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Basel ii in the United States of America
From the Basel ii Compliance Professionals Association (BCPA), the largest association of Basel ii Professionals in the world
 
Final Rule, USA: Risk-Based Capital Standards: Advanced Capital Adequacy Framework — Basel II
C. Overview of Final Rule
The final rule maintains the general risk-based capital rules’ minimum tier 1 risk based capital ratio of 4.0 percent and total risk-based capital ratio of 8.0 percent.
 
The components of tier 1 and total capital in the final rule are also the same as in the general risk-based capital rules, with a few adjustments described in more detail below.
 
The primary difference between the general risk-based capital rules and the final rule is the methodologies used for calculating risk-weighted assets.
 
Banks applying the final rule generally must use their internal risk measurement systems to calculate the inputs for determining the risk-weighted asset amounts for
 
(i) general credit risk (including wholesale and retail exposures);
 
(ii) securitization exposures;
 
(iii) equity exposures; and
 
(iv) operational risk.
 
In certain cases, however, banks must use external ratings or supervisory risk weights to determine risk-weighted asset amounts.
 
Each of these areas is discussed below.
 
Banks using the final rule also are subject to supervisory review of their capital adequacy (Pillar 2) and certain public disclosure requirements to foster transparency and market discipline (Pillar 3).
 
In addition, each bank using the advanced approaches remains subject to the tier 1 leverage ratio requirement, approaches remains subject to the prompt corrective action (PCA) thresholds.
 
Banks using the advanced approaches also remain subject to the market risk rule, where applicable.
Under the final rule, a bank must identify whether each of its on- and off-balance sheet exposures is a wholesale, retail, securitization, or equity exposure.
 
Assets that are not defined by any exposure category (and certain immaterial portfolios of exposures)
generally are assigned risk-weighted asset amounts equal to their carrying value (for onbalance
sheet exposures) or notional amount (for off-balance sheet exposures).
 
Wholesale exposures under the final rule include most credit exposures to companies, sovereigns, and other governmental entities.
 
For each wholesale exposure, a bank must assign four quantitative risk parameters:
 
PD (which is expressed as a decimal (that is, 0.01 corresponds to 1 percent) and is an estimate of the probability that an obligor will default over a one-year horizon);
 
LGD (which is expressed as a decimal and reflects an estimate of the economic loss rate if a default occurs during economic downturn conditions);
 
EAD (which is measured in dollars and is an estimate of the amount that would be owed to the bank at the time of default);
 
and M (which is measured in years and reflects the effective remaining maturity of the exposure).
 
Banks may factor into their risk parameter estimates the risk mitigating impact of collateral, credit derivatives, and guarantees that meet certain criteria.
 
Banks must input the risk parameters for each wholesale exposure into an IRB risk-based capital formula to
determine the risk-based capital requirement for the exposure.
 
Retail exposures under the final rule include most credit exposures to individuals and small credit exposures to businesses that are managed as part of a segment of exposures with similar risk characteristics and not managed on an individual-exposure basis.
 
A bank must classify each of its retail exposures into one of three retail subcategories – residential mortgage exposures; QREs, such as credit cards and overdraft lines; and other retail exposures.
 
Within these three subcategories, the bank must group exposures into segments with similar risk characteristics.
 
The bank must then assign the risk parameters PD, LGD, and EAD to each retail segment.
 
The bank may take into account the risk mitigating impact of collateral and guarantees in the segmentation
process and in the assignment of risk parameters to retail segments.
 
Like wholesale exposures, the risk parameters for each retail segment are used as inputs into an IRB risk based capital formula to determine the risk-based capital requirement for the segment.
 
For securitization exposures, the bank must apply one of three general approaches, subject to various conditions and qualifying criteria:
  • the Ratings-Based Approach (RBA), which uses external ratings to risk-weight exposures;
  • the Internal Assessment Approach (IAA), which uses internal ratings to risk-weight exposures to asset-backed commercial paper programs (ABCP programs);
  • or the Supervisory Formula Approach (SFA), which uses bank inputs that are entered into a supervisory formula to risk-weight exposures.
Securitization exposures in the form of gain-on-sale or credit enhancing interest-only strips (CEIOs) and securitization exposures that do not qualify for the RBA, the IAA, or the SFA must be deducted from regulatory capital.
 
Banks may use an internal models approach (IMA) for determining risk-based capital requirements for equity exposures, subject to certain qualifying criteria and floors.
 
If a bank does not have a qualifying internal model for equity exposures, or chooses not to use such a model, the bank must apply a simple risk weight approach (SRWA) in which publicly traded equity exposures generally are assigned a 300 percent risk weight and non-publicly traded equity exposures generally are assigned a 400 percent risk weight.
 
Under both the IMA and the SRWA, equity exposures to certain entities or made pursuant to certain statutory authorities (such as community development laws) are subject to a 0 to 100 percent risk weight.
 
Banks must develop qualifying AMA systems to determine risk-based capital requirements for operational risk.
 
Under the AMA, a bank must use its own methodology to identify operational loss events, measure its exposure to operational risk, and assess a risk-based capital requirement for operational risk.
 
Under the final rule, a bank must calculate its tier 1 and total risk-based capital ios by dividing tier 1 capital by total risk-weighted assets and by dividing total qualifying capital by total risk-weighted assets, respectively.
 
To calculate total risk weighted ets, a bank must first convert the dollar risk-based capital requirements for
exposures produced by the IRB risk-based capital approaches and the AMA into risk weighted asset amounts by multiplying the capital requirements by 12.5 (the inverse of the overall 8.0 percent risk-based capital requirement).
 
After determining the risk weighted asset amounts for credit risk and operational risk, a bank must sum these
amounts and then subtract any excess eligible credit reserves not included in tier 2 capital to determine total risk-weighted assets.
The final rule contains specific public disclosure requirements to provide important information to market participants on the capital structure, risk exposures, risk assessment processes, and, hence, the capital adequacy of a bank.
 
The public disclosure requirements apply only to the DI or bank holding company representing the top
consolidated level of the banking group that is subject to the advanced approaches, unless the entity is a subsidiary of a non-U.S. banking organization that is subject to comparable disclosure requirements in its home jurisdiction.
 
All banks subject to the rule, however, must disclose total and tier 1 risk-based capital ratios and the components of these ratios.
 
The agencies also proposed a package of regulatory reporting templates for the agencies’ use in assessing and monitoring the levels and components of bank risk-based capital requirements under the advanced approaches.
 
These templates will be finalized shortly.
The agencies are aware that the fair value option in generally accepted accounting principles as used in the United States (GAAP) raises potential risk-based capital issues not contemplated in the development of the New Accord.
 
The agencies will continue to analyze these issues and may make changes to this rule at a future date as necessary.
 
The agencies would address these issues working with the BCBS and other supervisory and regulatory authorities, as appropriate.

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