This document is a project report on risk management in banks submitted to the All India Management Association. It includes an executive summary, introduction to risk management in banking, objectives of the study, and research methodology. The report is divided into chapters that cover the conceptual framework of asset liability management, guidelines for ALM systems, a literature review on risk management, history and growth of the bank studied, risk management practices at ICICI Bank, performance evaluation of banks, and risk management guidelines for commercial banks.
This document is a project report on risk management in banks submitted to the All India Management Association. It includes an executive summary, introduction to risk management in banking, objectives of the study, and research methodology. The report is divided into chapters that cover the conceptual framework of asset liability management, guidelines for ALM systems, a literature review on risk management, history and growth of the bank studied, risk management practices at ICICI Bank, performance evaluation of banks, and risk management guidelines for commercial banks.
This document is a project report on risk management in banks submitted to the All India Management Association. It includes an executive summary, introduction to risk management in banking, objectives of the study, and research methodology. The report is divided into chapters that cover the conceptual framework of asset liability management, guidelines for ALM systems, a literature review on risk management, history and growth of the bank studied, risk management practices at ICICI Bank, performance evaluation of banks, and risk management guidelines for commercial banks.
This document is a project report on risk management in banks submitted to the All India Management Association. It includes an executive summary, introduction to risk management in banking, objectives of the study, and research methodology. The report is divided into chapters that cover the conceptual framework of asset liability management, guidelines for ALM systems, a literature review on risk management, history and growth of the bank studied, risk management practices at ICICI Bank, performance evaluation of banks, and risk management guidelines for commercial banks.
Download as DOC, PDF, TXT or read online from Scribd
Download as doc, pdf, or txt
You are on page 1of 105
At a glance
Powered by AI
The document discusses a project report submitted by a student on risk management in banks. It provides details about the student, outlines of the project report, declarations, certificates and acknowledgements.
The project report is about risk management in banks.
Details provided about the student include their name, registration number, course of study, and address.
A PROJECT REPORT ON
RISK MANAGEMENT IN BANK
SUBMITTED TO ALL INDIA MANAGEMENT ASSOCIATION-CENTRE FOR MANAGEMENT EDUCATION MANAGEMENT HOUSE, 14 INSTITUTIONAL AREA, LODHI ROAD, NEW DELHI-110002 OCTOBER, 2010 BY ABHIJEET KUMAR REGISTRATION NO. 70!21!07 GUIDED BY MR. RAKESH SINGH SR. MANAGER " #ACCOUNT$ FOR THE PARTIAL FULFILLMENT OF POST GRADUATION DIPLOMA IN MANAGEMENT #FINANCE$ To The Manager Evaluation AIMA CME 14, Intitutional Area Lo!hi Roa!, Ne" #elhi #ear $ir, I have ent the %no&i an! it ha 'een a&&rove! 'ut I haven(t re)eive! the )o&% o* the a&&roval %no&i, intea! ha )olle)te! the )ontrol nu+'er *ro+ the #elhi O**i)e, The %no&i )ontrol nu+'er i -./0 an! !ate! . th A&ril 1212, There*ore, I a+ en!ing the &ro3e)t re&ort along "ith a )o&% o* the %no&i "ith the e4&e)tation o* earliet )oni!eration *ro+ %our i!e, Than5ing %ou A'hi3eet 6u+ar Reg, No, /7281182/ #ate9 17 O)to'er, 1212 P%&'()* R(+&%* RISK MANAGEMENT IN BANK Submitted By A,-.'((* K/01% R(2. N&. 70!21!07 D1*(3 2 O)*&,(% 2010 DETAILS OF THE PROJECT 1, Na+e 9 A'hi3eet 6u+ar 1, Reg, No, 9 /7281182/ 0, Na+e o* the Coure 9 P:#M 4, A!!re 9 1/;-, In!ra <i5a Colon%, Mu5her3ee Nagar, Ne" #elhi 7, Title o* the &ro3e)t 9 Ri5 Manage+ent in =an5 8, Na+e o* the &ro3e)t $u&ervior 9 Ra5eh $ingh $r, Manager >A))ount? #ate9 17 O)to'er 1212 A,-.'((* K/01% STUDENT4S DECLARATION I here'% !e)lare that the &ro3e)t re&ort on @R.56 M1712(0(7* .7 B1768 u'+itte! to A99 I7:.1 M1712(0(7* A55&).1*.&7 C(7*%( ;&% M1712(0(7* E:/)1*.&7, Ne" #elhi in &artial *ul*ill+ent o* the reAuire+ent *or P&5* G%1:/1*( D.+9&01 .7 M1712(0(7* )o+&lete! i +% original "or5 an! not u'+itte! *or the a"ar! o* an% other #egree; #i&lo+a or other &riBe, Pla)e9 #elhi #ate9 17 O)to'er 1212 A,-.'((* K/01% CERTIFICATE Thi i to )erti*% that the !iertation title! @R.56 M1712(0(7* .7 B1768 i a *aith*ull% 'ona*i!e "or5 !one '% Mr, A'hi3eet 6u+ar un!er +% gui!an)e an! ea)h )o+&lete! a a &art o* training !one !uring 4 th e+eter *or the *ul*ill+ent o* the reAuire+ent o* P&5* G%1:/1*( D.+9&01 .7 M1712(0(7* #PGDM$, R16(5- S.72- S%. M1712(% #A))&/7*$ ACKNOWLEDGEMENT I have ha! )oni!era'le hel& an! u&&ort in +a5ing thi &ro3e)t re&ort a realit%, I a+ than5*ul to ICICI =an5 *ro+ "here I got the relevant in*or+ation regar!ing +% &ro3e)t, I a+ alo than5*ul to Mr, Ra5eh $ingh, $r, Manager >A))ount? "ho &rovi!e u all the relevant in*or+ation regar!ing +% &ro3e)t, I "oul! alo li5e to than5 +% *rien! an! *a+il% +e+'er, Than5 are alo !ue to the ta** o* AIMACCME Li'rar% an! In*or+ation Centre, In the en! I a+ than5*ul to that al+ight% go! "ho gave +e in&iration to )o+&lete thi &ro3e)t, A,-.'((* K/01% Reg, No, /7281182/ P:#M Ne" #elhi 17 O)to'er, 1212 INDEX Executive Summary 1 Chapter-1 -! Introduction to risk management in banking 3 Problem in study 4 Objectives in study 4 Research methodology 4 Limitation 5 Scope o the Study 5 Chapter- "-# !onceptual "rame#ork o $L% & 'uidelines or $sset Liability %anagement ($L%) System in "inancial Institutions ("IS) *& Revie# o e+isting literature summary ,- Chapter-$ $%-$# .istory and 'ro#th o the bank ,/ Risk %anagement at I!I!I 3& Chapter-& &%-#$ Perormance evaluation o bank 4* Risk %anagement 'uidelines or !ommercial 0anks 5, Inter10ank 2+posure and !ountry Risk 3- "oreign 2+change ("OR24) Risk -& C'(c)u*i'( + ,ec'mme(-ati'( #& .i/)i'0raphy #! EXEC1TI2E S1MMA,3 In normal course "is are e+pose to several major risk in the course o their business1 'enerally classiied as credit risk5 market risk5 operational risk1 #hich underlines the need o eective risk management system in "is6 7he "is needs to address these risks in a structure manner by upgrading the 8uality o their risk management and adopting more comprehensive $L% practices6 In order to give some giving to above lines #e have made a project report on I!I!I bank6 7he project is divided into three phases in irst phase #e have highlighted the introduction o risk management in banking sector5 the problem and objective o the project6 Secondly #e have also sho#n the research methodology o the #hole project6 Second phase consist o conceptual rame#ork o risk management and $L% it is also include some e+isting literature revie# on risk management6 7hird phase consist o history and gro#th o the bank also its include the perormance evaluation o the bank6 1 1 INT,OD1CTION TO ,ISK MANAGEMENT Risk management is recognised in today9s business #orld as an integral part o good management practice6 In its broadest sense5 it entails the systematic application o management policies5 procedures and practices to the tasks o identiying5 analysing5 assessing5 treating and monitoring risk6 7he past decade has also heralded enormous developments in ne# inancial products6 %ortgages and residential mortgages have given institutional and individual investors po#erul ne# tools #ith #hich to disperse risk both domestically and internationally6 $dvances in comple+ inancial products5 together #ith improvements in technology5 have lo#ered the cost o and e+panded opportunities or hedging risk6 :ith the raid gro#th in ne# tools5 8uantiying risk and interpreting risk measurements have never been more important6 7hese developments have enabled all companies to take a more proactive vie# to#ards risk6 Instead o only associating risk as a potential do#nside o their operations5 increasing numbers o irms are considering ho# risk can be managed positively to enhance the irm9s value6 0 4,O.LEM 0ank in the process o inancial intermediation are conronted #ith various kinds o inancial and non inancial risk vi;5credit risk5li8uidity risk5ore+ risk etc67hese risk are highly interdependent and event that aect one area o risk can have ramiication or a range o other risk categories so based on this problem #e are going to do our research that ho# commercial banks monitor such risk and controll the overall level o risk6 O.5ECTI2ES 7o kno# the concept o risk management in banking6 7o kno# the guidelines setup by R606I or commercial banks 7o kno# #hether the banks are ollo#ing those guidelines or not6 7o kno# the banks perormance6 ,ESEA,C6 MET6ODOLOG3 7o get the conclusion rom the undertaken project one should go through a proper methodology6 .ere in this project our methodology is based on t#o source5 primary and secondary source Sec'(-ary *'urce <nder secondary source #e have data collected rom outside the bank such as internet5 stock e+change 5icci library6 4 SCO4E O7 T6E ST1D3 7hrough eective and eicient asset1liability management5 the banks can increase their productivity and reduce cost1ineiciency6 I ineicient banking irms have a tendency to remain ineicient5 it #ould be o interest or the policy makers to investigate ho# these banks can remain economically viable and not be driven out o the banking market and this can be done through asset1liability management6 7he asset1liability management plays a very important role in the banks and has a very vital scope in these institutions6 7 CHAPTER 2 8 CONCE4T1AL 7,AMEWO,K A( Overvie8 6i*t'rica) .ac90r'u(- In the conte+t o present day9s rapidly changing business environment5 asset liability management in the inancial sector especially banking reers to a holistic approach to risk management5 concerning not only individual trading or balance sheet positions but #ith overall balance sheet perspective6 It re8uires assessing all available avenues or managing risks through natural methods5 diversiication5 pricing5 e+posure control5 and use o derivatives6 Risk can be categori;ed into credit and market risk6 .istorically5 credit risk constituted the major challenge to the banking sector6 .o#ever5 during the last t#o decades market risk has gained prominence and especially ater the 0asle !ommittee $ccord o *=--5 #hich #as instrumental in raming broad guidelines or determining the various risks associated #ith inancial sector6 $sset Liability %anagement ($L%) encompasses the eects o market risk6 C'(cept ': ALM $L% has gradually gained currency in Indian conditions in the #ake o the inancial sector reorms during the last decade #ith particular emphasis on interest rate deregulation6 7he techni8ue o managing both assets and liabilities has come into being as a strategic response o banks to inlationary pressure5 volatility in interest rates and adverse business environments including the recessionary trends in global economy5 i any6 Simply put5 asset1liability management is the management o total balance sheet dynamics #ith regard to its si;e and 8uality6 It involves5 a) >uantiication o risk and b) !onscious decision making #ith regard to asset1liability structure in order to ma+imi;e interest earnings #ithin the rame#ork o perceived risk6 7he / proitable gro#th and at times survival o a inancial institution depends on eective $L%6 Sc'pe a(- '/;ective* ': ALM 7he primary objectives o $L% is not to eliminate risk ? but to manage it in such a #ay that volatility o net interest income is minimi;ed in the short term time hori;on and net economic value o the organi;ation is protected in a long term time hori;on6 In banking scenario5 this #ould controlling the volatility o net income5 net interest margin5 capital ade8uacy5 and li8uidity risk and inally ensuring an acceptable balance bet#een proitability5 gro#th5 and risk6 $ sound $L% system should ocus on Revie# o interest rate outlook "i+ation o interest@product pricing on both assets and liabilities 2+amining loan portolio 2+amining investment portolio %easuring oreign e+change risk %anaging li8uidity risk Revie# o actual perormance vis1A1vis projections in respect o net proit5 interest spread and other balance sheet ratios 0udgeting and strategic planning 2+amine the proitability o ne# products - ALM-A( Exerci*e :'r ,i*9 ,etur( Tra-e-O:: Risk is an inherent part o banking business and in simple #ords may be deined as a proitability o loss or damage6 'iven the comple+ities o bank9s balance sheets and rapidity o changes5 chances o loss or risks are only comple+ in nature but also varied in dimension6 0roadly speaking5 banks are e+posed to both categories o risk vi;6credit risk and market risk6 :hile credit risk #hich is mainly on account o the counter party ailure in perorming the repayment obligation on due date i6e6 loan deaults are managed by the credit policy o the bank5 the market risk is related to the $sset Liability %anagement process and is caused by changes in market variables5 involving one or more o the ollo#ingB Interest rate risk "oreign e+change risk !ommodity price risk Stock market risk $L% as a process not only encompasses market risk but also involves li8uidity management5 unding and capital planning5 proitability gro#th and at times management o certain credit risks #hich are caused by market risk variables or e6g6 in a highly volatile interest rate environment5 loan deaults may increase thereby deteriorating the credit 8uality6 I(tere*t ,ate ,i*9 7he 0asle !ommittee on 0anking Supervision #hose recommendations have been accepted by the 0anking !ommunity throughout the #orld has called or the 0anks to have a comprehensive risk management process in place that eectively identiies5 measures5 monitors and control interest rate risk e+posure and that is subject to appropriate board and senior management oversight . (source1###6bis6org? $mendment to the !apital $ccord to Incorporate %arket Risks5 Canuary *==3)6 7raditionally5 interest rate risk means changes in the interest income due to changes in the rate o interest6 :hile this ocus is not misplaced5 it is deinitely incomplete in as much as it overlooks an important aspect1changes in interest rate resulting in the value o assets@liabilities6 7hus5 interest rate risk may be vie#ed rom t#o dierent complementary perspectives1 earning sensitivity to rate luctuations and price sensitivity o instruments@products to changes in interest rate6 !hanges in interest rates can aect banks #ith regard to changes in a) %arket value o assets@liabilities and o balance sheet (O0S) items? ultimately having impact on the value o net #orth6 b) Det interest income arising out o mismatch in the repricing terms o the assets and liabilities? c) Det income as a result o changes in interest income? d) Det income margin o#ing to changes in interest income and sensitivity o non1interest income to rate changes and e) !apital1asset ratio due to changes in net margin6 7he supervisory capital re8uirements established by 0asle !ommittee rom the end o *==& covers interest rate risks in the trading activities o banks6 $ccordingly5 interest Rate risks in the trading activities o banks6 $ccordingly5 interest rate risk management process has been constituted to include development o business strategy5 the assumption o assets and liabilities in banking and trading activities5 as #ell as a system o internal controls6 7he ocus has been on the need or eective interest rate risk measurement5 monitoring5 and control unctions #ithin the interest rate risk management process (Source1 Principles or management o interest rate risk by 0IS)6 12 $ccording to the studies conducted by 0asle !ommittee based on #orking e+perience o 0anks in more than *// countries5 the banks are normally e+posed to ollo#ing orms o interest rate risk6 a) Repricing risk b) Eield curve risk c) 0asis risk d) Optionally ,eprici(0 ri*9B arises rom timing dierences in the maturity (or i+ed rate) and repricing (or loating rate) o bank9s assets 5 liabilities and o balance sheet (O0S) positions #hile such repricing mismatches are undamental to the business o banking 5 they can e+pose a bank9s income and underlying economic value to unanticipated luctuations as interest rate varies6 "or instance5 a bank that unded a long term i+ed rate loan #ith a short term deposit could ace a decline in both the uture income arising rom the position and its underlying value i the interest rate increases6 7hese declines arises because the cash lo#s on the loan are i+ed over its lietime 5 #hile the interest paid on the unding is variable5 and increases ater the short term deposits matures6 3ie)- Curve ,i*9< arises #hen unanticipated shits o the yield curve have adverse eects on a bank9s income or underlying economic value6 "or e+ample5 the underlying economic value o a long position in */ yr government bonds hedged by a short position in 5yr government notes could decline sharply i the yield curve steepens5 even i the position is hedged against parallel movements in the yield curve6 .a*i* ,i*9< arises rom imperect correlation in the adjustment o the rates earned and paid on dierent instruments #ith other#ise similar repricing characteristics6 :hen interest rates changes5 these dierences can give rise to une+pected changes in the cash lo#s and earnings spread bet#een assets5 liabilities and O0S instruments o similar maturities or repricing re8uencies or e+ample a strategy o unding one year loan that reprices monthly based on 11 one month LI0OR5 e+poses the institution to the risk that the spread bet#een the t#o inde+ rates may change une+pectedly6 7he concept o basis risk is applicable or any set o t#o dierent interest rates6 "or e+ample5 basis risk bet#een thee ollo#ing the ollo#ing rates can be analy;edB Prime@LI0OR 7reasury 0ill@LI0OR !ertiicate o deposits@LI0OR LI0OR@!ommercial Paper Prime@!ertiicate o Feposit 7he reasons or basis risk depend on particula4r set o rates5 or e+ample5 Prime@LI0OR basis risks are as ollo#sB a) Prime is an administered rate #hile LI0OR is market rate6 7he LI0OR changes everyday5 but the prime changes inre8uently6 b) In <S conte+t5 prime is a rate applicable or loans in the <SGLI0OR is applicable or intermediated outside the <S6 7hus other things remaining the same5 costs o certain types o regulation (e6g6 Feposit Insurance Premium !hange) may impact prime only and not LI0OR6 c) Furing a declining rate environment5 Prime tends to lag changes in LI0OR5 leading to #ider spread6 In an increasing rate environment5 there is an urgency to increase Prime Rate5 resulting in declining spread6 7his kind o pricing is usual in products market also #hen costs are increasing5 prices go up 8uickly5 #hen costs are declining5 and prices go do#n slo#ly6 7he rate o change is dierent in dierent environments6 Opti'(a)ityB option provides the holder the right but not the obligations to buy5 sell or in some manner alter the cash lo# o an instrument or inancial contract6 Options5 may be in the orm o standard alone instruments such as e+change traded options or embedded #ithin an other#ise standard instrument like the various type o bonds and notes #ith caller put provisions5 loans #hich give 11 borro#ers the right to repay balances and various type o non1maturity deposit instruments #hich give depositors the right to #ithdra# unds at any time5 oten #ithout any penalties6 I not ade8uately managed5 the asymmetrical pay o characteristic o options held both e+plicit and embedded are generally e+ercised to the advantage o the holder and disadvantage o seller6 E::ect* ': I(tere*t ,ate ,i*9B Interest rate risk eects both on banks earning as #ell as its economic value6 2arnings5 comprising o net interest income i6e65 dierence bet#een total interest income and total interest e+pense has been the ocus o main attention traditionally5 and the impact o interest rate change on net interest income has been accepted rom time to time6 .o#ever5 in the emerging ne# scenario increasing ocus on ee1based income and other non1interest bearing income and e+penses have led to changes in the dimension o the game6 7he non1 interest income arising rom many activities can also be highly sensitive to market interest rates6 In international arena5 banks are providing the servicing and loan1administration unction or mortgage loan pools in return or a ee1 based on the volume o assets it administers6 :hen interest rates all5 the servicing bank may e+perience a decline in its ee income as the underlying mortgages get prepared6 In addition5 even traditional sources o non1interest income such as transaction processing ee are becoming more interest rate sensitive6 7his increased sensitivity has led both bank management and supervisors to take a broader vie# o potential eects o changes in market interest rates on bank earnings and to actor these broader eects into their estimated earnings under dierent interest rates environment6 7he economic value5 o a bank9s assets5 liabilities5 and O0S position can get aected due to luctuation in interest rates6 7he economic value o a bank can be vie#ed as the present value o banks e+pected net cash5 deined as the e+pected cash lo# on liabilities plus the e+pected net cash lo#s on O0S positions6 Since economic value considered the potential impacting interest rate changes on the present value o all uture cash lo#s5 it provides a comprehensive vie# o the potential long term eects o changes in interest rates6 7han is oered by the earlier earnings perspectives6 10 :hile the above t#o perspectives ocus on the impact o changes in uture interest rates on a banks uture perormances5 evaluation o impact past interest rate changes may have on uture perormance is also o great signiicance6 In particular instruments that are not marked to market may already contain embedded gains or losses due to past rate movements and may ultimately aect bank earnings6 "or e+ample5 a long term i+ed rate loan entered into #hen interest rates #ere lo# and reunded more recently #ith liabilities bearing a higher rate o interest #ill over its remaining5 represent a drain on banks resources 7'rei0( Excha(0e ,i*9< It reers to potential impact o movement in oreign e+change rates6 7he risk here is that the adverse luctuations in e+change rates may result in a loss6 "oreign e+change risk arises #hen there are unhedged current mismatches in an institution assets and liabilities6 7his risk persists until the open position is covered by means o hedging transactions6 7he amount at risk is a unction o the magnitude o the potential e+change rate changes and the si;e and duration o the oreign currency e+posures6 Indian banks normally do not undertake currency e+posure or unding operation (i6e6 unhedged conversion o resources in one currency or unding assets in another currency)6 !urrency position in Indian banks is concentrated in dealing rooms and these are subjected to constant monitoring through separate daylight and overnight limits and e+ception reporting6 C'mm'-ity ,i*9 It is a risk associated #ith trading in commodities6 !ommodity trading is not practiced by 0anks and "inancial Institutions in India6 St'c9 Mar9et ,i*9 $rises primarily because o movement o portolio value5 #hich may have an overall impact on 0anks inancial position in adverse condition6 7he li8uidation o 0arings and Fai#a 0ank is related to the market related risk associated #ith 14 over e+posure to stock market to inluence their proitability and long term viability6 In addition to market risk associated #ith $sset and Liability %anagement process the t#o other important aspects #hich are also o importance #hile discussing asset liability management include a) Li8uidity Risk %anagement b) !apital risk and capital planning Li=ui-ity ,i*9 It is the potential inability to generate cash to cope #ith the decline in deposits or increase in assets6 Li8uidity risk originates rom mismatches in the maturity patterns o assets and liabilities since banks deal #ith assets and liabilities #ith varied maturity patterns and risk proile5 they need to strike a trade1o bet#een been overtly li8uid and relatively li8uid6 $n eective measurement and monitoring process assessing all o banks cash inlo#s against its outlo# to identiy the potential or any net shortalls going or#ard orms an essential ingredient to overall li8uidity risk management6 7his includes unding re8uirements or o balance sheet commitments6 $s all banks are aected by changes in the economic climate and market conditions5 the monitoring o economic and market trends is also a key to li8uidity risk management6 7raditionally5 banks have been relying on core deposits or their unding6 .o#ever5 in today9s environment5 banks have resorted to other means o sources also or managing the li8uidity on ongoing basis6 !ash inlo#s arise rom such things as maturing assets5 saleable non1maturing assets5 access to deposit liabilities5 established credit lines that can be tapped and in developed #orld through asset securiti;ation also6 7hese need to be matched against cash lo#s stemming rom liabilities and contingent liabilities alling due5 especially committed lines o credit that can be dra#n do#n6 $ maturity ladder is thereore a useul device to compare cash outlo#s and cash inlo#s both on a day to day basis and over a period o time6 7he banks historical e+perience o the patterns o lo#s and kno#ledge o market conventions can also guide a bank9s decision on li8uidity risk management especially in a diicult scenario6 17 <se o H#hat iI analysis situations can also help in building dierent li8uidity scenarios or practical applications6 $n eective system o internal control in banks against li8uidity risk #ill involveB1 $ strong control environment $n ade8uate process or identiying and evaluating li8uidity risk 2stablishment o policy and procedure or handling such risks $n ade8uate inormation system !ontrol revie# o adherence to established policies and procedures6 Capita) ,i*9 %aintaining ade8uate capital on a continuous basis is the sine 8uo1non or sound banking practice6 In a business situation5 banks re8uire capital to insulate themselves rom the risks o business that they undertake6 7he capital accord o *=-- calls or detailed guidelines or maintaining ade8uate capital by banks to mitigate themselves rom problems arising in business development on account o inade8uate capital structure6 18 G1IDELINES 7O, ASSET LIA.ILIT3 MANAGEMENT >ALM? S3STEM IN 7INANCIAL INSTIT1TIONS >7IS? In the normal course5 "Is are e+posed to credit and market risks in vie# o the asset1liability transormation6 :ith liberalisation in Indian inancial markets over the last e# years and gro#ing integration o domestic markets #ith e+ternal markets5 the risks5 particularly the market risks5 associated #ith "Is9 operations have become comple+ and large5 re8uiring strategic management6 "Is are operating in a airly deregulated environment and are re8uired to determine interest rates on various products in their liabilities and assets portolios5 both in domestic as #ell as oreign currencies5 on a dynamic basis6 Intense competition or business involving both the assets and liabilities5 together #ith increasing volatility in the domestic interest rates as also in oreign e+change rates5 has brought pressure on the management o "Is to maintain a good balance amongst spreads5 proitability and long1term viability6 7hese pressures call or structured and comprehensive measures or institutionalising an integrated risk management system and not just ad hoc action6 7he "Is are e+posed to several major risks in the course o their business J generically classiied as credit risk5 market risk and operational risk J #hich underlines the need or eective risk management systems in "Is6 7he "Is need to address these risks in a structured manner by upgrading the 8uality o their risk management and adopting more comprehensive $L% practices than has been done hitherto6 7he envisaged $L% system seeks to introduce a ormalised rame#ork or management o market risks through measuring5 monitoring and managing li8uidity5 e+change rate and interest rate risks o a "I that need to be closely integrated #ith the "Is9 business strategy6 7his note lays do#n broad guidelines or "Is in respect o li8uidity5 e+change rate and interest rate risk management systems #hich orm part o the $L% unction6 7he initial ocus o the $L% unction #ould be to enorce the discipline o market risk management vi;6 managing business ater assessing the market risks involved6 7he objective o a good risk management systems should be to evolve into a strategic tool or eective management o "Is6 1/ 7he $L% process rests on three pillarsB $L% Inormation System %anagement Inormation System Inormation availability5 accuracy5 ade8uacy and e+pediency $L% Organisation Structure and responsibilities Level o top management involvement $L% Process Risk parameters Risk identiication Risk measurement Risk management Risk policies and tolerance levels6 ALM I(:'rmati'( Sy*tem $L% has to be supported by a management philosophy #hich clearly speciies the risk policies and tolerance limits6 7his rame#ork needs to be built on sound methodology #ith necessary supporting inormation system as the central element o the entire $L% e+ercise is the availability o ade8uate and accurate inormation #ith e+pedience6 7hus5 inormation is the key to the $L% process6 7here are various methods prevalent #orld1#ide or measuring risks6 7hese range rom the simple 'ap Statement to e+tremely sophisticated and data intensive Risk $djusted Proitability %easurement methods6 7he present guidelines #ould re8uire comparatively simpler inormation system or generating li8uidity gap and interest rate gap reports6 ALM Or0a(i*ati'( Successul implementation o the risk management process #ould re8uire strong commitment on the part o the senior management in the "I5 to integrate basic operations and strategic decision making #ith risk management6 7he 1- 0oard should have overall responsibility or management o market risks and should decide the risk management policy o the "I and set limits or li8uidity5 interest rate5 e+change rate and e8uity price risks6 7he $L!O is a decision1making unit5 consisting o the "IKs senior management including !2O5 responsible or integrated balance sheet management rom risk1return perspective including the strategic management o interest rate and li8uidity risks6 :hile each "I #ill have to decide the role o its $L!O5 its po#ers and responsibilities as also the decisions to be taken by it5 its responsibilities #ould normally includeB monitoring the market risk levels o the "I by ensuring adherence to the various risk1limits set by the 0oard? articulating the current interest rate vie# and a vie# on uture direction o interest rate movements and base its decisions or uture business strategy on this vie# as also on other parameters considered relevant6 deciding the business strategy o the "I5 both 1 on the assets and liabilities sides5 consistent #ith the "I9s interest rate vie#5 budget and pre1 determined risk management objectives6 7his #ould5 in turn5 includeB determining the desired maturity proile and mi+ o the assets and liabilities product pricing or both 1 assets as #ell as liabilities side? deciding the unding strategy i6e6 the source and mi+ o liabilities or sale o assets? the proportion o i+ed vs loating rate unds5 #holesale vs retail unds5 money market vs capital market unding 5 domestic vs oreign currency unding5 etc6 revie#ing the results o and progress in implementation o the decisions made in the previous meetings 7he $L% Support 'roups consisting o operating sta should be responsible or analysing5 monitoring and reporting the risk proiles to the $L!O6 7he sta 1. should also prepare orecasts (simulations) relecting the impact o various possible changes in market conditions on the balance sheet and recommend the action needed to adhere to "IKs internal limits6 C'mp'*iti'( ': ALCO 7he si;e (number o members) o $L!O #ould depend on the si;e o each institution5 business mi+ and organisational comple+ity6 7o ensure commitment o the 7op %anagement and timely response to market dynamics5 the !2O@!%F@F%F or the 2F should head the !ommittee6 7hough the composition o $L!O could vary across the "Is as per their respective set up and business proile5 it #ould be useul to have the !hies o Investment5 !redit5 Resources %anagement or Planning5 "unds %anagement @ 7reasury (ore+ and domestic)5 International 0usiness and 2conomic Research as the members o the !ommittee6 In addition5 the .ead o the 7echnology Fivision should also be an invitee or building up o %IS and related computerisation6 Some "Is may even have Sub1committees and Support 'roups6 C'mmittee ': Direct'r* 7he %anagement !ommittee o the 0oard or any other Speciic !ommittee constituted by the 0oard should oversee the implementation o the $L% system and revie# its unctioning periodically6 ALM 4,OCESS 7he scope o $L% unction can be described as ollo#sB Li8uidity risk management %anagement o market risks 7rading risk management "unding and capital planning Proit planning and gro#th projection
12 7he guidelines contained in this note mainly address Li8uidity and Interest Rate risks6 11 Li=ui-ity ,i*9 Ma(a0eme(t %easuring and managing li8uidity needs are vital or eective operation o "Is6 0y assuring a "IKs ability to meet its liabilities as they become due5 li8uidity management can reduce the probability o an adverse situation developing6 7he importance o li8uidity transcends individual institutions5 as li8uidity shortall in one institution can have repercussions on the entire system6 "Is9 management should measure not only the li8uidity positions o "Is on an ongoing basis but also e+amine ho# li8uidity re8uirements are likely to evolve under dierent assumptions6 2+perience sho#s that assets commonly considered to be li8uid5 such as 'overnment securities and other money market instruments5 could also become illi8uid #hen the market and players are unidirectional6 7hereore li8uidity has to be tracked through maturity or cash lo# mismatches6 "or measuring and managing net unding re8uirements5 the use o a maturity ladder and calculation o cumulative surplus or deicit o unds at selected maturity dates is adopted as a standard tool6 7he ormat o the Statement o Li8uidity is urnished in $nne+ure I6 7he %aturity Proile5 as detailed in $ppendi+ I5 could be used or measuring the uture cash lo#s o "Is in dierent time buckets6 7he time buckets5 may be distributed as underB i) * to *4 days ii) *5 to ,- days iii) ,= days and upto 3 months iv) Over 3 months and upto 3 months v) Over 3 months and upto * year vi) Over * year and upto 3 years vii) Over 3 years and upto 5 years viii) Over 5 years and upto & years i+) Over & years andupto */ years +) Over */ years6 11 7he investments are assumed as illi8uid due to lack o depth in the secondary market and are5 thereore5 generally sho#n5 as per their residual maturity5 under respective time buckets6 .o#ever5 some o the "Is may be maintaining securities in the L7rading 0ook95 #hich are kept distinct rom other investments made or retaining relationship #ith customers6 Securities held in the K7rading 0ook9 should be subject to the ollo#ing preconditionsB i)7he composition and volume o the 7rading 0ook should be clearly deined? ii)%a+imum maturity@duration o the trading portolio should be restricted? iii)7he holding period o the trading securities should not e+ceed =/ days? iv)!ut1loss limit(s) should be prescribed? v) Product1#ise deeasance periods (i6e6 the time taken to li8uidate the Lposition9 on the basis o li8uidity in the secondary market) should be prescribed? vi) Such securities should be marked1to1market on a daily@#eekly basis and the revaluation gain@loss should be charged to the proit and loss account? etc6 "Is #hich maintain such L7rading 0ooks9 consisting o securities that comply #ith the above standards5 are permitted to sho# the trading securities under *1 *4 days5 *51,- days and ,=1=/ days buckets on the basis o the deeasance periods6 7he 0oard@$L!O o the banks should approve the volume5 composition5 ma+imum maturity@duration5 holding@deeasance period5 cut loss limits5 etc65 o the L7rading 0ook9 6 "Is5 #hich are better e8uipped5 #ill have the option o evolving #ith the approval o the 0oard @ $L!O5 an i(te0rate- 2a)ue at ,i*9 >2a,? )imit or their entire balance sheet including the H0anking 0ookI and the H7rading 0ookI5 or the rupee as #ell as oreign currency portolio6 $ copy o the approved policy note in this regard5 should be or#arded to the Fepartment o 0anking Supervision5 "IF5 R0I6 :ithin each time bucket there could be mismatches depending on cash inlo#s and outlo#s6 :hile the mismatches upto one year #ould be relevant since these provide early #arning signals o impending li8uidity problems5 the main ocus should be on the short1term mismatches vi;65 *1*4 days and *51,- days6 "Is ho#ever5 are e+pected to monitor their cumulative mismatches (running total) across all time buckets by establishing internal prudential limits #ith the 10 approval o the 0oard @ $L!O6 7he (e0ative 0ap during *1*4 days and *51,- days time1buckets5 in normal course5 should not e+ceed */ per cent and *5 per cent respectively5 o the cash outlo#s in each time bucket6 I a "I in vie# o its current asset1liability proile and the conse8uential structural mismatches needs higher tolerance level5 it could operate #ith higher limit sanctioned by its 0oard @ $L!O giving speciic reasons on the need or such higher limit6 7he discretion to allo# a higher tolerance level is intended or a temporary period5 i6e6 till March $1@ %%1A :hile determining the tolerance levels5 the "Is may take into account all relevant actors based on their asset1liability base5 nature o business5 uture strategy5 etc6 7he R0I is interested in ensuring that the tolerance levels are determined keeping all necessary actors in vie# and urther reined #ith e+perience gained in Li8uidity %anagement6 7he Statement o Li8uidity may be prepared by placing all cash inlo#s and outlo#s in the maturity ladder according to the e+pected timing o cash lo#s6 $ maturing liability #ill be a cash outlo# #hile a maturing asset #ill be a cash inlo#6 It #ould also be necessary to take into account the rupee inlo#s and outlo#s on account o ore+ operations6 7hus5 the oreign currency resources raised abroad but s#apped into rupees and deployed in rupee assets5 #ould be relected in the rupee li8uidity statement6 Some o the "Is have the practice o disbursing rupee loans to their e+porter clients but denominating such loans in oreign currency in their books #hich are e+tinguished by the e+port proceeds6 Such oreign currency denominated loans too #ould be a part o rupee li8uidity statement since such loans are created out o rupee resources6 $s regards the oreign currency loans granted out o oreign currency resources on a back1to1 back basis5 a currency1#ise li8uidity statement or each o the oreign currencies in #hich liabilities and assets have been created6 Curre(cy ,i*9
"loating e+change rate arrangement has brought in its #ake pronounced volatility adding a ne# dimension to the risk proile o "Is9 balance sheets6 7he increased capital lo#s across ree economies ollo#ing deregulation have contributed to increase in the volume o transactions6 Large cross border lo#s 14 together #ith the volatility has rendered the "IsK balance sheets vulnerable to e+change rate movements6 Fealing in dierent currencies brings opportunities as also risks6 I the liabilities in one currency e+ceed the level o assets in the same currency5 then the currency mismatch can add value or erode value depending upon the currency movements6 %ismatched currency position5 besides e+posing the balance sheet to movements in e+change rate5 also e+poses it to country risk and settlement risk6 "Is undertake operations in oreign e+change such as borro#ings and making loans in oreign currency5 #hich e+poses them to currency or e+change rate risk6 7he simplest #ay to avoid currency risk is to ensure that mismatches5 i any5 are reduced to ;ero or near ;ero6 .o#ever5 irrespective o the strategies adopted5 it may not be possible to eliminate currency mismatches altogether6 $t present5 only ive "Is (vi;6 24I% 0ank5 I!I!I5 IF0I5 I"!I and II0I) have been granted by R0I (2!F) restricted authorisation to deal in oreign e+change under "2R$ *=&3 #hile other "Is are not authorised to deal in oreign e+change6 7he "Is are5 thereore5 unlike banks5 are not subject to the ull rigour o the reporting re8uirements under 2+change !ontrol regulations6 .ence5 the %$P and SIR statements prescribed or banks vide $F (%$ Series) circular no6 5, dated ,& Fecember *==& issued by R0I (2!F)5 are not applicable to "Is6 In order5 ho#ever5 to capture the li8uidity and interest rate risk inherent in the oreign currency portolio o the "Is5 it #ould be necessary to compile5 on an ongoing basis5 curre(cy-8i*e Statement o Li8uidity and IRS Statement5 separately or each o the currencies in #hich the "Is have an e+posure6 I(tere*t ,ate ,i*9 >I,,? Interest rate risk is the risk #here changes in market interest rates might adversely aect a "IKs inancial condition6 7he immediate impact o changes in interest rates is on "IKs earnings (i6e6 reported proits) by changing its Det Interest Income (DII)6 $ long1term impact o changing interest rates is on "IKs %arket Malue o 28uity (%M2) or Det :orth as the economic value o bank9s 17 assets5 liabilities and o1balance sheet positions get aected due to variation in market interest rates6 7he interest rate risk #hen vie#ed rom these t#o perspectives is kno#n as Learnings perspective9 and Leconomic value9 perspective5 respectively6 7he risk rom the earnings perspective can be measured as changes in the Det Interest Income (DII) or Det Interest %argin (DI%)6 7here are many analytical techni8ues or measurement and management o Interest Rate Risk6 In the conte+t o poor %IS5 slo# pace o computerisation in "Is5 the traditional 'ap analysis is considered to be a suitable method to measure the Interest Rate Risk in the initial phase o the $L% system6 .o#ever5 the "Is5 #hich are better e8uipped5 #ould have the option o deploying advanced IRR management techni8ues #ith the approval o their 0oard @ $L!O5 in addition to the 'ap $nalysis prescribed under the guidelines6 It is the intention o R0I to move over to the modern techni8ues o Interest Rate Risk measurement like Furation 'ap $nalysis5 Simulation and Malue at Risk over time #hen "Is ac8uire suicient e+pertise and sophistication in ac8uiring and handling %IS6 7he 'ap or %ismatch risk can be measured by calculating 'aps over dierent time intervals as at a given date6 'ap analysis measures mismatches bet#een rate sensitive liabilities and rate sensitive assets (including o1balance sheet positions)6 $n asset or liability is normally classiied as rate sensitive iB i) #ithin the time interval under consideration5 there is a cash lo#? ii) the interest rate resets@reprices contractually during the interval? iii) it is contractually pre1payable or #ithdra#able beore the stated maturities? iv) It is dependent on the changes in the 0ank Rate by R0I6 7he 'ap Report should be generated by grouping rate sensitive liabilities5 assets and o1balance sheet positions into time buckets according to residual maturity or ne+t re1pricing period5 #hichever is earlier6 $ll investments5 advances5 deposits5 borro#ings5 purchased unds5 etc6 that mature@re1price #ithin a speciied timerame are interest rate sensitive6 Similarly5 any principal repayment o loan is also rate sensitive i the "I e+pects to receive it #ithin the 18 time hori;on6 7his includes inal principal repayment and interim instalments6 !ertain assets and liabilities carry loating rates o interest that vary #ith a reerence rate and hence5 these items get re1priced at pre1determined intervals6 Such assets and liabilities are rate sensitive at the time o re1pricing6 :hile the interest rates on term deposits and bonds are generally i+ed during their currency5 the interest rates on advances could be re1priced any number o occasions5 on the pre1determined reset @ re1pricing dates and the ne# rate #ould normally correspond to the changes in PLR6 7he interest rate gaps may be identiied in the ollo#ing time bucketsB i) *1,- days ii) ,= days and upto 3 months iii) Over 3 months and upto 3 months iv) Over 3 months and upto * year v) Over * year and upto 3 years vi) Over 3 years and upto 5 years vii) Over 5 years and upto & years viii) Over & years and upto */ years i+) Over */ years +) Don1sensitive 7he various items o rate sensitive assets and liabilities and o1balance sheet items may be classiied into various time1buckets5 7he 'ap is the dierence bet#een Rate Sensitive $ssets (RS$) and Rate Sensitive Liabilities (RSL) or each time bucket6 7he positive 'ap indicates that it has more RS$s than RSLs #hereas the negative 'ap indicates that it has more RSLs6 7he 'ap reports indicate #hether the institution is in a position to beneit rom rising interest rates by having a positive 'ap (RS$ N RSL) or #hether it is in a position to beneit rom declining interest rates by a negative 'ap (RSL N RS$)6 7he 'ap can5 thereore5 be used as a measure o interest rate sensitivity6 2ach "I should set prudential limits on interest rate gaps in various time buckets #ith the approval o the 0oard@$L!O6 Such prudential limits should have a relationship #ith the T'ta) A**et*@ Ear(i(0 A**et* 'r E=uityA In 1/ addition to the interest rate gap limits5 the "Is #hich are better e8uipped #ould have the option o setting the prudential limits in terms o 2arnings at Risk (2aR) or Det Interest %argin (DI%) based on their vie#s on interest rate movements #ith the approval o the 0oard@$L!O6 7he classiication o various components o assets and liabilities into dierent time buckets or preparation o 'ap reports (Li8uidity and Interest Rate Sensitivity) as indicated in $ppendices I O II is the /e(chmar96 "Is #hich are better e8uipped to reasonably estimate the behavioural pattern5 embedded options5 rolls1in and rolls1out5 etc o various components o assets and liabilities on the basis o past data @ empirical studies could classiy them in the appropriate time buckets5 subject to approval rom the $L!O @ 0oard6 $ copy o the note approved by the $L!O @ 0oard may be sent to the Fepartment o 0anking Supervision5 "inancial Institutions Fivision6 7he impact o embedded options (i6e6 the customers e+ercising their options or premature closure o term deposits5 premature encashment o bonds and pre1 payment o loans and advances) on the li8uidity and interest rate risks proile o "Is and the magnitude o embedded option risk during the periods o volatility in market interest rates5 is 8uite substantial6 "Is should thereore evolve suitable mechanism5 supported by empirical studies and behavioural analysis5 to estimate the uture behaviour o assets5 liabilities and o1balance sheet items to changes in market variables and estimate the impact o embedded options6 In the absence o ade8uate historical database5 the entire amount payable under the embedded options should be slotted as per the residual period to the earliest e+ercise date6 $ scientiically evolved internal transer pricing model by assigning values on the basis o current market rates to unds provided and unds used is an important component or eective implementation o $L% System6 7he transer price mechanism can enhance the management o margin i6e6 lending or credit spread5 the unding or liability spread and mismatch spread6 It also helps centralising interest rate risk at one place #hich acilitate eective control and management o interest rate risk6 $ #ell deined transer pricing system also provide a rational rame#ork or pricing o assets and liabilities6 1- ,E2IEW O7 EXISTING LITE,AT1,E S1MMA,3 7he article is remark rom :lliam C %cFonough on risk management5 supervision and the ne# 0asel $ccord6 $ccording to the article in recent times the are ail to develop the commitment to manage risk appropriately to avoid this recent past re8uires a clear and consisted message5 as #ell as transparent pattern o behaviour6 $lso according to #illiam the #ork o inancial supervision is moving a#ay rom a purely retrospective5rules based approach6this is particularly in banking #orld60anks supervisor in many countries around the #orld are assessing the saety and soundness o banks based les on the strength o the balance sheet today5 and more on the strength o controls that #ill saeguard bank inancial health tomorro# but :illiam C believed that evaluating the strength o control is5 in itsel5 not enough in deed inancial sector re8uired innovation in the good and services oered6 $lso the member o basel committee believes that public policy can best support the enhancement o risk management by building incentives directly to their system o supervision6 $ccording to :illiam C the #hole article based on ho# supervisor have #orked to embrace and encourage the developments5 ho# enhancement in banks risk management processes5 driven by business imperatives5 have concurrently led supervisor to move to a more process1 oriented5 risk ocused approach to supervision6 Secondly ho# provision in De# 0asel $ccord support urther changes in there supervisory approach5 and promote urther enhancement in risk management o market risk and thirdly ho# those development #ill be coming together in there supervisory approach going or#ard1particularly in terms o there supervisory e+pections or management o market risk5 credit risk and operational risk by large banking organi;ation6 1. Summary ': artic)e 7he ollo#ing article has been delivered by Fr Rakesh %ohan5 Feputy 'overner o the Reserve 0ank o India6 7he article highlight the need to #ork to#ard reducing the real lending rates o banks6 $lso it ocused on the need to increase credit to S%2s as also look into aspects o creating an enabling environment or long term inancing6 7he article also state about the DP$s level 5the absolute amount o DP$s continues to be a major drag on the perormance o banks6 7he large volume o DP$s relects both an overhang o past dues and on1going problems o resh accretion6 7hereore reducing in DP$ level and appropriate risk management by banks #ould go a long #ay in improving eiciency o banks and inculcating a sound credit culture 02 CHAPTER 3 01 6ISTO,3 AND G,OWT6 O7 ICICI .ANK I!I!I 0ank Ltd6 #as ormed in *==4 as a ne# private sector bank6 Its initial e8uity capital o Rs *5/ crores #as ully subscribed by I!I!I5 and as a result5 I!I!I 0ank became a #holly o#ned subsidiary o I!I!I6 In %ay *==45 #hen I!I!I obtained its commercial banking license to establish I!I!I 0ank5 the Reserve 0ank o India (R0I) imposed a condition regarding dilution o promoter9s holding in the bank6 7his condition re8uired I!I!I to reduce its shareholding in I!I!I 0ank in stages5 irst to not more than &5P o its e8uity share capital5 and ultimately to not more than 4/P6 7his took place in the ollo#ing #aysB 3ear >73? Eve(t Am'u(t ,ai*e- >,*A? 6')-i(0 ': ICICI *==- IPO o *5 million e8uity shares o Rs6 */ each at a price o Rs6 35 per share 5,65 crores &46-/P ,/// $FR issue on DES2 or <SQ*&5 million &3364 crores 3,6,/P ,//* $c8uisition o 0ank o %adura (0O%)B , e8uity shares in lieu o every * share o 0O% ,33 crores 5563/P Fisinvestment o shares by I!I!I *=63= crores 4364/P ,//, Fisinvestment o shares by I!I!I /6-- crores 43P(on $ugust ,//,) Furing ,//*5 the senior managements o I!I!I and I!I!I 0ank e+plored the possibility amalgamation o I!I!I #ith I!I!I 0ank6 $s a bank5 I!I!I #ould have the ability to accept lo#1cost demand deposits and oer #ider range on products and services6 In vie# o such beneits and R0I9s guidelines on universal banking5 I!I!I e+plored various corporate restructuring alternatives or its transormation into a universal bank6 Subse8uently5 the shareholders o both the institutions approved such amalgamation and the e+change ratio 01 determined #as * ully paid1up e8uity share o I!I!I 0ank in lieu o , ully paid1 up e8uity shares o I!I!I6 $s a result o such amalgamation5 #hich #as approved by R0I on $pril ,35 ,//,5 the paid1up capital increased to Rs6 3*3 crores6 7he scheme o amalgamation became eective on %ay 35 ,//,6 R0I approved the merger subject to the ollo#ing major conditionsB !ompliance #ith Reserve Re8uirementsB I!I!I 0ank #ould comply #ith the !ash Reserve Re8uirements (!RR) and Statutory Li8uidity Reserve (SLR) Re8uirements as applicable to banks on the net demand and time liabilities o the bank5 inclusive o the liabilities pertaining to I!I!I rom the date o merger6 Other Prudential DormsB I!I!I 0ank #ill continue to comply #ith all prudential re8uirements and other instructions as applicable to banks issued by R0I rom time to time on the entire portolio o assets and liabilities o the bank ater the merger6 Priority Sector LendingB considering that the advances o I!I!I #ere not subject to the re8uirement applicable to banks in respect o priority sector lending5 I!I!I 0ank #ould ater merger5 maintain an additional */P over and above the re8uirement o 4/P5 i6e65 a total o 5/P o the net bank credit on the residual portion o the bank9s advances6 7his additional */P #ill apply until such time as the aggregate priority sector advances reaches a level o 4/P o the total net bank credit6 28uity 2+posure !eiling o 5PB 7he investments o I!I!I ac8uired by #ay o project inance as on the date o merger #ould be kept outside the e+posure ceiling o 5P o advances to#ards e+posure to e8uity and e8uity1linked instruments or a period o 5 years6 I!I!I 0ank should5 ho#ever5 mark1to1market the above instruments and provide or any loss in their value in the manner prescribed or investments6 00 "ollo#ing the amalgamation5 I!I!I 0ank has become the second largest among all scheduled commercial banks (S!0s) in India5 ranked on the basis o their total assets5 coming ater the State 0ank o India6 $t end1"E,//,5 I!I!I 0ank had a net#ork o 35= branches and 44 e+tension counters in ,5* centers across several India states6 Dearly 5*P (*-3 branches) o I!I!I9s branches are in urban@metropolitan areas6 7he balance is in rural@semi1urban areas6 7ill this time I!I!I 0ank had also installed *5/// $7%s6 S1.SIDIA,IES $t end1"E,//*5 I!I!I 0ank had no subsidiaries6 !onse8uent to the merger5 I!I!I9s subsidiary companies have become subsidiaries o I!I!I 0ank6 $t end1 "E,//,5 I!I!I 0ank had ** subsidiaries6 7he major subsidiaries are described belo#B *6 I!I!I Securities and "inance !o6 Ltd6 1 perorms key merchant baking activities including under#riting5 placement o debt and e8uity5 issue management and corporate advisory services6 ,6 I!I!I 0rokerage Services Ltd6 J engaged in security brokerage activities on DS2 and 0S26 36 I!I!I Securities .oldings Inc6 J incorporated in the <S5 this arm has been set up to provide investment banking services to investors in the <S #ho #ish to enter the Indian inancial market and to investors in India #ho #ish to enter the inancial markets in the <S6 46 I!I!I Securities Inc6 J incorporated in the <S5 this subsidiary has been set up to provide brokerage5 research and investment banking services to investors in the <S #ho #ish to enter the Indian inancial markets6 56 I!I!I Menture "unds %anagement !o6 Ltd6 J provides venture capital unding to a #ide spectrum o industrial sectors6 36 I!I!I Prudential Lie Insurance !o6 Ltd6 J carries out the business o Lie Insurance6 7his subsidiary has entered into an %o< #ith I!I!I 0ank or 04 distribution o its lie insurance policies through the bank9s branch net#ork6 &6 I!I!I Lombard 'eneral Insurance !o6 Ltd6 J carries out the business o general insurance6 -6 I!I!I .ome "inance !o6 Ltd6 J provides inance or housing6 07 MANAGEMENT 7he management team o I!I!I 0ank consists o the ollo#ing individuals #ho are very #ell 8ualiied5 possess rich e+perience and are competent proessionals rom their ield6 Name De*i0(ati'( %r6 R6M6 Ramath %anaging Firector O !2O %r6 .6D6 Sinor Coint %anaging Firector? In charge o domestic banking %s6 Lalita F6 'upte Coint %anaging Firector? In charge o international business %s6 Ralpana %orparia 2+ecutive Firector? In charge o legal department %r6 S6 %ukherji 2+ecutive Firector? In charge project inance %s6 !handa F6 Rochhar 2+ecutive Firector5 In charge o retail banking Fr6 Dachiket %or 2+ecutive Firector5 In charge o #holesale banking .1SINESS + O4E,ATIONS I!I!I 0ank9s asset base o Rs6 *5/4* billion (at end "E,//,) places it as the second largest scheduled commercial bank in India J behind only State 0ank o India (S0I)6 I!I!I 0ank9s asset base is nearly 464 times larger than the second1 largest ne# private sector bank in India J .F"! 0ank (assets o Rs6 ,3- billion as end1"E,//,)6 I!I!I 0ank9s principal activities include corporate banking5 retail banking and treasury operations6 ,ELATIONS6I4 WIT6 T6E GO2E,NMENT 7he 'oI has never directly held any shares o I!I!I 0ank6 .o#ever5 'oI9s controlled institutions held a ,/6-P stake in I!I!I 0ank at end $ugust ,//,6 7hese include the LI! (-63P)5 the 'I! and it9s subsidiaries (&63P)5 <7I (363P)5 and others (*63P)6 <nder the terms o the loan and guarantee acilities provided by the 'oI to I!I!I that have been transerred to I!I!I 0ank5 the 'oI 08 is entitled to appoint and has appointed one representative to the 0oF o I!I!I 0ank6 !omparison o key ratios is done on the basis o previous year and the current year6 0/ ,ISK MANAGEMENT AT ICICI Risk is an inherent part o I!I!I 0ank9s business5 and eective Risk !ompliance O $udit 'roup is critical to achieving inancial soundness and proitability6 I!I!I 0ank has identiied Risk !ompliance O $udit 'roup as one o the core competencies or the ne+t millennium6 7he Risk !ompliance O $udit 'roup 'roup (R! O $') at I!I!I 0ank benchmarks itsel to international best practices so as to optimise capital utilisation and ma+imise shareholder value6 :ith #ell deined policies and procedures in place5 I!I!I 0ank identiies5 assesses5 monitors and manages the principal risksB !redit risk (the possibility o loss due to changes in the 8uality o counterparties) %arket Risk (the possibility o loss due to changes in market prices and rates o securities and their levels o volatility) Operational risk (the potential or loss arising rom breakdo#ns in policies and controls5 human error5 contracts5 systems and acilities) 7he ability to implement analytical and statistical models is the true test o a risk methodology6 In addition to three departments #ithin the Risk !ompliance O $udit 'roup handling the above risks5 an $nalytics <nit develops 8uantitative techni8ues and models or risk measurement6 C,EDIT ,ISK MANAGEMENT !redit risk5 the most signiicant risk aced by I!I!I 0ank5 is managed by the !redit Risk !ompliance O $udit Fepartment (!R! O $F) #hich evaluates risk at the transaction level as #ell as in the portolio conte+t6 7he industry analysts o the department monitor all major sectors and evolve a sectoral outlook5 #hich is an important input to the portolio planning process6 7he department has done detailed studies on deault patterns o loans and prediction o deaults in the Indian conte+t6 Risk1based pricing o loans has been introduced6 7he unctions o this department includeB Revie# o !redit Origination O %onitoring !redit rating o companies@structures 0- Feault risk O loan pricing Revie# o industry sectors Revie# o large e+posures in industries@ corporate groups@ companies 2nsure %onitoring and ollo#1up by building appropriate systems such as !$S Fesign appropriate credit processes5 operating policies O procedures Portolio monitoring %ethodology to measure portolio risk !redit Risk Inormation System (!RIS) "ocussed attention to structured inancing deals Pricing5 De# Product $pproval Policy5 %onitoring %onitor adherence to credit policies o R0I Furing the year5 the department has been instrumental in reorienting the credit processes5 including delegation o po#ers and creation o suitable control points in the credit delivery process #ith the objective o improving customer response time and enhancing the eectiveness o the asset creation and monitoring activities6 $vailability o inormation on a real time basis is an important re8uisite or sound risk management6 7o aid its interaction #ith the strategic business units5 and provide real time inormation on credit risk5 the !R! O $F has implemented a sophisticated inormation system5 namely the !redit Risk Inormation System6 In addition5 the !R! O $F has designed a #eb1based system to render inormation on various aspects o the credit portolio o I!I!I 0ank6 MA,KET ,ISK COM4LIANCE + A1DIT G,O14 I!I!I 0ank is e+posed to all categories o %arket Risk5 vi;65 Interest Rate Risk (risk due to changes in interest rates) 0. 2+change Rate Risk (risk due to changes in e+change rates) 28uity Risk (risk due to change in e8uity prices) Li8uidity Risk (risk due to deterioration in market li8uidity or tradable instruments) 7he %arket Risk !ompliance O $udit Fepartment evaluates5 tests and approves market risk methodologies developed by the 7reasury6 It also participates in the ne# product approval process on a irm1#ide basis and evaluates all ne# products rom a market risk perspective O4E,ATIONAL ,ISK MANAGEMENT I!I!I 0ank5 like all large banks5 is e+posed to many types o operational risks6 7hese include potential losses caused by events such as breakdo#n in inormation5 communication5 transaction processing and settlement systems@ procedures6 7he $udit Fepartment5 an integral part o the Risk !ompliance O $udit 'roup5 ocusses on the operational risks #ithin the organisation6 In recent times5 there has been a shit in the audit ocus rom transactions to controls6 Some e+amples o this paradigm shit areB $dherence to internal policies5 procedures and documented processes Risk 0ased $udit Plan :idening o 7reasury operations audit coverage <se o !omputer $ssisted $udit 7echni8ues (!$$7s) Inormation Systems $udit Plans to develop@ buy sot#are to capture the #orklo# o the $udit Fepartment 7he $udit Fepartment conceptualised and put into operation a Risk 0ased $udit Plan during the year *==-1==6 7he Risk 0ased $udit Plan envisages allocation o audit resources in accordance #ith the risk constituents o I!I!I 0ank9s business6 42 CHAPTER 4 41 4E,7O,MANCE O7 ICICI .ANK *) !redit1Feposit (P)B 7his ratio is compared as underB :e notice that in the year *==& credit deposit ratio is 3=6-P #hich ell to ,*63&P in the year *==-6 In *=== it urther drop to **6,,P6 In ,/// it drop to *6/3P6 In the year ,//* it rose to 4655P6 In the year ,//, it rose to &/6-3P6 ,) Investment@Feposit (P)B 7his ratio is compared as underB :e notice that in the year *==& investment ratio is 33634P it rose to 36/4P in the year *==-6 In the year *=== again it rose to &6=3P6 In the year ,/// it rose to *6/,P6 In the year ,//* it rose to ,633P6In the year ,//, it rose to 4,6=3P #hich is a signiicant increase6 3) !ash @Feposit(P) B 7his ratio is compared as underB :e notice that in the year *==& !ash @deposit ratio is *,6,&P #hich ell to /63=P in the year *==-6 In the year *=== it again ell to ,633P6 In the year ,/// it ell to *64&P6In the year ,//* it again ell to /6/*P6In the year ,//, it ell to *6,4P6 4) Interest 2+pended@Interest 2arned(P)B this ratio is compared as under B :e notice that In the year *==& interest earned(P) is 346*P #hich rose to&6&-P6in the year *==-6 again it rose to 3633P6 in the year *===6 in the year ,/// it ell to /6/*P6 in the year ,//* again it ell to */6&3P6 in the year ,//, it ell to 5P6 5) Other Income@7otal Income(P) B this ratio is compared as underB :e notice that in the year *==& percentage o other income@total income is *-6=3P #hich rose to 56&5P in the year *==-6 In the year *=== it ell to */63P6 In the year ,/// there is a signiicant increase o 464&P6 in the year ,//* it ell to 36*P6 in the year ,//, It rose to 365P6 3) Operating 2+penses@7otal Income(P) B 7his ratio is compared as under B :e notice that the percentage o operating e+penses in the year *==& is *&6=-P #hich ell to *6,3P in the year *==-6In the year *=== again it ell to 41 363P6In the year ,/// it rose to /65=P6in the year ,//* it rose to -633P6in the year ,//, it rose to /6&*P6 &) Interest Income@7otal unds(P)B this ratio is compared as underB :e notice that percentage o interest income in the year *==& is *,643P #hich ell to ,6*&P in the year *==-6In the year *=== it rose to /634P6in the year ,/// it ell to *635P6in the year ,//* it ell to *6*4P6in the year ,//, it urther ell to 4633P6 -) Interest 2+pended@7otal "unds(P) B this ratio is compared as under *==&B1 &6=&P *==-B1/65=P(decrease) *===B /6=*P(increase) ,///B*6,=P(decrease) ,//*B*6&3P(decrease) ,//,B,6&5P(decrease) =) Det interest income@7otal unds(P) B 7his ratio is compared as under *==& B 4643P *==- B *65&P(decrease #hich take it to ,6-=P) *=== B /65-P(decrease #hich take it to ,63*P) ,/// B /633P( decrease) ,//* B /65=P(increase) ,//, B *65-P(decrease) */) Don interest income@total unds(P) B this ratio is compared as under *==& B,6=P *==-B/643P(increase) *===B*63,P(decrease) ,///B /63P(increase) ,//* B/63*P(decrease) ,//,B/645P(decrease) 40 **6 Operating e+pense@7otal unds(P) B this ratio is compared as under B *==& B,6&3P *==- B/64-P(decrease) *===B/633P(decrease urther) ,///B/6**P(decrease) ,//*B/653P(increase) ,//,B*6/3P(decrease) *,6) Proit beore provisions@total unds(P) B comparison o this I s done as underB *==& B 463*P *==- B/634P(decrease) *===B*654P(decrease) ,///B/6**P(increase) ,//*B/655P(decrease) ,//,B*6/*P(decrease) *36) Det Proit@7otal unds(P)B comparison o this is given as underB *==&B ,6&3P *==- B/6&5P(decrease) *===B/6&5P(decrease) ,///B/6*,P(decrease) ,//*B/6*P(decrease) ,//,B/65=P(decrease) *46) ROD:(P) B !omparison o this is done as under B *==&B,36&P *==-B*63*P(decrease) *===B/635P(decrease) 44 GA4 ANAL3SIS Out:)'8 1-1& -ay* 1!-B -ay* #-$ m'(th* $-" m'(th* "-1 year 1-$ year $-! year A/'ve ! T'ta) Dep'*it* 3*5,/3 =,*&& 4-*&/3 ,&&=/3 5&=-55 *,-=35= 4/3*- *44,* 3/=/=4- .'rr'8i(0* ==34= *4==&* 44*5,/ 3,,=3, -=4,-3 *4*3,53 3=5*3/ ,-4-,3 4//453& T'ta) 4*4-55 ,4,*4- =,3,,3 3//-3- *4&4*4* ,&/53*5 43544- ,==,44 &/=55*5 I(:)'8 L'a(*Ca-vA -,534 353=, ,55,=4 ,33*5/ 3&*/-& *3,,53, &33&33 *3&//3= 44,4*5* I(ve*tCSectA *3*==- 3-3,4 ,-=/*- ,3&53/ 5,*-&& &335&3 44&43* **55&/3 33*-&=/ T'ta) ,*453, */43*3 5443*, 5//3-/ -=,=34 ,/5=*3- *,***=4 ,5,5&&5 -/5,=4* Mi*match >.-A? 1,//,=3 1*3&-3, 13&-=*4 1*//*5- 15-**&& 13434&& &&5&43 ,,,353* *3/3=/3 'ap report indicates that there is a mismatch in the maturity buckets o *1*4 days to *13 years6 .o#ever this means RSLNRS$ this sho#s the bank in a position to beneit rom declining interest rate by a negative gap6 47 ICICI .ANK 7INANCIAL O2E,2IEW %%-%$ %%1-%$ %%%-%$ 1###-%$ 1##B-%$ 1##D-%$ 28uity Paid <p ,,/633 *=36-, *=36-, *35 *35 *5/ Det#orth 5-556= *,-=6/- **4=65* 3/-633 ,336&5 *-*6-- !apital 2mployed */4*/=6=, *=&3365= *,/&,633 3=-*63- 3,&=643 *&-*6-& 'ross 0lock 44=46,= 5-=63& 3*56*4 ,3*65& ,*-6=& **/65- Sales ,*5*6=3 *,4,6*3 -5,6-& 5446/5 ,5=6& *-,63- P0IF7 *=*,63* **//65& -,3634 53364* ,&*63& *&-6-3 P0F7 35363= ,3,6= *5363= **/6-= -46== 3*6&& P0I7 *-4-6,, */336-, &=-6-5 5*-6-- ,5&6, *&/63, P07 ,-=63 ,,36*5 *3*6= =3633 &/65, 53653 P$7 ,5-63 *3*6* */563 33633 5/6,, 4/6*3 !P 3,,63= *=&6-5 *3/6/= -/6-= 3463= 4-63& Revenue earnings in ore+ / / / / / / Revenue e+penses in ore+ / / / / / / 0ook Malue (<nit !urr) ,356&4 3565 5-64 *-63= *36*& *,6*3 %arket !apitalisation ,&3,643 3,5564 5**&63, 45,6* &556& / !2PS (annualised) (<nit !urr) *4643 =6-, 364& 46&- 36-, 36,, 2PS (annualised) (<nit !urr) **65, &6=3 56,* 36&, ,6=5 ,63- Fividend (annualisedP) ,/ ,/ *5 *, */ */ Payout (P) *&633 ,-6*4 ,46*3 3,6,3 3364 3&63- !ash "lo# "rom Operating $ctivities ,,4*6, 13=46/, */=*65& 33,6= 53-63& ,-*6- !ash "lo# "rom Investing $ctivities 1,363- 1&-63= 1536/3 14&63= 1*/56= 13/6** !ash "lo# "rom "inancing $ctivities *3*64 1,&64& &4*63& *5/6*5 3&65 1**6&3 Rate o 'ro#th (P) Det :orth (P) 3546,& *,6*4 ,&,6-, *565= 43633 *36/3 !apital 2mployed (P) 4,&65 3364- &,6=, **,6-= -46/4 536=& 'ross 0lock (P) 33,6*& -&6** ,/64- *=645 =-6/, **/6&5 Sales (P) &36,5 45634 536&3 */=64= 4,6*3 5&63* P0IF7 (P) &36&3 3363, 53655 =&645 5*6-= 3-6-3 P0F7 (P) 3464, 3&6&- 4*63 3/64& 3&65= *=36-3 P0I7 (P) &36&3 336*& 536=3 */*6&4 5/6&4 3-6,* P07 (P) ,&6=, &*643 4*6,- 3,63= 3*6&4 ,,46,3 P$7 (P) 3/634 5,6== 336*= ,36*3 ,56*4 *436/3 !P (P) 3,6=5 5,6/= 3/6-, ,56/4 336&4 *3/6** Revenue earnings / / / / / / 48 in ore+ (P) Revenue e+penses in ore+ (P) / / / / / / %arket !apitalisation (P) 1*36/3 13363- */3*6= 14/6*& / / Rey Ratios !redit1Feposit(P) ***653 4/6&3 336*- 3&6,* 4-643 3=6- Investment @ Feposit (P) =/6=5 4-6/, 45633 44634 3363- 33634 !ash @ Feposit (P) 36, &644 &645 -6=, **65- *,6,& Interest 2+pended @ Interest 2arned (P) &,644 3&644 &-6, &-6,* &*6-- 346* Other Income @ 7otal Income (P) ,*6=5 *5645 *-655 *46/- ,463- *-6=3 Operating 2+penses @ 7otal Income (P) ,,6&- ,,6/& *36&* *36*, *36&, *&6=- Interest Income @ 7otal "unds (P) 364- &6-* -6=5 */63 */6,3 *,643 Interest 2+pended @ 7otal "unds (P) ,65, 56,& & -6,= &63- &6=& Det Interest Income @ 7otal "unds (P) /6=3 ,654 *6=5 ,63* ,6-= 4643 Don Interest Income @ 7otal "unds (P) /6=- *643 ,6/4 *6&4 3633 ,6= Operating 2+penses @ 7otal "unds (P) *6/* ,6/4 *65* *63, ,6,- ,6&3 Proit beore Provisions @ 7otal "unds (P) /6=, *6=3 ,64- ,643 36=& 463* Det Proit @ 7otal unds (P) /64, *6/* *6** *6,3 *6=- ,6&3 ROD: (P) &6,3 *36,* *4645 ,,6/4 ,,63= ,36& .S ,//,/3 ,//*/3 ,////3 *===/3 *==-/3 *==&/3 !$PI7$L $DF LI$0ILI7I2S !apital S ,,/633 *=36-, *=36-, *35 *35 *5/ Reserves and Surplus S 5335654 */=,6,3 =5,63= *43633 */*6&5 3*6-- Feposits S 3,/-56** *33&-6,* =-336/, 3/&,6=4 ,3,=6/, *34&63 0orro#ings S 4-3-*6,* */3,6&= 4=*64& *==6-= *=,6,3 =,6== Other Liabilities O Provisions S *&4-&6& */3365* 535633 4//65, *=*643 *5=64 7O7$L */4*/=6=, *=&3365= *,/&,633 3=-*63- 3,&=643 *&-*6-& 4/ $SS27S !ash O 0alances #ith R0I *&&464& *,3*633 &,*6-= 4356-* 3*/6/= *5/634 0alances #ith 0anks O money at !all O Short Dotice **/**6-- ,33,6/3 ,3=36,& **&,644 53,6&= ,,,65- Investments S 35-=*6/- -*-36-3 44*363- ,-3*6,3 */,363= 435635 $dvances S 4&/346-& &/3*643 335&635 ,**/6*, **,&6-& &=- "i+ed $ssets S 4,3=634 3-46&5 ,,,6*, *==634 *-36& =363& Other $ssets S 4*5-6,- 53=6-3 33*63, *&,644 &*65= &=6,3 7O7$L */4*/=6=, *=&3365= *,/&,633 3=-*63- 3,&=643 *&-*6-& !ontingent Liabilities S 3=44365= *3-4-6/* =&-/64& 5/*36=& ,=/36,4 *4=56&3 0ills or collection *3,364, *,,=6- &3*644 43-643 ,*-6*= *,36/* 4L ,//,/3 (*,) ,//*/3 (*,) ,////3 (*,) *===/3 (*,) *==-/3 (*,) *==&/3 (*,) I6 ID!O%2 B Interest 2arned S ,*5*6=3 *,4,6*3 -5,6-& 5446/5 ,5=6& *-,63- Other Income S 3/56/, ,,36=3 *=46*= -=6*4 -56/= 4,635 7O7$L ,&536=5 *43=6/= */4&6/3 3336*= 3446&= ,,5633 II6 24P2DFI7<R2 B Interest e+pended S *55-6=, -3&63& 3336=5 4,565, *-363- **&6/= Operating 2+penses S 3,-6/= 3,46,- *43654 -36/- 5&635 4/65* Provisions O !ontingencies S 3**634 *436/4 *3*6,& 3*6,3 5/6,4 ,&63 7O7$L ,4=-635 *3/&6== =4*6&3 53=6-3 ,=465& *-56, III6 PRO"I7@LOSS Det Proit or the year ,5-63 *3*6* */563 33633 5/6,, 4/6*3 Prior Eear $djustments S / / / / / / Proit brought or#ard /6-3 /6- /6*3 /63= /6/, /63= 7O7$L ,5=6*3 *3*6= */5643 336&5 5/6,4 4/65, IM6 $PPROPRI$7IODS 7ranser to Statutory Reserves 35 -/ ,5 ,/ ,& ,565 7ranser to Other Reserves S *,3 3,65 5,6-, ,*6-4 5 / Proposed Fividend @ 7ranser to 'overnment S 4-65& 4-65& ,&64& ,*6&- *&6-5 *5 0alance c@ to 0alance Sheet *=653 /6-3 /6*4 /6*3 /63= /6/, 4- 7O7$L ,5=6*3 *3*6= */5643 336&5 5/6,4 4/65, 28uity Fividend 446/& 446/& ,46&5 *=6- *36,3 *5 !orporate Fividend 7a+ 465 465 ,6&, *6=- *63, / 28uity Fividend (P) ,/ ,/ *5 *, */ */ 2arning Per Share (Rs6)(<nit !urr6) **65, &6=3 56,* 36&, ,6=5 ,63- 0ook Malue(<nit !urr6) ,356&4 3565 5-64 *-63= *36*& *,6*3 2+traordinary Items S 1/6/3 1/6/= 1/6* 1/6/& 1/6/3 1/6/3 .S SC6ED1LES ,//,/3 ,//*/3 ,////3 *===/3 *==-/3 *==&/3 !$PI7$L $DF LI$0ILI7I2S !apital 28uity $uthorised 3// 3// 3// 3// 3// 3// Preerence !apital $uthorised / / / / / / <nclassiied $uthorised / / / / / / 28uity Issued ,,/633 *=36-, *=36-, *35 *35 *5/ 28uity Subscribed ,,/633 *=36-, *=36-, *35 *35 *5/ 28uity !alled <p ,,/633 *=36-, *=36-, *35 *35 *5/ Less B 28uity !alls in $rrears / / / / / / 28uity "oreited / / / / / / 28uity Suspense 3=,63& ,3654 / / / / $djustments to e8uity / / / / / / 28uity Paid <p ,,/633 *=36-, *=36-, *35 *35 *5/ Preerence !apital Paid <p / / / / / / <nclassiied Shares paid 1up / / / / / / 7O7$L !$PI7$L ,,/633 *=36-, *=36-, *35 *35 *5/ 28uity converted during the year / / / / / / 'FRs Issued Furing the Eear / / / / / / 0onus in 28uity / / / / / / Reserves and Surplus !ontingency Reserve / / / / / / Other Statutory Reserve ,4=643 *-4643 */36-3 &-6-3 5-6-3 3*6-3 !apital Reserves / / / / / / !apital Redemption Reserve / / / / / / Febt Redemption / / / / / / 4. Reserve Febenture Redemption Reserve */ / / / / / 2+change luctuation Reserve / / / / / / $malgamation Reserve / / / / / / Share Premium -/4654 -/4654 &3=6/3 3&65 3&65 / Revenue O other Reserves 45,463& =*6*, &=633 ,36-4 5 / Other Reserves ,&634 **634 / / / / Proit O Loss $@c *=653 /6-3 /6*4 /6*3 /63= /6/, 7O7$L R2S2RM2S 24!L<FID' R2M$L<$7IOD R2S2RM2 5335654 */=,6,3 =5,63= *43633 */*6&5 3*6-- Revaluation Reserve / / / / / / 7O7$L R2S2RM2S $DF S<RPL<S 5335654 */=,6,3 =5,63= *43633 */*6&5 3*6-- Feposits Femand Feposits ,&336*5 ,3,*6-3 *5-&64& 5&363, 3336*& 3*3633 Saving Feposits ,4=& *--/634 5336,3 ,,&6*, */36&4 4=63& 7erm O Other Feposits ,3-5*6=3 **-&56&* &&456,= 5,3=6, ,*3,6** =-*63 7O7$L F2POSI7S 3,/-56** *33&-6,* =-336/, 3/&,6=4 ,3,=6/, *34&63 0orro#ings 0orro#ings in India 1 R0I *4/6-= 3/*6,4 ,*-63& *4-64- / / 0orro#ings in India 1Other 0anks ,3-&63 3=&6- *=,6*- 4*6&& ,=6,= -/6/4 0orro#ings in India 1Other agencies =,356/= 3336&5 -/63, =634 *3,6=4 *,6=5 0orro#ings outside India ,,&/=6=& / / / / / !onvertible Febentures / / / / / / Don !onvertible Febentures *3&4464& / / / / / Partly !onvertible Febentures *336*= / / / / / Less B Febentures !alls in arrears / / / / / / 7O7$L 0ORRO:ID'S 4-3-*6,* */3,6&= 4=*64& *==6-= *=,6,3 =,6== Secured 0orro#ings included above / / / / / / Other Liabilities O Provisions 0ills Payable -*&633 3-/653 *4,6, **,6*= */&6-* 3-6&= Inter Oice $djustment (Det) 336/5 / / / / / Interest $ccrued ,,-=65* 55635 3365, ,364= *&653 563& Share $pplication *,-/6*, ,3654 / / / / 72 %oney <nclaimed Fividend / / / / / / Other Liabilities (Including Provisions) *3/3&63= 5&36&3 3-=6=* ,346-4 336/3 -46=4 7O7$L O7.2R LI$0ILI7I2S $DF PROMISIODS *&4-&6& */3365* 535633 4//65, *=*643 *5=64 7O7$L */4*/=6=, *=&3365= *,/&,633 3=-*63- 3,&=643 *&-*6-& ASSETS !ash O 0alances #ith R0I *&&464& *,3*633 &,*6-= 4356-* 3*/6/= *5/634 0alances #ith 0anks O money at !all O Short Dotice **/**6-- ,33,6/3 ,3=36,& **&,644 53,6&= ,,,65- Investments >uoted 'overnment Securities ,,&,,63* 4/&/644 ,-*46=4 *5,&633 &/463& 3*3633 Other $pproved Secutires &/643 4*64= / / / / Shares *=/-635 *,56*, *3/6=5 *3- 4&6/3 */64& Febentures O 0onds 3433633 3/&/6/- **3&6,, 33363* ,*365* 3=634 Investment in Subsidiaries 3/-6*- / / / / / <nits / / / / / / Other Investments 4*456*, -&=6&3 3/365& 5,=6,3 556*- 4,6*- 7O7$L IDM2S7%2D7S 35-=*6/- -*-36-3 44*363- ,-3*6,3 */,363= 435635 %arket Malue o >uoted Investments / / / / / / $dvances 0ills Purchased O Fiscounted ,4-46& */-&6/4 &/*63 4546=3 *4/6=, &364 !ash !redits5 Overdrat O Loans Repayable on Femand ,4/,65* 4=&/6=* ,5&&63& *3-365 -4*65= 33,6* 7erm Loans 4,*4&633 =&365* 3&-63- ,&*633 *45633 -=65 7O7$L $FM$D!2S 4&/346-& &/3*643 335&635 ,**/6*, **,&6-& &=- "i+ed $ssets Premises *4436*& ,/36/= *446&4 *3/6,* */363, ,-6-, Other "i+ed $ssets 3/5*6*, 3-365- *&/64 *3*633 **,635 -*6&3 'ross 0lock 44=46,= 5-=63& 3*56*4 ,3*65& ,*-6=& **/65- $ccumulated Fepreciation ,546=5 ,/46=, =36/, 3*6=3 356,& *46,* Det 0lock 4,3=634 3-46&5 ,,,6*, *==634 *-36& =363& !apital :ork1in1 / / / / / / 71 Progress 7O7$L "I42F $SS27S 4,3=634 3-46&5 ,,,6*, *==634 *-36& =363& 71 ,ISK MANAGEMENT G1IDELINES 7O, COMME,CIAL .ANKS I(tr'-ucti'( 0anks in the process o inancial intermediation are conronted #ith various kinds o inancial and non1inancial risks vi;65 credit5 interest rate5 oreign e+change rate5 li8uidity5 e8uity price5 commodity price5 legal5 regulatory5 reputational5 operational5 etc6 7hese risks are highly interdependent and events that aect one area o risk can have ramiications or a range o other risk categories6 7hus5 top management o banks should attach considerable importance to improve the ability to identiy5 measure5 monitor and control the overall level o risks undertaken6 7he broad parameters o risk management unction should encompassB i) organi;ational structure? ii) comprehensive risk measurement approach? iii) risk management policies approved by the 0oard #hich should be consistent #ith the broader business strategies5 capital strength5 management e+pertise and overall #illingness to assume risk? iv) guidelines and other parameters used to govern risk taking including detailed structure o prudential limits? v) strong %IS or reporting5 monitoring and controlling risks? vi) #ell laid out procedures5 eective control and comprehensive risk reporting rame#ork? vii) separate risk management rame#ork independent o operational Fepartments and #ith clear delineation o levels o responsibility or management o risk? and viii) periodical revie# and evaluation6 ,ISK MANAGEMENT ST,1CT1,E $ major issue in establishing an appropriate risk management organisation structure is choosing bet#een a centralised and decentralised structure6 7he global trend is to#ards centralising risk management #ith integrated treasury management unction to beneit rom inormation on aggregate e+posure5 70 natural netting o e+posures5 economies o scale and easier reporting to top management6 7he primary responsibility o understanding the risks run by the bank and ensuring that the risks are appropriately managed should clearly be vested #ith the 0oard o Firectors6 7he 0oard should set risk limits by assessing the bank9s risk and risk1bearing capacity6 $t organisational level5 overall risk management should be assigned to an independent Risk %anagement !ommittee or 2+ecutive !ommittee o the top 2+ecutives that reports directly to the 0oard o Firectors6 7he purpose o this top level committee is to empo#er one group #ith ull responsibility o evaluating overall risks aced by the bank and determining the level o risks #hich #ill be in the best interest o the bank6 $t the same time5 the !ommittee should hold the line management more accountable or the risks under their control5 and the perormance o the bank in that area6 7he unctions o Risk %anagement !ommittee should essentially be to identiy5 monitor and measure the risk proile o the bank6 7he !ommittee should also develop policies and procedures5 veriy the models that are used or pricing comple+ products5 revie# the risk models as development takes place in the markets and also identiy ne# risks6 7he risk policies should clearly spell out the 8uantitative prudential limits on various segments o banks9 operations6 Internationally5 the trend is to#ards assigning risk limits in terms o portolio standards or !redit at Risk (credit risk) and 2arnings at Risk and Malue at Risk (market risk)6 7he !ommittee should design stress scenarios to measure the impact o unusual market conditions and monitor variance bet#een the actual volatility o portolio value and that predicted by the risk measures6 7he !ommittee should also monitor compliance o various risk parameters by operating Fepartments6 $ prere8uisite or establishment o an eective risk management system is the e+istence o a robust %IS5 consistent in 8uality6 7he e+isting %IS5 ho#ever5 re8uires substantial upgradation and strengthening o the data collection machinery to ensure the integrity and reliability o data6 7he risk management is a comple+ unction and it re8uires specialised skills and e+pertise6 0anks have been moving to#ards the use o sophisticated models or measuring and managing risks6 Large banks and those operating in international markets should develop internal risk management models to be 74 able to compete eectively #ith their competitors6 $s the domestic market integrates #ith the international markets5 the banks should have necessary e+pertise and skill in managing various types o risks in a scientiic manner6 $t a more sophisticated level5 the core sta at .ead Oices should be trained in risk modelling and analytical tools6 It should5 thereore5 be the endeavour o all banks to upgrade the skills o sta6 'iven the diversity o balance sheet proile5 it is diicult to adopt a uniorm rame#ork or management o risks in India6 7he design o risk management unctions should be bank speciic5 dictated by the si;e5 comple+ity o unctions5 the level o technical e+pertise and the 8uality o %IS6 7he proposed guidelines only provide broad parameters and each bank may evolve their o#n systems compatible to their risk management architecture and e+pertise6 Internationally5 a committee approach to risk management is being adopted6 :hile the $sset 1 Liability %anagement !ommittee ($L!O) deal #ith dierent types o market risk5 the !redit Policy !ommittee (!P!) oversees the credit @counterparty risk and country risk6 7hus5 market and credit risks are managed in a parallel t#o1track approach in banks6 0anks could also set1up a single !ommittee or integrated management o credit and market risks6 'enerally5 the policies and procedures or market risk are articulated in the $L% policies and credit risk is addressed in Loan Policies and Procedures6 !urrently5 #hile market variables are held constant or 8uantiying credit risk5 credit variables are held constant in estimating market risk6 7he economic crises in some o the countries have revealed a strong correlation bet#een unhedged market risk and credit risk6 "ore+ e+posures5 assumed by corporates #ho have no natural hedges5 #ill increase the credit risk #hich banks run vis1A1vis their counterparties6 7he volatility in the prices o collateral also signiicantly aects the 8uality o the loan book6 7hus5 there is a need or integration o the activities o both the $L!O and the !P! and consultation process should be established to evaluate the impact o market and credit risks on the inancial strength o banks6 0anks may also consider integrating market risk elements into their credit risk assessment process6
77 C,EDIT ,ISK Lending involves a number o risks6 In addition to the risks related to credit#orthiness o the counter party5 the banks are also e+posed to interest rate5 ore+ and country risks6 !redit risk or deault risk involves inability or un#illingness o a customer or counter party to meet commitments in relation to lending5 trading5 hedging5 settlement and other inancial transactions6 7he !redit Risk is generally made up o transaction risk or deault risk and portolio risk6 7he portolio risk in turn comprises intrinsic and concentration risk6 7he credit risk o a bank9s portolio depends on both e+ternal and internal actors6 7he e+ternal actors are the state o the economy5 #ide s#ings in commodity@e8uity prices5 oreign e+change rates and interest rates5 trade restrictions5 economic sanctions5 'overnment policies5 etc6 7he internal actors are deiciencies in loan policies@administration5 absence o prudential credit concentration limits5 inade8uately deined lending limits or Loan Oicers@!redit !ommittees5 deiciencies in appraisal o borro#ers9 inancial position5 e+cessive dependence on collateral9s and inade8uate risk pricing5 absence o loan revie# mechanism and post sanction surveillance5 etc6 $nother variant o credit risk is counter party risk6 7he counter party risk arises rom non1perormance o the trading partners6 7he non1perormance may arise rom counter party9s reusal@inability to perorm due to adverse price movements or rom e+ternal constraints that #ere not anticipated by the principal6 7he counter party risk is generally vie#ed as a transient inancial risk associated #ith trading rather than standard credit risk6 7he management o credit risk should receive the top management9s attention and the process should encompassB a) %easurement o risk through credit rating@scoring? b) >uantiying the risk through estimating e+pected loan losses i6e6 the amount o loan losses that bank #ould e+perience over a chosen time hori;on (through tracking portolio behaviour over 5 or more years) and une+pected loan losses i6e6 the amount by #hich actual losses e+ceed the e+pected loss (through standard deviation o losses or the dierence bet#een e+pected loan losses and some selected target credit loss 8uantile)? c) Risk pricing on a scientiic basis? and 78 d) !ontrolling the risk through eective Loan Revie# %echanism and portolio management6 7he credit risk management process should be articulated in the bank9s L'a( 4')icy@ duly approved by the 0oard6 2ach bank should constitute a high level Cre-it 4')icy C'mmittee5 also called !redit Risk %anagement !ommittee or !redit !ontrol !ommittee etc6 to deal #ith issues relating to credit policy and procedures and to analyse5 manage and control credit risk on a bank #ide basis6 7he !ommittee should be headed by the !hairman@!2O@2F5 and should comprise heads o !redit Fepartment5 7reasury5 !redit Risk %anagement Fepartment (!R%F) and the !hie 2conomist6 7he !ommittee should5 inter alia, ormulate clear policies on standards or presentation o credit proposals5 inancial covenants5 rating standards and benchmarks5 delegation o credit approving po#ers5 prudential limits on large credit e+posures5 asset concentrations5 standards or loan collateral5 portolio management5 loan revie# mechanism5 risk concentrations5 risk monitoring and evaluation5 pricing o loans5 provisioning5 regulatory@legal compliance5 etc6 !oncurrently5 each bank should also set up !redit Risk %anagement Fepartment (!R%F)5 independent o the !redit $dministration Fepartment6 7he !R%F should enorce and monitor compliance o the risk parameters and prudential limits set by the !P!6 7he !R%F should also lay do#n risk assessment systems5 monitor 8uality o loan portolio5 identiy problems and correct deiciencies5 develop %IS and undertake loan revie#@audit6 Large banks may consider separate set up or loan revie#@audit6 7he !R%F should also be made accountable or protecting the 8uality o the entire loan portolio6 7he Fepartment should undertake portolio evaluations and conduct comprehensive studies on the environment to test the resilience o the loan portolio6 I(*trume(t* ': Cre-it ,i*9 Ma(a0eme(t !redit Risk %anagement encompasses a host o management techni8ues5 #hich help the banks in mitigating the adverse impacts o credit risk6 Cre-it Appr'vi(0 Auth'rity 2ach bank should have a careully ormulated scheme o delegation o po#ers6 7he banks should also evolve multi1tier credit approving system #here the loan 7/ proposals are approved by an L$pproval 'rid9 or a L!ommittee96 7he credit acilities above a speciied limit may be approved by the L'rid9 or L!ommittee95 comprising at least 3 or 4 oicers and invariably one oicer should represent the !R%F5 #ho has no volume and proit targets6 0anks can also consider credit approving committees at various operating levels i6e6 large branches (#here considered necessary)5 Regional Oices5 Tonal Oices5 .ead Oices5 etc6 0anks could consider delegating po#ers or sanction o higher limits to the L$pproval 'rid9 or the L!ommittee9 or better rated @ 8uality customers6 7he spirit o the credit approving system may be that no credit proposals should be approved or recommended to higher authorities5 i majority members o the L$pproval 'rid9 or L!ommittee9 do not agree on the credit#orthiness o the borro#er6 In case o disagreement5 the speciic vie#s o the dissenting member@s should be recorded6 7he banks should also evolve suitable rame#ork or reporting and evaluating the 8uality o credit decisions taken by various unctional groups6 7he 8uality o credit decisions should be evaluated #ithin a reasonable time5 say 3 J 3 months5 through a #ell1deined Loan Revie# %echanism6 4ru-e(tia) Limit* In order to limit the magnitude o credit risk5 prudential limits should be laid do#n on various aspects o creditB a) stipulate benchmark current@debt e8uity and proitability ratios5 debt service coverage ratio or other ratios5 #ith le+ibility or deviations6 7he conditions subject to #hich deviations are permitted and the authority thereor should also be clearly spelt out in the Loan Policy? b) single@group borro#er limits5 #hich may be lo#er than the limits prescribed by Reserve 0ank to provide a iltering mechanism? c) substantial e+posure limit i6e6 sum total o e+posures assumed in respect o those single borro#ers enjoying credit acilities in e+cess o a threshold limit5 say */P or *5P o capital unds6 7he substantial e+posure limit may be i+ed at "%%E 'r B%%E o capital unds5 depending upon the degree o concentration risk the bank is e+posed? d) ma+imum e+posure limits to industry5 sector5 etc6 should be set up6 7here must also be systems in place to evaluate the e+posures at reasonable 7- intervals and the limits should be adjusted especially #hen a particular sector or industry aces slo#do#n or other sector@industry speciic problems6 7he e+posure limits to sensitive sectors5 such as5 advances against e8uity shares5 real estate5 etc65 #hich are subject to a high degree o asset price volatility and to speciic industries5 #hich are subject to re8uent business cycles5 may necessarily be restricted6 Similarly5 high1 risk industries5 as perceived by the bank5 should also be placed under lo#er portolio limit6 $ny e+cess e+posure should be ully backed by ade8uate collaterals or strategic considerations? and e) banks may consider maturity proile o the loan book5 keeping in vie# the market risks inherent in the balance sheet5 risk evaluation capability5 li8uidity5 etc6 ,i*9 ,ati(0 0anks should have a comprehensive risk scoring @ rating system that serves as a single point indicator o diverse risk actors o a counterparty and or taking credit decisions in a consistent manner6 7o acilitate this5 a substantial degree o standardisation is re8uired in ratings across borro#ers6 7he risk rating system should be designed to reveal the overall risk o lending5 critical input or setting pricing and non1price terms o loans as also present meaningul inormation or revie# and management o loan portolio6 7he risk rating5 in short5 should relect the underlying credit risk o the loan book6 7he rating e+ercise should also acilitate the credit granting authorities some comort in its kno#ledge o loan 8uality at any moment o time6 7he risk rating system should be dra#n up in a structured manner5 incorporating5 inter alia5 inancial analysis5 projections and sensitivity5 industrial and management risks6 7he banks may use any number o inancial ratios and operational parameters and collaterals as also 8ualitative aspects o management and industry characteristics that have bearings on the credit#orthiness o borro#ers6 0anks can also #eigh the ratios on the basis o the years to #hich they represent or giving importance to near term developments6 :ithin the rating rame#ork5 banks can also prescribe certain level o standards or critical parameters5 beyond #hich no proposals should be 7. entertained6 0anks may also consider separate rating rame#ork or large corporate @ small borro#ers5 traders5 etc6 that e+hibit varying nature and degree o risk6 "ore+ e+posures assumed by corporates #ho have no natural hedges have signiicantly altered the risk proile o banks6 0anks should5 thereore5 actor the unhedged market risk e+posures o borro#ers also in the rating rame#ork6 7he overall score or risk is to be placed on a numerical scale ranging bet#een *135 *1-5 etc6 on the basis o credit 8uality6 "or each numerical category5 a 8uantitative deinition o the borro#er5 the loan9s underlying 8uality5 and an analytic representation o the underlying inancials o the borro#er should be presented6 "urther5 as a prudent risk management policy5 each bank should prescribe the minimum rating belo# #hich no e+posures #ould be undertaken6 $ny le+ibility in the minimum standards and conditions or rela+ation and authority thereor should be clearly articulated in the Loan Policy6 7he credit risk assessment e+ercise should be repeated biannually (or even at shorter intervals or lo# 8uality customers) and should be delinked invariably rom the regular rene#al e+ercise6 7he updating o the credit ratings should be undertaken normally at 8uarterly intervals or at least at hal1yearly intervals5 in order to gauge the 8uality o the portolio at periodic intervals6 Mariations in the ratings o borro#ers over time indicate changes in credit 8uality and e+pected loan losses rom the credit portolio6 7hus5 i the rating system is to be meaningul5 the credit 8uality reports should signal changes in e+pected loan losses6 In order to ensure the consistency and accuracy o internal ratings5 the responsibility or setting or conirming such ratings should vest #ith the Loan Revie# unction and e+amined by an independent Loan Revie# 'roup6 7he banks should undertake comprehensive study on migration (up#ard J lo#er to higher and do#n#ard J higher to lo#er) o borro#ers in the ratings to add accuracy in e+pected loan loss calculations6 ,i*9 4rici(0 Risk1return pricing is a undamental tenet o risk management6 In a risk1return setting5 borro#ers #ith #eak inancial position and hence placed in high credit 82 risk category should be priced high6 7hus5 banks should evolve scientiic systems to price the credit risk5 #hich should have a bearing on the e+pected probability o deault6 7he pricing o loans normally should be linked to risk rating or credit 8uality6 7he probability o deault could be derived rom the past behaviour o the loan portolio5 #hich is the unction o loan loss provision@charge os or the last ive years or so6 0anks should build historical database on the portolio 8uality and provisioning @ charge o to e8uip themselves to price the risk6 0ut value o collateral5 market orces5 perceived value o accounts5 uture business potential5 portolio@industry e+posure and strategic reasons may also play important role in pricing6 "le+ibility should also be made or revising the price (risk premia) due to changes in rating @ value o collaterals over time6 Large si;ed banks across the #orld have already put in place Risk $djusted Return on !apital (R$RO!) rame#ork or pricing o loans5 #hich calls or data on portolio behaviour and allocation o capital commensurate #ith credit risk inherent in loan proposals6 <nder R$RO! rame#ork5 lender begins by charging an interest mark1up to cover the e+pected loss J e+pected deault rate o the rating category o the borro#er6 7he lender then allocates enough capital to the prospective loan to cover some amount o une+pected loss1 variability o deault rates6 'enerally5 international banks allocate enough capital so that the e+pected loan loss reserve or provision plus allocated capital covers ==P o the loan loss outcomes6 7here is5 ho#ever5 a need or comparing the prices 8uoted by competitors or borro#ers perched on the same rating @8uality6 7hus5 any attempt at price1 cutting or market share #ould result in mispricing o risk and L$dverse Selection96 4'rt:')i' Ma(a0eme(t 7he e+isting rame#ork o tracking the Don Perorming Loans around the balance sheet date does not signal the 8uality o the entire Loan 0ook6 0anks should evolve proper systems or identiication o credit #eaknesses #ell in advance6 %ost o international banks have adopted various portolio management techni8ues or gauging asset 8uality6 7he !R%F5 set up at .ead Oice should be assigned the responsibility o periodic monitoring o the portolio6 7he portolio 8uality could be evaluated by tracking the migration 81 (up#ard or do#n#ard) o borro#ers rom one rating scale to another6 7his process #ould be meaningul only i the borro#er1#ise ratings are updated at 8uarterly @ hal1yearly intervals6 Fata on movements #ithin grading categories provide a useul insight into the nature and composition o loan book6 7he banks could also consider the ollo#ing measures to maintain the portolio 8ualityB *) stipulate 8uantitative ceiling on aggregate e+posure in speciied rating categories5 i6e6 certain percentage o total advances should be in the rating category o * to , or * to 35 , to 4 or 4 to 55 etc6? ,) evaluate the rating1#ise distribution o borro#ers in various industry5 business segments5 etc6? 3) e+posure to one industry@sector should be evaluated on the basis o overall rating distribution o borro#ers in the sector@group6 In this conte+t5 banks should #eigh the pros and cons o specialisation and concentration by industry group6 In cases #here portolio e+posure to a single industry is badly perorming5 the banks may increase the 8uality standards or that speciic industry? 4) target rating1#ise volume o loans5 probable deaults and provisioning re8uirements as a prudent planning e+ercise6 "or any deviation@s rom the e+pected parameters5 an e+ercise or restructuring o the portolio should immediately be undertaken and i necessary5 the entry1level criteria could be enhanced to insulate the portolio rom urther deterioration? 5) undertake rapid portolio revie#s5 stress tests and scenario analysis #hen e+ternal environment undergoes rapid changes (e6g6 volatility in the ore+ market5 economic sanctions5 changes in the iscal@monetary policies5 general slo#do#n o the economy5 market risk events5 e+treme li8uidity conditions5 etc6)6 7he stress tests #ould reveal undetected areas o potential credit risk e+posure and linkages bet#een dierent categories o risk6 In adverse circumstances5 there may be substantial correlation o various risks5 especially credit and market risks6 Stress testing can range rom relatively simple alterations in assumptions about one or more inancial5 structural or economic variables to the use o highly sophisticated models6 7he output o such portolio1#ide stress tests should be revie#ed by the 0oard and suitable changes may be made in prudential risk limits or 81 protecting the 8uality6 Stress tests could also include contingency plans5 detailing management responses to stressul situations6 3) introduce discriminatory time schedules or rene#al o borro#er limits6 Lo#er rated borro#ers #hose inancials sho# signs o problems should be subjected to rene#al control t#ice@thrice an year6 0anks should evolve suitable rame#ork or monitoring the market risks especially ore+ risk e+posure o corporates #ho have no natural hedges on a regular basis6 0anks should also appoint Portolio %anagers to #atch the loan portolio9s degree o concentrations and e+posure to counterparties6 "or comprehensive evaluation o customer e+posure5 banks may consider appointing Relationship %anagers to ensure that overall e+posure to a single borro#er is monitored5 captured and controlled6 7he Relationship %anagers have to #ork in coordination #ith the 7reasury and "ore+ Fepartments6 7he Relationship %anagers may service mainly high value loans so that a substantial share o the loan portolio5 #hich can alter the risk proile5 #ould be under constant surveillance6 "urther5 transactions #ith ailiated companies@groups need to be aggregated and maintained close to real time6 7he banks should also put in place ormalised systems or identiication o accounts sho#ing pronounced credit #eaknesses #ell in advance and also prepare internal guidelines or such an e+ercise and set time rame or deciding courses o action6 %any o the international banks have adopted credit risk models or evaluation o credit portolio6 7he credit risk models oer banks rame#ork or e+amining credit risk e+posures5 across geographical locations and product lines in a timely manner5 centralising data and analysing marginal and absolute contributions to risk6 7he models also provide estimates o credit risk (une+pected loss) #hich relect individual portolio composition6 7he $ltman9s T Score orecasts the probability o a company entering bankruptcy #ithin a *,1 month period6 7he model combines ive inancial ratios using reported accounting inormation and e8uity values to produce an objective measure o borro#er9s inancial health6 C6 P6 %organ has developed a portolio model LCreditMetrics or evaluating credit risk6 7he model basically ocus on estimating the volatility in the value o assets caused by variations in the 8uality 80 o assets6 7he volatility is computed by tracking the probability that the borro#er might migrate rom one rating category to another (do#ngrade or upgrade)6 7hus5 the value o loans can change over time5 relecting migration o the borro#ers to a dierent risk1rating grade6 7he model can be used or promoting transparency in credit risk5 establishing benchmark or credit risk measurement and estimating economic capital or credit risk under R$RO! rame#ork6 !redit Suisse developed a statistical method or measuring and accounting or credit risk #hich is kno#n as Cre-it,i*9FA 7he model is based on actuarial calculation o e+pected deault rates and une+pected losses rom deault6 7he banks may evaluate the utility o these models #ith suitable modiications to Indian environment or ine1tuning the credit risk management6 7he success o credit risk models impinges on time series data on historical loan loss rates and other model variables5 spanning multiple credit cycles6 0anks may5 thereore5 endeavour building ade8uate database or s#itching over to credit risk modelling ater a speciied period o time6 L'a( ,evie8 Mecha(i*m >L,M? LR% is an eective tool or constantly evaluating the 8uality o loan book and to bring about 8ualitative improvements in credit administration6 0anks should5 thereore5 put in place proper Loan Revie# %echanism or large value accounts #ith responsibilities assigned in various areas such as5 evaluating the eectiveness o loan administration5 maintaining the integrity o credit grading process5 assessing the loan loss provision5 portolio 8uality5 etc6 7he comple+ity and scope o LR% normally vary based on banks9 si;e5 type o operations and management practices6 It may be independent o the !R%F or even separate Fepartment in large banks6 7he main objectives o LR% could beB to identiy promptly loans #hich develop credit #eaknesses and initiate timely corrective action? to evaluate portolio 8uality and isolate potential problem areas? 84 to provide inormation or determining ade8uacy o loan loss provision? to assess the ade8uacy o and adherence to5 loan policies and procedures5 and to monitor compliance #ith relevant la#s and regulations? and to provide top management #ith inormation on credit administration5 including credit sanction process5 risk evaluation and post1sanction ollo#1 up6 $ccurate and timely credit grading is one o the basic components o an eective LR%6 !redit grading involves assessment o credit 8uality5 identiication o problem loans5 and assignment o risk ratings6 $ proper !redit 'rading System should support evaluating the portolio 8uality and establishing loan loss provisions6 'iven the importance and subjective nature o credit rating5 the credit ratings a#arded by !redit $dministration Fepartment should be subjected to revie# by Loan Revie# Oicers #ho are independent o loan administration6 0anks should ormulate Loan Revie# Policy and it should be revie#ed annually by the 0oard6 7he Policy should5 inter alia5 addressB Gua)i:icati'( a(- I(-epe(-e(ce 7he Loan Revie# Oicers should have sound kno#ledge in credit appraisal5 lending practices and loan policies o the bank6 7hey should also be #ell versed in the relevant la#s@regulations that aect lending activities6 7he independence o Loan Revie# Oicers should be ensured and the indings o the revie#s should also be reported directly to the 0oard or !ommittee o the 0oard6 7re=ue(cy a(- Sc'pe ': ,evie8* 7he Loan Revie#s are designed to provide eedback on eectiveness o credit sanction and to identiy incipient deterioration in portolio 8uality6 Revie#s o high value loans should be undertaken usually #ithin three months o 87 sanction@rene#al or more re8uently #hen actors indicate a potential or deterioration in the credit 8uality6 7he scope o the revie# should cover all loans above a cut1o limit6 In addition5 banks should also target other accounts that present elevated risk characteristics6 $t least 3/14/P o the portolio should be subjected to LR% in a year to provide reasonable assurance that all the major credit risks embedded in the balance sheet have been tracked6 Depth ': ,evie8* 7he loan revie#s should ocus onB $pproval process? $ccuracy and timeliness o credit ratings assigned by loan oicers? $dherence to internal policies and procedures5 and applicable la#s @ regulations? !ompliance #ith loan covenants? Post1sanction ollo#1up? Suiciency o loan documentation? Portolio 8uality? and Recommendations or improving portolio 8uality 7he indings o Revie#s should be discussed #ith line %anagers and the corrective actions should be elicited or all deiciencies6 Feiciencies that remain unresolved should be reported to top management6 7he Risk %anagement 'roup o the 0asle !ommittee on 0anking Supervision has released a consultative paper on Principles or the %anagement o !redit Risk6 7he Paper deals #ith various aspects relating to credit risk management6 7he Paper is enclosed or inormation o banks6 Cre-it ,i*9 a(- I(ve*tme(t .a(9i(0 Signiicant magnitude o credit risk5 in addition to market risk5 is inherent in investment banking6 7he proposals or investments should also be subjected to the same degree o credit risk analysis5 as any loan proposals6 7he 88 proposals should be subjected to detailed appraisal and rating rame#ork that actors in inancial and non1inancial parameters o issuers5 sensitivity to e+ternal developments5 etc6 7he ma+imum e+posure to a customer should be bank1#ide and include all e+posures assumed by the !redit and 7reasury Fepartments6 7he coupon on non1sovereign papers should be commensurate #ith their risk proile6 7he banks should e+ercise due caution5 particularly in investment proposals5 #hich are not rated and should ensure comprehensive risk evaluation6 7here should be greater interaction bet#een !redit and 7reasury Fepartments and the portolio analysis should also cover the total e+posures5 including investments6 7he rating migration o the issuers and the conse8uent diminution in the portolio 8uality should also be tracked at periodic intervals6 $s a matter o prudence5 banks should stipulate entry level minimum ratings@8uality standards5 industry5 maturity5 duration5 issuer1#ise5 etc6 limits in investment proposals as #ell to mitigate the adverse impacts o concentration and the risk o li8uidity6 Cre-it ,i*9 i( O::-/a)a(ce Sheet Exp'*ure 0anks should evolve ade8uate rame#ork or managing their e+posure in o1 balance sheet products like ore+ or#ard contracts5 s#aps5 options5 etc6 as a part o overall credit to individual customer relationship and subject to the same credit appraisal5 limits and monitoring procedures6 0anks should classiy their o1balance sheet e+posures into three broad categories 1 :u)) ri*9 (credit substitutes) 1 standby letters o credit5 money guarantees5 etc5 me-ium ri*9 (not direct credit substitutes5 #hich do not support e+isting inancial obligations) 1 bid bonds5 letters o credit5 indemnities and #arranties and )'8 ri*9 1 reverse repos5 currency s#aps5 options5 utures5 etc6 7he trading credit e+posure to counter parties can be measured on static (constant percentage o the notional principal over the lie o the transaction) and on a dynamic basis6 7he total e+posures to the counter parties on a dynamic basis should be the sum total oB *) the current replacement cost (unreali;ed loss to the counter party)? and 8/ ,) the potential increase in replacement cost (estimated #ith the help o MaR or other methods to capture uture volatility9s in the value o the outstanding contracts@ obligations)6 7he current and potential credit e+posures may be measured on a daily basis to evaluate the impact o potential changes in market conditions on the value o counter party positions6 7he potential e+posures also may be 8uantiied by subjecting the position to market movements involving normal and abnormal movements in interest rates5 oreign e+change rates5 e8uity prices5 li8uidity conditions5 etc6 8- INTE,-.ANK EX4OS1,E AND CO1NT,3 ,ISK $ suitable rame#ork should be evolved to provide a centralised overvie# on the aggregate e+posure on other banks6 0ank1#ise e+posure limits could be set on the basis o assessment o inancial perormance5 operating eiciency5 management 8uality5 past e+perience5 etc6 Like corporate clients5 banks should also be rated and placed in range o *155 *1-5 as the case may be5 on the basis o their credit 8uality6 7he limits so arrived at should be allocated to various operating centres and ollo#ed up and hal1yearly@annual revie#s undertaken at a single point6 Regarding e+posure on overseas banks5 banks can use the country ratings o international rating agencies and classiy the countries into lo# risk5 moderate risk and high risk6 0anks should endeavour or developing an internal matri+ that reckons the counter party and country risks6 7he ma+imum e+posure should be subjected to adherence o country and bank e+posure limits already in place6 :hile the e+posure should at least be monitored on a #eekly basis till the banks are e8uipped to monitor e+posures on a real time basis5 all e+posures to problem countries should be evaluated on a real time basis6 Mar9et ,i*9 7raditionally5 credit risk management #as the primary challenge or banks6 :ith progressive deregulation5 market risk arising rom adverse changes in market variables5 such as interest rate5 oreign e+change rate5 e8uity price and commodity price has become relatively more important6 2ven a small change in market variables causes substantial changes in income and economic value o banks6 %arket risk takes the orm oB *) Li8uidity Risk ,) Interest Rate Risk 3) "oreign 2+change Rate ("ore+) Risk 4) !ommodity Price Risk and 5) 28uity Price Risk 8. Mar9et ,i*9 Ma(a0eme(t %anagement o market risk should be the major concern o top management o banks6 7he 0oards should clearly articulate market risk management policies5 procedures5 prudential risk limits5 revie# mechanisms and reporting and auditing systems6 7he policies should address the bank9s e+posure on a consolidated basis and clearly articulate the risk measurement systems that capture all material sources o market risk and assess the eects on the bank6 7he operating prudential limits and the accountability o the line management should also be clearly deined6 7he $sset1Liability %anagement !ommittee ($L!O) should unction as the top operational unit or managing the balance sheet #ithin the perormance@risk parameters laid do#n by the 0oard6 7he banks should also set up an independent Mi--)e O::ice to track the magnitude o market risk on a real time basis6 7he %iddle Oice should comprise o e+perts in market risk management5 economists5 statisticians and general bankers and may be unctionally placed directly under the $L!O6 7he %iddle Oice should also be separated rom 7reasury Fepartment and should not be involved in the day to day management o 7reasury6 7he %iddle Oice should apprise the top management @ $L!O @ 7reasury about adherence to prudential @ risk parameters and also aggregate the total market risk e+posures assumed by the bank at any point o time6 Li=ui-ity ,i*9 Li8uidity Planning is an important acet o risk management rame#ork in banks6 Li8uidity is the ability to eiciently accommodate deposit and other liability decreases5 as #ell as5 und loan portolio gro#th and the possible unding o o1balance sheet claims6 $ bank has ade8uate li8uidity #hen suicient unds can be raised5 either by increasing liabilities or converting assets5 promptly and at a reasonable cost6 It encompasses the potential sale o li8uid assets and borro#ings rom money5 capital and ore+ markets6 7hus5 li8uidity should be considered as a deence mechanism rom losses on ire sale o assets6 /2 7he li8uidity risk o banks arises rom unding o long1term assets by short1term liabilities5 thereby making the liabilities subject to rollover or reinancing risk6 7he li8uidity risk in banks maniest in dierent dimensionsB i) 7u(-i(0 ,i*9 J need to replace net outlo#s due to unanticipated #ithdra#al@non1rene#al o deposits (#holesale and retail)? ii) Time ,i*9 1 need to compensate or non1receipt o e+pected inlo#s o unds5 i6e6 perorming assets turning into non1perorming assets? and iii) Ca)) ,i*9 1 due to crystallisation o contingent liabilities and unable to undertake proitable business opportunities #hen desirable6 7he irst step to#ards li8uidity management is to put in place an eective li8uidity management policy5 #hich5 inter alia5 should spell out the unding strategies5 li8uidity planning under alternative scenarios5 prudential limits5 li8uidity reporting @ revie#ing5 etc6 Li8uidity measurement is 8uite a diicult task and can be measured through stock or cash lo# approaches6 7he key ratios5 adopted across the banking system areB i) Loans to 7otal $ssets ii) Loans to !ore Feposits iii) Lar0e Lia/i)itie* >minus? Temp'rary I(ve*tme(t* t' Ear(i(0 A**et* >minus? Temp'rary I(ve*tme(t*5 #here large liabilities represent #holesale deposits #hich are market sensitive and temporary Investments are those maturing #ithin one year and those investments #hich are held in the trading book and are readily sold in the market? iv) 4urcha*e- 7u(-* t' T'ta) A**et*5 #here purchased unds include the entire inter1bank and other money market borro#ings5 including !ertiicate o Feposits and institutional deposits? and v) L'a( L'**e*CNet L'a(*6 /1 :hile the li8uidity ratios are the ideal indicator o li8uidity o banks operating in developed inancial markets5 the ratios do not reveal the intrinsic li8uidity proile o Indian banks #hich are operating generally in an illi8uid market6 2+periences sho# that assets commonly considered as li8uid like 'overnment securities5 other money market instruments5 etc6 have limited li8uidity as the market and players are unidirectional6 7hus5 analysis o li8uidity involves tracking o cash lo# mismatches6 "or measuring and managing net unding re8uirements5 the use o maturity ladder and calculation o cumulative surplus or deicit o unds at selected maturity dates is recommended as a standard tool6 7he ormat prescribed by R0I in this regard under $L% System should be adopted or measuring cash lo# mismatches at dierent time bands6 7he cash lo#s should be placed in dierent time bands based on uture behaviour o assets5 liabilities and o1balance sheet items6 In other #ords5 banks should have to analy;e the behavioural maturity proile o various components o on @ o1balance sheet items on the basis o assumptions and trend analysis supported by time series analysis6 0anks should also undertake variance analysis5 at least5 once in si+ months to validate the assumptions6 7he assumptions should be ine1tuned over a period #hich acilitate near reality predictions about uture behaviour o on @ o1balance sheet items6 $part rom the above cash lo#s5 banks should also track the impact o prepayments o loans5 premature closure o deposits and e+ercise o options built in certain instruments #hich oer put@call options ater speciied times6 7hus5 cash outlo#s can be ranked by the date on #hich liabilities all due5 the earliest date a liability holder could e+ercise an early repayment option or the earliest date contingencies could be crystallised6 7he dierence bet#een cash inlo#s and outlo#s in each time period5 the e+cess or deicit o unds5 becomes a starting point or a measure o a bank9s uture li8uidity surplus or deicit5 at a series o points o time6 7he banks should also consider putting in place certain prudential limits to avoid li8uidity crisisB *6 !ap on inter1bank borro#ings5 especially call borro#ings? ,6 Purchased unds vis1A1vis li8uid assets? /1 36 !ore deposits vis1A1vis !ore $ssets i6e6 !ash Reserve Ratio5 Li8uidity Reserve Ratio and Loans? 46 Furation o liabilities and investment portolio? 56 %a+imum !umulative Outlo#s6 0anks should i+ cumulative mismatches across all time bands? 36 !ommitment Ratio J track the total commitments given to corporates@banks and other inancial institutions to limit the o1balance sheet e+posure? &6 S#apped "unds Ratio5 i6e6 e+tent o Indian Rupees raised out o oreign currency sources6 0anks should also evolve a system or monitoring high value deposits (other than inter1bank deposits) say Rs6* crore or more to track the volatile liabilities6 "urther the cash lo#s arising out o contingent liabilities in normal situation and the scope or an increase in cash lo#s during periods o stress should also be estimated6 It is 8uite possible that market crisis can trigger substantial increase in the amount o dra# do#ns rom cash credit@overdrat accounts5 contingent liabilities like letters o credit5 etc6 7he li8uidity proile o the banks could be analysed on a static basis5 #herein the assets and liabilities and o1balance sheet items are pegged on a particular day and the behavioural pattern and the sensitivity o these items to changes in market interest rates and environment are duly accounted or6 7he banks can also estimate the li8uidity proile on a dynamic #ay by giving due importance toB *) Seasonal pattern o deposits@loans? ,) Potential li8uidity needs or meeting ne# loan demands5 unavailed credit limits5 loan policy5 potential deposit losses5 investment obligations5 statutory obligations5 etc6 /0 ALTE,NATI2E SCENA,IOS 7he li8uidity proile o banks depends on the market conditions5 #hich inluence the cash lo# behaviour6 7hus5 banks should evaluate li8uidity proile under dierent conditions5 vi;6 normal situation5 bank speciic crisis and market crisis scenario6 7he banks should establish benchmark or ('rma) *ituati'(5 cash lo# proile o on @ o balance sheet items and manages net unding re8uirements6 2stimating li8uidity under /a(9 *peci:ic cri*i* should provide a #orst1case benchmark6 It should be assumed that the purchased unds could not be easily rolled over? some o the core deposits could be prematurely closed? a substantial share o assets have turned into non1perorming and thus become totally illi8uid6 7hese developments #ould lead to rating do#n grades and high cost o li8uidity6 7he banks should evolve contingency plans to overcome such situations6 7he mar9et cri*i* *ce(ari' analyses cases o e+treme tightening o li8uidity conditions arising out o monetary policy stance o Reserve 0ank5 general perception about risk proile o the banking system5 severe market disruptions5 ailure o one or more o major players in the market5 inancial crisis5 contagion5 etc6 <nder this scenario5 the rollover o high value customer deposits and purchased unds could e+tremely be diicult besides light o volatile deposits @ liabilities6 7he banks could also sell their investment #ith huge discounts5 entailing severe capital loss6 C'(ti(0e(cy 4)a( 0anks should prepare !ontingency Plans to measure their ability to #ithstand bank1speciic or market crisis scenario6 7he blue1print or asset sales5 market access5 capacity to restructure the maturity and composition o assets and liabilities should be clearly documented and alternative options o unding in the event o bank9s ailure to raise li8uidity rom e+isting source@s could be clearly articulated6 Li8uidity rom the Reserve 0ank5 arising out o its reinance #indo# /4 and interim li8uidity adjustment acility or as lender o last resort should not be reckoned or contingency plans6 $vailability o back1up li8uidity support in the orm o committed lines o credit5 reciprocal arrangements5 li8uidity support rom other e+ternal sources5 li8uidity o assets5 etc6 should also be clearly established6 I(tere*t ,ate ,i*9 >I,,? 7he management o Interest Rate Risk should be one o the critical components o market risk management in banks6 7he regulatory restrictions in the past had greatly reduced many o the risks in the banking system6 Feregulation o interest rates has5 ho#ever5 e+posed them to the adverse impacts o interest rate risk6 7he Det Interest Income (DII) or Det Interest %argin (DI%) o banks is dependent on the movements o interest rates6 $ny mismatches in the cash lo#s (i+ed assets or liabilities) or repricing dates (loating assets or liabilities)5 e+pose banks9 DII or DI% to variations6 7he earning o assets and the cost o liabilities are no# closely related to market interest rate volatility6 Interest Rate Risk (IRR) reers to potential impact on DII or DI% or %arket Malue o 28uity (%M2)5 caused by une+pected changes in market interest rates6 Interest Rate Risk can take dierent ormsB Type* ': I(tere*t ,ate ,i*9 Gap 'r Mi*match ,i*9< $ gap or mismatch risk arises rom holding assets and liabilities and o1balance sheet items #ith dierent principal amounts5 maturity dates or repricing dates5 thereby creating e+posure to une+pected changes in the level o market interest rates6 /7 .a*i* ,i*9 %arket interest rates o various instruments seldom change by the same degree during a given period o time6 7he risk that the interest rate o dierent assets5 liabilities and o1balance sheet items may change in dierent magnitude is termed as basis risk6 7he degree o basis risk is airly high in respect o banks that create composite assets out o composite liabilities6 7he Loan book in India is unded out o a composite liability portolio and is e+posed to a considerable degree o basis risk6 7he basis risk is 8uite visible in volatile interest rate scenarios6 :hen the variation in market interest rate causes the DII to e+pand5 the banks have e+perienced avourable basis shits and i the interest rate movement causes the DII to contract5 the basis has moved against the banks6 Em/e--e- Opti'( ,i*9 Signiicant changes in market interest rates create another source o risk to banks9 proitability by encouraging prepayment o cash credit@demand loans@term loans and e+ercise o call@put options on bonds@debentures and@or premature #ithdra#al o term deposits beore their stated maturities6 7he embedded option risk is becoming a reality in India and is e+perienced in volatile situations6 7he aster and higher the magnitude o changes in interest rate5 the greater #ill be the embedded option risk to the banks9 DII6 7hus5 banks should evolve scientiic techni8ues to estimate the probable embedded options and adjust the 'ap statements (Li8uidity and Interest Rate Sensitivity) to realistically estimate the risk proiles in their balance sheet6 0anks should also endeavour or stipulating appropriate penalties based on opportunity costs to stem the e+ercise o options5 #hich is al#ays to the disadvantage o banks6 3ie)- Curve ,i*9 In a loating interest rate scenario5 banks may price their assets and liabilities based on dierent benchmarks5 i6e6 70s yields5 i+ed deposit rates5 call money /8 rates5 %I0OR5 etc6 In case the banks use t#o dierent instruments maturing at dierent time hori;on or pricing their assets and liabilities5 any non1parallel movements in yield curves #ould aect the DII6 7he movements in yield curve are rather re8uent #hen the economy moves through business cycles6 7hus5 banks should evaluate the movement in yield curves and the impact o that on the portolio values and income6 4rice ,i*9 Price risk occurs #hen assets are sold beore their stated maturities6 In the inancial market5 bond prices and yields are inversely related6 7he price risk is closely associated #ith the trading book5 #hich is created or making proit out o short1term movements in interest rates6 0anks #hich have an active trading book should5 thereore5 ormulate policies to limit the portolio si;e5 holding period5 duration5 deeasance period5 stop loss limits5 marking to market5 etc6/ ,ei(ve*tme(t ,i*9 <ncertainty #ith regard to interest rate at #hich the uture cash lo#s could be reinvested is called reinvestment risk6 $ny mismatches in cash lo#s #ould e+pose the banks to variations in DII as the market interest rates move in dierent directions6 Net I(tere*t 4'*iti'( ,i*9 7he si;e o nonpaying liabilities is one o the signiicant actors contributing to#ards proitability o banks6 :hen banks have more earning assets than paying liabilities5 interest rate risk arises #hen the market interest rates adjust do#n#ards6 7hus5 banks #ith positive net interest positions #ill e+perience a reduction in DII as the market interest rate declines and increases #hen interest rate rises6 7hus5 large loat is a natural hedge against the variations in interest rates6 // Mea*uri(0 I(tere*t ,ate ,i*9 0eore interest rate risk could be managed5 they should be identiied and 8uantiied6 <nless the 8uantum o IRR inherent in the balance sheet is identiied5 it is impossible to measure the degree o risks to #hich banks are e+posed6 It is also e8ually impossible to develop eective risk management strategies@hedging techni8ues #ithout being able to understand the correct risk position o banks6 7he IRR measurement system should address all material sources o interest rate risk including gap or mismatch5 basis5 embedded option5 yield curve5 price5 reinvestment and net interest position risks e+posures6 7he IRR measurement system should also take into account the speciic characteristics o each individual interest rate sensitive position and should capture in detail the ull range o potential movements in interest rates6 7here are dierent techni8ues or measurement o interest rate risk5 ranging rom the traditional %aturity 'ap $nalysis (to measure the interest rate sensitivity o earnings)5 Furation (to measure interest rate sensitivity o capital)5 Simulation and Malue at Risk6 :hile these methods highlight dierent acets o interest rate risk5 many banks use them in combination5 or use hybrid methods that combine eatures o all the techni8ues6 'enerally5 the approach to#ards measurement and hedging o IRR varies #ith the segmentation o the balance sheet6 In a #ell unctioning risk management system5 banks broadly position their balance sheet into 7rading and Investment or 0anking 0ooks6 :hile the assets in the trading book are held primarily or generating proit on short1term dierences in prices@yields5 the banking book comprises assets and liabilities5 #hich are contracted basically on account o relationship or or steady income and statutory obligations and are generally held till maturity6 7hus5 #hile the price risk is the prime concern o banks in trading book5 the earnings or economic value changes are the main ocus o banking book6 /- Tra-i(0 .''9 7he top management o banks should lay do#n policies #ith regard to volume5 ma+imum maturity5 holding period5 duration5 stop loss5 deeasance period5 rating standards5 etc6 or classiying securities in the trading book6 :hile the securities held in the trading book should ideally be marked to market on a daily basis5 the potential price risk to changes in market risk actors should be estimated through internally developed Malue at Risk (MaR) models6 7he MaR method is employed to assess potential loss that could crystalise on trading position or portolio due to variations in market interest rates and prices5 using a given conidence level5 usually =5P to ==P5 #ithin a deined period o time6 7he MaR method should incorporate the market actors against #hich the market value o the trading position is e+posed6 7he top management should put in place bank1#ide MaR e+posure limits to the trading portolio (including ore+ and gold positions5 derivative products5 etc6) #hich is then disaggregated across dierent desks and departments6 7he loss making tolerance level should also be stipulated to ensure that potential impact on earnings is managed #ithin acceptable limits6 7he potential loss in Present Malue 0asis Points should be matched by the %iddle Oice on a daily basis vis1A1vis the prudential limits set by the 0oard6 7he advantage o using MaR is that it is comparable across products5 desks and Fepartments and it can be validated through Lback testing96 .o#ever5 MaR models re8uire the use o e+tensive historical data to estimate uture volatility6 MaR model also may not give good results in e+treme volatile conditions or outlier events and stress test has to be employed to complement MaR6 7he stress tests provide management a vie# on the potential impact o large si;e market movements and also attempt to estimate the si;e o potential losses due to stress events5 #hich occur in the Htai)*H o the loss distribution6 0anks may also undertake scenario analysis #ith speciic possible stress situations (recently e+perienced in some countries) by linking hypothetical5 simultaneous and related changes in multiple risk actors present in the trading portolio to determine the impact o moves on the rest o the portolio6 MaR models could also be modiied to relect li8uidity risk dierences observed across assets over time6 International banks are no# estimating Li8uidity adjusted Malue at Risk (LaMaR) by assuming variable time /. hori;ons based on position si;e and relative turnover6 In an environment #here MaR is diicult to estimate or lack o data5 non1statistical concepts such as stop loss and gross@net positions can be used6 .a(9i(0 .''9 7he changes in market interest rates have earnings and economic value impacts on the banks9 banking book6 7hus5 given the comple+ity and range o balance sheet products5 banks should have IRR measurement systems that assess the eects o the rate changes on both earnings and economic value6 7he variety o techni8ues ranges rom simple maturity (i+ed rate) and repricing (loating rate) to static simulation5 based on current on1and1o1balance sheet positions5 to highly sophisticated dynamic modelling techni8ues that incorporate assumptions on behavioural pattern o assets5 liabilities and o1 balance sheet items and can easily capture the ull range o e+posures against basis risk5 embedded option risk5 yield curve risk5 etc6 Maturity Gap A(a)y*i* 7he simplest analytical techni8ues or calculation o IRR e+posure begins #ith maturity 'ap analysis that distributes interest rate sensitive assets5 liabilities and o1balance sheet positions into a certain number o pre1deined time1bands according to their maturity (i+ed rate) or time remaining or their ne+t repricing (loating rate)6 7hose assets and liabilities lacking deinite repricing intervals (savings bank5 cash credit5 overdrat5 loans5 e+port inance5 reinance rom R0I etc6) or actual maturities vary rom contractual maturities (embedded option in bonds #ith put@call options5 loans5 cash credit@overdrat5 time deposits5 etc6) are assigned time1bands according to the judgement5 empirical studies and past e+periences o banks6 $ number o time bands can be used #hile constructing a gap report6 'enerally5 most o the banks ocus their attention on near1term periods5 vi;6 monthly5 8uarterly5 hal1yearly or one year6 It is very diicult to take a vie# on interest rate movements beyond a year6 0anks #ith large e+posures in the -2 short1term should test the sensitivity o their assets and liabilities even at shorter intervals like overnight5 *1& days5 -1*4 days5 etc6 In order to evaluate the earnings e+posure5 interest Rate Sensitive $ssets (RS$s) in each time band are netted #ith the interest Rate Sensitive Liabilities (RSLs) to produce a repricing L'ap9 or that time band6 7he positive 'ap indicates that banks have more RS$s than RSLs6 $ positive or asset sensitive 'ap means that an increase in market interest rates could cause an increase in DII6 !onversely5 a negative or liability sensitive 'ap implies that the banks9 DII could decline as a result o increase in market interest rates6 7he negative gap indicates that banks have more RSLs than RS$s6 7he 'ap is used as a measure o interest rate sensitivity6 7he Positive or Degative 'ap is multiplied by the assumed interest rate changes to derive the 2arnings at Risk (2aR)6 7he 2aR method acilitates to estimate ho# much the earnings might be impacted by an adverse movement in interest rates6 7he changes in interest rate could be estimated on the basis o past trends5 orecasting o interest rates5 etc6 7he banks should i+ 2aR #hich could be based on last@current year9s income and a trigger point at #hich the line management should adopt on1or o1balance sheet hedging strategies may be clearly deined6 7he 'ap calculations can be augmented by inormation on the average coupon on assets and liabilities in each time band and the same could be used to calculate estimates o the level o DII rom positions maturing or due or repricing #ithin a given time1band5 #hich #ould then provide a scale to assess the changes in income implied by the gap analysis6 7he periodic gap analysis indicates the interest rate risk e+posure o banks over distinct maturities and suggests magnitude o portolio changes necessary to alter the risk proile6 .o#ever5 the 'ap report 8uantiies only the time dierence bet#een repricing dates o assets and liabilities but ails to measure the impact o basis and embedded option risks6 7he 'ap report also ails to measure the entire impact o a change in interest rate ('ap report assumes that all assets and liabilities are matured or repriced simultaneously) #ithin a given time1band and eect o changes in interest rates on the economic or -1 market value o assets5 liabilities and o1balance sheet position6 It also does not take into account any dierences in the timing o payments that might occur as a result o changes in interest rate environment6 "urther5 the assumption o parallel shit in yield curves seldom happen in the inancial market6 7he 'ap report also ails to capture variability in non1interest revenue and e+penses5 a potentially important source o risk to current income6 In case banks could realistically estimate the magnitude o changes in market interest rates o various assets and liabilities (basis risk) and their past behavioural pattern (embedded option risk)5 they could standardise the gap by multiplying the individual assets and liabilities by ho# much they #ill change or a given change in interest rate6 7hus5 one or several assumptions o standardised gap seem more consistent #ith real #orld than the simple gap method6 :ith the $djusted 'ap5 banks could realistically estimate the 2aR6 Durati'( Gap A(a)y*i* %atching the duration o assets and liabilities5 instead o matching the maturity or repricing dates is the most eective #ay to protect the economic values o banks rom e+posure to IRR than the simple gap model6 Furation gap model ocuses on managing economic value o banks by recognising the change in the market value o assets5 liabilities and o1balance sheet (O0S) items6 :hen #eighted assets and liabilities and O0S duration are matched5 market interest rate movements #ould have almost same impact on assets5 liabilities and O0S5 thereby protecting the bank9s total e8uity or net #orth6 Furation is a measure o the percentage change in the economic value o a position that #ill occur given a small change in the level o interest rates6 %easuring the duration gap is more comple+ than the simple gap model6 "or appro+imation o duration o assets and liabilities5 the simple gap schedule can be used by applying #eights to each time1band6 7he #eights are based on estimates o the duration o assets and liabilities and O0S that all into each time band6 7he #eighted duration o assets and liabilities and O0S provide a rough estimation o the changes in banks9 economic value to a given change in -1 market interest rates6 It is also possible to give dierent #eights and interest rates to assets5 liabilities and O0S in dierent time buckets to capture dierences in coupons and maturities and volatilities in interest rates along the yield curve6 In a more scientiic #ay5 banks can precisely estimate the economic value changes to market interest rates by calculating the duration o each asset5 liability and O0S position and #eigh each o them to arrive at the #eighted duration o assets5 liabilities and O0S6 Once the #eighted duration o assets and liabilities are estimated5 the duration gap can be #orked out #ith the help o standard mathematical ormulae6 7he Furation 'ap measure can be used to estimate the e+pected change in %arket Malue o 28uity (%M2) or a given change in market interest rate6 7he dierence bet#een duration o assets (F$) and liabilities (FL) is bank9s net duration6 I the net duration is positive (F$NFL)5 a decrease in market interest rates #ill increase the market value o e8uity o the bank6 :hen the duration gap is negative (FLN F$)5 the %M2 increases #hen the interest rate increases but decreases #hen the rate declines6 7hus5 the Furation 'ap sho#s the impact o the movements in market interest rates on the %M2 through inluencing the market value o assets5 liabilities and O0S6 7he attraction o duration analysis is that it provides a comprehensive measure o IRR or the total portolio6 7he duration analysis also recognises the time value o money6 Furation measure is additive so that banks can match total assets and liabilities rather than matching individual accounts6 .o#ever5 Furation 'ap analysis assumes parallel shits in yield curve6 "or this reason5 it ails to recognise basis risk6 -0 Simu)ati'( %any o the international banks are no# using balance sheet simulation models to gauge the eect o market interest rate variations on reported earnings@economic values over dierent time ;ones6 Simulation techni8ue attempts to overcome the limitations o 'ap and Furation approaches by computer modelling the bank9s interest rate sensitivity6 Such modelling involves making assumptions about uture path o interest rates5 shape o yield curve5 changes in business activity5 pricing and hedging strategies5 etc6 7he simulation involves detailed assessment o the potential eects o changes in interest rate on earnings and economic value6 7he simulation techni8ues involve detailed analysis o various components o on1and o1balance sheet positions6 Simulations can also incorporate more varied and reined changes in the interest rate environment5 ranging rom changes in the slope and shape o the yield curve and interest rate scenario derived rom %onte !arlo simulations6 7he output o simulation can take a variety o orms5 depending on users9 need6 Simulation can provide current and e+pected periodic gaps5 duration gaps5 balance sheet and income statements5 perormance measures5 budget and inancial reports6 7he simulation model provides an eective tool or understanding the risk e+posure under variety o interest rate@balance sheet scenarios6 7his techni8ue also plays an integral1planning role in evaluating the eect o alternative business strategies on risk e+posures6 7he simulation can be carried out under static and dynamic environment6 :hile the current on and o1balance sheet positions are evaluated under static environment5 the dynamic simulation builds in more detailed assumptions about the uture course o interest rates and the une+pected changes in bank9s business activity6 7he useulness o the simulation techni8ue depends on the structure o the model5 validity o assumption5 technology support and technical e+pertise o banks6 -4 7he application o various techni8ues depends to a large e+tent on the 8uality o data and the degree o automated system o operations6 7hus5 banks may start #ith the gap or duration gap or simulation techni8ues on the basis o availability o data5 inormation technology and technical e+pertise6 In any case5 as suggested by R0I in the guidelines on $L% System5 banks should start estimating the interest rate risk e+posure #ith the help o %aturity 'ap approach6 Once banks are comortable #ith the 'ap model5 they can progressively graduate into the sophisticated approaches6 7u(-* Tra(*:er 4rici(0 7he 7ranser Pricing mechanism being ollo#ed by many banks does not support good $L% Systems6 %any international banks #hich have dierent products and operate in various geographic markets have been using internal "unds 7ranser Pricing ("7P)6 "7P is an internal measurement designed to assess the inancial impact o uses and sources o unds and can be used to evaluate the proitability6 It can also be used to isolate returns or various risks assumed in the intermediation process6 "7P also helps correctly identiy the cost o opportunity value o unds6 $lthough banks have adopted various "7P rame#orks and techni8ues5 %atched "unds Pricing (%"P) is the most eicient techni8ue6 %ost o the international banks use %"P6 7he "7P envisages assignment o speciic assets and liabilities to various unctional units (proit centres) J lending5 investment5 deposit taking and unds management6 2ach unit attracts sources and uses o unds6 7he lending5 investment and deposit taking proit centres sell their liabilities to and buys unds or inancing their assets rom the unds management proit centre at appropriate transer prices6 7he transer prices are i+ed on the basis o a single curve (%I0OR or derived cash curve5 etc) so that asset1liability transactions o identical attributes are assigned identical transer prices6 7ranser prices could5 ho#ever5 vary according to maturity5 purpose5 terms and other attributes6 7he "7P provides or allocation o margin (ranchise and credit spreads) to proit centres on original transer rates and any residual spread (mismatch -7 spread) is credited to the unds management proit centre6 7his spread is the result o accumulated mismatches6 7he margins o various proit centres areB -8 Dep'*it pr':it ce(tre< 7ranser Price (7P) on deposits 1 cost o deposits J deposit insurance1 overheads6 Le(-i(0 pr':it ce(tre< Loan yields S 7P on deposits J 7P on loan inancing J cost o deposits J deposit insurance 1 overheads J loan loss provisions6 I(ve*tme(t pr':it ce(tre< Security yields S 7P on deposits J 7P on security inancing J cost o deposits J deposit insurance 1 overheads J provisions or depreciation in investments and loan loss6 7u(-* Ma(a0eme(t pr':it ce(tre< 7P on unds lent J 7P on unds borro#ed J Statutory Reserves cost J overheads6 "or illustration5 let us assume that a bank9s Feposit proit centre has raised a 3 month deposit U 365P p6a6 and that the alternative unding cost i6e6 %I0OR or 3 months and one year U -P and */65P p6a65 respectively6 Let us also assume that the bank9s Loan proit centre created a one year loan U *365P p6a6 7he ranchise (liability)5 credit and mismatch spreads o bank is as underB Proit !entres T'ta) Feposit "unds Loan Interest Income -6/ */65 *365 *365 Interest 2+penditure 365 -6/ */65 365 %argin *65 ,65 36/ &6/ Loan Loss Provision (e+pected) 1 1 *6/ *6/ Feposit Insurance /6* 1 1 /6* -/ Reserve !ost (!RR@ SLR) 1 *6/ 1 *6/ Overheads /63 /65 /63 *6& DII /6- *6/ *64 36, <nder the "7P mechanism5 the proit centres (other than unds management) are precluded rom assuming any unding mismatches and thereby e+posing them to market risk6 7he credit or counterparty and price risks are5 ho#ever5 managed by these proit centres6 7he entire market risks5 i6e interest rate5 li8uidity and ore+ are assumed by the unds management proit centre6 7he "7P allo#s lending and deposit raising proit centres determine their e+penses and price their products competitively6 Lending proit centre #hich kno#s the carrying cost o the loans needs to ocus on to price only the spread necessary to compensate the perceived credit risk and operating e+penses6 7hus5 "7P system could eectively be used as a #ay to centralise the bank9s overall market risk at one place and #ould support an eective $L% modelling system6 "7P also could be used to enhance corporate communication? greater line management control and solid base or re#arding line management6 -- 7O,EIGN EXC6ANGE >7O,EX? ,ISK 7he risk inherent in running open oreign e+change positions have been heightened in recent years by the pronounced volatility in ore+ rates5 thereby adding a ne# dimension to the risk proile o banks9 balance sheets6 "ore+ risk is the risk that a bank may suer losses as a result o adverse e+change rate movements during a period in #hich it has an open position5 either spot or or#ard5 or a combination o the t#o5 in an individual oreign currency6 7he banks are also e+posed to interest rate risk5 #hich arises rom the maturity mismatching o oreign currency positions6 2ven in cases #here spot and or#ard positions in individual currencies are balanced5 the maturity pattern o or#ard transactions may produce mismatches6 $s a result5 banks may suer losses as a result o changes in premia@discounts o the currencies concerned6 In the ore+ business5 banks also ace the risk o deault o the counter parties or settlement risk6 :hile such type o risk crystallisation does not cause principal loss5 banks may have to undertake resh transactions in the cash@spot market or replacing the ailed transactions6 7hus5 banks may incur replacement cost5 #hich depends upon the currency rate movements6 0anks also ace another risk called time1;one risk or .erstatt risk #hich arises out o time1lags in settlement o one currency in one centre and the settlement o another currency in another time1;one6 7he ore+ transactions #ith counter parties rom another country also trigger sovereign or country risk6 7'rex ,i*9 Ma(a0eme(t Mea*ure* *6 Set appropriate limits J open positions and gaps6 ,6 !lear1cut and #ell1deined division o responsibility bet#een ront5 middle and back oices6 7he top management should also adopt the MaR approach to measure the risk associated #ith e+posures6 Reserve 0ank o India has recently introduced t#o -. statements vi;6 %aturity and Position (%$P) and Interest Rate Sensitivity (SIR) or measurement o ore+ risk e+posures6 0anks should use these statements or periodical monitoring o ore+ risk e+posures6 Capita) :'r Mar9et ,i*9 7he 0asle !ommittee on 0anking Supervision (0!0S) had issued comprehensive guidelines to provide an e+plicit capital cushion or the price risks to #hich banks are e+posed5 particularly those arising rom their trading activities6 7he banks have been given le+ibility to use in1house models based on MaR or measuring market risk as an alternative to a standardised measurement rame#ork suggested by 0asle !ommittee6 7he internal models should5 ho#ever5 comply #ith 8uantitative and 8ualitative criteria prescribed by 0asle !ommittee6 Reserve 0ank o India has accepted the general rame#ork suggested by the 0asle !ommittee6 R0I has also initiated various steps in moving to#ards prescribing capital or market risk6 $s an initial step5 a risk #eight o ,65P has been prescribed or investments in 'overnment and other approved securities5 besides a risk #eight each o *//P on the open position limits in ore+ and gold6 R0I has also prescribed detailed operating guidelines or $sset1Liability %anagement System in banks6 $s the ability o banks to identiy and measure market risk improves5 it #ould be necessary to assign e+plicit capital charge or market risk6 In the mean#hile5 banks are advised to study the 0asle !ommittee9s paper on LOvervie# o the $mendment to the !apital $ccord to Incorporate %arket Risks9 J Canuary *==3 (copy enclosed)6 :hile the small banks operating predominantly in India could adopt the standardised methodology5 large banks and those banks operating in international markets should develop e+pertise in evolving internal models or measurement o market risk6 7he 0asle !ommittee on 0anking Supervision proposes to develop capital charge or interest rate risk in the banking book as #ell or banks #here the .2 interest rate risks are signiicantly above average (Loutliers9)6 7he !ommittee is no# e+ploring various methodologies or identiying Loutliers9 and ho# best to apply and calibrate a capital charge or interest rate risk or banks6 Once the !ommittee inalises the modalities5 it may be necessary5 at least or banks operating in the international markets to comply #ith the e+plicit capital charge re8uirements or interest rate risk in the banking book6 Operati'(a) ,i*9 %anaging operational risk is becoming an important eature o sound risk management practices in modern inancial markets in the #ake o phenomenal increase in the volume o transactions5 high degree o structural changes and comple+ support systems6 7he most important type o operational risk involves breakdo#ns in internal controls and corporate governance6 Such breakdo#ns can lead to inancial loss through error5 raud5 or ailure to perorm in a timely manner or cause the interest o the bank to be compromised6 'enerally5 operational risk is deined as any risk5 #hich is not categoried as market or credit risk5 or the risk o loss arising rom various types o human or technical error6 It is also synonymous #ith settlement or payments risk and business interruption5 administrative and legal risks6 Operational risk has some orm o link bet#een credit and market risks6 $n operational problem #ith a business transaction could trigger a credit or market risk6 Mea*ureme(t 7here is no uniormity o approach in measurement o operational risk in the banking system6 0esides5 the e+isting methods are relatively simple and e+perimental5 although some o the international banks have made considerable progress in developing more advanced techni8ues or allocating capital #ith regard to operational risk6 .1 %easuring operational risk re8uires both estimating the probability o an operational loss event and the potential si;e o the loss6 It relies on risk actor that provides some indication o the likelihood o an operational loss event occurring6 7he process o operational risk assessment needs to address the likelihood (or re8uency) o a particular operational risk occurring5 the magnitude (or severity) o the eect o the operational risk on business objectives and the options available to manage and initiate actions to reduce@ mitigate operational risk6 7he set o risk actors that measure risk in each business unit such as audit ratings5 operational data such as volume5 turnover and comple+ity and data on 8uality o operations such as error rate or measure o business risks such as revenue volatility5 could be related to historical loss e+perience6 0anks can also use dierent analytical or judgmental techni8ues to arrive at an overall operational risk level6 Some o the international banks have already developed operational risk rating matri+5 similar to bond credit rating6 7he operational risk assessment should be bank1#ide basis and it should be revie#ed at regular intervals6 0anks5 over a period5 should develop internal systems to evaluate the risk proile and assign economic capital #ithin the R$RO! rame#ork6 Indian banks have so ar not evolved any scientiic methods or 8uantiying operational risk6 In the absence any sophisticated models5 banks could evolve simple benchmark based on an aggregate measure o business activity such as gross revenue5 ee income5 operating costs5 managed assets or total assets adjusted or o1balance sheet e+posures or a combination o these variables6 ,i*9 M'(it'ri(0 7he operational risk monitoring system ocuses5 inter alia5 on operational perormance measures such as volume5 turnover5 settlement acts5 delays and errors6 It could also be incumbent to monitor operational loss directly #ith an analysis o each occurrence and description o the nature and causes o the loss6 .1 C'(tr') ': Operati'(a) ,i*9 Internal controls and the internal audit are used as the primary means to mitigate operational risk6 0anks could also e+plore setting up operational risk limits5 based on the measures o operational risk6 7he contingent processing capabilities could also be used as a means to limit the adverse impacts o operational risk6 Insurance is also an important mitigator o some orms o operational risk6 Risk education or amiliarising the comple+ operations at all levels o sta can also reduce operational risk6 4')icie* a(- 4r'ce-ure* 0anks should have #ell deined policies on operational risk management6 7he policies and procedures should be based on common elements across business lines or risks6 7he policy should address product revie# process5 involving business5 risk management and internal control unctions6 I(ter(a) C'(tr') One o the major tools or managing operational risk is the #ell1established internal control system5 #hich includes segregation o duties5 clear management reporting lines and ade8uate operating procedures6 %ost o the operational risk events are associated #ith #eak links in internal control systems or la+ity in complying #ith the e+isting internal control procedures6 7he ideal method o identiying problem spots is the techni8ue o sel1 assessment o internal control environment6 7he sel1assessment could be used to evaluate operational risk along#ith internal@e+ternal audit reports@ratings or R0I inspection indings6 0anks should endeavour or detection o operational problem spots rather than their being pointed out by supervisors@internal or e+ternal auditors6 .0 $long#ith activating internal audit systems5 the $udit !ommittees should play greater role to ensure independent inancial and internal control unctions6 7he 0asle !ommittee on 0anking Supervision proposes to develop an e+plicit capital charge or operational risk6 ,i*9 A00re0ati'( a(- Capita) A))'cati'( %ost o internally active banks have developed internal processes and techni8ues to assess and evaluate their o#n capital needs in the light o their risk proiles and business plans6 Such banks take into account both 8ualitative and 8uantitative actors to assess economic capital6 7he 0asle !ommittee no# recognises that capital ade8uacy in relation to economic risk is a necessary condition or the long1term soundness o banks6 7hus5 in addition to complying #ith the established minimum regulatory capital re8uirements5 banks should critically assess their internal capital ade8uacy and uture capital needs on the basis o risks assumed by individual lines o business5 product5 etc6 $s a part o the process or evaluating internal capital ade8uacy5 a bank should be able to identiy and evaluate its risks across all its activities to determine #hether its capital levels are appropriate6 7hus5 at the bank9s .ead Oice level5 aggregate risk e+posure should receive increased scrutiny6 7o do so5 ho#ever5 it re8uires the summation o the dierent types o risks6 0anks5 across the #orld5 use dierent #ays to estimate the aggregate risk e+posures6 7he most commonly used approach is the Risk $djusted Return on !apital (R$RO!)6 7he R$RO! is designed to allo# all the business streams o a inancial institution to be evaluated on an e8ual ooting6 2ach type o risks is measured to determine both the e+pected and une+pected losses using MaR or #orst1case type analytical model6 Rey to R$RO! is the matching o revenues5 costs and risks on transaction or portolio basis over a deined time period6 7his begins #ith a clear dierentiation bet#een e+pected and une+pected losses6 2+pected losses are covered by reserves and provisions and une+pected losses re8uire capital allocation #hich is determined on the principles o conidence levels5 time hori;on5 diversiication and correlation6 In this approach5 risk is measured in terms o variability o income6 .4 <nder this rame#ork5 the re8uency distribution o return5 #herever possible is estimated and the Standard Feviation (SF) o this distribution is also estimated6 !apital is thereater allocated to activities as a unction o this risk or volatility measure6 7hen5 the risky position is re8uired to carry an e+pected rate o return on allocated capital5 #hich compensates the bank or the associated incremental risk6 0y dimensioning all risks in terms o loss distribution and allocating capital by the volatility o the ne# activity5 risk is aggregated and priced6 7he second approach is similar to the R$RO!5 but depends less on capital allocation and more on cash lo#s or variability in earnings6 7his is reerred to as 2aR5 #hen employed to analyse interest rate risk6 <nder this analytical rame#ork also re8uency distribution o returns or any one type o risk can be estimated rom historical data6 2+treme outcome can be estimated rom the tail o the distribution6 2ither a #orst case scenario could be used or Standard Feviation *@,@,63= could also be considered6 $ccordingly5 each bank can restrict the ma+imum potential loss to certain percentage o past@current income or market value6 7hereater5 rather than moving rom volatility o value through capital5 this approach goes directly to current earnings implications rom a risky position6 7his approach5 ho#ever5 is based on cash lo#s and ignores the value changes in assets and liabilities due to changes in market interest rates6 It also depends upon a subjectively speciied range o the risky environments to drive the #orst case scenario6 'iven the level o e+tant risk management practices5 most o Indian banks may not be in a position to adopt R$RO! rame#ork and allocate capital to various businesses units on the basis o risk6 .7 CONCL1SION + ,ECOMMENDATION CONCL1SION So on the basis o the data provided to us #e can say that the banks are not strictly ollo#ing the $L% 'uidelines6 ,ECOMMENDATION $L!O should keep a vigil on the #orking o the banks and ensure that all the guidelines are met6 R0I should sho# the banks as to ho# the banks can beneit by ollo#ing their guidelines6 $ll the banks should provide complete inormation so that there is more transparency6 .8 .I.LIOG,A463 Re&ort9 A Roa! +a& *or I+&le+enting an Integrate! Ri5 Manage+ent $%te+ '% In!ian =an5 '% Mar 1227 >CRI$IL? in I=A =ulletin >Dan 1224?, Reerve =an5 o* In!ia, Re&ort on Tren! an! &rogre o* =an5ing in In!ia >variou %ear?, Annual Re&ort o* all 'an5 >1224C27?, I=A =ulletin >Mar 1220, Mar 1224?, Ee'ite o* all 'an5 tu!ie!, ./