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RISK MANAGEMENT IN BANKING SECTOR:
EMERGING ISSUES AND TRENDS
Assoc. Prof Taruna Shah
Dept. of Business Mgmt., AV College PG Centre, Hyderabad (Telangana ,India)
Abstract
Since the financial crisis, banks have gotten smarter about the way they manage their risks. It is no surprise that risk management in banks is changing and the risks involved are rising. Increased global competition, changing regulatory requirements, increased digitalisation and advances in technology are challenging the way banks interact with clients. There is also competition in the form of non bank firms expanding into the banking industry who want to take over the direct customer relationship and tap into the most lucrative part of the value chain—origination and sales. In this paper an attempt has been made to study the importance of risk management in banks and to review the emerging trends and issues in risk management in the banking sector.
Keywords: Bad Loans, Basel Accords, Cashless economy, Fintech , Risk Management
I INTRODUCTION
Banks have traveled a hard road since the global financial crash of 2008. They find themselves to be continually exposed to a variety of risks driven by the economic, geopolitical, technological, sociopolitical and environmental factors. While the magnitude and speed of regulatory change is unlikely to be uniform across countries, the future undoubtedly holds more regulation—both financial and non-financial—even for banks operating in emerging economies [1].
Largely in response to regulations that emerged from the 2008 crisis, risk management in banking has transformed over the past decade. Important trends are afoot that suggests risk management will experience even more sweeping changes in the next decade [2]. So unless banks are prepared to be proactive they will be left behind. Organisations must look at and be prepared for the continuum of risks that encompass not only known and unknown risks, but also those that are
‗unknowable‘ or that require elements of ‗black swan‘ management [1].
II OBJECTIVES
This study mainly intends to examine the following objectives.
To study the importance of risk management in banks
To study the emerging trends and issues in Bank risk management especially in the context of India.
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The market, credit and operational risks are the primary risks faced by a bank and are interrelated to each other.
Risks, such as market or credit, do not change in nature but evolve with the instruments and purposes they are used for [3]. The way we manage those risks, however, will be entirely different in the near future.
Risk management can be defined as a function of risk identification, measurement, monit oring and reporting to ensure that the returns are appropriate to the risk undertaken. Banks have had to deal with bad
debt, volatile funding markets and an uncertain economic environment. Risk management ensures that the bank holds adequate capital and reserves to make sure that its solvency and stability are not threatened, both in the short and the long run[4].
The capital measurement standards commonly known as the Basel Accords I and II published in 1988 and 2006 respectively, emphasized the importance of risk management by linking progressively the banks‘ capital adequacy to the risk weighted assets (RWA). Basel II involved progressively moving to sophisticated and complex risk measurement and management approaches to credit, market and operational r isks depending on the size, sophistication and complexity of the respective banks. In addition, Pillar 2 and Pillar 3 of Basel II emphasized the need for developing better risk management techniques in monitoring and managing risks not adequately covered or quantifiable under Pillar 1 and increased disclosure requirements. As a response to the global financial crisis of 2008, a package of reforms collectively referred to as Basel III have been implemented as part of the global regulatory effort to enhance the soundness and resilience of the banking system[5]
.
IV IMPORTANCE OF RISK MANAGEMENT IN BANKING SECTOR
The growing importance of managing banks is being driven by three sets of regulatory changes: the introduction of Basel III (both capital and liquidity requirements), the ongoing implementation of the Internal Capital Adequacy Assessment Process (ICAAP) and the International Financial Reporting Standards (IFRS 9) which aims to simplify the classification and measurement of Financial Instruments.
The Basel Committee on Banking Supervision (BCBS)[6] issued a comprehensive reform package entitled "Basel III: A global regulatory framework for more resilient banks and banking systems" in December 2010.According to BCBS, "Basel III is a comprehensive set of reform measures, to strengthen the regulation, supervision and risk management of the banking sector". Thus, Basel III is only a continuation of efforts initiated by them to enhance the banking regulatory framework under Basel I and Basel II. These reforms focus on capital, liquidity, leverage and macro prudential aspects of banking risk management to help create a more stable banking sector.
The RBI introduced the Basel III capital regulations for banks effective fiscal year 2013-14. The capital requirements were initially to be phased over a period, up to March 31, 2018, nine months ahead of the Basel Committee phase-in. But due to concerns from the industry on potential stress to asset quality, RBI extended the deadline for banks to implement Basel III capital rules by a year to March 31, 2019.
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The reforms require banks to raise the amount of common equity to 4.5% of assets by January 2019 from the 2% requirement under Basel II. The new minimum for Tier 1 capital has now been raised to 6%. The innovative elements of the Basel III requirements include additional layers of capital in form of the Capital Conservation Buffer and Countercyclical Capital Buffer, minimum liquidity requirements in the form of short term Liquidity Coverage Ratio (LCR) and long term structural Net Stable Funding Ratio (NSFR), a leverage ratio as a back - stop to the risk based capital framework and additional proposals for the Global Systemically Important Banks (G-SIBs).
The Capital Conservation Buffer is prescribed as 2.5% of common eq uity in addition to the 4.5% minimum requirement bringing the total common equity requirements to 7% which if breached would restrict pay -outs of earnings to help protect the minimum common equity requirement. The capital buffer can be used to absorb losses during periods of financial and economic stress.
The Reserve Bank of India has set the credit-to-GDP ratio and banks' credit-to-deposit ratios as the benchmarks for mandating the countercyclical capital buffers; the capital level required to prevent excessive lending during good times and create a cushion during times of economic stress. The countercyclical capital buffer entails common equity or other fully loss absorbing capital in the range of 0 – 2.5% to be implemented according to national circumstances and kicks in when credit to GDP ratio deviates significantly from the trend .
Minimum Capital Conservation Standards for individual banks Common Equity Tier 1 Ratio after including the current
periods retained earnings
Minimum Capital Conservation Ratio
(expressed as % of earnings)
As on March 31, 2016
As on March 31, 2017
As on March 31, 2018
5.5% - 5.65625% 5.5% - 5.8125% 5.5% - 5.96875% 100%
>5.65625% - 5.8125%
>5.8125% - 6.125%
>5.96875% -
6.4375% 80%
>5.8125% - 5.96875%
>6.125% - 6.4375%
>6.4375% -
6.90625% 60%
>5.96875% -
6.125% >6.4375% - 6.75%
>6.90625% -
7.375% 40%
>6.125% >6.75% >7.375% 0%
Souce:RBI Master Circular No DBOD.No.BP.BC.102/21.06.201/2013-14
Transitional Arrangements-Scheduled Commercial Banks (excluding LABs and RRBs)(% of RWAs)
Minimum capital ratios April 1, 2013
March 31, 2014
March 31, 2015
March 31, 2016
March 31, 2017
March 31, 2018
March 31, 2019
Minimum Common Equity Tier 1 (CET1) 4.5 5.5 5.5 5.5 5.5 5.5 5.5
Capital conservation buffer (CCB - - - 0.625 1.25 1.875 2.5
Minimum CET1+ CCB 4.5 5 5.5 6.125 6.75 7.375 8
Minimum Tier 1 capital 6 6.5 7 7 7 7 7
Minimum Total Capital* 9 9 9 9 9 9 9
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Minimum Total Capital +CCB 9 9 9 9.625 10.25 10.875 11.5
Phase-in of all deductions from CET1 (in %)# 20 40 60 80 100 100 100
*The difference between the minimum total capital requirement of 9% and the Tier 1 requirement can be met with Tier 2 and higher forms of capital;
# the same transition approach will apply to deductions from Additional Tier 1 and Tier 2 capital
An internationally harmonised Leverage Ratio has been introduced as a simple back -stop facility to complement the risk based capital framework in order to contain build -up of excessive leverage in the system and comprises of 3% loss absorbing capital relative to all of a bank‘s assets, including off-balance sheet assets without risk weighting. According to BCBS, banks internationally have to maintain LCR of 100% by January 1, 2019. In India, RBI has started phasing in implementation of the LCR from January 2015 with a minimum LCR of 60%.
An OECD study released on 17 February 2011[8], estimated that the medium-term impact of Basel III implementation on GDP growth would be in the range of −0.05% to −0.15% per year. Economic output would be mainly affected by an increase in bank lending spreads, as banks pass a rise in bank funding costs, due to higher capital requirements, to their customers.
The Supervisory Review Process of Basel II required banks to implement an internal process, called the Internal Capital Adequacy Assessment Process (ICAAP) (commensurate with their size, level of complexity, risk profile and scope of operations), for assessing their capital adequacy in relation to their risk profiles as well as a strategy for maintaining their capital levels. The ICAAP would be in addition to a bank‘s calculation of regulatory capital requirements and comprises a bank‘s procedures and measures designed to ensure the following: a) An appropriate identification and measurement of risks; b) An appropriate level of internal capital in relation to the bank‘s risk profile; and c) Application and further development of suitable risk management systems in the bank. It forms an integral part of the management and decision-making culture of a bank.
The ICAAP was implemented with effect from March 31, 2008 by the foreign banks and the Indian banks with operational presence outside India, and from March 31, 2009 by all other commercial banks, excluding the Local Area Banks and Regional Rural banks
In the budget speech 2014-15, Arun Jaitley announced that the IFRS converged accounting standards will become mandatory from FY 2016-17 for Indian Companies. As far as banking industry is concerned, RBI has finalized IFRS 9 & published it on July 24, 2014. IFRS 9 would be mandatory effective financial year beginning after Jan 1, 2018.As part of the International Financial Reporting Standards (IFRS 9), the Indian Banks need to start working towards IFRS Compliance i.e. Initiate gap closures, ready & test IT systems, finalize business models, bring about changes in the organization structure, processes etc.
V RECENT TRENDS AND ISSUES IN INDIAN BANKING SECTOR
The emerging risks facing banks today that are systemic and interconnected across global landscapes are the compliance governance, risk management practices and cyber security. These risks have to be managed under an enterprise risk management (ERM) framework [9].
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The banking industry is operating in a high-risk environment not only due to competitive pressures from inside the industry but also non-bank firms that are expanding into the banking industry. Low interest rates, changing business models, banks outsourcing of critical functions to third parties, increased legal settlements and regulatory penalties, an increase in sophisticated cyber attacks are creating increasing level of risks for the banks.
Recent events such as demonetisation and Donald Trump‘s foreign policies are certain to impact India‘s banking sector in 2017.Reserve Bank of India is pushing for a cashless economy and its implementation by the banking sector. The recent trends and issues in risk management in the banking sector are:
5.1 New Entrants
The banking landscape is changing with the entry of new players. Since April 2014, the Reserve Bank of India (RBI) has granted 23 banking licences - two as Universal Banks (April 2, 2014), eleven as Payments Banks (August 19, 2015) and ten as Small Finance Banks (September 16, 2015). The niche banks - small finance and payments banks -have been set up to further the regulator's objective of deepening financial inclusion. RBI is also planning to come up with "on tap" licences, which means there will not be any cut-off date for applying for these licences.
Two new universal banks-IDFC and Bandhan were allowed to be setup after a gap of 12 years (Yes Bank and Kotak Mahindra in 2003-04). 10 small finance banks - Ujjivan Financial Services Pvt. Ltd, Janalakshmi Financial Services Pvt. Ltd, Equitas Holdings Ltd, Au Financiers (India) Ltd, Capital Local Area Bank Ltd, Disha Microfin Pvt. Ltd, ESAF Microfinance and Investments Pvt. Ltd, RGVN (North East) Microfinance Ltd, Suryoday Micro Finance Pvt.
Ltd, and Utkarsh Micro Finance Pvt. Ltd. were granted in-principle licenses in 2015, to expand access to financial services in rural and semi-urban areas. They will offer basic banking services, accepting deposits and lending to unserved and underserved sections including small business units, small and marginal farmers, micro and small industries, and entities in the unorganized sector.
Initially eleven entities were granted in principle approval to be setup as payments banks by RBI-Aditya Birla Nuvo Ltd, Airtel M Commerce Services Ltd, Cholamandalam Distributions Ltd, Reliance Industries Ltd, Tech Mahindra Ltd,Vodafone m-Pesa Ltd, Fino Pay Tech Ltd, Department of Posts and National Securities Depository Ltd (NSDL) and includes two individuals Dilip Shanghavi, founder of Sun Pharmaceutical Industries Ltd, and Vijay Shekhar Sharma, founder of One97 Communications Ltd that runs mobile payment company Paytm. Three entities-Tech Mahindra, Cholamandalam Finance and Dilip Shanghvi-IDFC Bank-Telenor JV have dropped out. Unlike conventional banks, payment banks will not be in the business of lending. Essentially, these banks are targeted towards financially excluded customers like migrant workers, low-income households and small businesses.
The new entrants will intensify competition, particularly in the rural and semi-urban India with new products and higher rates to woo depositors and lower rates to sell loans. Airtel Payments Bank- a joint venture between Bharti Airtel and Kotak Mahindra Bank which started a pilot project in south India is offering 7.25% interest on savings accounts (against 4% offered by most banks) and free talk time—a minute per every rupee kept in the bank.
5.2 Fintech
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Financial technology or FinTech is any technological innovation in the financial sector and can include advances in financial education, retail banking, investment and crypto-currencies. FinTech covers digital innovations and technology-enabled business model innovations in the financial sector. Innovations central to FinTech include cryptocurrencies and the blockchain, new digital advisory and trading systems, artificial intelligence and machine learning, peer-to-peer lending, equity crowdfunding and mobile payment systems.
A crypto-currency is a digital currency created through encryption techniques. Bitcoin is the most famous. Some others are: litecoin, peercoin, namecoin, ether and primecoin. In India, most companies are associated with bitcoins.
Currently, there are four bitcoin exchanges in India: Coinsecure, Zebpay, Unocoin and BTCX India.
Fintech;
Payments and securities settlement
Deposit taking, debt and capital raising
Investment services, asset management and
insurance Support applications
Mobile payment methods, including app-based services
Crowdfunding
(crowdlending, peer-to-
peer lending) Robo advisors Big data
Internet payment methods, including payment initiation
service Instant credit Social trading Cloud computing
Open banking
Distributed ledger applications
Source: Financial Stability Review, Deutsche Bundesbank[9]
The global Fintech sector is expected to reach $45 Bn. and India‘s to reach $2.4Bn by 2020 growing at a CAGR of 7.1%. FinTech has brought in $1.77Bn in funding in India since 2014, with Paytm‘s $680 Mn. funding in September 2015 making up 38.5% of the entire sum. As of October 31, 2016, a total of 667 deals with $ 367.89 Mn. in funding were witnessed. Collaborations between this dynamic sector and the traditional banking sector can help propel growth.
5.3 Merger of SBI and its subsidiaries
State Bank of India, the nation‘s largest lender, will become one of the world‘s top 50 banks by assets in 2017 by merging its associate banks with itself. The combined entity‘s balance sheet will be at least Rs.37 trillion—five times that of ICICI Bank Ltd. This will make it a truly global bank able to compete for banking business on the international platform. In 2015, SBI ranked 52nd in the world by assets, according to Bloomberg. Following the merger, everything remaining the same, it would be ranked 45th. A larger balance sheet will enhance its risk-taking ability and expand its bandwidth to give loans. According to the BJP government (Arun Jaitley), the merger is likely
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to result in recurring savings, estimated at more than Rs 1,000 crore in the first year, through a combination of enhanced operational efficiency and reduced cost of funds. Its success may also encourage the government to take the path of consolidation for other state-owned banks.
5.4 Bad Loans
The aggregate non-performing assets of the banking sector stood at Rs. 6.5 trillion, or 8.6% of loans, at the end of June 2016. They have almost doubled (from Rs 3.4 trillion in September 2015 to Rs 6.68 trillion in September 2016) largely due to the classification requirement of the RBI. Demonetisation is likely to stall the recovery process further in the coming months.
Between August and December 2015, the RBI had inspected the loan portfolios of all banks and asked them to clean up their balance sheets by March 2017. In absolute terms, the gross non-performing assets (NPAs) of the 38 listed banks rose 6.44% in the September 2016 quarter, lower than 8.87% in the June quarter, and around a 32% rise over both the March and December 2015 quarters. After provisions, the rise in net NPAs in the September quarter was 4.81%, half of what we had seen in the June quarter (9.13%) and much lower than the 34.62% rise in March and 33.65% rise in December.
According to RBI database on Indian Economy, the rate of recovery of non-performing assets (NPAs) was 10.3 per cent, or Rs 0.228 trillion, out of the total NPAs of Rs 0.221 trillion during fiscal ended March 2016, against Rs 0.31 trillion (12.4 per cent) of the total amount of Rs 2.48 trillion reported in March 2015. The rate of recovery was 18.4 per cent, or Rs 0.32 trillion out of the total NPAs of Rs 1.74 trillion reported in March 2014. The recovery rate was even higher at 22 per cent (Rs 0.23 trillion) in March 2013 out of the total reported NPAs of Rs 1.05 trillion.
A total of 46.54 lakh cases to recover NPAs were filed in Lok Adalats, debt recovery tribunals and under the SARFAESI Act. Of this, 44.56 lakh cases were taken up by Lok Adalats during fiscal March 2016.As per RBI projections in its Financial Stability Report; the Gross NPAs of the Indian banking sector are expected to rise to 8.5% by March 2017 as compared to 7.6% in March 2016.
5.6 Banks’ loan portfolios, bank credit and asset quality
The cleaning up of bank balance sheets and the restoration of credit growth are vital, related elements in the growth agenda. Banks‘ credit growth dropped sharply to 5.7% in 2015-16 compared to 10% in 2014-15 as large corporate credit growth remained less than 5% with higher reliance on more cost effective funding sources such as NCDs &
CPs, weak demand and significant increase in NPAs in loans to industry. Growth of bank credit fell to a low of 5.1%
for the fortnight ended Dec.23, 2016, considered by economists to be the lowest in 60 years and mainly attributed to the disruption caused by demonetisation.
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World bank has lowered its growth forecast for India to 7% (from 7.6 % in 2016-17) citing one of the reasons as credit constraints due to impaired bank balance sheets.
High credit growth leading leverage
2006 -07
2007 -08
2008 -09
2009 -10
2010
-11 2011-12
2012 -13
2013- 14
2014-
15 2015-16 GDP Growth
(%) (Annual) 9.6 9.3 6.7 8.6 8.9 6.7 5.6 6.6 7.2 7.6
Credit Growth (%) (annual- As reported on the last Friday of the financial
year) 28.1 22.3 17.5 16.9 21.5 17 14.1 13.9 9.1 10.9
Credit growth Industrial
sector (%) 26.7 25 23 24.4 23.6 20.3 15.1 13.1 5.6 2.7
Source: RBI[11]
Loan Growth averaged 12.48 percent from 2012 until 2017, reaching an all time high of 18.70 percent in April 2012 and a record low of 4.80 percent in February 2017.The combination of demonetisation and the much-awaited goods and services tax (GST) may change the sentiment.
Asset quality is an important parameter to measure the health of the banks and concomitant with asset quality is the provisioning coverage that banks hold against stressed assets.
in %
Net NPA
Gross NPA
Stressed Assets
Mar.2013 3.2 9.2
Sept.2013 2.3 4.2 10.2
Mar. 2014 2.2 4.1 10
Sept.2014 2.5 4.5 10.7
Mar. 2015 2.5 4.6 11.1
Sept.2015 2.8 5.1 11.3
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Mar.2016 4.6 7.6 11.5
Source :RBI
Asset quality of the Indian banking system had improved significantly since introduction of prudential norms, SARFAESI Act, CDR Mechanism, Credit Information Companies, etc. As a fallout of the global financial crisis and the consequent economic downturn in many advanced nations in the west, the GNPAs in India have risen since 2008 RBI has been insisting that banks should review the classification of loans as part of an Asset Quality Review (AQR).The Gross NPAs of public sector banks increased to 9.6% in March 2016 as against 6%
in March 2015.The Net NPAs of banks also rose 4.6% in March 2016 compared to 2. 8% in September 2015.
5.7 Cashless Economy
There is a relentless push by the government for a cashless economy and its implementation by the banking system.
According to a 2014 study by Tufts University, The Cost of Cash In India, cash operations cost the Reserve Bank of India (RBI) and commercial banks about Rs. 21,000 crore annually. Also, a shift away from cash will make it more difficult for tax evaders to hide their income, a substantial benefit in a country that is fiscally constrained. The various cashless options available in India are:
E Wallets -- After demonetisation, use of e-wallets like paytm and freecharge have become very popular. These allow users to make payments using their mobile number or by scanning a QR code. There are many electronic wallets available in app stores like google play. They include jio money, vodafone mpesa & airtel money. Even banks have launched their own e wallet apps like State bank buddy and Yes Pay.
UPI -- Unified Payments Interface: To pay using this system requires two important things: a Smart phone and a Bank Account. Recently launched by National Payments Corporation of India, it makes digital transactions as simple as sending a text message through the creation of a ‗virtual payment address‘, an alias for the bank account.
Plastic Money-- means debit cards and credit cards that are used at ATM‘s for cash withdrawal and POS machines while shopping. Having a debit or credit cards make you burden free from carrying cash. Also risk of theft goes down to zero as it needs a PIN to carry out transactions.
Net Banking--All you need is a bank account with e-banking facility enabled on it. You can transfer funds to others account from the comfort of your home. You can make all payments and transfers yourself.
Aadhaar Card Enabled Payment System--allows a person to pay using his aadhaar card if it is linked to his bank account. Once you link your aadhaar card to your bank, you can make payments using your finger prints.
IndiaQR -- is a QR code which stores the bank details of a merchant which can be scanned by a smart phone to transfer a certain amount to merchant‘s account. All this is done by a smart phone app developed for this purpose. This system replaces the need of having POS machines to accept payments by credit or debit cards.
The merchant just needs a unique QR code which can be scanned by customer to transfer a specific amount
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directly to merchant‘s bank account. This system has been developed jointly by Visa, MasterCard Inc, and RuPay.
VI CONCLUSION
A glance at the competitive business environment of banking shows that factors affecting it are very different and more complex than in the past. Advancement of IT, technology and customer power are the characteristics of today's banking environment. Effective risk management requires specialisation and technical expertise as also an independent risk management function. One of the challenges that banks face is in developing comprehensive risk measurement models due to the scarcity of available historical and time series loss data and the quality, completeness and reliability of the data available. The HR policies and limited suitable number of the skilled human resources present myriad challenges in fully achieving this objective. Attrition and ability to retain the skilled personnel adds to the challenge.
A few changes which might be seen in the banking sector in the coming years are listed.
A more user friendly UPI II version may be implemented with the user having a lot more flexibility and features.
Second generation payment companies that will be experimenting more with the application of payments.
There will be a lot more startups emerging in the robo-advisory space, with the evolution of the wealth advisory sector.
The detection, assessment, and mitigation of risk must become part of the daily job of all bank employees and not only those in risk functions. With automation and more sophisticated analytical and technical capabilities, human intervention is needed to ensure appropriate and ethical application.
REFERENCES
[1]Colquitt JoEtta, ―Emerging Risks Facing the Financial Services Industry‖,June 2015
https://www.financierworldwide.com/emerging-risks-facing-the-financial-services-industry/#.WL5B5NR94_5 [2]Harle., P., Havas.,A, Samandari., H, The Future of Bank Risk Management-McKinsey & Co. article, July 2016 [3]Carell Phillippe,2009, Five emerging trends in risk management
https://www.gtnews.com/articles/five-emerging-trends-in-risk-management/
[4] A speech by Shri.R Gandhi, Deputy Governor, RBI- Indian Banking at Crossroads–Challenge of Risk Management from Globalisation to Financial Inclusion in Mumbai, March 2017
[5]Basel III: International Regulatory Framework for Banks http://www.bis.org/bcbs/basel3.htm
[6]Basel III: A global regulatory framework for more resilient banks and banking systems. http://www.bis.
org/publ/bcbs189.pdf.
[7]https://rbidocs.rbi.org.in/rdocs/Content/PDFs/FAS93F78EF58DB84295B9E11E21A91500B8.PDF
[8 ]Slovik Patrick and Cournède Boris ―Macroeconomic Impact of Basel III‖, Economics Department Working Paper No. 844 pp 5-13 http://www.oecd.org/officialdocuments/publicdisplaydocumentpdf/ ?cote=ECO/
WKP(2011) 13&docLanguage=En
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] http://www2.deloitte.com/tw/en/pages/financial-services/articles/impact-ifrs9.html[10]Deutsche Bundesbank Financial Stability Review 2016,‖ Technology-Enabled Financial Innovations: A Source of Opportunities and Risks‖ pp67-78
https://www.bundesbank.de/Redaktion/EN/Downloads/Publications/Financial_Stability_Review/2016_financial _stability_review.pdf?__blob=publicationFile
[11] A speech by N.S.Vishwanathan, Deputy Governor, RBI-Asset Quality of Indian Banks: Way Forward, New Delhi, August 30,2016 https://www.rbi.org.in/Scripts/BS_SpeechesView.aspx?Id=1023
