II. Reporting Format and Contents
1. Overview of the Reporting Format and Contents
The ultimate end product of the ICAAP process is the ICAAP document. This section on reporting format and contents is to provide guidance to banks to describe in a logical format the main assumptions and results of the ICAAP process. Consequently, the ICAAP document should bring into one place an assessment of the capital requirements in relation to a bank's risk profile, strategies, business plans, major risks, acquisitions, governance and internal risk management systems, etc. It also must establish the capital required for economic, regulatory and accounting purposes and help identify planned sources of capital to meet its objectives. Further, all relevant assessments and information should be covered and documented in the ICAAP.
Specifically, the objectives of the ICAAP and the related entities of the bank that are included by it should be specified. The main results of the ICAAP effort may be presented in a tabular format indicating the major components of capital requirements, capital available, capital buffers and proposed funding plans. Furthermore, the adequacy of the governance and bank's internal control and risk management processes should be included.
It is also important to document the strategic position of the bank, its balance sheet strength, planned growth in the major assets based on its Business plans for the next 12 to 18 months indicating the likely consumption in capital for this growth by major category.
Further, the results of major stress tests on capital requirements and capital supply for additional risks deterioration in the economic environment, recessionary periods, or other economic/political downturns are important aspects to be covered.
2. Executive Summary
The major purpose of the Executive Summary is to describe in a summary form the main results of the ICAAP effort which is to bring into one place objectives of the ICAAP, the assessment of the capital requirements for strategies, business plans, all risks, acquisitions, etc. Also presented and described should be the capital required for economic, regulatory and accounting purposes and identification of planned sources of capital to meet these objectives. The following information should be briefly described and where appropriate, relevant amounts are quantified and presented in a tabular format:
A. 1. Capital Required
■ Pillar 1 Capital Requirements
■ Pillar 2 Capital Requirements
■ Business Plans (Summarized)
■ Growth Rate and amounts by business lines
■ Capital requirements by business lines
■ Strategic Initiatives
■ Capital Expenses
■ Stress testing
■ Other capital requirements
■ Total capital requirements
2. Capital Available
■ Current Availability
■ IPOS
■ Qualifying Sukuks
■ Qualifying Debt issues
■ Rights issue
■ Other capital sources
■ Total capital sources
3. Buffer Available (1-2)
B. Dividends Proposed
C. Funding plans over the Time Horizon
D. Capital requirement for each subsidiary or affiliate
Other information that may be included in the Executive Summary are comments on significant matters on any of the items above.
3. Objective of an ICAAP
A description of the bank's specific objectives is desirable. In this regard, the differing purposes that capital serves: shareholder returns, rating objectives for the bank as a whole or for certain securities being issued, avoidance of regulatory intervention, protection against uncertain events, depositor protection, working capital, capital held for strategic acquisitions, etc.
4. Summary of Bank's Strategies Including its Current and Projected Financial and Capital Positions
This section would be the major elements of a bank's strategic and operational plans. It would include the present financial position of the bank and expected changes to the current business profile, the environment in which it expects to operate, its projected business plans (by appropriate lines of business), projected financial position, and future planned sources of capital.
Major aspects to be considered is formulating a business plan and the bank's strategies and initiative including aspects such as the political, economic, legal, components, etc. of the environment their likely profile and impact over the planning period of the Bank. This may consider aspects such as oil prices, legislation related to the Bank, i.e. foreign investments, consumer banking, capital markets, mortgages, leasing and installment companies, etc.
The starting balance sheet and the date over which the assessment is carried out should be disclosed.
The projected balance sheet should clearly indicate the major lines of business which are going to be inspected by the Bank's strategic initiatives, environmental changes and assumption over the planning period and the impact on capital requirements by major lines of business.
Also included would be the projected financial position, the projected capital available and projected capital resource requirements based on expected plans. These might then provide a baseline against which adverse scenarios might be compared.
5. Capital Adequacy and ICAAP
This section should include the following:
Disclosure of various types of Capital
An ICAAP establishes a framework for economic, legal, regulatory and accounting capital purposes and helps identify planned sources of capital to meet these needs. Consequently, this section should provide a distinction from the bank's perspective of the following capital classification indicating their purpose, minimum requirements and other attributes.
1. Regulatory Capital
2. Accounting Capital
3. Legal Capital
4. Economic Capital (if relevant)
Additionally, a bank will need to describe its position with respect to its definition, assimilation and usage within the bank's risk and performance assessment framework.
Consequently, this section should elaborate on the bank's view of the amount of capital it requires to meet its minimum regulatory needs and disclosure requirements under International Accounting Standards, or whether what is being presented is the amount of capital that a bank believes it needs to meet its strategic business objectives, external ratings, and a support for a dividend policy from a shareholders perspective, etc. For example, whether the capital required is based on a particular desired credit rating or includes buffers for strategic purposes or to minimize the charge for breaching regulatory requirements. Where economic capital models are used this would include the time horizon, economic description, scenario analyses, etc. including a description of how the severity of scenarios have been chosen.
Timing of the ICAAP
Generally, the ICAAP is prepared on an annual basis as at the end of each calendar year, i.e. 31 December 2008 (and is due in SAMA as at 31 January of the following year). However, should there be any variation to this timing, additional details will need to be provided. This will include the reasons for the effective date of the ICAAP. Other information to be provided will also include an analysis and consideration for any events between the effective date and the date of submission which could materially impact the ICAAP and the rationale for the time period over which ICAAP has been assessed.
Risk Covered in the ICAAP
An identification and appropriate description of the major risks faced in each of the following categories:
■ Credit Risk (Additional to Pillar 1)
■ Market Risk (Additional to Pillar 1)
■ Operational Risk (Additional to Pillar 1)
■ Liquidity Risk
■ Concentration Risk
■ Securitization Risk
■ Strategic Risk
■ Interest Rate Risk
SAMA recognizes banks’ internal systems as the principal tool for the measurement of interest rate risk in the banking book and the supervisory response. To facilitate SAMA’s monitoring of interest rate risk exposures across institutions, banks would have to provide the results of their internal measurement systems, expressed in terms of economic value relative to capital, using a standardized interest rate shock.
Further to the above, as per SAMA circular dated 10 November 2011, banks need to provide the following details:
- Provisions: The Bank should enhance the section on this topic by providing the following end of year information, for the past five years (including the current year).
- Specific, general and total provisions
- Provision expense charged to the income statement (net of recoveries)
- Default rates by major portfolios (Retail, Credit Card, Corporate, SME's, etc.)
- Total Non-performing Loans
- Coverage Ratio
2. Concentration Risk: The Banks should under the section on concentration risk include the following information for the past 3 years (including the current year).
- On and Off Balance Sheet Credit exposure to top ten customers as a percentage of total on and off balance sheet credit.
- On and Off Balance Sheet Credit exposure to top ten customers as a percentage of Bank's regulatory capital.
- Number of loans extended to connected parties and the total value of such loans as a percentage of total credit.
- Total value of loans to connected parties as a percentage of total regulatory capital.
- The banks could add comments on the concentration risk and how it affects their assessment of additional capital requirements, if any.
3. Liquidity Risk: The Banks should provide the following information as at the end of year.
- Liquidity Coverage Ratio
- Net Stable Funding Ratio
- In addition, the following information should be provided for the past three years (as at end of the year):
- Deposits from top (10) ten customer as a percentage of total customer deposits.
- Deposits from Wholesale markets (interbank, others) as a percentage of total liabilities.
4. Off Balance Sheet Activities: The following year-end information on Derivatives Activity should be provided for past 3 years with breakdown in Saudi Riyal, USD and other currencies.
- Interest rate Derivatives
- FX Derivatives
5.Capital Leverage Ratio: Banks should include information on the following:
- Basle Capital Leverage Ratio (current year)
- Legal Leverage Ratio under the Banking Control Law (for past 3 years)
(Refer to Paragraph 763 of International Convergence of Capital Measurement and Capital Standards – June 2006)
■ Macro Economic and Business Cycle Risk
■ Reputational Risk
■ Global Risk
■ Any other Risks identified
■ An explanation of how each of the risk has been identified, assessed, measured and the methodology and or models currently or to be employed in the future, and the quantitative results of that assessment;
■ where relevant, a comparison of that assessment with the results of the pillar 1 calculations;
■ a clear articulation of the bank's risk appetite by risk category; and
■ where relevant, an explanation of method used to mitigate these risks.
6. Approach and Methodology
Current Methodology
A description of how models and assessments for each of the major risks have been approached and the main assumptions made.
For instance, banks may choose to base their ICAAP on the results of Pillar 1 risks calculation with additional risks (e.g. concentration risk, interest rate risk in the banking book, etc.) assessed separately and added to Pillar 1. Alternatively, a bank may decide to base their ICAAP on internal models for all risks, including those covered under Pillar 1 (i.e. Credit, Market and Operational Risks) as additional risks.
The description would make clear which risks are covered by which modeling calculation or approach. This would include details of the models, methodology and process used to calculate risks in each of the categories identified and reason for choosing the models and method used in each case.
Future Approach and Methodology
Banks may provide a summary on the future models and methodologies being considered and developed including their strengths and weaknesses.
Internal Models: Pillar 1 and ICAAP comparisons
Should the internal models vary from any regulatory models approved for pillar 1 purposes, this section would provide a detailed comparison explaining both the methodological and parameterization differences between the internal models and the regulatory models and how those affect the capital measures for ICAAP purposes.
7. Details on Models Employed
A list of models utilized in the formulation of the ICAAP should be provided giving relevant and appropriate details as given below:
■ The key assumptions and parameters within the capital modeling work and background information on the derivation of any key assumptions.
■ How parameters have been chosen including the historical period used and the calibration process.
■ The limitations of the model.
■ The sensitivity of the model to changes in the key assumptions or parameters chosen.
■ The validation work undertaken to ensure the continuing adequacy of the model.
■ Whether the model is internally or externally developed. If externally acquired its generic name and details on the model developer.
■ Details should also be provided as to the extent of its acceptance by other regulatory bodies, users in the international financial community, overall reputation and market acceptance.
■ Specific details on the applications within the Bank, i.e. measurement of risks such as credit, liquidity, market, concentration, etc. or for the purpose of establishing internal credit risk classification ratings, risk estimates, PDs, LGDs, EADs, etc.
■ Major merits and demerits of the chosen models.
■ Results of the model validation obtained through
■ Back testing / Scenario testing
■ Analysis of the internal logic
■ Major methodologies or statistical technique used, i.e. value at risk models employing methods such as variance/co-variance; historical simulation, Monte Carlo method, etc.
■ Confidence levels embedded for regulatory capital, economic capital, or for external rating purposes.
Further, the explanation of the differences between results of the internal model for Pillar 1 would be set out at the level at which the ICAAP is applied. Therefore, if the firm's ICAAP document breaks downs the calculation by major legal regulated entities, an explanation for each of those individual entities would be appropriate.
SAMA would expect the explanation to be sufficiently granular to show the differences at the level of each of the Pillar 1 risks.
Data definition, i.e. whether the source is external or internal and if any data, manipulation of external data has been done for it to conform with internal data.
8. Stress and Scenario Tests Applied
Where stress tests or scenario analyses have been used to validate the results of modeling approaches, the following should be provided:
■ information on the quantitative results of stress tests and scenario analyses the bank carried out and the confidence levels and key assumptions behind those analyses, including, the distribution of outcomes;
■ information on the range of adverse scenarios which have been applied, how these were derived and the resulting capital requirements; and
■ where applicable, details of any additional business-unit specific or business plan specific stress tests selected.
Details on Stress and Scenario Testing:
This section should explain how a bank would be affected by an economic recession or downswings in the business or market relevant to its activities. SAMA is interested in how a bank would manage its business and capital so as to survive for example a recession whilst meeting minimum regulatory standards. The analysis would include financial projections for two to three years based on business plans and solvency calculations.
The severity of recession may typically be one that occurs only once in a 15 year period. The time horizon would be from the present day to at least the deepest part of the recession.
Typical scenarios would include:
■ how an economic downturn would affect
■ the bank's capital resources and future earnings; and
■ the bank's strategy takes into account future changes in its projected balance sheet, income statement, cash flow statement, impact on its financial assets, etc.
■ In both cases, it would be helpful if these projections showed separately the effects of management actions to changes in a bank's business strategy and the implementation of any contingency plans.
■ an assessment by the bank of any other capital planning actions to enable it to continue to meet its regulatory capital requirements through a recession. These actions may include new capital injections from related companies, new share issues through existing shareholders, IPO's, floatation of long term debt, Sukuks, etc.
■ For further details, refer to Attachment 1.
9. Capital Transferability Between Legal Entities
Details of any restrictions on the management's ability to transfer capital during stressed conditions into or out of the business(es) covered. These restrictions, for example, may include contractual, commercial, regulatory or statutory nature. A statutory restriction could be, for example, a restriction on the maximum dividend that could be declared and paid. A regulatory restriction could be the minimum regulatory capital ratio acceptable to SAMA.
10. Aggregation and Diversification
This section would describe how the results of the various risk assessments are brought together and an overall view taken on capital adequacy. This requires an acceptable methodology to combine risks using quantitative techniques. At the general level, the overall reasonableness or the detailed quantification approaches might be compared with the results of an analysis of capital planning and a view taken by senior management as to the overall level of capital that is appropriate.
■ Dealing with the technical aggregation, the following may be described:
i. any allowance made for diversification, including any assumed correlations within risks and between risks and how such correlations have been assessed including in stressed conditions;
ii. the justification for diversification benefits between and within legal entities, and the justification for the free movement of capital between legal entities in times of financial stress.
11. Challenge and Adoption of the ICAAP
This section would describe the extent of challenge and testing of the ICAAP. Accordingly, it would include the testing and control processes applied to the ICAAP models or calculations, and the senior management or board review and sign off procedures.
In making an overall assessment of a bank's capital needs, matters described below should be addressed:
i. the inherent uncertainty in any modeling approach;
ii. weaknesses in bank's risk management procedures, systems or controls;
iii. the differences between regulatory capital and available capital;
iv. the reliance placed on external consultants.
v. An assessment made by an external reviewer or internal audit.
Internal control review
The bank should conduct periodic reviews of its risk management process to ensure its integrity, accuracy, and reasonableness. Areas that should be reviewed include:
• Appropriateness of the bank’s capital assessment process given the nature, scope and complexity of its activities;
• Identification of large exposures and risk concentrations;
• Accuracy and completeness of data inputs into the bank’s assessment process;
• Reasonableness and validity of scenarios used in the assessment process; and
• Stress testing and analysis of assumptions and inputs.
• (Refer to Paragraph 745 of International Convergence of Capital Measurement and Capital Standards – June 2006)
12. Use of the ICAAP within the Bank
This area should demonstrate the extent to which capital management is embedded within the bank's operational and strategic planning. This would include the extent and use of ICAAP results and recommendation in the strategic, operational and capital planning process. Important elements of ICAAP including growth and profitability targets, scenario analysis, and stress testing may be used in setting of business plans, management policy, dividend policy and in pricing decisions.
This could also include a statement of the actual operating philosophy and strategy on capital management and how this links to the ICAAP submitted.
13. Future Refinements of ICAAP
A bank should detail any anticipated future refinements within the ICAAP (highlighting those aspects which are work-in-progress) and provide any other information that will help SAMA review a bank's ICAAP.