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Revisions to the Standardised Approach for credit risk

Type
Publication
Series
Consultative
Date Published
10 December 2015
Status
Closed
Sources
BCBS
Topics
Credit risk

The second consultative document on Revisions to the Standardised Approach for credit risk forms part of the Committee's broader review of the capital framework to balance simplicity and risk sensitivity, and to promote comparability by reducing variability in risk-weighted assets across banks and jurisdictions.

These proposals differ in several ways from an initial set of proposals published by the Committee in December 2014. That earlier proposal set out an approach that removed all references to external credit ratings and assigned risk weights based on a limited number of alternative risk drivers. Respondents to the first consultative document expressed concerns, suggesting that the complete removal of references to ratings was unnecessary and undesirable. The Committee has decided to reintroduce the use of ratings, in a non-mechanistic manner, for exposures to banks and corporates. The revised proposal also includes alternative approaches for jurisdictions that do not allow the use of external ratings for regulatory purposes.

The proposed risk weighting of real estate loans has also been modified, with the loan-to-value ratio as the main risk driver. The Committee has decided not to use a debt service coverage ratio as a risk driver given the challenges of defining and calibrating a global measure that can be consistently applied across jurisdictions. The Committee instead proposes requiring the assessment of a borrower's ability to pay as a key underwriting criterion. It also proposes to categorise all exposures related to real estate, including specialised lending exposures, under the same asset class, and apply higher risk weights to real estate exposures where repayment is materially dependent on the cash flows generated by the property securing the exposure.

This consultative document also includes proposals for exposures to multilateral development banks, retail and defaulted exposures, and off-balance sheet items.The credit risk standardised approach treatment for sovereigns, central banks and public sector entities are not within the scope of these proposals. The Committee is considering these exposures as part of a broader and holistic review of sovereign-related risks.

The Committee welcomes comments on all aspects of this consultative document and the proposed standards text. Comments on the proposals should be uploaded here by Friday 11 March 2016. All comments will be published on the website of the Bank for International Settlements unless a respondent specifically requests confidential treatment.


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.

AECM - European Association of Guarantee Institutions
Alliance Bank
American Express
Arab Banking Corporation
Asian Bankers Association
Assilea - Italian Leasing Association
Association Francaise des Societes Financieres
Association of Credit Rating Agencies in Asia
Association of European Development Finance Institutions
Association of German Pfandbrief Banks
Association of Property Lenders - CRE Financial Council - CREFC Europe
Association of Supervisors of Banks of the Americas
Associazione Bancaria Italiana
Australian Bankers Association
Austrian Federal Economic Chamber
Aviation Working Group
BAFT- International financial services trade association
Bangkok Bank Public Company Limited
Bank-ABC Islamic
Banking Association South Africa
Barclays
BCC Sala di Cesenatico
BFW Bundesverband Freier Immobilien- und Wohnungsunternehmen
Black Sea Trade and Development Bank
BPIFrance
British Bankers Association
Building Societies Association
Bundesverband Investment und Asset Management
BusinessEurope
Cambridge-Counties Bank
Canadian Bankers Association
Canadian Finance and Leasing Association
China Banking Association
Clydesdale Bank
Council of Mortgage Lenders
Crédit Agricole
Credit Foncier
Credit Suisse
Customer Owned Banking Association
Danish Mortgage Banks Federation -Danish Bankers Association - Association of Danish Mortgage Banks
Deutsche Bank
Deutsche Börse Group
Deutscher Industrie und Handelskammertag
Dubai Financial Services Authority
Dutch Banking Association
EBA Banking Stakeholder Group
EU Federation for the Factoring and Commercial Finance Industry
Eurofinas
European Association of Cooperative Banks
European Association of Credit Rating Agencies
European Association of Public Banks
European AVM Alliance
European Bank for Reconstruction and Development
European Banking Federation
European Community Shipowners Associations
European Mortgage Federation - European Covered Bond Council
Federal Ministry of Finance
Federation des Promoteurs Immobiliers de France
Federation of German Industries
FELABAN - Federacion Latinoamericana de Bancos
Finance Norway
Finanstilsynet and Norges Bank
Fitch Ratings
French Banking Federation
French Building Federation
GdW Bundesverband deutscher Wohnungs- u. Immobilienunternehmen
Genworth Financial
German Banking Industry Committee
Group Credit Libanais
Harald Hummer
Hayri Türkmen - Kuveyt Turk Katilm Bankasi AS
IFPImm - Institut du Financement des Professionnels de l Immobilier
IIF - GFMA - ISDA - IACPM
Indian Banks Association
Intermediary Mortgage Lenders Association
International Association of Credit Portfolio Managers
International Banking Federation
Islamic Financial Services Board
Japan Chamber of Commerce and Industry
Japan Credit Rating Agency
Japanese Bankers Association
Kasikornbank PCL
Korea Federation of Banks
Leaseurope
Ministry of Business and Growth
Moodys Investors Service
Mortgage Bankers Association
Office de Coordination Bancaire et Financière (OCBF)
OneSavings Bank
Polish Bank Association
Polish Financial Supervision Authority
Portuguese Banking Association
Rail Working Group
Rating and Investment Information
Residential Landlords Asociation
Risk Management Association
Royal Institution of Chartered Surveyors
Saudi Banks
Secure Trust Bank
Shinkumi Federation Bank
Spanish Banking Association
Standard and Poors
Standard Chartered
State Street - BNY Mellon - Northern Trust
State Street Corporation
Swedish Bankers Association
The Basel Club, Thailand
The Clearing House - SIFMA - Financial Services Roundtable
The Hong Kong Association of Banks
The National Association of Shinkin Banks
The Paragon Group of Companies
UBS
UEPC - European Union of Developers and House Builders
Unipol Gruppo Finanziario
US Mortgage Insurers
VDB - Association of German guarantee banks
World Council of Credit Unions
World Savings and Retail Banking Group - European Savings and Retail Banking Group
Yorkshire Building Society Group
Zaragoza Homebuilder's Federation
ZIA German Property Federation

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