Risk shifting and regulatory arbitrage: Evidence from operational risk

We document a robust negative relation between operational risk exposure and bank capital levels for a sample of large U.S. banks under the Basel I Capital Accords. The results are consistent with the notion that capital-constrained banks increased operational risk exposure at the time when Basel I regulations did not require an explicit capital charge for operational risk. More broadly, our results show new channel by which financial regulations incentivize banks to shift their risk taking to less regulated risk areas. We focus on the case of operational risk because it went from a largely unregulated risk type to a major risk that accounts for about 25% of large U.S. banks’ risk-weighted assets.     

Should the insurance industry be banking on risk escalation for solvency II?

Basel II introduced a three pillar approach which concentrated upon new capital ratios (Pillar I), new supervisory procedures (Pillar II) and demanded better overall disclosure to ensure effective market discipline and transparency. Importantly, it introduced operational risk as a standalone area of the bank which for the first time was required to be measured, managed and capital allocated to calculated operational risks. Concurrently, Solvency II regulation in the insurance industry was also re-imagining regulations within the insurance industry and also developing operational risk measures. Given that Basel II was first published in 2004 and Solvency II was set to go live in January 2014. This paper analyses the strategic challenges of Basel II in the UK banking sector and then uses the results to inform a survey of a major UK insurance provider. We report that the effectiveness of Basel II was based around: the reliance upon people for effective decision making; the importance of good training for empowerment of staff; the importance of Board level engagement; and an individual's own world view and perceptions influenced the adoption of an organizational risk culture. We then take the findings to inform a survey utilizing structural equation modelling to analyze risk reporting and escalation in a large UK insurance company. The results indicate that attitude and uncertainty significantly affect individual's intention to escalate operational risk and that if not recognized by insurance companies and regulators will hinder the effectiveness of Solvency II implementation.     

Olav Aabakken

Abstract

An empirical linear Bayes estimator is asymptotically optimal in the usual sense if its average risk converges to the risk of the corresponding linear Bayes estimator. The present paper demonstrates that the following result holds for the most commonly used models: If the unknown (structural) parameters are estimated in such a way that their mean square error converges at a certain rate, then the corresponding empirical linear Bayes estimator is asymptotically optimal with the same rate of risk convergence. In particular, this is the case for the random coefficient regression model, and for hierarchical models in the univariate case.     

Quantitative measures of operational risk: an application to funds management

Basel II defines operational risk as the risk of direct or indirect loss resulting from inadequate or failed internal processes, people or systems or from external events. In the past decade, there have appeared a number of quantitative approaches to measuring this risk, approaches that abstract from market risk and reputational risk. The challenge is to develop operational risk measures in an asset management context where there is only limited information available about the incidence and severity of operational loss events. We survey different approaches to this problem and argue that managing this risk through operational due diligence is a source of alpha in this funds management context.     

Dilatation monotone risk measures are law invariant

We prove that on an atomless probability space, every dilatation monotone convex risk measure is law invariant. This result, combined with the known ones, shows the equivalence between dilatation monotonicity and important properties of convex risk measures such as law invariance and second-order stochastic monotonicity. We would like to thank Johannes Leitner for helpful discussions. The second author made contributions to this paper while being affiliated to Heriot-Watt University and would like to express special thanks to Mark Owen, whose project (EPSRC grant no. GR/S80202/01) supported this research.     

The pricing of deposit insurance in the presence of systematic risk

Based on the Merton (1977) put option framework, we develop a deposit insurance pricing model that incorporates asset correlations, a measurement for the systematic risk of a bank, to account for the risk of joint bank failures. Estimates from our model suggest that actuarially fair risk-based deposit insurance that considers only individual bank failure risk is underpriced, leaving insurance providers exposed to net losses. Our estimates also capture the size premium where big banks are priced with higher deposit insurance than small banks. This result is particularly relevant to the current regulatory concerns on big banks that are too-big-to-fail. Above all, our approach provides a unifying framework for integrating risk-based deposit insurance with risk-based Basel capital requirements.     

Internal loss data collection implementation: evidence from a large UK financial institution

The paper conducts a critical analysis of internal loss data collection implementation in a UK financial institution. We use elite semi-structured interviews, with a sample of 15 operational risk consultants from a leading international financial institution. Using content analysis, the data covers a wide range of business areas, with particular attention drawn towards the development of internal loss collection and operational risk management. The results suggest that the development of operational risk management as a function stems from external compliance (Basel II) and the internal pressure to add value to the business portfolio. This need for compliance was augmented as a driver of internal loss data collection; however, participants also recognised that the function of loss data collection is a tool of solid internal risk management and enhances managerial decision-making. The research also highlights the problems in cleansing data in order to ensure that all information implemented in the capital allocation model is valid and reliable.     

从银行监管改革变迁看我国商业银行操作风险管理路径选择

本文从介绍国内外操作风险监管改革变迁入手,分析了巴塞尔协议III和巴塞尔协议II在提升银行风险管理水平方面的差异,通过对我国商业银行操作风险管理现状和问题进行分析,提出了建立操作风险管理体系本质上是在商业银行应用更为精细化的管理方法,我国区域性商业银行、全国性商业银行、全球性商业银行现阶段操作风险管理的路径只要与银行的业务性质、规模和复杂程度相适应就是最佳选择的观点。     

SCENARIO GENERATION FOR OPERATIONAL RISK

Operational risk is an increasingly important area of risk management. Scenarios are an important modelling tool in operational risk management as alternative viable methods may not exist. This can be due to challenging modelling, data and implementation issues, and other methods fail to take into account expert information. The use of scenarios has been recommended by regulators; however, scenarios can be unreliable, unrealistic and fail to take into account quantitative data. These problems have also been identified by regulators such as Basel, and presently little literature exists on addressing the problem of generating scenarios for operational risk. In this paper we propose a method for generating operational risk scenarios. We employ the method of cluster analysis to generate scenarios that enable one to combine expert opinion scenarios with quantitative operational risk data. We show that this scenario generation method leads to significantly improved scenarios and significant advantages for operational risk applications. In particular for operational risk modelling, our method leads to resolving the key problem of combining two sources of information without eliminating the information content gained from expert opinions, tractable computational implementation for operational risk modelling, improved stress testing, what‐if analyses and the ability to apply our method to a wide range of quantitative operational risk data (including multivariate distributions). We conduct numerical experiments on our method to demonstrate and validate its performance and compare it against scenarios generated from statistical property matching for comparison. Copyright © 2013 John Wiley & Sons, Ltd.     

Basel框架下ORI风险缓释效应的缺陷与修正

操作风险保险(Operational Risk Insurance,ORI)是操作风险管理的重要举措,新Basel协议在首次将操作风险纳入其监管框架第一支柱的同时,对ORI也给予了特别关注。然而,由于没有合理考量风险缓释效应,新Basel框架在这方面的各种安排可能会引致一系列与其目标相冲突的陷阱,如不公平竞争问题、监管套利问题等。本文试图通过对ORI风险缓释效应的量化分析,在揭示这些问题的同时为最终修正这些缺陷提供一些思路,从而更好地实现Basel框架的宗旨,也为完善我国的操作风险管理实践提供参考。     

A Critique of Revised Basel II

This paper critiques the revised Basel II capital requirements for banks. To provide a framework for analysis, the XYZ theory of regulatory capital is formulated. Independent of the XYZ theory, we argue that the revised Basel II capital rule for credit risk is not a good approximation to the ideal rule. Based on this, and using the XYZ theory, we argue that: (1) the revised Basel II rules should not replace the existing approaches for determining minimal capital standards, but should be used in conjunction with them, and (2) that calibrating the capital rules to maintain aggregate market capital is a prudent procedure.     

Does individualistic culture impact operational risk?

Employing a sample of 2,957 operational‐risk events across 31 countries from 1990 to 2011, we find that financial institutions located in countries with higher individualism tend to have higher operational risk. This positive relation is achieved through the risk‐taking channel and the earnings‐management channel. In addition, the magnitude of operational losses is higher in more individualistic countries. The results suggest that individualism serves as an important informal institutional determinant of operational risk in an international context. Endogeneity tests and various robustness checks confirm our findings.     

Bank regulation and international financial stability: A case against the 2006 Basel framework for controlling tail risk in trading books

In attempting to promote international financial stability, the Basel Committee on Banking Supervision (2006) provided a framework that sought to control the amount of tail risk that large banks around the world would take in their trading books relative to their corresponding minimum capital requirements. However, many of these banks suffered significant trading losses during the recent financial crisis. Our paper examines whether the Basel framework allowed banks to take substantive tail risk in their trading books without a capital requirement penalty. We find that it allowed banks to do so and that its minimum capital requirements can be notably procyclical. Hence, focusing on the way the Basel framework sought to control the amount of tail risk in trading books relative to their corresponding minimum capital requirements, our paper supports the view that it was not properly designed to promote financial stability. We also discuss alternative regulatory frameworks that would potentially be more effective than the Basel framework in preventing banks from taking substantive tail risk in their trading books without a capital requirement penalty.     

A new multi-factor risk model to evaluate funding liquidity risk of banks

The present paper investigates funding liquidity risk of banks. We present a new statistical multi-factor risk model leading to three new funding liquidity risk metrics, thanks to liquidity gap's probability distribution analysis. We test our model on a large sample composed of 593 US banking companies, this allows us to identify some stylized facts regarding the evolution of liquidity risk and its relationship with the size of banking companies. Our main motivation is to develop ‘the contractual maturity mismatch’ monitoring tool proposed within the Basel III reform.     

Multivariate models for operational risk

Böcker and Klüppelberg [Risk Mag., 2005, December, 90–93] presented a simple approximation of OpVaR of a single operational risk cell. The present paper derives approximations of similar quality and simplicity for the multivariate problem. Our approach is based on the modelling of the dependence structure of different cells via the new concept of a Lévy copula.     

新巴塞尔资本协议与商业银行操作风险量化管理

由于<新巴塞尔资本协议>把风险区分为市场风险、信用风险和操作风险,同时把操作风险纳入到资本充足率的计算之中;使得金融界对它的关注显著提高,并对量化操作风险提出了迫切要求.值得注意的是,国际上一些大银行在量化和度量操作风险管理上已经积累了较为丰富的经验,并取得一定的成就.目前我国的金融机构缺乏风险意识,尤其是在操作风险方面基本没有什么量化操作风险的科学方法,不能正确反映所承受的风险,操作风险的管理水平亟待提高.面对加入WTO之后国际金融机构在国内市场上的激烈竞争,我国金融机构应广泛借鉴国外商业银行的成功经验,加强操作风险的量化管理和研究.     

Rollover risk and credit risk under time-varying margin

For a firm financed by a mixture of collateralized (short-term) debt and uncollateralized (long-term) debt, we show that fluctuations in margin requirements, reflecting funding liquidity shocks, lead to increasing the firm’s default risk and credit spreads. The severity with which a firm is hit by increasing margin requirements highly depends on both its financing structure and debt maturity structure. Our results imply that an additional premium should be added when evaluating debt in order to account for rollover risks, especially for short-matured bonds. In terms of policy implications, our results strongly indicate that regulators should intervene fast to curtail margins in crisis periods and maintain a reasonably low margin level in order to effectively prevent creditors’ run on debt.     

Approximation of aggregate and extremal losses within the very heavy tails framework

The loss distribution approach is one of the three advanced measurement approaches to the Pillar I modeling proposed by Basel II in 2001. In this paper, one possible approximation of the aggregate and maximum loss distribution in the extremely low frequency/high severity case is given, i.e. the case of infinite mean of the loss sizes and loss inter-arrival times. In this study, independent but not identically distributed losses are considered. The minimum loss amount is considered increasing over time. A Monte Carlo simulation algorithm is presented and several quantiles are estimated. The same approximation is used for modeling the maximum and aggregate worldwide economy losses caused by very rare and very extreme events such as 9/11, the Russian rouble crisis, and the U.S. subprime mortgage crisis. The model parameters are fit on a data sample of operational losses. The respective aggregate and extremal loss quantiles are calculated.     

Decomposing the VIX: Implications for the predictability of stock returns

The VIX index is not only a volatility index but also a polynomial combination of all possible higher moments in market return distribution under the risk-neutral measure. This paper formulates the VIX as a linear decomposition of four fundamentally different elements: the realized variance (RV), the variance risk premium (VRP), the realized tail (RT), and the tail risk premium (TRP), respectively. Using an innovative and nonparametric tail risk measure, we find that approximately one-third of the VIX's formation is attributed to the TRP. In addition to VRP, RT and TRP are crucial components for predicting future returns on equity portfolios.     

Perspectives on risk and governance

Improper understanding and inefficient management of risk coupled with gaps in governance framework are considered to be major factors behind the outbreak of the Global Financial Crisis. This article highlights the gaps in the risk management and governance framework which led to the crisis and delineates international initiatives in building robust governance systems. The article also analyses the impact of new regulations on the economic growth and bank profitability which is the subject matter of intense debate currently and underscores the necessity of adopting Basel III by EMDEs. Highlighting the Reserve Bank of India's policy initiatives in mitigating the impact of global crisis, the paper discusses some contemporary issues in Basel III implementation in India.