have been deducted from capital fund as at `Capital Funds – (a)’ above, shall have a risk weight of `zero’. | |
(3) | The PDs net off the Current Liabilities and Provisions from the Current Assets, Loans and Advances in their Balance Sheet, as The Balance Sheet is drawn up as per the format prescribed under the Companies Act. For capital adequacy purposes, no such netting off should be done except to the extent of the provisions indicated above. |
(b) Risk weights for off-Balance Sheet items
The intrinsic credit risk in respect of off-Balance Sheet items is arrived at in a two stage process. The face value of each of the off-Balance Sheet items is multiplied by the ``credit conversion factor" as per the nature of the item, as indicated in the table below. This will then be multiplied with the weights relevant to the counter party to the contract (viz., Government, bank, Financial Institution etc.) as specified for on balance sheet items above.
Nature of item | Credit conversion | |||
factor percentage | ||||
i) | Financial guarantees considered | 100 | ||
as credit substitutes | ||||
ii) | Other guarantees | 50 | ||
iii) | Share/debenture/auction stock | 100 | ||
underwriting obligations | ||||
| ||||
iv) | Partly-paid shares/debentures | 100 | ||
and other securities | ||||
v) | Bills discounted/rediscounted | 100 | ||
vi) | Repurchase agreements (e.g. buy/sell) | 100 | ||
where the credit risk remains with the PD | ||||
vii) | Other contingent liabilities/ | 50 | ||
commitments like standby facility with | ||||
original maturity of over one year | ||||
viii) | Similar contingent liabilities/ | 0 | ||
commitments with original maturity of | ||||
upto one year or which can be uncondi- | ||||
tionally cancelled at any time | ||||
Note: Cash margins/deposits shall be deducted before applying the Conversion Factor.
(bi) Interest Rate Contracts
For the Interest Rate related contracts, which generally are - interest rate swaps, forward rate agreements, basis swaps, interest rate futures, interest rate options and other contracts of similar nature, the methodology for capital charge calculation will be as under :
(i) The notional principal amount will be multiplied by the Conversion Factors given below to arrive at the Adjusted Value.
Conversion Factor
@ 0.5% of Notional Principal Value for original maturity of less than 1 year
@ 1.0% for original maturity of one year and less than two years
@ 1.0% for each additional year from two years and above
(ii) The Adjusted Value thus obtained shall be multiplied by the Risk Weight applicable to the counter party as specified below:
Government/any exposure | 0% |
guaranteed by Government | |
Banks/Financial Institutions | 20% |
(as specified by DBOD) | |
Primary Dealers in the Government | 100% |
Securities market | |
All others | 100% |
Section-B : MARKET RISK
Market risk is defined as the risk of losses in on and off – balance sheet positions arising from movements in market prices. The objective in introducing the capital adequacy for market risk is to provide an explicit capital cushion for the price risk to which the PDs are predominantly exposed in their portfolio.
Internationally there are two methods for working out the capital charge for market risks viz : (i) the standardised model and (ii) the internal risk management based model – subject to fulfillment of certain conditions.
As the risk management systems at the PDs are still evolving, it is considered appropriate that PDs calculate capital charges based on the standardised method as also under the internal risk management framework based (VaR) model, the minimum parameters for which are indicated elsewhere in this Note, and maintain the higher of the two requirements.
In case the capital charges are already being maintained as per the risk based model and work out to be higher than as per the standardised method, such PDs should not scale down or modify the model. Permitting maintenance of capital charges based exclusively on the risk based model will be considered after the PDs gain sufficient experience in this regard.
The methodology for working out the capital charges for market risk on the portfolio are detailed in Annexure – 1(a) (Fixed Income instruments - as per the Standardised method), Annexure – 1(b) (Fixed Income instruments - as per the internal risk model [VaR] based method, Annexure – 2 (on Equity Positions) and Annexure – 3 (on Interest Rate Contracts).
Section C : SUMMATION OF CAPITAL ADEQUACY REQUIREMENTS
The capital adequacy requirements for the PDs will comprise
@ the credit risk requirements as indicated in Section : A, plus
@ the capital charge for market risk requirements as arrived at under Section:B Annexure-1(a) or (b), Annexures-2 and 3.
- Every Primary Dealer shall maintain a minimum capital ratio consisting of Tier I and Tier II Capital which shall not be less than fifteen per cent of its aggregate risk weighted assets and of risk adjusted value of off-balance sheet items.
- The total of Tier II Capital, if any, shall not exceed one hundred per cent of Tier I Capital, at any point of time.
- The total of Tier III Capital, if any, shall not exceed two hundred and fifty per cent of the Tier I and Tier II Capital available for meeting market risk capital charge i.e. excess over the credit and counter party risk capital requirements.
- In working out the eligible capital, the PDs are required to first calculate their minimum capital requirements for credit risk and only afterwards the capital charge towards market risk requirements. The total capital funds will represent the capital available to meet both the credit as also the market risks.
- The overall capital adequacy ratio will be calculated by establishing an explicit numerical link between the credit risk and the market risk factors, by multiplying the market risk capital charge with 6.67 i.e. the reciprocal of the minimum credit risk capital charge of 15 %. The resultant figure is added to the sum of risk weighted assets worked out for credit risk purpose. The numerator for calculating the overall ratio will be the PD’s Tier I , Tier II and the Tier III Capital after head room deductions, if any. Illustratively, the calculation of capital charge would be as under :
(i) | Total of Risk Weighted Assets for Credit | Rs. |
Risk as per Section A | ||
(ii) | (a) Tier I Capital funds (after deductions) | Rs. |
(b) Tier II Capital funds eligible | Rs. | |
(c) Total of available Tier I & II capital funds | Rs. | |
(iii) | Minimum credit risk capital required | Rs. |
i.e. (i) x 15 per cent | ||
(iv) | Excess of Tier I & II capital funds available | Rs. |
For market risk capital charge i.e. (ii) (c) – (iii) | ||
(v) | [a] The Market Risk capital charge worked | Rs. |
out as the higher of the amounts under the | ||
Standardised method and the one as per | ||
Internal Risk Management (VaR) Model, as at | ||
Section B, Annexure-1 plus Annexure-2 plus | ||
Annexure-3 or at 7 per cent of the securities | ||
Portfolio if VaR is not in place or not accepted | ||
By RBI | ||
(vi) | Capital funds available to meet (v) | Rs. |
i.e: excess of Tier I and Tier II as at (iv) above, | ||
plus | ||
eligible Tier III capital funds [maximum | ||
up to 250 % of (iv) above] | ||
(vii) | Over all Capital Adequacy | |
(a) Total RWA for credit risk i.e. (i) | Rs. | |
(b) Capital charge for market risk i.e. (v) | Rs. | |
(c) Numerical Link for (b) = | 6.67 | |
i.e.(reciprocal of credit risk capital ratio of 15%) | ||
(d) Risk Weighted Assets relating to | ||
Market Risk i.e. (b) x (c) | Rs. | |
(e) Total Risk Weighted Assets i.e. (a) + (d) | Rs. | |
(f) Minimum capital required i.e. (e) x 15% | Rs. | |
(g) Total Capital funds available i.e. (ii) + (vi) | Rs. | |
(h) less : Capital funds prescribed by other regulators/ | Rs. | |
licensors e.g. SEBI/ NSE/ BSE/OTCEI | ||
(i) Net capital funds available (g – h) | Rs. | |
for PD business | ||
The PDs should ensure that capital charge requirements are being met on a continuous basis. | ||
(viii) | Surplus Tier III Capital funds, if any | Rs. |
Annexure – 1 (a)
Fixed Income Instruments
Standardised method
Though generally choice between two principal methods of measuring the risk is permitted under the standardised method, the " duration’’ method is considered more appropriate for the PDs as compared to the method based on residual maturity. The capital charge under this method is the sum of four components :
- the net short or long position in the whole trading book;
- a small proportion of the matched positions in each time-band (the "vertical disallowance’’);
- a larger proportion of the matched positions across different time-bands (the "horizontal disallowance’’) ;
- a net charge for positions in options, where appropriate
Note : Since blank short selling in the cash position is not allowed, netting as indicated at (a) and the system of `disallowances’ as at (b) and (c) above are applicable currently only to the PDs entering into FRAs/IRSs.
Separate duration ladders should be used and capital charges summed up with no offsetting between positions of opposite sign, in case such a situation exists.
After mapping all the positions, individual net positions are to be summed within each time band irrespective of whether they are long or short positions, to produce a gross position figure.
Under the duration method, PDs with the necessary capability may, with RBI’s permission use a more accurate method of measuring all of their general market risks by calculating the price sensitivity of each position separately. PDs must elect and use the method on a continuous basis and the system adopted will be subjected to monitoring by RBI. The mechanics of this method are as follows:
- First calculate the price sensitivity of each instrument in terms of a change in interest rates of between 0.6 and 1.0 percentage points depending on the duration of the instrument (Table 1 );
- Slot the resulting sensitivity measures into a duration-based ladder with the thirteen time-bands set out in Table 1;
@ Subject the lower of the long and short positions in each time-band to a 5% capital charge towards vertical disallowance designed to capture basis risk;
@@ Carry forward the net positions in each time-band for horizontal offsetting across the zones subject to the disallowances set out in Table 2.
@ / @@ : Applicable only where opposite positions exist as explained at Note above.
Table 1 | |||
Duration time-bands and assumed changes in yield | |||
Assumed change in yield | Assumed change in yield | ||
Zone 1 | Zone 3 | ||
0 to 1month | 1.00 | 4 to 5 years | 0.85 |
1 to 3 mo | 1.00 | 5 to 7 years | 0.80 |
3 to 6 mo | 1.00 | 7 to 10 years | 0.75 |
6 to 12 mon | 1.00 | 10 to 15 years | 0.70 |
15 to 20 years | 0.65 | ||
Zone 2 | Over 20 years | 0.60 | |
1to2 years | 0.95 | ||
2 to 3 years | 0.90 | ||
3 to 4 years | 0.85 | ||
Table 2 | ||||
Horizontal disallowances | ||||
Zones | Time-band | Within the zone | Between adjacent zones | Between zones 1 and 3 |
Zone 1 | 0 – month | 40% | 40% | 100% |
1 - 3 months | ||||
3 – 6 months | ||||
6 – 12 months | ||||
Zone 2 | 1 – 2 years | 30% | ||
2 – 3 years | ||||
3 – 4 years | ||||
Zone 3 | 4 – 5 years | 30% | ||
5 – 7 years | ||||
7 – 10 years | ||||
10 – 15 years | ||||
15 – 20 years | ||||
Over 20 years | ||||
The gross positions in each time-band will be subject to risk weighting as per the assumed change in yield set out in Table 2, with no further offsets.
Annexure – 1(b)
Fixed Income Instruments
Internal risk model (VaR) based method
The PDs should calculate the capital requirement based on their internal Value at Risk model for market risk, as per the following minimum parameters :
- "Value-at-risk" must be computed on a daily basis.
- In calculating the value-at-risk, a 99th percentile, one-tailed confidence interval is to be used.
- An instantaneous price shock equivalent to a 30-day movement in prices is to be used, i.e. the minimum "holding period" will be thirty trading days.
- The choice of historical observation period (sample period) for calculating value-at-risk will be constrained to a minimum length of one year and not less than 250 trading days. For PDs who use a weighting scheme or other methods for the historical observation period, the "effective" observation period must be at least one year (that is, the weighted average time lag of the individual observations cannot be less than 6 months).
- The capital requirement will be the higher of (i) the previous day's value-at-risk number measured according to the above parameters specified in this section and (ii) the average of the daily value-at-risk measures on each of the preceding sixty business days, multiplied by a multiplication factor prescribed by RBI (3.30 presently).
- No particular type of model is prescribed. So long as the model used captures all the material risks run by the PDs, they will be free to use models, based for example, on variance-covariance matrices, historical simulations, or Monte Carlo simulations etc.
Annexure - 2
(b) Equity positions
This section sets out a minimum capital standard to cover the risk of holding or taking positions in equities by the PDs. It applies to long and short positions in all instruments that exhibit market behavior similar to equities, but not to non-convertible preference shares (which will be covered by the interest rate risk requirements described in Section B). Long and short positions in the same issue may be reported on a net basis. The instruments covered include equity shares, convertible securities that behave like equities, and commitments to buy or sell equity securities.
As with debt securities, the minimum capital standard for equities is expressed in terms of two separately calculated charges for the "credit risk’’ and for the "general market risk’’ of holding a position in equity as indicated in Sections A and B. For the purposes of market risk, the equity holdings should be included in the duration ladder with the maximum sensitivity i.e. below 1 month.
Annexure - 3
Interest rate contracts (derivatives)
The measurement system should include all interest rate derivatives and off-balance-sheet instruments in the portfolio, which react to changes in interest rates, [viz. forward rate agreements (FRAs), interest rate swaps (IRS)]. A summary of the rules for dealing with interest rate derivatives is set out below.
Calculation of positions
The derivatives should be converted into positions in the relevant underlying and become subject to market risk charges as described above. The amounts reported should be the market value of the principal amount of the underlying or of the notional underlying.
Forward Rate Agreements
These instruments are treated as a combination of a long and a short position in a notional Government security. The maturity of a future or a FRA will be the period until delivery or exercise of the contract, plus – where applicable – the life of the underlying instrument. For example, a long position in a June three-month interest rate future (taken in April) is to be reported as a long position in a Government security with a maturity of five months and a short position in a Government security with a maturity of two months. Where a range of deliverable instruments may be delivered to fulfil the contract, the PD has flexibility to elect which deliverable security goes into the duration ladder.
Interest Rate Swaps
Swaps will be treated as two notional positions in Government securities with relevant maturities. For example, an interest rate swap under which a PD is receiving floating rate interest and paying fixed will be treated as a long position in a floating rate instrument of maturity equivalent to the period until the next interest fixing and a short position in a fixed-rate instrument of maturity equivalent to the residual life of the swap. For swaps that pay or receive a fixed or floating interest rate against some other reference price, the interest rate and the reference rate components should be slotted into the appropriate repricing duration category, relevant for that component.
Allowable offsetting of matched positions
PDs may exclude from the interest rate maturity framework, long and short positions (both actual and notional) in identical instruments with exactly the same issuer, coupon, currency and maturity. In addition, opposite positions in the same category of instruments can in certain circumstances be regarded as matched and allowed to offset fully. To qualify for this treatment the positions must relate to the same underlying instruments, and be of the same nominal value. In addition, for Swaps and FRAs: the reference rate (for floating rate positions) must be identical and the coupon closely matched (i.e. within 15 basis points); and the next interest fixing date or, for fixed coupon positions, the residual maturity must correspond within the following limits:
. less than one month hence: same day;
. between one month and one year hence: within seven days;
. over one year hence: within thirty days.
PDs with large swap books may use alternative formulae for these swaps to calculate the positions to be included in the duration ladder. One method would be to first convert the payments required by the swap into their present values. For that purpose, each payment should be discounted using/building zero coupon yields, and a single net figure for the present value of the cash flows entered into the appropriate time-band using procedures that apply to zero (or low) coupon bonds; these figures should be slotted into the general market risk framework as set out earlier. Another method would be to calculate the sensitivity of the net present value implied by the change in yield used in the duration method and allocate these sensitivities into the time-bands set out in Table 1 to Annexure – 1(a).
Attachment I
Criteria for Tier – III Capital
The principal form of eligible capital to cover market risk consists of shareholders’ and retained earnings (Tier I Capital) and supplementary capital (Tier II Capital) as defined in the Note. But PDs may also employ a third tier of capital ("Tier III"), consisting of short-term subordinated debt as defined in paragraph 2 below for the sole purpose of meeting a portion of the capital requirements for market risks, subject to the following conditions:
- PDs will be entitled to use Tier III Capital solely to support market risks as defined in Section B. This means that any capital requirement arising in respect of credit and counter party risk, including the credit counter party risk in respect of derivatives etc. in terms of Section A (b) of the Note, need to be met by the Tier I and II Capital only;
- Tier III Capital will be limited to 250% of a PD’s Tier I Capital that is required to support market risks i.e. surplus after meeting the credit and counter party risk capital requirements;
- in case a PD is having surplus Tier II Capital elements, they may be substituted for Tier III up to the same limit of 250% subject to the limitations that - eligible Tier II Capital may not exceed total Tier I Capital, and long-term subordinated debt may not exceed 50% of Tier I Capital (long-term subordinated debt with a minimum original term to maturity of over five years will continue to be part of Tier II Capital);
- the sum total of Tier II plus Tier III Capital should not exceed total Tier I Capital.
2. For short-term subordinated debt to be eligible as Tier III Capital, it needs, if circumstances demand, to be capable of becoming part of PD’s permanent capital and that be available to absorb losses in the event of insolvency. It must, therefore, at a minimum;
- be unsecured, subordinated and fully paid up;
- have an original maturity of at least two years;
- not be repayable before the agreed repayment date unless the RBI agrees;
- be subject to a lock-in clause that neither interest nor principal may be paid (even at maturity) if such payment means that the PD falls below or remains below its minimum capital requirement.
3. In calculating eligible capital, it will be necessary first to calculate the PD’s minimum capital requirement for credit risk, and only afterwards its market risk requirement, to establish how much Tier I and Tier II Capital is available to support market risk. Tier III Capital will be regarded as eligible only if it can be used to support market risks under the conditions set out in paragraphs 1 and 2 above. Excess, as unused but eligible Tier III Capital, which is not at present supporting market risks, may be reported separately.
Attachment II
Criteria for use of internal model to measure market risk capital charge
A. General criteria
- The use of an internal model will be conditional upon the explicit approval of the Reserve Bank.
- RBI will only give its approval if, at a minimum, it is satisfied that:
- the PD's risk management system is conceptually sound and its implementation is certified by external auditors;
- the PD has, in the RBI’s view, sufficient numbers of staff skilled in the use of sophisticated models not only in the trading area but also in the risk control, audit, and back office areas;
- the PD has, in the RBI’s judgement, a proven track record of reasonable accuracy in measuring risk (back testing);
- the PD regularly conducted stress tests along the lines discussed in Para B.4 below
- RBI has the right to insist on a period of initial monitoring of the live testing of a PD’s internal model before it is used for capital charge purposes.
- In addition to these general criteria, PDs using internal models for capital purposes will be subject to the requirements detailed in Sections B.1 to B.5 below.
B.1 Qualitative standards
The extent to which PDs meet the qualitative criteria contained herein will influence the level at which the RBI will ultimately set the multiplication factor referred to in Section B.3 (h) below, for the PD. Only those PDs, whose models are in full compliance with the qualitative criteria, will be eligible for use of the minimum multiplication factor. The qualitative criteria include:
- The PD should have an independent risk control unit that is responsible for the design and implementation of the system. The unit should produce and analyse daily reports on the output of the PD's risk measurement model, including an evaluation of the relationship between measures of risk exposure and trading limits. This unit must be independent from trading desks and should report directly to senior management of the PD.
- The unit should conduct a regular back testing programme, i.e. an ex-post comparison of the risk measure generated by the model against actual daily changes in portfolio value over longer periods of time, as well as hypothetical changes based on static positions.
- Board of Directors and senior management should be actively involved in the risk control process and must regard risk control as an essential aspect of the business to which significant resources need to be devoted. In this regard, the daily reports prepared by the independent risk control unit must be reviewed by a level of management with sufficient seniority and authority to enforce both reductions in positions taken by individual traders and reductions in the PD’s overall risk exposure.
- The PD’s internal risk measurement model must be closely integrated into the day-to-day risk management process of the institution. Its output should accordingly be an integral part of the process of planning, monitoring and controlling the PD’s market risk profile.
- The risk measurement system should be used in conjunction with internal trading and exposure limits. In this regard, trading limits should be related to the PD’s risk measurement model in a manner that is consistent over time and that it is well-understood by both traders and senior management.
- A routine and rigorous programme of stress testing should be in place as a supplement to the risk analysis based on the day-to-day output of the PD’s risk measurement model. The results of stress testing should be reviewed periodically by senior management and should be reflected in the policies and limits set by management and the Board of Directors. Where stress tests reveal particular vulnerability to a given set of circumstances, prompt steps should be taken to manage those risks appropriately.
- PDs should have a routine in place for ensuring compliance with a documented set of internal policies, controls and procedures concerning the operation of the risk measurement system. The risk measurement system must be well documented, for example, through a manual that describes the basic principles of the risk management system and that provides an explanation of the empirical techniques used to measure market risk.
- An independent review of the risk measurement system should be carried out regularly in the PD’s own internal auditing process. This review should include both the activities of the trading desks and of the risk control unit. A review of the overall risk management process should take place at regular intervals (ideally not less than once a year) and should specifically address, at a minimum:
- . the adequacy of the documentation of the risk management system and process;
- . the organisation of the risk control unit ;
- . the integration of market risk measures into daily risk management;
- . the approval process for risk pricing models and valuation systems used by front and back-office personnel;
- . the validation of any significant change in the risk measurement process;
- . the scope of market risks captured by the risk measurement model;
- . the integrity of the management information system;
- . the accuracy and completeness of position data;
- . the verification of the consistency, timeliness and reliability of data sources used to run internal models, including the independence of such data sources;
- . the accuracy and appropriateness of volatility and other assumptions;
- . the accuracy of valuation and risk transformation calculations;
- . the verification of the model's accuracy through frequent back testing as described in (b) above and in the Attachment III.
- The integrity and implementation of the risk management system in accordance with the system policies/procedures laid down by the Board of Directors should be certified by the external auditors as outlined at Para B.5.
- A copy of the back testing result should be furnished to RBI.
B.2 Specification of market risk factors
An important part of a PD’s internal market risk measurement system is the specification of an appropriate set of market risk factors, i.e. the market rates and prices that affect the value of the PD’s trading positions. The risk factors contained in a market risk measurement system should be sufficient to capture the risks inherent in all the PD’s portfolio of on-and-off-balance sheet positions. The following guidelines should be kept in view:
- For interest rates, there must be a set of risk factors corresponding to interest rates in each portfolio in which the PD has interest-rate-sensitive on-or-off-balance sheet positions.
- For equity prices, at a minimum, there should be a risk factor that is designed to capture market-wide movements in equity prices (e.g. a market index). Position in individual securities or in sector indices could be expressed in "beta-equivalents" relative to this market-wide index. More detailed approach would be to have risk factors corresponding to various sectors of the equity market (for instance, industry sectors or cyclical and non-sectors), or the most extensive approach, wherein, risk factors corresponding to the volatility of individual equity issues are assessed. The method could be decided by the PDs corresponding to their exposure to the equity market and concentrations.
The risk measurement system should model the yield curve using one of a number of generally accepted approaches, for example, by estimating forward rates of zero coupon yields. The yield curve should be divided into various maturity segments in order to capture variation in the volatility of rates along the yield curve. For material exposures to interest rate movements in the major instruments, PDs must model the yield curve using all material risk factors, driven by the nature of the PD’s trading strategies. For instance, a PD with a portfolio of various types of securities across many points of the yield curve and that engages in complex arbitrage strategies, would require a greater number of risk factors to capture interest rate risk accurately.
The risk measurement system must incorporate separate risk factors to capture spread risk (e.g. between bonds and swaps), i.e. risk arising from less than perfectly correlated movements between Government and other fixed-income instruments.
B.3. Quantitative standards
- PDs should update their data sets at least once every three months and should also reassess them whenever market prices are subject to material changes. RBI may also require a PD to calculate their value-at-risk using a shorter observation period if, in it’s judgement, this is justified by a significant upsurge in price volatility.
- The multiplication factor will be set by RBI on the basis of the assessment of the quality of the PD’s risk management system, as also the back testing framework and results, subject to an absolute minimum of 3. The document `Back testing’ mechanism to be used in conjunction with the internal risk based model for market risk capital charge’, enclosed as Attachment III, presents in detail the back testing mechanism.
PDs will have flexibility in devising the precise nature of their models, but the parameters indicated at Annexure-1(b) are the minimum which the PDs need to fulfil for acceptance of the model for the purpose of calculating their capital charge. RBI will have the discretion to apply stricter standards.
B.4 Stress testing
1. PDs that use the internal models approach for meeting market risk capital requirements must have in place a rigorous and comprehensive stress testing program to identify events or influences that could greatly impact them.
2. PD’s stress scenarios need to cover a range of factors than can create extraordinary losses or gain in trading portfolios, or make the control of risk in those portfolios very difficult. These factors include low-probability events in all major types of risks, including the various components of market, credit and operational risks.
3. PD’s stress test should be both of a quantitative and qualitative nature, incorporating both market risk and liquidity aspects of market disturbances. Quantitative criteria should identify plausible stress scenarios to which PDs could be exposed. Qualitative criteria should emphasize that two major goals of stress testing are to evaluate the capacity of the PD’s capital to absorb potential large losses and to identify steps the PD can take to reduce its risk and conserve capital. This assessment is integral to setting and evaluating the PD’s management strategy and the results of stress testing should be routinely communicated to senior management and, periodically, to the PD’s Board of Directors.
4. PDs should combine the standard stress scenarios with stress tests developed by PDs themselves to reflect their specific risk characteristics. Specifically, RBI may ask PDs to provide information on stress testing in three broad areas, which are discussed in turn below.
(a) Scenarios requiring no simulations by the PD.
5. PDs should have information on the largest losses experienced during the reporting period available for RBI’s review. This loss information could be compared to the level of capital that results from a PD’s internal measurement system. For example, it could provide RBI with a picture of how many days of peak day losses would have been covered by a given Value-at-Risk estimate.
(b) Scenarios requiring a simulation by the PD.
6. PDs should subject their portfolios to a series of simulated stress scenarios and provide RBI with the results. These scenarios could include testing the current portfolio against past periods of significant disturbance, for example, the January 1998 volatility incorporating both the large price movements and the sharp reduction in liquidity associated with these events. A second type of scenario would evaluate the sensitivity of the PD’s market risk exposure to changes in the assumptions about volatilities and correlations. Applying this test would require an evaluation of the historical range of variation for volatilities and correlations and evaluation of the PD’s current positions against the extreme values of the historical range. Due consideration should be given to the sharp variation that at times has occurred in a matter of days in periods of significant market disturbance.
(c) Scenarios developed by the PD itself to capture the specific characteristics of its portfolio
7. In addition to the scenarios prescribed by RBI under (a) and (b) above, a PD should also develop its own stress tests which it identified as most adverse based on the characteristics of its portfolio. PDs should provide RBI with a description of the methodology used to identify and carry out the scenarios, as well as with a description of the results derived from these scenarios.
8. The results should be reviewed periodically by senior management and should be reflected in the policies and limits set by management and the Board of Directors. Moreover, if the testing reveals particular vulnerability to a given set of circumstances, RBI would expect the PD to take prompt steps to manage those risks appropriately (e.g. by reducing the size of its exposures).
B.5 External Validation
PDs should get the internal model’s accuracy validated by external auditors, including at a minimum, the following:
- verifying that the internal validation processes described in B.1(h) are operating in a satisfactory manner;
- ensuring that the formulae used in the calculation process as well as for the pricing of complex instruments are validated by a qualified unit, which in all cases should be independent from the trading desks;
- Checking that the structure of internal models is adequate with respect to the PD’s activities and geographical coverage;
- Checking the results of the PD’s back testing of its internal measurement system (i.e. comparing Value-at-Risk estimates with actual profits and losses) to ensure that the model provides a reliable measure of potential losses over time. PDs should make the results as well as the underlying inputs to their value-at-risk calculations available to the external auditors;
- Making sure that data flows and processes associated with the risk measurement system are transparent and accessible. In particular, it is necessary that auditors are in a position to have easy access, wherever they judge it necessary and under appropriate procedures, to the models’ specifications and parameters.
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Attachment III
"BACK TESTING" mechanism to be used in conjunction with the internal risk based model for market risk capital charge
The following are the parameters of the back testing framework for incorporating into the internal models approach to market risk capital requirements.
Primary Dealers that have adopted an internal model-based approach to market risk measurement are required routinely to compare daily profits and losses with model-generated risk measures to gauge the quality and accuracy of the their risk measurement systems. This process is known as "back testing".
The objective of the back testing efforts is the comparison of actual trading results with model-generated risk measures. If the comparison uncovers sufficient differences, problems almost certainly must exist, either with the model or with the assumptions of the back test.
II. Description of the back testing framework
The back testing program consists of a periodic comparison of the Primary Dealer’s daily Value-at-Risk measures with the subsequent daily profit or loss ("trading outcome"). The Value-at-Risk measures are intended to be larger than all but a certain fraction of the trading outcomes, where that fraction is determined by the confidence level of the Value-at-Risk measure. Comparing the risk measures with the trading outcomes simply means that the Primary Dealer counts the number of times that the risk measures were larger than the trading outcome. The fraction actually covered can then be compared with the intended level of coverage to gauge the performance of the Primary Dealer’s risk model.
Under the Value-at-Risk framework, the risk measure is an estimate of the amount that could be lost on a set of positions due to general market movements over a given holding period, measured using a specified confidence level.
The back tests to be applied compare whether the observed percentage of outcomes covered by the risk measure is consistent with a 99% level of confidence. That is, they attempt to determine if a PD’s 99th percentile risk measures truly cover 99% of the firm’s trading outcomes.
i) Significant changes in portfolio composition relative to the initial positions are common at trading day end. For this reason, the back testing framework suggested involves the use of risk measures calibrated to a one-day holding period.
A more sophisticated approach would involve a detailed attribution of income by source, including fees, spreads, market movements, and intra-day trading results.
Primary Dealers should perform back tests based on the hypothetical changes in portfolio value that would occur were end-of-day positions to remain unchanged.
ii) Back testing using actual daily profits and losses is also a useful exercise since it can uncover cases where the risk measures are not accurately capturing trading volatility in spite of being calculated with integrity.
Primary Dealers should perform back tests using both hypothetical and actual trading outcomes. The steps involve calculation of the number of times that the trading outcomes are not covered by the risk measures ("exceptions"). For example, over 200 trading days, a 99% daily risk measure should cover, on average, 198 of the 200 trading outcomes, leaving two exceptions.
The back testing framework to be applied entails a formal testing and accounting of exceptions on a quarterly basis using the most recent twelve months of date. Primary Dealers may however base the back test on as many observations as possible. Nevertheless, the most recent 250 trading days' observations should be used for the purposes of back testing. The usage of the number of exceptions as the primary reference point in the back testing process is the simplicity and straightforwardness of this approach.
Normally, in view of the 99% confidence level adopted, a lever of 4 exceptions in the observation period of 250 days would be acceptable to consider the model as accurate. Exceptions above this, would invite supervisory actions. Depending on the number of exceptions generated by the Primary Dealer’s back testing model, both actual as well as hypothetical, RBI may initiate a dialogue regarding the Primary Dealer’s model, enhance the multiplication factor, may impose an increase in the capital requirement or disallow use of the model as indicated above depending on the number of exceptions.
In case large number of exceptions are being noticed, it may be useful for the PDs to dis-aggregate their activities into sub sectors in order to identify the large exceptions on their own. The reasons could be of the following categories:
Basic integrity of the model
- The PD’s systems simply are not capturing the risk of the positions themselves (e.g. the positions of an office are being reported incorrectly).
- Model volatilities and/or correlations were calculated incorrectly (e.g. the computer is dividing by 250 when it should be dividing by 225).
- The risk measurement model is not assessing the risk of some instruments with sufficient precision (e.g. too few maturity buckets or an omitted spread).
- Random chance (a very low probability event).
- Markets moved by more than the model predicted was likely (i.e. volatility was significantly higher than expected).
- Markets did not move together as expected (i.e. correlations were significantly different than what was assumed by the model).
- There was a large (and money-losing) change in the PD’s positions or some other income event between the end of the first day (when the risk estimate was calculated) and the end of the second day (when trading results were tabulated).
Model’s accuracy could be improved
Bad luck or markets moved in fashion unanticipated by the model
Intra-day trading
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