BANK OF BOTSWANA

BANKING SUPERVISION DEPARTMENT

GUIDELINES ON RISK MANAGEMENT

Issue Date: May 15, 2018

AUTHORITY, PURPOSE AND SCOPE ................................................................................. 3
(a) Authority ................................................................................................................................. 3
(b) Purpose ................................................................................................................................... 3
(c) Scope ....................................................................................................................................... 3
DEFINITIONS ........................................................................................................................... 4
INTRODUCTION .................................................................................................................... 10
(a) Types of Material Banking Risks ......................................................................................... 11
(b) Risk Management Process .................................................................................................... 11
(c) Basic Elements of a Sound Risk Management System ........................................................ 12
(d) Risk Management Function .................................................................................................. 15
(e) Risk Disclosures .................................................................................................................... 16
STRATEGIC RISK MANAGEMENT ................................................................................... 18
(a) Strategic Planning Process .................................................................................................... 18
(b) Strategic Risk Identification ................................................................................................. 18
(c) Strategic Risk Measurement .................................................................................................. 19
(d) Strategic Risk Mitigation, Monitoring and Control ............................................................. 19
(e) Strategic Risk Reporting ....................................................................................................... 20
CREDIT RISK .......................................................................................................................... 21
(a) Establishing an Appropriate Credit Risk Environment ......................................................... 21
(b) Credit Risk Identification and Measurement ........................................................................ 23
(c) Credit Risk Monitoring and Control ..................................................................................... 26
(d) Credit Risk Reporting ........................................................................................................... 35
MARKET RISK ....................................................................................................................... 36
(a) Market Risk Identification .................................................................................................... 36
(b) Market Risk Measurement .................................................................................................... 36
(c) Market risk Monitoring and Control .................................................................................... 37
(d) Market Risk Reporting ......................................................................................................... 38
INTEREST RATE RISK ............................................................................................................. 39
(a) Interest Rate Risk Identification ........................................................................................... 39
(b) Interest Rate Risk Measurement ........................................................................................... 40
(c) Interest Rate Risk Monitoring and Control .......................................................................... 42

(e) Interest Rate Risk Reporting ................................................................................................ 43
FOREIGN EXCHANGE RISK .................................................................................................. 45
(a) Foreign Exchange Risk Identification .................................................................................. 45
(b) Foreign Exchange Risk Measurement .................................................................................. 46
(d) Foreign Exchange Risk Monitoring and Control ................................................................. 47
(e) Foreign Exchange Risk Reporting ........................................................................................ 48
7. LIQUIDITY RISK MANAGEMENT .................................................................................... 49
(a) Liquidity Risk Identification ................................................................................................. 49
(b) Measurement and Management of Liquidity Risk ................................................................ 49
(c) Liquidity Risk Monitoring and Control ................................................................................ 50
(d) Liquidity Risk Reporting ....................................................................................................... 52
8. OPERATIONAL RISK MANAGEMENT ........................................................................... 54
(a) Operational Risk Culture ...................................................................................................... 54
(b) Operational Risk Identification and Measurement ............................................................... 54
(c) Operational Risk Monitoring, Control and Mitigation ......................................................... 56
(d) Operational Risk Reporting .................................................................................................. 59
(e) Business Resiliency and Continuity ..................................................................................... 60
9. COUNTRY AND TRANSFER RISK .................................................................................... 63
10. COMPLIANCE RISK MANAGEMENT ............................................................................ 65
(a) Compliance Risk Identification ............................................................................................ 65
(b) Compliance Risk Measurement ............................................................................................ 65
(c) Compliance Risk Monitoring, Control and Mitigation ........................................................ 66
(d) Compliance Risk Reporting .................................................................................................. 68
11. REPUTATIONAL RISK MANAGEMENT ........................................................................ 69
(a) Identification of Reputational Risk ....................................................................................... 69
(b) Measurement of Reputational Risk ...................................................................................... 70
(c) Monitoring, Control and Mitigation of Reputational Risk ................................................... 70
(d) Reporting of Reputational Risk ............................................................................................ 71

1. AUTHORITY, PURPOSE AND SCOPE

(a) Authority

1.1 These Guidelines are issued by the Bank of Botswana (Bank) pursuant to its authority set forth in Section 4(2) of the Bank of Botswana Act (CAP. 55:01).

(b) Purpose

1.2 The purpose of these Guidelines is to implement the provisions of all relevant sections of the Banking Act (CAP. 46:04) (Act) for the ultimate attainment of the requirements of Section 4(1) of the Bank of Botswana Act, as well as to provide guidance to banks on the management of risks, in line with the Basel Core Principles 15 - 25 and international best practice.

(c) Scope

1.3 These Guidelines apply to a bank licensed by the Bank under the Act and statutory banks established under separate Acts of Parliament, which fall under the purview of the Bank’s supervision in terms of Section 53(2) of the Act and/or their respective statutes.

2. DEFINITIONS

(a) Accommodation - A loan, advance or other credit facility, financial guarantee or other liability granted or incurred by a bank to or on behalf of any person, natural or legal.

(b) Act - The Banking Act (CAP.46:04).

(c) Audit Committee - A committee (or equivalent body) established by a board of directors of a bank for the purpose of overseeing the accounting and financial reporting processes and audits of the financial statements of a bank and ensuring the adequacy and effectiveness of the bank’s internal control systems.

(d) bank - A company which is licensed by the Bank, pursuant to the Act, to conduct banking business as defined in Section 3 of the Act.

(e) Bank - The Bank of Botswana established under the Bank of Botswana Act (CAP. 55:01).

(f) Banking book - refers to positions that are not assigned to the trading book.

(g) Basel II Directive - Directive on the Revised International Convergence of Capital Measurement and Capital Standards for Botswana

(h) Basis risk: refers to the impact of relative changes in interest rates for financial instruments that have (i) either similar tenors, but are priced using different interest rate reference curves (reference rate basis risk); or which have (ii) different tenors, but with the same reference curve (tenor basis risk or short-term non-parallel gap risk); or which have (iii) similar tenors and reference curves, but in different currencies (currency basis risk).

(i) Board of Directors - The highest body of authority in a bank responsible for the bank’s business and risk strategy, organisational financial soundness and governance. The board also provides effective oversight of senior management.

(j) Contagion effects: the advent of the spread of negative or positive consequences of a financial or economic nature across countries or regions.

(k) Contingency Funding Plan - A compilation of policies, procedures, and action plans for responding to severe disruptions to a bank’s ability to fund some or all of its activities in a timely manner and at a reasonable cost.

(l) Counterparty risk: the risk that a party to a transaction or contract will fail to fulfil its contractual obligations.

(m) Credit swaps: contracts where one side pays an ongoing fee in exchange for a guarantee that upon default the insurance will pay the full principal amount due to the contract owner.

(n) Enterprise-wide risk management: is the overall management of risk that an organisation takes and holds to achieve its strategic objectives. It is the sum of the various risks the organisation takes in the various categories and focuses on optimising the balance and interaction of the different types of risks.

(o) Expected credit losses (ECL): is the probability-weighted estimate of credit losses (i.e., the present value of all cash shortfalls) over the expected life of a financial instrument.

(p) Exposure - The amount of a bank’s exposure is calculated as follows:

(a) The sum of all loans and credit facilities granted, either directly or indirectly, to a person or group of inter-related persons, such as:

(i) term loans, overdrafts, credit lines and other credit facilities;

(ii) trade bills discounted, invoice discounts and factoring;

(iii) credit substitutes, such as guarantees, acceptances, letters of credit and bills, and finance lease receivables;

(iv) underwriting of debt and equity securities, and other forms of participations;

(v) securitised assets and other transactions with recourse;

(vi) credit derivatives, futures and forwards, swaps and option contracts such as credit default swaps and other derivatives; and

(vii) contingent liabilities, such as commitments to extend credit, performance bonds and warranties.

(b) Less the amount by which the above-listed accommodations are irrevocably secured by:

(i) eligible financial collateral meeting all the requirements of the Directive on the Revised International Convergence of Capital Measurement and Capital Standards for Botswana (Basel II Directive) placed with a bank that granted the accommodation; or

(ii) an eligible guarantee meeting all the requirements of the Basel II Directive; and

(iii) For a guarantee to be considered eligible, the following conditions must be satisfied:

(a) The credit protection must represent a direct claim on the protection provider;

(b) The guarantee or credit derivative must be explicitly referenced to specific exposures or a pool of exposures, such that the extent of the credit protection is clearly defined and incontrovertible;

(i) allows the protection provider to unilaterally cancel the protection;

(ii) increases the effective cost of the protection, as a result of the deteriorating credit quality of the protected exposure;

(iii) prevents the protection provider from being obliged to pay out in a timely manner, in the event that the original obligor fails to make any payments due; and

(iv) allows the maturity of the credit protection to be reduced by the protection provider.

(d) It must be legally effective and enforceable in all jurisdictions which are relevant at the time of the conclusion of the credit agreement;

(e) In addition to the legal certainty requirements for a guarantee to be eligible, the following conditions must also be satisfied:

(i) Upon default or non-payment by a counterparty, a bank must have the right to pursue, in a timely manner, the guarantor, for any monies due under the claim, in respect of which the guarantee is provided;

(ii) The guarantor must either make a lump sum payment of all monies due under the claim to the bank or assume the payment obligations of the counterparty that was covered by the guarantee;

(iii) A bank must have the right to receive any such payments from the guarantor, without first having to take legal action in order to pursue the counterparty for payment;

(iv) The guarantee must be an explicitly documented obligation assumed by the guarantor;

(v) The guarantee must cover all types of payments the underlying obligor is expected to make in respect of the claim; and

(vi) Where a guarantee covers payment of the principal only, interest and other amounts not covered by the guarantee must be treated as the uncovered portion.

(q) Foreign exchange settlement risks: is the risk of loss when a bank in a foreign exchange transaction pays the currency it sold, but does not receive the currency it bought.

(r) Funding Liquidity Risk - The risk that the bank will not be able to efficiently meet both the expected and unexpected current and future cash flows and collateral needs without affecting either daily operations and/or the financial condition of the bank.

(s) Interest rate sensitivity gap: measures the responsiveness of the asset and liability portfolio to changes in interest rates.

(t) Interest rate swaps: is an agreement to exchange one stream of interest payments for another.

(u) Liquid Assets - Freely transferable assets, unencumbered by any charge or lien whatsoever, located in Botswana and are central bank eligible, including:

(i) Treasury bills, Bank of Botswana Certificates, and other securities issued by the Botswana government or the Bank and maturing within 370 days;

(ii) Negotiable instruments of such types as the Bank may approve and payable within a period of 184 days; and

(iii) Such other assets as the Bank may from time to time, approve, provided that they: (1) have distinct denominations of at least P1 000; (2) are listed and actively traded by an exchange in Botswana, if instruments of public issue; (3) disclose the earliest possible date that a borrower may pre-pay; (4) are rated no less than AA- by an external credit assessment institution acceptable to the Bank; and (5) are otherwise acceptable to the Bank in accordance with the requirements for the Secured Lending Facility.

(v) Liquidity - The ability of a bank to fund asset growth and/or meet contractual obligations as they fall due, including obligations to fund loan and investment commitments, deposit withdrawals and other maturing liabilities, without incurring unacceptable capital losses.

(w) Liquidity Risk - The risk of loss to a bank resulting from inability to meet actual needs for cash or inadequate liquidity levels, which must be covered by funds obtained at excessive cost.

(x) Liquidity-Risk Management - The process of ensuring that the bank’s needs for funds, including maintaining the required level of liquidity and meeting expected and contingent cash needs can be regularly met at a reasonable cost.

(y) Management-action-trigger limits: represents the management's tolerance for accepting the market risk related losses on a daily and cumulative month-to-date basis, especially on the trading portfolio.

(z) Management information system (MIS): A computer system consisting of hardware and software that serves as the backbone of an organisation's operations.

(aa) Mark-to-market: is a measure of the fair value of accounts that can change over time, such as assets and liabilities.

(bb) Net Funding Requirements - The liquid assets necessary to fund a bank’s cash obligations and commitments in future, determined by performing a cash flow analysis in which all cash inflows are measured against all cash outflows to identify potential net shortfalls.

(cc) Open Position - the difference between a bank’s total of its foreign currency-denominated assets and liabilities, both spot and forward, in Pula currency (equivalent) balances.

(dd) Optionality risk: refers to the risk that arises from price movements in instruments that are either automatic or behavioral to changes in interest rates.

(ee) Related Person - Includes all of the following without limitations: (1) Significant shareholder; (2) member of a board of directors or audit committee; (3) principal officer and senior management officials, (4) guarantor of a trust; (5) A person who maintains a trust on behalf of a bank or its affiliate; (6) Any person who is related to such significant shareholder, member of a board of directors or audit committee, principal officer or family member or business interest; (7) subsidiary of a bank; (8) company or undertaking in which at least a 5 percent interest is held by a bank; (9) parent company of a bank; (10) company that is under common control with a bank; and (11) A company that holds at least a 5 percent interest of another company in which a bank holds at least a 5 percent interest.

(ff) Risk transfer: risk transfer is a risk management and control strategy that involves the contractual shifting of a pure risk from one party to another.

(gg) Senior Management Official - Any person who is an officer of a bank, including those holding positions of managing director or chief executive officer (and deputies), chief financial or operations officer, chief lending officer, chief internal auditor, chief treasury officer (or their equivalents), and other heads of department (core banking functions) and/or others who are in a policy-making position.

(hh) Stop loss: an advance order to sell an asset when it reaches a particular price point. It is used to limit loss or gain in a trade.

(ii) Stress testing - is a generic term often used to describe various techniques and procedures employed by banks to gauge their potential vulnerability to exceptional but plausible events. Stress testing alerts bank management to adverse unexpected outcomes related to a variety of risks and provides an indication of how much capital might be needed to absorb losses should large shocks occur.

(jj) Swap: is a derivative contract through which two parties exchange financial instruments.

(kk) Syndicated loans - credits granted by a group of banks to a borrower.

(ll) Trade financing: is the financing and facilitation of trade of goods and services, locally and internationally.

(mm) Trading book - a trading book consists of positions in financial instruments or commodities held either with a trading intent or in order to hedge other elements of the trading book.

(nn) Unencumbered - Not pledged either explicitly or implicitly as security, collateral, guarantee and/or other credit-enhancement for any transaction.

(oo) Unexpected losses: Losses above expected levels.

(pp) Value at risk (VaR): is a method of calculating financial risk based on a defined probability level. It indicates the potential loss of a position/asset over a period of time with a given level of confidence.

(qq) Yield curve risk: is a risk that arises when unanticipated shifts of the yield curve have adverse effects on a bank’s income or underlying economic value.

3. INTRODUCTION

3.1 Risk-taking is inherent in banking business. Excessive and poorly managed risk can, however, lead to losses and thus pose a threat to the safety and soundness of a bank. Therefore, the Bank places emphasis on the adequacy of a bank’s management of risk and issues these Guidelines for the purpose of providing guidance to all banks on minimum standards and requirements for sound and effective management procedures and systems to be in place at every bank.

3.2 For the purpose of these Guidelines, risk in a bank refers to the possibility that the outcome of an action or event could bring adverse impact on solvency, earnings, cash or, in general, sustainability of a bank’s operations. Such outcomes could result in either direct diminution of a bank’s earnings, or erosion of capital, loss of cash, or cash flow, or the imposition of constraints on a bank’s ability to meet business objectives. These constraints could hinder a bank’s capability to conduct business in a safe and sound manner, including the ability to effectively take advantage of opportunities that could enhance performance. As such, the board of directors (board) and senior management officials (Management) of a bank are expected to ensure that the risk a bank is taking is understandable, measurable, controllable and within a bank’s capacity to readily withstand adverse effects.

3.3 Effective risk management is core to the success of every bank and encompasses all activities that affect a bank’s risk profile. The board and Management of a bank should put in place appropriate systems and infrastructure to identify, measure, monitor, control and report overall risks that a bank may assume.

3.4 These Guidelines are aligned to the Basel Core Principles for Effective Banking Supervision. Core Principle 15 on ‘risk management processes’ requires banks and banking groups to have comprehensive risk management processes (including effective board and senior management oversight) to identify, evaluate, monitor and control or mitigate all material risks, and to assess a bank’s overall capital adequacy in relation to the risk profile. Risk-taking should be commensurate with the nature, size and complexity of a bank and the degree of a bank’s risk appetite and tolerance level. The risks a bank may be exposed to depend on factors such as business activities, nature and type of products, business cycle, economic sectors, geographic location, business model and, in general, operating strategy.

3.5 These Guidelines are not intended to prescribe a uniform set of risk-management strategies for all banks. The sophistication of processes, systems and internal controls for risk management is determined by the nature, size and complexity of the business activities of a bank.

3.6 The guidance expressed in these Guidelines is not exhaustive; other relevant regulatory requirements and applicable industry standards should also be taken into account as appropriate.

(a) Types of Material Banking Risks

3.7 The Bank assesses inherent risks using the expected impact on the supervised bank’s earnings, liquidity, capital, and, more broadly, set goals/objectives. Quantitative and qualitative factors are applied in the process of risk assessment. These Guidelines highlight some of the risks inherent in banking business as follows:

(i) Strategic Risk;
(ii) Credit Risk;
(iii) Market Risk;
(a) Interest Rate Risk;
(b) Foreign Exchange Risk;
(iv) Liquidity Risk;
(v) Operational Risk;
(vi) Country and Transfer Risk;
(vii) Compliance Risk; and
(viii) Reputational Risk.

3.8 These risks are intertwined; hence they should be managed in an integrated manner (enterprise-wide risk management).

(b) Risk Management Process

3.9 Each bank must prepare a comprehensive risk-management programme (RMP) tailored to its needs and circumstances. The RMP should be reviewed at least annually. The RMP should, at the minimum, include the following elements:

(i) Risk Identification

3.10 In order to properly manage risk, a bank must recognise and understand risks that may arise from both existing and new business initiatives (interest rate processes, products, delivery channels, etc.). For example, risks inherent in a lending activity include credit, liquidity, interest rate and operational risks. Risk identification should be a continuing process, and should be understood at both transactional and portfolio levels.

(ii) Risk Measurement

3.11 Risk should be measured accurately and timely in order to determine the impact on the bank’s profitability and capital. Risk measurement tools should be tested periodically for accuracy. Good risk-measurement systems assess the risks of both individual transactions and portfolios.

3.12 Where a bank uses models to measure components of risk, such a bank should ensure that the board and Management understand the limitations and uncertainties relating to the output of the models and the risks inherent in their use. In addition, the output of such models should be a reasonable reflection of the risks assumed. A bank should perform regular and independent validation; and testing of the models used.

For example, an internal credit risk-rating system and/or modelling should be validated using well-established external rating system/methodology.

(iii) Risk Monitoring

3.13 A bank should put in place an effective management information system (MIS) to monitor risk levels and facilitate the timely review of risk positions and exceptions. Monitoring reports should be frequent, timely, accurate and informative. Such reports should be distributed to appropriate individuals for implementation, to be specifically identified in the bank’s procedures.

(iv) Risk Mitigation and Control

3.14 A bank should establish and communicate risk limits through policies, standards, and procedures which define responsibility and authority. These limits should serve as a means to control exposure to various risks associated with the bank’s activities; they should have a process to authorise and document exceptions or changes to risk limits when warranted. A bank may also apply various mitigating tools in minimising exposure to various risks.

(c) Basic Elements of a Sound Risk Management System

3.15 A sound risk-management system should, at a minimum, have the following key elements:

Risk governance framework, including, active board and senior management oversight (BMO);
Adequate policies, procedures and limits (PPL);
Adequate risk measurement, monitoring and management information system (MIS); and
Adequate internal controls (ICs).

(i) Active Board and Senior Management Oversight

3.16 The board provides effective oversight on Management’s actions to ensure that the actions of the latter are consistent with the risk strategy, risk appetite framework and policies of the bank. The board should approve the overall business strategies and significant policies of the bank, including those related to taking and managing risks, and should also ensure that Management have skills, expertise and competence commensurate with the nature, scale and complexity of the bank’s business. The board should comprise individuals with diversified skills and work experience. Within the board, there should be a member or members designated or assigned specific responsibilities for risk-management oversight activities.

3.17 Board members should continually enhance their skills so that they are able to understand the types of risks to which banks are exposed. The board should demand to be furnished with periodic reports by a bank, for it to identify, in a timely manner, the nature and significance of the risks a bank is exposed to. The board should use

this information to provide clear guidance regarding the level of exposures suitable to a bank and have the responsibility to ensure that Management implements the procedures and controls necessary to comply with adopted policies.

3.18 Management is responsible for ensuring that the day-to-day activities of a bank are consistent with the bank’s risk strategy. This includes risk appetite and policies approved by the board; establishing and communicating a strong awareness of an effective internal control environment and high ethical standards; as well as establishing clear guidance regarding the business and risk strategy such as risk limits, in order to ensure that activities undertaken by a bank are within the risk appetite prescribed by the board of the bank.

(ii) Adequate Policies, Procedures, and Limits

3.19 The board and Management of a bank should tailor the risk-management policies and procedures to the types of risks that arise from the activities of the bank. The bank's policies and procedures should provide detailed guidance for the day-to-day implementation of broad business strategies and, generally, include limits designed to shield the bank from excessive and imprudent risks. Senior management is expected to modify these tools when necessary to respond to changes in a bank's activities or business conditions.

3.20 Every bank should ensure that:

policies, procedures and limits provide for the adequate identification, measurement, monitoring and control of the risks posed by a bank's significant activities;
established limits are understood by, and regularly communicated to, relevant staff;
policies clearly delineate accountability and lines of authority across the bank's activities;
risk-management strategic policies, processes and limits are properly documented, regularly reviewed and appropriately adjusted to reflect changing risk appetites, risk profile, market and macroeconomic conditions; and communicated within the bank; and
policies provide for the review of activities which are new to the bank in order to ensure that the infrastructure necessary to identify, measure, monitor and control risks associated with the activity are in place before the activity is adopted.

(iii) Adequate Risk Measurement, Monitoring and Management Information Systems

3.21 In order to ensure effective measurement and monitoring of risk and management information systems, the following should be observed:

a bank's risk monitoring practices and reports should address all the material risks;
key assumptions, data sources and procedures used in monitoring risk should be appropriate, adequately documented and tested for reliability on an ongoing basis;
reports and other forms of communication should be consistent with a bank's activities, structured to monitor exposures and compliance with established limits, goals, objectives; and, as appropriate, compare actual versus expected performance;
reports to the bank's board and Management should be accurate and timely and contain sufficient information for decision makers to identify any adverse trends and to evaluate adequately the level of risk faced by a bank;
risk monitoring activities must be supported by an information system that provides the board and Management with timely reports on the financial condition, operating performance and risk exposure of a bank, as well as with regular and sufficiently detailed reports for line managers engaged in the day-to-day management of the bank's activities. The sophistication of the bank's information system must keep pace with developments in the bank's risk profile, increased business complexity and new products or business lines; and
the board and Management must put in place a reporting format, which clearly delineates the likely occurrence (frequency) and impact, to be signed at regular intervals by relevant senior management officers and Board members.

(iv) Adequate Internal Controls

3.22 A bank's audit and risk management committees should review the adequacy and effectiveness of internal control systems and means through which risk exposures are managed. A sound internal control process consists of the following interrelated elements: management oversight and control culture; risk recognition and assessment; control activities and segregation of duties; information and communication; and monitoring activities and correcting deficiencies.

3.23 A bank should establish and maintain an effective system of controls, including the enforcement of official lines of authority and appropriate separation of duties, such as trading, custody and back-office.

3.24 Failure to implement and maintain an adequate separation of duties can lead to serious losses, compromise the financial integrity of a bank and may warrant formal enforcement action by the Bank.

3.25 Ideally, internal controls should be tested by an independent internal auditor, who reports directly either to a bank's board or its audit committee.

3.26 In order to ensure the adequacy of a bank's internal controls and audit procedures, the following should be observed:

the system of internal controls should be appropriate to the type and level of risks posed by the nature and scope of a bank's activities;
the bank's organisational structure should establish clear lines of authority and responsibility for monitoring adherence to policies, procedures, and limits;
reporting lines should provide sufficient independence of the control areas from the business lines and adequate separation of critical functions throughout the bank, such as those relating to trading, custodial and back-office activities¹;
official bank structures should reflect actual operating practices;
financial, operational and regulatory reports should be reliable, accurate and timely; wherever applicable, exceptions should be noted and promptly investigated;
adequate procedures for ensuring compliance with applicable laws and regulations should be in place;
internal audit or other control review practices should provide for independence and objectivity;
internal controls and information systems should be adequately tested and reviewed; the coverage, procedures, findings and responses to audits and review tests should be adequately documented; identified material weaknesses should be given appropriate and timely high level attention; and Management's actions to address material weaknesses should be objectively verified and reviewed; and
the bank's audit committee or board of directors should review the effectiveness of internal audits and other control review activities on a regular basis.

(d) Risk Management Function

3.27 Every bank should establish a risk management function (function) headed by a senior management official (executive level), which oversees risk-management strategies employed by a bank. The function should be independent of those that take or accept risks on behalf of a bank and should report directly, functionally to the board or relevant sub-committee of the board.

¹ For example: business origination, payments, reconciliation, risk management, accounting, audit and compliance.

3.28 The risk management function should ensure that effective processes are put in place for:

(i) identifying current and emerging risks;
(ii) developing risk assessment and measurement systems; (iii) establishing policies, practices and other control mechanisms to manage risks; (iv) developing risk-tolerance limits for senior management and board approval; (v) monitoring positions against approved risk-tolerance limits; and (vi) reporting results of risk monitoring to senior management and the Board.

(e) Risk Disclosures

3.29 A bank should make sufficient public disclosures that would allow stakeholders to determine whether it identifies, assesses, monitors and controls/mitigates risks effectively. The amount and type of disclosures should correspond with the size, risk profile and complexity of the bank's operations, and evolving industry practices. The disclosures must include, at least, the following elements:

(i) A formal disclosure policy approved by the board of directors, which addresses the bank’s approach to determining what risk disclosures it will make and the internal controls over the disclosure process;

(ii) Implement a process for assessing the appropriateness of the bank’s disclosures, including the verification and the frequency of the disclosures. The disclosures should be consistent with how senior management and the board assess and manage the risk of the bank; and

(iii) The public relations function of the bank or its designate should manage the communication of information to the market, so that it either builds reputation or minimises the impact of adverse reputation risk events. It should also be responsible for monitoring a bank’s reputation within the market place. Depending on the nature, size and complexity, and the risk profile of a bank, the specifics of the governance structure of the public relations function may vary.

3.30 These risk-management disclosures must, at a minimum, meet the requirements under Pillar III of Basel II.

(f) Risk Capital

3.31 Consistent with the Basel II Directive, a bank must hold Basel II compliant capital to cushion all risks.

3.32 In addition, a bank must ensure that well-defined processes are in place to assess its capital adequacy in relation to its risk profile. Based on the material risks identified, a bank should assess its overall capital adequacy, and develop a strategy for maintaining capital levels consistent with its risk profile and business plans. This

should be reflected in a bank’s capital planning process and the setting of internal capital targets. The capital planning process must be dynamic and forward-looking in relation to a bank’s risk profile. In addition, a bank should have a robust system for the continuous monitoring and reporting of risk exposures, and assess how its changing risk profile affects its capital.

3.33 For risks that are not easily quantifiable or related to capital, focus should be directed at ensuring the effectiveness of their management and mitigation. Adequate systems and processes for managing these risks should be put in place and implemented effectively, with consideration for providing appropriate capital for any residual risks that cannot be reduced to satisfactory levels.

(g) Supervisory Expectations

3.34 In the discharge of their functions, supervisors shall apply a risk-based supervisory approach to assess risk in a broader context than that reflected by the balance sheets of individual banks. That is, the supervisory “risk perimeter” shall extend beyond accounting consolidation concepts. In this regard, when compiling a bank’s risk profile, the supervisor should consider risks arising from within an individual bank (solo perspective), from its associated entities (banking group and group-wide basis) or from the prevailing macroeconomic environment. This is in line with the requirements of Principle 8 of the Basel Core Principles for Effective Banking Supervision, that requires the supervisor to develop and maintain a forward-looking assessment of the risk profile of individual banks and banking groups, proportionate to their systemic importance; as well as to identify, assess and address risks emanating from banks.

3.35 Consistent with the Basel II Directive, the supervisor shall ensure that banks periodically disclose to the market their risk-management practices to promote and maintain public confidence. Such risk disclosure and transparency will allow market participants to understand more fully a bank’s risk profile and thereby reduce market uncertainties about the bank’s financial strength.

(h) External Auditors

3.36 Consistent with the requirements of the Banking Act, relevant accounting standards and international best practice and Guidelines on banks’ audit committees, annual independent external audit and publication of audited financial statements, a bank’s external auditor should monitor its compliance with the requirements of these guidelines. Where there is a breach or non-compliance, such auditor must notify the Bank as soon as practical. Furthermore, the auditor should always communicate in writing to those charged with governance all significant audit findings and reportable matters, including poor risk management practices.

4. STRATEGIC RISK MANAGEMENT

4.1 Strategic risk is a possible source of loss that might arise from the pursuit of an unsuccessful business plan. For example, strategic risk might arise from making poor business decisions, from the substandard execution of decisions, from inadequate resource allocation, or from failure to respond adequately to changes in the business environment.

4.2 Strategic risk can arise from either internal or external risk factors. Internal factors are under the control of the bank and can affect or deter the implementation of the strategic plan. Such factors include the organisational structure; culture, work processes and procedures; personnel; and information and technology. External risk factors are factors which the bank has minimal or no control over and can also affect or deter the realisation of the goals determined in the strategic plan. Such factors may include competition; change of target customers; technological changes; economic factors and regulations.

(a) Strategic Planning Process

4.3 A bank should put in place a strategic plan, which should be supported by a realistic budget. A strategic plan clarifies a bank’s overall purpose, defines goals and priorities and determines practical approaches for achieving targeted priorities. Therefore, it should encompass the following:

(i) support or participation of the board, delegated committees, senior management and staff from various departments;

(ii) adequacy of information in developing assumptions in relation to economic factors, technological changes, changes in law, position of the bank compared to competitors, current competitive position, future market trends and customer needs, among others;

(iii) consistency of the operational plans with the overall objective of a bank;

(iv) assessment of actual performance against strategic plans; and

(v) a bank should periodically evaluate actual performance against the strategic plan in order to monitor and adjust its plans appropriately. The evaluation should be measurable, and with adequate frequency.

(b) Strategic Risk Identification

4.4 Identification and measurement of strategic risk can be determined through strategic planning and the preparatory process of a strategic plan. Both the strategic plan and the operational plan, as well as the budget, should be consistent with the business scope, complexity, external environment and internal factors of the bank, including the size and resources.

4.5 The strategic risk management policy should provide general guidelines to strategic risk management. The policy should contain at least the following: definition of strategic risk; sources of strategic risk; risk mitigation factors and a bank’s accepted tolerance for strategic risk exposure.

4.6 Management should fully participate and carefully decide on the basis of information that business and strategic plans are feasible and appropriate. Management should ensure good communication and cooperation between all employees and departments involved in the strategic planning process.

4.7 A bank should establish and maintain a management information system (MIS) which enables the board to identify and measure the risks associated with the bank’s strategic plan. The level of sophistication of the system should depend on the nature, scale and complexity of the business segments within the business plan of a bank. The MIS should enable Management to monitor:

(i) current and forecast economic conditions;
(ii) current and forecast industry and market conditions; (iii) exposure to different sectors and associated sector risks; and (iv) mechanisms that are in place to identify exceptions to limits and guidelines, and corrective action required.

(d) Strategic Risk Mitigation, Monitoring and Control

4.8 A bank needs strong internal control systems to ensure that it is not unduly exposed to strategic risks. Hence, a bank should adopt and implement robust strategic risk mitigation measures and techniques to enhance the achievement of strategic objectives. These include engaging requisitely qualified and experienced board and Management, formulation of strategic and operational plans, high quality personnel and proper training, comprehensive risk-management systems and adequate access to information, as well as timely and efficient introduction of new products or services. Internal controls should ensure that:

(i) a bank’s structure establishes clear lines of authority; (ii) a bank’s systems and structures provide for business continuity planning; and (iii) the process of setting up and reviewing strategic and business plans are comprehensive and carefully adhered to.

4.9 Internal and external audits are integral to the implementation of a risk-management process to control risk associated with a bank’s business strategy. To carry out their function effectively, Internal Auditors should have appropriate skills, knowledge and authority as well as independence within a bank to ensure that senior management reacts to and acts upon their recommendations.

4.10 A bank’s internal audit function should, among other things, perform periodic checks on whether the strategic risk-management system is properly implemented and the established policies and control procedures in respect of risk management are complied with.

(e) Strategic Risk Reporting

4.11 The reporting of strategic risk should be entrusted to an independent functional unit within a bank. Reporting could be in the form of performance reporting, on-going monitoring and/or appraisal to the board.

4.12 In order to enable effective risk reporting, the board and senior management should ensure the availability of information systems which can identify and measure strategic risk in an accurate, reliable and regular manner. The information systems should be able to provide information required to support implementation of a bank’s strategic plans. Therefore, the information systems should be able to collect financial, accounting and other data, such as data on economic conditions, competition, technology and regulatory requirements. Furthermore, to remain effective, a bank should review its MIS regularly and subject it to regular upgrades and modification.

4.13 Reporting should be done, at least once a year; in order to provide timely and adequate information to judge the changing nature of the bank’s strategic risk profile and evaluate compliance with the stated policy objectives and constraints. This notwithstanding, any material changes of information on a bank’s strategic risk profile or other items of the strategic plan prone to rapid change must be reported in the interim.

5. CREDIT RISK²

5.1 This section provides guidance on sound practices in credit risk management. While the principles contained in this section are, in the main, applicable to the business of lending, should be applied to all activities where credit risk is present.

5.2 Credit risk is defined as the risk that a counterparty will fail to perform fully its financial obligations, or the potential that a bank borrower or counterparty will fail to meet its obligations in accordance with agreed terms. It could arise from multiple activities, such as default of loan or bond obligation, or from the guarantor, credit enhancement provider or derivative counterparty failing to meet its obligations. Credit risk also includes credit concentration risk and insider lending.

5.3 The goal of credit risk management is to maximise a bank’s risk-adjusted rate of return by maintaining credit risk exposures within acceptable parameters. A bank needs to manage the credit risk inherent in the entire portfolio, as well as the risk in individual credits or transactions. The effective management of credit risk is a critical component of a comprehensive approach to risk management and is essential to the long-term success of any banking organisation.

5.4 For most banks, loans are the largest and most obvious source of credit risk. However, other sources of credit risk exist throughout the activities of a bank, including in the banking book and trading book, and both on and off-balance sheet items. For example banks face credit risk (or counterparty risk) in various financial transactions other than loans, including on inter-bank transactions, trade financing, foreign exchange transactions, financial futures, swaps, bonds, equities, options, and in the extension of commitments and guarantees, and the settlement of transactions.

5.5 The sound practices for the effective management of credit risk set out in this section addresses the following areas:

(a) Credit risk management, policies and procedures; (b) Credit risk identification and measurement; (c) Credit risk monitoring and control; and (d) Credit risk reporting.

(a) Establishing an Appropriate Credit Risk Environment

5.6 A bank should formulate and implement a structured credit risk management strategy, which will include credit-risk policies and related processes. The strategy should be approved and reviewed regularly (at least annually) by the board of directors. The strategy and policies should cover the various activities of the bank

² Reference Documents: Guidelines on the Revised International Convergence of Capital Measurement and Capital Standards for Botswana (Basel II) (September 8, 2015); Basel Core Principles for Effective Banking Supervision (September 2012) (Principles 17, 18, 19, 20 and 21); Principles for the Management of Credit Risk (September 2000).

in which credit exposure is a significant risk and should reflect the bank’s risk appetite, risk profile and capital strength.

5.7 The credit-risk strategy should establish the objectives for assuming, identifying, measuring, monitoring, reporting and controlling or mitigating credit risk.

5.8 Sound credit risk management involves managing the risk and reward relationship and controlling and minimising credit risk across a wide spectrum, such as exposure type, economic sector, geographical location, currency, maturity, target markets, desired portfolio mix and anticipated profitability. This might also include identification of target markets and other desirable outcomes such as levels of diversification and concentration tolerance.

5.9 A bank’s comprehensive credit risk management programme should:

(a) identify existing or potential credit risks to which the bank is exposed in conducting its business activities and developing and implementing sound and prudent credit policies to effectively manage and control these risks;

(b) develop and implement effective credit granting, documentation and collection processes; and

(c) develop and implement comprehensive procedures to effectively monitor and control the nature, character and quality of the credit portfolio.

5.10 The Management of a bank should implement the credit strategy approved by the board of directors. The board should ensure that senior management is fully capable of managing the credit activities conducted by the bank and that such activities are effected based on the risk strategy, policies and tolerance levels approved by the board.

5.11 The senior management of a bank should develop policies and procedures for identifying, measuring, monitoring and controlling credit risk. The policies should be designed and implemented in the context of internal and external factors such as the bank’s level of capital, management and staff capabilities, credit needs in the bank’s market area, anticipated future growth and technology.

5.12 Policies and procedures that are properly developed and implemented should enable the bank to:

(a) maintain sound credit-granting standards;
(b) identify, measure, monitor and control credit risk at both individual and portfolio levels; (c) properly evaluate new business opportunities; and (d) identify and administer problem credits.

5.13 For a bank’s credit policy to be considered adequate, it should, at a minimum, address the following:

(i) types of credit offered by the bank, by exposure type (commercial, consumer, real estate, etc.), economic sector, geographic location, currency, maturity, target markets and desired portfolio mix;

(ii) guidelines which, at a minimum, address the goals for portfolio mix and risk diversification, and the bank’s plans for monitoring and taking appropriate corrective action, if deemed necessary, on any concentrations that may exist;

(iii) detail the structure of the credit approval authority and process, approval limits and approval lending authority of each loan officer, management or board credit committee, including procedures for granting exceptions;

(iv) responsibility of the board of directors in reviewing, ratifying or approving loans;

(v) indicate acceptable collateral and terms and conditions under which unsecured loans would be granted;

(vi) terms and conditions for both price and non-price related items, including maturity and payment structure, interest rate, fees and collateral;

(vii) limitations on the maximum volume of credits, individually and by exposure type;

(viii) credit documentation, monitoring and classification;

(ix) appropriate and adequate collection procedures, including, but not limited to, actions to be taken against borrowers who default; and

(x) reporting and internal communication of exceptions.

5.14 A bank should provide a system to conduct credit risk management under Directive on the Revised International Convergence of Capital Measurement and Capital Standards for Botswana (Basel II) in a manner suited to the risk management approach it has adopted.

(b) Credit Risk Identification and Measurement

5.15 A bank should have methodologies that enable it to quantify the risk involved in exposures to individual borrowers or counterparties. A bank should use measurement techniques that are appropriate to the complexity and level of the risks involved in its activities, based on robust data, and subject to periodic validation (e.g., externally validated internal rating model).

5.16 A bank should have objective and precise statistical techniques, such as value at risk, for the measurement of credit risk quantity. A bank should also be able to analyse credit risk at the product and portfolio level, in order to identify any particular sensitivities or concentrations.

5.17 A bank should have a management information systems (MIS) and analytical techniques that enable Management to measure the credit risk inherent in all on and off-balance sheet activities. The MIS should provide adequate information on the composition of the credit portfolio, including identification of any concentrations of risk.

5.18 The bank’s information system should be able to aggregate credit exposures to individual borrowers and counterparties by type, economic sectors, country, geographical area and currency.

5.19 The bank’s MIS should monitor actual exposures against established limits and all exposures should be included in a risk-limit measurement system. The exposures approaching risk limits should be brought to the attention of senior management. Exceptions to credit-risk limits should be reported to senior management, on a meaningful and timely basis.

5.20 The measurement of credit risk should take into account:

(i) the specific nature of the credit (loan, derivative, overdraft, etc.) and its contractual and financial conditions (maturity, reference rate, etc.);

(ii) the exposure profile until maturity in relation to potential market movements;

(iii) the existence of credit risk mitigants, such as collateral or guarantees; and

(iv) the potential for default based on the internal credit risk rating.

5.21 A bank should periodically employ stress testing and back testing in evaluating the quality of its credit risk-assessment models and establish internal tolerance limits for differences between expected and actual outcomes; and have processes for updating limits, as conditions warrant. The validation of internal credit risk assessment models should be subject to periodic review by qualified, independent individuals (e.g., internal, external auditors and bank supervisors):

5.22 Stress testing of the credit portfolio should involve identifying possible events or future changes in economic conditions that could have unfavourable effects on a bank’s credit exposures and assessing the bank’s ability to withstand such changes. Three areas that a bank could usefully examine are:

(a) economic or industry downturns (both in the whole economy and in particular sectors);

(b) market risk events (interest rate risk and foreign exchange risk); credit-risk events higher than expected levels of delinquencies and defaults; and

5.23 Stress testing could range from relatively simple alterations in assumptions about one or more financial, structural or economic variables to the use of highly sophisticated financial models.

5.24 The output of the tests should be reviewed periodically by senior management and appropriate action taken in cases where the results exceed agreed tolerances. Stress-test analyses should include contingency plans regarding actions management might take given certain scenarios. The output should also be incorporated into the process for assigning and updating policies and limits.

Credit Granting Processes

5.25 A bank should operate within sound, well-defined credit-granting criteria. These criteria should include a clear indication of the bank’s target market and a thorough understanding of the borrower or counterparty as well as the purpose and structure of the credit and its source of repayment.

5.26 A bank’s credit-granting approval process should establish accountability for decisions taken and designate who has the absolute authority to approve credits or changes in credit terms. Approval authorities should be commensurate with the expertise of the individuals involved.

5.27 Each bank should develop a clear understanding of the credit risk involved in more complex credit-granting activities. For example, loans to certain industry sectors, asset securitisation, customer-written options, credit derivatives (e.g., credit swaps, interest rate swaps) and credit-linked notes.

5.28 All extensions of credit should be made free of conflict of interest and on an arm’s-length basis. Extensions of credit should be made subject to the criteria and processes described in the bank’s credit granting process.

5.29 Material transactions³ with related parties should be subject to the approval of the board (excluding board members with conflict of interest), and in certain circumstances (e.g., a large loan to a major shareholder) reported to the Bank.

³ Refer to Section 17 of the Banking Act Cap. 46:04 and Banking Regulation 9 for material transactions. Also refer to Guidelines on Transactions with Related Parties and Guidelines on Large Exposures

5.30 A bank that participates in loan syndications or other such loan consortia should not place undue reliance on the credit risk analysis done by the lead underwriter or on external commercial loan credit ratings. All syndicate participants should perform their own due diligence, including independent credit risk analysis and review of syndicate terms prior to committing to the syndication. Each bank should analyse the risk and return on syndicated loans in the same manner as directly sourced loans.

5.31 A bank could utilise techniques to mitigate credit risk consistent with the standardised approach for credit risk as outlined in Annexure 3 of the Basel II Directive. Transactions should, however, be entered into primarily on the strength of the borrower’s credit worthiness and ability to repay the facility in accordance with the agreed terms. Collateral should neither be a substitute for a comprehensive assessment of the borrower or counterparty nor should it compensate for insufficient information. A bank should have policies covering the acceptability of various forms of collateral, procedures for the ongoing valuation of such collateral and a process to ensure that collateral is, and continues to be, enforceable and realisable. With regard to guarantees, a bank should evaluate the level of coverage being provided in relation to the credit quality and legal capacity of the guarantor.

5.32 A bank should develop appropriate credit limits, consistent with the bank’s risk appetite, risk profile and capital strength which are understood by, and regularly communicated to all relevant staff. Limits should be defined in line with the existing Guidelines on Large Exposures and a bank must ensure that it complies with these guidelines.

5.33 A bank should have procedures to identify situations where, in considering credits, it is appropriate to classify a group of obligors as connected counterparties and, thus, as a single borrower. This would include aggregating exposures to a group of accounts exhibiting financial interdependence, including corporate or non-corporate, where they are under common ownership or control or with strong connecting links. A bank should have procedures for aggregating exposures to individual clients across business activities.

5.34 A bank should establish overall credit limits at the level of individual borrowers and counterparties, and groups of connected counterparties that aggregate in a comparable and meaningful manner, the different types of exposures, both in the banking and trading book and on-and-off-balance sheet. The limits should also be established for particular industries or economic sectors, countries, geographic regions and specific products. The limits established should comply with those stipulated in the Banking Act, Regulations and/or Guidelines, where necessary.

5.35 A bank may manage credit concentrations and other portfolio issues using such mechanisms as loan sales, credit derivatives, securitisation programmes and other secondary loan markets, provided that it has policies and procedures, as well as adequate controls, in place for these mechanisms.

5.36 A bank is encouraged to develop and utilise an internal credit risk rating system in managing and monitoring credit risk. The rating system should be consistent with the nature, size and complexity of a bank’s activities. Large loans, as determined by the board, must be individually assessed and rated using the internal credit grading (rating) system. Other smaller loans or groups of smaller loans (i.e., schemes), may be classified on the basis of either a credit risk grading system, payment delinquency status or credit scoring system.

5.37 Where internal ratings are assigned to an individual borrower or counterparty at the time the credit is granted, such rating should be reviewed on a periodic basis and be assigned a new rating when conditions either improve or deteriorate. It is also important that the consistency and accuracy of ratings is examined periodically by a function such as an independent credit review group.

5.38 A bank must validate internally generated credit ratings/scoring by mapping such ratings to the ratings of the recognised external credit rating agencies outlined in the Revised Directive on the International Convergence of Capital Measurement and Capital Standards for Botswana.

5.39 Exposures with credit risk grades for individually assessed loans that are either large, complex, high risk, deteriorating ratings or problem credits should be subject to additional oversight and monitoring; for example, through more frequent visits from credit officers and inclusion on a watch list that is regularly reviewed by the board and senior management. The internal credit risk ratings could be used by line management in different departments to track the current characteristics of the credit portfolio and help determine necessary changes to the credit strategy of the bank.

5.40 A bank should maintain proper documentation for each credit accommodation. Credit documentation requirements for each type of credit accommodation offered by the bank should be listed in its credit granting standards.

5.41 The credit files should include all the information necessary to ascertain the current financial condition of the borrower or counterparty, as well as sufficient information to enable decision making. Credit files should, at a minimum, include credit application, current financial statements, financial analysis, record of all credit reference letters, appraisal, record of all guarantees and securities, record of terms and conditions of the facility and internal credit ratings.

Asset/Credit Classification

5.42 At the minimum, a bank should classify its assets into the following regulatory credit classification categories:

(a) Standard or Pass

5.43 A credit is in the “pass/standard category if there are no:

(i) Material or significant performance problems (the credit is current and the borrower is complying, and is expected to continue to comply, with all terms of the contract); or

(ii) Technical and/or legal documentation deficiencies.

(b) Special Mention or Watch

5.44 A credit should be in the “special mention” or watch category if it is currently protected, but potentially weak. That is, assets with potential weaknesses that may, if not checked or corrected, weaken the asset as a whole or potentially jeopardise a borrower’s repayment capacity in the future. This would, for example, include credit given through inadequate loan agreement or covenants, a lack of control over collateral, or incomplete or inadequate documentation, as well as adverse trends which are not yet serious enough for a classification of Substandard.

5.45 A credit should be classified as “sub-standard” if it has one or more well-defined weaknesses that make the full collection of principal and interest questionable. This would include, for example, (i) deterioration of the borrower’s financial condition, including net worth and/or repayment capacity; (ii) the pledged collateral (if any) is undocumented, insufficient, or deteriorating; (iii) the borrower’s financial information is absent or unsatisfactory; (iv) other adverse factors exist, which cause concern regarding the ability of the borrower to repay the credit in accordance with the existing repayment terms, such as delinquency of 90 days, significant deviation from original source of repayment or carryover debt; and/or (v) an actual breach of the contract has occurred.

5.46 All accommodations that are three (3) months in arrears should be, at a minimum, be classified as “Substandard”.

(d) Doubtful

5.47 A credit shall be classified as “doubtful” when weaknesses exist which make collection or repayment in full, highly questionable and improbable based upon currently existing circumstances, and the estimated recoverable amount of the pledged collateral (if any). Such credits generally display high levels of delinquency and the possibility of loss is very high. However, because of certain important and reasonably specific pending factors, which may work to the advantage and strengthening of the credit, classification of the credit as “loss” is deferred until its more exact status is determined. Pending factors include a merger/acquisition and capital injection. .

5.48 All accommodations that are four (4) to six (6) months in arrears should be, at a minimum, be classified as “doubtful”.

(e) Loss

5.49 At the time of classification, the credit is deemed uncollectable and of such little value that it should not continue to be included on the accounts and financial statements of the bank. The classification of credit as loss does not mean that the credit has no recovery or salvage value, but that the bank should not defer writing it off even though at least part of the value could be recovered in the future. Such classification does not cancel the borrower’s obligation to repay, nor does it mean that the bank should not continue to exercise its full legal right to collection or payment. Loans classified as loss may have severe delinquency, unsecured and/or not well secured and not in the process of collection. Overdrafts considered loss may be hardcore, stagnant for a long period of time and unsecured or not well secured.

5.50 All accommodations that are more than six (6) months in arrears should be considered for classification as “Loss”,

Performing and Non-Performing Status of Credit Exposures

5.51 For regulatory reporting and disclosure purposes, credit exposures shall be broadly categorised as “performing” and “non-performing”; where performing exposures shall consist of “standard” and “special mention” exposures (subject to such exposures not having significant credit risk as per the prevailing accounting standards). Non-performing exposures shall consist of all “special mention” exposures with significant credit risk as per applicable accounting standards, sub-standard, doubtful and loss, as well as all credit exposures that meet the definition of non-performing loans outlined in paragraphs 5.54-5.57 below.

Mapping Regulatory Non-performing Assets (NPA) Frameworks with the Accounting Concept of Impaired Assets – Interim Approach

5.52 A bank should map the five regulatory categories of credit exposures onto the accounting concept of impaired assets (IFRS 9) as detailed below. Pass credit exposures shall map onto Stage 1. Stage 3 shall consist of sub-standard, doubtful and loss exposures, while the special-mention exposures shall be disaggregated into performing and non-performing (as per paragraph 5.51) and the performing portion would form part of Stage 1, while the performing portion will map onto Stage 2.

	Regulatory Credit Exposure Categorisation
	Standard/ Pass	Special Mention/Watch	Sub-Standard	Doubtful	Loss
	Performing	Non-performing
IFRS 9 Categorisation	Stage 1	Stage 2	Stage 2	Stage 3

Frequency of asset classification

5.53 Asset reclassification should be done on a monthly basis. However, if between these reviews the bank gains knowledge of a significant deterioration in the quality of an individual credit or in part of the bank’s portfolio, the bank should reclassify such credit exposures to reflect their true status.

Identification of non-performing exposures

5.54 Non-performing exposures should always be categorised for the whole exposure, including when non-performance relates to only a part of the exposure, for instance, unpaid interest. For off-balance sheet exposures, such as loan commitments or financial guarantees, the whole exposure is the entire cancellable nominal amount.

5.55 The following exposures shall be considered as non-performing:

(a) all exposures that are “defaulted” under the Basel II framework;

(b) all exposures that are credit-impaired (having experienced a downward adjustment to their valuation due to deterioration of their creditworthiness) according to the applicable accounting framework;

(i) are material exposures that are more than 90 days past due; or

(ii) where there is evidence that full repayment based on the contractual terms, original or, when applicable, modified (e.g., repayment of principal and interest) is unlikely without the bank’s realisation of collateral, whether or not the exposure is current and regardless of the number of days the exposure is past due.

(d) forborne exposures⁴ should be identified as non-performing when they meet the specific criteria provided for in this definition.

5.56 Collateralisation or received guarantees should have no direct influence on the categorisation of an exposure as non-performing. That is, the collateralisation or guarantee status does not influence the past-due status, including the counting of past-due days and the determination of the exposure as nonperforming, once the materiality and overdue days threshold have been met. When the relevant criteria are met, an exposure should be categorised as non-performing even if the collateral value exceeds the amount of the past-due exposure.

⁴ See paragraph 5.59

Re-categorisation of non-performing exposures as performing

5.57 An exposure ceases to be non-performing and can be re-categorised as performing when all the following criteria are simultaneously met:

(a) the counterparty does not have any material exposure more than 90 days past due;

(b) repayments have been made when due over a period of at least three continuous months as specified by the supervisor. A longer repayment period shall be required for non-performing forborne exposures as detailed in paragraphs 5.58 – 5.64;

(c) the counterparty’s situation has improved to the extent that the full repayment of the exposure is likely, according to the original or, when applicable, modified conditions; and

(d) the exposure is not “defaulted” according to the Basel II standard or “impaired” according to the applicable accounting framework.

5.58 The following situations will not lead to the re-categorisation of a non-performing exposure as performing:

(a) partial write-off of an existing non-performing exposure, (i.e., when a bank writes off part of a non-performing exposure that it deems to be uncollectable);

(b) repossession of collateral on a non-performing exposure, until the collateral is actually disposed of and the bank realises the proceeds (when the exposure is kept on balance sheet, it is deemed non-performing); or

(c) extension or granting of forbearance measures to an exposure that is already identified as non-performing subject to the relevant exit criteria for non-performing exposures. The re-categorisation of a non-performing exposure as performing should be made at the same level (i.e., at counterparty or transaction level) as when the exposure was originally categorised as non-performing.

Identification of forbearance

5.59 Forbearance includes concessions that are granted due to the counterparty’s financial difficulty on any exposure in the form of a loan, a debt security or an off-balance sheet item (e.g., loan commitments or financial guarantees) regardless of the measurement method for accounting purposes.

5.60 The identification of an exposure as forborne does not affect its categorisation as impaired for accounting purposes or as defaulted in accordance with the regulatory framework.

5.61 Refinancing an existing exposure with a new contract due to the financial difficulty of a counterparty could qualify as a concession, even if the terms of the new contract are no more favourable for the counterparty than those of the existing transaction.

5.62 A forborne exposure will be identified as such until it meets both of the following exit criteria:

(a) When all payments, as per the revised contractual terms, have been made in a timely manner over a continuous repayment period not less than one year (probation period for reporting). The starting date of the probation period should be the scheduled start of payments under the revised terms, regardless of the performing or non-performing status of the exposure at the time that forbearance was granted; and

(b) The counterparty has resolved its financial difficulty.

5.63 Forbearance may be granted on performing or non-performing exposures. When forbearance is applied to a non-performing exposure, the exposure should remain non-performing. When forbearance is applied to a performing exposure, the bank then needs to assess whether the exposure meets the non-performing criteria, even if the forbearance resulted in a new exposure. When the original exposure would have been categorised as non-performing at the time of granting forbearance, had the forbearance not been granted, the new exposure should be categorised as non-performing.

5.64 When a forborne exposure under the probation period is granted new forbearance, this should trigger a re-start of the probation period, and banks should consider whether the exposure should be categorised as non-performing. Similarly, when a forborne exposure becomes non-performing during the 12-month probation period, the probation period starts again.

5.65 A bank must not use forbearance practices to avoid categorising loans as non-performing. Therefore, the definition prohibits the upgrading of a non-performing exposure by granting forbearance measures and requires a separate categorisation for forbearance exposures.

Treatment of Accrued Interest on Impaired Credits

5.66 Accrued interest on any loan in arrears exceeding three months should be suspended. Such accrued interest should only be released to income when both the interest and the past due principal amounts have been collected in cash. This principle should be applied to overdrafts in excess of authorised limits and any other credits, investments, etc., which do not perform in accordance with agreed terms for a defined period, in this case 90 days and above.

5.67 A bank should cease to accrue interest on a credit as soon as it is identified as impaired. At a minimum, the following credits should be placed on non-accrual status:

(i) All adversely classified credits

(ii) Credits 90 days or more past due. (A bank may determine in its own credit policy that certain types of credits should be subject to non-accrual when delinquent for less than 90 days).

Capital Requirements for Impaired Credits (non-performing for more than 90 days)

5.68 A bank should hold capital for any unsecured portion of any loan that is past due for more than 90 days, net of specific provisions (including partial write-offs), as prescribed in the Basel II Directive.

Credit Impairment Provisions

5.69 A bank must compute credit impairment provisions in terms of the relevant accounting standards and such provisions shall be accordingly mapped onto the corresponding prudential credit exposure categorisation.

Loan-Loss Provisioning Policy

5.70 A bank should develop and implement comprehensive procedures and information systems to monitor the quality of its loan portfolio. These procedures should define criteria for identifying and reporting potential problem credits and other transactions to ensure that they are subject to more frequent monitoring, as well as possible corrective action, classification and/or provisioning.

5.71 A loan should be identified as a problem asset when there is reason to believe that all amounts due, including principal and interest, will not be collected in accordance with the contractual terms of the loan agreement. A loan should be re-classified as performing when all arrears have been cleared and the loan has been brought fully to current status; repayments have been made in a timely manner over a continuous period (with evidence of continued collection), in accordance with the agreed contractual terms.

5.72 A loan shall be classified as impaired if the bank considers that the obligor is unlikely to pay its credit obligations to the bank in full, without recourse by the bank to the legal actions allowed under the agreement and law, such as realising security (if held); and/or the obligor is past due for more than 90 days on any material credit obligation to the bank. Overdraft facilities will be considered as being impaired once the customer has breached an advised limit.

5.73 A bank’s provisioning policy should clearly set out how the bank will manage problem credits. Responsibility for such credits may be assigned to the originating business function, a specialised workout section, or a combination of the two, depending upon the size and nature of the credit and the reason for its problems.

5.74 Loan accounting policies and practices should be selected and applied in a consistent way that reasonably ensures that the loan and loan loss provisioning information is reliable and verifiable.

5.75 The provisioning policy and processes should ensure that the bank maintains adequate provisions for identified and expected losses in accordance with the prevailing applicable accounting standards. In addition, a bank must provision for expected credit losses (ECL) from the time a loan is originated, rather than awaiting “trigger events” signaling imminent losses. Such provisioning should be forward looking (based on reasonable and supportable information that includes historical, current and forecast information). Furthermore, a bank must hold adequate capital to absorb unexpected losses. The bank’s policies and process for grading and classifying its loans and provisioning should take into account off-balance sheet exposures as well.

5.76 A bank is required to ensure that valuation, classification and provisioning for significant exposures are conducted on an individual item basis. A bank should set an appropriate threshold for the purpose of identifying significant exposures and to regularly review set thresholds. The remainder of the portfolio should be segmented into groups of loans with similar credit risk characteristics for evaluation and analysis on a collective basis. A bank may use different methods on group loans for the purpose of assessing credit and valuation. For example, loans may be grouped on the basis of one or more of the following characteristics: estimated default probabilities or credit risk grades, loan type, product type, market segment, geographical location, collateral type or past-due status.

5.77 A bank should be able to demonstrate, for individually assessed loans that are, or likely to be impaired, how the amount of any impairment is determined and measured. This includes proof of existence of procedures describing the impairment measurement techniques available and steps performed to determine which technique is most appropriate in a given situation. If a bank determines that observable data does not indicate that impairment exists for an individually assessed loan, the bank

Bank of Botswana Guidelines on Risk Management