Home

Risk Based Supervision

Risk based Supervision


Risk based supervision is all about continuous monitoring and assessing How well a banks internal control systems operate in actual and projected environment. Such a supervision makes up for a forward looking. Proactive supervisory programme unlike the old system where we examine by hind sight the concluded transactions. After the industry experienced huge failures, there is now focused attention to the internal control systems.

The key to the risk based supervision is finding a way to ensure that the banks have in place adequate systems of internal control.

risk-based-supervision-icon

The systems in place should be able identify, monitor and manage risk rather than be devoted to the review of discrete transactions. Such a system should be tested on an ongoing basis to ensure that the internal control system fuction the way they should.

Basle committee noted and attributed the problems leading to significant losses in the industry to

1. Inadequate assessment of the risk of certain banking activities whether on or balance sheet. Major losses were found to occur due to the failure of the bank to continuously assess the products and activities or update risk assessment when significant changes occurred in the environment or business conditions. The existing control systems were found to be wanting to cope with such a change

2. Lack of management over sight and accountability and failure to develop strong control culture with in the bank.

3. The absence of Key control activities like segregation of duties, approvals, verifications, reconciliations and review of operative performance.

4. Inadequate communication of information between the levels of management with in the bank

Following principles have been laid down for the assessment of internal control systems, management oversight and control culture.

1. The board of directors should have the responsibility for approving strategies and policies; understanding the risks run by the bank setting acceptable levels for these risks; ensuring that the senior management takes steps necessary to identify control and monitor these risks approving the organizational structure; and ensuring that the senior management is monitoring the effectiveness of the control system

2. Senior management should have the responsibility for implementing strategies approved by the board

3. Board and senior management are responsible for promoting high standards of ethics and integrity and for establishing a culture with in the organization that emphasises and demonstrates at all levels the importance of internal control system

4. Senior management should ensure that the risks and internal and external factors affecting the achievement of the banks strategies and objectives are continually being evaluated

5. Control activities should be an integral part of the daily operations of a bank S.M. to ensure this

6. S.M. to ensure that there is appropriate segregation of duties

7. S.M. to ensure that there are adequate and comprehensive internal financial, operational and compliance data.

8. S.M. to ensure and establish effective channels of communication to ensure that all levels staff are fully aware of policies and procedures affecting their duties and responsibilities. S.M. to also ensure that there exists appropriate information systems.

9. S.M. should continually monitor overall effectiveness of the banks internal controls.

10. There should be an effective and comprehensive internal audit and control system carried out by trained staff.

11. There should be system for timely reporting of deficiencies.

risk-based-supervision-icon

Banking and the Applicability of Risk Based Supervision


Though the International banks have gone far ahead of Indian banks in handling volumes, variety, and complexity, we have not lagged behind in so far as risk exposures are concerned. We did not experience Barrings, LTCM, Enron, and Sumitomo types of risk crisis. But we did witness in a smaller measure the presence of mis-adventure, recklessness, systemic inadequacies when Harshad Mehta scam surfaced in stock exchange. We did see how far banks were willing to be taken for a ride with a rogue stockbroker.

Banks were willing to be associated with his activities and exposed themselves to the grave risk of losing huge money, name and fame. Banks like S.B.I, National Housing Bank, several foreign banks, co-operative banks were itching for quick buck and short cut for prosperity. When the bubble burst and the ball game stopped they all got struck up. Banks like Bank of Karad and a few co-operative banks had to close down. Few other banks merged. Large number of banks faced punitive action (The book" WHO WON, WHO LOST, WHO GOT AWAY" brought to light the risky honey mooning of banks with the Rogue stock trader)

Small investors who lost their life savings are still shy of the capital market. No amount of concession, relaxation, incentives from the Govt. and the R.B.I restored the confidence of these strong small time investors in large numbers. The probe by Joint Parliamentary Committee revealed almost all kinds and variety of risks present in the industry, starting from Credit risk, Market risk, Liquidity risk, Settlement risk, Default risk. Name and fame risk etc to the recently focused attention to the Operational risks as well.

This was followed by U.T.I scam and frauds here and there in a few banks. Counterfeit and duplicate securities and stock certificates, wiful defaulters to both banks and financial institutions, failure of large sized projects, due to demand recession and cost and time over run, poor heath (Financial) of Electricity boards public sector units losing their competitiveness due to privatization all these and more contributed to the agony of the banks.

All these took place in the wake of implementation of various supervisory guidelines on capital adequacy norms, prudential guidelines and ceilings on guidelines on capital adequacy norms, prudential guidelines and ceilings on lending, balance sheet disclosures and transparency, huge provisioning need on classified accounts, capital erosion on one side and the need for conforming to the Basles capital adequacy at 8% on risk weighted assets on the other. The aggressive recovery oriented action resulting in huge concessions and write offs besides some hard core assets seeking permanent position in the balancesheet.

Banks had to face all these new challenges and face the severe competition consequent upon liberalization measures, licensing policy, interest-rate de- regulation. Credit pick up continues to sluggish. Good borrower customers have recourse to borrowing at such rates as are unviable to lending banks. It is quite some time now that almost all banks Investment portfolio has comfortably overtaken the Credit portfolio. There is limited scope for Indian banks to supplement revenues by fee based income.

It is in this back drop banks are aggressively going for bullet loans, extending large guarantees, for green field projects and state undertaken projects which ought to have the finance of budgetary allocation. The default by public and state sector corporations (Like H. M. T, H.P.F) landed them under banks non - performing asset category.

To improve the bottom line there is virtual scramble for retail lending under different schemes in a large scale manner. Loans for house building and real estate loans once under control now thrown open. Gone are the days where value of land buildings and rentals never crashed. Fall in market prices of real estate securities common to other countries is slowly creeping in. Future position of these credits and its realisability, only the future can tell us.

In this state of affairs the relevance of risk based credit supervision, new risk based capital allocation and effective risk management system needs no stronger emphasis.

RISK is explained as a possibility of meeting the danger, suffering harm or loss or loss being exposed to harm or loss.

Risk management is the systematic process of understanding, measuring. controlling risk exposures to achieve the objectives. It consists of planning. organizing, co-ordinating and managing of activities undertaken with the intent of providing an environment that minimizes the adverse impact on the organizations resources, earnings and cash flows.

The design of risk management in India common to all and to cover all the situations are difficult to be blue printed. Such a design should be bank specific, risk specific dictated by the size, complexity of functions levels of technical risk specific dictated by the size, complexity of functions levels of technical expertise and quality of M.I S.

Risks
Credit RiskMarket riskOperational risk

As a primary step towards risk management efforts we have to understand appreciate various category of risks.

Risks are broadly classified as:

1. Credit risk

2. Market risk

3. Operational risk

4. Others