On Thursday, December 7th, the Basel Committee for Banking Supervision (“BCBS”) published several papers laying out the revised requirements for the calculation of risk-weighted assets (“RWAs”) and capital floors. These papers finalize the work that BCBS has undertaken since 2012 to calibrate the Basel III framework. Basel III was introduced to address the most pressing deficiencies from the 2007-08 crisis and to make banks more resilient.
The reforms finalized today together with earlier publications that revise the calculation of RWAs, including the revised market risk framework published in January 2016, are collectively referred to as “Basel IV” by the industry, given the scale of change. Revisions to the RWA calculation for all Pillar 1 risk types have been introduced through Basel IV. The reforms, therefore, affect all banks, regardless of their size, business models and irrespective of the use of standardized or advanced approaches for calculating regulatory capital. Under “Basel IV”, standardized approaches have become more risk-sensitive whilst the use of internal models is constrained. The introduction of a relatively high capital floor (at 72.5%) to internally-modeled RWAs was deemed as one of the most controversial elements of this new package.
BCBS wants to achieve several goals with the new rules. On one hand, it aims to reestablish the trust in banks’ RWAs by closing the gap in variability and to make RWAs more comparable. BCBS, therefore, has limited the use of internal models, whilst the standardized approaches used by most banks world-wide will become more risk-sensitive and reflect developments in the financial markets of the last years. For operational risk, internal models can no longer be used and the standardized approaches will be replaced by a new approach. No agreement on the RWA treatment of sovereign exposures was reached but a discussion paper was published. Apart from the calculation of RWAs, some changes to the leverage ratio were also agreed, including an extra buffer for globally systematically important banks.
Impact on business models and strategies of banks
Despite the fact that today’s published rules are relatively less stringent compared to the original proposals some European banks will face a significant increase in their RWAs and therefore their capital ratios. The changes can vary from bank to bank and depend on several factors, like extend of the use of internal models for the measurement of risks or the business models.
“While some banks may suffer an increase of 10%-15% at the end of the transition phase, some other banks can even profit from the new rules and lower RWA” says Martin Neisen, Partner and PwC’s Global Basel IV Leader. “The impact of Basel IV will also vary from country to country depending on the local lending practices”.
The changes collectively will require banks to re-examine capital consumption across their business lines and potentially adjust their pricing and product offering. The revised framework will, therefore, have an impact on firms’ strategy and business models. The BCBS expects that it will result in some re-distribution of capital in the system. The capital floors are likely to be the focus area for the larger banks, whilst smaller institutions will particularly have to consider what infrastructure and technology enhancements are needed to handle the increased volume and granularity of data required under the more complex standardized approaches.
Banks need to react despite the long period to implementation
The revised package will be introduced starting in 2022, though most of the rules are to be phased-in from 2022 to 2027. The implementation of the new framework for market risk that was finalized in 2016 (Fundamental review of the trading book – “FRTB”) was also postponed to 2022. This means, that there will be a “big bang” in 2022 when all new RWA rules must be applied for the first time. This will allow firms to adjust and better manage the capital impact. National lawmakers will also need to take steps to introduce the “Basel IV” package into binding national law and to set timelines accordingly.
The new rules for banks will also affect other participants of the financial market. If the capital costs for banks increase, this will be reflected in the interest rates and fees for their clients. Competitors of banks like insurance companies, asset managers, fintech or hedge funds are ready to step in and do business that is not attractive to banks anymore.
“Even though the proposed implementation timeline may look like the far away future, it is imperative for all banks to take action now”, says Martin Neisen. “We welcome the fact that banks have certainty about the new regulations, but it is clear that banks will require significant time, effort and resources to understand the impact, adjust and implement.”
Read more about PwC’s tools and solutions to assist you with navigating the extensive changes from Basel IV at our Basel IV webpage.