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RISK MANAGEMENT IN BANKS: AN OVERVIEW
LEARNING OBJECTIVES
After studying this chapter you will be able to:
♦ Identify cost differences as basis for international trade;
♦ evaluate the classical theory of international trade;
♦ extend classical theory of trade to wider situations.
RISK DEFINED
Most dictionaries define ‘risk” as the chance of loss or damage to property or person. An
agriculturist carries the risk that rains may fail and crops may wither. An office goer faces the risk
of rains flooding the streets disturbing traffic and his not reaching his office in time. A
businessman lives with the risk of his sales falling. A student has the risk of failing in his
examination. A patient faces risk to his life when he undergoes a surgery. The surgeon who
conducts the operation faces the risk of being accused of inadequate skill and professional
negligence. In all these events, we talk of risk only when uncertainty is associated with it. In none
of the cases above, there is certainty that the fears will turn out to be true. Then only it qualifies to
be a risk. There is no risk if the event is sure to happen or will never happen.
In its true meaning, risk is not associated only with the negative connotation. Risk is the
uncertainty about the outcome of an event. The risk is that the actual outcome may be better or
worse than the expected outcome. In this sense, a bank branch not reaching the deposit target is a
risk; so also deposits exceeding the budget. In financial management risk is defined as the
deviation in the actual cash flows as compared to the expected cash flows. For instance, as against
the estimated sales of Rs. 10 lakhs, the actual sales may be Rs. 8 lakhs or Rs. 12 lakhs. In both the
cases, the actual cash inflow has deviated from the expectation and therefore provides instances of
materialisation of risk.
2.2 RISK MANAGEMENT IN BNKS
It may be emphasised that where there is certainty, there is no risk. Where an event is
certain, there is no risk because it can be accurately provided for. There is no risk in investing in
capital asset. Its economic life is known and depreciation is accordingly provided for. Thus risk is
essentially related to uncertainty. Uncertainty refers to the doubt about what will or will not
happen in future. The doubt arises because there are at least two possible outcomes. The event is
perceived as a risk when at least one of the outcomes is undesirable.
The extent of the risk is measured by the probability of the undesirable outcome occurring.
The total of probability of any event is one. If the probability of undesirable outcome is zero,
certainly the undesirable event will not happen and there is no loss. If the probability is one, the
undesirable event will definitely happen; there is no risk, but there is certainty of loss. Therefore,
the risk is there only when the probability of undesirable outcome falls between zero and one.
Higher the probability, greater is the risk.
Statistically, risk is measured by standard deviation. As we know, the standard deviation
captures both negative and positive deviations from the mean value. Therefore, all deviations
from the expected outcome are taken as risks, even though some of them may be positive.
However, when it comes to risk management all efforts are directed towards avoiding the
downslide rather than worrying about the windfall. Therefore, for the purpose of our study, we
will define risk as the potential losses that may arise due to unexpected changes in the cash flows
of a bank.
TYPES OF RISK
Business risks are of two types: (i) financial risk and (ii) nonfinancial risk. Risk that involves
financial losses when the undesirable outcome occurs is financial risk. For instance, when an
investment is made in equity shares, the risk involved is the nonrealisation of the expected
return. This is financial risk. Risks that do not involve financial losses are nonfinancial risks. The
production department not being able to get the desired quality is a nonfinancial risk.
Another way of classification of risk is: (i) pure risk and (ii) speculative risk. Pure risk exists
when there is either loss or no loss. There is no possibility of profit when pure risk exists. When
an investor invests in the fixed deposit of a nonbanking company, he takes up a pure risk. There
is risk of default of payment of interest or repayment of principal, but there is no chance of the
deposit taking company repaying more than the agreed amount. Speculative risk entails the
possibility of profit as well as loss. If the outcome is as estimated by the speculator he gains; if the
outcome is otherwise, he loses.
Banking business involves all types of risk.
World over the regulatory distinction among commercial banks, investment banks and other
financial institutions like insurance are fast vanishing. Banks have become virtual supermarkets
for all financial services. The activities and range of products offered by banks have multiplied.
Basel Committee provides the following mapping of business activities of a modern bank:
TABLE 2.1 MAPPING OF BUSINESS LINES OF A BANK
Level 1 Level 2 Activity Groups
Corporate Finance Mergers and acquisitions, underwriting,
Municipal/Governmen privatisations, securitisation, research, debt
Corporate
t Finance (government, high yield), equity,
Finance
Merchant Banking syndications, IPO, secondary private
Advisory Services placements
Sales Fixed income, equity, foreign exchanges,
Trading & Market Making commodities, credit, funding, own position
Sales Proprietary Positions securities, lending and repos, brokerage,
Treasury debt, prime brokerage.
Retail lending and deposits, banking
Retail Banking
services, trust and estates
Private lending and deposits, banking
Retail
Private Banking services, trust and estates, investment
Banking
advice
Merchant/commercial/corporate cards,
Card Services
private labels and retail
Project finance, real estate, export finance,
Commercial
Commercial Banking trade finance, factoring, leasing, lending,
Banking
guarantees, bills of exchange
Payment and Payments and collections, funds transfer,
External clients
Settlement clearing and settlement
Escrow, depository receipts, securities
Custody
Agency lending (customers) corporate actions
Services Corporate Agency Issuer and paying agents
Corporate Trust
Discretionary Fund Pooled, segregated, retail, institutional,
Asset Management closed, open, private equity
Management NonDiscretionary Pooled, segregated, retail, institutional,
Fund Management closed, open
Retail
Retail Brokerage Execution and full services
Brokerage
Source: Annex 6 of Basel Committee’s Revised Framework on International Convergence of Capital
Measurements and Capital Standards, 2004.
TYPES OF RISKS
Table 1 indicates the multitude of activities undertaken by a bank. Along with the expansion of
the activities, the risk profile of banks has also expanded and become complex. Banks are
confronted with various kinds of financial and nonfinancial risks captured succinctly in Fig. 2.1.
The risks faced by a bank are highly interdependent and events that affect one area of risk can
have ramifications for range of other categories.
• Liquidity Risk
Liquidity is the ability to efficiently accommodate deposit and other liability decreases, as well as,
fund loan portfolio growth and possible funding of offbalance sheet claims. A bank has
adequate liquidity when sufficient funds can be raised, either by increasing liabilities or
converting assets, promptly and at a reasonable cost.
2.4 RISK MANAGEMENT IN BNKS
Funding Risk
LIQUIDITY RISK Time Risk
Call Risk
Portfolio Risk
CREDIT RISK
Counterparty Risk
Interest Rate Risk
BANK MARKET RISK Forex Risk
RISKS Price Risk
Legal Risk
OPERATIONAL Regulatory Risk
RISK Others
Strategic Risk
OTHER RISKS
Reputation Risk
Fig 2.1 Risks in Banking Business
The liquidity risk of banks arises from funding of longterm assets by shortterm liabilities,
thereby making the liabilities subject to rollover or refinancing risk. The liquidity risk in banks
manifests three dimensions:
Funding risk – need to replace net outflows due to unanticipated withdrawal/nonrenewal
of deposits (wholesale and retail);
Time risk – need to compensate for nonreceipt of expected inflows of funds, i.e.,
performing assets turning into nonperforming assets; and
Call risk – due to crystallisation of contingent liabilities and inability to undertake
profitable business opportunities when desirable.
• Credit Risk
Credit risk or default risk involves inability or unwillingness of a customer or counterparty to
meet commitments in relation to lending, trading, hedging, settlement and other financial
transactions. The credit risk is generally made up of portfolio risk and counterparty risk.
The credit risk of a bank’s portfolio relates to the quality of its assets as a whole. It depends on
both external and internal factors. The external factors are the state of the economy, wide swings
in commodity/equity prices, foreign exchange rates and interest rates, trade restrictions,
economic sanctions, government policies etc. The internal factors are deficiencies in loan
policies/administration, absence of prudential credit concentration limits, inadequately defined
lending limits for Loan Officers/Credit Committees, deficiencies in appraisal of borrowers’
financial position, excessive dependence on collaterals and inadequate risk pricing, absence of
loan review mechanism and post sanction surveillance, etc.
The counterparty risk arises from nonperformance of the trading partners. The non
performance may arise from counterparty’s refusal/inability to performance due to adverse price
movements or from external constraints that were not anticipated by the principal.
• Market Risk
Market risk, also known as price risk, arises from changes in market rates and prices. It takes the
form of interest rate risk, foreign exchange rate risk, commodity price risk and equity price risk.
RISK MANAGEMENT IN BANKS: AN OVERVIEW 2.5
Interest rate risk refers to potential impact on net interest income or net interest margin or
market value of equity caused by unexpected changes in market interest rates.
Foreign exchange risk is that a bank may suffer losses as a result of adverse exchange rate
movements during a period in which it has open position in a foreign currency or maturity
mismatches in foreign currency position. In the foreign exchange business, banks also face the
risk of default of the counterparties or settlement risk.
Commodity risk and equity price risk arise when the investment made by a bank falls in value.
• Operational Risk
Operational risk is defined as the risk of loss resulting from inadequate or failed internal
processes, people and systems or from external events. Legal risk includes, among others,
exposure to fines, penalties or punitive damages resulting from supervisory actions, as well as
private settlements.
• Other Risks
These include strategic risks and reputation risks.
Strategic risk refers to the loss of income and capital arising from taking bad business
decisions.
Reputation risk refers to the loss of income and capital arising from negative publicity. The
negative publicity, which may be true or untrue, adversely affects the bank’s customer base,
bringing down the business and causes a fall in the profitability of the bank.
D ETERMINATION OF OBJECTIVES
The objective of any business organisation is to maximise the wealth of its shareholders. The
same objective underlies the functioning of a bank. The risk profile of a bank plays a major role in
achieving this corporate objective. While the corporate objective also serves as the objective of
risk management in broad terms, in framing the specific objectives of risk management, the
internal and external factors affecting banking business should be factored in. Considering the
uncertainty inherent in risk management, the primary objective of risk management is to survive
and continue as an operating unit under any trying circumstances. There should be a proper
balancing of other subobjectives like minimising cost of risk management, maximisation of
profit, compliance with legal requirements and fulfilling social responsibility.
Once the objectives have been defined they should be formalised into the risk management
policy of the bank. Formulation of the risk management policy is the responsibility of the highest
policy making body, viz., the board of directors of the bank.
IDENTIFICATION OF RISKS
Banks offer a variety of services and products and are exposed to numerous risks. Identification
of risks involves identification of the specific types with each of these services or transactions.
In the early part of this chapter we saw the classification of banking services into eight major
business lines. Each line is subdivided into different sublines. For instance, the main lines are
2.6 RISK MANAGEMENT IN BNKS
corporate finance, trading and sales, retail banking etc. In turn the sublines for retail banking are
retail banking, private banking and card services. On the other hand the various risks recognised
are liquidity risk, market risk, credit risk, operational risk, foreign exchange risk, etc. While most
or all of these risks may be relevant to a specific line like retail banking, the impact of the
different risks is not the same. Identification of risk involves recognition of all the possible risks
associated with a business activity, so as to gauge their impact and concentrate on managing the
major risks related to the activity and thus ensure the healthy performance of the bank. While
dealing with retail banking credit risk and liquidity risk may warrant greater attention than
foreign exchange rate risk.
• Banking Book and Trading Book
One way of classifying the banking activities from the risk management perspective is to divide
them as (a) balance sheet exposure (b) offbalance sheet exposure. The balance sheet exposure can
be again divided into (i) banking book and (ii) trading book.
Banking book. Banking book includes all advances, deposits and borrowings which are
meant to be held till their maturity. The assets and liabilities included in the banking book have
the following characteristics:
they are normally held till their maturity; and
they are normally carried in the books at historical cost.
Since the assets and liabilities held in banking books are of different maturities, it may lead
to liquidity risk. The interest rate may change during the period these items are held leading to
interest rate risk. Advances made to customers carry with them the risk of default in payment of
interest or repayment of principal, and hence the bank is exposed to credit risk. Banking book is
also exposed to omissions and commissions in the implementation of internal control systems
and changes in the external events. Hence they are exposed to operational risk. However, these
items are not affected by the price changes as they are held at historical cost, and therefore are not
exposed to market risk.
Trading book. Trading book refers to such of the items in the assets side of the balance sheet
that are meant for short term holding, mainly to take advantage of their price movements. The
characteristics of trading book are:
they are held for a short term and will be liquidated before their maturity; and
they are marked to market periodically. That is, their book values are compared with
ruling market prices and any adverse movement is accounted for as loss.
Trading book relates mainly to investments made by a bank on its own account. They are
such items whose value fluctuates with market variables. Investments in fixed income securities,
equities, foreign currency, commodities and derivatives fall under this category. While these
items are held, they are subjected to marking to market and hence are affected by the market
prices. They are thus subject to market risk. When they are liquidated, the changing demand and
supply condition for the particular security/commodity may result in adverse price movements.
Hence they are subject to market liquidity risk. Trading book is also exposed to credit risk of the
counterparty defaulting on his commitment. The operational risk also affects the trading book as in
the case of banking book.
Offbalance sheet exposure. Letters of credit, guarantees, and derivative contracts
undertaken by a bank on behalf of its customers comprise the offbalance sheet exposure of the
bank. Offbalance sheet exposure is contingent in nature and may involve payment obligation on
the happening of specified contingencies. When they thus become fund based exposure,
depending upon the nature of the underlying transaction, it may become banking book or
trading book. Accordingly, the offbalance sheet exposure may have liquidity, credit, market,
operational and interest rate risks.
RISK MANAGEMENT IN BANKS: AN OVERVIEW 2.7
• Transaction Level and Aggregate Level Risks
Another way of looking at the risks is to recognising them at transaction level and aggregate
level.
Transaction level. Risk can be recognised and managed at the level of individual
transactions. Each business line has a number of services. Each service in turn is availed by a
number of customers. Some of the services are offered as standard products such as housing
loan, consumer loan, credit cards etc. Some of the services are tailor made to the specific
requirements of a customer. Each of these innumerable transactions involves risk specific to the
type of the transaction and specific to the customer. These risks are identified and managed at the
branch level where the transaction takes place.
Aggregate level. The risk profile of the aggregate of the transactions does not equate the
sum of risks of individual transactions because of the effect of the diversification of the portfolio
comprising these transactions. For instance, the individual commercial loan accounts of a bank
carry credit risks. The individual borrowers belong to different sectors of the economy and their
prosperity do not always go together. When one sector of the economy is passing through
difficult days, other sectors may be prospering. Therefore the risk profile at the aggregate level is
different from the sum of the risk profile of the individual borrowers. The aggregated risk of the
entire bank is known as the portfolio risk and is managed at the corporate level.
R ISK MEASUREMENT
Risk measurement refers to the quantifying the effect of the risk on the earnings and capital value
of the bank. It involves identification of the key parameters affecting each type of risk and
quantifying the effect of their variations on the earnings of the bank. The parameters can be
compared with those of other banks to judge the efficiency of risk management at the bank.
Fluctuations in prices, loan recovery rate, default in settlement of transactions, devolvement of
nonfund based exposures are some of the key parameters used. Risk management involves
quantifying the uncertainties associated with these risk elements. Quantitative measurements can
be done through sensitivity analysis, volatility measurement and valueatrisk analysis. These
methods are discussed in the chapter on Market Risk.
With regard to risk measurement, the Reserve Bank of India has suggested the following:
“Large banks and those operating in international markets should develop internal risk
management models to be able to compete effectively with their competitors. As the domestic
market integrates with the international markets, the banks should have necessary expertise and
skill in managing various types of risks in al scientific manner. The core staff at Head Offices
should be trained in risk modelling and analytical tools.
“Given the diversity of balance sheet profile, it is difficult to adopt a uniform framework for
management of risks in India. The design of risk management functions should be bank specific,
dictated by the size, complexity of functions, the level of technical expertise and the quality of
MIS. The Reserve Bank guidelines only provide broad parameters and each bank may evolve its
own systems compatible to its risk management architecture and expertise.”
R ISK MITIGATION
Risk mitigation refers to the measures adopted to reduce the uncertainties associated with the
risk elements. Total risk elimination can be achieved only by not undertaking any transaction.
What is practical is to take certain measures which can reduce the probability of occurrence of the
loss event or reduces its impact on the bank’s earnings. The following methods may be adopted
towards risk mitigation: (a) portfolio diversification, (b) risk pricing and (c) hedging.
• Portfolio Diversification
The bank should diversify its assets and liabilities in such a way that occurrence of an event does
2.8 RISK MANAGEMENT IN BNKS
not affect its major portion of assets or liabilities. Statistically, the combined variance of a
portfolio will be much lower than the sum of the variances of individual elements in the portfolio
when those elements have low or negative correlation. This is because when the elements have
no correlation among themselves they move in different directions. When one element is affected
by an event, others will not be affected or may even be benefited. The overall return of the
portfolio will not be affected much. By having prudential norms for exposure to different sectors
and individual customers, and having ceiling for different types of business, a bank can have a
diversified portfolio of business and customers; thereby it mitigates the risk.
• Risk Pricing
In pricing the product, a bank should consider not only cost of rendering the service, but also the
risk premium. For instance, while the cost of funds for a specified period would be the same for
the bank, while quoting the rate of interest for the borrower, the credit rating of the customer
should also be considered. Higher the risk, greater should be the cost of service to the customer.
Risk pricing is a method by which a bank can protect itself from fall in profits. At the same time,
risk pricing can also be used as a method by which a bank can avoid undertaking highly risky
business from its point of view. By quoting price sufficiently high, the customer would be
dissuaded from utilising the product/service from the bank.
• Hedging
Hedging is a method by which a bank can protect itself from changes in the variables by doing
some cover operations. The cover operation may include securitisation of advances, buying credit
derivatives, buying currency derivatives like futures, options and swaps etc. By hedging the bank
protects itself from adverse movements of variables. At the same it, it also loses the opportunity
to gain from favourable movements.
comprehensive risk measurement approach;
risk management policies;
guidelines and other parameters used to govern risk taking including detailed structure of
prudential limits;
strong MIS for reporting, monitoring and controlling risks;
well laid out procedures, effective control and comprehensive risk reporting framework;
separate risk management framework; and
periodical review and evaluation.
• Risk Management Structure
A major issue in establishing an appropriate risk management organisation structure is choosing
between a centralised and decentralised structure. The global trend is towards centralising risk
management with integrated treasury management function to benefit from information on
aggregate exposure, natural netting of exposures, economies of scale and easier reporting to top
management.
The organisational structure for risk management consists of three tiers.
Board of Directors. The primary responsibility of understanding and managing the risk
should be vested with the Board of Directors. The Board should decide the risk management
RISK MANAGEMENT IN BANKS: AN OVERVIEW 2.9
policy of he bank and set limits for liquidity, interest rate, foreign exchange and equity price risks
by assessing the bank’s risk and riskbearing capacity.
Risk Management Committee. At the organisational level, overall risk management should
be assigned to an independent Risk Management Committee. It will be a Board level sub
committee including CEO and heads of Credit, Market and Operational Risk Management
committees forming the third tier. The functions of Risk Management Committee should
essentially be to
identify, monitor and measure the risk profile of the bank;
determine the level of risks that will be in the best interest of the bank;
develop policies and procedures;
verify the models that are used for pricing complex products;
review the risk models as development takes place in the markets;
identify new risks.
Committees for Specific Risks. Each bank may, depending on the size of organisation,
constitute high level committees as follows:
Asset Liability Management Committee (ALCO) or Market Risk Management Committee,
to manage market risk including liquidity risk;
Credit Risk Management Committee, to manage credit risk; and
Operational Risk Management Committee to manage operational risk.
To control the supply of money and credit;
To encourage savings by ensuring the health of the banks;
To ensure proper distribution of bank credit and other services among the public;
To avoid concentration of financial power with few individuals and institutions;
To help sectors of the economy that have special credit needs (priority sectors);
To provide government with credit and tax revenues;
To render stability to the monetary system of the country.
Thus the main focus of the regulation was on protecting the interests of the customers of the
bank and achieving the economic objectives of the government through the banking system. The
regulatory measures also were structured to achieve these objectives. The measures included (a)
licensing requirements for establishing the bank as well as for opening branches; (b) prescription
of minimum capital requirements; (c) reserve requirements; (d) selective credit control, (e) open
market operations; (f) administered interest rates and (g) moral suation.
Thus, the risks that the banks were subjecting themselves to, in rendering the services to
their customers were not considered in the traditional regulatory measures. By prescribing
2.10 RISK MANAGEMENT IN BNKS
minimum capital requirement and reserve requirements, regulators thought that the safety of the
banks and hence that of their customers was ensured.