Overview EU-wide Stress Test 2014 Mario Quagliariello – Head of the Risk Analysis Unit
23/05/2014 - Executive Banking Briefing - Athens
Agenda 1
Context
2
Key features
3
Quantification of different risk types
4
Process and time line
2
Supervisory stress testing in the EU 2014: Where are we? EU-wide stress test 2011 Pre-emptive capital raising Credit sensitivities Disclosure (capital and sovereign)
EU-wide recapitalisation
9% after sovereign buffer EUR 204bn capital raised CT1 ratio comparable to US EU CT1 sufficient if RWA can be trusted
EU-wide stress test 2014
AQRs EBA recommendation Common definition of NPL CAs responsibility PIT assessment of capital to recapitalise
Forward looking assessment and reaction function
Focus today
RWA consistency Ongoing, leading to supervisory consistency, transparency and benchmarking 3
3. EBA stress testing – towards 2014 EBA Core Tier 1 capital ratio dispersion measures (median, average, interquartile range, 5th and 95th percentiles)
Motivation: Multi country – multi institution Motivation
Components of EU-wide stress test
Comprehensive, consistent and relevant scenario
Microeconomic perspective Assessing cross border groups Why?
Comparability across markets
Tools
Macroeconomic perspective Concentrations and correlations
Constrained bottom-up methodology (key features, risk quantification, templates)
Systemic shocks Transparency
Detailed disclosure to inform supervisors and market participants
Consistent, relevant and efficient EU-wide stress test What?
124 consolidated banks, 28 jurisdictions, 80% of total assets in the EU
Cooperation
Cooperation amongst supervisors and other involved parties
5
The suite of stress tests
Type
Aim
Use System-wide microprudential stress tests
Firms
Firms own stress testing
Risk analysis
Supervisors
Micro prudential stress tests under pillars 1 and 2
bank-by-bank information on risks and vulnerabilities
Supervisory analysis; early warning tools
Macro economic stress tests;
Aggregated information on systemic risks and vulnerabilities
Systemic stability, economic policy implications
Macro prudential authorities
System-wide macro prudential stress tests
Banks’ risk management
•Hybrid in methods and aims; multiple use •Focused on sample bottom up stress test •Focused on sample top down stress tests •Focused on comparability
6
Agenda 1
Context
2
Key features
3
Quantification of different risk types
4
Process and time line
7
Overview key features (1/2) Consolidation
Scenario
Time-horizon and reference date
Capital
• Highest level of consolidation • Perimeter of the banking group as defined by the CRD/CRR
• Common baseline and adverse macro-economic scenarios and stressed market parameters for positions sensitive to a change of market prices • CAs may develop additional sensitivities to incorporate country specific features
• Consolidated year-end 2013 figures • Scenarios applied over a period of three years (from 2014 to 2016)
• CET1, with transitional arrangements; CoCos reported if trigger is above the bank’s CET1 ratio in the adverse scenario • CAs may, in addition, assess the impact of the stress test on other yardsticks • Prudential filters are discretion of CAs; conditions for common approach assessed
8
Overview key features (2/2) Hurdle rate
• 8% Common Equity Tier 1 ratio for the baseline scenario • 5.5% Common Equity Tier 1 ratio for the adverse scenario • CA may calibrate possible supervisory measures based on a ladder of intervention points and set higher hurdle rates
Static balance sheet
• Zero growth assumption for baseline and adverse scenario and same business mix • Assets and liabilities that mature replaced with similar financial instruments in terms of type, credit quality and original maturity; no workout of defaulted assets • Exemption due to mandatory restructuring plans announced before reference date
Risk coverage
• Solvency stress test – credit risk, market risk, sovereign risk, securitisation, cost of funding, non-interest income and costs, operational risk; no liquidity stress test • CAs may include additional risks but results reported under common approach
Process
• EBA responsible for common methodology, templates, disclosure • Competent authorities responsible for quality assurance and reaction function • Outcome of AQR may inform starting point
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Agenda 1
Context
2
Key features
3
Quantification of different risk types
4
Process and time line
10
Overview credit risk methodology Scope
• All assets in the banking book which are exposed to credit risk including counterparty credit risk, on and off-balance sheet positions, IRB and STA portfolios • Methodology also applied to IRC
Methodology
• Stressed point-in-time PD and point-in-time LGD for provisioning • Potential rating migration and stressed IRB regulatory parameters for RWA
Impact on P&L
• Expected loss based on point-in-time parameters used to calculate credit risk losses on performing portfolio • Additional losses on defaulted portfolio based on worsening LGDs and portfolio characteristics
Impact of RWA
• Stressed RWA in IRB and STA, including RWA for defaulted assets and IRB excess or shortfall • RWA floored at 2013 levels
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Overview market risk methodology Scope
• All financial assets and liabilities assessed at fair value (positions in HfT, AfS and designated at fair value through profit and loss portfolios) • Hedge accounting portfolios • Securitisations held at fair value
Methodology
• Simplified: bank-specific reduction in NTI based on historical variation • Comprehensive: full revaluation of positions based on market risk parameters • CVA haircuts for OTC derivatives • Default of largest counterparty (excl. CCP, market infrastructure, sovereign)
Impact on P&L
• Reduction in NTI or other comprehensive income impact due to fair value variation; loss from default of largest counterparty; loss from CVA haircuts • Valuation adjustments on debt securities and P&L gains resulting from credit spread widening of own liabilities cannot be taken into account
Impact of RWA
• RWA increase for VaR, SVaR and CRM capital charges due to predefined assumptions (constant RWA for banks using simplified approach; VaR replaced by SVaR for banks using comprehensive approach, fixed scaling for CRM) • IRC and CVA increase due to worsened risk parameters
12
Overview securitisation risk methodology Scope
• Securitisation and re-securitisation positions assessed at fair value (HfT, AfS, designated at fair value through profit and loss) and amortised cost positions
Methodology
• Increase of RWA depending on risk profile of the positions (three risk buckets) • Impairment estimates for positions not held for trading • Application of market risk methodology for fair value positions
Impact on P&L
• Impairments for securitisation positions not held for trading • Mark-to-market treatment for positions at fair value in line with market risk methodology
Impact of RWA
• RWA increase for all securitisation positions based on pre-defined risk buckets
13
Overview cost of funding and interest income
Scope
• Interest bearing assets and liabilities
Methodology
• Sensitivity analysis of the P&L effect for deterioration in wholesale funding markets and a significant increase in retail funding costs • Banks’ own estimates but subject to constraints • Asymmetric pass-through • LTRO replaced with MRO
Impact on P&L
• Increase of cost of funding partially mitigated by an increase in interest income
Impact of RWA
• N/A
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Overview sovereign risk methodology Scope
• Sovereign exposures (direct debt exposures as well as indirect exposures to central and local governments) • Assessed at fair value (HfT, AfS, fair value through profit and loss) and amortised cost positions
Methodology
• All fair value positions: application of market risk methodology for impact of changes in market prices • Regulatory banking book positions: application of credit risk methodology for impairment estimates based on rating migration defined by ESRB/ECB
Impact on P&L
• Direct P&L impact for positions accounted for at fair value (with AFS prudential filters phased out 20/40/60%) • Further impairment estimates for regulatory banking book assets
Impact of RWA
• RWA increase due to worsened risk parameters in IRB and STA
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Agenda 1
Context
2
Key features
3
Quantification of different risk types
4
Process and time line
16
Overview responsibilities Common methodology, templates Data hub for final dissemination
European Systemic Risk Board European Commission
•
Common scenario (in cooperation with ECB, NCAs)
28 Nations, 28 National Supervisory Authorities and ECB
• •
Responsibility for the quality assurance Assessment of the reliability and robustness of banks’ assumptions, data, estimates and results Definition and communication of any additional sensitivities Supervisory reaction function
Non-SSM National Competent Authorities
SSM ECB, National Competent Authorities
• •
Joint work and information sharing
• •
European Banking Authority
124 banks in 2014 EU-wide stress test • 20 Non-SSM banks
104 SSM banks
Calculation of bottom-up stress test results
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Tentative time line April
Preparation
Calculation
May
June
July
August
September
October
Finalisation methodology, templates, scenario
Advance data collection
Iteration with banks
ST calculation by banks
Disclosure
Disclosure preparation
29/04/14 Publication methodology, templates, scenario
Workshop with banks
Submission first results to EBA via CAs
EBA feedback on results to CAs
Publication of results
Milestones Publication ECB benchmarks
Submission close-tofinal results to EBA
18
Overview disclosure P&L
• Main P&L items like net interest income, net trading income, impairments for financial assets and other comprehensive income
Credit risk
• Exposure, RWA, value adjustments and provisions, default and loss rates • No disclosure of credit risk parameter
Market risk
• Market risk position by main risk types
Securitisation
Sovereign
RWA
Capital
• Securitisation exposure, RWA and impairments
• Sovereign exposure by country, maturity and accounting treatment
• RWA by risk type • Capital position, components and adequacy including stressed solvency ratios • Capital restructuring 19
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