Wednesday, September 9, 2015

TOO BIG TO FALL - Systemically Important Banks

RBI Press Release dated 31st August 2015:-
QUOTE”:
The Reserve Bank of India announced today the designation of State Bank of India and ICICI Bank Ltd. as Domestic Systemically Important Banks (D-SIBs).
The Reserve Bank had issued the Framework for dealing with Domestic Systemically Important Banks (D-SIBs) on July 22, 2014. The D-SIB Framework requires the Reserve Bank to disclose the names of banks designated as D-SIBs every year in August starting from August 2015. The Framework also requires that D-SIBs may be placed in four buckets depending upon their Systemic Importance Scores (SISs). Based on the bucket in which a D-SIB is placed, an additional common equity requirement has to be applied to it, as mentioned in the D-SIB Framework.
The D-SIB Framework specifies a two-step process of identification of D-SIBs. In the first step, the sample of banks to be assessed for systemic importance has to be decided. The selection of banks in the sample for computation of SIS is based on analysis of their size as a percentage of annual GDP.
Based on the methodology provided in the D-SIB Framework and data collected from banks as on March 31, 2015, the banks identified as D-SIBs and associated bucket structure are as under:
Bucket
Banks
Additional Common Equity Tier 1 requirement as a percentage of Risk Weighted Assets (RWAs)
5
-
1.0%
4
-
0.8%
3
State Bank of India
0.6%
2
-
0.4%
1
ICICI Bank
0.2%
The additional Common Equity Tier 1 (CET1) requirements applicable to D-SIBs will be applicable from April 1, 2016 in a phased manner and would become fully effective from April 1, 2019. The additional CET1 requirement will be in addition to the capital conservation buffer.
Further, as mentioned in the D-SIB Framework, in case a foreign bank having branch presence in India is a Global Systemically Important Bank (G-SIB), it has to maintain additional CET1 capital surcharge in India as applicable to it as a G-SIB, proportionate to its Risk Weighted Assets (RWAs) in India.
Sangeeta Das
Director
“UNQUOTE”

Reserve Bank of India has identified State Bank of India and ICICI Bank as systemically important banks in India, requiring these lenders to keep aside additional capital to cover risk.
Their capital requirement rises by 0.6% and 0.2% respectively, but this may not have much significance because banks in India in general maintain more than two to three percentage points more capital than regulatory stipulation
The baking regulator said the additional common equity tier 1 requirements for SBI and ICICI Bank will be applicable from April 1, 2016 in a phased manner and would become fully effective from April 1, 2019. This will be in addition to the capital conservation buffer.
RBI Executive director NS Vishwanathan said that Indian banks need to adhere to more stringent capital requirements compared to their global counterparts under the new Basel III framework because of the many gaps existing in the system.

What is a systemically important bank?

Systemically important bank or a bank that is ‘too big to fail’ is one whose failure will have nationwide or worldwide repercussions. A bank failure is a scenario in which the bank or financial institution is unable to pay its depositors or fulfil its financial obligations.


Reasons as to why SBI and ICICI Bank were declared systemically important?
The Reserve Bank of India (RBI) uses a methodology to determine whether a bank is systemically important or not on the basis of its size, interconnectedness, substitutability and complexity. Such banks are called domestic-systemically important banks (D-SIB). RBI has now selected two banks namely State Bank of India and ICICI bank as Domestic Systematically Important Banks (D-SIB) . As per RBI , these two banks are too big to fall. But the fact is that these two banks are vulnerable to more risk and they have more gross Non Performing Assets (NPA) , one among public sector banks and another among private banks. If RBI is able to unearth all hidden NPA and add them to existing declared NPA ,  these two big banks will be prone to more risk than any other banks in their domain. We have seen in the past how reputed IT company Satyam Computer managed to portray good picture of the company in the balance sheet year after year. Later when fraud perpetuated by Satyam was exposed by none other than Promoter , Government was caught unaware and the most famous team of Auditors (PWC) also expressed helplessness . It was only shareholders in the company who had to suffer the most. As regards ICICI bank , RBI has little to say and GOI has no direct stake but investors have greater stake in form of share participation. As far as SBI is concerned, RBI and GOI has greater role and greater stake whereas people of India, too, have almost considerably big stake. In both the cases , investors and depositors will suffer the most if they fail or they face crisis even to little extent.
Factors considered:
Size takes into account all exposures (Loans, savings deposits, commissions from mutual fund businesses) of a bank. According to RBI, “The impairment or failure of a bank of large size is more likely to damage the confidence in the banking systems as a whole.”
SBI and ICICI Bank’s total credit risk exposure was over Rs 30 lakh crore or around 30% of India’s GDP. Secondly, a bank is deemed more interconnected if it has borrowed or lent more money from other banks or financial institutions.
Sustainability is a financial infrastructure indicator which determines if the services provided by the bank are easily replaceable or not. For instance, if a bank that fulfilled the highest number RTGS transactions was to fail its effect on the financial system would be relatively higher. SBI (along with its subsidiaries) and ICICI Bank complete 23% of all RTGS transactions.

Lastly, if a bank has higher complexity the cost and time taken to resolve its issues will higher. Among other things complexity takes into account the size of international liabilities. The two banks have a collective overseas exposure of Rs 5 lakh crore as of June 30.


Does this makes them ‘too big to fail’ (TBTF), as the US puts it?

SIBs are perceived as banks that are ‘Too Big To Fail (TBTF)’. This perception of TBTF creates an expectation of government support for these banks at the time of distress. Due to this perception, these banks enjoy certain advantages in the funding markets. However, the perceived expectation of government support amplifies risk-taking, reduces market discipline, creates competitive distortions, and increases the probability of distress in the future. These considerations require that SIBs should be subjected to additional policy measures to deal with the systemic risks and moral hazard issues posed by them.


Will  SBI and ICICI Bank will be treated at par to Citigroup and Bank of America in case of a crisis?
Citigroup and Bank of America were among the many banks – which gave rise to the term TBTF – that had assumed too much risk in the absence of regulations. Also, these risky assets were spread all over the world. Therefore, if these banks were not bailed out — at a cost of $700 billion — the global financial system would have faced an even graver crisis. After the crisis central banks and governments, globally, adopted a stronger regulatory stance that could prevent and foresee any such crises.
In October 20101, the Financial Stability Board (FSB) recommended that all member countries needed to have in place a framework to reduce risks attributable to Systemically Important Financial Institutions (SIFIs) in their jurisdictions. The FSB asked the Basel Committee on Banking Supervision (BCBS) to develop an assessment methodology comprising both quantitative and qualitative indicators to assess the systemic importance of Global SIFIs (G-SIFIs), along with an assessment of the extent of going-concern loss absorbency capital which could be provided by various proposed instruments. In response, BCBS came out with a framework in November, 2011 (since up-dated in July, 2013) for identifying the Global Systemically Important Banks (G-SIBs) and the magnitude of additional loss absorbency capital requirements applicable to these G-SIBs.
6. The BCBS is also considering proposals such as large exposure restrictions and liquidity measures which are referred to as “other prudential measures” in the FSB Recommendations and Time Lines. The G20 leaders had asked the BCBS and FSB in November 2011 to extend the G-SIBs framework to Domestic Systemically Important Banks (D-SIBs) expeditiously.

Does India have such regulations?
Primarily these are stipulated reserve requirements such as the cash reserve ratio/SLR etc. Also, there are norms such as the globally-accepted Basel III that require banks to have a certain amount of capital adequacy ratio, which determine how much shock a bank can absorb.While these apply for all banks, SBI and ICICI Bank, which have been identified as D-SIB, will have to maintain additional capital as a percentage of its risk weighted assets.

This additional percentage is 0.6% for SBI and 0.2% for ICICI Bank as mentioned in the press release of RBI above. The two banks will have to implement this in a phased manner by April 1, 2019 or face further restrictions. All of the above are however, preemptive measures.


What if these banks do fail?
RBI’s wholly-owned subsidiary Deposit Insurance and Credit Guarantee Corporation (DICGC) insures savings, fixed, current and recurring deposits with all commercial up to a maximum of Rs 1,00,000, which means you will lose all your savings above that amount.
Apart from the personal impact, a bank failure will imply all other deposits with the bank will be liquidated and RBI will take over the bank’s operation till it is acquired by someone else. However, this is a very rare case and since the early nineties no bank has failed in India as RBI has stepped in and effected a merger.
Source:
- https://rbi.org.in/scripts/bs_viewcontent.aspx?Id=2861