Category: Regulatory Capital

Regulatory Capital

Bank Constraints: 3Q08

This updates a review of Canadian bank constraints for 2Q08.

Big-6 Bank Constraint Summary
3Q08
  Note RY BNS BMO TD CM NA
Equity Capital A 17,892 16,310 13,609 13,563 8,695 3,930
Tier 1 Cap B 24,150 22,075 18,047 17,491 11,626 5,534
Tier 2 Cap C 5,578 3,969 4,353 7,211 5,461 2,196
Total
Capital
D 29,728 26,044 22,400 24,702 17,087 7,730
Tier 1 Ratio E 9.5% 9.8% 9.9% 9.5% 9.8% 10.0%
Total Ratio F 11.7% 11.5% 12.3% 13.4% 14.4% 13.9%
Assets to
Capital
Multiple
G 19.4 17.8 15.9 17.9 17.7 15.7
RWA to
T1R = 7%
H +36% +40% +41% +36% +40% +43%
RWA to
TotR = 10%
I +17% +15% +23% +34% +44% +39%
Assets to
ACM = 20
J +3% +12% +26% +12% +13% +27%
Assets to
ACM = 23
K +19% +29% +45% +28% +30% +46%
A : See Bank Capitalization Summary : 3Q08
B, C, D, E, F: From Supplementary Packages

G: See source notes from Note A reference; some are my estimates
H: Percentage increase in Risk Weighted Assets that results in a Tier 1 Ratio of 7% [OSFI’s “Well Capitalized” benchmark]; = (E / 0.07 – 1) %
I: Percentage Increase in Risk Weighted Assets that results in a Total Capital Ratio of 10% [OSFI’s “Well Capitalized” Benchmark]; = (F / 0.10 -1) %
J: Percentage Increase in Assets that results in an Assets-to-Capital Multiple of 20x; = ((20 / G) – 1) %
K: Percentage Increase in Assets that results in an Assets-to-Capital Multiple of 23x; = ((23 / G) – 1) %
The limiting constraint is bolded.

In determining the limiting factor, it has been assumed that 23x is the actual limit for the Assets to Capital multiple; OSFI has stated that 23x is OK as long as they meet certain conditions and otherwise apply for permission. Given that OSFI maintains a veil of secrecy over the issue, it has been assumed that the 20x multiple is simply stated for decorative purposes.

It should also be noted that the calculation of the ACM has been recently revised by OSFI, with what I must say is rather weak justification.

Regulatory Capital

Bank Capitalization Summary: 3Q08

The Big-Six banks have now all released their 2Q08 financials. The results may now be summarized, with the links pointing to the PrefBlog posts reporting on the quarterly reports:

Big-6 Capitalization Summary
3Q08
  Note RY BNS BMO TD CM NA
Equity Capital A 17,892 16,310 13,609 13,563 8,695 3,930
Preferreds Outstanding B 2,552 2,560 1,996 2,175 2,931 774
Issuance Capacity C 1,400 1,671 1,386 1,877 790 78
Equity / Risk Weighted Assets D 7.04% 7.22% 7.47% 7.34% 7.33% 7.07%
Tier 1 Ratio E 9.5% 9.8% 9.9% 9.5% 9.8% 10.0%
Total Capital Ratio F 11.7% 11.5% 12.3% 13.4% 14.4% 13.9%
Assets to Capital Multiple G 19.4x 17.8x 15.9x 17.9x 17.7x 15.7x
A is a measure of the size of the bank
B is … um … how many preferreds. Are outstanding
C is how many more (million CAD) they could issue if they so chose
D is a measure of the safety of the preferreds – the first loss buffer, expressed as a percentage of their Risk-Weighted Assets. Higher is better. It may be increased by issuing common (or making some money and keeping it); preferred issuance will not change it.
E is the number that OSFI and fixed-income investors will be watching. Higher is better, and it may be increased by issuing preferreds.
F is less sexy than E, but still important.
G is even less sexy than F, but PAY ATTENTION!
Regulatory Capital

NA Capitalization: 3Q08

NA has released its Third Quarter 2008 Report and Supplementary Package, so it’s time to recalculate how much room they have to issue new preferred shares – assuming they want to!

Step One is to analyze their Tier 1 Capital, reproducing the prior format:

NA Capital Structure
October, 2007
& July, 2008
  4Q07 3Q08
Total Tier 1 Capital 4,442 5,534
Common Shareholders’ Equity 95.0% 84.3%
Preferred Shares 9.0% 14.0%
Innovative Tier 1 Capital Instruments 11.4% 15.0%
Non-Controlling Interests in Subsidiaries 0.4% 0.5%
Goodwill -15.8% -13.0%
Miscellaneous NA -0.7%
‘Miscellaneous’ includes ‘short positions of own shares’ and ‘securitization related deductions’

Next, the issuance capacity (from Part 3 of the introductory series):

NA
Tier 1 Issuance Capacity
October 2007
& July 2008
  4Q07 3Q08
Equity Capital (A) 3,534 3,930
Non-Equity Tier 1 Limit (B=A/3), 4Q07
(B=0.428*A), 2Q08
1,178 1,682
Innovative Tier 1 Capital (C) 508 830
Preferred Limit (D=B-C) 670 852
Preferred Actual (E) 400 774
New Issuance Capacity (F=D-E) 270 78
Items A, C & E are taken from the table
“Risk Adjusted Capital Ratiosl”
of the supplementary information;
Note that Item A includes everything except preferred shares and innovative capital instruments


Item B is as per OSFI Guidelines; the limit was recently increased.
Items D & F are my calculations

and the all important Risk-Weighted Asset Ratios!

NA
Risk-Weighted Asset Ratios
October 2007
& July 2008
  Note 2007 3Q08
Equity Capital A 3,534 3,930
Risk-Weighted Assets B 49,336 55,557
Equity/RWA C=A/B 7.16% 7.07%
Tier 1 Ratio D 9.0% 10.0%
Capital Ratio E 12.4% 13.9%
Assets to Capital Multiple F 18.6x 15.7x
A is taken from the table “Issuance Capacity”, above
B, D & E are taken from RY’s Supplementary Report
C is my calculation
F is taken from the OSFI site for 4Q07. The 2Q08 figure is approximated by subtracting goodwill of 707 from total assets of 123,608 to obtain adjusted assets of 122,901 and dividing by 7,353 total capital. The result of 16.7x was in agreement with the figure ultimately reported by OSFI. The 3Q08 figure subtracts goodwill of 722 from total assets of 121,931 [Page 1 of Sup] to obtain adjusted assets of 121,209 and dividing by 7,730 total capital.

National Bank does not disclose its Assets-to-Capital Multiple. Their Report to Shareholders simply states (Note 4):

In addition to regulatory capital ratios, banks are expected to meet an assets-to-capital multiple test. The assets-to-capital multiple is calculated by dividing a bank’s total assets, including specified off-balance sheet items, by its total capital. Under this test, total assets should not be greater than 23 times the total capital. The Bank met the assets-to-capital multiple test in the third quarter of 2008.

Well … at least they’re delevering! It is also interesting to note that they have – basically – maxed out on their expanded allowance of non-equity Tier 1 Capital.

Regulatory Capital

TD Capitalization: 3Q08

TD has released its Third Quarter 2008 Report and Supplementary Package, so it’s time to recalculate how much room they have to issue new preferred shares – assuming they want to!

Step One is to analyze their Tier 1 Capital, reproducing the prior format:

TD Capital Structure
October, 2007
& July, 2008
  4Q07 3Q08
Total Tier 1 Capital 15,645 17,491
Common Shareholders’ Equity 131.5% 164.3%
Preferred Shares 6.2% 12.4%
Innovative Tier 1 Capital Instruments 11.1% 10.0%
Non-Controlling Interests in Subsidiaries 0.1% 0.1%
Goodwill -49.0% -84.4%
Miscellaneous NA -2.5%
‘Common Shareholders Equity’ includes ‘Common Shares’, ‘Contributed Surplus’, ‘Retained Earnings’ and ‘FX net of Hedging’
‘Miscellaneous’ includes ‘Securitization Allowance’, ‘ALLL/EL shortfall’ and ‘Other’.

Next, the issuance capacity (from Part 3 of the introductory series):

TD
Tier 1 Issuance Capacity
October 2007
& July 2008
  4Q07 3Q08
Equity Capital (A) 12,931 13,563
Non-Equity Tier 1 Limit (B=A/3), 4Q07
(B=0.428*A), 2Q08
4,310 5,805
Innovative Tier 1 Capital (C) 1,740 1,753
Preferred Limit (D=B-C) 2,570 4,052
Preferred Actual (E) 974 2,175
New Issuance Capacity (F=D-E) 1,346 1,877
Items A, C & E are taken from the table
“Regulatory Capital”
of the supplementary information;
Note that Item A includes everything except preferred shares and innovative instruments


Item B is as per OSFI Guidelines; the limit was recently increased.
Items D & F are my calculations

and the all important Risk-Weighted Asset Ratios!

TD
Risk-Weighted Asset Ratios
October 2007
& July 2008
  Note 2007 3Q08
Equity Capital A 12,931 13,563
Risk-Weighted Assets B 152,519 184,674
Equity/RWA C=A/B 8.48% 7.34%
Tier 1 Ratio D 10.3% 9.5%
Capital Ratio E 13.0% 13.4%
Assets to Capital Multiple F 19.7x 17.9x
A is taken from the table “Issuance Capacity”, above
B, D & E are taken from TD’s Supplementary Report
C is my calculation.
F is from Note 9 of the quarterly report

The reported Assets-to-capital multiple reflects that goodwill is deducted from total capital (the denominator) AND FROM TOTAL ASSETS (the numerator); given TD’s huge goodwill, this makes rather a difference! It is noteworthy that they have delevered so much in the past year.

The average credit risk-weight of the assets has increased to 26.6% in 3Q08 from 24.6% in 1Q08, largely due to Corporate lending, which during this period has increased to 26.0% from 24.8% of total exposure and to 46.2% from 40.6% of risk-weighted exposure.

Regulatory Capital

RY Capitalization: 3Q08

RY has released its Third Quarter 2008 Report and Supplementary Package, so it’s time to recalculate how much room they have to issue new preferred shares – assuming they want to!

Step One is to analyze their Tier 1 Capital, reproducing the prior format:

RY Capital Structure
October, 2007
& July, 2008
  4Q07 3Q08
Total Tier 1 Capital 23,383 24,150
Common Shareholders’ Equity 95.2% 111.6%
Preferred Shares 10.0% 10.6%
Innovative Tier 1 Capital Instruments 14.9% 15.3%
Non-Controlling Interests in Subsidiaries 0.1% 1.5%
Goodwill -20.3% -36.7%
Miscellaneous NA -2.3%
‘Miscellaneous’ includes ‘Substantial Investments’, ‘Securitization-related deductions’, ‘Expected loss in excess of allowance’ and ‘Other’

Next, the issuance capacity (from Part 3 of the introductory series):

RY
Tier 1 Issuance Capacity
October 2007
& July 2008
  4Q07 3Q08
Equity Capital (A) 17,545 17,892
Non-Equity Tier 1 Limit (B=A/3), 4Q07
(B=0.428*A), 2Q08
5,848 7,658
Innovative Tier 1 Capital (C) 3,494 3,706
Preferred Limit (D=B-C) 2,354 3,952
Preferred Actual (E) 2,344 2,552
New Issuance Capacity (F=D-E) 10 1,400
Items A, C & E are taken from the table
“Regulatory Capital”
of the supplementary information;
Note that Item A includes everything except preferred shares and innovative capital instruments


Item B is as per OSFI Guidelines; the limit was recently increased.
Items D & F are my calculations

and the all important Risk-Weighted Asset Ratios!

RY
Risk-Weighted Asset Ratios
October 2007
& July 2008
  Note 2007 3Q08
Equity Capital A 17,545 17,892
Risk-Weighted Assets B 247,635 254,189
Equity/RWA C=A/B 7.09% 7.04%
Tier 1 Ratio D 9.4% 9.5%
Capital Ratio E 11.5% 11.7%
Assets to Capital Multiple F 19.8x 19.4x
A is taken from the table “Issuance Capacity”, above
B, D, E & F are taken from RY’s Supplementary Report
C is my calculation.

It’s good to see that RY has reduced its Assets-to-Capital multiple to within normal bounds (this has not always been the case) – even if we follow international practice and retain the EL/ALLL deductions, the ratio is 19.8x.

We see from the supplementary data that the average credit risk weight of their assets has increased from 23% in 2Q08 to 25% in 3Q08, which ties in with the minimal change in their capital ratios. This, in turn, is due to a decline in their “Trading-Related” exposure, in which “Repo-Style Transactions”, with a risk-weight of 2%, has declined to total exposure of $151-billion from $168-billion.

Regulatory Capital

CM Capitalization: 3Q08

CIBC (Stock symbol CM … I can never quite decide how to present it!) has released its Third Quarter 2008 Report and Supplementary Package, so it’s time to recalculate how much room they have to issue new preferred shares – assuming they want to!

Step One is to analyze their Tier 1 Capital, reproducing the prior format:

CM Capital Structure
October, 2007
& July, 2008
  4Q07 3Q08
Total Tier 1 Capital 12,379 11,626
Common Shareholders’ Equity 90.1% 92.7%
Preferred Shares 23.7% 25.2%
Innovative Tier 1 Capital Instruments 0% 0%
Non-Controlling Interests in Subsidiaries 1.1% 1.3%
Goodwill -14.9% -16.6%
Misc. NA -2.6%
‘Misc.’ is comprised of Basel II adjustments to Tier 1 Equity

Next, the issuance capacity (from Part 3 of the introductory series):

CM
Tier 1 Issuance Capacity
October 2007
& July 2008
  4Q07 3Q08
Equity Capital (A) 9,448 8,695
Non-Equity Tier 1 Limit (B=A/3), 4Q07
(B=0.428*A), 3Q08
3,149 3,721
Innovative Tier 1 Capital (C) 0 0
Preferred Limit (D=B-C) 3,149 3,721
Preferred Actual (E) 2,931 2,931
New Issuance Capacity (F=D-E) 218 790
Items A, C & E are taken from the table
“Regulatory Capital”
of the supplementary information;
Note that Item A includes Goodwill, FX losses, non-controlling interest, Gains on sale of securitizations and 50/50 deductions


Item B is as per OSFI Guidelines; the limit was recently increased.
Items D & F are my calculations

and the all important Risk-Weighted Asset Ratios!

CM
Risk-Weighted Asset Ratios
October 2007
& July 2008
  Note 4Q07 3Q08
Equity Capital A 9,448 8,695
Risk-Weighted Assets B 127,424 118,500
Equity/RWA C=A/B 7.41% 7.33%
Tier 1 Ratio D 9.7% 9.8%
Capital Ratio E 13.9% 14.4%
Assets to Capital Multiple F 19.0x 17.7x
A is taken from the table “Issuance Capacity”, above
B, D & E are taken from CM’s Supplementary Report
C is my calculation.
F is from Page 26 of the quarterly report
Note that CM reports “Common Equity to risk-weighted assets” of 9.1%. They do not include “non-controlling interests”, “goodwill” and the Basel II adjustments in the numerator; I do.

Again, the 4Q07 figures are not directly comparable with the 3Q08 figures due to the change from Basel I to Basel II.

On a Basel I basis, the Tier I and Total Capital ratios got a big boost in the first quarter with the capital raise, but have since declined; the Tier 1 ratio is now the lowest it has been in the last two years, but the total capital ratio has improved since the second quarter. The improvement in the total capital ratio over the quarter may be attributed to issues of sub-debt.

Further, on a Basel I basis, Total Risk Weighted Assets have increased somewhat since 4Q07, basically due to an increase of $5-billion in the risk-weight of “Other Loans”. It is not entirely clear what these other loans are; the balance sheet amounts for Personal Loans and Credit Card Loans are up $2.2-billion and $1.4-billion, respectively, but that doesn’t account for the increase. It may possibly be the risk weighting that has changed rather than the unadjusted balance sheet value.

Regulatory Capital

BNS Capitalization: 3Q08

BNS has released its Third Quarter 2008 Report and Supplementary Package, so it’s time to recalculate how much room they have to issue new preferred shares – assuming they want to!

Step One is to analyze their Tier 1 Capital, reproducing the prior format:

BNS Capital Structure
October, 2007
& July, 2008
  4Q07 3Q08
Total Tier 1 Capital 20,225 22,075
Common Shareholders’ Equity 81.5% 85.9%
Preferred Shares 8.1% 11.6%
Innovative Tier 1 Capital Instruments 13.6% 12.5%
Non-Controlling Interests in Subsidiaries 2.5% 2.1%
Goodwill -5.6% -9.7%
Miscellaneous NA -2.3%

Next, the issuance capacity (from Part 3 of the introductory series):

BNS
Tier 1 Issuance Capacity
October 2007
& July 2008
  4Q07 3Q08
Equity Capital (A) 15,840 16,310
Non-Equity Tier 1 Limit (B=A/3), 4Q07
(B=0.428*A), 2Q08
5,280 6,981
Innovative Tier 1 Capital (C) 2,750 2,750
Preferred Limit (D=B-C) 2,530 4,231
Preferred Actual (E) 1,635 2,560
New Issuance Capacity (F=D-E) 895 1,671
Items A, C & E are taken from the table
“Regulatory Capital”
of the supplementary information;
Note that Item A includes Goodwill, FX losses, “Other Capital Deductions” and non-controlling interest


Item B is as per OSFI Guidelines; the limit was recently increased.
Items D & F are my calculations

and the all important Risk-Weighted Asset Ratios!

BNS
Risk-Weighted Asset Ratios
October 2007
& July 2008
  Note 2007 3Q08
Equity Capital A 15,840 16,310
Risk-Weighted Assets B 218,300 225,800
Equity/RWA C=A/B 7.26% 7.22%
Tier 1 Ratio D 9.3% 9.8%
Capital Ratio E 10.5% 11.5%
Assets to Capital Multiple F 18.22x 17.75x
A is taken from the table “Issuance Capacity”, above
B, D & E are taken from BNS’s Supplementary Report
C is my calculation.
F is from OSFI (4Q07) and BNS’s Supplementary Report (3Q08) of total assets ($462.4-billion) divided by total capital ($26.044-billion)
(see below)

The calculations for the Assets-to-Capital multiple are not comparable; the OSFI figure will include an allowance for off-balance-sheet exposure. It should be noted that, according to the Supplementary Report, The “Tangible Common Equity” ratio, calculated according to Basel I, has declined to 6.5% in 3Q08 from 7.2% in 4Q07.

The Basel I “Tier 1” and “Total Capital” ratios also show a declining trend for the year to date. As has been noted before, Scotia does not adequately disclose its “Expected Losses” under Basel II, as distinct from its “General Allowances”.

It is apparent from the Quarterly Trend in the Basel I data that Scotia has been bulking up on its Risk Weighted Assets big-time, largely through “Loans and Acceptances” (which includes Securities Purchased under Resale Agreements”. This has been financed largely through deposits. To some extent, this reflects Scotia’s acquisition of Banco del Desarrollo in 2Q08:

The Bank completed the acquisition of Chile’s Banco del Desarrollo on November 26, 2007, through the acquisition of 99.5 per cent of the outstanding shares for $1.0 billion Canadian dollar equivalent (CDE). Total assets at acquisition were approximately CDE $5.6 billion, mainly comprised of loans. The Bank will combine the operations of Banco del Desarrollo with its existing Scotiabank Sud Americano banking operations. Based on acquisition date fair values, approximately CDE $797 million has been allocated to the estimated value of goodwill acquired. The purchase price allocation may be refined as the Bank completes its valuation of the assets acquired and liabilities assumed.

According to the 3Q08 Report:

The Bank’s total assets at July 31, 2008, were $462 billion, up $50 billion or 12% from October 31, 2007, including a $16 billion positive impact from foreign currency translation and the acquisition of Banco del Desarrollo. Growth was widespread across most asset categories, including retail, commercial and corporate lending. Compared to the prior quarter, assets grew by $9 billion.

The Bank’s loan portfolio grew $45 billion or 20% from October 31, 2007, including $7 billion from foreign currency translation. On the retail lending side, domestic residential mortgage growth was $15 billion, before securitization of $3 billion. The International acquisition of Banco del Desarrollo in Chile contributed $1 billion to the increase in mortgages. Personal loans were up $7 billion, with all regions experiencing positive growth.

Business and government loans increased $26 billion from October 31, 2007, or $21 billion excluding the impact of foreign currency translation. Loans in Scotia Capital were up $11 billion on the corporate lending side as well as to support trading operations. In International Banking,
business and government loans increased $13 billion. The acquisition of Banco del Desarrollo contributed $3 billion, and loans in Asia and the Caribbean grew $5 billion and $2 billion, respectively.

Update: Right on cue, Scotia announced a new issue of Tier 1-eligible preferreds after releasing the results; this will help their Tier 1 and Total Capital ratios.

Regulatory Capital

BMO Capitalization: 3Q08

BMO has released its Third Quarter 2008 Report and Supplementary Package, so it’s time to recalculate how much room they have to issue new preferred shares – assuming they want to, in this environment!

Step One is to analyze their Tier 1 Capital, reproducing the prior format:

BMO Capital Structure
October, 2007
& July, 2008
  4Q07 3Q08
Total Tier 1 Capital 16,994 18,047
Common Shareholders’ Equity 83.8% 83.8%
Preferred Shares 8.5% 11.1%
Innovative Tier 1 Capital Instruments 14.3% 13.5%
Non-Controlling Interests in Subsidiaries 0.2% 0.2%
Goodwill -6.7% -8.0%
Miscellaneous NA -0.5%

Next, the issuance capacity (from Part 3 of the introductory series):

BMO
Tier 1 Issuance Capacity
October 2007
& July 2008
  4Q07 3Q08
Equity Capital (A) 13,126 13,609
Non-Equity Tier 1 Limit (B=A/3), 4Q07
(B=0.428*A), 2Q08
4,375 5,824
Innovative Tier 1 Capital (C) 2,422 2,442
Preferred Limit (D=B-C) 1,953 3,382
Preferred Actual (E) 1,446 1,996
New Issuance Capacity (F=D-E) 507 1,386
Items A, C & E are taken from the table
“Capital and Risk Weighted Assets”
of the supplementary information;
Note that Item A includes Goodwill and non-controlling interest


Item B is as per OSFI Guidelines; the limit was recently increased.
Items D & F are my calculations

and the all important Risk-Weighted Asset Ratios!

BMO
Risk-Weighted Asset Ratios
October 2007
& July 2008
  Note 2007 3Q08
Equity Capital A 13,126 13,609
Risk-Weighted Assets B 178,687 182,258
Equity/RWA C=A/B 7.35% 7.47%
Tier 1 Ratio D 9.51% 9.90%
Capital Ratio E 11.74% 12.29%
Assets to Capital Multiple F 17.17x 15.87x
A is taken from the table “Issuance Capacity”, above
B, D & E are taken from BMO’s Supplementary Report
C is my calculation.
F is from OSFI (4Q07) and BMO’s Supplementary Report (2Q08)

BMO’s supplementary data discloses a “Tangible common equity-to-risk-weighted-assets” figure that sounds like it should be equal to my “Equity/RWA” in the table. Their figure is 7.44%; it is not immediately clear to me how this figure is calculated.

Of interest is the improvement in their capital ratios, including the Assets-to-Capital multiple. It appears that their earnings are being used to displace borrowings, rather than being levered up.

I note as well that there is no adjustment to capital for “Expected loss in excess of allowance”, indicating that their ALLL is again equal to the EL which is indicative of conservative approach to assessing credit write-offs.

Primers

Basel II in the United States : CRS Report RL33278

This background report has been written by the Congressional Research Service.

Good background, an excellent primer. Of particular interest was:

The third pillar of the Basel II framework is public disclosure. Pillar three is a set of public information disclosures that a bank must make about itself. These disclosures are to make it easier for creditors and investors in financial markets to assess a bank’s risk posture more accurately and adjust borrowing and capital costs accordingly. The idea behind this requirement is to bring market discipline to bear to give bank management a cost incentive to adopt strong safety and soundness practices. The disclosure requirements will also make it easier for depositors, investors, and regulators to make comparisons across banking institutions. This knowledge, in turn, is expected to affect the willingness of investors to invest in banks and their related businesses. Without pillar three, financial institutions could become more opaque and more difficult to understand as the institutions develop new products and complex risk-hedging strategies that are difficult to evaluate. It could also make it more difficult to understand the risk profile of the firm creating and selling these products as well as the firms buying and using them.

Stirring principals certainly; I’m not sure how well it works in practice, but I do find American disclosure far superior to Canadian disclosure. OSFI, for instance, will not reveal why they have given Royal Bank an increased Assets to Capital multiple cap for the last five-odd years.

Regulatory Capital

S&P Recognizes Implicit MMF Guarantees When Assessing Banks

I hadn’t been aware of this when I wrote my opinion piece A Collateral Proposal

The Federal Reserve discloses a “memo to file” on a meeting June 8, 2004, with S&P about Basel II:

Standard & Poor’s proprietary capital model is the primary driver for assessing capital, but regulatory capital is also taken into consideration. Standard & Poor’s already incorporates an operational risk capital charge into its capital assessment of trust and custody banks by deducting a certain basis point amount from capital for the amount of assets under custody (AUC) and assets under management (AUM).

With regard to assets under management, Standard & Poor’s methodology requires banks to hold more capital for money market funds than for equities and fixed income pooled funds, as it is the investor who takes the market risk for the latter two asset classes. The bank, on the other hand, provides an implicit guarantee with money market funds. This is because a bank will step in and support its sponsored money market funds if they are in danger of “breaking the buck”.

Assiduous readers will remember that the proposal to incorporate the implicit credit guarantee banks give to their branded Money Market Funds has been supported in principal by Ian de Verteuil of BMO-CM – although his proposal differs somewhat in specifics.