Credit Risk Transfer News

12/12/2017

Finalizing the Basel III Reforms Basel IV

 

Basel IV in Banking

Introduction

Basel IV, often referred to as the finalization of Basel III, is the latest set of international banking regulations developed by the Basel Committee on Banking Supervision (BCBS). While regulators officially avoid the term Basel IV, many in the financial industry use it to highlight the scale of changes compared to earlier frameworks.

The reforms, finalized in December 2017, represent the most comprehensive update to global banking standards since the aftermath of the financial crisis. Basel IV seeks to restore credibility to banks’ capital ratios, reduce variability in risk-weighted assets (RWAs), and ensure that banks across jurisdictions are measured by more consistent standards.


Why Basel IV Was Introduced

The Global Financial Crisis (2007–2009) exposed flaws in the Basel II and early Basel III frameworks. Even as Basel III was rolled out, regulators identified three key issues:

  1. Excessive reliance on internal models – Large banks could use complex internal models to calculate RWAs, often underestimating risk compared to smaller banks using standardized approaches.

  2. Inconsistency across banks – The same type of risk exposure produced very different capital requirements depending on the bank and jurisdiction.

  3. Incomplete coverage of risks – Certain credit, market, and operational risks were not fully captured under existing rules.

Basel IV was designed to close these gaps.


Core Elements of Basel IV

1. Credit Risk Reforms

  • Stricter standardized approaches for credit risk, with more risk sensitivity.

  • Revised risk weights for exposures such as residential real estate, commercial property, and corporates.

  • Removal of the option for banks to use internal models for low-default portfolios (e.g., certain corporates, banks, and equity exposures).

2. Operational Risk

  • Replacement of multiple existing approaches (Basic Indicator, Standardized, Advanced Measurement) with a single Standardized Measurement Approach (SMA).

  • Capital requirements now link more directly to banks’ income and historical operational loss experience.

3. Market Risk (FRTB – Fundamental Review of the Trading Book)

  • Introduces stricter definitions of the trading book vs. banking book.

  • New standardized approach and internal models approach for market risk.

  • More sensitivity to liquidity horizons and risk factors.

4. Output Floor

  • The most controversial element:

    • Banks using internal models must maintain RWAs at least 72.5% of what they would be under the standardized approach.

    • Designed to limit variability in RWAs between banks and increase comparability.

5. Leverage Ratio Adjustments

  • Introduction of a leverage ratio buffer for Global Systemically Important Banks (G-SIBs).


Basel IV Timeline of Key Dates

  • December 2017 – Basel Committee finalizes Basel III reforms, unofficially called Basel IV.

  • January 2023 – Basel IV implementation begins in most jurisdictions (delayed by one year from the original 2022 schedule due to COVID-19).

  • January 2025 – EU and other jurisdictions align their local Capital Requirements Regulation (CRR3) and Directive (CRD VI) with Basel IV.

  • January 2028 – Full global implementation of Basel IV expected, including the 72.5% output floor and all revised risk frameworks.


Expected Impact of Basel IV

For Banks

  • Higher capital requirements for certain exposures, particularly real estate and large corporates.

  • Reduced reliance on internal models, forcing banks to rely more on standardized approaches.

  • Operational risk capital increases for banks with high historical loss profiles.

  • Pressure on profitability, as stricter rules reduce return on equity (ROE).

For Regulators

  • Greater comparability across banks globally.

  • Reduced systemic risk and improved transparency.

  • Stronger confidence in capital adequacy metrics.

For Markets

  • Large, complex banks will face higher compliance and reporting costs.

  • Smaller banks may benefit, as reliance on standardized approaches reduces competitive imbalances.

  • Lending patterns may shift, with higher capital charges affecting real estate and corporate lending.


Criticisms of Basel IV

  • Cost of compliance – Implementation requires major IT and reporting upgrades.

  • Credit supply impact – Some argue stricter capital rules will reduce banks’ willingness to lend.

  • Global inconsistencies – Different timelines in different regions (e.g., EU, US, Asia) could create competitive imbalances.

  • Complexity – Despite simplification efforts, the reforms remain highly technical.


Basel III vs. Basel IV: What Changed

  • Basel III: Focused on capital quality, buffers, leverage, and liquidity standards.

  • Basel IV: Focuses on risk measurement consistency, model restrictions, and the output floor.

  • Basel III made banks stronger; Basel IV makes their capital ratios more credible and comparable.


Conclusion

Basel IV represents a critical milestone in the global regulation of banks. While it is technically the finalization of Basel III, its scope and impact are profound enough to warrant its own identity. By 2028, when Basel IV is fully implemented, the international banking system will operate under a far stricter and more standardized regime.

The reforms may reduce profitability and lending flexibility, but they aim to restore trust, comparability, and resilience across the banking sector. For regulators, investors, and society, Basel IV is not just about numbers — it is about ensuring stability in an interconnected financial world.

9/05/2017

managing credit risk efficiently

 

Cash-Funded vs. Unfunded Significant Risk Transfers (SRTs)

Introduction

In modern banking, managing credit risk efficiently has become just as important as generating revenue. One of the most important tools in this process is the Significant Risk Transfer (SRT). Through SRT transactions, banks can reduce their risk-weighted assets (RWAs) and achieve capital relief, allowing them to deploy capital more effectively.

Within the SRT market, two primary structures dominate: cash-funded SRTs and unfunded SRTs. While both are designed to achieve the same objective — transferring risk from banks to external investors — their mechanisms, benefits, and risks differ significantly.


What Is a Significant Risk Transfer (SRT)?

A Significant Risk Transfer is a financial transaction where a bank shifts the credit risk of a portfolio of loans or assets to third-party investors. In return, the bank obtains capital relief under Basel III/IV rules, since regulators recognize that part of the risk has been offloaded.

SRTs can be executed via different instruments, such as:

The distinction between cash-funded and unfunded structures lies in how protection sellers cover potential losses.


Cash-Funded SRTs

Definition:
In cash-funded transactions, the protection seller (usually an investor, fund, or insurer) posts cash collateral upfront. This collateral is placed in a segregated account or invested in high-quality assets, which the bank can draw on in case of credit losses.

How It Works:

  • Bank transfers the credit risk of a loan portfolio.

  • Investor provides cash collateral.

  • If losses occur, the collateral is used to compensate the bank.

  • If no losses occur, the investor earns interest or spread on the collateral.

Advantages:

  1. Lower counterparty risk: Since collateral is already in place, the bank faces minimal exposure if the investor defaults.

  2. Regulatory comfort: Supervisors like the ECB and PRA prefer cash-funded deals due to their transparency and security.

  3. Investor credibility not critical: Even if the investor has weaker credit, the collateral protects the bank.

Drawbacks:

  1. Capital lock-up: Investors must tie up large amounts of cash, reducing liquidity.

  2. Lower yield for investors: Returns are limited compared to unfunded structures.

  3. Higher costs for banks: Because investors demand compensation for immobilizing capital.

Market Example:
Collateralized loan obligations (CLOs) and funded CLNs are common forms of cash-funded SRTs, widely used across Europe.


Unfunded SRTs

Definition:
In unfunded transactions, the protection seller provides no upfront collateral. Instead, the seller guarantees to cover losses contractually — usually through a credit default swap (CDS) or an insurance policy.

How It Works:

  • Bank enters into a contract with a protection seller (e.g., insurer).

  • No cash is exchanged at the start, only contractual risk coverage.

  • If losses occur, the protection seller pays from its own resources.

  • Investor earns a premium in exchange for taking on the risk.

Advantages:

  1. Capital efficiency for investors: No upfront cash required, freeing liquidity for other uses.

  2. Lower transaction cost for banks: Cheaper than cash-funded SRTs.

  3. Attractive to long-term investors: Insurance companies and pension funds with deep balance sheets can handle unfunded exposures.

Drawbacks:

  1. High counterparty risk: Payment depends on the solvency of the protection seller.

  2. Regulatory restrictions: Allowed in the EU, but prohibited in the UK, reflecting supervisory caution.

  3. Complexity in enforcement: Recovery in case of default can be legally and operationally challenging.

Market Example:
Unfunded SRTs are often structured with insurers or highly rated counterparties, such as using CDS contracts on mortgage or corporate loan portfolios.


Key Differences at a Glance

FeatureCash-Funded SRTUnfunded SRT
CollateralCash posted upfrontNone, contractual promise
Counterparty RiskLowHigher
Regulatory AcceptanceStrongCautious (restricted in UK)
Investor LiquidityLocked upPreserved
Cost for BanksHigherLower
Investor TypeFunds, asset managersInsurers, strong balance sheet institutions

Regulatory Views

  • European Central Bank (ECB): Supports SRTs as capital management tools but warns of correlation risk if banks lend to their own SRT investors.

  • Prudential Regulation Authority (PRA, UK): More restrictive, allowing only cash-funded SRTs to ensure robustness.

  • Basel Committee on Banking Supervision (BCBS): Actively reviewing the benefits and risks of both funded and unfunded SRTs in the context of Basel IV.

Supervisors emphasize that capital relief must be “genuine and durable”, not cosmetic.


Future Outlook

Both structures will continue to play roles in bank risk management, but trends suggest:

  • Cash-funded SRTs will remain dominant due to stronger regulatory acceptance.

  • Unfunded SRTs may grow in the EU if investor demand increases and regulators gain confidence in long-term counterparties like insurers.

  • Hybrid models may evolve, combining cash collateral with unfunded guarantees for flexibility.

  • Demand for green and ESG-linked SRTs could encourage innovative risk-sharing structures.


Conclusion

Cash-funded and unfunded SRTs represent two approaches to the same problem: how to transfer risk efficiently while optimizing regulatory capital. Cash-funded deals provide maximum safety and regulatory comfort, but at a higher cost. Unfunded deals offer flexibility and efficiency, but at the price of increased counterparty risk.

For banks, the choice depends on balance sheet needs, investor appetite, and regulatory environment. For investors, the decision rests on liquidity preferences, return targets, and risk tolerance. Ultimately, both structures are central to the evolution of modern banking, helping institutions balance resilience with growth.

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