Students of the dark art of bank capital adequacy measurement were excited this week by the release of some proposed revisions to APRA’s “Prudential Standard APS 111 Capital Adequacy” (APS 111); i.e. the one which sets out the detailed criteria for measuring an ADI’s Regulatory Capital.
Is anyone still reading? Possibly not, but there is something I think worth noting here if you want to understand what may be happening with Australian bank capital. This is of course only a consultation at this stage but I would be very surprised if the key proposal discussed below is not adopted.
The Short Version
The consultation paper has a number of changes but the one that I want to focus on is the proposal to apply stricter constraints on the amount of equity an ADI invests in banking and insurance subsidiaries.
In order to understand how this impacts the banks, I have to throw in two more pieces of Australian bank capital jargon, specifically Level 1 and Level 2 capital.
- Level 1 is the ADI itself on a stand alone basis (note that is a simplification but close enough to the truth for the purposes of this post).
- Level 2 is defined in the consultation paper as “The consolidation of the ADI and all its subsidiaries other than non-consolidated subsidiaries; or if the ADI is a subsidiary of a non-operating holding company (NOHC), the consolidation of the immediate parent NOHC and all the immediate parent NOHC’s subsidiaries (including any ADIs and their subsidiaries) other than non-consolidated subsidiaries.”
You can be forgiven for not being familiar with this distinction but the capital ratios typically quoted in any discussion of Australian bank capital strength are the Level 2 measures. The Unquestionably Strong benchmark that dominates the discussion is a Level 2 measure. The changes proposed in this consultation however operate at the Level 1 measurement (the ones that virtually no one currently pays any attention to) and not the Level 2 headline rate.
This has the potential to impact the “Unquestionably Strong” benchmark and I don’t recollect seeing this covered in the consultation paper or any public commentary on the proposal that I have seen to date.
APRA has been quite open about the extent to which these changes are a response to the RBNZ proposal to substantially increase equity requirements for NZ banks.
“This review was prompted in part by recent proposals by the Reserve Bank of New Zealand (RBNZ) to materially increase capital requirements in New Zealand. The RBNZ’s proposals and APRA’s processes are a natural by-product of both regulators working to protect their respective communities from the costs of financial instability and the regulators continue to support each other as these reforms are developed.”
The changes have however been calibrated to maintain the status quo based on the amounts of capital the Australian majors currently have invested in their NZ subsidiaries.
“APRA has calibrated the proposed capital requirements so they are broadly consistent with … the current capital position of the four major Australian banks, in respect of these exposures (i.e. preserving most of the existing capital uplift).”
It follows that any material increase in the capital the majors are required to invest in their NZ subsidiaries (in response to the RBNZ’s proposed requirement) will in turn require that they have to hold commensurately more common equity on a 1:1 basis in the Level 1 ADI to maintain the existing Level 1 capital ratios.
So far as I can see, the Level 2 measure does not require that this extra capital invested in banking subsidiaries be subject to the increased CET1 deductions applied at Level 1. It follows that the Level 2 CET1 ratio will increase but the extent to which a creditor benefits from that added strength will depend on which part of the banking group they sit.
I am not saying this a problem in itself. The RBNZ has the authority to set the capital requirements it deems necessary, Australian bank shareholders can make their own commercial decisions on whether the diluted return on equity meets their requirements and APRA has to respond to protect the interests of the Australian banking system.
I am saying that measuring relative capital adequacy is getting more complicated so you need to pay attention to the detail if this matters to you. In particular, I am drawing attention to the potential for the Level 2 CET1 ratios of the Australian majors to increase in ways that the existing “Unquestionably Strong” benchmark is not calibrated to. I don’t think this matters much for Australian bank depositors who have a very safe super senior position in the Australian loss hierarchy. It probably does matter for creditors who are closer to the sharp end of the loss hierarchy including senior and subordinated bondholders.
To date, the Level 2 capital adequacy ratios have been sufficient to provide a measure of relative capital strength; a higher CET1 ratio equals greater capital strength and that was probably all you needed to know. Going forward, I think you will need to pay closer attention to what is happening at the Level 1 measure to gain a more complete understanding of relative capital strength. The Level 2 measure by itself may not tell you the full story.
The detail
As a rule, APRA’s general capital treatment of equity exposures is to require that they be deducted from CET1 Capital in order to avoid double counting of capital. The existing rules (APS 111) however provides a long-standing variation to this general rule when measuring Level 1 capital adequacy. This variation allows an ADI at Level 1 to risk weight (after first deducting any intangibles component) its equity investments in banking and insurance subsidiaries. The risk weight is 300 percent if the subsidiary is listed or 400 per cent if it is unlisted.
APRA recognises that this improves the L1 ratios by around 100bp versus what would be the case if a full CET1 deduction were applied but is comfortable with that outcome based on current exposure levels.
The RBNZ’s (near certain) move towards higher CET1 requirements however threatens to undermine this status quo and potentially see a greater share of the overall pool of equity in the group migrate from Australia to NZ. APRA recognises of course that the RBNZ can do whatever it deems best for NZ depositors but APRA equally has to ensure that the NZ benefits do not come at the expense of Australian depositors (and other creditors).
To address this issue, APRA is proposing to limit the extent to which an ADI may use debt to fund investments in banking and insurance subsidiaries.
- ADIs, at Level 1, will be required to deduct these equity investments from CET1 Capital, but only to the extent the investment in the subsidiary is in excess of 10 per cent of CET1 Capital.
- An ADI may risk weight the investment, after deduction of any intangibles component, at 250 per cent to the extent the investment is below this 10 per cent threshold.
- The amount of the exposure that is risk weighted would be included as part of the related party limits detailed in the recently finalised APS 222.
As APRA is more concerned about large concentrated exposures, it is proposing to limit the amount of the exposure to an individual subsidiary that can be leveraged to 10 per cent of an ADI’s CET1 Capital. This means capital requirements are increasing for large concentrated exposures, as amounts over the 10 per cent threshold would be required to be met dollar-for-dollar by the ADI parent company.
Summing up
What APRA is proposing to do makes sense to me. We can debate the necessity for the RBNZ to insist on virtually 100% CET1 capital (for the record, I continue to believe that a mix of CET1 and contingent convertible debt is likely to be a more effective source of market discipline). However, once it became clear that the RBNZ was committed to its revised capital requirements, APRA was I think left with no choice but to respond.
What will be interesting from here is to see whether investments of CET1 in NZ banking subsidiaries increase in response to the RBNZ requirement or whether the Australian majors choose to reduce the size of their NZ operations.
If the former (i.e. the majors are required to increase the capital committed to NZ subsidiaries) then we need to keep an eye on how this impacts the Level 2 capital ratios and what happens to the “Unquestionably Strong” CET1 benchmark that currently anchors the capital the Australian majors maintain.
This is a pretty technical area of bank capital so it is possible I am missing something; if so please let me know what it is. Otherwise keep an eye on how the capital adequacy targets of the Australian majors respond to these developments.
Tony (From the Outside)
From the outside 
Actually this was a highly politicized issue in Europe, which led to the delay of the implementation of Basel III by a year. It also led to heated debates between France and Italy and Sweden, UK, and the U.S. Eventually France/Italy won with no deduction and a 250% risk weight – the percentage now copied by APRA.
The proposed deduction of equity at Level 1, instead of the 400% risk weight, creates an incentive to upstream excess reserves (or, if possible, assets) to the parent. Though nothing really happens at Level 2, at Level 1 the subsidiary will become a drag, as its growth is more or less constrained by the amount of equity of the parent.
Now, there is unlikely a problem when the parent company is large relative to the sub (CBA). But if the sub is large, as is the case with ANZ, the deduction may affect the solvency position of the parent at Level 1.
Agreed that the rules are carefully calibrated, mindful of the current situation, but going forward this may be a bit of a problem.
Regarding international level playing field, the NZ subs are probably worse off under APRA rules than they would be under European rules, as these have no deduction. Let’s see how this plays out.
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Do you know if there was any science/analysis behind the 250% RW?
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It’s from Basel III, and on par with EU CRR, Art 49 and I think Art 48 on the threshold deductions
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But is there any analysis on why 250% as opposed to some other number?
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It was 400, which was a the sum of two risk weights (370+30?). The 250 … gee, perhaps an Italian job, a mystery to me.
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Martien, just picking up on your point about the extent to which the proposed deduction creates an incentive to upstream excess reserves.
I think the first issue here is that none of the Australian majors will currently have excess capital in their NZ subsidiaries given the increased capital requirements implemented to date and the likelihood that the RBNZ proposal for extra capital seems almost certain to be passed into regulation.
That said, the marginal dollar of capital in NZ subsidiaries is likely to be in the form of retained earnings. That is already not counted in the Level 1 capital of the parent so the proposed change in the APRA measurement seems to make no difference.
However, under the existing rules it is possible to pay up a dividend to the parent and then have the capital reinvested back in the subsidiary in the form of paid up capital. Nothing changes in substance under this arrangement but the Level 1 capital of the parent improves because they get the benefit of 100% of the upstreamed capital in the Level 1 numerator for the cost of a 400% RW on the capital reinvested; i.e. the Level 1 capital ratio of the parent improves. This is a regulatory arbitrage that would have become much more significant as the size of the capital invested in the NZ subsidiaries increases relative to the parent. The APS 222 large exposure limits would have placed some constraints on the arbitrage but not eliminated it.
The changes that APRA proposes for the Level 1 measure close down this arbitrage. The main point of my post was to draw attention to the potential for the combined effect of all these changes (RBNZ higher capital plus APRA changes to Level 1 measure) to impact the Level 2 measure in ways that may require the existing Unquestionably Strong benchmark to be revisited and possibly recalibrated.
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