Hi, Mr. Harper, for the following question, although I get the correct answer, can you explain the meaning of credit substitution approach? and why D is wrong?View attachment 744
Thanks for your help, Dr. Jayanthi Sankaran,Hi @no_ming,
The approach traditionally taken by the Basel Committee for handling guarantees and credit derivatives such as credit default swaps is the "credit substitution" approach. Suppose that a AA-rated company guarantees a loan to a BBB-rated company. For the purposes of calculating credit risk capital, the credit rating of the guarantor is substituted for the credit rating of the borrower so that the capital is calculated as though the loan had been made to the AA-rated company.
This overstates the credit risk because, for the lender to lose money, both the guarantor and the borrower must default (with the guarantor defaulting before the borrower). The Basel Committee has addressed this issue. In July 2005, it published a document concerned with the treatment of double defaults under Basel II (see Bank for International Settlements, "The Application of Basel II to Trading Activities and the Treatment of Double Defaults," July 2005)
That is why (D) is wrong because it states that the "credit substitution approach" often understates the credit risk involved. Instead it overstates the credit risk as shown above!
Hope that helps!
Criteria for inclusion in Tier 2 Capital
- Issued and paid-in
- Subordinated to depositors and general creditors of the bank
- Is neither secured nor covered by a guarantee of the issuer or related entity or other arrangement that legally or economically enhances the seniority of the claim vis-à-vis depositors and general bank creditors
- Maturity:
a. minimum original maturity of at least five years
b. recognition in regulatory capital in the remaining five years before maturity will be amortised on a straight line basis
c. there are no step-ups or other incentives to redeem- May be callable at the initiative of the issuer only after a minimum of five years:
a. To exercise a call option a bank must receive prior supervisory approval;
b. A bank must not do anything that creates an expectation that the call will be exercised; and
c. Banks must not exercise a call unless:
i. They replace the called instrument with capital of the same or better quality and the replacement of this capital is done at conditions which are sustainable for the income capacity of the bank; or
ii.The bank demonstrates that its capital position is well above the minimum capital requirements after the call option is exercised.- The investor must have no rights to accelerate the repayment of future scheduled payments (coupon or principal), except in bankruptcy and liquidation.
Hi @no_ming See page 18 of https://www.dropbox.com/s/a1cd3wwtsi62gyw/bcbs189.pdf?dl=0 i.e., emphasis mine to highlight why question is correct to exclude (d) and not the call minimum is five years
@no_ming to what notes do you refer?
I. Definition of capital
A. Components of capital
Elements of capital
49. Total regulatory capital will consist of the sum of the following elements:
1. Tier 1 Capital (going-concern capital)
a. Common Equity Tier 1
b. Additional Tier 1
2. Tier 2 Capital (gone-concern capital)
For each of the three categories above (1a, 1b and 2) there is a single set of criteria that instruments are required to meet before inclusion in the relevant category.
Limits and minima
50. All elements above are net of the associated regulatory adjustments and are subject to the following restrictions (see also Annex 1):
- Common Equity Tier 1 must be at least 4.5% of risk-weighted assets at all times.
- Tier 1 Capital must be at least 6.0% of risk-weighted assets at all times.
- Total Capital (Tier 1 Capital plus Tier 2 Capital) must be at least 8.0% of risk weighted assets at all times.
Hi @no_ming okay thank you for the clarification re notes: Re Basel III, technically what you say is true as an explicit rule but that's only because the Basel 3 capital rules already imply this. The source here is pretty good at http://www.bis.org/publ/bcbs189.htm where please note (page 12):
You can see Tier 1 Capital, which is CE Tier 1 + Additional Tier 1, needs to be at least 6.0% of the total capital which must be 8.0%, such that the rule you cite isn't really necessary. I hope that helps!
Hi @no_ming I think i agree, but I can't tell you that I am certain there is a difference. You are correct: Basel 2 includes the explicit "The total capital ratio must be no lower than 8%. Tier 2 capital is limited to 100% of Tier 1 capital." I would have thought that, in Basel 2, this nevertheless allows for a total capital under your scenario of 16 because, I had assumed the Tier 2 requirement refers to the qualifying 8%. But if we interpret it literally, then under your scenario, B2 would count only 12 (6+6) as total capital, and indeed it would seem that you are correct. I do agree that Basel 3 has eliminated this explicit requirement that T2 cannot exceed T1; I cannot find it. Therefore, until I can find evidence otherwise, I do agree with you Thank you!
@no_ming @David Harper CFA FRMHi, Mr. Harper, the answer of the following question B, but seems C can be the answer too, do you agree?
Moreover, if the question asked for whether the case met Basel requirement, should I consider the Capital conservation buffer as a whole? (e.g. requirement of Tier 1 CET = 4.5% + 2.5% = 7%, Tier 1 = 8.5%, Total capital = 10.5%?)
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Hi Nicole, thx for your help. But unfortunately, I dont have the permission to read it@no_ming @David Harper CFA FRM
It looks like this is one of our practice questions, and this same question is discussed here: https://forum.bionicturtle.com/thre...i-regulatory-capital-changes.7944/#post-30978
Thank you,
Nicole