As the financial sector is key for the transition towards a low-carbon and more circular economy, financial institutions have to deal with climate-related and environmental financial risks (C&E risks). At the same time, the increased importance of these C&E risks also presents new business opportunities for the financial sector. Therefore, to support banks in their self-assessment and action plans, Zanders developed a Scan & Plan Solution on C&E risks.

According to the 2021 World Economic Forum Global Risk Report¹, extreme weather, climate action failure, human environmental damage and biodiversity loss are ranked as four of the top five global risks by highest likelihood and four of the six global risks with the largest impact. It is not surprising that over the past years, numerous articles on C&E risks have been published and many initiatives have been taken to identify, measure and manage these risks. The Paris Agreement², the United Nations 2030 Agenda for Sustainable Development³ and more recently the European Green Deal⁴ are the main examples of international governmental responses to address C&E risks.

The financial sector is considered key for the transition towards a low-carbon and more circular economy. This is illustrated by the fact that the European Central Bank (ECB) has identified climate-related risks as a key risk driver for the euro area banking system in their Single Supervisory Mechanism Risk Map⁵. At the same time, the increased importance of C&E risks also presents new business opportunities for the financial sector, such as providing sustainable financing solutions and offering new financial instruments that facilitate C&E risk management. To illustrate, the UN’s Intergovernmental Panel on Climate Change⁶ (IPCC) estimates that the required investment for alignment with the Paris Agreement would be at least $3.5tn per year until 2050 for the energy sector alone.

To address C&E risks, the ECB published a Guide on climate-related and environmental risks⁷ for banks that describes the ECB’s supervisory expectations related to risk management and disclosure. Banks are required by the ECB to perform a self-assessment with respect to the supervisory expectations and to draft an action plan in 2021. The self-assessments and plans will subsequently be reviewed and challenged by the ECB as part of the supervisory dialogue. In 2022, the ECB will conduct a full supervisory review of bank’s practices related to C&E risks.

The Zanders Scan & Plan Solution provides clear insights into gaps with the ECB expectations and proposes practical actions that are tailored to a bank’s nature, scale and complexity. This article provides a brief explanation of C&E risks, outlines a few specific ECB supervisory expectations and elaborates on the Solution.

Definition of C&E risk

Financial risks from climate and environmental change arise from two primary risk categories:

• Physical risks. The first risk category concerns physical risks caused by acute (direct events) or chronic (longer-term events which cause gradual deterioration) C&E events. Examples of acute events are floods, wildfires and heatwaves, whereas chronic events relate to the likes of rising sea levels, acidity and biodiversity losses, for example.
• Transition risks. The second risk category comprises transition risks resulting from the process of moving towards a low-carbon economy. Changes in policy, regulation, technology, market sentiment and consumer sentiment could destabilize markets, tighten financial conditions and lead to procyclicality of losses.

These two risk categories are distinct from other risk categories in the following aspects: 1) they have a correlated and non-linear impact on all business lines, sectors and geographies, 2) they have a long-term nature and 3) the future impact is largely dependent on short-term actions. The risk categories are, among others, drivers of credit, market and operational risk, as shown in Figure 1.

Figure 1: Examples of the impact of physical risks and transition risks on traditional risk types from the ECB Guide on climate-related and environmental risks.

ECB Supervisory Expectations

In the Guide on climate-related and environmental risks⁷, published in November 2020, the ECB explains that banks are expected to reflect C&E risks as drivers of existing risk categories (e.g., credit risk, market risk, operational risk) rather than as a separate risk type. This indicates that not only efforts should be made by banks to develop risk management practices related to C&E risks but that these practices should also be integrated in existing risk management frameworks, models and policies.

The ECB Guide covers four main areas. First, in relation to ‘business models and strategy’, the ECB expects banks to understand the impact of C&E risks on their business environment and integrate C&E risks in their business strategy. Secondly, the guide addresses ‘governance and risk appetite’. The ECB expects a bank’s management to include C&E risks in the risk appetite framework, assign responsibilities related to C&E risks to the three lines of defense and establish internal reporting. Thirdly, in relation to ‘risk management’, the ECB expects that banks integrate C&E risks into their existing risk management framework. Finally, regarding ‘disclosures’, the ECB expects banks to disclose meaningful information and metrics on C&E risks. The four above-mentioned areas are covered in 13 expectations, which are in turn further divided in 46 sub-expectations. Banks are required by the ECB to perform a self-assessment with respect to the supervisory expectations and to draft an action plan in 2021. The self-assessments and plans will subsequently be reviewed and challenged by the ECB as part of the supervisory dialogue. The ECB recommends National Competent Authorities, in their supervision of less significant institutions, to apply these expectations proportionate to the nature, scale and complexity of the bank’s activities.

Zanders has thoroughly analyzed all (sub)-expectations and has highlighted a few specific expectations including possible actions below.

Expectation 4.2: Institutions are expected to develop appropriate key risk indicators (KRI) and set appropriate limits for effectively managing climate-related and environmental risks in line with their regular monitoring and escalation arrangements.

Here, the ECB expects institutions to monitor and report their exposures to C&E risks based on current data and forward-looking estimations. In addition, institutions are expected to assign quantitative metrics to C&E risks. It is however acknowledged that, since definitions, taxonomies and methodologies are still under development, qualitative metric or proxy data can be used as long as specific quantitative metrics are not yet available. The ECB deems that the metrics should reflect the long-term nature of climate change, and explicitly consider different paths for temperature and greenhouse gas emissions. Finally, the ECB expects institutions to define limits on the metrics based on the risk appetite regarding C&E risks.

This expectation has various elements to it, and Zanders has defined as the most important and first step to identify the internal and external data availability related to C&E risks. If the data availability allows it, an institution should set up quantitative metrics and limits on these metrics that reflect C&E risks. A first step to achieve this would be to define several firmwide KRIs, for example by limiting the carbon emission of the whole portfolio in line with the Paris Agreement² or other (inter)national climate agreements. These KRIs can then be cascaded down to business lines and/or portfolios, such as limiting the exposure to specific sectors with large carbon footprints or substantial use of water. If the current data availability does not allow for quantitative metrics, the bank should identify which data is still lacking and assess ways to collect this data from internal data sources or external data providers in the course of time. In the meantime, qualitative metrics or proxies could be developed such as a qualitative score for the sophistication of the climate strategy of large corporates in the portfolio.

Should a bank already have some metrics in place, Zanders advises to evaluate if these metrics sufficiently cover all material physical and transition C&E risks that the bank is expected to face and if there are ways to increase the sophistication of these metrics, for example by including forward-looking estimations. Finally, Zanders advises banks to create a monitoring procedure to ensure that these metrics and their limits are evaluated regularly.

Expectation 8.1: Climate-related and environmental risks are expected to be included in all relevant stages of the credit-granting process and credit processing.

In this expectation, the ECB underlines that banks should identify and assess material factors that affect the default risk of loan exposures. The quality of the client’s own management of C&E risks may be taken into account in this case. In addition, banks are expected to consider changes in the credit risk profiles based on sectors and geographical areas.

The way to address this expectation is highly dependent on the nature of the bank, on the existing credit granting process and on the availability of data. Some examples of including C&E risk in the credit granting process in a qualitative way, which Zanders has observed in the market, are the development of shadow PD models that trigger mitigating actions in case of large discrepancies with the regular PDs, or the introduction of a scorecard based on quantitative as well as qualitative aspects.

It should be noted that these and other solutions are not mutually exclusive and that multiple approaches can be adopted for different parts of the portfolio. Also, the efforts for several individual expectations can be combined. For example, taking C&E risks into account in the credit granting process could also be linked to the qualitative and quantitative metrics set as part of expectation 4.2 (see above). The quality of the client’s own management of C&E risks can for instance be measured based on the qualitative score for the climate strategy sophistication of large corporates mentioned above.

Expectation 11: Institutions with material climate-related and environmental risks are expected to evaluate the appropriateness of their stress testing, with a view to incorporating them into their baseline and adverse scenarios.

This expectation indicates that banks should evaluate the appropriateness of their stress testing in relation to C&E risks. In this evaluation, the bank should take into account the following considerations: i) how will the bank be affected by physical and transition risks, ii) how will C&E risks evolve under various scenarios (thereby taking into account that these risks may not fully be reflected in historical data), and iii) how may C&E risks materialize in the short-, medium- and long-term. Based on these considerations and on scientific climate change pathways as well as on assumptions that fit with their risk profile and individual specification, banks should incorporate C&E risks in their baseline and adverse scenarios.

To address this recommendation, Zanders advises banks to first identify C&E risks scenarios with different severities based on the materiality of C&E risks for the bank. Examples of this include early or late transition to a low-carbon economy (transition risk), introduction of a carbon tax (transition risk) or staying below or above a 2°C temperature increase (physical risk). These scenarios could be based on scientific scenarios from the IPCC⁸ or the International Energy Agency⁹. The next step is to translate these scenarios into macro-economic variables, such as GDP, inflation and loan valuations, over a range of relevant sectors and geographies. Since there is not yet a single methodology to do this, banks need to be creative and combine new qualitative and quantitative approaches with existing modeling methodologies.

Zanders Scan & Plan Solution

To manage C&E risks, to seize new business opportunities and to meet the regulatory expectations related to C&E risks, it is crucial for banks to have transparency about their exposure to these risks. To support banks with this, the Zanders Scan & Plan Solution is available. The Scan assesses the gaps between the bank’s current practices and each of the expectations in the ECB guide. These gaps are scored based on a pre-defined scoring system and are shown in a heatmap that is easy to interpret. Subsequently, the Plan proposes possible actions to close the identified gaps. These possible actions will be tailored to the nature, scale, and complexity of the bank and to the level of sophistication of the bank in the field of C&E risks. The Scan & Plan will be provided in the form of a detailed report.

Zanders has previously supported clients on topics related to climate change, published market insights and supported research. In addition, Zanders has broad experience in supporting clients in each of the areas of the ECB guide: business models and strategy, governance and risk appetite, risk management and disclosure. Hence, Zanders is in an excellent position to also support banks with the implementation of the proposed actions from the Scan & Plan or with shaping new business activities related to C&E risks.

To learn more about the Zanders Scan & Plan solution and how Zanders can support your institution with managing C&E risks, please contact Petra van Meel, Marije Wiersma or Pieter Klaassen.

References
1) http://www3.weforum.org/docs/WEF_The_Global_Risks_Report_2021.pdf
2) https://unfccc.int/sites/default/files/english_paris_agreement.pdf
3) https://sdgs.un.org/2030agenda
4) https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal_en
5) https://www.bankingsupervision.europa.eu/ecb/pub/ra/html/ssm.ra2021~edbbea1f8f.en.html#toc1
6) https://www.ipcc.ch/site/assets/uploads/sites/2/2019/02/SR15_Chapter4_Low_Res.pdf
7) https://www.bankingsupervision.europa.eu/ecb/pub/pdf/ssm.202011finalguideonclimate-relatedandenvironmentalrisks~58213f6564.en.pdf
8) https://www.ipcc.ch/report/emissions-scenarios/
9) https://www.iea.org/reports/world-energy-model/sustainable-development-scenario

One of the key subjects in this re-assessment is the implementation of tangible and transparent Environment, Social, and Governance (ESG) factors into the business.

Treasury can drive sustainability throughout the company from two perspectives, namely through initiatives within the Treasury function and initiatives promoted by external stakeholders, such as banks, investors, or its clients. When considering sustainability, many treasurers first port of call is to investigate realizing sustainable financing framework. This is driven by the high supply of money earmarked for sustainable goals. However, besides this external focus, Treasury can strive to make its own operations more sustainable and, as a result, actively contribute to company-wide ESG objectives.

Figure 1: ESG initiatives in scope for Treasury

Treasury holds a unique position within the company because of the cooperation it has with business areas and the interaction with external stakeholders. Treasury can leverage this position to drive ESG developments throughout the company, stay informed of latest updates and adhere to regulatory standards. This article shows how Treasury can become a sustainable support function in its own right, highlights various initiatives within and outside the Treasury department and marks the benefits for Treasury – on top of realising ESG targets.

Internal initiatives

Automation and digitalization drive certain environmental initiatives within the Treasury department. Full digitalized records and bank statement management and the digitalization of form processes reduce the adverse environmental impact of the Treasury department. Besides reducing Treasury’s environmental footprint, digitalization improves efficiency of the Treasury team. By reducing the number of manual, cumbersome operational activities, time can be spent on value-adding activities rather than operational tasks.

Another great example of how Treasury can contribute to the ESG goals of the company, is to incorporate ESG elements in the capital allocation process. This can be done by adding ESG related risk factors to the weighted average cost of capital (WACC) or hurdle investment rates. By having an ESG linked WACC, one can evaluate projects by measuring the real impact of ESG on the required return on equity (ROE). By adjusting the WACC to, for example, the level of CO2 that is emitted by a project, the capital allocation process favours projects with low CO2 emissions.

An additional internal initiative is the design of a mobility policy with the objective to lower CO2 emissions. On one hand, this relates to decreasing the amount of business trips made by the Treasury department itself. On the other hand, it relates to the reduction of business travel by stakeholders of treasury such as bankers, advisors and system vendors. A framework that offsets the added value of a real-life meeting against the CO2 emission is an example of a measure that supports CO2 reduction on both sides. Such a framework supports determination whether the meeting takes place online or in person.

Furthermore, embedding ESG requirements into bank selection, system selection and maintenance processes is a valuable way of encouraging new and existing partners to undertake ESG related measures.

When it comes to social contributions, the focus could be on the diversity and inclusion of the Treasury department, which includes well-being, gender equality and inclusivity of the employees. Pursuing these policies can increase the attractiveness of the organization when hiring talent and make it easier to retain talent within the company, which is also beneficial to the Treasury function.

The development of a structured model that defines the building blocks for Treasury to support the achievement of companywide ESG objectives is a governance initiative that Treasury could undertake. An example of such a model is the Zanders Treasury and Risk Maturity Model, which can be integrated in any organization. This framework supports Treasury in keeping track of its ESG footprint and its contribution to company-wide sustainable objectives. In addition, the Zanders sustainability dashboard provides information on metrics and benchmarks that can be applied to track the progress of several ESG related goals for Treasury. Some examples of these are provided in our ‘Integration of ESG in treasury’ article.

External initiatives

Besides actions taken within the Treasury department, Treasury can boost company-wide ESG performance by leveraging their collaboration with external stakeholders. One of these external initiatives is sustainability linked financing, which is a great tool to encourage the setting of ambitious, company-wide ESG targets and link these to financing arrangements. Examples of sustainability linked financing products include green loans and bonds, sustainability-linked loans, and social bonds. To structure sustainability-linked financing products, corporates often benefit from the guidance of external parties when setting KPIs and ambitious targets and linking these to the existing sustainability strategy. Besides Treasury’s strong relationships with banks, retaining good relationships with (ESG) rating agencies and financial institutions is critical to stay abreast of the latest updates and adhere to regulatory standards. Additionally, investing excess cash in a sustainable manner, using green money market funds or assessing the ESG rating of counterparties, is an effective way of supporting sustainability.

Apart from financing instruments, Treasury can drive the ESG strategy throughout the organization in other ways. Treasury can seek collaborations with business partners to comply with ESG targets, which is another effective manner to achieve ESG related goals throughout the supply chain. An increasing number of corporates is looking to reduce the carbon footprint of their supply chain, for which collaboration is essential. Treasury can support this initiative by linking supplier onboarding on its supply chain finance program to the sustainability performance of suppliers.

To conclude

As developments in ESG are rapidly unfold9ing, Zanders has started an initiative to continuously update our clients to stay ahead of the latest trends. Through the knowledge and network that we have built over the years, we will regularly inform our clients on ESG trends via articles on the news page on our website. The first article will be devoted to the revision of the Sustainability Linked Loan Principles (SLLP) by the Loan Market Association (LMA) and its American and Asian equivalents.

We are keen to hear which topics you would like to see covered. Feel free to reach out to Joris van den Beld or Sander van Tol if you have any questions or want to address ESG topics that are on your agenda.

The Bank of England is even of the opinion that climate change represents the tragedy of the horizon: “by the time it is clear that climate change is creating risks that we want to reduce, it may already be too late to act” [1]. This article provides a summary of the type of financial risks resulting from climate change, various initiatives within the financial industry relating to the shift towards a low-carbon economy, and an outlook for the assessment of climate change risks in the future.

At the December 2015 Paris Agreement conference, strict measures to limit the rise in global temperatures were agreed upon. By signing the Paris Agreement, governments from all over the world committed themselves to paving a more sustainable path for the planet and the economy. If no action is taken and the emission of greenhouse gasses is not reduced, research finds that per 2100, the temperature will have increased by 3°C to 5°C².. Climate change affects the availability of resources, the supply and demand for products and services and the performance of physical assets. Worldwide economic costs from natural disasters already exceeded the 30-year average of USD 140 billion per annum in seven out of the last ten years. Extreme weather circumstances influence health and damage infrastructure and private properties, thereby reducing wealth and limiting productivity. According to Frank Elderson, Executive Director at the DNB, this can disrupt economic activity and trade, lead to resource shortages and shift capital from more productive uses to reconstruction and replacement³.

According to the Bank of England, financial risks from climate change come down to two primary risk factors⁴:

Increasing concerns about climate change has led to a shift in the perception of climate risk among companies and investors. Where in the past analysis of climate-related issues was limited to sectors directly linked to fossil fuels and carbon emissions, it is currently being recognized that climate-related risk exposures concern all sectors, including financials. Banks are particularly vulnerable to climate-related risks as they are tied to every market sector through their lending practices.

Financial risks

• Physical risks. The first risk factor concerns physical risks caused by climate and weather-related events such as droughts and a sea level rise. Potential consequences are large financial losses due to damage to property, land and infrastructure. This could lead to impairment of asset values and borrowers’ creditworthiness. For example, as of January 2019, Dutch financial institutions have EUR 97 billion invested in companies active in areas with water scarcity⁵. These institutions can face distress if the water scarcity turns into water shortages. Another consequence of extreme climate and weather-related events is the increase in insurance claims: in the US alone, the insurance industry paid out USD 135 billion from natural catastrophes in 2017, almost three times higher than the annual average of USD 49 billion.
• Transition risks. The second risk factor comprises transition risks resulting from the process of moving towards a low-carbon economy. Revaluation of assets because of changes in policy, technology and sentiment could destabilize markets, tighten financial conditions and lead to procyclicality of losses. The impact of the transition is not limited to energy companies: transportation, agriculture, real estate and infrastructure companies are also affected. An example of transition risk is a decrease in financial return from stocks of energy companies if the energy transition undermines the value of oil stocks. Another example is a decrease in the value of real estate due to higher sustainability requirements.

These two climate-related risk factors increase credit risk, market risk and operational risk and have distinctive elements from other risk factors that lead to a number of unique challenges. Firstly, financial risks from physical and transition risk factors may be more far-reaching in breadth and magnitude than other types of risks as they are relevant to virtually all business lines, sectors and geographies, and little diversification is present. Secondly, there is uncertainty in timing of when financial risks may be realized. The possibility exists that the risk impact falls outside of current business planning horizons. Thirdly, despite the uncertainty surrounding the exact impact of climate change risks, combinations of physical and transition risk factors do lead to financial risk. Finally, the magnitude of the future impact is largely dependent on short-term actions.

Initiatives

Many parties in the financial sector acknowledge that although the main responsibility for ensuring the success of the Paris Agreement and limiting climate change lies with governments, central banks and supervisors also have responsibilities. Consequently, climate change and the inherent financial risks are increasingly receiving attention, which is evidenced by the various recent initiatives related to this topic.

Banks and regulators

The Network of Central Banks and Supervisors for Greening the Financial System (NGFS) is an international cooperation between central banks and regulators⁶. NGFS aims to increase the financial sector’s efforts to achieve the Paris climate goals, for example by raising capital for green and low-carbon investments. NGFS additionally maps out what is needed for climate risk management. DNB and central banks and regulators of China, Germany, France, Mexico, Singapore, UK and Sweden were involved from the start of NGFS in 2017. The ECB, EBA, EIB and EIOPA are currently also part of the network. In the first progress report of October 2018, NGFS acknowledged that regulators and central banks increased their efforts to understand and estimate the extent of climate and environmental risks. They also noted, however, that there is still a long way to go.

In their first comprehensive report of April 2019, NGFS drafted the following six recommendations for central banks, supervisors, policymakers and financial institutions, which reflect best practices to support the Paris Agreement⁷:

1. Integrating climate-related risks into financial stability monitoring and micro-supervision;
2. Integrating sustainability factors into own-portfolio management;
3. Bridging the data gaps by public authorities by making relevant data to Climate Risk Assessment (CRA) publicly available in a data repository;
4. Building awareness and intellectual capacity and encouraging technical assistance and knowledge sharing;
5. Achieving robust and internationally consistent climate and environment-related disclosure;
6. Supporting the development of a taxonomy of economic activities.

All these recommendations require the joint action of central banks and supervisors. They aim to integrate and implement earlier identified needs and best practices to ensure a smooth transition towards a greener financial system and a low-carbon economy. Recommendations 1 and 5, which are two of the main recommendations, require further substantiation.

• The first recommendation consists of two parts. Firstly, it entails investigating climate-related financial risks in the financial system. This can be achieved by (i) mapping physical and transition risk channels to key risk indicators, (ii) performing scenario analysis of multiple plausible future scenarios to quantify the risks across the financial system and provide insight in the extent of disruption to current business models in multiple sectors and (iii) assessing how to include the consequences of climate change in macroeconomic forecasting and stability monitoring. Secondly, it underlines the need to integrate climate-related risks into prudential supervision, including engaging with financial firms and setting supervisory expectations to guide financial firms.
• The fifth recommendation stresses the importance of a robust and internationally consistent climate and environmental disclosure framework. NGFS supports the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD⁸) and urges financial institutions and companies that issue public debt or equity to align their disclosures with these recommendations. To encourage this, NGFS emphasizes the need for policymakers and supervisors to take actions in order to achieve a broader application of the TCFD recommendations and the growth of an internationally consistent environmental disclosure framework.

Future deliverables of NGFS consist of drafting a handbook on climate and environmental risk management, voluntary guidelines on scenario-based climate change risk analysis and best practices for including sustainability criteria into central banks’ portfolio management.

Asset managers

To achieve the climate goals of the Paris Agreement, €180 billion is required on an annual basis⁵. It is not possible to acquire such a large amount from the public sector alone and currently only a fraction of investor capital is being invested sustainably. Research from Morningstar shows that 11.6% of investor capital in the stock market and 5.6% in the bond market is invested sustainably⁹. Figure 1 shows that even though the percentage of capital invested in sustainable investment funds (stocks and bonds) is growing in recent years, it is still worryingly low.

Figure 1: Percentage of invested capital in Europe in traditional and sustainable investment funds (shares and bonds). Source: Morningstar [9].

The current levels of investment are not enough to support an environmentally and socially sustainable economic system. As a result, the European Commission (EC) has raised four initiatives through the Technical Expert Group on sustainable finance (TEG) that are designed to increase sustainable financing¹⁰. The first initiative is the issuance of two kinds of green (low-carbon) benchmarks. Offering funds or trackers on these indices would lead to an increase in cash flows towards sustainable companies. Secondly, an EU taxonomy for climate change mitigation and climate change adaptation has been developed. Thirdly, to enable investors to determine to what extent each investment is aligned with the climate goals, a list of economic activities that contribute to the execution of the Paris Agreement has been drafted. Finally, new disclosure requirements should enhance visibility of how investment firms integrated sustainability into their investment policy and create awareness of the climate risks the investors are exposed to.

Insurance firms

Within the insurance sector, the Prudential Regulation Authority (PRA) requires insurers to follow a strategic approach to manage the financial risks from climate change. To support this, in July 2018, the Bank of England (BoE) formed a joint working group focusing on providing practical assistance on the assessment of financial risks resulting from climate changes. In May 2019, the working group issued a six-stage framework that helps insurers in assessing, managing and reporting physical climate risk exposure due to extreme weather events¹¹. Practical guidance is provided in the form of several case studies, illustrating how considering the financial impacts can better inform risk management decisions.

Authorities

Another initiative is the Climate Financial Risk Forum (CFRF), a joint initiative of the PRA and the Financial Conduct Authority (FCA)¹². The forum consists of senior representatives of the UK financial sector from banks, insurers and asset managers. CFRF aims to build capacity and share best practices across financial regulators and the industry to enhance responses to the financial climate change risks. The forum set up four working groups focusing on risk management, scenario analysis, disclosure and innovation. The purpose of these working groups, which consist of CFRF members as well as other experts such as academia, is to provide practical guidance on each of the four focus areas.

Current status and outlook

On 5 June 2019, the TCFD published a Status Report assessing a disclosure review on the extent to which 1,100 companies included information aligned with these TCFD recommendations in their 2018 reports. The report also assessed a survey on companies’ efforts to live up to TCFD recommendations and users’ opinion on the usefulness of climate-related disclosures for decision-making¹³. Based on the disclosure review and the survey, TCFD concluded that, while some of the results were encouraging, not enough companies are disclosing climate change-linked financial information that is useful for decision-making. More specifically, it was found that:

• “Disclosure of climate-related financial information has increased, but is still insufficient for investors;
• More clarity is needed on the potential financial impact of climate-related issues on companies;
• Of companies using scenarios, the majority do not disclose information on the resilience of their strategies;
• Mainstreaming climate-related issues requires the involvement of multiple functions.”

Further, the BoE finds that despite the progress, there is still a long way to go: while many banks are incorporating the most immediate physical risks to their business models and assess exposures to transition risks, many of them are not there yet in their identification and measurement of the financial risks. They stress that governments, financial firms, central banks and supervisors should work together internationally and domestically, private sector and public sector, to achieve a smooth transition to a low-carbon economy. Mark Carney, Governor of the BoE, is optimistic and argues that, conditional on the amount of effort, it should possible to manage the financial climate risks in an orderly, effective and productive manner⁴.

With respect to the future, Frank Elderson made the following claim: “Now that European banking supervision has entered a more mature phase, we need to retain a forward-looking strategy and develop a long-term vision. Focusing on greening the financial system must be a part of this.”³.

References

¹ https://www.bankofengland.co.uk/-/media/boe/files/speech/2019/avoiding-the-storm-climate-change-and-the-financial-system-speech-by-sarah-breeden.pdf
² https://public.wmo.int/en/media/press-release/wmo-climate-statement-past-4-years-warmest-record
³ https://www.bankingsupervision.europa.eu/press/interviews/date/2019/html/ssm.in190515~d1ab906d59.en.html
⁴ https://www.bankofengland.co.uk/-/media/boe/files/prudential-regulation/report/transition-in-thinking-the-impact-of-climate-change-on-the-uk-banking-sector.pdf
⁵ https://fd.nl/achtergrond/1294617/beleggers-moeten-met-de-billen-bloot-over-klimaatrisico-s
⁶ https://www.dnb.nl/over-dnb/samenwerking/network-greening-financial-system/index.jsp
⁷ https://www.banque-france.fr/sites/default/files/media/2019/04/17/ngfs_first_comprehensive_report_-_17042019_0.pdf
⁸ https://www.fsb-tcfd.org/publications/final-recommendations-report/
⁹ http://www.morningstar.nl/nl/
¹⁰ https://ec.europa.eu/info/publications/sustainable-finance-technical-expert-group_en
¹¹ https://www.bankofengland.co.uk/-/media/boe/files/prudential-regulation/publication/2019/a-framework-for-assessing-financial-impacts-of-physical-climate-change.pdf
¹² https://www.bankofengland.co.uk/news/2019/march/first-meeting-of-the-pra-and-fca-joint-climate-financial-risk-forum
¹³ https://www.fsb-tcfd.org/wp-content/uploads/2017/06/FINAL-2017-TCFD-Report-11052018.pdf

How can SAP technology support organizations with the consequences of IBOR reform? In this article we outline the SAP enhancements relating to the IBOR reform, discuss how to implement these enhancements, and pinpoint specific areas of attention based on our most recent SAP projects on IBOR reform implementation.

SAP provides a roadmap to support interest rate benchmark reforms. SAP has developed a standard solution to support the daily compounding interest calculation with overnight risk-free rates, which have become the new interest rate benchmarks like for example for USD, GBP and CHF currencies. This standard solution has been included in different versions of SAP: from ECC EHP8 to most recent versions of S/4 HANA.

The SAP solution consists of a set of composite SAP notes that need to be installed. It is recommended to install the SAP notes as a part of the support pack. There are three core SAP composite notes to install:

• 2939657 (common basis for TRM and CML)
• 2932789 (RFR in TRM)
• 2880124 (for CML)

Additional SAP notes and/or activation of business functions may be required, especially if implementation takes place in SAP ECC. The implementation of the SAP notes is the first and the core step, but SAP also requires an update of the configuration objects.

Transaction management
The following five points should be followed for transaction management:

1) Activation of the parallel condition of the cash flow calculation.

This activation is done on the level of a respective product type. The following product categories are supported:

• Money market deals (product category 550 and 580)
• Bonds (product category 040)
• SWAP (product category 620)

SAP recommends the creation of the new product types. It is also possible to do the activation by extending the configuration of the existing product types without any issues. However, we would still recommend executing prove-of-concept prior to amending existing product types to ensure there is no regression effect or dumps in the specific SAP environment.

Activation of parallel conditions will enable the following enhancements in SAP:

• New interest conditions (Compound interest calculation and Average compound interest calculation) with spread components that can be calculated linearly or compounded.
• Updated interest cash flow calculation according to the new interest conditions (new FiMa).
• Parallel interest conditions (spread is linear and maintained as separate flow in the deal).
• New fields and functionalities in the deal maintenance (Weighting, Lookback, Lockout periods etc).

Please note that SAP may require extra business function activation to enable selection of cash flow calculation in SPRO (such as FIN_TRM_INS_LOCBR).

2) For the Interest rate swaps the below notes should be installed:

• 2971185 (Risk-Free Rates for Interest Rate Swaps: Collective Note)
• 2973302 – Business Function: Interest Rate Swap Enhancements (FIN_TRM_IR)

It is strongly recommended to install and run report ZSAP_FTR_IRSWAP_NOTES which will indicate if any SAP note or business function is missing or invalid.

3) Amendment of the field selection for the respective condition types.

With the changes there are more fields to be created, therefore field selection needs to be changed accordingly.

4) There are new fields to be created in the deals, therefore you should consider if changes are required in the field selection in Transaction manager.

5) In the case where mirror deals are configured, you should validate that the conditions (interest calculation type of nominal interest and date structure) in the mirror deals are properly mirrored. Activation of the business function FIN-TRM-MME may be required.

Yield Curve Framework
Creation of the new yield curves where the new grid points should represent the reference interest rates based on the overnight risk-free rates. IBOR reform might result in a need for a corporate to change methodology for mark-to-market calculations of the financial instruments. New discounting yield curves will be required for the net present value calculation of FX contracts and interest rate derivatives. New yield curves might also be required for projecting future cash flows for interest rate derivatives in the mark-to-market calculations.

Creation of new yield curves (and evaluation types) requires thorough attention and input from Treasury and Accounting teams and it should be signed off by the auditor. This configuration also requires good communication with market data providers in order to retrieve correct data for the additional data feed.

Market Risk Analyzer
Creation of the new evaluation types. This is required to enable cash flow discounting to be based on the new yield curves. It is not recommended to amend existing calculation types for the audit purposes.

Market data feed
New reference interest rates in SAP. It is essential to have the new set of risk-free-rates as well as IBOR fallback rates, adjusted or term rates received from your market data provider. The scope here fully depends on the existing active deals, your migration approach, and alignment with your financial counterparties.

Treasury Accounting
Changes in assignment of the update types for accrual/deferral. An additional grouping term is required to be added for the respective update types.

In case there is a business need to aggregate daily cash flows, changes to the flow types for the nominal interest are required. With compound interest calculation, SAP calculates and posts interest cash flows daily, while interest settlement occurs based on the terms of the deal. Hence, daily flows (e.g. 30 flows for a monthly settlements) need to be reconciled with a single settlement at the settlement date. This daily cash flow maintenance and reconciliation may lead to extra workload for the back office/accounting team. Therefore, businesses might prefer to aggregate (net) these daily cash flows. A new flow type and derivation rule may be configured to support this requirement. This would be an update of the existing accounting, which represents a potential regression impact.

SAP IHC interest conditions
Consider changes in the IHC interest conditions for debit/credit balances in case a variable reference interest rate based in RFR is applied. Please note that SAP IHC does not support compounding of the interest for the daily balancing.

Reports
We also recommend executing a round of regression testing of SAP TRM. The new functionality potentially can impact your reports’ variants and layouts, therefore potential regression updates are required. Please validate if the fields showing variable interest rates are properly populated with the data, especially the collective processing report for OTC interest rate instrument (TI92).

Custom functionality and SAP queries
It is important to review your bespoke functionalities in SAP, which are related to TRM, MRA, Market data feed etc. Additionally, it is worthwhile to validate your SAP queries for Treasury, especially the ones designed for month end purposes: NPVs, Accrual/Deferral calculation etc. Pay attention to table TRLIT_AD_TRANS and how the table is updated.

IBOR reform and Zanders

Zanders is closely following all IBOR reform related regulations and latest developments. We have also developed a proprietary methodology to support our clients in this regulatory transition, with several projects already successfully completed.

Given our expertise in treasury management, valuations and treasury technology, we are well equipped to support financial and nonfinancial organizations in the IBOR reform from both a functional and a technological perspective. We assist our clients throughout the entire project, from the impact assessment to roadmap definition, and finally the transition itself. Functional support could include definition of the new reference rates, definition of the new yield curves for discounting and projecting future cash flows, formulation of the business cutover plan, support in the new interest calculation methodologies and new market conventions, changing procedures and other many other activities.

To learn more about the IBOR reform, see our previously published insights:

• https://zanders-migration.appealstaging.co.uk/en/latest-insights/preparing-your-treasury-management-system-for-the-ibor-replacement/
• https://zanders-migration.appealstaging.co.uk/en/latest-insights/a-new-milestone-on-the-ibor-reform-road/
• https://zanders-migration.appealstaging.co.uk/en/news/announcement-on-the-end-of-libor/
• https://zanders-migration.appealstaging.co.uk/en/latest-insights/zanders-ibor-assessment/
• https://zandersadvisory.com/latest-insights/sap-responds-to-ibor-reform/

In this article we do not cover the migration of existing deals and impact to hedge accounting, as this will be explained in a separate article. Should you have any questions or quires regarding SAP implementation of IBOR reform, please feel free to contact Aleksei Abakumov or +31 35 692 89 89.

Under the FRTB internal models approach (IMA), the capital calculation of risk factors is dependent on whether the risk factor is modellable. Insufficient data will result in more non-modellable risk factors (NMRFs), significantly increasing associated capital charges.

NMRFs

Risk factor modellability and NMRFs

The modellability of risk factors is a new concept which was introduced under FRTB and is based on the liquidity of each risk factor. Modellability is measured using the number of ‘real prices’ which are available for each risk factor. Real prices are transaction prices from the institution itself, verifiable prices for transactions between arms-length parties, prices from committed quotes, and prices from third party vendors.

For a risk factor to be classed as modellable, it must have a minimum of 24 real prices per year, no 90-day period with less than four prices, and a minimum of 100 real prices in the last 12 months (with a maximum of one real price per day). The Risk Factor Eligibility Test (RFET), outlined in FRTB, is the process which determines modellability and is performed quarterly. The results of the RFET determine, for each risk factor, whether the capital requirements are calculated by expected shortfall or stressed scenarios.

Consequences of NMRFs for banks

Modellable risk factors are capitalised via expected shortfall calculations which allow for diversification benefits. Conversely, capital for NMRFs is calculated via stressed scenarios which result in larger capital charges. This is due to longer liquidity horizons and more prudent assumptions used for aggregation. Although it is expected that a low proportion of risk factors will be classified as non-modellable, research shows that they can account for over 30% of total capital requirements. 

There are multiple techniques that banks can use to reduce the number and impact of NMRFs, including the use of external data, developing proxies, and modifying the parameterisation of risk factor curves and surfaces. As well as focusing on reducing the number of NMRFs, banks will also need to develop early warning systems and automated reporting infrastructures to monitor the modellability of risk factors. These tools help to track and predict modellability issues, reducing the likelihood that risk factors will fail the RFET and increase capital requirements.

Methods for reducing the number of NMRFs

Banks should focus on reducing their NMRFs as they are associated with significantly higher capital charges. There are multiple approaches which can be taken to increase the likelihood that a risk factor passes the RFET and is classed as modellable.

Enhancing internal data

The simplest way for banks to reduce NMRFs is by increasing the amount of data available to them. Augmenting internal data with external data increases the number of real prices available for the RFET and reduces the likelihood of NMRFs. Banks can purchase additional data from external data vendors and data pooling services to increase the size and quality of datasets.

It is important for banks to initially investigate their internal data and understand where the gaps are. As data providers vary in which services and information they provide, banks should not only focus on the types and quantity of data available. For example, they should also consider data integrity, user interfaces, governance, and security. Many data providers also offer FRTB-specific metadata, such as flags for RFET liquidity passes or fails.

Finally, once a data provider has been chosen, additional effort will be required to resolve discrepancies between internal and external data and ensure that the external data follows the same internal standards.

Creating risk factor proxies

Proxies can be developed to reduce the number or magnitude of NMRFs, however, regulation states that their use must be limited. Proxies are developed using either statistical or rules-based approaches.

Rules-based approaches are simplistic, yet generally less accurate. They find the “closest fit” modellable risk factor using more qualitative methods, e.g. using the closest tenor on the interest rate curve. Alternatively, more accurate approaches model the relationship between the NMRF and modellable risk factors using statistical methods. Once a proxy is determined, it is classified as modellable and only the basis between it and the NMRF is required to be capitalised using stressed scenarios.

Determining proxies can be time-consuming as it requires exploratory work with uncertain outcomes. Additional ongoing effort will also be required by validation and monitoring units to ensure the relationship holds and the regulator is satisfied.

Developing own bucketing approach

Instead of using the prescribed bucketing approach, banks can use their own approach to maximise the number of real price observations for each risk factor.

For example, if a risk model requires a volatility surface to price, there are multiple ways this can be parametrised.  One method could be to split the surface into a 5x5 grid, creating 25 buckets that would each require sufficient real price observations to be classified as modellable. Conversely, the bank could instead split the surface into a 2x2 grid, resulting in only four buckets. The same number of real price observations would then need to be allocated between significantly less buckets, decreasing the chances of a risk factor being a NMRF.

It should be noted that the choice of bucketing approach affects other aspects of FRTB. Profit and Loss Attribution (PLA) uses the same buckets of risk factors as chosen for the RFET. Increasing the number of buckets may increase the chances of passing PLA, however, also increases the likelihood of risk factors failing the RFET and being classed as NMRFs.

Conclusion

In this article, we have described several potential methods for reducing the number of NMRFs. Although some of the suggested methods may be more cost effective or easier to implement than others, banks will most likely, in practice, need to implement a combination of these strategies in parallel. The modellability of risk factors is clearly an important part of the FRTB regulation for banks as it has a direct impact on required capital. Banks should begin to develop strategies for reducing the number of NMRFs as early as possible if they are to minimise the required capital when FRTB goes live.

Intraday Bank Statements offers a cash manager additional insight in estimated closing balances of external bank accounts and therefore provides the information to manage the cash more tightly on the company’s bank accounts.

In any SAP Treasury implementation, conversation will eventually turn to the integration of external systems and providers for efficient straight-through processing of data and the additional controls it provides. SAP has introduced the TPI functionality to manage one of the more challenging of these interfaces which is the integration between SAP and the external trade platforms.

The general outline for any trade integration solution would contain the following high-level components:

• The ability to collect the trade requirements in the form of FX orders from all relevant sources.
• A trade dashboard for the dealers to view and manage all requested orders.
• Ability to send the FX orders to an external trade platform for trade execution.
• Capturing of the executed trade in the treasury module, ensuring that the FX order data is also recorded to identify the purpose of the FX transaction.

There are many levels of complexity of how each of these components have been developed in the past for different organizations, from the simplest Excel templates to the most complex bespoke modules with live interfaces to manage the end-to-end trading needs.

The choice of how much an organization would want to invest in these complex solutions would depend on the volume, importance of the trading function, need for enhanced control around trading, and the level of enriched data to be recorded automatically on the deals. Now, with a standard alternative available from SAP, an extensive business case may no longer be necessary to incorporate the more complex of these requirements, as the improved controls and efficiency of processing data is available with less risk and investment than previously considered.

The solution can be broadly defined under the SAP S/4 HANA functionality and the SAP Cloud Platform (SCP) functionality as seen below.

Figure 1

SAP S/4 HANA – Trade Platform Integration
The S/4 HANA functionality covers the first of the components mentioned before. Here SAP has introduced an entirely new database in the SAP environment to manage and control Trade Requests – the SAP equivalents of FX orders.

These Trade Requests may be created automatically off the back of other SAP tools such as Cash Management, Hedge Management Cockpit, Balance Sheet Hedging or simply from manual requests. The resulting Trade Request contains the same data categorizations that apply to a deal in TRM, such as portfolio, characteristics, internal references, and other fields normally found under Administration. All of this data collected prior to trading will be carried to the actual deal once executed, ensuring the dealers will not be responsible for accurately capturing this information on the deal that may not be relevant to them but necessary for further processing.

The clear benefit of this new integration is that it bridges the gap between the determination of trade requirements from Cash Management or FX risk reporting, and the dealers who are to execute and fulfil the trades. This allows the information related to the purpose of the trade (e.g.; the portfolio, exposure position, profit center, etc.) to be allocated to the Trade Request and subsequently to the executed trade automatically without the need of any manual enrichment.

Specially within the context of the Hedge Management Cockpit, this is very useful in the further automatic assignment of trades to hedge relationships, as the purpose of the trade is carried throughout the process.

SAP Cloud Platform – Trade Platform Integration
While the database in S/4 HANA remains the central transaction data source throughout the process, the functionality in SCP provides a set of tools for the dealers to manage the trades requests as needed.

This begins with some business rules to help differentiate how the trades will be fulfilled, either directly externally with a bank counterparty or internally via the treasury center.

All the external trades now can be found on the central Trade Request dashboard “Manage Trade Requests”, which acts as an order book from where the dealers/front office have a clear view on all deal requests that are been triggered from different areas of the organization and where in addition to being able to manage all the trade requests centrally, the status of each trade request is available to ensure no duplicate trading.

Figure 2

Figure 3

From the dashboard, a dealer can choose to group trades into a block, split the trades and edit them as necessary or alternatively the Trade Requests may be cancelled or manually traded as a “Phone Trade”.
The Send function on the dashboard will trigger the interface to the external trade platform for the selected trade requests taking into account the split and block trade requirements. The requests will then be executed and fulfilled on the external platform where the executed trade details such as rate and counterparty are captured back in the application, which in turns triggers the automatic creation of the FX deal in SAP S/4 HANA. The executed trade details can then be displayed on SCP application “Manage Trades”.

Figure 4

Figure 5

Internal trade requests can be automatically fulfilled at a price determined by the business rules defined by the users. This includes pricing based on the associated external deal rate (back-to-back scenario) with a commission, or pricing based on market data with a commission element.

The deals captured in SAP S/4 HANA whether internal or external, all contain the enriched data with all the originating information relating to the trade request, so that the FX deal itself accurately reflects the purpose of the position for further reporting.

Future SAP Roadmap
Although initially only the FX instruments were included in scope, SAP is now extending the ability to execute Money Market Fund purchases and sales through the platform including the associated dividend and rebate flows. This is another step to truly set up the TPI function as a central trade location for front office to operate from, covering not only FX risk requirements, but also the management of cash investment transacting.

Credit risk management is also now on the table, with pre-trade credit risk analyzer information integrated to the TPI application so that counterparty limits may be checked pre-trade to give the opportunity to exclude certain counterparties from quotation. This is certainly an improvement on the historical functionality of SAP TRM where a breach would only be noted after the deal has already been executed.

Conclusion
The recent SAP advancements in the area of TPI provide many opportunities for an organization to incorporate additional control, efficiency and transparency to the dealing process, not only for the front office, but also for the rest of the treasury team. While dealers benefit from a central platform where they can best execute the trades, middle office can get immediate feedback on their FX exposure positions as the deal immediately reflects with the correct characteristics, while the cash management team benefits from a simple ability to request and monitor the FX and investment decisions that have been sent to the dealers. The accounting team stands to benefit greatly as the accounting parameters on the deal are no longer the domain of a front office trader, but rather can be determined by the purpose of the original trade request which dictates the accounting treatment, including the automatic assignment to hedge relationships.

The SAP TPI solution therefore optimizes not only the dealers’ execution role, but also ties together the preceding and dependent processes into one fully straight through process that will benefit the whole treasury organization.

It is no longer just about the source of market data, questions such as integration, validation, storage, consistency and distribution within an organization need to be considered. In this article we will look at some of the considerations when deciding on how to source market data and how in-built applications can reduce risk and cost while improving automation.

Which Market Data Vendor?
There are multiple market data vendors, either directly providing data or consolidating (normalizing) data from multiple sources before making it available to clients. To choose a market data vendor, an organization must firstly understand what the requirements are and this is not only based on the Treasury requirements but wider business and IT requirements:

• What data and when should it be delivered?
• IT capabilities to develop and maintain an interface or leverage inbuilt third party/core application capabilities
• Data validation and distribution

Integration

Market data vendors can provide data using multiple methods, from Excel downloads to a simple file transfer to integrated APIs to import data directly into its applications. The level of integration is driven by the market data requirements, for example, a few FX rates once a month will not justify a level of integration above importing an Excel spreadsheet or even manually entering the rates. However, most organizations require large data sets, sourced on a timely basis and validated without the need for manual intervention.

The way an organization integrates market data will, in some way, depend on the IT strategy and in-house capabilities. Some IT functions have strong in-house development teams capable of building and maintaining APIs to retrieve and import the market data, others will prefer to have the market data integration managed by a third party application. There are costs associated with both options but leveraging the inbuilt capabilities of an application that is already part of the organizations IT landscape can reduce not only the complexity of loading market data but long-term costs of maintaining the solution.

SAP and some top tier TMS applications act as a market data vendor by providing an inbuilt market data interface to access market data. SAP’s Market Rates Management module provides standard integration to both Refinitiv (formerly Thomson Reuters) as well as a more generic option for loading rates from other sources. The key benefit of SAP’s Market Rates Management is that it allows an organization to define its data requirements and import the data from a single source under a single contract while reducing the IT overhead as the module will fall under existing SAP support structures.

Validation and Distribution
Having correct and precise market data is crucial in almost every treasury process while business processes require a consistent data set across all platforms and operations. Market data validation has grown increasingly important, historically, manual, Excel-based or fully bespoke system processes have been used to validate market data, providing a very limited audit trail, introducing user errors and the potential to impact financial postings should an error not be identified. Automated data validation uses rules-based processes executed once the market data has been received that identify, remove, or flag inaccurate or anomalous information, delivering a clean dataset, ensuring the accuracy of the market data in the receiving applications/systems is correct and identical.

The distribution of validated market data to all systems and applications that require it needs to be considered when selecting a market data provider and integration solutions. There may be license implications in distributing data to multiple systems and applications which can increase the recurring costs while the options to distribute the data have the similar IT considerations as the initial integration but potentially on a larger scale, depending on how many different systems and applications require the data. As with the integration to the market data vendor, the ability to leverage 3rd party applications can reduce the costs and complexity of market data distribution.

We can support the validation and distribution process with a tool: Zanders Market Data Platform. This Zanders Inside solution, powered by Brisken, builds a bridge between the market databases and the enterprise application landscape of companies. In this way, the Market Data Platform takes away the operational risks of the market data process. The Market Data Platform runs on the SAP Cloud Platform infrastructure to ensure a secure cloud computing environment to integrate data and business processes to meet all your market data needs.

How does the Market Data Platform work?
The Market Data Platform has many functionalities. First, the platform retrieves the market data from the selected sources. Also, the platform is the source of truth for historical market data, and all activities are logged in the audit center. Subsequently calculations and market data validations are performed. Finally, the hub distributes the market data across the company’s system landscape at the right time and in the right format. The platform can directly be linked to SAP through the cloud connector, and connections to other treasury management systems are also possible, for example with IT2 or with text files. The added value of the Market Data Platform versus other solutions such as SAP Market Rates Management is the additional validation of data e.g., checking completeness and accuracy of the received data on the platform before distributing it for use.

The Zanders Market Data Platform is the solution for your market data validation processes. Would you like to learn more on this new initiative or receive a free demo of our solution? Do not hesitate to reach out to us!

The EBA has recently published the findings and observations from their TRIM on-site inspections. A significant number of deficiencies were identified and are required to be remediated by institutions in a timely fashion.

Since the Global Financial Crisis 2007-09, concerns have been raised regarding the complexity and variability of the models used by institutions to calculate their regulatory capital requirements. The lack of transparency behind the modelling approaches made it increasingly difficult for regulators to assess whether all risks had been appropriately and consistently captured.

The TRIM project was a large-scale multi-year supervisory initiative launched by the ECB at the beginning of 2016. The project aimed to confirm the adequacy and appropriateness of approved Pillar I internal models used by Significant Institutions (SIs) in euro area countries. This ensured their compliance with regulatory requirements and aimed to harmonise supervisory practices relating to internal models.

TRIM executed 200 on-site internal model investigations across 65 SIs from over 10 different countries. Over 5,800 deficiencies were identified. Findings were defined as deficiencies which required immediate supervisory attention. They were categorised depending on the actual or potential impact on the institution’s financial situation, the levels of own funds and own funds requirements, internal governance, risk control, and management.

The findings have been followed up with 253 binding supervisory decisions which request that the SIs mitigate these shortcomings within a timely fashion. Immediate action was required for findings that were deemed to take a significant time to address.

Assessment of Market Risk

TRIM assessed the VaR/sVaR models of 31 institutions. The majority of severe findings concerned the general features of the VaR and sVaR modelling methodology, such as data quality and risk factor modelling.

19 out of 31 institutions used historical simulation, seven used Monte Carlo, and the remainder used either a parametric or mixed approach. 17 of the historical simulation institutions, and five using Monte Carlo, used full revaluation for most instruments. Most other institutions used a sensitivities-based pricing approach.

VaR/sVaR Methodology

Data: Issues with data cleansing, processing and validation were seen in many institutions and, on many occasions, data processes were poorly documented.

Risk Factors: In many cases, risk factors were missing or inadequately modelled. There was also insufficient justification or assessment of assumptions related to risk factor modelling.

Pricing: Institutions frequently had inadequate pricing methods for particular products, leading to a failure for the internal model to adequately capture all material price risks. In several cases, validation activities regarding the adequacy of pricing methods in the VaR model were insufficient or missing.

RNIME: Approximately two-thirds of the institutions had an identification process for risks not in model engines (RNIMEs). For ten of these institutions, this directly led to an RNIME add-on to the VaR or to the capital requirements.

Regulatory Backtesting

Period and Business Days: There was a lack of clear definitions of business and non-business days at most institutions. In many cases, this meant that institutions were trading on local holidays without adequate risk monitoring and without considering those days in the P&L and/or the VaR.

APL: Many institutions had no clear definition of fees, commissions or net interest income (NII), which must be excluded from the actual P&L (APL). Several institutions had issues with the treatment of fair value or other adjustments, which were either not documented, not determined correctly, or were not properly considered in the APL. Incorrect treatment of CVAs and DVAs and inconsistent treatment of the passage of time (theta) effect were also seen.

HPL: An insufficient alignment of pricing functions, market data, and parametrisation between the economic P&L (EPL) and the hypothetical P&L (HPL), as well as the inconsistent treatment of the theta effect in the HPL and the VaR, was seen in many institutions.

Internal Validation and Internal Backtesting

Methodology: In several cases, the internal backtesting methodology was considered inadequate or the levels of backtesting were not sufficient.

Hypothetical Backtesting: The required backtesting on hypothetical portfolios was either not carried or was only carried out to a very limited extent

IRC Methodology

TRIM assessed the IRC models of 17 institutions, reviewing a total of 19 IRC models. A total of 120 findings were identified and over 80% of institutions that used IRC models received at least one high-severity finding in relation to their IRC model. All institutions used a Monte Carlo simulation method, with 82% applying a weekly calculation. Most institutions obtained rates from external rating agency data. Others estimated rates from IRB models or directly from their front office function. As IRC lacks a prescriptive approach, the choice of modelling approaches between institutes exhibited a variety of modelling assumptions, as illustrated below.

Recovery rates: The use of unjustified or inaccurate Recovery Rates (RR) and Probability of Defaults (PD) values were the cause of most findings. PDs close to or equal to zero without justification was a common issue, which typically arose for the modelling of sovereign obligors with high credit quality. 58% of models assumed PDs lower than one basis point, typically for sovereigns with very good ratings but sometimes also for corporates. The inconsistent assignment of PDs and RRs, or cases of manual assignment without a fully documented process, also contributed to common findings.

Modellingapproach: The lack of adequate modelling justifications presented many findings, including copula assumptions, risk factor choice, and correlation assumptions. Poor quality data and the lack of sufficient validation raised many findings for the correlation calibration.

Assessment of Counterparty Credit Risk

Eight banks faced on-site inspections under TRIM for counterparty credit risk. Whilst the majority of investigations resulted in findings of low materiality, there were severe weaknesses identified within validation units and overall governance frameworks.

Conclusion

Based on the findings and responses, it is clear that TRIM has successfully highlighted several shortcomings across the banks. As is often the case, many issues seem to be somewhat systemic problems which are seen in a large number of the institutions. The issues and findings have ranged from fundamental problems, such as missing risk factors, to more complicated problems related to inadequate modelling methodologies. As such, the remediation of these findings will also range from low to high effort. The SIs will need to mitigate the shortcomings in a timely fashion, with some more complicated or impactful findings potentially taking a considerable time to remediate.

With the introduction of the new cash management in S/4HANA in 2016, SAP has announced the bank account management functionality, which treats house bank accounts as master data. With this change of design, SAP has aligned the approach with other treasury management systems on the market moving the bank account data ownership from IT to Treasury team.