Wed 13 May 2020
Pierre Latrobe at Mazars discusses recent HKMA initiatives taken in response to Covid-19 and their implications for Hong Kong banks, highlighting credit risk as a growing threat.
The Hong Kong economy has been confronted by several downside factors over the last two years. The first hit was the initiation of the US trade war with China in July 2018 that disrupted supply chains around the globe. The second hit was the ongoing domestic social unrest initiated in April 2019 surrounding the possible passage of an extradition law in Hong Kong. More recently, the Covid-19 outbreak and containment measures imposed across the world has also hit the Hong Kong economy, long considered one of the most open in the world.
The domestic social unrest and the US trade war triggered the recession in Hong Kong in 2019, the full-year growth rate being -1.2%. It is worth noting that Hong Kong was the only economy in recession in Asia Pacific in 2019. The real GDP growth forecast for 2020 has now been revised to -4% to -7%, from -1.5% to 0.5% initially.
One positive element is that the banking sector entered the current crisis in a more resilient position than they were leading up to the 2008 great financial crisis. Indeed, supervisory authorities, including the HKMA (Hong Kong Monetary Authority), had requested financial institutions to reinforce capital and liquidity ratios as well as build-up buffers to face a period of stress.
The latest published statistics showed the consolidated Tier 1 capital ratio of locally incorporated Hong Kong banks amounted to 20.7% at the end of 2019 compared to 18.2% in the first half of 2019, well above minimum international standards. Considering the healthy position of the Hong Kong banks, it makes sense that the HKMA has spared no effort in taking measures to ensure banks continue financing businesses amid a challenging environment.
Additional measures have been rolled out by the HKMA in March and April 2020 in response to Covid-19 to free up lending capacity as well as relax regulatory, liquidity and operational constraints.
Relief for borrowers
The HKMA established a banking sector SME lending coordination mechanism in October 2019 to strengthen funding support from major banks for SMEs. The mechanism aims to alleviate pressure on SME cash flows, as far as the credit and risk management policies of banks allow. As of 3 April 2020, nearly 9,000 applications from SMEs involving principal repayment holidays, loan extensions and relief loans have been approved, involving over HKD 57 billion.
With regard to lending arrangements, banks were asked by the HKMA to provide relief to corporate borrowers by offering principal payment holidays on a pre-approval basis for a period of six months for corporate borrowers meeting specific financial conditions. It is worth noting that the principal payment holiday should not lead an exposure to downgrade to a lower category in accordance with the HKMA’s existing loan classification guidelines.
Other measures to alleviate cash-flow pressure and help minimise closures of local enterprises were also taken, including to allow the conversion of trade financing lines into temporary overdraft facilities, and the start of the special 100% Loan Guarantee under the SME Financing Guarantee in April 2020.
Relief from countercyclical capital buffer, regulatory reserve
Following a first reduction in the countercyclical capital buffer (CCyB) from 2.5 to 2.0 percent in October 2019 to address the impact of the domestic social unrest, the HKMA announced in March 2020 another decrease from 2.0 to 1.0 percent in order to ease credit conditions and foster economic growth in Hong Kong. It is estimated this released around HKD 700-800 billion in bank lending capacity.
The HKMA also lowered the regulatory reserve (RR) requirement on locally incorporated banks by 50%, which should provide additional lending capacity. At the transition date to HKFRS 9 in January 2018, the HKMA had required locally incorporated banks to maintain an RR on top of accounting provisions to mitigate potential gaps regarding the data, systems and controls required to determine expected credit losses.
Smooth operation of the interbank market
Several measures are intended to increase the banking sector’s liquidity. This includes providing further flexibility on the rolling over of Standby Liquidity Facilities (SLF) to bring more certainty on the longer-term funding requirements of banks, and fixing SLF rates to reduce market volatility rather than making reference to market rates and prevailing market conditions.
In addition, the HKMA encourages banks to utilise their liquidity buffers under specific circumstances and is willing to accept banks operating temporarily with a lower level of liquidity ratio, as long as the average monthly Liquidity Maintenance Ratio (LMR) remains above 25%. For the Liquidity Coverage Ratio (LCR), HKMA allows monetization of high-quality liquid assets (HQLA) under certain circumstance even this makes LCR goes below required level.
In addition, the HKMA entered into repurchase agreements with the Federal Reserve and temporarily exchange the US Treasuries held by the HKMA for US dollars, which can then be made available to banks in Hong Kong.
Operational capacity of Hong Kong banks
In light of the deferral of the implementation of the final Basel III reform package by one year to 1 January 2023 by the oversight body of the Basel Committee on Banking Supervision (BCBS), the HKMA has deferred the implementation of the revised frameworks on credit risk, operational risk, output floor and leverage ratio as well as revised market risk and credit valuation adjustment framework.
In addition, the HKMA decided to postpone the 2020 Supervisor Driven Stress Test to 2021 in common with other jurisdictions. In our view, the postponement may also be justified to safeguard the regulator’s reputational risk. Scenario design is complex in particular in a period of uncertainty. There is no guarantee that the ‘right’ scenarios will be chosen by a regulator which raises a risk that markets interpret a ‘pass’ on a stress test as an indicator of good health of a bank. Should the bank fail soon afterwards, the reputation of the supervisor would be blemished.
Recent statistics published by the HKMA indicates that loans and advances granted by Hong Kong banks continue to grow, albeit slightly. Since the HKMA established the banking sector SME lending coordination mechanism in October 2019 and the pause in the social unrest since December 2019, there has been only monthly positive growth in lending – a positive development.
*Derived from HKMA Monthly Statistical Bulletin (May 2020, Issue 309)
The increase in loans and advances was from HKD 10.35 trillion in October 2019 to HKD 10.67 trillion in March 2020, including a significant increase in March 2020 despite challenging market conditions.
Among the total lending, loans for use in Hong Kong slightly increased from 65.1% in October 2019 to 65.8% in March 2020, while the loans for use outside Hong Kong decreased from 30.2% to 29.7%. This means that additional lending is benefiting the Hong Kong economy which supports the efficiency of the stimulus triggered by supervisory measures.
It is correct for a regulator to prompt banks to maintain or increase lending to support economic objectives. Yet, as we indicated in October 2019[1], there is a delicate trade-off to achieve, since unleashing lending support may undermine the credit quality reported by banks.
The HKMA indicated in April 2020 that locally incorporated banks reported notable increases in their accounting provisions in general for the second half of 2019 given the deterioration in the Hong Kong environment.
For example, Hang Seng Bank reported expected credit losses on gross loans and advances to customers of 0.37% as of December 2019, compared to 0.31% as of December 2018. Bank of East Asia reported 0.74% and 0.51% and DBS reported 1.71% and 1.40% for the same closing periods. It should be emphasised that the worsening reported figures as of December 2019 did not include the impact of the current Covid-19 pandemic.
Based on published results from global banks for the first quarter of 2020, there is no doubt that Hong Kong banks will report significant credit quality deterioration due to the pandemic in the near term. As an example, HSBC reported an increased allowance for ECL from USD 9.2 billion at 31 December 2019 to USD 11.1 billion at 31 March 2020, due mainly to the impact of Covid-19 and weakening oil prices on the forward economic outlook.
The question is to what extent Hong Kong banks will be in a position to continue financing the real economy without putting at risk their own financial health?
Credit risk has been a growing threat to the banking industry due to the challenging economic conditions since July 2018. This may narrow the capability of banks to continue supporting lending in the long term. Indeed, the recent measures to support the Hong Kong economy stripped the banks of several capital and liquidity buffers. For as long as the banks are advised to adopt a sympathetic stance in dealing with customers facing financial stress due to Covid-19, this may delay the identification of non-performing exposures and jam up the existing prudent credit decisioning framework of the banks. This could lead to the emergence of other issues for the future and impede Hong Kong’s economic recovery.
Moreover, the real damage to the economy of the first wave of the outbreak is going to be understood once the supporting measures fade. To make matters worse, due to the uncertainty around the scale and the duration of the crisis, it is more difficult to define a plausible and reliable scenario for the next six months and onwards in order to adjust a bank’s strategy.
Last but not least, contrary to many other jurisdictions that are facing predominantly the Covid-19 crisis, the Hong Kong economy has to manage uncertainty around other downside risks that triggered the recession last year and have not yet fully played out. Who can predict the future of US-China trade relations and the resurgence of domestic social unrest once the pandemic is over?
One thing for sure is that credit risk management should be one of the top priority for the banking sector in Hong Kong in the coming months. Indeed, the Hong Kong economy will need strong banks to recover more quickly.
This article first appeared in Regulation Asia on 13th May 2020.
[1] https://financialservices.mazars.com/the-supervisory-answer-to-hong-kongs-worsening-economic-performance/
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Solvency, liquidity, transparency and oversight requirements: as the Basel Committee meeting in Santiago, Chile in November 2016 demonstrated, there is still much to be discussed on the finalisation of the Basel III agreements. However, the inauguration of the new President of the USA could change the condition of the international dialog. Some might decide to […]
In about nine months, IFRS 9 will replace IAS 39 and the new accounting environment won’t be the only element to be impacted. In recent months, the Basel Committee on Banking Supervision (BCBS), the EU Commission and the European Banking Authority (EBA) have also been tackling the impact of the new IFRS 9 provisioning on […]
There is a clear pipeline of jumbo disposal Non-Performing Loans (NPLs) in Italy, thanks to the ECB push, however vendors will need to take into careful consideration a few factors in their decision, such as recent regulatory reforms of insolvency and foreclosure and a possible EU bad bank. 1. ECB Push Europe’s NPL assets are […]
After the Basel Committee consultation in October and then the European Commission’s legislative proposal of the package CRR II / CRD V in November 2016, the EBA has now given its opinion on the management impact of IFRS 9 on regulatory capital, notwithstanding a second impact study has just been completed. This opinion, primarily addressed […]
Cyberattacks aren’t just getting more frequent, they are also becoming significantly more vicious and sophisticated. The majority of today’s data breaches result from human error, making cybersecurity a “people problem” as well as a technology issue. The solution to this people problem can’t be solved by purchasing new hardware or software or implementing sophisticated network […]
Non-Performing Loans (NPLs) are a key issue and will continue to be on the European agenda as a top priority for a long time. On the one hand, the ECB guidelines are already applicable, as they represent a best practice reference for the day-by-day work of the Joint Supervisory Teams. On the other hand, the […]
The European Central Bank (“ECB”) recently launched public consultation on guidance to banks on non-performing loans (“NPL”). Consultation periods runs until 15 of November 2016. As NPL harms the profitability, funding and capital of banks and more globally the real economy, the ECB issued this guidance, aiming to achieve common practices for how to handle […]
During the last few weeks, the volume of loans issued by banks has snowballed as governments release programmes to bail out businesses affected by Covid-19. As a result of these higher volumes, the exceptional increase in underwriting activity raises several issues for banks. Most notably, banks, like all commercial institutions, are also having to cope […]
With COVID-19, being declared a pandemic on March 11, 2020, financial institutions have had to shift most of their resources to mitigate the risks that have arisen. This has adversely affected important activities, one of which is market participants’ efforts to detach from LIBOR before its cessation at the end of 2021. As a result, […]
We have identified and ranked the key risks for financial services business leaders in 2024 based on market research, regulatory insights as well as our assessment of the current difficulties facing firms. We also highlight the changes in risk rankings compared to last year, justified by global events and new regulations that have surfaced in […]
The global climate crisis has triggered the financial sphere to address the way in which it conducts business. Climate risk consideration is currently growing in the banking industry but should also be considered by banks in the Credit Valuation Adjustment (CVA) when pricing derivatives. The credit risk for long dated derivatives (beyond 10 years), reflected […]
With the approaching end of the investigation phase of the ECB’s digital euro project in October 2023, and the expectance of a decision on starting a realisation phase by the end of this year, the pros and cons of a potential digital euro have been widely discussed in the past months. The topic became even […]
The European Commission published on 18 April 2023 a new legislative package aiming to adapt and strengthen the framework for crisis management and deposit insurance (CMDI), with an acute focus on small and medium-sized banks. This proposal, which follows the announcement of the Eurogroup finance ministers inviting the Commission and the European co-legislators to review […]
In recent weeks, we have witnessed the successive bankruptcies of three banks in the United States, as well as the hasty takeover of Credit Suisse by UBS. This chain of events inevitably calls into question whether this trajectory echoes the leadup to the financial crisis of 2008. In reality, whilst these crises have stark similarities, […]
The rapid collapse of one of Switzerland’s most emblematic banks, following the demise of tech lenders on America’s west coast, has raised concern over banking stability. What are the consequences for the sector, the economy and for society? Gregory Marchat, Global Head of FS Advisory, and Emmanuel Dooseman, Global Head of Banking and Capital Markets, […]
The momentum towards a low-carbon economic system is only set to grow. Financial services firms are pivotal actors in the transition; consequently, increasing demands are being put on them to demonstrate their sustainable finance activities and credentials. This blog explains what sustainable finance is and why it matters to financial services firms. What is Sustainable […]
Implementing credible environmental, social and governance (ESG) actions requires successful enablers. So how can firms identify these enablers and, crucially, remove barriers to implementation? If we take our latest C-Suite Sustainability Barometer, we can see that out of the over 1,100 businesses accounted for in the survey, 75% are planning to increase their investment in […]
In an interview, Korbinian Ibel, Director General at the European Central Bank (ECB), shares insight on how bank-specific direct supervision works, what the current risks and challenges are, and priorities to look out for in the coming years. What does the Banking Supervision arm of the European Central Bank do? Find out about its policies, […]
“I see digital as the future of finance”. These are the words of the Executive Vice President of the European Commission (EC), Valdis Dombrovskis, voiced in the summer of 2020. He has undoubtedly been proven right as governments and central banks around the world have heightened their efforts to keep oversight of the digital transition […]
After two years marked by the Covid-19 crisis, the first half of 2022 offered the prospect of a return to a certain economic normality. However, the outbreak of war in Ukraine combined with a deteriorating economic environment have reshuffled the cards and once again brought banks into a zone of turbulence and uncertainty. So how […]
Since the Covid-19 pandemic, post-model adjustments1, or management overlays, have become an increasingly common and accepted mechanism used by banks to manage expected credit losses (ECLs). The number of post-Covid unprecedented events related to the war in Ukraine, energy crisis and global economic uncertainty has raised a number of questions relating to the consistency and […]
The European Banking Authority (EBA) is tasked, in cooperation with the European Systematic Risk Board (ESRB), to initiate and coordinate biennial EU-wide stress testing exercises to assess the resilience of institutions to adverse market developments. The objective is to provide supervisors, banks, and other market participants with a common analytical framework to consistently compare and […]
The Federal Reserve Board (FED) will commence its first bottom-up climate scenario analysis exercise at the beginning of 2023, as announced on 29 September. The exercise will be exploratory in nature and will not result in extra capital requirements. The list of designated participants consists of six of the largest U.S. banks, i.e., Bank of […]
The first supervisory climate risk stress test (2022 CST) conducted by the European Central Bank (ECB) has concluded with official results and findings made public on 8 July 2022. The exercise has complemented the broader ECB’s agenda to assess the readiness of banks in Europe to manage climate-related and environmental risks. The 2022 CST was […]
Climate change is now firmly in the focus of prudential regulators and supervisors across the globe. Against this background, the European Banking Authority (EBA) is mandated to assess whether a dedicated prudential treatment of exposures related to assets or activities associated substantially with environmental and social objectives would be justified. Based on its findings, the […]
The last few weeks have been marked by an ongoing review of the supervisory priorities initially listed by the Single Supervisory Mechanism (SSM) for 2022-24, and developments in the climate agenda outlined by the European Central Bank (ECB). ECB’s supervisory priorities for 2022-24 remain stable despite geopolitical instabilities and challenges At the beginning of 2022, […]
For several months now, we have been in an economic and financial environment that we have not seen for some years. In May, inflation in the Eurozone reached 8.1%, with six countries exceeding 10%, while the United States recorded an 8.6% year-on-year price increase. The short-term reasons for the return of inflation are well known, […]
Central Bank Digital Currencies (CBDCs) continue to receive increasing attention not only from the ECB but all over the world. So far, 10 countries [1] have already deployed CBDC programmes with another 15 countries [2] currently conducting pilot programmes. In total, 105 countries are considering using CBDC programmes, representing over 95% of global GDP and […]
The chair of the European Central Bank’s Supervisory Board, Andrea Enria, has voiced several times in the past months the supervisor’s concern with the increasing growth of the leveraged finance sector, which deals with loans to highly indebted borrowers. By mid-2021, the combination of a strong global loan moratoria policy and the long-standing low interest […]
The Eurofi financial forum is a setting for exchanges between European Union (EU) economic and financial regulators and senior financial sector executives from the industry. It occurs bi-annually alongside the Economic and Financial Affairs Council configuration (ECOFIN) meetings. This summary takes stock of the Eurofi discussions, as well as recent publications by the EU Commission […]
Despite banks emerging from the Covid-19 crisis in reasonably good health, the war in Ukraine combined with a global energy crisis and an uncertain economic landscape have once again put the spotlight on credit risk exposures. To better understand credit risk trends, Mazars conducted an analysis of 26 banks in 11 European countries in May […]
Crypto-asset markets have been on banks’ radar for some time. While interest and involvement have varied, regulatory developments have been a driving force. In September 2020, the European Union (EU) published a proposal for the regulation of Markets in Crypto-assets (MiCA), offering a uniform legal framework for crypto-assets in the EU. On 14 March 2022, […]
To adapt to the swiftly evolving regulatory landscape and meet stakeholders’ expectations, financial firms are increasingly formulating sustainability strategies to address environmental, social and governance (ESG) factors. Notably, emissions reduction and the pursuit of net-zero targets have become central elements of ESG strategies for many financial firms, according to the latest Mazars’ survey Sustainability practices stocktake: […]
Mazars recently hosted a Financial Services INED Roundtable Dining Event in Dublin[1]. Over 50 financial services independent non-executive directors (INEDs) attended, from banking, asset management, funds and insurance entities operating across the EU and UK. The roundtable focussed on the challenges facing INEDs in the current unpredictable macroeconomic environment. The new and emerging risks and […]
Last October, the European Central Bank (ECB) initiated the preparation phase of the Digital Euro project, following two years of investigation and a proposal on the establishment of a digital euro published by the European Parliament (EP) in June 2023. In January, the ECB began seeking potential providers to develop a digital euro platform and infrastructure […]
The European Central Bank (ECB) issued the SSM supervisory priorities for the 2024-2026 cycle on 19 December 2023. They sum up what institutions under the direct supervision of the ECB should expect in terms of areas of supervision, in 2024 notably, and allow firms to prepare themselves for forthcoming onsite inspections or thematic reviews. Please […]
In January 2024, the European Central Bank (ECB) published its Climate and Nature Plan for 2024-2025. This plan aims to: This plan underscores those financial risks stemming from climate change remain a key area of attention for the ECB. The ECB will continue working on several topics including stress testing, scenarios and climate-related data, and […]
DORA is a legislative proposal that aims to improve the digital operational resilience and ensure the performance and stability of the financial system of the member countries of the European Union in the face of the risks associated with ICT (Information and Communication Technology) in the financial sector (cyber-threats, cyber-attacks). The DORA requirements will apply […]
In late 2023, and to coincide with COP 28, Mazars published its latest Sustainability practices survey on the progress banks and insurers have made in embedding sustainability into their businesses, our most comprehensive and information-rich report to date covering 404 executives in banks and insurance companies in 16 countries Despite sustainability being in the limelight […]
The Single Resolution Board (SRB) convened its annual conference on 13 February 2024 with a theme highlighting the focus for the year: ‘The road ahead: risk, readiness and resilience’. While significant strides have been made with the EU banking resolution framework and tools, the SRB’s Chair Dominique Laboureix recalled this is not the end of […]
In environmental, social and governance (ESG) reporting, materiality is crucial for enhancing transparency and accountability in sustainability and climate-related disclosures. Importantly, it helps identify and report on matters that are deemed significant, emphasizing their relevance to stakeholders. Materiality comes in various forms. Financial materiality focuses on sustainability issues impacting financial performance, aligning with annual financial […]
On 29 June 2023, the European Union’s (EU) Markets in Crypto Assets Regulation (MiCA) entered into force. It is being implemented in stages depending on the provisions, between June and December 2024. The regulation, which provides clearer rules for crypto-asset service providers and token issuers, is much needed for this fast-changing industry. The rapidly approaching […]
Under IFRS 9, forward-looking information is a key component of Expected Credit Loss (ECL) calculations. However, forward-looking information requires a significant level of judgement, making comparisons difficult to navigate. Indeed, similar to the use of post-model adjustments, forward-looking scenarios have also been reported by stakeholders in the context of the IFRS 9 impairment post-implementation review […]
The integration of environmental, social and governance (ESG) considerations into strategic planning is increasingly becoming a common practice among financial services firms. However, climate-related risks can also serve as drivers of financial risk for institutions. These risks can manifest through various transmission channels, translating climate and environmental (C&E) risks into more conventional categories such as […]
There is growing pressure for banks and insurers to incorporate C&E factors in their risk management frameworks (RMF). As a practice, it gives the ability to set clear thresholds for the climate impacts banks and insurers are willing and able to absorb. By establishing these thresholds, firms can effectively monitor their exposure to C&E risks, […]
There are increasing regulatory expectations globally for financial institutions to disclose and demonstrate how sustainability-related responsibilities are allocated within the organisation. In this respect, the increasing global trend towards mandatory sustainability disclosure frameworks continues to underscore the significant role that the finance function is anticipated to assume in sustainability. It’s a trend reflected in Mazars’ […]
On 19 December 2023, the European Central Bank (ECB) published its updated Single Supervisory Mechanism (SSM) strategic supervisory priorities for the period 2024 to 2026. The priorities indicate what banks should expect in terms of supervisory activities in 2024. For 2024-2026, the ECB supervisory priorities are built upon three main pillars: These priorities were informed […]
While the banking sector has shown resilience over recent years, the economic environment and geopolitical situation remain tense. So, what does this mean for risks to the banking sector? More specifically, what is the impact on capital requirements for banks with the implementation of the Capital Requirements Regulation (CRR3) and the Capital Requirements Directive (CRD6), […]
The Basel Committee on Banking Supervision (BCBS) and Financial Stability Board (FSB) published reports in October 2023 on the causes and lessons learnt from the Spring 2023 banking turmoil. The BCBS report provides an assessment of the causes of the banking turmoil, the regulatory and supervisory responses, and the initial lessons learnt. The FSB report […]
The implementation of the European Union’s ‘Taxonomy’ regulation, which integrates two climate objectives, was carried out on 1 January 2022 through the ‘Climate’ Delegated Act released in April 2021. In line with this, the banking sector has been provided with corresponding regulations, allowing banks to measure the portion of their financing dedicated to sustainable economic […]
The IIF Annual Membership meeting is a setting for insights and perspectives from global financial regulators and senior financial sector executives on topical economic and regulatory issues. Being a forum with global coverage means that it is a valuable setting for picking up future economic and regulatory directions. A packed agenda under the theme of Building […]
The war in Ukraine, as well as the unprecedented sanctions imposed by the European Union, the United States and their partners against Russia have had major consequences for financial services institutions. For foreign companies operating in Russia or Ukraine, the first concern was the safety of their staff. They had to make difficult choices to […]
In March 2022, the European Central Bank (ECB) published its second snapshot of climate-related and environmental risk disclosure levels among significant institutions under its direct supervision. In line with the results of the first snapshot published in November 2020 – regarded as the baseline measurement – none of the institutions in scope for this second […]
American entrepreneur, Malcolm Forbes, once described diversity as “the art of thinking independently together”. Today, diversity is beginning to emerge as a quintessential workforce norm and institutions have started to acknowledge the differences in their staff compositions that are deeply ingrained in the fabric of their organisational culture. With many challenges remaining, the independent think […]
March 2020 marked the first time – since its inception in 2014 – that the Bank of England (BoE) cancelled its annual stress tests for the UK’s biggest lenders. Instead, they undertook a desktop analysis of the UK banking sector resilience. In late 2020, the Financial Policy Committee (FPC) judged that most banks have capital […]
While 2020 went relatively smoothly for the banking sector, uncertainties remain on the potential effects of Covid-19 on the real economy. Any negative impact could lead to heavy losses for the sector, especially when support measures are gradually phased out. These measures have not only contained the anticipated increase in credit risks, but have also […]
On 13 November 2020, the EBA published the final methodological note for the 2021 EU-wide stress-testing exercise. The aim of the stress tests is to assess the resilience of financial institutions to adverse economic and financial developments, in particular in the event of an increase in credit risk due to the default of the borrower. […]
The publication on 29 January of baseline and adverse scenarios, output templates, instructions and market assumptions required to carry out stress tests signals the go-ahead by the European Banking Association (EBA) for the 2021 regulatory exercise. Because of the Covid-19 pandemic, these tests, originally planned for 2020, will take place between now and 31 July […]
With the economic repercussions of the Covid-19 crisis yet to be fully assessed, a robust resolution framework is essential to ensure the stability of the banking system. While the banks were given leave to postpone the reporting of some less urgent information in spring 2020, the Single Resolution Board (SRB) has reiterated the importance of […]
European sustainable finance regulations evolved considerably in 2020, and the European Banking Authority (EBA) is continuing this trend into 2021. It recently published a discussion paper assessing the potential inclusion of Environmental, Social and Governance (ESG) risks in the supervisory review and evaluation process (SREP) performed by national competent authorities (NCAs)[1]. What firms need to […]
With more than half of the world’s fastest-growing economies located in Africa1, the continent’s economic outlook is a positive one. Average annual GDP growth since 2000 is over 5%, placing Africa as the second-fastest growing economy behind Latin America. Real GDP growth, estimated at 3.4% for 2019, is projected to accelerate to 4.1% in 2021. […]
In this edition of our Banking Regulatory Radar, we cover the key regulatory developments in the banking sector for 2020-2025. The latest version of the Mazars’ Regulatory Radar has been updated with all the Level 2 legislation published in 2020, as well as the measures that were taken in the context of the Covid-19 pandemic. […]
Facebook’s ambition to create a transferable global digital coin between users on the social media giant’s messaging platforms WhatsApp and Messenger has been controversial from the outset. Perhaps not surprisingly, the backlash from regulators around the world was substantial from day one. The world’s leading economies were less than enthusiastic of the possibility of a […]
Around one-fifth of global banking activity is undertaken in the UK. Almost half of the UK’s banking assets are held by international banks. The PRA currently supervises approximately 250 international banks, both branches and subsidiaries, which are part of around 180 international groups. Background On 11 January 2021, the PRA shared in a Consultation Paper […]
Against the background of a new year still severely affected by the persistence of the pandemic throughout the world and economies facing an unprecedented global macro-economic shock, the Basel Committee has felt it necessary to address the audit of the expected credit loss (ECL) accounting estimate within the overall financial statement audit. With IFRS 9 […]
One of the anticipated challenges in the transition from IBOR rates to risk-free rates (RFRs) is the management of its impact on quantitative models. The ones currently used for pricing IBOR-linked financial instruments account for term rates which are “forward-looking”. The RFRs replacing the IBORs are all overnight rates. This means that a term rate […]
Under article 430c of the updated Capital Requirements Regulation (CRR 2), the European Parliament and the Council of the European Union mandate that the European Banking Authority (EBA) perform a feasibility study on reducing the reporting burden for the European banking sector while ensuring data collection for monetary policy, resolution and supervisory purposes and take […]
An important milestone in the IBOR transition is the change in rates used by LCH and CME for discounting and Price Alignment Interest (PAI) calculations for USD OTC cleared swaps. Indeed, on October 16, 2020, they moved from using the daily Effective Federal Funds Rate (Fed Funds) to the Secured Overnight Funding Rate (SOFR) for […]
In the early 1990s, stress tests became a popular internal tool for international banks to examine risks and gain a better understanding of threats to the institutions’ balance sheet. From there, the Basel Accord was amended in the mid- ’90s and required banks and investment firms to conduct stress tests. However, these were more internal […]
The revised market risk framework – also known as the Fundamental Review of the Trading Book (‘FRTB’) – not only impacts an institution’s regulatory capital charge calculation for market risk, but also affects operational, governance and business strategies. FRTB brings significant change. With the aim of harmonising capital standards for market risks across jurisdictions and […]
One of the major challenges of IBOR transition is the availability of historical data on alternative risk-free rates (RFRs) required to implement interest rate model changes or re-calibration. With the Secured Overnight Financing Rate (SOFR) only published since April 2018, the available time series do not provide enough observations for risk modelling. Adding to that, […]
Over recent years, technology and software have become strategic assets for competitiveness and resilience in the banking sector. Institutions have no choice but to invest to develop and deliver innovative services whilst managing ever greater IT and cybersecurity risks. The pandemic and announcement of lockdown measures posed a significant challenge for banks’ technology teams as […]
The Federal Reserve Board released stress test results for DFAST 2020 including additional sensitivity analysis, considering the COVID19 outbreak, to assess the resiliency of large banks under three hypothetical recessions, or downside scenarios, that could result from the coronavirus event. Furthermore, the Board provides guidance for large banks to maintain resiliency during economic uncertainties from […]
Over the past decade, the financial services industry has been disrupted by the arrival of new players whose rise to prominence has pushed traditional banks – previously faced with little competition – to transform themselves. In this context, technology and innovation, particularly 5G, will allow the most skilful and agile banking organisations to take advantage […]
The Targeted Review of Internal Models (TRIM) was one of the largest projects by the European Central Bank (ECB) aimed at identifying potential sources of unwarranted or non-risk based variability in Significant Institutions (SIs) risk-weighted assets (RWA) from the use of Pillar 1 internal models such as Probability of Default (PD), Loss Given Default (LGD) […]
The invasion of Ukraine by Russia on 24 February 2022 is considered the most significant geopolitical event since the Second World War. While there is no question of military intervention by the European Union (EU) at the moment, the EU has nevertheless decided on a major package of sanctions that will have a heavy impact […]
The creation of a new Anti-Money Laundering Authority will transform the supervision of money laundering and financing terrorism (AML/CFT) in the EU. Proposed reforms also extend the AML/CFT rules to all crypto-asset service providers, as well as include specific rules concerning due diligence on customers and beneficial ownership. It is expected that some of these […]
A central database to strengthen the anti-money laundering and counter-terrorist financing (AML/CFT) framework was launched by the European Banking Authority (EBA) on 31 January 2022. Called EuReCA, the new database will be essential to coordinate efforts by national competent authorities and the EBA to prevent and fight money laundering and terrorist financing (ML/TF) risks throughout […]
As regulated entities execute their post-Brexit strategies and relocate their European Union (EU) operations from the UK to other EU states, a key issue to be addressed for those relocating to Ireland remain to be the impending legislative changes surrounding increased accountability standards for executives and non-executives. Not least, the breaking of the participation link, […]
The great financial crisis triggered a massive wave of bankruptcies in the worldwide banking sector, affected not only large international banks such as Lehman Brothers but also local ones such as Northern Rock in the UK. Basel prudential standards are designed to cope with financial risks stemming from the global banking system without taking into […]
On 19 January 2022, Mr Patrick Amis, the head of ECB Directorate General Specialised Institutions and Less Significant Institutions (DG/SPL) had a formal meeting with Mazars to discuss the implications of the pandemic for the LSIs and the supervisory focus. The main risks outlined by Mr Amis, were in the areas of NPLs, digitalisation, IRRBB, […]
Supervisory priorities 2022-2024 In December 2021, the European Central Bank (ECB) and the national supervisory authorities of the Eurozone countries published their supervisory priorities for 2022-2024. The three-year coverage enables the ECB banking supervision to achieve good progress in addressing the identified vulnerabilities while at the same time affording enough flexibility in any corresponding actions […]
The growing importance of sustainability issues and the role of credit institutions in financing transformation places climate and environmental risks at the core of regulatory and supervisory scrutiny today. For some years now, the Network for Greening the Financial System (NGFS), comprising central banks and national supervisory authorities, has been working to enhance sustainability and […]
Financial institutions and non-bank financial technology companies (FinTechs) alike make extensive use of various machine learning models (MLOps) in core and non-core areas of their business. Banks, for example, rely on such models for a range of risk assessments, including predictive underwriting, credit risk management, suspicious and/or fraudulent activity management, fair lending compliance, derivative and […]
The Covid-19 pandemic has amplified technology’s impact on the banking sector, helping to prove that technology now stands at the core of business sustainability for banks. In their constant search for convenience, digitally-savvy customers have pushed banks’ focus towards providing global business solutions more than ever. A new normal has emerged: an environment where banks’ […]
As the PRA transitions from a “rule-taker” to a “rule-maker”, small and medium-sized banks operating in the UK can expect to benefit from a more “streamlined” regulatory regime that could be easier to interpret, implement and maintain; but at the same time, they can also expect the PRA to be progressively more involved in scrutinising […]
The digitalisation of banking processes and the introduction of AI-led technology impact the central and strategic role of information systems within the banking system. The growing use of information and communication technology (ICT) exposes all financial institutions to an increasing level of digital risk that could weaken their operational resilience, in particular, due to more […]
The identification and management of non-performing loans or NPLs as early as possible by banks are among supervisors’ current high-level priorities. Indeed, when prudential, monetary, and fiscal crisis mitigation mechanisms are tapered, the weakening of borrowers’ creditworthiness could materialise, along with increasing credit risks and therefore NPLs. This expected rise of new NPLs in European […]
The unveiling of the new banking package “CRR3 – CRD6” on 27 October 2021 presents a further landmark on the road to implementing the final Basel III agreements. The regulatory scheme will also focus on the revision of the market risk framework from January 2019, as well as the latest developments in pillar 3 requirements. […]
The low level of banking consolidation in Europe compared to other countries is raising concerns among the supervisory community in Europe. It is a trend further reinforced after the financial crisis of 2007/2008 that produced a noticeable slowdown in consolidation operations in the EU. So what has been the impact, and what can we expect […]
Climate change introduces considerable economic challenges. On the one hand, financial institutions must contribute to the transition to a low-carbon and balanced economy to effectively combat global warming. On the other hand, the financial sector is exposed to climate-related and environmental risks and therefore needs to implement appropriate risk management practices within a financial stability […]
On 30 July, the European Central Bank unveiled the 2021 supervisory stress test results, which demonstrated that the region’s banking system is resilient in an unfavourable environment. The Common Equity Tier 1 (CET1) ratio has fallen 5.2% to 9.9% under the 3-year adverse scenario, while under the baseline scenario the CET1 ratio will reach 15.8% […]
Local and international trends have transformed the way banks operate, affecting their capital positions and profitability. In particular, ongoing digitalisation programmes and technological innovation continue to add pressure on traditional banking models, including the supply chain. While management’s focus on capital preservation, profitability and growth for shareholders remains, risks from an operational perspective have intensified. […]
With the current ultra-low interest rate environment and market volatility having a negative impact on banks’ returns and, ultimately, their capital positions, operating models must quickly adapt and become more cost-efficient to maintain profitability. This drive for cost-efficiency has become more apparent as innovation in technology and ongoing digitalisation have further upended traditional banking systems […]
Brexit, or the UK’s departure from the European Union, became a reality on 1 January 2021. In terms of the regulatory impact for the financial sector, and the banking sector in particular, the UK being a third country, UK banks can no longer benefit from the European passport for their continental activities. Therefore, they can […]
On 1 March 2021, the European Banking Authority (EBA) launched a public consultation on draft implementing technical standards (ITS) for Pillar 3 disclosures of environmental, social and governance (ESG) risks, under its capital requirements regulation (CRR) mandate. The consultation will end on 1 June 2021. Large banking institutions with securities traded on a regulated market […]
The last five years have been a time of much challenge and change for the Central Banking Fraternity in Europe. Crisis, both economic and political, has been followed by much adjustment and change, including both practical economic and policy interventions, structural change in the form of Banking Union, much new regulation and most recently the […]
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