2022-05-17
The Reserve Bank of New Zealand issued this guidance to define the methodology for measuring market risk exposure and determining capital adequacy for registered banks. It mandates disclosure of capital charges for interest rate, currency, and equity risks, while excluding fixed assets, commodities, and shareholders' equity from the framework. The document details the standard models for calculating capital charges, including specific rules for interest rate repricing schedules, derivatives, and netting, alongside audit requirements for financial statements.
Ref #3089763 Market Risk Guidance Notes Prudential Supervision Department Document BS6 Issued: March 2011
2 Ref #3089763 BS6 March 2011 GUIDANCE NOTE ON: THE MEASUREMENT OF EXPOSURE TO MARKET RISK FOR RESERVE BANK CAPITAL ADEQUACY AND DISCLOSURE PURPOSES The purpose of this guidance note is to explain the methodology to be used by all registered banks for disclosing exposure to interest rate, currency, and equity risk, which also determines the capital that New Zealand-incorporated registered banks must hold against those risks.
Introduction
3 Ref #3089763 BS6 March 2011 Capital Requirement 6. The calculation of the total capital that a New Zealand-incorporated registered bank must hold against market risk exposures is set out in Part 10 of “Capital adequacy framework (standardised approach)” (BS2A) for banks subject to that approach, and is duplicated in Part 7 of “Capital adequacy framework (internal models based approach)” (BS2B) for banks subject to that approach. Total capital for market risk is the sum of the aggregate capital charge for interest rate risk, the aggregate capital charge for foreign currency risk, and the aggregate capital charge for equity risk. Main Disclosure Requirements 7. The disclosure Orders in Council (the “Orders”) require New Zealand-incorporated banks to disclose their capital charge for market risk, broken down into sub-totals for each type of market risk in their full year and half year disclosure statements, and the total amount in their off-quarter disclosure statements. This forms part of the disclosure of all the components of the bank’s total capital requirement. Overseas-incorporated banks are required to disclose notional capital charges for market risk, calculated in the same way, but described as notional charges to reflect the fact that they are not subject to actual Reserve Bank capital requirements in relation to their New Zealand business. All banks are also required to disclose the implied risk-weighted exposure for each category of market risk, calculated as 12.5 x capital charge. This is a measure of gross exposure to each risk, and is intended to be on a comparable basis with actual or implied risk-weighted exposures for other risks. 8. Banks must disclose this market risk information in respect of their end-of-period exposures in every disclosure statement. In their full year and half year disclosure statements banks are also required to disclose their peak exposures to each type of market risk over the most recent six months. The disclosure of peak market risk exposures is important because significant exposures can be (dis)established in a short period of time. Accordingly, if the market risk disclosure regime is to be effective and meaningful, disclosure of peak exposures is an essential element of the framework. Derivation Of Aggregate Market Risk Capital Charges 9. For the purposes of the end-period capital requirement and disclosure, aggregate market risk capital charges must be derived using the prescribed standard models set out in BS2A and BS2B. 10. To calculate the peak intra-period capital charge against each category of market risk, a registered bank can either calculate its end-of-day capital charge against that risk for each day over the period using the prescribed standard model, or can use any other method, such as an approach based on its own internal models, provided that that method does not yield amounts which are materially lower than the amounts which would have been derived under the standard models.
4 Ref #3089763 BS6 March 2011 Audit Requirements 11. The market risk and capital adequacy disclosures made for the full financial year and for the half year period must be examined by an external auditor. The audit opinion must state whether or not anything has come to the auditor’s attention which would cause the auditor to believe that the information on market risk and capital adequacy is not in all material respects prepared in accordance with the bank’s conditions of registration and disclosed in accordance with the applicable requirements in the Orders. 12. The full audit requirements in respect of market risk information are set out in clause 20 and Schedule 1 of the Order for locally incorporated banks, and clause 21 and Schedule 1 of the Order for overseas incorporated banks. No audit requirement applies in the off-quarters, although as for other disclosures, banks may voluntarily subject that information to audit or review. International Comparability 13. The Basel market risk framework provides for the use of either a standard model, or banks’ internal models, subject to the latter being approved by the relevant supervisory authority. 14. The standard models set out in BS2A and BS2B are based on the standard models within the Basel capital adequacy framework, and similarly to Basel, fixed assets and equity instruments representing shareholders’ funds are not included. There are some significant differences, though, between the two frameworks:
The Basel framework permits banks to use their own internal models to determine their capital requirement for market risk. The Reserve Bank has not implemented this element of the Basel framework to date, but intends to do so in due course. However, the Reserve Bank does allow banks to use alternative methods to calculate their intra-period peak capital charges for market risk.
The Basel model captures interest rate risk in the trading book only, and it is a matter of national supervisory discretion as to whether interest rate risk is additionally monitored from a broader viewpoint, that is, with respect to the bank as a whole. The framework contained in BS2A and BS2B captures banks' total exposure to interest rate risk to recognise that it is important to measure exposure to interest rate risk irrespective of whether that risk arises in the trading book or the banking book. If banks wish to separately disclose interest rate risk in the trading or banking books, they are permitted, but not required, to do so.
Unlike the Basel framework, the New Zealand framework does not capture commodity risk. This is because, as noted above, commodity risk is generally not significant for registered banks. However, the Reserve Bank will continue to monitor whether the disclosure of exposure to such risks, or a capital charge against them, should be required.
5 Ref #3089763 BS6 March 2011 and this is the capital charge. By contrast, the capital charges for currency and equity risk are derived by first calculating the gross exposure and then multiplying that amount by 8%. This is designed to ensure that the different forms of market risk exposure are placed on a comparable scale, that is, the required capital charge, which is intended to cover the value at risk. Interest Rate Exposure Standard Model 16. The standard model for calculating the capital charge for interest rate risk is set out in Part 10 of “Capital adequacy framework (standardised approach)” (BS2A) and also in Part 7 of “Capital adequacy framework (internal models based approach)” (BS2B). Under the standard model, banks' exposure to interest rate risk is measured using interest rate repricing schedules. Banks should refer to relevant financial reporting standards for additional guidance, particularly concerning the meaning of financial terms. Appendix 1 contains an example which illustrates the use of interest rate repricing schedules to measure interest rate risk using the standard methodology set out in BS2A and BS2B. Interest Rate Repricing Schedules 17. Banks must allocate financial instruments to specified time bands in a manner which reasonably reflects their assessment of the interest rate repricing date of those instruments. In allocating financial instruments across time bands, banks should use the New Zealand dollar carrying values of recognised financial instruments and the New Zealand dollar contract (or face) values of unrecognised financial instruments. 18. The time bands and time zones used in the repricing schedule are broadly consistent with the Basel model, but in some zones there are fewer time bands than under the Basel model. The specified time bands and zones are as follows:
Time bands Time zones up to 1 month 1-6 months 6-12 months Zone 1 1-2 years 2-4 years Zone 2 4-6 years 6-10 years over 10 years Zone 3
6 Ref #3089763 BS6 March 2011 Treatment of Financial Instruments 19. Banks are generally free to place instruments in the time bands according to their assessments of the interest rate repricing dates of those instruments. 20. But, in allocating instruments to the relevant time bands, banks are expected to comply with the following guidelines:
7 Ref #3089763 BS6 March 2011 Interest Rate Insensitive Retail Products 24. Interest rate insensitive retail products (RIRP's) are any financial asset or financial liability, or part thereof, for which the bank considers the interest rate earned/paid is insensitive to changes in the general level of interest rates. 25. RIRP's comprise mainly zero and low interest retail savings and transaction accounts, eg cheque account balances, saving accounts earning say 3 per cent interest or less. RIRP's can also include zero or low interest lending, eg credit card balances. 26. RIRP's can be allocated to one of two categories: core or seasonal RIRP's. Seasonal RIRP's are that proportion of RIRP's which are sensitive to intra-year seasonal patterns, ie - tax or Christmas flows. Observed variations in RIRP's over more than one year, or expected variations in RIRP's arising from future marketing strategies or technological change, are not seasonal variations. No more than 20 per cent of the end-of-period RIRP balances should be allocated to the seasonal category. 27. Seasonal RIRP's can be allocated across time bands based on banks' observations of the interest rate repricing behaviour of these funds. The 20 per cent "cap" on the amount of RIRP's that can be allocated to the seasonal category is designed to facilitate interbank comparisons of interest rate exposures. The 20 per cent threshold is based on a survey of banks' allocation of RIRP's into seasonal and core categories. 28. Core or non-seasonal RIRP's must be allocated across time bands in the following manner: Time bands Percentage of core RIRP’s 0-1 month 1-6 months 6-12 months 1-2 years 2-4 years 4-6 years 5% 5% 10% 20% 40% 20% 29. This allocation of core RIRP balances represents an industry average treatment. While individual banks may have different assumptions about the repricing behaviour of these instruments, it is important that all banks allocate their core RIRP's across time bands in the manner outlined above so that a bank's exposure to interest rate risk can be compared with the exposures of other banks. Derivatives 30. The following provides guidance on the treatment of foreign exchange contracts and derivative products:
8 Ref #3089763 BS6 March 2011 underlying fixed rate agreement and a financial liability (or asset) with a maturity equivalent to the term of the underlying floating rate agreement. The value of the notional financial asset and financial liability for an interest rate swap agreement is the notional value of the swap contract.
Directional interest rate risk 34. After the financial instruments have been allocated to the appropriate time bands in the manner described above, the net open position in each time band can be calculated. The net open position in a time band is calculated by subtracting the amount of financial liabilities in the time band from the financial assets in that band.
9 Ref #3089763 BS6 March 2011 35. The net open position in each time band is then risk weighted based on the duration of financial instruments in that time band and the assumed change in interest rates. Thus, the risk-weighted net open position measures the change in banks' net financial assets for an assumed change in interest rates. Banks which have the capacity to calculate the actual modified duration of their financial assets and liabilities, can derive their exposure to directional risk using their own systems, provided the assumed changes in interest rates are no less conservative than those contained in Table 1. 36. Alternatively banks can apply the standard risk weights contained in Table 1. These are broadly consistent with the Basel standard model. Specifically the modified durations are derived using the Basel assumption of an eight per cent coupon on all financial instruments. The assumed changes in interest rates are also consistent with Basel. Small differences in the risk weights arise because Table 1 contains fewer time bands than the Basel model. Table 1: Standard Duration Weights, Interest Rate Changes, and Risk Weights up to 1 mth 1-6 mths 6-12 mths 1-2 yrs 2-4 yrs 4-6 yrs 6-10 yrs 10+ yrs Duration Weights 0 0.3 0.7 1.4 2.5 4.3 5.8 7.3 Interest Rate Changes (%) 1.0 0.9 0.8 0.7 0.6 0.6 Risk Weights (%) 0 0.3 0.7 1.3 2.0 3.0 3.5 4.4 37. The sum of the risk-weighted open positions in each time band is the exposure to directional interest rate risk. This risk may be either positive or negative. Yield curve risk 38. The implied assumption in the measure of directional interest rate risk is that interest rate movements in each of the time bands are perfectly correlated. Accordingly, the measure of interest rate risk in a single currency needs to be adjusted to account for yield curve risk or imperfect correlation in interest rates across the yield curve. 39. The approach taken to adjust for yield curve risk is the same as the Basel "standard model". The methodology involves making a set of "horizontal disallowances" where positions in one time band are used to offset positions in another time band, ie - a proportion of the offset is added back to the risk figure. The proportion of the offset which is added back varies according to the proximity of the time bands to one another. The further apart the time bands, the greater the add-on arising from imperfect correlation along the yield curve. The horizontal methodology is as follows. (The example in Appendix 1 illustrates this methodology.)
10 Ref #3089763 BS6 March 2011 40. The yield curve is split into three time zones as identified below. There are two categories of horizontal disallowances (or add-ons):- intra-zone horizontal disallowances for divergent yield curve movements within a time zone, and inter-zone horizontal disallowances for divergent curve movements between time zones.
Intra-zone disallowances 41. The aggregate risk-weighted long and short positions in each time zone are calculated. The risk-weighted matched position in a particular time zone is the lesser of the absolute value of the risk-weighted long open positions and the absolute value of the risk-weighted short open positions in that time zone. The residual position in each time zone is the difference between the sum of the risk-weighted long and short positions in that time zone. The residual position is used to calculate inter-zone disallowances (refer below). 42. The matched position in a time zone is multiplied by a disallowance factor to determine the value of the intra-zone horizontal disallowance for that zone. The intra-zone disallowance factors are the same as those used in the Basel standard model and are as follows:
Time Zones Disallowance factors Zone 1 Zone 2 Zone 3 40% 30% 30% 43. The higher intra-zone disallowance factor for zone 1 reflects the lower correlation between interest rates in neighbouring time bands on short dated securities vis-à-vis long dated securities. Inter-zone disallowances 44. Inter-zone disallowances are derived by matching the residual positions in a particular time zone (as derived above) with the residual positions in the corresponding time zone. This method is outlined in Part 10 of BS2A and Part 7 of BS2B and is illustrated in the example in Appendix 1. The disallowance factors are the same as those contained in the Basel standard model and are as follows: Time Zones Disallowance factors Zone 1&2 Zone 2&3 Zone 1&3 40% 40% 100% 45. Banks should calculate the inter-zone (horizontal) disallowances in the following order to avoid overstating the measure of risk: Zones 1&2, Zones 2&3, and then Zones 1&3.
11 Ref #3089763 BS6 March 2011 46. Horizontal disallowances (both intra-zone and inter-zone) should always increase a bank's risk in a particular currency. Thus, if a bank's directional risk in a particular currency is negative (positive), the horizontal disallowances should be negative (positive). Basis risk 47. Basis risk has been accounted for by applying the Basel vertical disallowance methodology. When there are matched positions (ie where gross financial assets have been offset or netted against gross financial liabilities) in a time band, the amount of the matched position (ie the lesser of the absolute value of the risk-weighted financial assets and the absolute value of the risk-weighted liabilities in the band), is multiplied by a vertical disallowance factor to derive the amount of basis risk. (The example in Appendix 1 illustrates this methodology.) 48. Financial assets and financial liabilities are classified into two categories for the purposes of applying vertical disallowances: RIRP's and "securities" (financial instruments other than RIRP's). The vertical disallowance factors for these categories are as follows:
When at least one of the instrument types in the matched position is a RIRP 20% When the matched position comprises only securities: 5%
(c) If the absolute risk-weighted matched position is less than or equal to the absolute risk-weighted value of the RIRP's, then the vertical disallowance amount is the risk-weighted matched position times 20%. (d) If the risk-weighted matched position is more than the absolute risk-weighted value of the RIRP's, then the vertical disallowance amount is: (i) the absolute risk-weighted value of RIRP's times 20%; plus (ii) the remainder of the risk-weighted matched position (ie, the difference between the risk-weighted matched position and the absolute riskweighted RIRP's) times 5%.
12 Ref #3089763 BS6 March 2011 50. Vertical disallowances should always increase a bank's risk in a particular currency. Thus, if a bank's directional risk in a particular currency is negative (positive), the amount of vertical disallowance should be negative (positive). Aggregate capital charge for interest rate risk 51. A bank's aggregate capital charge for interest rate risk across all currencies is the greater of the absolute value of the sum of long individual currency positions and the absolute value of the sum of the short individual currency positions. This aggregation rule accounts, at least in part, for correlations in interest rate movements across currencies. This approach is less conservative than the standard Basel model which requires the aggregation of the absolute positions across currencies. Banks disclose the aggregate capital charge for interest rate risk, which is a positive number – they do not have to disclose whether they are exposed to an increase in interest rates (ie have an aggregate long position) or a decrease in interest rates (ie have an aggregate short position). Peak Capital Charge 52. One option for banks to comply with the requirement to disclose the intra-period peak capital charge (actual or notional) is to derive their capital charge at the end of each day using the standard methodology. 53. The alternative, as noted previously, is for banks to use their own internal models to derive the peak interest rate risk capital charge. They may do this provided they are satisfied that the peak capital charge is not materially lower than that which would have been derived using the standard model. Banks can use this option if they do not have the capacity, or would not find it efficient, to recalculate their capital charge, using the standard methodology, every time there is a significant change in the end-of-day interest rate repricing profile of traded or variant instruments. 54. A common "own value-at-risk method" used for peak reporting is a scalar approach. Under this method, the end-of-period capital charge, as derived using the standard model, is scaled by the ratio of peak capital charge (using the bank’s internal value-atrisk method) to end-of-period capital charge (using the internal value-at-risk method). Under this approach, bank directors would have to be satisfied of a number of factors including that the correlation between the internal method and the Reserve Bank's method is high and stable over time or, if it is not, that the bank’s own internal model results in an upward error.
13 Ref #3089763 BS6 March 2011 Foreign Currency Exposure Standard Model 55. The standard model for deriving the capital charge for foreign currency risk is set out in Part 10 of “Capital adequacy framework (standardised approach)” (BS2A) and also in Part 7 of “Capital adequacy framework (internal models based approach)” (BS2B). Coverage 56. Structural positions denominated in foreign currencies that are of a fixed long-term nature such as capital instruments issued by the banking group, financial instruments issued by associates of the registered bank, or investments in premises, are not included in the measure of foreign currency exposure. All other financial instruments involving an identifiable and definite foreign currency risk should be included in the measure of exposure. Single Foreign Currency Exposure 57. A bank’s exposure in a single foreign currency is the aggregate amount of its financial assets (both recognised and unrecognised) less the aggregate amount of its financial liabilities (both recognised and unrecognised) denominated in that foreign currency. A foreign currency is a currency other than New Zealand dollars. 58. Recognised financial instruments should be valued at the New Zealand dollar carrying amount. Unrecognised financial instruments should be valued at the New Zealand dollar contract or face value. However, where banks have the capacity to value financial instruments on a present value basis, they may do so for the purposes of deriving their exposure in a single currency. 59. The New Zealand dollar value of a financial instrument is the foreign currency value of that instrument converted to New Zealand dollars at the mid-point of market bid and offer rates applying at the close of business on the relevant day. Treatment of Financial Instruments 60. The following financial instruments should be included in the measure of foreign currency exposures:
14 Ref #3089763 BS6 March 2011
15 Ref #3089763 BS6 March 2011 Equity Exposure in a Single Currency 65. A bank’s equity exposure in a single currency is the aggregate amount of its equity instrument claims or assets (both recognised and unrecognised) less the aggregate amount of its equity instrument obligations or liabilities (both recognised and unrecognised) in that currency. This methodology includes equity exposures in all currencies including New Zealand dollars. 66. Recognised financial instruments should be valued at the New Zealand dollar carrying amount. Unrecognised financial instruments should be valued at the New Zealand dollar contract or face value. However, where banks have the capacity to value financial instruments on a present value basis, they may do so for the purposes of deriving their exposure in a single currency. Treatment of Equity Instruments 67. Equity instruments which should be included in the measure of equity exposure include:
16 Ref #3089763 BS6 March 2008
17 Ref #3089763 BS6 March 2008
18 Ref #3089763 BS6 March 2008