The Bank for International Settlements has published a report from The Joint Forum “Developments in credit risk management across sectors: current practices and recommendations.” The Joint Forum was established in 1996 under the aegis of the Basel Committee on Banking Supervision (BCBS), the International Organization of Securities Commissions (IOSCO) and the International Association of Insurance Supervisors (IAIS) to deal with issues common to/across the banking, securities and insurance sectors, including the regulation of financial conglomerates.
In 2013 the Joint Forum undertook a survey of supervisors and firms in the banking, securities and insurance sectors globally in order to understand the current state of credit risk (CR) management given the significant market and regulatory changes since the financial crisis of 2008. Credit risk is generally defined as the risk that a counterparty will fail to perform fully its financial obligations, and can arise from multiple activities across sectors. For example, CR could arise from the risk of default on a loan or bond obligation, or from the risk of a guarantor, credit enhancement provider or derivative counterparty failing to meet its obligations.
Fifteen supervisors and 23 firms responded to the survey, representing the banking, securities and insurance sectors in Europe, North America and Asia. The surveys were not meant to be a post-mortem of the events leading up to the financial crisis, but rather a means to provide insight into the current supervisory framework around credit risk and the state of CR management at the firms, as well as implications for the supervisory and regulatory treatments of credit risk. The survey aimed to update previous Joint Forum work, most recently a 2006 paper, and used that date as the benchmark when asking about changes. The survey asked questions regarding:
- products posing challenges to CR management
- new credit risk transfer tools
- market developments and regulatory/statutory changes affecting CR management and the resulting changes in firm CR management practices
- changes in key operations, risk management, internal control and governance frameworks with respect to CR management
- changes in the use of models to aggregate credit risk
- changes in supervision of CR management
- changes in collateral risk
Based on the analysis of the responses from the supervisor and firm surveys and subsequent discussions with firms, the following themes emerged. Also detailed below are recommendations for consideration by supervisors.
1. Propelled by the experience of 2008 and by regulators, firms have improved their management of credit risk in areas such as governance and risk reporting. Risk aggregation has also become more sophisticated since the financial crisis. Regulatory requirements such as the Basel framework and stress testing have been one driver of the modelling enhancements. Firms highlighted increased reliance upon stress testing using their internal models. Against this background, some supervisors cautioned that there is a risk that some credit risk management or regulatory capital models may not adequately capture risk-taking.
Recommendation 1: Supervisors should be cautious against over-reliance on internal models for credit risk management and regulatory capital. Where appropriate, simple measures could be evaluated in conjunction with sophisticated modelling to provide a more complete picture.
2. In the current low interest rate environment, there is a “search for yield” by some firms across sectors. This manifests itself in an increase in firms’ risk tolerance in a variety of different products such as auto lending by banks, increasingly risky assets in the investment portfolio for life insurers, and the syndicated leveraged loan market. Lower-quality assets with lower-rated counterparties could generate more credit risk.
Recommendation 2: With the current low interest rate environment possibly generating a “search for yield” through a variety of mechanisms, supervisors should be cognisant of the growth of such risk-taking behaviours and the resulting need for firms to have appropriate risk management processes.
3. Over-the-counter (OTC) derivatives, both cleared and uncleared, are a significant source of credit risk at financial institutions across sectors. As a result of both regulation and firm practices, firms are increasing the amount of initial margin they collect from trading counterparties for uncleared trades, and central counterparties (CCPs) in many jurisdictions are implementing risk management standards intended to ensure that they collect adequate financial resources from their member firms.
Recommendation 3: Supervisors should be aware of the growing need for high-quality liquid collateral to meet margin requirements for OTC derivatives sectors, and if any issues arise in this regard they should respond appropriately. The Parent Committees should consider taking appropriate steps to promote the monitoring and evaluation of the availability of such collateral in their future work while also considering the objective of reducing systemic risk and promoting central clearing through collateralisation of counterparty credit risk exposures that stems from non-centrally cleared OTC derivatives.
4. The increase in central clearing of OTC derivatives has clear benefits by reducing risk to individual counterparties, as articulated by both supervisors and firms. The consequence of this is to shift and concentrate credit risk to CCPs. Many firms have responded by increasing analysis of and reporting on CCPs.
Recommendation 4: Supervisors should consider whether firms are accurately capturing central counterparty exposures as part of their credit risk management.
