CAR Mean Capital Adequacy Ratio

Capital Adequacy Ratio is both a calculation and a standard. The calculation is:
(Tier 1 Capital + Tier 2 Capital) ÷ Risk Weighted Assets

The standard is 10%.

Accounting becomes very important in the final steps of this calculation because of the classification defined by Basel III.

  • Tier 1 Capital are common stock, retained earnings and non-redeemable preferred stock.
  • Tier 2 Capital are subordinated debt, hybrid instruments, revaluation reserves and undisclosed reserves.
Photoshopped image of Alan Greenspan, former Chairman of the Federal Reserve Board

Essentially, Tier 1 are what most people think of as shares of a corporation and what the bank has earned and retained over the years. Retaining the earnings rather than using it to provide dividends is a way to increase the assets of the organization, build a reserve to be deployed when needed. Tier 2 are preferred equity and long term debt the bank borrows, leverage.

The Capital is there to fund the business when business takes a sudden downturn. The 10% standard means that business can suddenly take a 10% dive and the bank will still be solvent. When CAR is 0%, the bank must start selling its assets to pay for its debts. One way to reduce the likelihood of avoiding this level is to be able to deploy borrowed funds that are due later to pay for the ones that are due currently. While this doesn’t mean the bank is healthy, but this gives the bank time to rebuild its reserves.


About the Author: Marcus Maltempo is a compliance professional with more than a decade of experience helping banks, law firms and clients manage investigations and regulatory responses.


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CCAR Means Comprehensive Capital Analysis and Review

The Comprehensive Capital Analysis and Review (CCAR) is an annual exercise by the Federal Reserve to assess whether the largest bank holding companies operating in the United States have sufficient capital to continue operations throughout times of economic and financial stress and that they have robust, forward-looking capital-planning processes that account for their unique risks.
As part of this exercise, the Federal Reserve evaluates institutions’ capital adequacy, internal capital adequacy assessment processes, and their individual plans to make capital distributions, such as dividend payments or stock repurchases. – United States Federal Reserve

Regions covered by the Federal Reserve Banks
Regions covered by the Federal Reserve Banks

There is no one who has had a career is CCAR because it was only created in 2010 and first performed in 2011. Previous to this exercise, a similar assessment was done under the name of Supervisory Capital Assessment Program (SCAP). It was performed once in 2009. SCAP was inspiration for CCAR, which is not performed yearly in the first quarter. The Federal reserve are in constant discussions about the test during the process and provides a previous of the assessment in March to the banks that are involved in the assessment. There are 31 banks that must participate in CCAR. Participation primarily has to do with size and market reach because CCAR is testing the financial system’s ability avoid a bank crisis.


About the Author: Marcus Maltempo is a compliance professional with more than a decade of experience helping banks, law firms and clients manage investigations and regulatory responses.


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Hybrid Securities are debt securities with traits borrowed from equities

Hybrid securities are securities that have features of both debt and equity.

Wall Street 1929
Wall Street 1929

The classic example of a hybrid instrument is a convertible bond. This is, generally, a corporate bond with a condition attached to it. This condition states that if the equity shares of the corporation issuing the bond hits a certain valuation in the market, the bondholder will be allowed to exchange the bond for a certain number of shares. The number of shares is determined by the bond’s principal value, which is almost always $1000, and how many shares that principal could buy. For a buyer of bonds, this reduces the risk of losing out on exposure to equity if the issuing corporation does very well, without losing the status of a bond, which, as a debt, will be paid back before assets are distributed to non-debt liability holders. For the issuing corporation, usually the bonds hold a slightly lower interest rate than it would otherwise.


About the Author: Marcus Maltempo is a compliance professional with more than a decade of experience helping banks, law firms and clients manage investigations and regulatory responses.


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RWA Mean Risk Weighted Assets

http://corpoinsider.blog.com/2012/11/04/credit-suisse-going-under-extreme-model-makeover/
Suisse 1 Kilo Fine Gold

Risk Weighted Assets is more of a concept than an asset. When a bank lends money, there is a chance some of it will not be paid back. The “some” that might not be paid back is the RWA. The Capital Adequacy Requirement (CAR) requires banks to maintain a Risk-Based Capital Ratio. This is a simple calculation of dividing Regulatory Capital with RWA. Regulatory Capital is the amount of Tier 1 and 2 capital a bank is required to possess at all times. Ideally, a bank would like to have a high Regulatory Capital and low RWA. The risk weights inflate bank assets. While larger assets are considered a good thing on the balance sheet, generally, in this case it is not. RWA valuation is not used to meet the SEC filing requirements. It is used to meet the Basel III requirements. There are 26 classifications of assets with varying risks. Each classification requires the bank to multiply assets by a Basel II prescribed risk weight.

Conceptually, here is what RWA looks like:
The bank lends $100 to a borrower. This particular type of loan with this type of borrower has a significant chance of getting but just $95. Because the risk of lose if $5, the $100 is multiplied by 105%. For this $100 loan, it is a $105 RWA. Banks are required to hold 1/10 in the Risk-Based Capital Ratio. Without the RWA, the bank would have to hold $10 (1/10=$10/$100). But since the $100 is being changed to an RWA of $105, the bank now has to hold $10.50 (1/10=$10.5/$105).

Resources


About the Author: Marcus Maltempo is a compliance professional with more than a decade of experience helping banks, law firms and clients manage investigations and regulatory responses.


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DFAST Means Dodd-Frank Annual Stress Test

Dodd-Frank Annual Stress Test is a simulation that tests the financial system’s ability to remain solvent. It was enacted when Congress enacted Dodd-Frank Wall Street Reform and Consumer Protection Act, commonly know as the Dodd-Frank Act, named for its sponsors Senators Chris Dodd (Connecticut) and Barney Frank (Massachusetts).

Scenarios simulated are not arbitrary. There are 28 variables and they are based on historical economic crises. The variables are such things as rise in unemployment, rise in oil prices, rise in interest rates, fall of the GDP or a sudden equity market crash. National banks and federal savings associations are categorized into two for the simulation: those with more that $50 Billion in assets and those with less. Those with less than $10 Billion are exempt from participating in the Test.

Dodd-Frank Update.com Logo
Dodd-Frank Update.com Logo

Resources


About the Author: Marcus Maltempo is a compliance professional with more than a decade of experience helping banks, law firms and clients manage investigations and regulatory responses.


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SSFA Means Simplified Supervisory Formula Approach

http://en.wikipedia.org/wiki/Federal_Deposit_Insurance_Corporation#mediaviewer/File:US-FDIC-Seal.svg
US FDIC Seal

Financial Institution Letter

Regulatory Capital Rules:
Regulatory Capital Tool for Securitization Exposures

FIL-7-2015
2/11/2015
Summary:

The FDIC has published a simplified supervisory formula approach (SSFA) tool as part of its continued outreach efforts to help institutions implement the revised capital rules. The SSFA is a new method banks may use under the revised capital rules to calculate capital requirements for securitization exposures. It is a formula-based approach designed to apply relatively higher capital requirements to the more risky junior tranches that are the first to absorb losses, and relatively lower requirements to the most senior tranches.

Statement of Applicability to Institutions Under $1 Billion in Total Assets: This Financial Institution Letter applies to all FDIC-supervised banks and savings associations, including community institutions.

Distribution:
FDIC-Supervised Banks and Savings Associations

Complete Financial Institution Letter: http://www.fdic.gov/news/news/financial/2015/fil15007.html


About the Author: Marcus Maltempo is a compliance professional with more than a decade of experience helping banks, law firms and clients manage investigations and regulatory responses.