Approaches to Stress Testing Credit Risk: Experience gained on Spanish FSAP



Similar documents
TOP-DOWN STRESS TESTS AS A MACRO-PRUDENTIAL TOOL: METHODOLOGY AND PRACTICAL APPLICATION. Carlos Pérez Montes and Carlos Trucharte Artigas (*)

Consultation Paper: Review of bank capital adequacy requirements for housing loans (stage one).

THE IMPACT OF MACROECONOMIC FACTORS ON NON-PERFORMING LOANS IN THE REPUBLIC OF MOLDOVA

Non-Bank Deposit Taker (NBDT) Capital Policy Paper

Group-wide Stress Testing: A Case Study. Enrico Piotto

Banco Sabadell Stress test results. 15 th July 2011

EBA discussion paper and call for evidence on SMEs and SME supporting factor (EBA in EBA/DP/2015/02)

Stress-testing testing in the early warning system of financial crises: application to stability analysis of Russian banking sector

Risk Based Financial Planning Beyond Basel 2

The Western Hemisphere Credit & Loan Reporting Initiative (WHCRI)

Statistics for Retail Finance. Chapter 8: Regulation and Capital Requirements

The Financial Projection Model 2.0 and its Implementation into Stress Testing and Other Projections. Murat Arslaner

Regulatory and Economic Capital

For further information UBI Banca Investor Relations Tel UBI Banca Press relations Tel.

Stress Test Modeling in Cards Portfolios

Validation of Internal Rating and Scoring Models

Basel Committee on Banking Supervision. An Explanatory Note on the Basel II IRB Risk Weight Functions

Central Credit Registers (CCRs) as a Multi Purpose Tool to close Data Gaps

CHILE FINANCIAL SECTOR ASSESSMENT PROGRAM

Stress Testing: Credit Risk

CITIGROUP INC. BASEL II.5 MARKET RISK DISCLOSURES AS OF AND FOR THE PERIOD ENDED MARCH 31, 2013

CONSULTATION PAPER P October Proposed Regulatory Framework on Mortgage Insurance Business

Measurement of Banks Exposure to Interest Rate Risk and Principles for the Management of Interest Rate Risk respectively.

Stress Testing Trading Desks

The Approach of the Banking Regulator

Regulatory Stress Testing For Mortgage Loan Portfolios

The validation of internal rating systems for capital adequacy purposes

STRESS TESTING GUIDELINE

INTERNATIONAL MONETARY FUND THE WORLD BANK. Analytical Tools of the FSAP. Approved by Cesare Calari and Stefan Ingves.

COMMERZBANK Capital Update - EU Wide Stress Test Results.

Managing Capital Adequacy with the Internal Capital Adequacy Assessment Process (ICAAP) - Challenges and Best Practices

Guidance for the Development of a Models-Based Solvency Framework for Canadian Life Insurance Companies

ACCEPTANCE CRITERIA FOR THIRD-PARTY RATING TOOLS WITHIN THE EUROSYSTEM CREDIT ASSESSMENT FRAMEWORK

2013 Comprehensive Capital Analysis and Review (CCAR) and Dodd-Frank Stress Tests

CHALLENGES FOR BASEL II IMPLEMENTATION IN CHILE

Portfolio Management for Banks

How To Write A Bank

Basel Committee on Banking Supervision. Working Paper on the IRB Treatment of Expected Losses and Future Margin Income

Prudential definition of assets: micro and macro prudential perspective

1) What kind of risk on settlements is covered by 'Herstatt Risk' for which BCBS was formed?

Discussion Paper. Maximum Event Retention for Lenders Mortgage Insurers. Australian Prudential Regulation Authority.

2016 Comprehensive Capital Analysis and Review

Net Stable Funding Ratio

EBA-GL July Guidelines. on the minimum list of qualitative and quantitative recovery plan indicators

Guidance Note: Stress Testing Class 2 Credit Unions. November, Ce document est également disponible en français

CREDIT RISK MANAGEMENT

The Internal Capital Adequacy Assessment Process (ICAAP) and the Supervisory Review and Evaluation Process (SREP)

Stress Testing the Canadian Banking System: A System-Wide Approach

Basel II, Pillar 3 Disclosure for Sun Life Financial Trust Inc.

INSURANCE. Moody s Analytics Solutions for the Insurance Company

(Part.1) FOUNDATIONS OF RISK MANAGEMENT

Central Bank of Ireland Guidelines on Preparing for Solvency II Pre-application for Internal Models

CP FOR DRAFT RTS ON RWS/LGDS ARTICLES 124 AND 164 CRR EBA/CP/2015/12. 6 July Consultation Paper

Profit from Big Data flow. Regulatory Stress Testing For Mortgage Loan Portfolios by Opera Solutions, LLC. All rights reserved.

Validation of low-default portfolios in the Basel II Framework

INTERNAL CAPITAL ADEQUACY ASSESSMENT

STRUCTURED FINANCE RATING CRITERIA 2015

1. Introduction Process for determining the solvency need Definitions of main risk types... 9

Key matters in examining Liquidity Risk Management at Large Complex Financial Groups

Basel II. Tamer Bakiciol Nicolas Cojocaru-Durand Dongxu Lu

Financial stability, systemic risk & macroprudential supervision: an actuarial perspective

THE EARLY WARNING SYSTEM PRESENTATION DEFINITION

EAD Calibration for Corporate Credit Lines

LIQUIDITY RISK MANAGEMENT GUIDELINE

Impact analysis of stress tests in the financial system

DECLARATION ON STRENGTHENING THE FINANCIAL SYSTEM LONDON SUMMIT, 2 APRIL 2009

BASEL III PILLAR 3 CAPITAL ADEQUACY AND RISKS DISCLOSURES AS AT 30 SEPTEMBER 2015

Correlation between Growth Rate and Non Performing Retail Loans in the Republic of Macedonia

Please see below for the current credit ratings of Santander UK:

REMARKS ON THE BASEL CAPITAL FRAMEWORK AND TRADE FINANCE, 27 FEBRUARY 2014 SESSION 4. Mr. Andrew CORNFORD Research Fellow Financial Markets Center

ING Bank, fsb (ING DIRECT) appreciates the opportunity to comment on the Base1 I1 notice of proposed rulemaking (NPR).

Market Risk Capital Disclosures Report. For the Quarter Ended March 31, 2013

ALM Stress Testing: Gaining Insight on Modeled Outcomes

Guideline. Category: Sound Business and Financial Practices. No: E-18 Date: December 2009

CAPITAL SHORTFALL: A NEW APPROACH TO RANKING and REGULATING SYSTEMIC RISKS Viral Acharya, Robert Engle and Matthew Richardson 1

Basel Committee on Banking Supervision. Basel III counterparty credit risk - Frequently asked questions

Draft Supervisory Guidance on. Internal Ratings-Based Systems. for Corporate Credit

This chapter assesses the risks that were identified in the first chapter and elaborated in the earlier chapters of this report.

SEMINAR ON CREDIT RISK MANAGEMENT AND SME BUSINESS RENATO MAINO. Turin, June 12, Agenda

EIOPA Stress Test Press Briefing Frankfurt am Main, 4 July 2011

Capital Adequacy: Advanced Measurement Approaches to Operational Risk

Measuring non-performing loans. during (and after) credit booms

IMPLEMENTATION NOTE. Validating Risk Rating Systems at IRB Institutions

The Bank of Canada s Analytic Framework for Assessing the Vulnerability of the Household Sector

Financial Risk Management

Annual Economic Report 2015/16 German council of economic experts. Discussion. Lucrezia Reichlin, London Business School

BBVA: Strengths in the new environment

Dr. Edward I. Altman Stern School of Business New York University

Transcription:

Approaches to Stress Testing Credit Risk: Experience gained on Spanish FSAP Messrs. Jesús Saurina and Carlo Trucharte Bank of Spain Paper presented at the Expert Forum on Advanced Techniques on Stress Testing: Applications for Supervisors Hosted by the International Monetary Fund Washington, DC May 2-3, 2006 The views expressed in this paper are those of the author(s) only, and the presence of them, or of links to them, on the IMF website does not imply that the IMF, its Executive Board, or its management endorses or shares the views expressed in the paper.

INTERNATIONAL MONETARY FUND Expert Forum on Advanced Techniques on Stress Testing: Applications for Supervisors Approaches to Stress Testing Credit Risk Experience gained on Spanish FSAP Washington DC May 2 2006 Banco de España

PRESENTATION CONTENTS 1. Introduction 2. Specific issues: Preliminaries 3. Sensitivity Analysis A) Portfolio Distinction B) Variables subject to shock and calibration C) Final Impact D) Lessons learned 4. Scenario Analysis A) Scope of application B) Breakdown analysis: Differentiation between business and credit risk C) Modeling of credit risk drivers D) Final Impact E) Lessons learned F) Final comments 5. Robustness 6. Issues for discussion 7. Conclusion 2

1. Introduction (I) Responsibilities of financial authorities: ensure sound, stable and efficient financial markets--------- Financial Stability Financial Stability: combination of prudential regulation and effective supervision Stress tests: complementary tool to take measures to cope with plausible adverse events--------- Stress Tests are useful assessment tools Financial Stability 3

1. Introduction (II) Importance at the individual-institution level and at the system level * Individual-institution level: facilitating internal controls in the course of risk management (capability of defining risk profiles more accurately). * System as a whole: identification of vulnerabilities with potential to affect soundness of the financial system. IMF recommendation to run regularly stress tests (FSAP methodology) and financial stability related issues--------- Basic principles and guidelines needed for Stress Tests 4

2. Specific Issues: Preliminaries (Credit Risk) Scope of application: Bank s loan portfolios. Less developed than market or interest rate risk stress tests: lesser availability of data. However, greater importance to be given: significance of credit risk (weight and importance of loan portfolios). Credit Risk can be analyzed both in Sensitivity and Scenario Analysis. 5

3. Sensitivity Analysis (I) A) Portfolio differentiation: By asset types: corporate and individuals (within asset type, for example, between mortgage loans and consumer credit) Distinction enables to design, calibrate and determine the final impact of defined shocks properly: - Determine whether or not a shock has an effect - Different sensitivity: intensity of the impact may differ significantly - Account for the different levels in the values of risk drivers 6

3. Sensitivity Analysis (II) B) Variables subject to shock and calibration Traditionally Sensitivity Analysis of credit risk entailed : * Worsening the credit quality of all borrowers in a fixed amount (downgrading them one or two notches). * Increase in Non-performing loans--- increase in provisions. Now, if data availability: Make use of historical or probabilistic calibration Application to Probabilities of Default (PD), Loss given Default (LGD) and Exposure at Default (EAD). - Maximum historical variations (usually coincide with downturns) - Translation into current values of risk parameters: percentage-point increase observed. 7

3. Sensitivity Analysis (III) C) Final Impact - Impact on profitability and solvency. - Estimate of expected losses and recognition of a higher volume of impairment losses - Policy measures: if major problems due to the impact detected, revision of adequacy of prudential elements in place. 8

Sensitivity Analysis Diagram PORTFOLIO DESAGREGATION PD / LGD / EAD SHOCK CALIBRATION / TIMEFRAME RESULTS INTERPRETATION PORTFOLIO Asset Type A LOAN PORTFOLIO PORTFOLIO Asset Type B PD / LGD / EAD SHOCK Percentage- point increase STRESSED PORTFOLIO PORTFOLIO Asset Type C PROFITS EFFECT SOLVENCY EFFECT 9

3. Sensitivity Analysis (IV) D) Lessons learned Calibration Warning: Awareness of possible structural changes Avoidance of extreme approaches - Application of maximum recorded highs: Different economic and risk management context - Substitutes to extreme situations do not offer better solutions: * e.g. apportion largest observed change among a number of periods (1-3 years) * Fundamental limitation: Holding unchanged the setting while dynamic characterization of the economy in general and of banks activity in particular 10

3. Sensitivity Analysis (IV) D) Lessons learned Final impact All existing prudential elements must be considered when quantifying shock s impact. Otherwise distortion of the reality is created and could arise competitive disadvantages. 11

4. Scenario Analysis (I) A) Scope of application -Scope of application of scenario analysis banks balance sheet and profit and loss account (P&L). Advantages: - Detailed monitoring of items liable to be affected by a particular shock. - Adequate assessment of impact on banks main operations 12

4. Scenario Analysis (II) B) Breakdown Analysis: Differentiation between Business and Credit Risk -Delimitation of the two basic risks in scenario analysis: * Business Risk * Credit Risk. - Business risk: Included in the banks balance sheets and P&L account. - Credit Risk: Borrowers financial condition. Borrowers creditworthiness. 13

4. Scenario Analysis (III) B) Breakdown analysis: Differentiation between Business and Credit Risk - Approximation to Business Risk: Simulation of the main line items of the Balance sheet and the P&L account. Econometric models or internal management information from banks own risk models. - Approximation to Credit Risk: Offer an alternative view to traditional approaches in stress tests: Modeling borrowers PD, LGD and EAD versus modeling an equation for credit loss provisions 14

4. Scenario Analysis (IV) C) Modeling of credit Risk Drivers - Approximation to Credit Risk: Parameterization of main credit risk drivers General measure used by banks to evaluate and manage credit risk Reference parameter for supervisory authorities to assess credit risk - Relate PD in terms of macroeconomic variables ----- Translate the shocks of a stress scenario into credit risk. PD it = F[ α j * Macro_variables jt + δ j * borrowers charact. jit ] - Full shock effect transferred when LGD and EAD also expressed in terms of macro variables. LGD it = G [Macro_variables (hosing prices, interest rates ), borrowers characteristics ] 15

4. Scenario Analysis (V) D) Final Impact - Analysis of the sensitivity of major line items to the shock (breaking down the effect). - Assessing credit risk provides an estimate of stressed expected losses which determines the volume of provisions to set aside------ Impact on profits. - Impact on solvency: change in expected losses and coverage thereof by provisions. - Policy measures: if major problems due to the impact detected, revision of adequacy of prudential elements in place. 16

Scenario Analysis Diagram RISK DISTINCTION BASELINE SCENARIO MACROECONOMICS VARIABLES STRESSED SCENARIO RESULTS INTREPRETATION BASE PROJECTION STRESSED PROJECTION BUSINESS RISK BALANCE SHEET PROJECTION ITEMS BALANCE SHEET STRESSED ITEMS BASELINE SCENARIO ANALYSIS P & L PROJECTION ITEMS SHOCK P & L STRESSED ITEMS STRESSED BALANCE BASELINE STRESSED P & L CREDIT RISK LOAN PORTFOLIO STRESSED PORTFOLIO BREAKING DOWN EFFECT BY ITEMS PROFITS EFFECT SOLVENCY EFFECT 17

4. Scenario Analysis (V) E) Lessons learned Analyzing the bottom line of the P&L account may hide significant individual effects. Avoidance of erratic movement of the P&L bottom line. Individual banks agree on this view. Banks not allowed to put into practice reactive measures to alter initial hypothesis Banks not accustomed to this type of exercise. Make of use of their internal budgets which include some type of reactions. Approximation to banks internal way of calculating risk drivers (PDs). Scenario Analysis not reduced to credit risk analysis. Enrichment comes from the inclusion of balance sheet and P&L account items. 18

4. Scenario Analysis (V) F) Final Comments: possible constraints The approach takes for granted the following: * Data availability * Development of banks internal models * Supervisory authorities in possession of borrowers classification method * Convergence between output of both banks and authorities systems. Remaining challenge: Among others: Consideration of second-round and feedback effects 19

4. Scenario Analysis (VI) F) Final Comments : Basel II purposes - Basel II stipulates the performance of stress test to determine capital adequacy - That implies: Involvement of supervisory authorities in design, calibration and analysis of impact Adequate approach to test credit risk: whether the excess of capital large enough to weather an adverse shock Development and integration of stress tests as prudential tools: general acceptance of them and setting common grounds 20

4. Robustness Spain-FSAP analysis of credit risk has been thorough Top-down approach (run by Banco de España and IMF) Bottom-up (run by a significant number of credit institutions) Comprehensive database individual data and models from credit institutions aggregated balance sheets, P&L accounts and solvency reporting data Credit Register (CIR) 21

4. Robustness Credit Register (CIR) low threshold (any loan above 6.000 euros) both families and firms different loan products: mortgages, consumer loans different types of firms (real estate developers, other firms) key role in stress testing credit risk 22

4. Robustness Additional exercise combining scenario analysis individual accounting and solvency data Credit Register information panel data analysis Simple methodology PD modeling bank by bank along time expected losses, impact on P&L and solvency ratios dispersion analysis overall robustness but, maybe, some fragility at particular credit institutions Complete coverage of credit risk stress testing 23

5. Issues for discussion Structural break in the economy: joining a monetary union, lower levels of interest rates and lower volatility change in long-term relationships shift in the response to shocks in risk management by banks improvement in measurement of credit risk improvement in management of credit risk (securitization, credit transfer of risk, more weight to control risk departments, derivatives, shift in the impact of shock on banks Uncertainty about the degree of confidence on stress testing results 24

5. Issues for discussion 1,2 1,0 0,8 0,6 10 9 8 7 6 5 4 3 2 1 0 sep-85 sep-87 sep-89 sep-91 sep-93 sep-95 sep-97 sep-99 sep-01 Personas Físicas Personas Jurídicas Crecimiento del PIB 7 6 5 4 3 2 1 0-1 -2-3 0,4 0,2 0,0 mar-99 mar-00 mar-01 mar-02 mar-03 mar-04 mar-05 1dt 2dt Año 93 5,0 4,5 4,0 3,5 3,0 2,5 2,0 1,5 1,0 0,5 0,0 mar-99 mar-00 mar-01 mar-02 mar-03 mar-04 mar-05 1dt 2dt Año 93 25

5. Issues for discussion How to react to a bad news stress testing exercise? 1) We are close to the shock almost no degree of freedom to react even counterproductive to react 2) We are far away from the shock are we going to see the problem (former slide)? are we going to react? Prudential tools: proper risk management, solvency requirements, asset classification, moral suasion, 26

5. Issues for discussion Procyclicality credit risk is an ex ante concept credit risk enters loan portfolios in good times, when problem loans and PDs are low an stress test exercise in good times will show, probably, a low impact: do nothing However empirical evidence shows that loans granted during good times are riskier than those granted during bad times Variables Coefficient SE Coefficient SE Coefficient SE Dependant variable DEFAULT ijt+2 (0/1) DEFAULT ijt+3 (0/1) DEFAULT ijt+4 (0/1) Bank characteristics LOANG it 0.001 0.001 0.002 0.001 *** 0.002 0.001 *** Province dummies yes yes yes Industry dummies yes yes yes No. Observations 1,823,656 1,643,708 1,433,074 Time period 1985-2004 1985-2004 1985-2004 Wald test [χ(2)] / p-value 8,966 0.00 4,802 0.00 2,987 0.00 27

5. Issues for discussion Dynamic provisioning take into account when the risk appears in the balance sheet countercyclical provisioning reinforces solvency of individual institutions and the stability of the financial system the mechanism might be incorporated in the Pillar 2 28

6. Conclusion Stress testing credit risk is one of the multiple weapons in the hands of bank supervisors (and bank managers) Importance of databases (in particular, Credit Registers) Refine methodologies use in Basel II, Pillar 1 and 2 What to do with stress test results? risk management capital adequacy dynamic provisioning 29

THANKS FOR YOUR ATTENTION