Best Practices in Interest Rate Risk Management for the Banking Book 0 Chicago | London | SingaporeInc. © 2014 Quantitative Risk Management, Best Practices in Interest Rate Risk Management for the Banking Book I. Introduction II. Defining and Measuring IRRBB III. Global Perspectives of IRRBB IV. Challenges in IRRBB Management V. Moving Towards Best Practices VI. Conclusion 1 © 2014 Quantitative Risk Management, Inc. Banks Must Manage Interest Rate Risk in the Banking Book (IRRBB) Managing interest rate risk in the banking book (IRRBB) is more important now than in recent history Interest rate levels and volatility Increasing scrutiny of measurement processes Typically, Asset-Liability management struggles to balance two primary objectives of IRRBB management: Maximize earnings growth while minimizing earnings volatility Maximize long-term shareholder returns through market-based metrics An approach that integrates both earnings-based and market-value-based approaches enables best-practice management of IRRBB 2 © 2014 Quantitative Risk Management, Inc. Best Practices in Interest Rate Risk Management for the Banking Book I. Introduction II. Defining and Measuring IRRBB III. Global Perspectives of IRRBB IV. Challenges in IRRBB Management V. Moving Towards Best Practices VI. Conclusion 3 © 2014 Quantitative Risk Management, Inc. What Is IRRBB? Interest rate risk (IRR) is the exposure of the bank’s capital and earnings to adverse movements in interest rates The banking book is usually considered to be all of the bank’s assets and liabilities, and its off-balance sheet, excluding the trading book Changes in interest rates affect the underlying economic value of the bank’s assets, liabilities, and off-balance sheet Changes in cash flows Present value of future cash flows Changes in interest rates affect the accrual earnings of the bank 4 Changes in net interest income Changes in other interest-sensitive income and expenses © 2014 Quantitative Risk Management, Inc. There Are Many Sources and Drivers of IRRBB Sources All sources of IRRBB must be captured Risk factors Repricing Yield curve Basis Optionality Practices around the world vary with respect to including credit spread risk in the banking book Basel has separated out IRRBB from CSRBB EBA requires that the curve used for EVE analysis exclude instrument- or entity-specific credit spreads and liquidity risk 5 Interest rates Volatilities © 2014 Quantitative Risk Management, Inc. Additional Best Practice Considerations: Model Interest-Sensitive Non-Interest Income Interestsensitive non-interest income must be modeled 6 For many institutions, non-interest income has become a significant component of net income Non-interest income arising from loan servicing or origination can have a complex relationship with market interest rates © 2014 Quantitative Risk Management, Inc. Additional Best Practice Considerations: Integrate Robust Behavioral Models Robust, wellparameterized behavioral models must be integrated In addition to loan prepayment models and line-of-credit draw models, focus on deposit segmentation and runoff analysis is increasing with respect to both IRRBB and liquidity There are more advanced modeling techniques being used, but at a minimum, segmentation of core vs. non-core deposit attrition should be used Administered rate pricing models are also a key input. For instance, deposit models should incorporate the appropriate sensitivity to the underlying market drivers 7 © 2014 Quantitative Risk Management, Inc. Typical IRRBB Risk Metrics Economic value perspective Economic value of equity (EVE) is the present value of the bank’s expected net cash flows (including assets, liabilities, and off-balance sheet) discounted using current market rate Duration of equity (DOE) measures the sensitivity of EVE in different scenarios Earnings perspective Net interest income (NII) is the difference between interest received from assets and interest paid on liabilities NII sensitivity is usually the focus of earnings risk analysis, though best practice dictates the use of net income (NI) which also includes important sources of interest-sensitive income/expense Total return perspective Combines the best attributes of the economic value and earnings perspectives 8 © 2014 Quantitative Risk Management, Inc. Best Practices in Interest Rate Risk Management for the Banking Book I. Introduction II. Defining and Measuring IRRBB III. Global Perspectives of IRRBB IV. Challenges in IRRBB Management V. Moving Towards Best Practices VI. Conclusion 9 © 2014 Quantitative Risk Management, Inc. Regulators Have Emphasized the Economic Value-Based Approach Regulators recognize that institutions use both economic-valueand earnings-based approaches for IRRBB A Basel Committee paper on economic capital practices highlighted EVE, VaR, and EaR-based techniques as commonly used approaches for IRRBB economic capital However, their emphasis has been on the economic value-based approach Basel and EBA have both provided supervisory guidance centered on using EVE-based measures to ensure sufficient capital for IRRBB APRA mandates an EVE-based VaR calculation with a 99% confidence level and 1-year holding period in determining the IRRBB capital requirements for re-pricing and yield curve risk The Federal Home Loan Banks are subject to a regulatory “market risk” capital requirement based on a banking book VaR calculation with 99% confidence over a 6-month horizon 10 © 2014 Quantitative Risk Management, Inc. No Explicit Standards for Earnings-Based Approaches Have Been Established Yet No explicit, standardized regulatory analysis has been prescribed for earnings-based approaches Recently, the Basel Committee set up a Task Force on Interest Rate Risk geared toward capturing IRRBB within the regulatory capital framework To prevent “regulatory arbitrage” between the trading and banking books To address the concern of potential losses stemming from rising interest rates Regulators have begun collecting data from banks for this task force, but no guidelines on preferred approaches (EVE or NII) have been published yet 11 © 2014 Quantitative Risk Management, Inc. Management Views May Differ from the Current Regulatory View Regulatory capital metrics commonly used for other risks (e.g. market risk in the trading book, operational risk) are consistent with measurement techniques used for risk management However, there is not a clear link with IRRBB Balance sheet management is typically focused around earnings, while regulators typically focus on EVE-based capital metrics Lower earnings do not necessarily translate into loss of capital Across the world, we see variation in the focus of IRR measurement Brasil, Australia – EVE Europe – EVE and interest rate gap US – earnings and EVE (to a lesser degree) 12 © 2014 Quantitative Risk Management, Inc. Stress Testing Has Helped Align Management Objectives with Regulatory Objectives One of the difficulties of coming up with earnings-based regulatory guidance has to do with standardization Earnings results are heavily impacted by underlying assumptions about how the balance sheet evolves “Runoff” or “constant” assumptions are not realistic or in-line with how a bank will manage its balance sheet Realistic new business assumptions are institution-specific and therefore hard to standardize Some jurisdictions, particularly the US, have instituted stress testing combined with a comprehensive review of assumptions (CCAR) Institutions that have embraced such integrated analysis have leveraged the stress testing exercise into a fully integrated balance sheet management process that can be used to manage the bank in any scenario However, this undertaking can be expensive for both the regulators and the institutions that they regulate 13 © 2014 Quantitative Risk Management, Inc. Best Practices in Interest Rate Risk Management for the Banking Book I. Introduction II. Defining and Measuring IRRBB III. Global Perspectives of IRRBB IV. Challenges in IRRBB Management V. Moving Towards Best Practices VI. Conclusion 14 © 2014 Quantitative Risk Management, Inc. There Are Various Constituents Within the Institution, Each with Different Interest Rate Risk Objectives CFO: wants no surprises in reported quarterly NII results Investor relations: may identify major shareholder duration targets that are not being met Business and portfolio managers: suggest ways to restructure balance sheet across asset and liability classes, to improve level of NII AL managers: help balance these objectives 15 © 2014 Quantitative Risk Management, Inc. Successful AL Managers Are Able to Communicate with All Constituents and Balance Their Objectives They use NII and DOE as appropriate in discussions with interested parties At the same time, they understand and communicate the relationship between NII sensitivity and DOE They define DOE and NII policies that are appropriate to the structure of their balance sheet and the objectives of the institution They propose hedges and other actions that facilitate effective management of NII and DOE 16 © 2014 Quantitative Risk Management, Inc. Leveraging DOE and NII-Sensitivity Information Can Be Challenging Understanding of the complex relationship between DOE and NII is limited How are they related? Why should management care about DOE limits when NII is the “real” focus? DOE and NII policy limits are too restrictive or loose, and therefore difficult to manage or meaningless Balance sheet actions may impact DOE undesirably, potentially replacing NII policy violations with DOE policy violations However, these challenges are not insurmountable 17 © 2014 Quantitative Risk Management, Inc. Best Practices in Interest Rate Risk Management for the Banking Book I. Introduction II. Defining and Measuring IRRBB III. Global Perspectives of IRRBB IV. Challenges in IRRBB Management V. Moving Towards Best Practices VI. Conclusion 18 © 2014 Quantitative Risk Management, Inc. What Can Your Valuation Results Tell You About Your Income Sensitivity? DOE is useful for capturing the IRR of the current position beyond the typical income-sensitivity horizon Risk can be placed (intentionally or unintentionally) in later years Policy limits now exist for both DOE results and income sensitivity DOE is a single measure that provides a directional indicator that aggregates both long- and short-term NII sensitivity in the current position A positive DOE implies income is negatively impacted by rising rates A negative DOE implies income is positively impacted by rising rates Simultaneously meeting both market value and income sensitivity policy limits can be challenging if the relationship DOE and NII is not clear What does it tell us about the timing of NII risk? What does it tell us about the magnitude of NII risk through time? 19 © 2014 Quantitative Risk Management, Inc. AL Managers Should Focus on the Contribution of NII Risk to DOE Many of you think of your balance sheet as two positions: assets and liabilities Conceptually, you also have a third position, the net interest margin (NIM), which also contributes to the overall level of DOE A portion of the NIM’s DOE comes from the change in value due to discounting Another portion of the NIM’s DOE comes from the changes in the level of income—care needs to be taken to focus on this particular portion in your DOE analysis 20 © 2014 Quantitative Risk Management, Inc. A Better Understanding of the Relationship Between DOE and NII Sensitivity Leads to More Appropriate DOE Limits Hedging DOE will not necessarily result in a desirable NII profile However, hedging short- and long-term NII can be used as a basis to define appropriate DOE limits Appropriate DOE limits will only violated when NII limits are violated The following exercise will demonstrate how to determine DOE limits that are aligned with NII sensitivity limits 21 © 2014 Quantitative Risk Management, Inc. Set DOE Limits That Are Consistent with NII Risk An exercise that minimizes the changes in income will help you to begin to understand the level of DOE associated with minimal NII risk 1. Typically, to focus on the current position, you use a runoff assumption— this should be the starting point of your DOE limit-setting 2. Layer hedges to stabilize income based on current balance sheet, to get a natural/embedded target DOE 3. Given the structure of your balance sheet today, this is the DOE associated with very little NII risk The next step is to repeat this exercise, but allowing some upside and downside to earnings, to calibrate limits In this manner, you are setting your limits based on NII and then translating them back into DOE This process requires periodic assessment as the structure of your balance sheet evolves 22 © 2014 Quantitative Risk Management, Inc. Set DOE Limits That Are Consistent with NII Risk 300 Net Interest Income (in Millions 200 Upper NII Limit 100 0 Lower NII Limit -100 NII Sensitivity -200 -300 1 2 3 4 5 6 7 8 9 10 Year of Forecast Duration of Equity: DOE: 3.25 -5 23 -3 -1 0 1 3 © 2014 Quantitative Risk Management, Inc. Set DOE Limits That Are Consistent with NII Risk 300 Upper NII Limit Net Interest Income (in Millions 200 100 Lower NII Limit 0 NII Sensitivity -100 Neutralized NII Position Sensitivity -200 -300 1 2 3 4 5 6 7 8 9 10 Year of Forecast Duration of Equity Range Associated with NII Sensitivity Limits: 0 Sensitivity DOE: 2.5 -5 -3 -1 0 1 3 Original DOE: 3.25 24 © 2014 Quantitative Risk Management, Inc. Set DOE Limits That Are Consistent with NII Risk 300 Upper NII Limit Net Interest Income (in Millions 200 Lower NII Limit 100 NII Sensitivity 0 Neutralized NII Position Sensitivity Upper Limit DOE NII -100 -200 -300 1 2 3 4 5 6 7 8 9 10 Year of Forecast Duration of Equity Range Associated with NII Sensitivity Limits: 0 Sensitivity DOE: 2.5 -5 -3 -1 0 1 3 Original DOE: 3.25 25 © 2014 Quantitative Risk Management, Inc. Upper Limit DOE: 5.0 Set DOE Limits That Are Consistent with NII Risk 300 Upper NII Limit Net Interest Income (in Millions 200 Lower NII Limit 100 NII Sensitivity 0 Neutralized NII Position Sensitivity Upper Limit DOE NII -100 -200 Lower Limit DOE NII -300 1 2 3 4 5 6 7 8 9 10 Year of Forecast Duration of Equity Range Associated with NII Sensitivity Limits: Lower Limit DOE: 1.5 -5 -3 -1 0 1 0 Sensitivity DOE: 2.5 3 Original DOE: 3.25 26 © 2014 Quantitative Risk Management, Inc. Upper Limit DOE: 5.0 Best Practices in Interest Rate Risk Management for the Banking Book I. Introduction II. Defining and Measuring IRRBB III. Global Perspectives of IRRBB IV. Challenges in IRRBB Management V. Moving Towards Best Practices VI. Conclusion 27 © 2014 Quantitative Risk Management, Inc. Conclusion Measurement of IRRBB has once again become a priority in terms of both the management and regulatory view The global vision of IRRBB has started to change, although EVE-based metrics are still the standard worldwide Recognition that both EVE- and earnings-based perspectives are best practice For AL managers, relating DOE and NII sensitivity can be a challenging task Once the relationship is better understood, policies can be established that will ultimately improve the risk management process 28 © 2014 Quantitative Risk Management, Inc. Thank you 29 Chicago | London | SingaporeInc. © 2014 Quantitative Risk Management, World Headquarters: 181 West Madison Street, 41st Floor Chicago, IL 60602 +1 312 782 1880 London Office: 13 Austin Friars London EC2N 2HE +44 (0)20 7920 9442 Singapore Office: 65 Chulia Street, #27-08 Singapore 049513 +65 6536 3402 www.qrm.com 30 © 2014 Quantitative Risk Management, Inc.
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