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Basel I is the round of deliberations by central bankers from around the world, and in 1988, the Basel Committee
on Banking Supervision (BCBS) in Basel, Switzerland, published a set of minimum capital requirements for
banks. This is also known as the 1988 Basel Accord, and was enforced by law in the Group of Ten (G-10) countries
in 1992. A new set of rules known as Basel II was later developed with the intent to supersede the Basel I accords.
However they were criticized by some for allowing banks to take on additional types of risk, which was
considered part of the cause of the US subprime financial crisis that started in 2008. In fact, bank regulators in the
United States took the position of requiring a bank to follow the set of rules (Basel I or Basel II) giving the more
conservative approach for the bank. Because of this it was anticipated that only the few very largest US Banks
would operate under the Basel II rules, the others being regulated under the Basel I framework. Basel III was
developed in response to the financial crisis; it does not supersede either Basel I or II, but focuses on different
issues primarily related to the risk of a bank run.
Background
The Committee was formed in response to the messy liquidation of Cologne-based Herstatt Bank in 1973. On 26
June 1974 a number of banks had released Deutschmarks (the German currency) to the Herstatt Bank in exchange
for dollar payments deliverable in New York. Due to differences in the time zones, there was a lag in the dollar
payment to the counterparty banks; during this lag period, before the dollar payments could be effected in New
York, the Herstatt Bank was liquidated by German regulators.
This incident prompted the G-10 nations to form the Basel Committee on Banking Supervision in late 1974, under
the auspices of the Bank for International Settlements (BIS) located in Basel, Switzerland.
Main Framework
Basel I, that is, the 1988, Basel Accord, is primarily focused on credit risk and appropriate risk-weighting of assets.
Assets of banks were classified and grouped in five categories according to credit risk, carrying risk weights of 0%
(for example cash, bullion, home country debt like Treasuries), 20% (securitisations such as mortgage-backed
securities (MBS) with the highest AAA rating) 50%, 100% (for example, most corporate debt), and some assets
given No rating. Banks with an international presence are required to hold capital equal to 8% of their riskweighted assets (RWA).
The tier 1 capital ratio = tier 1 capital / all RWA
The total capital ratio = (tier 1 + tier 2 + tier 3 capital) / all RWA
Leverage ratio = total capital/average total assets
Banks are also required to report off-balance-sheet items such as letters of credit, unused commitments, and
derivatives. These all factor into the risk weighted assets. The report is typically submitted to the Federal Reserve
Bank as HC-R for the bank-holding company and submitted to the Office of the Comptroller of the
Currency (OCC) as RC-R for just the bank.
From 1988 this framework was progressively introduced in member countries of G-10, comprising 13 countries as
of 2013: Belgium, Canada, France, Germany, Italy, Japan, Luxembourg,Netherlands, Spain, Sweden, Switzerland,
United Kingdom and the United States of America.
Over 100 other countries also adopted, at least in name, the principles prescribed under Basel I. The efficacy with
which the principles are enforced varies, even within nations of the Group.
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BASEL II
Basel II
Banking
Monetary policy
Central bank
Risk
Risk management
Regulatory capital
Tier 1
Tier 2
Pillar 1: Regulatory Capital
Credit risk
Standardized
IRB Approach
F-IRB
A-IRB
PD
LGD
EAD
Operational risk
Basic
Standardized
AMA
Market risk
Duration
Value at risk
Pillar 2: Supervisory Review
Economic capital
Liquidity risk
Legal risk
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Disclosure
BASEL II is the second of the Basel Accords, (now extended and effectively superseded[clarification needed] by Basel III),
which are recommendations on banking laws and regulations issued by the Basel Committee on Banking
Supervision.
Basel II, initially published in June 2004, was intended to create an international standard for banking regulators
to control how much capital banks need to put aside to guard against the types of financial and operational risks
banks (and the whole economy) face. One focus was to maintain sufficient consistency of regulations so that this
does not become a source of competitive inequality amongst internationally active banks. Advocates of Basel II
believed that such an international standard could help protect the international financial system from the types
of problems that might arise should a major bank or a series of banks collapse. In theory, Basel II attempted to
accomplish this by setting up risk and capital management requirements designed to ensure that a bank
has adequate capital for the risk the bank exposes itself to through its lending and investment practices. Generally
speaking, these rules mean that the greater risk to which the bank is exposed, the greater the amount of capital
the bank needs to hold to safeguard its solvency and overall economic stability.
Politically, it was difficult to implement Basel II in the regulatory environment prior to 2008, and progress was
generally slow until that year's major banking crisis caused mostly by credit default swaps, mortgage-backed
security markets and similar derivatives. As Basel III was negotiated, this was top of mind, and accordingly much
more stringent standards were contemplated, and quickly adopted in some key countries including the USA.
Objective
The final version aims at:
1. Ensuring that capital allocation is more risk sensitive;
2. Enhance disclosure requirements which would allow market participants to assess the capital adequacy
of an institution;
3. Ensuring that credit risk, operational risk and market risk are quantified based on data and formal
techniques;
4. Attempting to align economic and regulatory capital more closely to reduce the scope for regulatory
arbitrage.
While the final accord has at large addressed the regulatory arbitrage issue, there are still areas where
regulatory capital requirements will diverge from the economic capital.
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Recent update
September 2005 update
On September 30, 2005, the four US Federal banking agencies (the Office of the Comptroller of the Currency,
the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office
of Thrift Supervision) announced their revised plans for the U.S. implementation of the Basel II accord. This
delays implementation of the accord for US banks by 12 months.
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Implementation progress
Regulators in most jurisdictions around the world plan to implement the new accord, but with widely
varying timelines and use of the varying methodologies being restricted. The United States' various
regulators have agreed on a final approach. They have required the Internal Ratings-Based approach for the
largest banks, and the standardized approach will be available for smaller banks.
In India, Reserve Bank of India has implemented the Basel II standardized norms on 31 March 2009 and is
moving to internal ratings in credit and AMA(Advanced Measurement Approach) norms for operational
risks in banks.
Existing RBI norms for banks in India (as of September 2010): Common equity (incl of buffer): 3.6%(Buffer
Basel 2 requirement requirements are zero.); Tier 1 requirement: 6%. Total Capital : 9% of risk weighted
assets.
According to the draft guidelines published by RBI the capital ratios are set to become: Common Equity as
5% + 2.5% (Capital Conservation Buffer) + 02.5% (Counter Cyclical Buffer), 7% of Tier 1 capital and
minimum capital adequacy ratio (excluding Capital Conservation Buffer) of 9% of Risk Weighted Assets.
Thus the actual capital requirement is between 11 and 13.5% (including Capital Conservation Buffer and
Counter Cyclical Buffer).[11]
In response to a questionnaire released by the Financial Stability Institute (FSI), 95 national regulators
indicated they were to implement Basel II, in some form or another, by 2015.
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The European Union has already implemented the Accord via the EU Capital Requirements Directives and
many European banks already report their capital adequacy ratios according to the new system. All the credit
institutions adopted it by 2008-09.
Australia, through its Australian Prudential Regulation Authority, implemented the Basel II Framework on
the 1st of January 2008.
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BASEL III (or the Third Basel Accord) is a global, voluntary regulatory standard on bank capital
adequacy, stress testing and market liquidity risk. It was agreed upon by the members of the Basel in 201011,
and was scheduled to be introduced from 2013 until 2015; however, changes from 1 April 2013 extended
implementation until 31 March 2018 and again extended to 31 March 2019. The third installment of the Basel
Accords (see Basel I, Basel II) was developed in response to the deficiencies in regulation revealed by the financial
crisis of 200708. Basel III was supposed to strengthen bank capital requirements by increasing bank liquidity and
decreasing bank leverage.
Capital requirements
The original Basel III rule from 2010 was supposed to require banks to hold 4.5% of common equity (up from 2%
in Basel II) and 6% of Tier I capital (including common equity and up from 4% in Basel II) of "risk-weighted
assets" (RWAs). Basel III introduced two additional "capital buffers"a "mandatory capital conservation buffer"
of 2.5% and a "discretionary counter-cyclical buffer" to allow national regulators to require up to an additional
2.5% of capital during periods of high credit growth.
Leverage ratio
Basel III introduced a minimum "leverage ratio". The leverage ratio was calculated by dividing Tier 1 capital by
the bank's average total consolidated assets (not risk weighted); The banks were expected to maintain a leverage
ratio in excess of 3% under Basel III. In July 2013, the U.S. Federal Reserve announced that the minimum Basel III
leverage ratio would be 6% for 8 Systemically important financial institution (SIFI) banks and 5% for their insured
bank holding companies.
Liquidity requirements
Basel III introduced two required liquidity ratios. The "Liquidity Coverage Ratio" was supposed to require a bank
to hold sufficient high-quality liquid assets to cover its total net cash outflows over 30 days; the Net Stable
Funding Ratio was to require the available amount of stable funding to exceed the required amount of stable
funding over a one-year period of extended stress.
Large Bank Holding Companies (BHC) those with over $250 billion in consolidated assets, or more in onbalance sheet foreign exposure, and to systemically important, non-bank financial institutions; to hold
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enough HQLA to cover 30 days of net cash outflow. That amount would be determined based on the peak
cumulative amount within the 30-day period.
Regional firms (those with between $50 and $250 billion in assets) would be subject to a modified LCR at
the (BHC) level only. The modified LCR requires the regional firms to hold enough HQLA to cover 21 days
of net cash outflow. The net cash outflow parameters are 70% of those applicable to the larger institutions
and do not include the requirement to calculate the peak cumulative outflows.
Smaller BHCs, those under $50 billion, would remain subject to the prevailing qualitative supervisory
framework.
The U.S. proposal divides qualifying HQLAs into three specific categories (Level 1, Level 2A, and Level 2B).
Across the categories the combination of Level 2A and 2B assets cannot exceed 40% HQLA with 2B assets limited
to a maximum of 15% of HQLA.
Level 1 represents assets that are highly liquid (generally those risk-weighted at 0% under the Basel III
standardized approach for capital) and receive no haircut. Notably, the Fed chose not to include GSE-issued
securities in Level 1, despite industry lobbying, on the basis that they are not guaranteed by the "full faith
and credit" of the U.S. government.
Level 2A assets generally include assets that would be subject to a 20% risk-weighting under Basel III and
includes assets such as GSE-issued and -guaranteed securities. These assets would be subject to a
15% haircut which is similar to the treatment of such securities under the BCBS version.
Level 2B assets include corporate debt and equity securities and are subject to a 50% haircut. The BCBS and
U.S. version treats equities in a similar manner, but corporate debt under the BCBS version is split between
2A and 2B based on public credit ratings, unlike the U.S. proposal. This treatment of corporate debt securities
is the direct impact of the DoddFrank Act's Section 939, which removed references to credit ratings, and
further evidences the conservative bias of U.S. regulators approach to the LCR.
The proposal requires that the LCR be at least equal to or greater than 1.0 and includes a multiyear transition
period that would require: 80% compliance starting 1 January 2015, 90% compliance starting 1 January 2016, and
100% compliance starting 1 January 2017.
Lastly, the proposal requires both sets of firms (large bank holding companies and regional firms) subject to the
LCR requirements to submit remediation plans to U.S. regulators to address what actions would be taken if the
LCR falls below 100% for three or more consecutive days.
Implementation
Summary of originally (2010) proposed changes in Basel Committee language
First, the quality, consistency, and transparency of the capital base will be raised.
Tier 1 capital: the predominant form of Tier 1 capital must be common shares and retained earnings
Tier 2 capital: supplementary capital, however, the instruments will be harmonised
Tier 3 capital will be eliminated.[15]
Second, the risk coverage of the capital framework will be strengthened.
Promote more integrated management of market and counterparty credit risk
Add the credit valuation adjustmentrisk due to deterioration in counterparty's credit rating
Strengthen the capital requirements for counterparty credit exposures arising from banks' derivatives,
repo and securities financing transactions
Raise the capital buffers backing these exposures
Reduce procyclicality and
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Provide additional incentives to move OTC derivative contracts to qualifying central counterparties
(probably clearing houses). Currently, the BCBS has stated derivatives cleared with a QCCP will be riskweighted at 2% (The rule is still yet to be finalized in the U.S.)
Provide incentives to strengthen the risk management of counterparty credit exposures
Raise counterparty credit risk management standards by including wrong-way risk
Third, a leverage ratio will be introduced as a supplementary measure to the Basel II risk-based framework,
intended to achieve the following objectives:
Put a floor under the buildup of leverage in the banking sector
Introduce additional safeguards against model risk and measurement error by supplementing the
risk based measure with a simpler measure that is based on gross exposures.
Fourth, a series of measures is introduced to promote the buildup of capital buffers in good times that can be
drawn upon in periods of stress ("Reducing procyclicality and promoting countercyclical buffers").
Measures to address procyclicality:
Dampen excess cyclicality of the minimum capital requirement;
Promote more forward looking provisions;
Conserve capital to build buffers at individual banks and the banking sector that can be used in
stress; and
Achieve the broader macroprudential goal of protecting the banking sector from periods of excess credit
growth.
Requirement to use long term data horizons to estimate probabilities of default,
downturn loss-given-default estimates, recommended in Basel II, to become mandatory
Improved calibration of the risk functions, which convert loss estimates into regulatory capital
requirements.
Banks must conduct stress tests that include widening credit spreads in recessionary scenarios.
Promoting stronger provisioning practices (forward-looking provisioning):
Advocating a change in the accounting standards towards an expected loss (EL) approach
(usually, EL amount := LGD*PD*EAD).[16]
Fifth,a global minimum liquidity standard for internationally active banks is introduced that includes a 30day liquidity coverage ratio requirement underpinned by a longer-term structural liquidity ratio called
the Net Stable Funding Ratio. (In January 2012, the oversight panel of the Basel Committee on Banking
Supervision issued a statement saying that regulators will allow banks to dip below their required liquidity
levels, the liquidity coverage ratio, during periods of stress. [17])
The Committee also is reviewing the need for additional capital, liquidity or other supervisory measures to
reduce the externalities created by systemically important institutions.
As of September 2010, proposed Basel III norms asked for ratios as: 79.5% (4.5% + 2.5% (conservation buffer) + 0
2.5% (seasonal buffer)) for common equity and 8.511% for Tier 1 capital and 10.513% for total capital.[18]
On 15 April, the Basel Committee on Banking Supervision (BCBS) released the final version of its Supervisory
Framework for Measuring and Controlling Large Exposures (SFLE) that builds on longstanding BCBS guidance
on credit exposure concentrations.[19]
U.S. implementation
The U.S. Federal Reserve announced in December 2011 that it would implement substantially all of the Basel III
rules. It summarized them as follows, and made clear they would apply not only to banks but also to all
institutions with more than US$50 billion in assets:
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"Risk-based capital and leverage requirements" including first annual capital plans, conduct stress tests,
and capital adequacy "including a tier one common risk-based capital ratio greater than 5 percent, under both
expected and stressed conditions" see scenario analysis on this. A risk-based capital surcharge
Market liquidity, first based on the United States' own "interagency liquidity risk-management
guidance issued in March 2010" that require liquidity stress tests and set internal quantitative limits, later
moving to a full Basel III regime - see below.
The Federal Reserve Board itself would conduct tests annually "using three economic and financial market
scenarios". Institutions would be encouraged to use at least five scenarios reflecting improbable events, and
especially those considered impossible by management, but no standards apply yet to extreme scenarios.
Only a summary of the three official Fed scenarios "including company-specific information, would be made
public" but one or more internal company-run stress tests must be run each year with summaries published.
Single-counterparty credit limits to cut "credit exposure of a covered financial firm to a single counterparty as
a percentage of the firm's regulatory capital. Credit exposure between the largest financial companies would
be subject to a tighter limit".
"Early remediation requirements" to ensure that "financial weaknesses are addressed at an early stage". One
or more "triggers for remediationsuch as capital levels, stress test results, and risk-management
weaknessesin some cases calibrated to be forward-looking" would be proposed by the Board in 2012.
"Required actions would vary based on the severity of the situation, but could include restrictions on growth,
capital distributions, and executive compensation, as well as capital raising or asset sales".
As of January 2014, the United States has been on track to implement many of the Basel III rules, despite
differences in ratio requirements and calculations.
KEY MILESTONES
Capital requirements
Date Milestone: Capital requirement
2014
Minimum capital requirements: Start of the gradual phasing-in of the higher minimum capital
requirements.
2015 Minimum capital requirements: Higher minimum capital requirements are fully implemented.
2016 Conservation buffer: Start of the gradual phasing-in of the conservation buffer.
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2011 Supervisory monitoring: Developing templates to track the leverage ratio and the underlying components.
2013
Parallel run I: The leverage ratio and its components will be tracked by supervisors but not disclosed and
not mandatory.
2015 Parallel run II: The leverage ratio and its components will be tracked and disclosed but not mandatory.
2017
Final adjustments: Based on the results of the parallel run period, any final adjustments to the leverage
ratio.
2018 Mandatory requirement: The leverage ratio will become a mandatory part of Basel III requirements.
Liquidity requirements[edit]
Date Milestone: Liquidity requirements
2011 Observation period: Developing templates and supervisory monitoring of the liquidity ratios.
2015
Introduction of the LCR: Initial introduction of the Liquidity Coverage Ratio (LCR), with a 60%
requirement. This will increase by ten percentage points each year until 2019.
2018 Introduction of the NSFR: Introduction of the Net Stable Funding Ratio (NSFR).
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CRITICISM
Think tanks such as the World Pensions Council have argued that Basel III merely builds on and further expands
the existing Basel II regulatory base without fundamentally questioning its core tenets, notably the ever-growing
reliance on standardized assessments of "credit risk" marketed by two private sector agencies- Moody's and S&P,
thus using public policy to strengthenanti-competitive duopolistic practices.
Basel III has also been criticized by banks, organized in the Institute of International Finance, an international
association of global banks based in Washington, D.C., who argue that it would hurt them and economic growth.
The OECD estimated that implementation of Basel III would decrease annual GDP growth by 0.05
0.15%, blaming the slow recovery from the financial crisis of 200708 on the regulation. Basel III was also
criticized as negatively affecting the stability of the financial system by increasing incentives of banks to game the
regulatory framework. The American Bankers Association, community banks organized in the Independent
Community Bankers of America, and some of the most liberal Democrats in the U.S. Congress, including the
entire Maryland congressional delegation with Democratic Senators Ben Cardin and Barbara Mikulski and
Representatives Chris Van Hollen and Elijah Cummings, voiced opposition to Basel III in their comments to
the Federal Deposit Insurance Corporation, saying that the Basel III proposals, if implemented, would hurt small
banks by increasing "their capital holdings dramatically on mortgage and small business loans".
Others have argued that Basel III did not go far enough to regulate banks as inadequate regulation was a cause of
the financial crisis. On 6 January 2013 the global banking sector won a significant easing of Basel III Rules, when
the Basel Committee on Banking Supervision extended not only the implementation schedule to 2019, but
broadened the definition of liquid assets.
FURTHER STUDIES
In addition to articles used for references (see References), this section lists links to publicly available high-quality
studies on Basel III. This section may be updated frequently as Basel III remains under development.
Date Source
Feb
Basel
III
for
Comments
dummies "All you need to know about Basel III in 10 minutes." Updated
Page 13 of 14
2012
Video
Dec
2011
Jun
2011
BNP
Paribas:
Economic
Basel III: no Achilles' BNP Paribas' Economic Research Department study on
Research
spear
Basel III.
Department
Feb
2011
Georg, co-Pierre
Feb
2011
May
2010
OECD
Journal:
Thinking Beyond Basel
Financial Market
OECD study on Basel I, Basel II and III.
III
Trends
May
2010
Bloomberg
Businessweek
Reuters
The Economist
May
2010
May
2010
Impact
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