With historically low interest rates and radically uncertain times during and after the COVID-19 crisis, which in turn is leading to unpredictable customer behaviours, it is increasingly prudent for ADIs to proactively monitor their business risks associated with lending and borrowing that depend on interest rate movements and customer behavioural changes. Similar to other risks associated with the banking business such as Credit/Market/Liquidity/Operational risks, ADIs should be simulating the impact on
their interest rate related risk profile by considering macro-economic outlook into their scenarios and take appropriate actions to mitigate any short term or long-term impacts that is beyond the risk appetite of the bank.
In Australia, APRA has outlined the revised draft Australian version of IRRBB standards in APS117 that considers the finalised BASEL III norms for IRRBB as well as the local nuances in the Industry and regulations. APRA initiated its consultation process on IRRBB back in Feb 2018 as part of the overall BASEL related revisions to the capital regulatory framework. Subsequently APRA provided a formal response to the feedbacks received through the consultation on 4 September 2019. APRA intends to finalise the consultation process in 2020 and publish the revised prudential practice guide and reporting standards.
IRRBB requirements will be applicable to all ADI’s. Branches of foreign banks and smaller ADI’s in particular may find the IRRBB requirements challenging to implement.
Due to COVID-19, APRA has delayed the implementation of these standards in Australia to 1 January 2023. While this is a welcome move, the changes proposed under these regulations will need to be carefully evaluated by all ADIs to assess business readiness to adopt these standards from process, technology and people point of view. In summary, the key proposals are to:
standardise aspects of the internal modelling approach including placing constraints on the repricing assumptions an ADI can use for non-maturity deposits according to whether or not it is a core deposit and the calculations for optionality risk;
remove the basis risk capital add-on; and
extend the application of risk management requirements to all ADIs. Standardised ADIs will not be subject to an IRRBB capital charge unless APRA determines otherwise.
According to APRA, the above proposed changes are unlikely to materially impact capital allocations for ADIs. However, the key consideration for ADIs here is the operational readiness and cost considerations to fulfil this obligation. In particular for smaller ADIs and foreign bank branches who are also now required to apply the risk management requirements.
In our recently published whitepaper, we discussed the key requirements around interest rate risk in the banking book (IRRBB) and highlighted the need for ADIs to strategically consider the process, tools and methodologies applied in assessing, monitoring and managing this risk efficiently and in a timely manner during the current
environment. To learn more about the short & long term impacts of interest rate in the banking book, please download our whitepaper here.