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Basel II: Significant progress on major issues

Type
Publication
Series
Consultative
Date Published
11 October 2003
Status
Closed
Sources
BCBS
Topics
Credit risk

On 10-11 October 2003, the members of the Basel Committee on Banking Supervision (the "Committee") met in Madrid to decide on responses to public comments received on the New Basel Capital Accord.

Next steps in the New Basel Capital Accord

The Committee is pleased to have received over 200 comments on its Third Consultative Paper ("CP3"), which can be found on the website of the Bank for International Settlements. The responses indicate that there is continued broad support for the structure of the New Accord and agreement on the need to adopt a more risk-sensitive capital framework.

All members of the Committee agreed on the importance of finalising the New Accord expeditiously and in a manner that is technically and prudentially sound. Such an Accord should offer considerable benefits over the existing system. Moreover, it is important in the near term to provide banks with as much certainty as possible while they plan and prepare for the adoption of the new rules. Committee members committed to work promptly to resolve the outstanding issues by no later than mid-year 2004.

The Committee also acknowledges the importance of national rule-making processes underway in several jurisdictions and that it will need to consider the outcome of these national processes within this timeframe.

The Committee welcomes the efforts of banks in preparing for implementation and encourages them to continue. The ongoing further discussions by the Committee as outlined in this press release are not expected to alter the need for banks to continue improving databases and risk management systems in preparation for the New Accord.

Areas of focus

The principal areas in which the Committee has identified opportunities to improve the framework include the following:

  • changing the overall treatment of expected versus unexpected credit losses;
  • simplifying the treatment of asset securitisation, including eliminating the "Supervisory Formula" and replacing it by a less complex approach;
  • revisiting the treatment of credit card commitments and related issues; and
  • revisiting the treatment of certain credit risk mitigation techniques.

The Committee and its working groups have developed a plan for concluding these issues.

Treatment of expected and unexpected losses

With respect to the internal ratings-based ("IRB") treatment of credit losses, the existing proposals called for banks to hold enough capital to absorb expected and unexpected credit losses with a particular treatment for provisions. Committee members recognise that this approach represented a practical compromise to address differences in national accounting practices and supervisory authority regarding provisioning. However, in the light of the public comments received on CP3 and subsequent research undertaken by its working groups, the Committee decided to revisit the issue and to adopt an approach based on unexpected losses.

The broad direction of the approach that the Committee has directed its working groups to develop further is described in the attachment to this press release. The Committee invites interested parties to comment on this proposal by year-end 2003. Although the Committee does not believe that this proposal would change substantially the mechanics of the New Accord, from a conceptual point of view, the Committee considers it sufficiently important to merit additional public consideration.

At this time, the Committee does not foresee the need for changes to the standardised approach.

At the Committee's January 2004 meeting, it will evaluate the outcome of the consultation on the expected/unexpected loss issue, assess further related work on the calibration of the IRB approach, and review the progress made in resolving the other technical issues mentioned above. It will also assess related work on the calibration of the IRB approach in light of the Committee's objectives on overall capital. At that time, the Committee will provide a further update on the status of its discussions.

Calibration of the New Accord

The Committee also discussed the importance of ensuring that the calibration of the New Accord achieves the Committee's objectives. Accordingly, the Committee agreed that prior to implementation, a further review of the calibration of the New Accord will be conducted on the basis of additional information, for example, further impact assessments that are planned in some jurisdictions and the monitoring of banks' parallel calculations. If necessary, the Committee will propose additional adjustments to the calibration of the New Accord based on this review. These adjustments are not expected to alter the fundamental structure of the New Accord.

Implementation efforts

The Committee notes that it has intensified its efforts to facilitate implementation of the New Accord. In August 2003, the Committee published a set of principles for the cross-border application of the New Accord to promote closer practical co-operation and information exchange among supervisors. The Accord Implementation Group ("AIG"), which was established to promote consistency through the exchange of information between supervisors on approaches to implementation, is accelerating its work. The AIG's work also includes home-host implementation issues associated with the advanced approaches to operational risk.

Appointment of a new Secretary General

Upon the completion of Madame Danièle Nouy's term as Secretary General of the Basel Committee, the Committee has named Mr Ryozo Himino of the Japanese Financial Services Agency as the new Secretary General. He will assume his new duties on 1 November 2003. The Secretariat is hosted by the Bank for International Settlements in Basel, Switzerland, and provides technical and administrative support to the Committee and its working groups.

At their meeting in Madrid, Committee members expressed their great appreciation for Madame Nouy's service to the Committee, which spans seven years, and her stewardship of the negotiation process for the New Accord as Secretary General.


Attachment

Proposed Treatment of Expected and Unexpected Losses

On the basis of its public consultation process, the Basel Committee is convinced that a major improvement in the New Accord is possible in relation to the treatment of expected losses. This note summarises the conclusions that the Committee has reached in this regard. In light of the value that the Committee places on transparency and public consultation, as well as important implications of these decisions, the Committee is requesting public comment on this proposed modification to its framework by 31 December 2003.

The internal ratings-based ("IRB") approach produces a statistical measurement of both the unexpected losses and the expected losses that banks face in relation to their credit risk exposures. The Third Consultative Paper's ("CP3") framework incorporated both expected and unexpected loss components into the IRB capital requirement.

The Committee now believes that a separation of the treatment of unexpected and expected losses within the IRB approach would lead to a superior and more consistent framework. Under this modified approach, the measurement of risk-weighted assets (that is, the IRB capital requirement) would be based solely on the unexpected loss portion of the IRB calculations. Accordingly, certain offsets within the IRB framework, in particular future margin income, would no longer be necessary.

Importantly, however, the Committee believes that it is critical to put into place a separate treatment of expected losses with the objective of ensuring strong incentives for banks to provision properly against expected losses. Under this separate treatment, banks will compare the IRB measurement of expected losses with the total amount of provisions that they have made, including both general and specific provisions. For any individual bank, this comparison will produce a "shortfall" if the expected loss amount exceeds the total provision amount, or an "excess" if the total provision amount exceeds the expected loss amount.

The Committee is proposing that shortfall amounts, if any, be deducted from capital. This deduction would be taken 50% from Tier One capital and 50% from Tier Two capital, in line with other deductions from capital included in the New Accord.

Excess provision amounts, if any, are proposed to be eligible as an element of Tier Two capital, similar to the current treatment of general provisions. The Tier Two eligibility of such excess amounts is further proposed to be subject to limitation at supervisory discretion, but in no case would be allowed to exceed 20% of Tier Two capital of a bank. In proposing this treatment, the Committee recognises that banks may have valid reasons for setting provisions in excess of the expected loss amount calculated by the IRB approach and wishes to avoid discouraging banks from doing so where appropriate.

This treatment of shortfall and excess amounts would be in lieu of the current inclusion of general provisions in Tier Two capital.

It is important to note that the incorporation of this new approach into the IRB framework may require some re-calibration of that framework to ensure that the overall impact of its proposals is consistent with the Committee's objectives. The Committee is undertaking further efforts to identify where such adjustments may be needed.

Although the Committee does not believe that adjustments to the standardised approach to credit risk are necessary in conjunction with this proposal, the Committee welcomes comments on this issue.

The Committee invites interested parties to provide comment on all aspects of this specific proposal by 31 December 2003 to relevant national supervisory authorities and central banks and may also be sent to the Basel Committee on Banking Supervision at the Bank for International Settlements, CH-4002, Basel, Switzerland. Comments are also invited by e-mail: BCBS.Capital@bis.org or by fax: +41 61 280 9100, and should be directed to the attention of the Basel Committee Secretariat.


Comments received

The Committee wishes to thank those who have taken the time and effort to express their views on the above consultation. The comments received are available in PDF format below.

Allen, M and Sharifi, S PDF: 4 pages, 44 KB
America's Community Bankers PDF: 7 pages, 149 KB
Aon Professional Risks Scanned PDF: 3 pages, 144 KB
Appraisal Institute PDF: 3 pages, 90 KB
Asian Bankers Association Scanned PDF: 10 pages, 3370 KB
Assifact PDF: 25 pages, 290 KB
Assilea PDF: 5 pages, 230 KB
Assocation Française des Sociétés Financiers PDF: 30 pages, 537 KB
Association of Supervisors of Banks of the Americas Scanned PDF: 6 pages, 294 KB
Associazione Bancaria Italiana Scanned PDF: 57 pages, 269 KB
Australia and New Zealand Banking Group PDF: 27 pages, 215 KB
Austrian Authorities PDF: 11 pages, 116 KB
Aviation Working Group Scanned PDF: 2 pages, 102 KB
Bahamas Central Bank Scanned PDF: 7 pages, 1829 KB
Banco Centroamericano de Integracion Economica Scanned PDF: 2 pages, 94 KB
Banco de Mexico PDF: 9 pages, 235 KB
Banco de Portugal PDF: 3 pages, 74 KB
Bank Leumi Israel PDF: 1 page, 55 KB
Bank Negara Malaysia Scanned PDF: 5 pages, 175 KB
Bank of America Scanned PDF: 10 pages, 3307 KB
Bank of Guyana PDF: 2 pages, 89 KB
Bank of Jamaica Scanned PDF: 13 pages, 545 KB
Bank of Thailand Scanned PDF: 7 pages, 371 KB
Bank One Corporation PDF: 7 pages, 183 KB
Bank Van de Nederlandse Antillen Scanned PDF: 5 pages, 209 KB
Bankenfachverband PDF: 49 pages, 562 KB
Bankers Association for Finance and Trade PDF: 2 pages, 114 KB
Bankers Association of the Republic of China PDF: 2 pages, 58 KB
Banking Regulation and Supervision Agency of Turkey PDF: 10 pages, 177 KB
Barclays Group PDF: 3 pages, 41 KB
Bayerische Staatsminister fur Wirtschaft, Verkehr und Technologie Scanned PDF: 14 pages, 676 KB
Belgian Bankers Association PDF: 38 pages, 222 KB
Belize Central Bank PDF: 2 pages, 76 KB
BNP Paribas PDF: 34 pages, 326 KB
Bodurtha, J PDF: 1 page, 72 KB
Brazil Central Bank Scanned PDF: 5 pages, 1047 KB
British Virgin Islands Financial Services Commission PDF: 3 pages, 210 KB
Bundesverband der Deutschen Industrie Scanned PDF: 3 pages, 103 KB
Bundesverband deutscher Banken PDF: 14 pages, 706 KB
Bundesverband Investment and Asset Management PDF: 10 pages, 63 KB
Burundi Central Bank PDF: 2 pages, 84 KB
Canadian Bankers Association PDF: 43 pages, 358 KB
Capital One Financial Corporation PDF: 31 pages, 235 KB
Caribbean Group of Bank Supervisors PDF: 13 pages, 133 KB
Central Bank of Barbados PDF: 6 pages, 83 KB
Central Bank of Oman Scanned PDF: 5 pages, 250 KB
Central Bank of the United Arab Emirates Scanned PDF: 2 pages, 80 KB
Central Bank of Trinidad and Tobago PDF: 6 pages, 118 KB
Centre National des Professions Financières Scanned PDF: 7 pages, 352 KB
Chile Superintendent of Banks PDF: 1 page, 54 KB
China Banking Regulation Commission Scanned PDF: 7 pages, 562 KB
Citigroup PDF: 17 pages, 77 KB 22 Aug 03
Commission de Surveillance du Secteur Financier Scanned PDF: 7 pages, 273 KB
Commonwealth Bank Group PDF: 9 pages, 140 KB
Companhia Portuguesa de Rating PDF: 11 pages, 112 KB
Consumer Mortgage Coalition PDF: 4 pages, 119 KB
Corporación Andina de Fomento Scanned PDF: 14 pages, 687 KB
Council of Mortgage Lenders PDF: 3 pages, 13 KB
Credit Suisse Group PDF: 48 pages, 216 KB
Czech National Bank and Czech Banking Association PDF: 15 pages, 97 KB
Danish Bankers Association PDF: 3 pages, 65 KB
Danish FSA PDF: 3 pages, 83 KB
De Lage Landen International BV PDF: 5 pages, 120 KB
Deutscher Industrie und Handelskammertag PDF: 5 pages, 34 KB
Ecuador Superintendency of Banks and Insurance PDF: 13 pages, 168 KB
Embrechts P, Furrer H, and Kaufmann R PDF: 17 pages, 201 KB
Estonian FSA Scanned PDF: 1 page, 40 KB
Eurochambres PDF: 7 pages, 167 KB
Euroclear PDF: 8 pages, 73 KB
European Association of Co-operative Banks PDF: 8 pages, 44 KB
European Central Bank PDF: 13 pages, 64 KB 19 Sep 03
European Institute for International Economics PDF: 11 pages, 237 KB
European Mortgage Federation PDF: 6 pages, 134 KB
European Private Equity and Venture Capital Association Scanned PDF: 7 pages, 275 KB
European Savings Banks Group - World Savings Banks Institute PDF: 7 pages, 146 KB
European Shadow Financial Regulatory Committee Scanned PDF: 4 pages, 246 KB 22 Aug 03
European Union of Housebuilders and Developers PDF: 11 pages, 120 KB
Experian-Scorex PDF: 5 pages, 147 KB
FBE PDF: 63 pages, 693 KB
FEBRABAN PDF: 11 pages, 177 KB
Federation Bancaire Française Scanned PDF: 37 pages, 518 KB
FEFSI PDF: 8 pages, 46 KB
Financial Guardian Group PDF: 27 pages, 100 KB
Financial Services Roundtable PDF: 16 pages, 262 KB
Finnish Authorities PDF: 10 pages, 119 KB
Finnish Bankers' Association PDF: 6 pages, 85 KB
Fitch Ratings PDF: 8 pages, 60 KB
FleetBoston Financial Corporation PDF: 9 pages, 188 KB
Förderungsverein der Primärbanken PDF: 2 pages, 71 KB
Fortis Bank PDF: 12 pages, 297 KB
Gecalux Group Scanned PDF: 2 pages, 108 KB
German Bausparkassen PDF: 5 pages, 116 KB
Goldman Sachs Scanned PDF: 5 pages, 228 KB
Griffith-Jones, S and Spratt, S PDF: 18 pages, 151 KB
Hiroyuki, Ota PDF: 2 pages, 25 KB
Hong Kong Association of Banks PDF: 8 pages, 213 KB
Hungarian authorities PDF: 7 pages, 159 KB
Industrial Bank of Taiwan PDF: 4 pages, 34 KB 19 Sep 03
Inner City Press Scanned PDF: 9 pages, 475 KB
Institut der Wirtschaftsprufer PDF: 7 pages, 68 KB
Institute of Chartered Accountants in England & Wales Scanned PDF: 7 pages, 344 KB
Institute of International Bankers PDF: 11 pages, 41 KB
Institute of International Finance PDF: 48 pages, 146 KB
International Air Transport Association Scanned PDF: 2 pages, 2220 KB
International Monetary Fund Scanned PDF: 7 pages, 366 KB
International Valuation Standards Committee PDF: 3 pages, 330 KB
ISDA-TBMA PDF: 45 pages, 377 KB
Japanese Bankers Association PDF: 21 pages, 295 KB
JP Morgan Chase Scanned PDF: 21 pages, 1362 KB
KeyCorp PDF: 13 pages, 149 KB
KPMG Scanned PDF: 13 pages, 585 KB 19 Sep 03
Kredittilsynet-Norges Bank PDF: 16 pages, 161 KB
Leaseurope PDF: 19 pages, 120 KB
Lehman Brothers Scanned PDF: 9 pages, 464 KB
LIBA and BBA PDF: 20 pages, 270 KB
Linklaters Business Services PDF: 6 pages, 117 KB
Loan Market Association Scanned PDF: 30 pages, 768 KB
Malta Financial Services Authority PDF: 4 pages, 127 KB
Marsh Inc PDF: 12 pages, 78 KB
Massachusetts Bankers Association PDF: 2 pages, 9 KB
Mauritius Banks PDF: 7 pages, 119 KB
MBNA America Bank Scanned PDF: 26 pages, 1598 KB
McHenry Savings Bank PDF: 1 page, 24 KB
Mellon Financial Corporation PDF: 3 pages, 91 KB
Merrill Lynch PDF: 6 pages, 41 KB
Moody's PDF: 4 pages, 169 KB
Mortgage Bankers Association of America PDF: 5 pages, 108 KB
Mortgage Insurance Companies of America PDF: 9 pages, 223 KB
National Association of Home Builders Scanned PDF: 13 pages, 452 KB
National Association of Realtors PDF: 6 pages, 131 KB
National Bank of Slovakia PDF: 3 pages, 93 KB
National Housing Federation PDF: 2 pages, 76 KB
Netherlands Bankers Association PDF: 16 pages, 159 KB
New York Clearing House PDF: 9 pages, 154 KB
New York Foreign Exchange Committee PDF: 5 pages, 164 KB
New York State Banking Department PDF: 8 pages, 112 KB
Norinchukin Bank PDF: 5 pages, 59 KB
Norwegian Financial Services Association Scanned PDF: 3 pages, 167 KB
Norwegian Savings Banks Association PDF: 7 pages, 142 KB
Österreichische Verband der Immobilientreuhänder PDF: 2 pages, 58 KB
PNC Financial Services Group PDF: 8 pages, 36 KB
Polish Banking Supervisory Authority PDF: 5 pages, 110 KB
Raiffeisen Bankengruppe - Austria PDF: 19 pages, 110 KB
Rating and Investment Information Inc PDF: 2 pages, 52 KB
Real Estate Roundtable PDF: 3 pages, 1357 KB
Regional Banks Association of Japan PDF: 1 page, 119 KB
Reserve Bank of India PDF: 14 pages, 146 KB
Reserve Bank of Zimbabwe PDF: 3 pages, 88 KB
Resti, A and Sironi, A PDF: 44 pages, 368 KB
Risk Management Association PDF: 37 pages, 312 KB
RMA Committee on Security Lending PDF: 15 pages, 133 KB
Royal Bank of Scotland Group Scanned PDF: 5 pages, 328 KB
Royal Institution of Chartered Surveyors PDF: 8 pages, 117 KB
Saudi Arabian Monetary Agency Scanned PDF: 8 pages, 332 KB 11 Nov 03
Securities Industry Association PDF: 4 pages, 88 KB
Securitisation Associations PDF: 41 pages, 1290 KB
South African Reserve Bank Scanned PDF: 17 pages, 144 KB
Spanish Banking Association PDF: 55 pages, 928 KB
Standard & Poors PDF: 18 pages, 88 KB 30 Sep 03
Standard Chartered Scanned PDF: 4 pages, 238 KB
State Street Scanned PDF: 6 pages, 434 KB
Suntrust Scanned PDF: 5 pages, 292 KB
Superintendencia de Banca y Seguros Peru PDF: 14 pages, 163 KB
Swedish Bankers Association PDF: 10 pages, 130 KB
Swiss Bankers Association Scanned PDF: 26 pages, 1741 KB
Synovus Financial Corporation PDF: 5 pages, 127 KB
Talbot Underwriting PDF: 11 pages, 197 KB
Tanzanian Banking Industry Scanned PDF: 3 pages, 124 KB
Taylor, C PDF: 37 pages, 320 KB
Thirlwell, J PDF: 5 pages, 77 KB
Treasury Strategies Scanned PDF: 8 pages, 166 KB 22 Aug 03
UBS PDF: 8 page, 156 KB
UEAPME PDF: 6 pages, 124 KB
Universität Heidelberg Scanned PDF: 2 pages, 44 KB
Universität Karlsruhe PDF: 7 pages, 215 KB
University of Regensburg PDF: 7 pages, 143 KB
Verband der Burgschaftsbanken PDF: 3 pages, 74 KB
Wachovia PDF: 24 pages, 277 KB
Washington Mutual Scanned PDF: 6 pages, 439 KB 22 Aug 03
Wells Fargo Scanned PDF: 16 pages, 1048 KB 19 Sep 03
Westpac PDF: 21 pages, 212 KB
Willis Limited PDF: 5 pages, 122 KB
Wirtschaftskammer - Österreich PDF: 34 pages, 316 KB
World Bank Scanned PDF: 5 pages, 234 KB
World Council of Credit Unions PDF: 5 pages, 61 KB
Zentraler Kreditausschuss PDF: 82 pages, 407 KB
Zentralverband des Deutschen Handwerks Scanned PDF: 5 pages, 206 KB

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