C5-2020: Application of Requirements Relating to the Granularity Criteria

P O Box 427 Pretoria 0001 South Africa
370 Helen Joseph Street Pretoria 0002
+27 12 313 3911 / 0861 12 7272 www.resbank.co.za 1 C5/2020 To: All banks, branches of foreign institutions, controlling companies, eligible institutions and auditors of banks or controlling companies Circular 5/2020 issued in terms of section 6(4) of Banks Act, 1990:
Interpretation and application of criteria relating to the granularity for retail exposures Executive summary The purpose of this circular is to provide clarity on the interpretation and application of the granularity criteria for retail exposures as specified in regulation 23(8)(b) read with regulation 23(6)(b) of the Regulations relating to Banks. This circular also serves to provide clarity regarding the reporting of the retail asset class for the standardised approach (STA). This circular replaces Banks Act Circular 3 of 2014 (C3/2014), dated 13 February 2014.

1. Introduction
   1.1 Under the STA for credit risk, banks may apply different interpretations and
   applications of the criteria relating to the granularity of retail exposures, as outlined in regulation 23(8)(b) read with regulation 23(6)(b) of the Regulations relating to Banks (the Regulations) which could result in inconsistency in capital calculations and reporting of regulatory retail exposures in the BA returns.
   1.2 For an exposure to be included in a bank’s retail portfolio and consequently, be
   risk weighted at the preferential risk weight of 75 per cent, it has to meet all four criteria specified in regulation 23(6)(b) of the Regulations.
   1.3 For example, the Regulations require that the retail portfolios of banks should be
   sufficiently diversified to warrant a 75 per cent risk weight. In this regard, for inclusion in the retail portfolio, banks are required, among other things, to ensure that no aggregate exposure to a person exceeds 0,2 per cent of the aggregate amount relating to the bank’s retail portfolio (i.e., the granularity criteria for retail exposures).
   1.4 The purpose of this circular is to provide clarity regarding the interpretation and
   application of the granularity criteria for retail exposures as specified in regulation 23(8)(b) read with regulation 23(6)(b) of the Regulations. This circular also serves to provide clarity regarding the reporting of the retail asset class for the STA.
   1.5 This circular replaces C3/2014, dated 13 February 2014.

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2. Regulation references
2.1 Regulation 23(8)(b) read with regulation 23(6)(b)(iii) of the Regulations stipulates
that for an exposure to be included in the bank’s retail portfolio and, consequently, be risk weighted at the preferential risk weight of 75 per cent, a bank shall, among other things, apply the granularity criteria to this exposure.
3. Banks Act circular
3.1 The Prudential Authority’s application and interpretation of regulation 23(8)(b)
read with regulation 23(6)(b) of the Regulations is set out below:
3.1.1 The aggregate exposure to a person referred to in regulations 23(6)(b)(iii) and
23(6)(b)(iv) of the Regulations shall be calculated after the application of the relevant specified credit conversion factors (CCFs).
3.1.2 Furthermore, regulation 23(6)(b)(ii) of the Regulations specifically excludes
residential mortgage loans, as specified in regulation 23(6)(c) of the Regulations from the category of retail exposures to which a risk weight of 75 per cent is applied.
3.1.3 If the aggregate exposure, excluding residential mortgage loans, to a person is in
excess of R12,5 million, the person shall be excluded from the retail portfolio.
3.1.4 To ensure that the retail portfolio is sufficiently diversified, the granularity criteria
are applied to the remainder of the retail portfolio as discussed above. In cases where the aggregate exposure to a person exceeds the 0,2 per cent threshold calculated by the bank at each reporting date, the exposure shall remain in the retail portfolio for regulatory reporting purposes and be risk weighted at 100 per cent.
3.2 The impact of the above interpretations on the classification of retail-exposures
can be summarised as follows:
No
Yes
No
Yes
Portion of exposure
LTV ≤80%
Residential mortgages
On balance sheet portion +
Off balance sheet portion AFTER CCFs
Exposure meets granularity test?
Yes No
Exposure to an individual or SME, which exposure is not overdue:
Exposure ≤R12,5 million?
Exposure meets Product criteria?
Portion of exposure
80%< LTV <100%
Portion of exposure LTV
≥100%
Excluded from
Retail portfolio
Other exposures to an individual or SME
RW = 75% RW = 100%
Included in
Retail portfolio
RW = 75%
Included in
Retail portfolio
RW = 100%
RW = 35%

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3.2.1 The above interpretation can be further explained by way of the following
example:
Information of Bank X
Total retail portfolio, excluding any exposures that are overdue, after the application of the specified CCFs:
R 1,35 billion
Mortgage loans that are included in the category of claims secured by residential property R 0,30 billion Aggregate exposures, excluding residential mortgage loans, to persons that individually exceeded the threshold of R12,5 million R 0,05 billion Step 1: Exclude residential mortgages Total retail portfolio, excluding any exposures that are overdue, after the application of the specified CCFs R 1,35 billion LESS Mortgage loans that are included in the category of claims secured by residential property R 0,30 billion R 1,05 billion Step 2: Exclude exposures to a person in excess of R12,5 million Retail portfolio excluding residential mortgage loans R 1,05 billion LESS: Exposures to persons that individually exceeded the threshold of R12,5 million R 0,05 billion R 1 billion Step 3: Calculate the 0.2 per cent threshold Threshold (R1 billion x 0.2 per cent) R 2 million Step 4a: Aggregate exposures to a person that meet the relevant other requirements relating to retail exposures and are less than, or equal to, R2 million shall be risk weighted at 75 per cent. Step 4b: Aggregate exposures to a person that meet the relevant other requirements relating to retail exposures and are greater than R2 million shall be risk weighted at 100 per cent and included in the retail portfolio for regulatory reporting purposes.

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4. Acknowledgement of receipt
4.1. Kindly ensure that a copy of this circular is made available to your institution’s
independent auditors. The attached acknowledgement of receipt duly completed and signed by both the chief executive officer of the institution and the said auditors should be returned to the Prudential Authority at the earliest convenience of the aforementioned signatories. Kuben Naidoo Deputy Governor and CEO: Prudential Authority Date: 2020-12-07 The previous circular issued was Banks Act Circular 4/2020, dated 7 December 2020.