Risk Management By Tariq Ullah Khan
ISLAMIC DEVELOPMENT BANK
ISLAMIC RESEARCH AND TRAINING INSTITUTE
RISK MANAGEMENT
AN ANALYSIS OF ISSUES IN
ISLAMIC FINANCIAL INDUSTRY
TARIQULLAH KHAN
HABIB AHMED
OCCASIONAL PAPER
NO. 5
JEDDAH - SAUDI ARABIA
1422H (2001)
© Islamic Research and Training Institute, 2001
Islamic Development Bank
King Fahd National Library Cataloging-in-Publication data
Khan, Tariqullah
Risk Management: An Analysis of Issues in Islamic Financial Industry
Tariqullah Khan and Habib Ahmed - Jeddah
183 P; 17 x 24 cm
ISBN: 9960-32-109-6
Risk Management - Religious Aspects
Business Enterprises; Finance - Religious Aspects
I- Ahmed, Habib (j.a.) II-Title
658.155 dc 2113/22
Legal Deposit No. 2113/22
ISBN: 9960-32-109-6
______________________________________________________________________________
The findings, interpretations and conclusions expressed in this paper are entirely those of the
authors. They do not necessarily represent the views of the Islamic Development Bank, its member
countries, and the Islamic Research and Training Institute.
References and citations from this study are allowed but must be properly acknowledged.
First Edition
1422H (2001)
1
ABOUT THE AUTHORS
TARIQULLAH KHAN HABIB AHMED
Born in Chitral, Pakistan (1954), is a Born in Chittagong, Bangladesh (1959) is an
member of IRTI’s research staff since Economist at the Islamic Research and
Muharram 1404H (October 1983). Before Training Institute (IRTI) of the Islamic
joining IRTI, he was in the faculty of the Development Bank. He has an M.A.
Economics Department, Gomal (Economics) from University of Chittagong,
University, Pakistan (1976-81), and Bangladesh, Cand. Oecon. (M.Econ.) from
International Institute of Islamic University of Oslo, Norway, and Ph.D. from
Economics, International Islamic University of Connecticut, USAUnited States of America. Before
University, Pakistan (1981-83), teaching joining IRTI in February 1999, he taught at
in particular, monetary, development and the University of Connecticut, USAUnited States of America, Eastern
international economics. He has an M.A. Connecticut State University, USAUnited States of America, National
(Economics) degree from the University University of Singapore, and University of
of Karachi, Pakistan, and a Ph.D. degree Bahrain. He taught various courses on
from the Loughborough University, Economics including Business Cycles and
United Kingdom. At IRTI, his research Forecasting, Economic Development,
interest has been in the area of theoretical International Finance, Macroeconomics,
developments in Islamic finance and its Money and Banking, and Quantitative
practical challenges in an international, Economics. He has published articles in
mixed and competitive market and international refereed journals such as
regulatory environments. In this area, Applied Economics, Applied Economics
some of his recent research works Letters, Contemporary Economic Policy,
published by IRTI include: “Demand for Economics Letters, Journal of Economics
and Supply of Mark-up and PLS Funds in and Business, Journal of International Trade
Islamic Banks” (1995), Performance and and Economic Development, and Savings and
Practices of Modaraba Companies With Development. His current research interests
Special Reference to Pakistan (1996), are Islamic Economics and Finance. Couple
Interest-free Alternatives for External of his recent publications in Islamic
Resource Mobilization with Special Economics and Finance include Exchange
Reference to Pakistan (1997), Regulation Rate Stability: Theory and Policies from an
and Supervision of Islamic Banks (2000) Islamic Perspective and “Incentive
with M. Umer Chapra and “Islamic Quasi Compatible Profit-Sharing Contracts: A
Equity (Debt) Instruments” (2000). Theoretical Treatment”.
E-mail: [email protected] E-mail: [email protected]
ISLAMIC DEVELOPMENT BANK
ISLAMIC RESEARCH AND TRAINING INSTITUTE
Postal Address: P.O. Box 9201, Jeddah 21413
Kingdom of Saudi Arabia
Cable Address: BANKISLAMI-Jeddah Telephone: 6361400
Telex: 601137/601945 Facsimile: 6378927 / 6366871
E. Mail: [email protected] Home Page: http://www.irti.org/
Legal Deposit no.2113/22
ISBN: 9960-32-109-6
2
CONTENTS
Pages
ACKNOWLEDGEMENTS 7
FOREWORD 9
GLOSSARY 11
ABBREVIATIONS 15
EXECUTIVE SUMMARY 17
I. Introduction 21
1.1 Unique nature of Islamic banking risks 21
1.2 Systemic importance of Islamic banks 22
1.3 Objectives of the paper 23
1.4 Outline of the paper 24
II. Risk Management: Basic Concepts and Techniques 25
2.1 Introduction 25
2.2 Risks faced by financial institutions 27
2.3 Risk management: background and evolution 28
2. 4 Risk management: the process and system 30
2.4.1 Establishing appropriate risk management environment
and sound policies and procedures 30
2.4.2 Maintaining an appropriate risk measurement, mitigating,
and monitoring process
31
2.4.3 Adequate internal controls
32
2.5 Management processes of specific risks
32
2.5.1 Credit risk management
32
2.5.2 Interest rate risk management
34
2.5.3 Liquidity risk management
36
2.5.4 Operational risk management
38
2.6 Risk management and mitigation techniques
39
2.6.1 GAP analysis
39
2.6.2 Duration-gap analysis
3
2.6.3 Value at risk (VaR) 40
2.6.4 Risk adjusted rate of return (RAROC) 41
2.6.5 Securitization 42
2.6.6 Derivatives 44
2.6.6.1 Interest-rate swaps 46
2.6.6.2 Credit derivatives 47
2.7 Islamic financial institutions: nature and risks 49
2.7.1 Nature of risks faced by Islamic banks 49
2.7.2 Unique counterparty risks of Islamic modes of finance 51
2.7.2.1 Murāba ah financing 53
2.7.2.2 Salam financing 54
2.7.2.3 Isti nā‘ financing 54
2.7.2.4 Mushārakah - Muārabah (M-M) financing 55
III. Risk Management: A Survey of Islamic Financial Institutions 56
3.1 Introduction 59
3.2 Risk perceptions 59
3.2.1 Overall risks faced by Islamic financial institutions 60
3.2.2 Risks in different modes of financing 61
3.2.3 Additional issues regarding risks faced by Islamic 62
financial institutions
3.3 Risk management system and process 65
3.3.1 Establishing appropriate risk management environment 66
and sound policies and procedures
3.3.2 Maintaining an appropriate risk measurement, mitigating,
and monitoring process 66
3.3.3 Adequate internal controls 67
3.4 Other issues and concerns 71
3.5 Risk management in Islamic financial institutions: an 72
assessment
IV. Risk Management: Regulatory Perspectives 75
4.1 Economic rationale of regulatory control on bank risks 77
4.1.1 Controlling systemic risks 77
4.1.2 Enhancing the public’s confidence in markets 77
4
4.1.3 Controlling the risk of moral hazard 79
4.2 Instruments of regulation and supervision 81
4.2.1 Regulating risk capital: current standards and new 82
proposals 82
4.2.1.1 Regulatory capital for credit risk: present standards
4.2.1.2 Reforming regulatory capital for credit risk: the 83
Proposed New Basel Accord
4.2.1.3 Treatment of credit risk under the Proposed New
Accord 84
4.2.1.4 Regulatory treatment of market risk 86
4.2.1.5 Banking book interest rate risk 91
4.2.1.6 Treatment of securitization risk 92
4.2.1.7 Treatment of operational risks 93
4.2.2 Effective supervision 93
4.2.3 Risk disclosures: enhancing transparency about the future 94
4.3 Regulation and supervision of Islamic banks 98
4.3.1 Relevance of the international standards for Islamic banks 102
4.3.2 The present state of Islamic banking supervision 102
4.3.3 Unique systemic risk of Islamic banking 103
4.3.3.1 Preventing risk transmission 105
4.3.3.2 Preventing the transmission of risks to demand 106
deposits
4.3.3.3 Other systemic considerations 109
V. Risk Management: Fiqh Related Challenges 112
5.1 Introduction 113
5.1.1 Attitude towards risk 113
5.1.2 Financial risk tolerance 113
5.2. Credit risks 115
5.2.1 Importance of expected loss calculation 116
5.2.2 Credit risk mitigation techniques 116
5.2.2.1 Loan loss reserves 117
5.2.2.2 Collateral 117
5.2.2.3 On-balance sheet netting 118
5
5.2.2.4 Guarantees 121
5.2.2.5 Credit derivatives and securitization 121
5.2.2.6 Contractual risk mitigation 123
5.2.2.7 Internal ratings 125
5.2.2.8 RAROC 126
5.2.2.9 Computerized Models 128
5.3 Market risks 129
5.3.1 Business challenges of Islamic banks: a general observation 129
5.3.2 Composition of overall market risks 129
5.3.3 Challenges of benchmark rate risk management 131
5.3.3.1 Two-step contracts and GAP analysis 132
5.3.3.2 Floating rate contracts 133
5.3.3.3 Permissibility of swaps 135
5.3.3 Challenges of managing commodity and equity price risks 135
5.3.3.1 Salam And commodity futures 137
5.3.3.2 Bay‘ al -Tawrīd with Khiyār al-shar 138
5.3.3.3 Parallel contracts 139
5.3.4 Equity price risks and the use of Bay‘al‘arboon 140
5.3.5 Challenges of managing foreign exchange risk 143
5.3.5.1 Avoid transaction risks 143
5.3.5.2 Netting 144
5.3.5.3 Swap of liabilities 144
5.3.5.4 Deposit swap 144
5.3.5.5 Currency forwards and futures 145
5.3.5.6 Synthetic forward 145
5.3.5.7 Immunization 146
5.4 Liquidity risk 146
VI. Conclusions 146
6.1 The environment 151
6.2 Risks faced by the Islamic financial institutions 151
6.3 Risks management techniques 152
6.4 Risk perception and management in Islamic banks 152
6
6.5 Regulatory concerns with risks management 152
6.6 Instruments of risk-based regulation 153
6.7 Risk-based regulation and supervision of Islamic banks 154
6.8 Risk management: Sharī‘ah -based challenges 154
155
VII. Policy Implications
7.1 Management responsibility 157
7.2 Risk reports 157
7.3 Internal ratings 157
7.4 Risk disclosures 158
7.5 Supporting institutions and facilities 158
7.6 Participation in the process of developing the international 158
standards
7.7 Research and training 159
159
Appendix 1: List of financial institutions included in the study
Appendix 2: Samples of risk reports 161
Appendix 3: Questionnaire 163
Bibliography 167
177
7
ACKNOWLEDGEMENTS
A number of people have contributed with comments, suggestions, and
input at different stages of writing of this paper. We would like to thank the
members of the Policy Committee of Islamic Development Bank (IDB) and our
colleagues of the Islamic Research and Training Institute (IRTI) who gave
valuable suggestions on the proposal of the paper.
The study surveyed risk management issues on Islamic financial
institutions. We are grateful to all Islamic banks that have responded to our
questionnaires. These banks include AlBaraka Bank Bangladesh Limited,
ALBaraka Turkish Finance House, Turkey, Meezan Investment Bank Limited,
Pakistan, Badr Forte Bank, Russia, Islami Bank Bangladesh Limited, Kuwait
Turkish Evkaf Finans House, Turkey, and Tadamon Islamic Bank, Sudan. We
had also visited several Islamic financial institutions in four countries to
interview the officials and collect information on risk management issues in
these institutions. We gratefully acknowledge their cooperation and assistance in
providing us with all the relevant information. Among the banks and officials
who deserve special mention are the following:
ABC Islamic Bank, Bahrain: Mr. Hassan A. Alaali (Executive Director).
Abu Dhabi Islamic Bank, UAE: Abdul-Rahman Abdul-Malik (Chief
Executive), Badaruzzaman H. A. Ahmed (Vice President, Internal Audit
Dept.), Ken Baldwin (Manager, ALM), Ahmed Masood (Manager
Strategic Planning) and Asghar Ijaz (Manager Special Projects).
AlBaraka Islamic Bank, Bahrain: Abdul Kader Kazi (Senior Manager,
International Banking).
Bahrain Islamic Bank, Bahrain: Abdulla AbolFatih (General Manager),
Abdulla Ismail Mohd. Ali (Credit Manager), Jawaad Ameeri (Credit
Department Supervisor), and Adnan Abdulla Al-Bassam (Internal Audit
Department Manager).
Bahrain Monetary Authority, Bahrain: Anwar Khalifa al Sadah (Director,
Financial Institutions Supervision Directorate).
Bank Islam Malaysia Berhad, Kuala Lumpur, Abdul Razak Yaakub,
Head, Risk Management Department.
Citi Islamic Investment Bank, Bahrain: Aref A. Kooheji (Vice President,
Global Islamic Finance).
8
Dubai Islamic Bank, UAE: Buti Khalifa Bin Darwish (General Manager).
Faisal Islamic Bank Egypt, Cairo, Tag ElDin. A. H. Sadek, Manager
Foreign Department.
First Islamic Investment Bank, Bahrain: Alan Barsley and Shahzad Iqbal.
Investors Bank, Bahrain: Yash Parasnis (Head of Risk Management).
Islamic Development Bank, Jeddah, Saudi Arabia.
Shamil Bank of Bahrain, Bahrain: Dr Saad S. AlMartaan (Chief
Executive) and Ghulam Jeelani (Assistant General Manager, Risk
Management).
Earlier drafts of this paper were presented at the IRTI seminar and IDB’s
Policy Committee meeting. We would like to thank Mabid Ali al-Jarhi, Boualem
Bendjilali, M. Umer Chapra, Hussien Kamel Fahmy, Munawar Iqbal, and M.
Fahim Khan from IRTI and the members of the Bank’s Policy Committee for
their valuable comments and suggestions. We are also grateful to Sami
Hammoud, Consulting Expert on Islamic Banking and Finance, Zamir Iqbal,
World Bank, Professor Mervyn K. Lewis, University of South Australia, and
David Marston, International Monetary Fund (IMF), who as external referees
gave thoughtful comments and suggestions on the paper. We are also thankful to
Mr. Syed Qamar Ahmad for proof reading the final version of the paper.
The comments and suggestions of these scholars were helpful in revising
the paper. The views expressed in the paper, however, do not reflect their views,
nor of IRTI or IDB. Views expressed and any remaining errors in the final draft
are those of the authors only.
Jumada' II 29, 1422H TARIQULLAH KHAN
September 17, 2001 HABIB AHMED
9
FOREWORD
The Islamic financial industry is growing continuously ever since the
first institutions started operating during the early Seventies. At the present, most
Islamic financial services are being provided in almost all parts of the world by
different financial institutions. Standards for financial reporting, accounting and
auditing have already been put in place. Progress is being made in establishing
an Islamic capital and inter-bank money market, an Islamic rating agency and an
Islamic financial services supervisory board. These developments imply that the
Islamic financial industry has become systemically important for the
international financial system.
Due to its special treatment of different risks, asset-based nature and the
strong concerns of clients for Islamic values, the concept of Islamic finance
contains inherent features that enhance market discipline and financial stability.
However, due to the relatively new microstructures of the Islamic modes of
finance and the unique risk characteristics of liabilities and assets, the Islamic
financial industry also poses a number of systemic risks. Research studies can be
instrumental in strengthening its stabilizing features and in mitigating the
potential sources of instability. As a result, the stability of financial markets can
be enhanced along with attaining the objective of growth. This is important for
the industry's sustained growth and its contribution to the stability and efficiency
of the international financial markets.
With such a background, the Board of Executive Directors of the
Islamic Development Bank (IDB), asked IRTI to conduct a research dealing
with risk management issues of the Islamic financial industry. As a result,
Tariqullah Khan and Habib Ahmed - researchers at the Institute have prepared
the present paper. Indeed, the subject is very important and the authors have
attempted to undertake a comprehensive stock taking and analysis of some of the
relevant issues. Standard setters, Sharī‘ah scholars, policy makers, practitioners,
academia and researchers may find the work relevant. It is hoped that the study
will be instrumental in motivating to conduct more research in this important
area.
Mabid Ali Al-Jarhi
Director, IRTI
10
11
GLOSSARY
(ARABIC TERMS USED IN THE PAPER)
al khirāju bi al- : These are the two fundamental axioms of Islamic finance
amān and al implying that entitlement to return from an asset is
ghunmu bi al intrinsically related to the liability of loss of that asset.
ghurm
‘arboon, bay‘ : A sale contract in which a small part of the price is paid
al- as an earnest money (down payment), the object and its
remaining price are exchanged in a future date. In case
the buyer rescinds from the contract he has to forego the
earnest money compensating the seller in causing a delay
in sale.
Band al-I sān : Beneficence clause in a Salam contract used in the Sudan.
It is aimed at compensating the party to the contract that
is adversely affected due to changes in prices between
signing the contract and its final settlement.
Band al-Jazāa : Penalty clause in an Isti nā‘ to ensure contract
enforceability.
Bay‘ : Stands for sale and has been used here as a prefix in
referring to the different sale-based modes of Islamic
finance, like Murāba ah, Ijārah, Isti nā‘ and Salam.
Fiqh : Refers to the whole corpus of Islamic jurisprudence. In
contrast with conventional law, Fiqh covers all aspects of
life, religious, political, social or economic. In addition to
religious observances like prayer, fasting, Zakāh and
pilgrimage, it also covers family law, inheritance, social
and economic rights and obligations, commercial law,
criminal law, constitutional law and international
relations, including war. The whole corpus of Fiqh is
based primarily on interpretations of the Qur’an and the
Sunnah and secondarily on Ijmā‘ (consensus) and Ijtihād
(individual judgement). While the Qur’an and the Sunnah
are immutable, Fiqhī verdicts may change due to
changing circumstances.
Gharar : Uncertainty of outcome caused by ambiguous conditions
in contracts of deferred exchange.
12
Ijārah, bay‘ al- : Sale of usufructs (operating lease).
Isti nā‘ , bay‘ : Refers to a contract whereby a manufacturer (contractor)
al- agrees to produce (build) and deliver a certain good or
premise at a given price on a given date in the future.
This is an exception to the general Sharī‘ah ruling which
does not allow a person to sell what he does not own and
possess. As against Salam, the price here need not be
paid in advance. It may be paid in installments, in steps
with the preferences of the parties or partly at the front
end and the balance later on as agreed.
Ju‘ālah : Service contract, performing a given task for a fee.
Khiyār al-shar : The option to rescind from a sale contract based on some
conditions stipulated by one party without fulfilling,
which a party can rescind from the contract.
Muārabah : An agreement between two or more persons whereby one
or more of them provide finance, while the others provide
entrepreneurship and management to carry on any
business venture whether trade, industry or service, with
the objective of earning profits. The profit is shared by
them in an agreed proportion. The loss is borne only by
the financiers in proportion to their share in total capital.
The entrepreneur’s loss lies in not getting any reward for
his/her services.
Murāba ah, : Sale at a specified profit margin. The term is, however,
bay‘ al- now used to refer to a sale agreement whereby the seller
purchases the goods desired by the buyer and sells them
at an agreed marked-up price, the payment being settled
within an agreed time frame, either in installments or
lump sum. The seller bears the risk for the goods until
they have been delivered to the buyer. Murāba ah is also
referred to as bay‘al mu‘ajjal.
13
Mushārakah : An Islamic financing technique whereby all the partners
share in equity as well as management. The profits can be
distributed among them in accordance with agreed ratios.
However, losses must be shared according to the share in
equity.
Qar asan : A loan extended without interest or profit sharing.
Rahn : Collateral.
Ribā : Literally means increase or addition, and refers to the
‘premium’ that must be paid by the borrower to the
lender along with the principal amount as a condition for
the loan or an extension in its maturity. It is regarded by
a predominant majority of Muslims to be equivalent to
interest.
Salam, bay‘ al- : Sale in which payment is made in advance by the buyer
and the delivery of goods is deferred by the seller. This
is also, like Isti nā‘, an exception to the general Sharī‘ah
ruling that you cannot sell what you do not own and
possess.
Sharī‘ah : Refers to the divine guidance as given by the Qur’an and
the Sunnah and embodies all aspects of the Islamic faith,
including beliefs and practices.
Tawrīd, bay‘ : Contractual sale in which known quality and amount of
al- an object is supplied by a supplier for a known price to be
paid on an agreed upon periodic schedule.
Wakālah : Agency - appointment of someone else to render a work
on behalf of the principal for a fee.
14
15
ABBREVIATIONS
AAOIFI Accounting & Auditing Organization for Islamic Financial
Institutions
BCBS: Basel Committee for Banking Supervision
BIA: Basic Indicator Approach
BIS: Bank for International Settlements
BMA: Bahrain Monetary Agency
CA: Capital Arbitrage
CAMELS: Capital, Assets, Management, Earnings, Liquidity, and
Sensitivity to risk
CAPM: Capital Asset Pricing Model
DGAP: Duration Gap
EAD: Exposure at Default
EL: Expected Loss
FIs: Financial Institutions
FTSE: Financial Times Stock Exchange
G10: Group of Ten
GDP: Gross Domestic Product
HSBC: Hong Kong Shanghai Banking Corporation
IAIB: International Association of Islamic Banks
IAIS: International Association of Insurance Supervisors
IASC: International Accounting Standards Committee
IASs: International Accounting Standards
IDB: Islamic Development Bank
IMA: Internal Management Approach
IMF: International Monetary Fund
IOSCO: International Organization of Securities Commissioners
IRB: Internal Rating Based
IRTI: Islamic Research and Training Institute
ISDA: International Swap & Derivatives’ Association
JFFC: Joint Forum on Financial Conglomerates
LDA: Loss Distribution Approach
LGD: Loss Given Default
LIBOR: London Inter-bank Offered Rate
LLR: Lender of Last Resort
LR: Leverage Ratio
16
LTCM: Long Term Capital Management
MCM: Murāba ah Clearing Market
MDB: Multilateral Development Banks
M-M: Muārabah - Mushārakah
MOF: Maturity of Facility
ODS: Object Deferred Sale
OECD: Organization for Economic Co-operation and Development
OIC: Organization of Islamic Conference
OTC: Over the Counter
PD: Probability of Default
PLS: Profit-and-Loss Sharing
PPFs: Principal Protected Funds
RAROC: Risk Adjusted Rate of Return on Capital
RSA: Rate Sensitive Assets
RSL: Rate Sensitive Liabilities
RWA: Risk Weighted Assets
SA: Standard Approach
SPV: Special Purpose Vehicle
UAE: United Arab Emirates
UL: Unexpected Loss
VaR: Value at Risk
WL: Worst Loss
17
EXECUTIVE SUMMARY
Islamic financial industry has come a long way during its short history.
The future of these institutions, however, will depend on how they cope with the
rapidly changing financial world. With globalization and informational
technology revolution, scopes of different financial institutions have expanded
beyond national jurisdictions. As a result, the financial sector in particular has
become more dynamic, competitive, and complex. Moreover, there is a rapidly
growing trend of cross-segment mergers, acquisitions and financial
consolidation, which blurs the unique risks of the various segments of the
financial industry. Furthermore, there has been an unprecedented development in
computing, mathematical finance and innovation of risk management
techniques. All these developments are expected to magnify the challenges that
Islamic financial institutions face particularly as more well established
conventional institutions have started to provide Islamic financial products.
Islamic financial institutions need to equip themselves with the up-to-date
management skills and operational systems to cope with this environment. One
major factor that will determine the survival and growth of the industry is how
well these institutions manage the risks generated in providing Islamic financial
services.
Studying risk management issues of the Islamic financial industry is an
important but complex subject. The present paper discusses and analyzes a
number of issues concerning the subject. First, it presents an overview of the
concepts of risks and risk management techniques and standards as these exist in
the financial industry. Second, the unique risks of the Islamic financial services
industry and the perceptions of Islamic banks about these risks are surveyed
through a questionnaire and analyzed. Third, the main regulatory concerns with
respect to risks and their treatment with a view to draw some lessons for Islamic
banks are discussed. Fifth, a number of Sharī‘ah related challenges concerning
risk management are identified and discussed. Finally, conclusions and policy
implications are summarized.
The study concludes that financial markets liberalization is associated
with an increase in risks and financial instability. Risk management processes
and techniques enable financial institutions to control undesirable risks and to
take benefit of the business opportunities created by the desirable ones. These
18
processes are of important concern for regulators and supervisors as these
determine the overall efficiency and stability of the financial systems.
The study shows that the Islamic financial institutions face two types of
risks. The first type of risks they have in common with traditional banks as
financial intermediaries, such as credit risk, market risk, liquidity risk and
operational risk. However, due to Sharī‘ah compliance the nature of these risks
changes. The second type is of new and unique risks that the Islamic banks face
as a result of their unique asset and liability structures. Consequently the
processes and techniques of risk identification and management available to the
Islamic banks could be of two types – standard techniques which are not in
conflict with the Islamic principles of finance and techniques which are new or
adapted keeping in view their special requirements.
Due to their unique nature, the Islamic institutions need to develop more
rigorous risk identification and management systems. The paper identifies a
number of policy implications the implementation of which can be instrumental
in promoting a risk management culture in the Islamic financial industry.
i. The management of all banks need to create a risk management
environment by clearly identifying the risk objectives and strategies of
the institution and by establishing systems that can identify, measure,
monitor, and manage various risk exposures. To ensure the effectiveness
of the risk management process, Islamic banks also need to establish a
proficient internal control system.
ii. Risk reporting is extremely important for the development of an efficient
risk management system. The risk management systems in Islamic
banks can be substantially improved by allocating resources for
preparing a number of periodic risk reports such as capital at risk
reports, credit risk reports, operational risk reports, liquidity risk reports
and market risk reports.
iii. An Internal Rating System (IRS) is highly relevant for the Islamic
banks. At initial stages of its introduction the IRS may be seen as a risk
based inventory of individual assets of a bank. Such systems have
proved highly effective in filling the gaps in risk management systems
hence in enhancing external rating of institutions. This contributes to
cutting the cost of funds. Internal rating systems are also very relevant
for the Islamic modes of finance. Most Islamic banks already use some
19
form of internal ratings. However, these systems need to be strengthened
in all Islamic banks.
iv. Risk-based management information, internal and external audit, and
asset inventory systems can greatly enhance risk management systems
and processes.
v. Substantial risks faced by the Islamic banks can be reduced if a number
of supporting institutions and facilities are provided. These include a
lender of last resort facility, deposit protection system, liquidity
management system, legal reforms to facilitate Islamic banking and
dispute settlement, uniform Sharī‘ah standards, adoption of AAOIFI
standards and establishing a supervisory board for the industry.
vi. The Islamic financial industry being a part of the global financial
markets is effected by the international standards. It is thus imperative
for the Islamic financial institutions to follow-up the process of standard
setting and to respond to the consultative documents distributed in this
regard by the standard setters on a regular basis.
vii. Risk management systems strengthen financial institutions. Therefore,
risk management needs to be assigned a priority in research and training
programs.
20
21
I
INTRODUCTION
Islamic financial institutions were established three decades ago as an
alternative to conventional financial institutions mainly to provide Sharī‘ah
compatible investment, financing, and trading opportunities. During its short
history, the growth in the nascent banking industry has been impressive. One of
the main functions of financial institutions is to effectively manage risks that
arise in financial transactions. To provide financial services at low risk,
conventional financial institutions have developed different contracts, processes,
instruments, and institutions to mitigate risks. The future of the Islamic financial
industry will depend to a large extent on how these institutions will manage
different risks arising from their operations.
1.1 UNIQUE NATURE OF ISLAMIC BANKING RISKS
A distinction between theoretical formulations and actual practices of
Islamic banking can be observed. Theoretically, it has been an aspiration of
Islamic economists that on the liability side, Islamic banks shall have only
investment deposits. On the asset side, these funds would be channeled through
profit sharing contracts. Under such a system, any shock on the asset side shall
be absorbed by the risk sharing nature of investment deposits. In this manner,
Islamic banking offers a more stable alternative to the traditional banking
system. The nature of systemic risks of such a system would be similar to the
risks inherent in mutual funds.
The focus of this study is on the actual practices of Islamic banks. The
practice of Islamic banking, however, is different from the theoretical
aspirations. On the assets side, investments can be undertaken using profit
sharing modes of financing (Muārabah and Mushārakah) and fixed-income
modes of financing like Murāba ah (cost-plus or mark-up sale), installment sale
(medium/long term Murāba ah), Isti nā‘/ Salam (object deferred sale or pre-
paid sale) and Ijārah (leasing). The funds are provided only for such business
activities which are Sharī‘ah compatible. On the liability side, deposits can be
made either in current accounts or in investment accounts. The former is
considered in Islamic banks as Qar asan (interest-free loan) or Amānah
(trust). These have to be fully returned to depositors on demand. Investment
depositors are rewarded on the basis of profit and loss sharing (PLS) method and
22
these deposits share the business risks of the banking operations. Using profit
sharing principle to reward depositors is a unique feature of Islamic banks. This
feature along with the different modes of financing and the Sharī‘ah compliant
set of business activities change the nature of risks that Islamic banks face.
1.2 SYSTEMIC IMPORTANCE OF ISLAMIC BANKS
The Islamic financial services industry comprises of Islamic commercial
and investment banks, windows of conventional banks offering Islamic financial
services, mutual and index funds, leasing and Muārabah companies and
Islamic insurance companies. The present paper specifically deals with the risks
facing the Islamic commercial and investment banks.
Since its beginning in the early 1970s, the growth of the Islamic
financial industry has been robust. While some countries have introduced
Islamic financial services along with conventional ones, three countries (Iran,
Pakistan, and Sudan) have opted for comprehensive reforms with the objective
of transforming their financial systems to an Islamic one. According to the
International Association of Islamic Banks (IAIB), the number of Islamic
financial institutions stood at 176 at the end of 1997.1 These financial institutions
had a combined capital of US$ 7.3 billion and assets and liabilities worth US$
147.7 billion. In 1997, Islamic banks managed funds worth US$ 112.6 billion
making a net profit of US$ 1.2 billion. The historical data on these financial
variables is given in Table 1.1.
Table 1.1
Size of Islamic Financial Institutions
Some Financial Highlights (Amount in US$ Million)
Year No. of Combined Combined Combined Combined
Banks Capital Assets Funds Net
Managed Profits
1993 100 2,309.3 53,815.3 41,587.3 N.A.
1994 133 4,954.0 154,566.9 70,044.2 809.1
1995 144 6,307.8 166.053.2 77,515.8 1,245.5
1996 166 7271.0 137,132.5 101,162.9 1,683.6
1997 176 7333.1 147,685.0 112,589.8 1,218.2
Source: Directory of Islamic Banks and Financial Institutions-1997, The International Association
of Islamic Banks, Jeddah.
١
The data collected by the IAIB is available only up to 1997 and the IAIB is no more
operational.
23
During a short history of its existence, the Islamic banks have performed
reasonably well. A recent study on the performance of Islamic banks shows that
these institutions are well capitalized, profitable and stable2. Furthermore, this
paper indicates that Islamic banks have not only grown at a faster rate than their
conventional counterparts, but have also outperformed them in other criteria. On
the average, Islamic banks have larger capital-asset ratios and have used their
resources better than conventional banks. Furthermore, the Islamic institutions
have yielded profitability ratios that are superior to those of traditional banks.
Linear and exponential forecasts from the data in Table 1.1 indicate that
the estimate of capital of Islamic financial institutions is valued between US$ 13
billion and US$ 23.5 billion in 2002.3 The corresponding projections for assets
held by these institutions are US$ 198.6 billion and US$ 272.7 billion
respectively in the same year. Given the performance and the potential market of
Islamic financial services, Islamic banking sector has grown at a fast pace and
rapidly gained global dimension. This is witnessed by the involvement of many
multinational financial institutions like ANZ Grindlays, Chase Manhattan,
Citicorp, Commerzbank AG, HSBC, and Morgan Stanley Dean Witter & Co. in
Islamic products. Major world stock exchanges like Dow Jones and FTSE
having introduced Islamic indices.
1.3 OBJECTIVES OF THE PAPER
While Islamic banks being commercial enterprises would be more
concerned with growth of assets and profitability, regulators would prefer the
banks to be more stable and have growth as secondary concern. Due to the
unprecedented developments in the areas of computing, information and
mathematical finance, the financial services markets have become extremely
complex. Moreover, cross-segment mergers, acquisitions, and financial
consolidation have blurred the risks of various segments of the industry.
Given this complexity, dynamism, and transformation in the financial
sector there are several questions that can be raised related to Islamic banks.
How do the Islamic banks perceive their own risks and these various
developments? How regulators expect to respond to the new risks inherent in
Islamic banks? What possible Sharī‘ah compatible risk management instruments
٢
For details, see Iqbal (2000).
٣
While linear projections are estimated assuming constant growth rate, the exponential
forecasts are the optimistic figures estimated by assuming exponential growth. Note that
given the small number of observations, these forecasts should be taken as indicative only.
24
are available at the present? What are the prospects of exploring new
instruments in the future? What are the implications of all these for the
competitiveness of Islamic banks? How is stability of the Islamic financial
institutions going to be affected? The objective of the present paper is to address
some of these questions. Specifically the paper aims at the following:
i. Presenting an overview of the concepts of risks and risk management
techniques and standards as these exist in the financial industry.
ii. Discussing the unique risks of the Islamic financial services industry and
the perceptions of Islamic banks about these risks.
iii. Reviewing the main regulatory concerns with respect to risks and their
treatment with a view to draw some lessons for Islamic banks.
iv. Discussing and analyzing the Sharī‘ah related challenges concerning
risk management in the Islamic financial services industry and
v. Presenting policy implications for developing a risk management culture
in Islamic banks.
1.4 OUTLINE OF THE PAPER
In section two, we discuss the basic concepts of risks and their
management as practiced in the conventional financial sector. This section also
provides details of the various processes to manage different risks. The section
ends with identifying the nature of risks found in Islamic financial institutions
and instruments. Section three, reports results from a survey on risk management
issues in Islamic financial institutions. The survey covered 17 Islamic
institutions from 10 different countries. The results covers the perspectives of
Islamic bankers towards different risks, the process of risk management in these
institutions, and some other aspects related to Islamic financial institutions.
Section four discusses the risk management aspects from the regulatory
viewpoints. Based on, among others, the proposals of Basel Committee, the
section touches on the regulatory aspects for Islamic financial institutions.
Among others, it covers issues related to capital requirements in Islamic
financial institutions and different approaches to manage various risks. Section
five covers some Fiqhī issues related to risk management. Other than pointing
out the Sharī‘ah viewpoints towards different techniques and instruments used
for risk mitigation, proposals are made on developing new techniques. Some
suggestions are also given for consideration of Sharī‘ah experts to deliberate on.
The last section concludes the paper and presents policy implications for
developing risk management culture in Islamic banks.
25
II
RISK MANAGEMENT:
BASIC CONCEPTS AND TECHNIQUES
In this section we discuss the basic risk concepts and issues related to
risk management. After defining and identifying different risks, we describe the
risk management process. Risk management process is a comprehensive system
that includes creating an appropriate risk management environment, maintaining
an efficient risk measurement, mitigating, and monitoring process, and
establishing an adequate internal control arrangement. After outlining the basic
idea of the risk management process and system, we discuss the main elements
of the management process for specific risks. The latter part of the section
examines the risks involved in Islamic financial institutions. We review the
nature of traditional risks for Islamic financial institutions and point out some
specific risks that Islamic banks face. We then discuss the risks inherent in
different Islamic modes of financing.
2.1. INTRODUCTION
Risk arises when there is a possibility of more than one outcome and the
ultimate outcome is unknown. Risk can be defined as the variability or volatility
of unexpected outcomes.4 It is usually measured by the standard deviation of
historic outcomes. Though all businesses face uncertainty, financial institutions
face some special kinds of risks given their nature of activities. The objective of
financial institutions is to maximize profit and shareholder value-added by
providing different financial services mainly by managing risks.
There are different ways in which risks are classified. One way is to
distinguish between business risk and financial risks. Business risk arises from
the nature of a firm’s business. It relates to factors affecting the product market.
Financial risk arises from possible losses in financial markets due to movements
in financial variables (Jorion and Khoury 1996, p. 2). It is usually associated
with leverage with the risk that obligations and liabilities cannot be met with
current assets (Gleason 2000, p. 21).
٤
This definition is from Jorion and Khoury (1996, p. 2).
26
Another way of decomposing risk is between systematic and
unsystematic components. While systematic risk is associated with the overall
market or the economy, unsystematic risk is linked to a specific asset or firm.
While the asset-specific unsystematic risk can be mitigated in a large diversified
portfolio, the systematic risk is nondiversifiable. Parts of systematic risk,
however, can be reduced through the risk mitigation and transferring techniques.
To understand the underlying principle of risk management, we use
Oldfield and Santomero (1997) classification of risks. Accordingly, financial
institutions face the following three types of risks: risks that can be eliminated,
those that can be transferred to others, and the risks that can be managed by the
institution. Financial intermediaries would avoid certain risks by simple business
practices and will not take up activities that impose risks upon them. The
practice of financial institutions is to take up activities in which risks can be
efficiently managed and shift risks that can be transferred.
Risk avoidance techniques would include the standardization of all
business-related activities and processes, construction of diversified portfolio,
and implementation of an incentive-compatible scheme with accountability of
actions. Some risk that banks face can be reduced or eliminated by transferring
or selling these in well-defined markets. Risk transferring techniques include,
among others, use of derivatives for hedging, selling or buying of financial
claims, changing borrowing terms, etc.
There are, however, some risks that cannot be eliminated or transferred
and must be absorbed by the banks. The first is due to the complexity of the risk
and difficulty to separate it from asset. The second risk is accepted by the
financial institutions as these are central to their business. These risks are
accepted because the banks are specialized in dealing with them and get
rewarded accordingly. Examples of these risks are the credit risk inherent in
banking book activities and market risks in the trading book activities of banks.
There is a difference between risk measurement and risk management.
While risk measurement deals with quantification of risk exposures, risk
management refers to “the overall process that a financial institution follows to
define a business strategy, to identify the risks to which it is exposed, to quantify
those risks, and to understand and control the nature of risks it faces” (Cumming
and Hirtle 2001, p. 3). Before we discuss the risk management process and
27
measurement techniques, we give an overview of the risks faced by financial
institutions and the evolution of risk management.
2.2. RISKS FACED BY FINANCIAL INSTITUTIONS
The risks that banks face can be divided into financial and non-financial
ones.5 Financial risk can be further partitioned into market risk and credit risk.
Non-financial risks, among others, include operational risk, regulatory risk, and
legal risk. The nature of some of these risks is discussed below.
Market Risk is the risk originating in instruments and assets traded in
well-defined markets. Market risks can result from macro and micro sources.
Systematic market risk result from overall movement of prices and policies in
the economy. The unsystematic market risk arises when the price of the specific
asset or instrument changes due to events linked to the instrument or asset.
Volatility of prices in various markets gives different kinds of market risks. Thus
market risk can be classified as equity price risk, interest rate risk, currency risk,
and commodity price risk. As a result, market risk can occur in both banking and
trading books of banks. While all of these risks are important, interest rate risk is
one of the major risk that banks have to worry about. The nature of this risk is
briefly explained below.
Interest Rate Risk is the exposure of a bank’s financial condition to
movements in interest rates. Interest rate risk can arise from different sources.
Repricing risk arises due to timing differences in the maturity and repricing of
assets, liabilities and off-balance sheet items. Even with similar repricing
characteristics, basis risk may arise if the adjustment of rates on assets and
liabilities are not perfectly correlated. Yield curve risk is the uncertainty in
income due to changes in the yield curve. Finally instruments with call and put
options can introduce additional risks.
٥
This classification of risk is taken from Gleason (2000).
28
Credit Risk is the risk that counterparty will fail to meet its obligations
timely and fully in accordance with the agreed terms. This risk can occur in the
banking and trading books of the bank. In the banking book, loan credit risk
arises when counterparty fails to meet its loan obligations fully in the stipulated
time. This risk is associated with the quality of assets and the probability of
default. Due to this risk, there is uncertainty of net-income and market value of
equity arising from non-payment and delayed payment of principal and interest.
Similarly, trading book credit risk arises due to a borrower’s inability or
unwillingness to discharge contractual obligations in trading contracts. This can
result in settlement risk when one party to a deal pays money or delivers assets
before receiving its own assets or cash, thereby, exposing it to potential loss.
Settlement risk in financial institutions particularly arises in foreign-exchange
transactions. While a part of the credit risk is diversifiable, it cannot be
eliminated completely.
Liquidity Risk arises due to insufficient liquidity for normal operating
requirements reducing the ability of banks to meet its liabilities when it falls due.
This risk may result from either difficulties in obtaining cash at reasonable cost
from borrowings (funding or financing liquidity risk) or sale of assets (asset
liquidity risk). One aspect of asset-liability management in the banking business
is to minimize the liquidity risk. While funding risk can be controlled by proper
planning of cash-flow needs and seeking newer sources of funds to finance cash-
shortfalls, the asset liquidity risk can be mitigated by diversification of assets
and setting limits of certain illiquid products.
Operational Risk is not a well-defined concept and may arise from
human and technical errors or accidents. It is the risk of direct or indirect loss
resulting from inadequate or failed internal processes, people, and technology or
from external events. While people risk may arise due to incompetence and
fraud, technology risk may result from telecommunications system and program
failure. Process risk may occur due to various reasons including errors in model
specifications, inaccurate transaction execution, and violating operational control
limits.6 Due to problems arising from inaccurate processing, record keeping,
system failures, compliance with regulations, etc., there is a possibility that
operating costs might be different from what is expected affecting the net-
income adversely.
٦
For a list of different sources of operational risk see Crouhy et.al. (2001, p. 487).
29
Legal Risks relate to risks of unenforceability of financial contracts.
This relates to statutes, legislation, and regulations that affect the fulfillment of
contracts and transactions. This risk can be external in nature (like regulations
affecting certain kind of business activities) or internal related to bank’s
management or employees (like fraud, violations of laws and regulations, etc.).
Legal risks can be considered as a part of operational risk (BCBS, 2001a).
Regulatory risk arises from changes in regulatory framework of the country.
2.3. RISK MANAGEMENT: BACKGROUND AND EVOLUTION
Though business activities have been always exposed to risks, the
formal study of managing risk started in the later half of the last century.
Markowitz’s (1959) seminal paper first indicated that portfolio selection was a
problem of maximizing its expected return and minimizing the risks. A higher
expected return of a portfolio (measured by the mean) can result only from
taking more risks. Thus, investors’ problem was to find the optimal risk-return
combination. His analysis also points out the systematic and unsystematic
components of risk. While the unsystematic component can be mitigated by
diversification of assets, the systematic component has to be borne by the
investor. Markowitz’s approach, however, faced operational problems when a
large number of assets are involved.
Sharpe’s (1964) Capital Asset Pricing Model (CAPM) introduces the
concepts of systematic and residual risks. Advances in this model include
Single-Factor Models of Risk that estimates the beta of an asset. While residual
(firm specific) risk can be diversified, beta measures the sensitivity of the
portfolio to business cycles (an aggregate index). The dependence of CAPM on
a single index to explain the risks inherent in assets is too simplistic.
Arbitrage Pricing Theory proposed by Ross (1976) suggests that
multiple factors affect the expected return of an asset. The implication of the
Multiple Factor Model is that the total risk is the sum of the various factor-
related risks and residual risk. Thus, a multiple of risk-premia can be associated
with an asset giving the respective factor-specific betas. Though the Multiple
Factors Model is widely accepted, there is however, no consensus regarding the
factors that affect the risk of an asset or the way it is estimated. There are three
approaches in which this model can be implemented. While the Fundamental
Factors model estimates the factor specific risk- premia assuming the respective
factor-specific betas as given, the macroeconomic model assumes the risk-
30
premia as given and estimates the factor-specific betas. Statistical models
attempt to determine both the risk-premia and betas simultaneously.
Modern risk management processes and strategies have adopted features
of the above mentioned theories and adopted many tools to analyze risk. An
important element of management of risk is to understand the risk-return trade-
off. Investors can expect a higher rate of return only by increasing the risks. As
the objective of financial institutions is to increase the net income of the
shareholders, managing the resulting risks created to achieve this becomes an
important function of these institutions. They do this by efficiently diversifying
the unsystematic risks and reducing and transferring the systematic risk.
There are two broad approaches to quantify risk exposures facing
financial institutions. One way is to measure risks in a segmented way (e.g.,
GAP analysis to measure interest rate risk and Value at Risk to assess market
risks). The other approach is to measure risk exposure in a consolidated way by
assessing the overall firm level risk (e.g., Risk adjusted rate of return, RAROC
for firm level aggregate risk).7
2. 4. RISK MANAGEMENT: THE PROCESS AND SYSTEM
Though main elements of risk management include identifying,
measuring, monitoring, and managing various risk exposures,8 these cannot be
effectively implemented unless there is a broader process and system in place.
The overall risk management process should be comprehensive embodying all
departments/sections of the institution so as to create a risk management culture.
It should be pointed out that the specific risk management process of individual
financial institutions depends on the nature of activities and the size and
sophistication of an institution. The risk management system outlined here can
be a standard for banks to follow. A comprehensive risk management system
should encompass the following three components.9 We outline the basic
concept of the risk management process and system in this section.
٧
For a discussion on adopting consolidated risk management from the supervisors’ and the
banks perspectives see Cumming and Hirtle (2001).
٨
See (Jorion 2001, p. 3) for a discussion.
٩
These three components are derived from BCBS’s recommendations of managing specific
risks. See BCBS (1999 and 2001b).
31
2.4.1. Establishing Appropriate Risk Management Environment and Sound
Policies and Procedures
This stage deals with the overall objectives and strategy of the bank
towards risk and its management policies. The board of directors is responsible
for outlining the overall objectives, policies and strategies of risk management
for any financial institution. The overall risk objectives should be communicated
throughout the institution. Other than approving the overall policies of the bank
regarding risk, the board of directors should ensure that the management takes
the necessary actions to identify, measure, monitor, and control these risks. The
board should periodically be informed and review the status of the different risks
the bank is facing through reports.
Senior management is responsible to implement these broad
specifications approved by the board. To do so, the management should establish
policies and procedures that would be used by the institution to manage risk.
These include maintaining a risk management review process, appropriate limits
on risk taking, adequate systems of risk measurement, a comprehensive
reporting system, and effective internal controls. Procedures should include
appropriate approval processes, limits and mechanisms designed to assure the
bank’s risk management objectives are achieved. Banks should clearly identify
the individuals and/or committees responsible for risk management and define
the line of authority and responsibility. Care should be taken that there is
adequate separation of duties of risk measurement, monitoring and control
functions.
Furthermore, clear rules and standards of participation should be
provided regarding position limits, exposures to counterparties, credit and
concentration. Investment guidelines and strategies should be followed to limit
the risks involved in different activities. These guidelines should cover the
structure of assets in terms of concentration and maturity, asset-liability
mismatching, hedging, securitization, etc.
2.4.2. Maintaining an Appropriate Risk Measurement, Mitigating, and
Monitoring Process
Banks must have regular management information systems for
measuring, monitoring, controlling and reporting different risk exposures. Steps
that need to be taken for risk measurement and monitoring purposes are
establishing standards for categorization and review of risks, consistent
32
evaluation and rating of exposures. Frequent standardized risk and audit reports
within the institution is also important. The actions needed in this regard are
creating standards and inventories of risk based assets, and regularly producing
risk management reports and audit reports. The bank can also use external
sources to assess risk, by using either credit ratings, or supervisory risk
assessment criterion like CAMELS.
Risks that banks take up must be monitored and managed efficiently.
Banks should do stress testing to see the effects on the portfolio resulting from
different potential future changes. The areas a bank should examine are the
effects of downturn in the industry or economy and market risk events on default
rates and liquidity conditions of the bank. Stress testing should be designed to
identify the conditions under which a bank’s positions would be vulnerable and
the possible responses to such situations. The banks should have contingency
plans that can be implemented under different scenarios.
2.4.3. Adequate Internal Controls
Banks should have internal controls to ensure that all policies are
adhered to. An effective system of internal control includes an adequate process
for identify and evaluating different kinds of risks and having sufficient
information systems to support these. The system would also establish policies
and procedures and their adherence are continually reviewed. These may include
conducting periodic internal audits of different processes and producing regular
independent reports and evaluations to identify areas of weakness. An important
part of internal control is to ensure that the duties of those who measure,
monitor, and control risks are separated.
Finally, an incentive and accountability structure that is compatible with
reduced risk taking on part of the employees is also an important element to
reduce overall risk. A prerequisite of these incentive-based contracts is accurate
reporting of the bank’s exposures and internal control system. An efficient
incentive compatible structure would limit individual positions to acceptable
levels and encourage decision makers to manage risks in a manner that is
consistent with the banks goals and objectives.
2.5. MANAGEMENT PROCESSES OF SPECIFIC RISKS
As mentioned above the total risk of an asset can be assigned to different
sources. Given the general guidelines of risk management process above, in this
33
section we give details of risk management processes for specific risks faced by
banks.
2.5.1. Credit Risk Management10
The board of directors should outline the overall credit risk strategies by
indicating the bank’s willingness to grant credit to different sectors, geographical
location, maturity, and profitability. In doing so it should recognize the goals of
credit quality, earnings, growth, and the risk-reward tradeoff for its activities.
The credit risk strategy should be communicated throughout the institution.
The senior management of the bank should be responsible to implement
the credit risk strategy approved by the board of directors. This would include
developing written procedures that reflect the overall strategy and ensure its
implementation. The procedures should include policies to identify, measure,
monitor, and control credit risk. Care has to be given to diversification of
portfolio by setting exposure limits on single counterparty, groups of connected
counterparties, industries, economic sectors, geographical regions, and
individual products. Banks can use stress testing in setting limits and monitoring
by considering business cycles, interest rate and other market movements. Banks
engaged in international credit need to assess the respective country risk.
Banks should have a system for ongoing administration of various credit
risk-bearing portfolios. A proper credit administration by a bank would include
an efficient and effective operations related to monitoring documentation,
contractual requirements, legal covenants, collateral, etc., accurate and timely
reporting to management, and compliance with management policies and
procedures and applicable rules and regulations.
Banks must operate under a sound, well-defined credit-granting criteria
to enable a comprehensive assessment of the true risk of the borrower or
counterparty to minimize the adverse selection problem. Banks need
information on many factors regarding the counterparty to whom they want to
grant credit. These include, among others, the purpose of the credit and the
source of repayment, the risk profile of the borrower and its sensitivity to
economic and market developments, borrowers repayment history and current
capacity to repay, enforceability of the collateral or guarantees, etc. Banks
should have a clear and formal evaluation and approval process for new credits
١٠
This section is based on the credit risk management process discussed in BCBS (1999).
34
and extension of existing credits. Each credit proposal should be subject to
careful analysis by a credit analyst so that information can be generated for
internal evaluation and rating. This can be used for appropriate judgements
about the acceptability of the credit.
Granting credit involves accepting risks as well as producing profits.
Credit should be priced so that it appropriately reflects the inherent risks of the
counterparty and the embedded costs. In considering the potential credit, the
bank needs to establish provisions for expected loss and hold adequate capital to
absorb the unexpected losses. Banks can use collateral and guarantees to help
mitigate risks inherent in individual transactions. Note, however, that collateral
cannot be a substitute for comprehensive assessment of a borrower and strength
of the repayment capacity of the borrower should be given prime importance.
Banks should identify and manage credit risk inherent in all of its assets
and activities by carefully reviewing the risk characteristics of the asset or
activity. Special care is needed particularly when the bank embarks on new
activities and assets. In this regard, adequate procedures and controls need to be
taken to identify the risks in new asset or activity. Banks must have analytical
techniques and information systems to measure credit risk in all on- and off-
balance sheet activities. The system should be able to provide information on
sensitivities and concentrations in the credit portfolio. Banks can manage
portfolio issues related to credit through loan sales, credit derivatives,
securitization, and involvement in secondary loan markets.
Banks must have a system for monitoring individual credits, including
determining the adequacy of provisions and reserves. An effective monitoring
system would provide the bank, among others, the current financial condition of
the counterparty. The system would be able to monitor projected cash-flow and
the value of the collateral to identify and classify potential credit problems.
While monitoring the overall composition and quality of the portfolio, a bank
should not only take care about the concentrations with respect to counterparties
activities but also the maturity.
Banks should develop internal risk rating systems to mange credit risk.
A well-structured internal rating system can differentiate the degree of credit risk
in different credit exposures of a bank by categorizing credits into various
gradations in risk. Internal risk ratings are important tool in monitoring and
controlling credit risk as periodic ratings enable banks to determine the overall
35
characteristics of the credit portfolio and indicates any deterioration in credit
risk. Deteriorating credit can then be subject to additional monitoring and
supervision.
A bank should have independent ongoing credit reports for the board of
directors and senior management to ensure that the bank’s risk exposure are
maintained within the parameters set by prudential standards and internal limits.
Banks should have internal controls to ensure that credit policies are adhered to.
These may include conducting periodic internal audits of the credit risk
processes to identify the areas of weakness in the credit administration process.
Once the problem credits are identified, banks should have a clear policy and
system for managing problem credits. The banks should have effective workout
programs to manage risk in their portfolio.
2.5.2. Interest Rate Risk Management11
The board of directors should approve the overall objectives, broad
strategies and policies that govern the interest rate risk of a bank. Other than
approving the overall policies of the bank regarding interest rate risk the board
of directors should ensure that the management takes the necessary actions to
identify, measure, monitor, and control these risks. The board should
periodically be informed and review the status of interest rate risk the bank is
facing through reports.
Senior management must ensure that the bank follows policies and
procedures that enable the management of interest rate risk. These include
maintaining an interest rate risk management review process, appropriate limits
on risk taking, adequate systems of risk measurement, a comprehensive interest
rate risk reporting system, and effective internal controls. Banks should be able
to identify the individuals and/or committees responsible for interest rate risk
management and define the line of authority and responsibility.
Banks should have clearly defined policies and procedures for limiting
and controlling interest rate risk by delineating responsibility and accountability
over interest rate risk management decisions and defining authorized
instruments, hedging strategies and position taking opportunities. Interest rate
risk in new products should be identified by carefully scrutinizing the maturity,
١١
This section is based on the interest rate risk management process discussed in BCBS
(2001).
36
repricing or repayment terms of an instrument. The board should approve new
hedging or risk management strategies before these are implemented.
Banks should have a management information system for measuring,
monitoring, controlling and reporting interest rate exposures. Banks should have
interest rate risk management systems that assess the effects of rate changes on
both the earnings and economic value. These measurement systems should be
able to utilize generally accepted financial concepts and risk management
techniques to assess all interest risk associated with a bank’s assets, liabilities,
and off-balance sheet positions. Some of the techniques for measuring a bank’s
interest risk exposure are GAP analysis, duration, and simulation. Possible stress
tests can be undertaken to examine the effects of changes in the interest rate,
changes in the slope of the yield curve, changes in the volatility of the market
rates, etc. Banks should consider the “worse case” scenarios and ensure that
appropriate contingency plans are available to tackle these situations.
Banks must establish and enforce a system of interest rate risk limits and
risk taking guidelines that can achieve the goal of keeping the risk exposure
within some self-imposed parameters over a range of possible changes in interest
rates. An appropriate limit system enables the control and monitoring of interest
rate risk against predetermined tolerance factors. Any violation of limits should
be made known to senior management for appropriate action.
Interest rate reports for the board should include summaries of the
bank’s aggregate exposures, compliance with policies and limits, results of stress
tests, summaries of reviews of interest rate risk policies and procedures, and
findings of internal and external auditors. Interest rate risk reports should be in
details to enable senior management to assess the sensitivity of the institution to
changes in the market conditions and other risk factors.
Banks should have adequate system of internal controls to ensure the
integrity of their interest rate risk management process and to promote effective
and efficient operations, reliable financial and regulatory reporting, and
compliance with relevant laws, regulations, and institutional policies. An
effective system of internal control for interest rate risk includes an adequate
process for identify and evaluating risk and having sufficient information
systems to support these. The system would also establish policies and
procedures and their adherence are continually reviewed. These periodic
reviews would cover not only the quantity of interest rate risk, but also the
37
quality of interest rate risk management. Care should be taken that there is
adequate separation of duties of risk measurement, monitoring and control
functions.
2.5.3. Liquidity Risk Management12
As banks deal with other people’s money that can be withdrawn,
managing liquidity is one of the most important functions of the bank. The
senior management and the board of directors should make sure that the bank’s
priorities and objectives for liquidity management are clear. Senior management
should ensure that liquidity risk is effectively managed by establishing
appropriate policies and procedures. A bank must have adequate information
system to measure, monitor, control and report liquidity risk. Regular reports on
liquidity should be provided to the board of directors and senior management.
These reports should include, among others, the liquidity positions over
particular time horizons.
The essence of liquidity management problem arises from the fact that
there is a trade-off between liquidity and profitability and mismatch between
demand and supply of liquid assets. While the bank has no control over the
sources of funds (deposits), it can control the use of funds. As such, a bank’s
liquidity position is given priority in allocating funds. Given the opportunity cost
of liquid funds, banks should make all profitable investments after having
sufficient liquidity. Most banks now keep protective reserves on top of planned
reserves. While the planned reserves are derived from either regulatory
requirements or forecasts, the amount of the protective reserve depends on the
management’s attitude towards liquidity risk.
Liquidity management decisions have to be undertaken by considering
all service areas and departments of the bank. Liquidity manager must keep track
and coordinate the activities of all departments that raise and use funds in the
bank. Decisions regarding the banks liquidity needs must be analyzed
continuously to avoid both liquidity surplus and deficit. In particular, the
liquidity manager should know in advance when large transactions (credit,
deposits, withdrawals) would take place to plan effectively for resulting liquidity
surpluses or deficits.
١٢
The discussion on Liquidity Risk Management is derived from BCBS (2000).
38
A bank should establish a process of measuring and monitoring net
funding requirements by assessing the bank’s cash inflows and outflows. The
bank’s off-balance sheet commitments should also be considered. It is also
important to assess the future funding needs of the bank. An important element
of liquidity risk management is to estimate a bank’s liquidity needs. Several
approaches have been developed to estimate the liquidity requirements of banks.
These include the sources and uses of funds approach, the structure of funds
approach, and the liquidity indicator approach.13 A maturity ladder is a useful
device to compare cash inflows and outflows for different time periods. The
deficit or surplus of net cash flows is a good indicator of liquidity shortfalls and
excesses at different points in time.
Unexpected cash flows can arise from some other sources. As more and
more banks are engaged in off-balance sheet activities, banks should also
examine the cash flows on this account. For example, contingent liabilities used
in these accounts (like financial guarantees and options) can represent
substantial sources of outflows of funds. After identifying the liquidity
requirements, a series of worse case scenarios can be analyzed to estimate both
possible bank specific shocks and economy-wide shock. The bank should have
contingency funding plans of handling the liquidity needs during these crises.
Possible responses to these shocks would include the speed with which assets
can be liquidated and the sources of funds that banks can use in the crisis. If the
bank is dealing with foreign currency, it should have a measurement, monitoring
and control system for liquidity in active currencies.
Banks should have adequate internal controls over its liquidity risk
management process that should be a part of the overall system of internal
control. An effective system would create a strong control environment and have
an adequate process of identifying and evaluating liquidity risk. It should have
adequate information system that can produce regular independent reports and
evaluations to review adherence to established policies and procedures. The
internal audit function should also periodically review the liquidity management
process to identify any problems or weaknesses for appropriate action by the
management.
١٣
For a discussion on these methods see Rose (1999).
39
2.5.4. Operational Risk Management14
The board of directors and senior management should develop the
overall policies and strategies for managing operational risk. As operational risk
can arise due to failures in people, processes, and technology, management of
this risk is more complex. Senior management needs to establish the desired
standards of risk management and clear guidelines for practices that would
reduce operational risks. In doing so, care needs to be taken to include people,
process, and technology risks that can arise in the institution.
Given the different sources in which operational risk can arise, a
common standard for identification and management of these needs to be
developed. Care needs to be taken to tackle operational risk arising in different
departments/organizational unit due to people, process, and technology. As such
a wide variety of guidelines and rules have to be spelled out. To do so, the
management should develop an ‘operational risk catalogue’ in which business
process maps for each business/ department of the institution are outlined. For
example, the business process for dealing with client or investor should be laid
out. This catalogue will not only identify and assess operational risk but also can
be used for transparency by the management and auditors.
Given the complexity of operational risk, it is difficult to quantify it.
Most of the operational risk measurement techniques are simple and
experimental. The banks, however, can gather information of different risks
from reports and plans that are published within the institution (like audit
reports, regulatory reports, management reports, business plans, operations
plans, error rates, etc.). A careful review of these documents can reveal gaps that
can represent potential risks. The data from the reports can then be categorized
into internal and external factors and converted into likelihood of potential loss
to the institution. A part of the operational risk can also be hedged. Tools for
risk assessment, monitoring, and management would include periodic reviews,
stress testing, and allocation of appropriate amount of economic capital.
As there are various sources of operational risk, it needs to be handled in
different ways. In particular, risk originating from people needs effective
management, monitoring, and controls. These include establishing an adequate
operating procedure. One important element to control operational risk is to have
clear separation of responsibilities and to have contingency plans. Another
١٤
This part is based on BCBS (1998) and Crouhy, et.al. (2001, Chapter 13).
40
significant element is to make sure that reporting systems are consistent, secure,
and independent of business. The internal auditors play an important role in
mitigating operational risk.
2.6. RISK MANAGEMENT AND MITIGATION TECHNIQUES
Many risk measurement and mitigation techniques have evolved in
recent times. Some of these techniques are used to mitigate specific risks while
others are meant to deal with overall risk of a firm. In this section we outline
some contemporary techniques used by well-established financial institutions.
2.6.1. GAP Analysis
GAP analysis is an interest rate risk management tool based on the
balance sheet. GAP analysis focuses on the potential variability of net-interest
income over specific time intervals. In this method a maturity/repricing schedule
that distributes interest-sensitive assets, liabilities, and off-balance sheet
positions into time bands according to their maturity (if fixed rate) or time
remaining to their next repricing (if floating rate) is prepared. These schedules
are then used to generate indicators of interest rate sensitivity of both earnings
and economic value to changing interest rates.
GAP models focus on managing net interest income over different time
intervals. After choosing the time intervals, assets and liabilities are grouped into
these time buckets according to maturity (for fixed rates) or first possible
repricing time (for flexible rates). The assets and liabilities that can be repriced
are called rate sensitive assets (RSAs) and rate sensitive liabilities (RSLs)
respectively, and GAP equals the difference between the former and the latter.
Thus for a time interval, GAP is given by,
GAP = RSAs – RSLs (2.1)
Note that GAP analysis is based on the assumption of repricing of
balance sheet items calculated according to book value terms. The information
on GAP gives the management an idea about the effects on net-income due to
changes in the interest rate. For example, if the GAP is positive, then the rate
sensitive assets exceed liabilities. The implication is that an increase in future
interest rate would increase the net interest income as the change in interest
income is greater than the change in interest expenses. Similarly, a positive
GAP and a decline in the interest rate would reduce the net interest income. The
41
banks can opt to hedge against such undesirable interest rate changes by using
interest rate swaps (outlined in Section 2.6.6.1).
2.6.2. Duration-GAP Analysis
Duration model is another measure of interest rate risk and managing net
interest income derived by taking into consideration all individual cash inflows
and outflows. Duration is value and time weighted measure of maturity of all
cash flows and represents the average time needed to recover the invested funds.
The standard formula for calculation of duration D is given by,
n
∑ CF × t × (1 + i )
−t
t
D= t =1
n
(2.2)
∑ CF × (1 + i )
−t
t
t =1
where CFt is the value of cash flow at time t, which is the number of periods the
cash flow from the instrument is received, and i is the instrument’s yield to
maturity. The duration analysis compares the changes in market value of the
assets relative to its liabilities. Average duration gaps of assets and liabilities are
estimated by summing the duration of individual asset/liability multiplied by its
share in the total asset/liability. A change in the interest rate affects the market
value through the discounting factor (1+i)-t. Note that the discounted market
value of an instrument with a longer duration will be affected relatively more
due to changes in the interest rate. Duration analysis, as such, can be viewed as
the elasticity of the market value of an instrument with respect to interest rate.
Duration gap (DGAP) reflects the differences in the timing of asset and
liability cash flows and given by,
DGAP = DA - u DL (2.3)
where DA is the average duration of the assets, DL is the average duration of
liabilities, and u is the liabilities/assets ratio. Note that a relatively larger u
implies higher leverage. A positive DGAP implies the duration of assets is
greater than that of liabilities. When interest rate increases by comparable
amounts, the market value of assets decrease more than that of liabilities
resulting in the decrease in the market value of equities and expected net-interest
income. Similarly, a decline in the interest rate decreases the market value of the
equity with a positive DGAP. Banks can use DGAP analysis to immunize
portfolios against interest rate risk by keeping DGAP close to zero.
42
2.6.3. Value at Risk (VaR)15
Value at Risk (VaR) is one of the newer risk management tools. The
VaR indicates how much a firm can lose or make with a certain probability in a
given time horizon. VaR summarizes financial risk inherent in portfolios into a
simple number. Though VaR is used to measure market risk in general, it
incorporates many other risks like foreign currency, commodities, and equities.
VaR has many variations and can be estimated in different ways. We outline the
underlying concept of VaR and the method of estimating it below.
Assume that an amount A0 is invested at a rate of return of r, so that after
a year the value of portfolio is A= A0 (1+r). The expected rate of return from
the portfolio is µ with standard deviation σ. VAR answers the question of how
much can the portfolio lose in a certain time period t (e.g., month). To compute
this, we construct the probability distribution of the returns r. We then choose a
confidence level c (say 95) percent. VaR tells us what is the loss (A*) that will
not be exceeded c percent of the cases in the given period t. In other words, we
want to find the loss that has a probability of 1-c percent of occurrence in the
time period t. Note that there is a rate of return r* corresponding to A*.
Depending on the basis of comparison, VaR can be estimated in the absolute and
relative sense. Absolute VaR is the loss relative to zero and relative VaR is the
loss compared to the mean µ. The basic idea of estimating VAR is shown in
Figure 2.1 below.
A simpler parametric method can be used to estimate VaR by converting
the general distribution into a standard normal distribution. This method is not
only easier to use but also gives more accurate results in some cases. To use the
parametric method to estimate VaR, the general distribution of the rates of return
are converted into a normal distribution in the following way
-α= (-r*-µ)/σ (2.4)
Note that α represents the standard normal distribution equivalent loss
corresponding to confidence level of 1-c of the general distribution (i.e., r*).
Thus, in a normal distribution, α would be 1.65 (or 2.33) for a confidence level
c=95 (or c= 99 percent). Expressing time period T in years (so that one month
would be 1/12), the absolute and relative VaRs using the parametric method are
then given as
١٥
For an extensive discussion on VaR, see Jorion (2001).
43
VaR( zero) = A0 (ασ T − µT ) (2.5)
and
VaR(mean) = A0ασ T (2.6)
respectively. Say, for a monthly series the VaR (zero) is estimated to be ‘y’ at 95
percent confidence level. This means that under normal market conditions, the
most the portfolio can lose over a month is an amount of y with a probability of
95 percent (see Box 1 for an example).
Figure 2.1
Basic Concept of Value at Risk
VAR (0)
Distribution of Returns
5 percent loss VAR (µ)
probability
r* 0 µ Monthly Return, r (%)
2.6.4. Risk Adjusted Rate of Return (RAROC)
Risk adjusted rate of return (RAROC), developed by Bankers Trust in
the late 1970s, quantifies risk by considering the tradeoff of risk and reward in
different assets and activities. By the end of the 1990s, RAROC was considered
a leading edge methodology to measure performance and a best practice
standard by financial institutions. It gives an economic basis to measure all the
relevant risks consistently and gives managers tools to make the efficient
decisions regarding risk/return tradeoff in different assets. As economic capital
protects financial institutions against unexpected losses, it is vital to allocate
capital for various risks that these institutions face. RAROC analysis shows how
much economic capital different products and businesses need and determines
the total return on capital of a firm. Though RAROC can be used to estimate the
44
capital requirements for market, credit and operational risks, it is used as an
integrated risk management tool.16
Figure 2.2
Estimation of Risk Capital for RAROC
Distribution of Loss
5 percent
0 EL WL
Loan Loss Risk Capital Provision
From a loss distribution over a given horizon (say a year) expected
losses (EL) can be estimated as average losses of the previous years. Worst case
loss (WL) is the maximum potential loss. The worst case loss is estimated at a
given level of confidence, c (e.g., 95 or 99 percent). The unexpected loss (UL) is
the difference between the worst case and expected loss (i.e., UL=WL-EL). Note
that while the expected loss is included as costs (as loan loss provision) when
determining the returns, the unexpected losses arising from random shocks
require capital to absorb the loss. The unexpected or worst case loss is estimated
at a given level of confidence, c, as it is too costly for an organization to have
capital for all potential loss. If the confidence level is 95 percent then there is a
probability of 5 percent that actual losses will exceed the economic capital. The
part of the loss that is not covered by the confidence level is the catastrophic risk
that the firm faces and can be insured. Estimation of risk capital from a loss
distribution function is shown in Figure 2.2. RAROC is determined as,
١٦
For a discussion of the use of RAROC to determine capital for market, credit and
operational risks, see Crouhy, et.al. (2000, pp. 543-48).
45
RAROC = Risk-adjusted Return / Risk Capital,
where risk-adjusted return equals total revenues less expenses and expected
losses (EL), and risk capital is that reserved to cover the unexpected loss given
the confidence level. While the expected loss is factored in the return (as loan
loss provision), the unexpected loss is equivalent to the capital required to
absorb the loss. A RAROC of x percent on a particular asset means that the
annual expected rate of return of x on the equity is required to support this asset
in the portfolio. Note that RAROC can be used as a tool of capital allocation by
estimating the expected loss ex ante, and used for performance evaluation by
utilizing realized losses ex post.
2.6.5. Securitization
Securitization is a procedure studied under the systems of structured
finance or credit linked notes.17 Securitization of a bank’s assets and loans is a
device for raising new funds and reducing bank’s risk exposures. The bank pools
a group of income-earning assets (like mortgages) and sells securities against
these in the open market, thereby transforming illiquid assets into tradable asset-
backed securities. As the returns from these securities depend on the cash flows
of the underlying assets, the burden of repayment is transferred from the
originator to these pooled assets. The structure of securitization process in
shown in Figure 2.3 below. The bank, the originator of the securities, packages
its assets into pools of similar assets. These assets are passed on to a special
purpose vehicle (SPV) or issuer of securities. Note that the SPV is a separate
entity than the originator so that the viability of the bank does not affect the
credit status of assets in the pool. The issued securities are sold to the investors.
A trustee ensures that the SPV fulfills all aspects of the transaction and provides
all services. These include transfer of assets to the pool, fulfilling guarantees and
collateral requirements in case of default. The trustee also collects and transfers
the cash flows generated from the pooled assets to the investors.
١٧
For a detailed discussion of structured finance and credit linked notes related to
securitization see Caouttee et.al (1998, Chapter 23) and Das (2000, Chapter 4) respectively.
46
BOX 1:
Examples of Estimating VaR and RAROC
Estimating VaR: An Example
Assume an investment portfolio marked to the market is valued at SR 100 million has
expected rate of return of 5 percent and standard deviation of 12 percent. We are
interested to estimate VaR for holding period of one month at 99 percent confidence
interval. Using the symbols in the text, this information can be written as follows:
A0=100 million, µ = 5 percent, σ = 12 percent, c=99, α=2.33, and T=1/12.
Note that 99 percent confidence interval yields α=2.33 in a normal distribution. Given
the above we can estimate the two variants of VaR as:
VaR(mean) = A0ασ T
= 100 × 2.33 × 0.12 × (1/12)0.5 = 8.07
and,
VaR( zero) = A0 (ασ T − µT )
=100[2.33 × 0.12 × (1/12)0.5 – 0.05× (1/12)] = 8.07-0.42= 7.65
The result in the relative sense (i.e. relative to mean) implies that under normal
conditions there is a 99 percent chance that the loss of the portfolio will not exceed SR
8.07 million over a month. In the absolute sense (i.e. relative to zero) this amount is
SR 7.65 million.
Estimating RAROC: An Example
Assume that a bank has funds of SR 500 million, of which SR 460million are deposits
and the remaining SR 40 million equity (Step 2 below shows how this amount is
determined). Say the bank pays an interest rate of 5 percent to the depositors. As
capital is used for unexpected losses, it is invested in risk-free asset (like government
bonds) that has a return of 6 percent. The institution invests its remaining liability in
projects that yields an expected return of 10 percent. The average loss per annum is
estimated at SR 5 million with the worst case loss of SR 45 million at 95 percent
confidence interval. The annual operating costs of the bank is SR 10 million. Given
this information, we can estimate the RAROC for the portfolio in the following steps.
1. Estimate Risk Adjusted Return (= Total Revenue – Total Cost – Expected Loss)
Total Revenue = Income from Investment + Income from Bonds
=460 × 0.10 + 40 × 0.06 = 46 + 2.4 = 48.4
Total Cost = Payment to Deposits + Operating Costs
=460 × 0.05 + 10 = 23 + 10 = 33
Expected Loss = 5
Risk Adjusted Return = 48.4 -33 – 5 = 10.4
2. Estimate Risk Capital (=Worst Case Loss – Expected Loss)
= 45 – 5 = 40
3. Estimate RAROC (=Risk Adjusted Return/Risk Capital) ×100
=10.4/40 ×100 = 26 percent
A RAROC of 26 percent means that the portfolio has an expected rate of return on
equity of 26 percent.
47
Figure 2.3
Securitization Process
Bank
(Originator) Bank Assets
Pool of Assets
Trustee
Special Purpose
Vehicle (SPV)
Asset-backed Securities or Issuer
Investors
By pooling assets through securitization, a bank can diversify its credit
risk exposure and reduce the need to monitor each individual asset’s payment
stream. Securitization also can be used to mitigate interest rate risk as a bank can
harmonize the maturity of the assets to that of the liabilities by investing in a
wide range of available securities. The process of securitization enables banks to
transfer risky assets from its balance sheet to its trading book.
2.6.6. Derivatives
In recent years derivatives have been increasingly taking an important
role not only as instruments to mitigate risks but also as sources of income
generation. A derivative is an instrument whose value depends on the value of
something else. The major categories of derivatives are futures, options, and
swap contracts.18 Futures are forward contracts of standardized amounts that are
traded in organized markets. Like futures, options are financial contracts of
standardized amounts that give buyers (sellers) the right to buy (sell) without
any obligation to do so. Swap involves agreement between two or more parties
to exchange set of cash flows in the future according to predetermined
specifications.
١٨
For a discussion on derivatives see Hull (1995) and Kolb (1997).
48
Recent years have witnessed the explosion of the use of derivatives. To
understand the size of the derivatives in some perspective, we compare it with
the global GDP. In 1999, when the world GDP stood at USD 29.99 trillion, the
notional amount of global over-the–counter derivatives was USD 88.2 trillion.
Of these, USD 60.09 trillion (or around 68 percent) were interest rate
derivatives. Interest rate swaps accounted to USD 43.94 trillion or 73 percent of
the interest contracts and around 50 percent of total notional value of
derivatives.19 In this section we briefly outline the structure of two derivatives
that have relevance to risk management in banking.
2.6.6.1. Interest-Rate Swaps
As mentioned above, interest rate swaps constitute almost half of the
notional value of all derivatives. Interest rate swaps are used to mitigate the
interest rate risk. Though interest rate swaps can take different types, we outline
formats of two basic ones here.
The simplest of the interest rate (plain vanilla) swap involves two
counterparties, one having an initial position in a fixed debt instrument and the
other in a floating rate obligation. To understand why the two counterparties
would be interested to swap their interest payments, assume that counterparty A
is a financial institution that has to pay a floating interest on its liability (say it
pays LIBOR+1 percent on its deposits). The counterparty, however, is locked in
an asset that pays a fixed rate of interest for a certain number of years (say 10
percent on a 5-year mortgage). An increase in LIBOR can affect the income of
the financial institution adversely. The counterparty B with the floating rate asset
of LIBOR+3 percent is exposed to interest rate risk and wants to eliminate it. By
swapping the interest payments on their assets, the counterparties can immune
their earnings from movements in the interest rate. Note that at the end of the
contract period, only the net difference of the interest payments takes place
between the counterparties, as the principal involved on both sides of a swap is
usually the same amount. The structure of an interest rate swap is shown in
Figure 2.4.
١٩
Data on world income is taken from World Development Indicators (2001) and on
derivatives from BCBS (2001c).
49
Figure 2.4
Interest Rate Swap
Fixed interest: 10%
Counterparty A Counterparty B
Floating interest: LIBOR+3%
The other example of interest rate swap we provide is the one where
parties raise funds at different rates. The swap is beneficial to parties even if one
party can raise funds at higher rates than the other for different types of funds.
The underlying concept of this swap contract is similar to that of theory of
comparative advantage of trade. The objective of the swap is to exchange the
costs of raising funds on the basis of comparative advantages. Table 2.1 shows
an example. We observe that party B can raise both short and long-term funds at
lower rates than party A. Party A, however, can raise short-term funds 0.50
percent cheaper than long-term funds and party B can raise long-term funds 0.25
percent cheaper than short-term funds. Say due to the asset structures, party A
needs long-term funds and party B short-term. Party B can raise long-term funds
at 2.5 percent (11.5%-9%) lower than party A. Party B can pay its own cost of
raising short-term funds 9.25 percent less 0.25 percent (i.e., 9 percent) to party
A. In this way B saves 0.25 percent on the cost of the funds of its own choice.
Party A also saves 0.25 percent if it raises short term funds at (9.25%+ 1.75%)
and pays 0.25 percent to party B (adding up to 11.25 percent), instead of paying
11.50 percent for raising long-term funds by its own. Both end up with a net
financial gain as well as paying in consistency with their own asset and liability
structures. Thus the principle of a swap is similar to that of free trade on the
basis of comparative advantages. Since swaps are arranged in trillions of US
dollars in real life, they are hence the practical manifestation of the theory of
gains from comparative advantages under free trade.
50
Table 2.1
Comparative Advantages in Fund Raising
Cost of raising Cost of raising Cost difference %
long-term short-term
fixed rate floating rate
funds % funds %
Party A 11.50% Benchmark Can raise short-term funds
rate .50% cheaper than long-
(9.25%)+1.75 term funds
Party B 9% Benchmark Can raise long-term funds
rate i.e., .25% cheaper than short-
9.25% term funds
B competitive in 2.5% 1.75%
both by
2.6.6.2. Credit Derivatives
Credit derivatives are instruments used to trade credit risk. Credit
derivatives may take different forms such as swaps, options, and credit linked
notes.20 The basic model involves the banks finding a counterparty that assumes
the credit risk for a fee, while the bank itself retains the asset on its book. We
outline the nature of a simple credit swap here. The purpose of the derivative is
to provide default protection to the bank (risk seller) and compensation to the
risk buyer for taking up the bank’s credit risk. By paying a premium, the default
risk of an asset is swapped for the promise of a full or partial payment if the
asset defaults. Credit derivative can be implemented to deal with any part of the
credit risk exposure, like the amount, maturity, etc. The structure of a credit
swap is illustrated in Figure 2.6.
Figure 2.6
Credit Swap
Pays a fixed premium
Bank (risk seller) Risk Buyer
Makes payment in case of default
2.7. ISLAMIC FINANCIAL INSTITUTIONS: NATURE AND RISKS
٢٠
For a discussion on different types of credit derivatives, see Caouette et.al (1998, pp. 307-
309) and Crouhy et.al (2001, pp. 448-61).
51
In order to understand the risks that Islamic financial institutions face,
we first briefly discuss the nature of these institutions. To have the discussion in
some perspective, we outline the types of conventional institutions. Financial
intermediaries are broadly classified as depositary institutions, investment
intermediaries, and contractual intermediaries. Commercial banks, forming bulk
of the depositary institutions, specialize in intermediation obtaining most of its
loanable funds from deposits of the public. Investment intermediaries offer
liquid securities to the public for long-term investment. Investment
intermediaries are mutuals, with customers being the owners who receive
income in form of dividends and capital gains. Investment intermediaries
typically invest in secondary markets and, as such, avail investors opportunities
to hold securities of private and public institutions. Contractual intermediaries
constitute insurance firms and pension funds.21
Iqbal et.al. (1998) distinguish two models of Islamic banks based on the
structure of the assets.22 The first is the two-tier Muārabah model that replaces
interest by profit-sharing (PS) modes on both liability and asset sides of the
bank. In particular, in this model all assets are financed by PS modes of
financing (Muārabah). This model of Islamic banking will also take up the role
of an investment intermediary, rather than being a commercial bank only
(Chapra 1985, p. 154). The second model of Islamic banking is the one-tier
Muārabah with multiple investment tools. This model evolved because Islamic
banks faced practical and operational problems in using profit-sharing modes of
financing on the asset side. As a result, they opted for fixed-income modes of
financing. As mentioned earlier, fixed-income instruments include Murāba ah
(cost-plus or mark-up sale), installment sale (medium/long-term Murāba ah),
Isti nā‘/ Salam (object deferred sale or pre-paid sale) and Ijārah.23
٢١
Depending on the regulatory framework of a specific country, financial institutions may
perform different functions. For example, universal banks are consolidated institutions
providing different financial services that may include intermediation, investment
management, insurance, brokerage, and holding equity of non-financial firms (Heffernan
1996). A simple case of universal bank is in which the liability is the same as commercial
banks, but the asset side differs. While the assets of commercial banks are in form of loans
only, universal banks can hold equity along with loans. By holding equity positions, universal
banks can essentially get involved in the decision making and management of the firm.
٢٢
Iqbal, et.al. (1998) mention three models, the third one being the case where Islamic
banks work as agent (wakeel), managing funds on behalf of clients on basis of fixed
commission.
٢٣
For a discussion on these modes of financing see Ahmad (1993), Kahf and Khan (1992),
and Khan (1991).
52
Islamic banking offers financial services by complying with the
religious prohibition of Ribā. Ribā is a return (interest) charged in a loan (Qar
asan) contract. This religious injunction has sharpened the differences between
current accounts (interest free loans taken by owners of the Islamic bank) and
investment deposits (Muārabah funds). In the former case, the repayment on
demand of the principal amount is guaranteed without any return. The owners of
current accounts do not share with the bank in its risks. In case of investment
deposits, neither the principal nor a return is guaranteed. Investment accounts
can be further classified as restricted and unrestricted, the former having
restrictions on assets that the funds can be used for and on withdrawals before
maturity date. The owners of investment accounts participate in the risks and
share in the bank’s profits on pro rata basis. The contracts of Qar asan and
Muārabah are thus the fundamental pillars of Islamic banking and their
characteristics must fully be protected for the preservation of the uniqueness of
Islamic banks.
The Islamic bank described above appears to have characteristics of
both an investment intermediary and a commercial bank. The ownership pattern
of the Islamic bank resembles that of a commercial bank as the depositors do not
own the bank and do not have voting rights. In Islamic finance parlance, this
means while Mushārakah contract characterizes the equity owners, deposits take
the form of Muārabah contracts.24 An Islamic bank, however, has similarities
with an investment intermediary as it shares the profit generated from its
operations with those who hold investment accounts. After paying the depositors
a share of the profit, the residual net-income is given out to the shareholders as
dividends.
Using profit-sharing modes in Islamic banks changes the nature of risks
these institutions face. The returns on saving/investment deposit are state
contingent. As the depositors are rewarded on a profit-loss sharing (PLS)
method, they share the business risks of the banking operations of the bank. The
profit/loss sharing feature of these depositors introduces some other risks.
Furthermore, the use of Islamic modes of financing on the asset sides changes
the nature of traditional risks. We outline the nature of risks that Islamic banks
face and risks inherent in different modes of financing below.
٢٤
One difference between Mushārakah and Muārabah is that while in the former case the
financier also has a role in management of the project, it does not in the latter case.
53
2.7.1. Nature of Risks faced by Islamic Banks
Credit Risk: Credit risk would take the form of settlement/payment risk
arising when one party to a deal pays money (e.g. in a Salam or Isti nā‘contract)
or delivers assets (e.g., in a Murāba ah contract) before receiving its own assets
or cash, thereby, exposing it to potential loss. In case of profit-sharing modes of
financing (like Muārabah and Mushārakah) the credit risk will be non-payment
of the share of the bank by the entrepreneur when it is due. This problem may
arise for banks in these cases due to the asymmetric information problem in
which they do not have sufficient information on the actual profit of the firm. As
Murāba ah contracts are trading contracts, credit risk arises in the form of
counterparty risk due to nonperformance of a trading partner. The non-
performance can be due to external systematic sources.
Benchmark Risk: As Islamic banks do not deal with interest rate, it
may appear that they do not have market risks arising from changes in the
interest rate. Changes in the market interest rate, however, introduce some risks
in the earnings of Islamic financial institutions. Financial institutions use a
benchmark rate, to price different financial instruments. Specifically, in a
Murāba ah contract the mark-up is determined by adding the risk premium to
the benchmark rate (usually the LIBOR). The nature of fixed income assets is
such that the mark-up is fixed for the duration of the contract. As such if the
benchmark rate changes, the mark-up rates on these fixed income contracts
cannot be adjusted. As a result Islamic banks face risks arising from movements
in market interest rate.
Liquidity Risk: As mentioned above, liquidity risk arises from either
difficulties in obtaining cash at reasonable cost from borrowings or sale of
assets. The liquidity risk arising from both sources is critical for Islamic banks.
As interest based loans are prohibited by Sharī‘ah, Islamic banks cannot borrow
funds to meet liquidity requirement in case of need. Furthermore, Sharī‘ah does
not allow the sale of debt, other than its face value. Thus, to raise funds by
selling debt-based assets is not an option for Islamic financial institutions.
Operational Risk: Given the newness of Islamic banks, operational risk
in terms of person risk can be acute in these institutions. Operational risk in this
respect particularly arises as the banks may not have enough qualified
professionals (capacity and capability) to conduct the Islamic financial
operations. Given the different nature of business the computer software
54
available in the market for conventional banks may not be appropriate for
Islamic banks. This gives rise to system risks of developing and using
informational technologies in Islamic banks.
Legal Risk: Given the different nature of financial contracts, Islamic
banks face risks related to their documentation and enforcement. As there are no
standard form of contracts for various financial instruments, Islamic banks
prepare these according to their understanding of the Sharī‘ah, the local laws,
and their needs and concerns. Lack of standardized contracts along with the fact
that there are no litigation systems to resolve problems associated with
enforceability of contracts by the counterparty increases the legal risks
associated with the Islamic contractual agreements.
Withdrawal Risk: A variable rate of return on saving/investment
deposits introduces uncertainty regarding the real value of deposits. Asset
preservation in terms of minimizing the risk of loss due to a lower rate of return
may be an important factor in depositors' withdrawal decisions. From the bank’s
perspective, this introduces a ‘withdrawal risk’ that is linked to the lower rate of
return relative to other financial institutions.
Fiduciary Risk: A lower rate of return than the market rate also
introduces fiduciary risk, when depositors/investors interpret a low rate of return
as breaching of investment contract or mismanagement of funds by the bank
(AAOIFI 1999). Fiduciary risk can be caused by breach of contract by the
Islamic bank. For example, the bank may not be able to fully comply with the
Sharī‘ah requirements of various contracts. While, the justification for the
Islamic banks’ business is compliance with the Sharī‘ah, an inability to do so or
not doing so willfully can cause a serious confidence problem and deposit
withdrawal.
Displaced Commercial Risk: This risk is the transfer of the risk
associated with deposits to equity holders. This arises when under commercial
pressure banks forgo a part of profit to pay the depositors to prevent withdrawals
due to a lower return (AAOIFI 1999). Displaced commercial risk implies that
the bank though may operate in full compliance with the Sharī‘ah requirements,
yet may not be able to pay competitive rates of return as compared to its peer
group Islamic banks and other competitors. Depositors will again have the
incentive to seek withdrawal. To prevent withdrawal, the owners of the bank
55
will need to apportion part of their own share in profits to the investment
depositors.
2.7.2. Unique Counterparty Risks of Islamic Modes of Finance
In this section we discuss some of the risks inherent in some Islamic
modes of financing.
2.7.2.1. Murāba ah Financing
Murāba ah is the most predominantly used Islamic financial contract. If
the contract is standardized its risk characteristics can be made parable to
interest-based financing. Based on similarity in risk characteristics of the contract
with the risk characteristics of interest-based contracts, Murāba ah is approved
to be an acceptable mode of finance in a number of regulatory jurisdictions.
However, such a standardized contract may not be acceptable to all Fiqh
scholars. Moreover, as the contract stands at present, there is a lack of complete
uniformity in Fiqh viewpoints. The different viewpoints can be a source of
counterparty risks as a result of the atmosphere of an ineffective litigation.
The main point in this regard stems from the fact that financial
Murāba ah is a contemporary contract. It has been designed by combining a
number of different contracts. There is a complete consensus among all Fiqh
scholars that this new contract has been approved as a form of deferred trading.
The condition of its validity is based on the fact that the bank must buy (become
owner) and after that transfer the ownership right to the client. The order placed
by the client is not a sale contract but it is merely a promise to buy. According to
the OIC Fiqh Academy Resolution, a promise can be binding on one party only.
OIC Fiqh Academy, AAOIFI, and most Islamic banks treat the promise to buy
as binding on the client. Some other scholars, however, are of the opinion that
the promise is not binding on the client; the client even after putting an order and
paying the commitment fee can rescind from the contract. The most important
counterparty risk specific to Murāba ah arises due to this unsettled nature of the
contract, which can pose litigation problems.
Another potential problem in a sale-contract like Murāba ah is late
payments by the counterparty as Islamic banks cannot, in principle, charge
anything in excess of the agreed upon price. Nonpayment of dues in the
stipulated time by the counterparty implies loss to banks.
56
2.7.2.2 Salam Financing
There are at least two important counterparty risks in Salam. A brief
discussion of these risks is provided here.
i. The counterparty risks can range from failure to supply on time or even
at all, and failure to supply the same quality of good as contractually
agreed. Since Salam is an agricultural based contract, the counterparty
risks may be due to factors beyond the normal credit quality of the
client. For example, the credit quality of the client may be very good but
the supply may not come as contractually agreed due to natural
calamities. Since agriculture is exposed to catastrophic risks, the
counterparty risks are expected to be more than normal in Salam.
ii. Salam contracts are neither exchange traded nor these are traded over
the counter. These contracts are written between two parties to a
contract. Thus all the Salam contracts end up in physical deliveries and
ownership of commodities. These commodities require inventories
exposing the banks to storage costs and other related price risk. Such
costs and risks are unique to Islamic banks.
2.7.2.3 Isti nā‘ Financing
While extending Isti nā‘ finance the bank exposes its capital to a number of
specific counterparty risks. These include for example:
i. The counterparty risks under Isti nā‘ faced by the bank from the
supplier’s side are similar to the risks mentioned under Salam. There
could be a contract failure regarding quality and time of delivery.
However, the object of Isti nā‘ is more in the control of the counterparty
and less exposed to natural calamities as compared to the object of
Salam. Therefore, it can be expected that the counterparty risk of the
sub-contractor of Isti nā‘ although substantially high, is lesser severe as
compared to that of the Salam.
ii. The default risk on the buyer’s side is of the general nature, namely,
failure in paying fully on time.
iii. If the Isti nā‘ contract is considered optional and not binding as the
fulfillment of conditions under certain Fiqhī jurisdictions may need,
57
there is a counterparty risk as the supplier maintains the option to
rescind from the contract.
iv. Considering that like the client in the Murāba ah contract, if the client
in the Isti nā‘ contract is given the option to rescind from the contract
and decline acceptance at the time of delivery, the bank will be exposed
to additional risks.
These risks exist because, an Islamic bank while entering into an Isti nā‘
contract assumes the role of a builder, a constructor, a manufacturer and
supplier. Since the bank does not specialize in these traits, it relies on
subcontractors.
2.7.2.4. Mushārakah - Muārabah (M-M) Financing
Many academic and policy oriented writings consider that the allocation
of funds by the Islamic banks on the basis of the Mushārakah and Muārabah is
preferable as compared to the fixed return modes of Murāba ah, leasing and
Isti nā‘. But in practice the Islamic banks’ use of the M-M modes is minimal.
This is considered to be due to the very high credit risk involved25.
The credit risk is expected to be high under the M-M modes due to the
fact that there is no collateral requirement, there is a high level of moral hazard
and adverse selection and banks’ existing competencies in project evaluation and
related techniques are limited. Institutional arrangements such as tax treatment,
accounting and auditing systems, regulatory framework are all not in favor of a
larger use of these modes by banks.
One possible way to reduce the risks in profit sharing modes of
financing is for Islamic banks to function as universal banks. Universal banks
can hold equity along with loans. In case of Islamic banks this would imply
financing using Mushārakah mode. Before investing in projects on this basis,
however, the bank needs to do a thorough feasibility study. By holding equity
positions, universal banks can essentially get involved in the decision making
and management of the firm. As a result, the bank will be able to monitor the use
of funds by the project more closely and reduce the moral hazard problem.
Some economists however, argue that banks by not opting for these
modes are actually not benefiting from portfolio diversification and hence taking
25
Credit risk in context of these modes is similar to the common notion of not receiving
the funds back on time or fully.
58
more risks rather than avoiding risks. Moreover, the use of M-M modes on both
sides of the banks’ balance sheets will actually enhance systemic stability as any
shocks on the asset side will be matched by an absorption of the shock on the
deposit side. It is also argued that incentive compatible contracts can be
formulated which can reduce the effect of moral hazard and adverse selection.
However, these arguments ignore the fact that banks basically specialize in
optimizing credit portfolios not optimizing in credit and equity portfolios.
Furthermore, since the Islamic banks’ use of current accounts on the liability
side is very high, the shocks on the assets side cannot be absorbed by these
accounts on the liability side. Hence greater use of M-M on the asset side could
actually cause a systemic instability given the large current accounts utilized by
the Islamic banks.
59
60
III
RISK MANAGEMENT:
A SURVEY OF ISLAMIC FINANCIAL
INSTITUTIONS
3.1. INTRODUCTION
This chapter examines different aspects of risk management issues in
Islamic financial institutions (FIs). Results from a survey based on
questionnaires and field level interviews with Islamic bankers are reported.
Questionnaires were sent to 68 Islamic financial institutions in 28 countries and
the authors visited Bahrain, Egypt, Malaysia and the UAE to discuss issues
related to risk management with the officials of the Islamic financial institutions.
A total of 17 questionnaires were received from 10 countries. The financial
institutions that responded and included in the study are given in Appendix 1.
Before discussing risk management related issues, we report averages of
some basic balance sheet data on Table 3.1. The average value of assets of 15
Islamic financial institutions stands at US$ 494.2 million with a capital of US$
73.4 million.26 The average capital/asset ratio of these institutions stands at 32.5
percent. This ratio is relatively large due to the inclusion of investment banks
that have higher capital/asset ratio. The lower section of the table shows the term
structure of assets. A large percentage of the assets (68.8 percent) of the
financial institutions have short-term maturity (of less than a year), 9.8 percent
have maturity between 1 to 3 years, and the remaining 31.4 percent are invested
in assets that are invested assets that mature after three years.
Table 3.1
Basic Balance Sheet Data (1999-2000)
Number of Average
Observations
Assets (Million US$) 15 494.2
Capital (Million US$) 15 73.4
Capital/Asset Ratio (Percentage) 15 32.5
Maturity of Assets
Less than 1 year(Percentage of Assets) 12 68.8
1-3 yearsa 12 9.8
More than 3 years 12 21.4
a-One financial institution reports term structure for 1-5 years.
٢٦
The data for the IDB was not included in these estimations, as given its size and nature, it
would bias the results.
61
The questions related to risk management issues in the questionnaire can
be broadly divided into two types. The first set of questions relates to
perceptions of the bankers related to different issues. They were asked to
identify the severity of different problems that their institutions faced on a scale
of 1 to 5, with 1 indicating “Not Serious” and 5 implying “Critically Serious”.
We report the average ranks of the available responses. Note that these rankings
are indicative of the relative risk perceptions of the bankers and do not mean
anything in the absolute sense. The second type of questions had either
affirmative/negative answers or are marked with an × if applicable. In these
cases we report the number of institutions in our sample that were marked to be
affirmative answers. The remaining answers were either negative or left
unanswered. One possible reason for abstention is that the question might not
have been relevant to the institution. For example, FIs not engaged in certain
modes of financing (like Salam and diminishing Mushārakah) may not have
responded to questions related to these instruments. Similarly, banks that are
operating only in the domestic economy are not exposed to exchange rate or
country risks and may have ignored questions related to these issues. For some
questions, however, multiple answers are possible. In these cases, it is possible
that the percentage of affirmative responses may add up to be greater than 100.
The results from the survey are discussed into three sections. The first
section examines the risk perceptions of the Islamic financial institutions. Given
the different nature of Islamic banks, the risks faced by these institutions are
identified and ranked according to their severity. The second section scrutinizes
different aspects of the risk management system and process in Islamic financial
institutions. To do so, we divide discussion into the three constituents of risk
management process outlined in Chapter 2. The third section discusses some
other issues related to risk management in Islamic financial institutions.
3.2. RISK PERCEPTIONS
The nature of Islamic banks is different from that of conventional
interest-based banks, mainly due to the profit-sharing features and modes of
financing used. This changes the kind of risks that these institutions face. In this
section, we report some perspectives of Islamic bankers regarding the risks that
their institutions face.
62
3.2.1.Overall Risks faced by Islamic Financial Institutions
Table 3.2 reports the average rankings of different kinds to risks faced
by Islamic FIs. Note that the rank has a range of 1 to 5, the former indicating
“Not serious” and the latter implying “Critically Serious”. It appears that Islamic
bankers rank the mark-up (interest rate) risk as the most critical risk they face
(3.07) followed by operational risk (2.92), and liquidity risk at 2.71. While credit
risk is the risk that most FIs deal with, they do not rank this risk as severe as
these risks (2.71). Among the risks listed, Islamic FIs consider market risk to be
the least risky (2.50).
The reasons for considering mark-up risk the highest may be that
Islamic debt contracts (like Murāba ah) cannot be repriced and cannot use
swaps to transfer this risk. Operational risk may have been ranked high because
given the new nature of Islamic banking a lot of the issues related to the
operations need to be instituted. These include training of employees, creating
computer programs and legal documents, etc. Liquidity risk is also ranked higher
than credit risk due to the lack of money market instruments to manage liquidity.
One reason of a relatively low credit risk may be that with asset or commodity
based financing that most Islamic FIs use, this risk is minimized as the
asset/commodity serves as collateral.
Table 3.2
Risk Perception-Overall Risks Faced by Islamic Financial Institutions
Number of Relevant Average Rank*
Responses
Credit Risk 14 2.71
Mark-up Risk 15 3.07
Liquidity Risk 16 2.81
Market Risk 10 2.50
Operational Risk 13 2.92
- The rank has a scale of 1 to 5, with 1 indicating ‘Not Serious’ and 5 denoting ‘Critically
Serious’.
Market risk is incurred on instruments like commodities and equities
traded in well-traded markets appears to be least risky. This risk arising from
movements in the prices of goods/securities are usually a part of the trading
book of a bank. On the banking book, conventional banks trade in bonds to keep
63
a part of their assets in liquid money-market instruments. As the majority of the
Sharī‘ah scholars forbid the sale of debt, trading in bonds almost nonexistent in
Islamic FIs.27 Islamic banks, however, can trade in commodities and assets
backed securities. The later securities are scant, leaving only trading in
commodities that can be as a source of market risk for Islamic FIs. As not too
many banks are involved in commodity trading, this may be a reason for a low
ranking of market risk by Islamic FIs.
3.2.2. Risks in Different Modes of Financing
Table 3.3 reports the Islamic bankers’ viewpoints on different kinds of
risks inherent in various Islamic modes of financing. The results of these risks
are discussed below.
Table 3.3
Risk Perception-Risks in different Modes of Financing
Credit Mark-up Risk Liquidity Operational Risk
Risk Risk
Murāba ah 2.56 2.87 2.67 2.93
(16) (15) (15) (14)
Muārabah 3.25 3.0 2.46 3.08
(12) (11) (13) (12)
Mushārakah 3.69 3.4 2.92 3.18
(13) (10) (12) (11)
Ijārah 2.64 2.92 3.1 2.9
(14) (12) (10) (10)
Isti nā‘ 3.13 3.57 3.0 3.29
(8) (7) (6) (7)
Salam 3.20 3.50 3.20 3.25
(5) (4) (5) (4)
Diminishing 3.33 3.4 3.33 3.4
Mushārakah (6) (5) (6) (5)
Note: The numbers in parentheses indicates the number of respondents.
- The rank has a scale of 1 to 5, with 1 indicating ‘Not Serious’ and 5 denoting ‘Critically
Serious’.
Credit Risk
Credit risk appears to be the least in Murāba ah (2.56) and the most in
Mushārakah (3.69) followed by diminishing Mushārakah (3.33) and Muārabah
٢٧
A form of debt-based bonds exists in Malaysia.
64
(3.25). It appears that profit-sharing modes of financing are perceived to have
higher credit risk by the bankers. Note that credit risk in case of profit-sharing
modes of financing arises if the counterparties do not pay the banks their due
profit-share. Furthermore, this amount if not known to banks ex ante. Ijārah
ranks as second (2.64) after Murāba ah as having the least credit risks. Like the
Murāba ah contract, Ijārah contract gives the banks a relatively certain income
and the ownership of the leased asset remains with the bank. Isti nā‘ and Salam
ranked at 3.13 and 3.20 respectively are relatively more risky. These product-
deferred modes of financing are perceived to be riskier than price-deferred sale
(Murāba ah). This may arise as the value of the product (and hence the return)
at the end of the contract period is uncertain. There are chances that the
counterparty may not be able to deliver the goods on time. This may arise to
different reasons like natural disasters (for commodities in a Salam contract) and
production failure (for products in Isti nā‘ contract). Even if the good is
delivered, there can be uncertainty regarding the price of the good upon delivery
affecting the rate of return.
The results on credit risk give some insight to the composition of
instruments in Islamic banks. We have noted earlier, Islamic banks’ assets are
concentrated in fixed-income assets (like Murāba ah and Ijārah). The results
from the survey indicate that one explanation for the concentration of assets in
fixed income assets may be that these instruments are perceived as having the
least credit risk among the Islamic modes of financing. As banks business is to
take up and manage credit risks, Islamic banks do not opt for other profit-sharing
modes of financing (like Muārabah and Mushārakah) as they regard these
instruments to be relatively more risky.
Mark-up Risk
Table 3.3 shows that mark-up risk ranked highest in terms of severity in
product-deferred contracts of Isti nā‘ (3.57) and Salam (3.5), followed by profit-
sharing modes of financing of Mushārakah and diminishing Mushārakah
(ranked at 3.4) and Muārabah (3.0).28 Murāba ah is considered to have the
least mark-up risk (2.87) followed by Ijārah (2.92). Mark-up (interest rate) risk
tends to be higher in long-term instruments with fixed rates. One reason for
higher concern of mark-up risk in Isti nā‘ may be that these instruments are
٢٨
Mark-up risk can appear in profit sharing modes of financing like Muārabah and
Mushārakah as profit-sharing ratio depends on, among others, a benchmark rate like LIBOR.
For a discussion on the determining profit-sharing ratio see Ahmed (2002).
65
usually of long-term nature. This is particularly true for real estate projects. The
contracts are tied up to a certain mark-up rate and changes in the interest rate
expose these contracts to risks. Murāba ah shows the least risk as this mode of
financing is usually short-term. After Murāba ah, Ijārah is conceived to have
relatively less mark-up risk. Even though Ijārah contracts may be of long-term,
the return (rent) on these contracts can be adjusted to reflect market conditions.
Among the profit-sharing modes of financing, the Islamic bankers rank
Mushārakah and diminishing Mushārakah relatively higher as these are usually
longer-term engagements. Muārabah is usually used for short-term financing
and has a lower mark-up risk than these two instruments.
Liquidity Risk
Liquidity risk of instruments will be smaller if the assets can be sold in
the markets and/or have short-term maturity. The bankers consider Muārabah
to have the least liquidity risk (2.46) followed by Murāba ah (2.67). Note that
both of these instruments are usually used for short term financing. Other
instruments are perceived as relatively more risky, with diminishing
Mushārakah showing the highest liquidity risk (with a rank of 3.33) and
product-deferred instruments of Salam and Isti nā‘ closely following at 3.2 and
3.0 respectively. Ijārah is also perceived to have a relatively higher liquidity risk
(3.1).
Operational Risk
As mentioned above, operational risk can arise from different sources.
Some aspects relevant to operational risk in Islamic banks are the legal risk
involved in contracts, the understanding of the modes of financing by
employees, producing computer programs and legal documents for different
instruments, etc. The rankings showing the operational risk for different
instruments should include these concerns. It appears that operational risk is
lower in fixed income assets of Murāba ah and Ijārah (2.93 and 2.9
respectively) and one of the highest in product-deferred sale contracts of Salam
and Isti nā‘ (3.25 and 3.29). Profit-sharing modes of financing of Muārabah
and Mushārakah follow close with ranks of 3.08 and 3.18 respectively.
Operational risk is highest in diminishing Mushārakah (3.4). The relatively
higher rankings of the instruments indicate that banks find these contracts
complex and difficult to implement.
66
3.2.3. Additional Issues regarding Risks faced by Islamic Financial
Institutions
Table 3.4 shows the Islamic bankers’ viewpoints on some specific risk
related issues related to Islamic FIs. Given that the Islamic banking is a
relatively new industry, the Islamic bankers are of the view that there is a lack of
understanding of the risks involved in Islamic modes of financing. They rank the
gravity of this problem at 3.82. As the rates of returns on deposits in Islamic
banks are based on profit sharing, this imposes certain risks on the liability side
of the balance sheet. Even though returns on deposits can vary, Islamic banks are
under pressure to give the depositors return similar to that of other banks. They
rank this concern at 3.64. This factor is important as a lower return than that
given by other banks leads to two additional risks. First, the withdrawal risk that
can result from a lower rate of return is considered serious as shown by its
ranking of 3.64. The banks also regard fiduciary risk, in which the depositors
blame the bank for a lower rate of return, serious with a rank of 3.21.
Table 3.4
Risk Perception-Additional Issues regarding Risks faced by Islamic
Financial Institutions
No. of Average
Relevant Rank*
Responses
1. Lack of understanding of risks involved in Islamic 17 3.82
modes of financing.
2. The rate of return on deposits has to be similar to 14 3.64
that offered by other banks.
3. Withdrawal Risk: A low rate of return on deposits 14 3.64
will lead to withdrawal of funds
4. Fiduciary Risk: Depositors would hold the bank 14 3.21
responsible for a lower rate of return on deposits
- The rank has a scale of 1 to 5, with 1 indicating ‘Not Serious’ and 5 denoting ‘Critically
Serious’.
Note that most of the rankings in Table 3.4 that Islamic bankers assign
to specific risks faced by their institutions are higher than all the rankings of
traditional risks that financial institutions face (as reported in Table 3.2). To
have some indication of this we compare the averages of these specific risks
faced by Islamic banks (Table 3.4) with that of the traditional risks (Table 3.2).
The average for the former is 3.58 while it is 2.80 for the latter. Thus, Islamic
banks not only face some risks that are different from conventional banks, but
67
there is a feeling that these risks are more serious and not well understood. This
calls for more research in risk related issues in Islamic FIs to understand and
manage these risks.
Islamic financial institutions have also identified other risks that they
face. At the government level, these include legal aspects and taxes (e.g., taxes
on interest, leases, Murāba ah profit, and services). At the central bank level,
additional risks include those arising central bank regulations and legislation, no
Islamic window for borrowing in terms of need. Other risks pointed are those
arising from Sharī‘ah, non-availability of short-term funds foreign exchange,
natural disasters, specific industries, domestic economy and politics, and
international financial and market environment.
3.3. RISK MANAGEMENT SYSTEM AND PROCESS
As discussed in Chapter 2, the system and process of risk management has three
main constituents. We discuss the risk management practices of Islamic financial
institutions under these three heads below. As mentioned above, we report the
affirmative answers given to different questions by the institutions in the sample.
3.3.1. Establishing Appropriate Risk Management Environment and Sound
Policies and Procedures
Table 3.5 reports some aspects of establishing a risk management
environment. While 13 institutions (76.5 percent) of the institutions have a
formal risk management system in place, 16 (94.1 percent) institutions have a
section/committee responsible for identifying, monitoring and controlling
various risks. The same number of institutions (16) have internal guidelines,
rules and concrete procedures related to risk management. In the sample, 13
(76.5 percent) banks have a clear policy of promoting asset quality and 14 (82.4
percent) of them have guidelines that are used for loan approvals. Only 12 banks
(70.6 percent) determine the mark-up rates on loans by taking account of the
loan grading or the risks of the counterparty.
68
Table 3.5
Establishing an Appropriate Risk Management Environment, Policies and
Procedures
No. of Percentage
Affirmative of Total
Responses
1. Do you have a formal system of Risk 13 76.5
Management in place in your organization?
2. Is there a section/committee responsible for 16 94.1
identifying, monitoring, and controlling various
risks?
3. Does the bank have internal guidelines/rules and 16 94.1
concrete procedures with respect to the risk
management system?
4. Is there a clear policy promoting asset quality? 13 76.5
5. Has the bank adopted and utilized guidelines for a 14 82.4
loan approval system?
6. Are mark-up rates on loans set taking account of 12 70.6
the loan grading?
3.3.2. Maintaining an Appropriate Risk Measurement, Mitigating, and
Monitoring Process
Table 3.6 shows the number of affirmative responses to some issues
related to risk measurement and mitigating process. A relatively small number of
Islamic banks in the sample (41.2 percent) have a computerized support system
to estimate the variability of earnings for risk management purposes. The main
risk faced by banks is credit risk. To mitigate this risk majority of the banks
(94.1 percent) has credit limits for individual counterparty and 13 institutions
(76.5 percent) have a system for managing problem loans. Most banks have a
policy of diversifying investments across sectors and industries (88.2 percent
and 82.4 percent respectively). A smaller number of banks (64.7 percent)
diversify their investments across countries. This lower number may reflect the
fact that some banks operate only domestically. To measure and manage
liquidity risk, 12 institutions (70.6 percent) compile maturity ladder chart to
monitor cash flows and gaps. To measure benchmark or interest rate risk, a small
fraction of the institutions (only 29.4 percent) use simulation analysis. Around
three-quarters of the banks (76.5 percent) have a regular reporting system on risk
management for senior management.
69
Table 3.6
Maintaining an Appropriate Risk Measuring, Mitigating, and Monitoring
Process
No. of % of
Affirmative Total
Responses
1. Is there a computerized support system for 7 41.2
estimating the variability of earnings and risk
management?
2. Are credit limits for individual counterparty set 16 94.1
and are these strictly monitored?
3. Does the bank have a policy of diversifying investments across:
a) Different countries 11 64.7
b) Different sectors (like manufacturing, trading 15 88.2
etc.)
c) Different Industries (like airlines, retail, etc.) 14 82.4
4 Does the bank have in place a system for 13 76.5
managing problem loans?
7. Does the bank regularly (e.g. weekly) compile a 12 70.6
maturity ladder chart according to settlement date
and monitor cash position gaps?
8. Does the bank regularly conduct simulation 5 29.4
analysis and measure benchmark (interest) rate
risk sensitivity?
9. Does the bank have in place a regular reporting 13 76.5
system regarding risk management for senior
officers and management?
Table 3.7 shows the different risk reports that the banks in the sample
produce. Note that a few institutions have indicated that they may not have
separate risk reports as indicated in the table, but may prepare report(s) that may
include information on some of these risks. The table shows that the most widely
used report in the Islamic banks is liquidity risk report with 13 banks (76.5
percent) producing these, followed by credit risk report (70.6 percent). The
operational risk reports are least used with only 3 institutions (17.6 percent)
producing these. Few institutions produce interest rate reports (23.5 percent) and
aggregate market risk report (29.4 percent). While11 Islamic banks in the sample
(64.7 percent) have capital at risk report 10 banks (58.8 percent) produce
commodities and equities position risk reports, relatively fewer institutions
prepare foreign exchange and country risk reports (41.2 percent and 35.3 percent
respectively). One reason for these low numbers may be that some countries
operate domestically only and as such are not exposed to either foreign exchange
or country risks.
70
Table 3.7
Maintaining an Appropriate Risk Measuring, Mitigating, and Monitoring
Process-Risk Reports
No. of Percentage
Affirmative of Total
Responses
1. Capital at Risk Report 11 64.7
2. Credit Risk Report 12 70.6
3. Aggregate Market Risk Report 5 29.4
4. Interest Rate Risk Report 4 23.5
5. Liquidity Risk Report 13 76.5
6. Foreign Exchange Risk Report 7 41.2
7. Commodities & Equities Position Risk Report 10 58.8
8. Operational Risk Report 3 17.6
9. Country Risk Report 6 35.3
Some financial institutions produce other specific risk reports not
included in Table 3.7 above. These include Compliance Risk Report, Bad and
Doubtful Receivables Report, Monthly Progress Report, Defaulting Cases
Report, and Related Party Exposure Report.
Table 3.8 exhibits different risk measuring and mitigation techniques
used by Islamic banks. There may be a variety of formats in which these
techniques can be used, ranging from very simple analysis to sophisticated
models. The most common risk measuring and managing technique is the credit
ratings of prospective investors used by 76.5 percent of the institutions in the
sample. Around 65 percent of the institutions use internal rating system for these
ratings.29 Maturity matching analysis to mitigate liquidity risks is used by 10
institutions (58.8 percent). While more than half of the institutions (52.9 percent)
estimate worst case scenarios, 47.1 percent of them use duration analysis to
estimate interest rate risk and risk adjusted rate of return on capital (RAROC) to
determine the overall risk. Seven banks (41.2 percent) in the sample use
different types of Earnings at Risk, Value at Risk. Only 29.4 percent of the
banks use simulation techniques to assess different risks.
٢٩
The internal rating system is used by large commercial banks to determine the economic
capital they should hold as insurance against losses. BIS (2001) is trying to introduce the
internal rating system to determine the capital requirements of banks in its new standards
(see, section four). The internal rating system which the Islamic banks have reported using
can be considered as a simple listing of assets in accordance with their quality particularly,
for provisioning loan loss reserves.
71
Table 3.8
Maintaining an Appropriate Risk Measuring, Mitigating, and Monitoring
Process-Measuring and Management Techniques
No. of Affirmative Percentage
Responses of Total
1. Credit Ratings of Prospective Investors 13 76.5
2. Gap Analysis 5 29.4
3. Duration Analysis 8 47.1
4. Maturity Matching Analysis 10 58.8
5. Earnings at Risk 7 41.2
6. Value at Risk 7 41.2
7. Simulation techniques 5 29.4
8. Estimates of Worst Case scenarios 9 52.9
9. Risk Adjusted Rate of Return on Capital 8 47.1
(RAROC)
10. Internal Rating System 11 64.7
The banks indicate the use of some other techniques not listed in Table
3.8 above. These include analysis of the collateral, sector and market exposure
of debtors, lending, risk analysis, measuring the effect of price of a particular
commodity (like oil) and global stock market on borrower.
Table 3.9 focuses on the monitoring aspects of risk management. Note
that there can be more than one answer to the questions so the sum of the
percentages (given in parenthesis) may exceed 100.30 Almost 70 percent of the
banks reappraise the collateral regularly and 29.4 percent of them do so
occasionally. A large percentage of the banks (82.4 percent) also confirm a
guarantor’s intention to guarantee loans regularly. One institution reviews such
guarantee occasionally. For institutions engaged in international investments, 8
(47.1 percent) review the country ratings regularly, 3 (17.7 percent) do so
occasionally and 1 bank does not review these ratings at all. Note that specific
question on reserve provision for losses was omitted in the questionnaire.
Though most Islamic banks have excess reserves, the information on RAROC
indicates about half of these institutions estimate risk capital to account for
unexpected losses.
٣٠
Five institutions had more than one answer. The bank can have more than one answer as
they may take different approaches depending on the asset type and the tenure of the contract.
72
While a significant number of banks (76.5 percent) use international
accounting standards, only 64.7 percent of them use AAOIFI standards. Five
institutions report using other accounting standards, mainly national ones. The
frequency of assessing profit and loss positions is daily for 7 (41.2 percent)
institutions, weekly for 4 (23.5 percent) banks and monthly for almost 70
percent of the banks.
Table 3.9
Maintaining an Appropriate Risk Measuring, Mitigating, and Monitoring
Process- Risk Monitoring
Regularly Occasionally Never
1. Does the bank periodically 12 5
reappraise collateral (asset)? (70.6%) (29.4%)
2. Does the bank confirm a 14 1
guarantor’s intention to guarantee (82.4%) (5.9%)
loans with a signed document?
3. If loans are international, does the 8 3 1
bank regularly review country (47.1%) (17.7%) (5.9%)
ratings?
4. Does the bank monitor the 12 2
borrower’s business performance (70.6%) (11.8%)
after loan extension?
International AAOIFI Other
5. Does the accounting standards 13 11 5
used by the bank comply with the (76.5%) (64.7%) (29.4%)
following standards?
Daily Weekly Monthly
6. Positions and Profits/Losses are 7 4 12
assessed? (41.2%) (23.5%) (70.6%)
3.3.3. Adequate Internal Controls
Table 3.10 points out some aspects of internal controls that Islamic FIs
have in place. Eleven banks (64.7 percent) indicate that they have some form of
internal control system in place that can promptly identify risks arising from
changes in the environment. The same number of banks have countermeasures
and contingency plans against disasters and accidents. A large percentage (82.4
percent) of the banks has separated duties of those who generate risks and those
who manage and control risks. Thirteen banks (76.5 percent) indicate that
internal auditor reviews and verifies the risk management systems, guidelines,
73
and risk reports. A high of 94.1 percent of these institutions have backups of
software and data files.
Table 3.10
Adequate Internal Controls
No. of Percentage
Affirmative of Total
Responses
1. Does the bank have in place an internal 11 64.7
control system capable of swiftly dealing with
newly recognized risks arising from changes
in environment, etc.?
2. Is there a separation of duties between those 14 82.4
who generate risks and those who manage
and control risks?
3. Does the bank have countermeasures 11 64.7
(contingency plans) against disasters and
accidents?
4. Is the Internal Auditor responsible to review 13 76.5
and verify the risk management systems,
guidelines, and risk reports?
5. Does the bank have backups of software and 16 94.1
data files?
3.4. OTHER ISSUES AND CONCERNS
In recent times there has been an exponential growth in the use of
derivatives by conventional financial institutions for both risk mitigation and
income generating purposes. There are, however reservations regarding use of
derivatives from the Sharī‘ah perspectives. As such, with an exception of a few,
most Islamic financial institutions do not use derivatives. This is revealed in
Tables 3.11 and 3.12. Table 3.11 shows the institutions using derivatives for
hedging (risk mitigation) purposes and Table 3.12 points out the number of
banks using these instruments for income generating purposes. These tables
show that while there is only one case of use of forward contracts for income
generating purposes, there are several cases of use of derivatives for risk
mitigation purposes. Specifically, there are three cases of currency forwards, and
one case each of commodity forwards, currency swaps, commodity swaps, and
mark-up swaps. The case of mark-up swap (or profit rate swap) is interesting.
74
Table 3.11
Use of Derivatives for Hedging (Risk management) Purposes (No. of
Institutions)
Forwards Futures Options Swaps
Currency 3 - - 1
Commodity 1 - - 1
Equity - - - -
Mark-up Rate - - - 1
Table 3.12
Use of Derivatives for Income Generation Purposes (No. of Institutions)
Forwards Futures Options Swaps
Currency 1 - - -
Commodity - - - -
Equity - - - -
Interest Rate - - - -
Table 3.13
Lack of Instruments/Institutions related to Risk Management
No. of Relevant Average
Responses Rank*
1. Short-term Islamic financial assets that can be 15 3.87
sold in secondary markets
2. Islamic money markets to borrow funds in case 16 4.13
of need.
3. Inability to use derivatives for hedging. 14 3.93
4. Inability to re-price fixed return assets (like 16 3.06
Murāba ah) when the benchmark rate changes.
5. Lack of legal system to deal with defaulters. 15 4.07
6. Lack of regulatory framework for Islamic banks. 15 3.8
- The rank has a scale of 1 to 5, with 1 indicating ‘Not Serious’ and 5 denoting ‘Critically
Serious’.
Table 3.13 sheds light on the seriousness of some constraints that
Islamic financial institutions face in managing risks. The first two concerns
relate to the lack of financial instruments/institutions for liquidity risk
management. Lack of Islamic financial assets that can be bought/sold in
secondary markets is ranked at a high of 3.87 and the absence of Islamic money
markets to borrow funds in case of need at 4.13. The banks rank inability to use
derivatives to transfer risks at 3.93. Among the concerns listed in the table,
75
inability to reprice assets is considered the least serious (ranked at 3.06). This
may be due to the fact that the most of the assets in Islamic banks use have
short-term maturity and interest rate risk is relatively small. The bankers,
however, have worries about legal and regulatory risks. These are ranked at 4.07
and 3.8 respectively. Note that these constraints identified by Islamic banks are
ranked much higher than the traditional risks (like credit risk, interest rate risk,
etc. listed in Table 2) that these institutions face.
Table 3.14 reports the responses of Islamic banks to some issues related
to their operations. Ten banks (58.8 percent) in the sample are actively engaged
in research to develop Islamic compatible risk management instruments and
techniques. When a new risk management product or scheme is introduced, a
significant number of Islamic banks (76.5 percent) get clearance from the
Sharī‘ah board. Only three banks (17.7 percent) have used securitization to raise
funds and transfer risks. A relatively small number of banks (41.2 percent) have
a reserve that is used to increase the profit share of depositors in low performing
years. This is done mainly to mitigate the withdrawal and fiduciary risks that
Islamic banks face. Note that investment banks and the only development bank
(IDB) do not have depositors in the traditional sense and this question does not
apply to them.
Table 3.14
Other Issues related to Islamic Financial Institutions
No. of Affirmative Percentage
Responses of Total
1. Is your bank actively engaged in research to 10 58.8
develop Islamic compatible Risk
Management instruments and techniques?
2. When a new risk management product or 13 76.5
scheme is introduced, does the bank get
clearance from the Sharī‘ah Board?
3. Does the bank use securitization to raise 3 17.7
funds for specific investments/projects?
4. Do you have a reserve that is used to 7 41.2
increase the profit share (rate of return) of
depositors in low-performing periods.
5. Is your bank of the view that the Basel 10 58.8
Committee standards should be equally
applicable to Islamic banks?
6. Is your organization of the view that 9 52.9
supervisors/regulators are able to assess the
true risks inherent in Islamic banks?
7. Does your organization consider that the 9 52.9
76
risks of investment depositors and current
accounts shall not mix?
The final set of questions in Table 3.14 relates to the regulatory aspects
of Islamic banks. Only 9 banks (52.9 percent) are of the view that
supervisors/regulators are able to assess the risks inherent in Islamic banks and
10 (58.8 percent) of them conclude that the Basel Committee standards should
be equally applicable to Islamic banks. Nearly half of the banks (52.9 percent)
believe that risks of investment deposits and current accounts should not mix.
The views of Islamic financial institutions regarding the capital requirements is
shown in Table 15.3. As is seen, the views given are different. Seven banks
(41.2 percent) are of the view that the capital requirements for Islamic banks
should be less than conventional banks, 6 banks (35.3 percent) think it should be
equal to that of their conventional counterparts, and only three institutions
acknowledge this should be less.
Table 3.15
Capital Requirement in Islamic Banks compared to Conventional Banks
Less Same More
Do you think that the capital 7 6 3
requirements for Islamic (41.2%) (35.3%) (17.7%)
banks as compared to
conventional banks should be
3.5. RISK MANAGEMNET IN ISLAMIC FINANCIAL INSTITUTIONS:
AN ASSESSMENT
The above analysis has touched on different aspects of risk management
in Islamic FIs. It first identifies the severity of different risks and then examines
the risk management process in Islamic banks. Among the traditional risks
facing Islamic banks, mark-up risk is ranked the highest, followed by operational
risk. The results show that Islamic financial institutions face some risks that are
different from that faced by conventional financial institutions. These banks
reveal that some of these risks are considered more serious than the conventional
risks faced by financial institutions. Profit-sharing modes of financing
(diminishing Mushārakah, Mushārakah and Muārabah) and product-deferred
sale (Salam and Isti nā‘) are considered more riskier than Murāba ah and
Ijārah. Other risks arise in Islamic banks as they pay depositors a share of the
profit that is not fixed ex ante. The Islamic banks are under pressure to give
returns similar to other institutions, as they believe that the depositors will hold
77
the bank responsible for a lower rate of return and may cause withdrawal of
funds by the depositors.
In order to get an overall assessment of the risk management system of
Islamic FIs, we report averages of the three constituents of this process. The
average score represents the sum of affirmative answers as a percentage of the
total possible answers in each component. For example, the average score for
“Establishing an Appropriate Risk Management Environment, Policies, and
Procedures” (Table 3.5) is 82.4 percent. We arrive at this number by taking the
sum of all affirmative answers given by financial institutions in Table 3.5 (i.e.
84) as a percentage of all possible affirmative answers (i.e. 17×6=102). The
corresponding figures for “Maintaining an Appropriate Risk Measuring,
Mitigating, and Monitoring Process” (Table 3.6) and “Adequate Internal
Controls” (Table 3.10) are 69.3 percent and 76 percent respectively.
These figures indicate that Islamic banks have been able to establish
better risk management policies and procedures (82.4 percent) than measuring,
mitigating, and monitoring risks (69.3 percent), with internal controls
somewhere in the middle (76 percent). We note two points from these results.
First, the overall averages are relatively high. One reason of this may be that
there is an upward bias of the banks included in the sample. We believe that the
banks that have relatively better risk management systems have responded to the
questionnaires giving these higher averages. Second, the relative percentages
indicate that Islamic financial institutions have to upgrade their measuring,
mitigating, and monitoring process followed by internal controls to improve
their risk management system.
The results also point out that the lack of some instruments (like short-
term financial assets and derivatives) and money market hampers risk
management in Islamic financial institutions. There is a need for research in
these areas to develop instruments and their markets that are compatible with
Sharī‘ah. At the government level, the legal system and regulatory framework of
the Islamic financial system needs to be understood and appropriate policies
undertaken to cater to the needs of Islamic banks.
It should be noted that the views expressed in this chapter are those of
Islamic bankers. As pointed out in the Introduction, the view of risks and their
management of the bankers will differ from the perspectives of the regulators
and the members of Sharī‘ah board. Given the different objectives, regulators
78
and Sharī‘ah experts may take a more conservative approach towards risk and
its management. These perspectives are discussed in the following chapters.
79
IV
RISK MANAGEMENT:
REGULATORY PERSPECTIVES
4.1 ECONOMIC RATIONALE OF REGULATORY CONTROL ON
BANK RISKS
Banks generate assets by using depositors’ funds. Since the rate of
return on the banks’ equity depends on the volume of assets accumulated, banks
have the natural inclination to mix little amount of their own equity with as
much of depositors’ money as possible. Hence banks’ assets exceed their
equities several times. If assets are far larger than equities, even a small loss on
assets could be enough to wipe out a bank’s equity and cause it to collapse and
loss to depositors. As a result of the contagion effects and disruptions in the
payments and settlement processes, the collapse of even a small bank can be a
source of a big systemic instability. The Islamic banks are no exception to this
systemic phenomenon. Liberalization, electronic banking and clearance and
settlement processes, availability of diverse financial assets, financial
consolidation and emergence of highly leveraged institutions have added to the
fragility of financial systems. The primary concern of regulatory standards and
supervisory oversights is to ensure systemic stability, protect the interest of
depositors and enhance the public’s confidence on the financial intermediation
system. However, due to the rapidly changing nature of financial markets,
regulatory and supervisory standard setting appears to always remain as a “work
in progress”. In this section we discuss regulatory and supervisory concerns with
risk management at the level of individual banks. We also present an overview
of the recent supervisory trends in aligning bank capital with asset risks and the
implications of this for Islamic banks.
4.1.1. Controlling Systemic Risks
Systemic risk is the probability that failure of even a small bank could
result in the contagion effect and the whole payments system could be disrupted.
This could lead to a financial crisis, decline in the value of assets in place,
impairing growth taking capabilities of the economy, creating unemployment,
decreasing economic welfare and even causing social and political instability.
80
For a number of reasons banks are the only institutions having such significance
for systemic stability.
i) Banks are not only business firms but are also agents of the payments,
clearance and settlement system.
ii) Banks are highly leveraged and exposed to financial risks and instability.
iii. Regulatory interference is not always perfect. Particularly, deposit
protection schemes and lender of last resort facilities create moral hazard
on the part of both banks and depositors.
iv. Due to financial liberalization, technological and computing revolution,
and electronic banking, clearing and settlements systems have enabled
banking to cross-geographic boundaries and regulatory jurisdictions.
v. The extent of mergers, financial consolidation and cross-segment
activities – banks writing insurance contracts, insurance companies
undertaking investment activities and investment banks mobilizing
deposits etc., is on the rise leading to the mixing of the risks of these
different segments. The systemic importance of a bank is different
compared to an investment firm or an insurance company. The failure of
a bank creates a severe contagion effects due to the disruption of the
payments and settlement processes. Compared to this the failure of an
insurance or investment firm will have a more isolated effect on the firm
itself. Moreover, insurance firms and investment banks are not covered
by lender of last resort or deposit insurance schemes; hence they do not
face moral hazard and adverse selection problems as such. Furthermore,
the nature of liabilities and assets of banks and the other firms are
different. Cross-segment activities blur all these functional differences
and mix the different types of risks, making regulation and supervision
more important.31
vi. An important source of systemic risk is the relationship of banks with
highly leveraged firms. Banks are not only highly leveraged themselves,
31
Banks are prone to “runs” for a number of reasons: (i) Banks owe to depositors and other
creditors fixed obligations irrespective of the quality of their assets (this feature, however
does not exist in Islamic banks), (ii) The value of bank assets is not known to depositors –
bank runs thus are psychological and confidence matter rather than a true assessment of asset
values of banks (iii) depositors are paid on the basis of first come first served if bank run
happens leading to a run in case of problems and (iv) banks are much more interconnected
through the payments and settlement process – depositors know that. See (Llewellyn 1999).
81
but are also a source of creating leverage. Leverage increases financial
risks and creates financial instability. Banks themselves being highly
leveraged can be severely destabilized if they keep large exposures to
other highly leveraged firms. Therefore banks need to be aware about
the risks and risk management systems of their counterparties.32
vii. Banks undertake large amounts of off-balance sheet activities.
Particularly, due to an increase in securitization and derivative activities
these off-balance sheet activities have increased disproportionately.
These activities although useful are a source of disguise leverage of
banks.
4.1.2 Enhancing the Public’s Confidence in Markets
The efficiency of financial markets depends on the confidence of the
public in the financial intermediaries, which in turn depends on the integrity of
these institutions. Public confidence in financial institutions strengthens the
financial intermediation system and the society as a whole benefit from these in
terms of financial efficiency and stability. Some of the benefits of financial
intermediation which need to be strengthened by the regulatory process are
given here:
i. Due to economies of scale, specialization and technical expertise,
financial intermediaries are more suited to evaluate the risks of
counterparties as compared to individual savers. Thus financial
intermediation reduces information cost, moral hazard and adverse
selection and consequently the cost of finance. Due to lack of
confidence on the financial intermediation system the public could
withdraw from it. As a result, the cost of funds in the economy will
increase leading to an inefficient allocation of resources.
32
A classical real world case of a relatively small firm potentially causing a meltdown of
global financial markets happened in September 1998 when Long-Term Capital Management
(LTCM), a US Hedge Fund with a capital of $ 4.8 billion and assets of $ 200 billion was
rescued by regulators. Collapse of the LTCM could have caused a serious systemic
instability. This incident triggered a series of regulatory guidelines and standards regarding
banks’ relationship with highly leveraged firms and counter party risk management. See, for
example, Report of the (US) Presidents’ Working Group on Hedge Fund, Leverage and the
Lessons of Long-Term Capital Management (1999), BCBS, Sound Practices for Banks'
Interaction with Highly Leveraged Institutions (1999). All BCBS publications can be
accessed at: www.bis.org.
82
ii. Financial intermediaries reduce a number of mismatches between the
preferences and needs of savers and investors. These are maturity
mismatches, size of fund mismatches and liquidity mismatches. As a
result of confidence problem these mismatches could increase,
increasing the frictions in the process of resource allocation.
iii. Financial intermediaries are much more capable of assessing the risks of
alternative investment opportunities in comparison to individual savers.
As a result of a confidence problem this comparative advantage cannot
be utilized.
iv. Efficiency in processing the transactions of the payments system is
extremely important for reducing the transaction costs. Electronic
systems have made the process even more critical for the competitive
efficiency of an economy. Lack of public confidence in the financial
institutions can impair the utilization of the payments facilities and the
economy can be inefficient as compared to its competitors.
In order to enhance the public’s confidence on the financial
intermediation system, the interests of depositors and other users of financial
services need to be protected. Depositors of banks in particular and users of
financial services in general are not in a position to protect their own interests
like the shareholders of banks and other firms. There are a number of reasons for
this that require regulatory and supervisory oversight.
i. Depositors and other customers of the financial services industry are
numerous and often have short-term relationships with banks and other
financial institutions. As a group and individually, they are not able to
monitor the activities of financial institutions, which always involve
complex long-term contracts.
ii. Financial institutions play important fiduciary role. The financial
contracts at the time of selling to the clients may be of a particular
nature. These contracts may later be changed due to genuine needs or
merely due to moral hazard on the part of the institutions. Customers
cannot effectively monitor the enforcement of the contracts in their own
best interest overtime.
83
iii. Customer protection has become even more important in the new regime
of e-banking, rising trends of money laundering and other acts of deceit
on the part of some elements.
For these and other reasons the regulatory and supervisory authorities
have to safeguard and protect the interests of customers. Without such a
protection and safeguard the integrity of markets cannot be ensured and the
confidence of customers on the financial institutions cannot be strengthened. As
a result, inefficiency, systematic instability and financial crisis can grip the
markets effecting economic development and welfare adversely.
4.1.3 Controlling the Risk of Moral Hazard
Some of the policies and safety nets introduced by regulatory authorities
to protect the integrity of markets, to safeguard the interests of depositors and to
avoid systemic risks often become the source of moral hazard on the part of
depositors as well as banks. Regulation and supervision is also required to
safeguard these safety net arrangements.
i. The lender of last resort (LLR) facility of central banks aims at
preventing bank runs by providing liquidity facility to banks in times of
crisis. Many studies indicate that since central banks are there to rescue
banks, particularly, banks which are “too big to fail”, they behave
imprudently. In addition to the regulatory oversight, it is often
recommended that the LLR facility shall be provided at a very high cost
and that the private sector shall participate in overcoming any financial
crisis by taking direct responsibility for financial losses.
ii. The deposit insurance schemes aim at providing protection to depositors
in case of bank failure. Since the depositors have to lose nothing as the
deposits are insured, banks undertake risky activities. Since the rate of
interest on deposits is fixed, in case of success of their risky operations,
all the high return are accrued to the owners of banks and in case of
losses deposits are protected in any way. Since deposits are protected,
depositors also have no incentive to monitor the activities of banks. Thus
a number of studies have found that financial instability is high in
countries where deposits are fully protected33. An effective regulatory
and supervisory oversight is thus required to prevent or at least minimize
٣٣
See, Demirguc and Enrica (2000).
84
the adverse consequences of the safety net schemes put in place by the
public authorities.
4.2 INSTRUMENTS OF REGULATION AND SUPERVISION
The regulation of financial institutions is generally classified into
conduct of business regulation and prudential regulation. The former type of
regulation is required to protect the interests of customers. The interests of
customers can be protected by requiring banks to put certain minimum amount
of their own capital at stake and ensuring timely disclosure of accurate
information. Establishing a satisfactory level of competence and integrity in
supplying banking services, maintaining a leveled playing field for competition
and ensuring the production and supply of fair financial contracts and products
are also the primary requirements in this regard. To achieve these objectives of
conduct of business regulation, uniform sets of standards, rules and guidelines
are required. Prudential regulation is directed at systemic safety by ensuring the
soundness of individual financial institutions through the application of the set
standards and guidelines across institutions. The instruments used for the
regulation and supervision of financial institutions can broadly be classified into
three categories:
a) Ensuring the maintenance of a minimum level of risk-based capital,
b) Putting in place an effective system of risk-based supervision and
c) Making certain the timely disclosure of correct information about
risk management systems and processes.
4.2.1 Regulating Risk Capital: Current Standards and New Proposals
Bank capital is the most effective source of protection against risks. It is
also an effective means of regulation because capital standards can be enforced
uniformly across institutions and jurisdictions. In general, capital refers to
shareholders’ equity. Capital is required to support the risks of assets and for its
stabilization and confidence building role, particularly, against the eventuality of
any crisis and in fact when it arises. Traditionally, adequacy of capital in a
banking firm is gauged by the capital/asset ratio i.e., the leverage ratio (LR). The
LR does not cover the relative risks of different assets. In addition, it does not
take into account the stabilization role of funds, which due to their long-term
maturity as compared to deposits have the potential to relieve the pressure on
shareholders’ equity in case of a crisis. Therefore, the 1988 Basel Capital
85
Accord34 introduced the concept of risk weights for assets and it distinguishes
between tier-1 and tier-2 capital35. The Accord requires that internationally
active banks in G-10 countries shall maintain at least 3% leverage ratio, at least
4% tier-1 capital against risk weighted assets (RWAs) and at least 8% total
capital (tier-1 plus tier-2) against RWAs36. In this section we briefly overview
the salient features of the existing and proposed regulatory capital standards.
4.2.1.1 Regulatory Capital for Credit Risk: Present Standards
Credit risks are so much important for banks and from regulators’
perspective that the 1988 Capital Accord requires capital only against credit
risks for on-balance sheet and off-balance sheet assets of banks. Banks are in
the business of borrowing money to lend. As a result of lending, receivables
from clients make an overwhelming part of their total assets. The quality of
these assets, therefore, depends on the timely and full repayment by the clients.
A failure to do so, i.e. default, is always probable depending on the credit quality
of the client. The primary concern of regulators is, therefore, that banks should
be aware of their credit risk and maintain a minimum level of capital to
overcome any instability caused by default by a client. Total assets of a bank are
put into five risk categories (0%, 10%, 20%, 50% and 100%). Summary
٣٤
The Basel Committee for Banking Supervision – an international standard setting body
was established by the Central Bank Governors of the Group of Ten Countries at the end of
1974. The Committee's members now come from Belgium, Canada, France, Germany, Italy,
Japan, Luxembourg, the Netherlands, Spain, Sweden, Switzerland, United Kingdom and
United States. In 1988, the Committee decided to introduce a capital measurement system
commonly referred to as the Basel Capital Accord. This system provided for the
implementation of a credit risk measurement framework with the aim to establish a minimum
capital standard of 8% of total risk-weighted assets by the end of 1992. In 1996 the Accord
was amended also to require capital for market risks. The Accord is expected to remain
effective till 2005 when the New Accord is expected to be implemented.
٣٥
The capital standards differentiate between Tier - 1 capital or core capital (pure capital or
basic equity), Tier – 2 capital or supplementary capital, tier-3 capital recognized by the 1996
amendment and leverage ratio in the following form. A. Supervisors shall ensure that Tier – 1
(core) capital, i.e., a) basic equity + b) disclosed reserves from post-tax bank earnings minus
a) good will, and b) investment in subsidiaries, shall not fall short of 50% of a bank's total
capital. B. Supervisors shall also ensure that Tier – 2 (supplementary) capital, i.e., a)
undisclosed reserves, + b) revaluation reserves, + c) general loan loss reserves, + d) hybrid
debt instruments, + e) subordinated term debt of 5 years’ maturity (maximum limit 50% of
tier – 1 capital), shall not exceed 50% of a bank's total capital. C. In some countries
subordinated debt having a maturity of less than 5 years is classified as tier - 3 capital in
accordance with the 1996 amendment of the Accord covering market risks.
٣٦
These standards are also maintained in the proposed New Basel Accord too, see the
discussion below.
86
composition of each risk bucket for on-balance sheet items is given in Table
4.137.
Total capital requirement for on-balance sheet assets is reached by
putting all assets into their respective buckets and deriving RWAs of the bucket
as a first step. For example, assets in 0% risk weight category are default risk
free assets. These assets do not need any capital for their protection. Assets in
100% risk weight category are very risky and all such assets need minimum 4%
tier-1 and 8% total capital protection. If the assets in this category are $100
million, a minimum of $ 8 million ($100m*.08) total capital is required for this
category of assets. In the second step the required capital for all categories is
added up to calculate the minimum capital requirement for the on-balance sheet
items.
Table 4.1
Summary of Risk Capital Weights by Broad On-Balance-Sheet Asset Categories
Risk Weights Asset Category
(%)
0 Cash and gold bullion claims on OECD governments such as
Treasury bonds or insured residential mortgages.
0, 10, 20, or 50% Claims on national public sector entities excluding central
at national government and loans guaranteed by them
discretion
20 Claims on OECD banks and OECD public sector entities such
as securities issued by US government agencies or claims on
municipalities. Claims on multilateral banks or claims
guaranteed by them
50 Loans fully secured by mortgage on residential property.
100 All other claims such as corporate bonds and less-developed
country debt, a claim on non-OECD banks, equity, real estate,
premises, plant and equipment.
For the non-derivative off-balance sheet exposures a credit conversion
system and a set of risk weights is provided. Using these guidelines the off-
balance sheet exposures are converted into their on-balance sheet equivalents
and capital requirement is determined. Capital requirement for the off-balance
sheet derivative positions is calculated separately, again using the standards set
for this purpose. The over all credit risk capital requirement according to the
٣٧
For explanations and details see, BCBS (1988).
87
1988 Accord is the sum total of the on-balance sheet and off-balance sheet
capital requirements.
4.2.1.2 Reforming Regulatory Capital for Credit Risk: The Proposed New
Basel Accord
Although the 1988 Accord was meant for application in the G10 and
other OECD countries, it has become a standard benchmark for determining the
capital adequacy of banks worldwide. For the first time, it provided a systematic
framework for aligning bank capital with the risks of their assets. A number of
studies confirm that since the introduction of the Accord, bank capital has been
strengthened in almost all countries. However, for a number of reasons, the 1988
Accord is under review and will be replaced by the proposed New Accord
during 200538. Some of the reasons, which have prompted the review of the
Accord, are given here.
i. The Accord was meant for internationally active banks of G10 and other
OECD countries. But the non-G10 and non-OECD countries have also
embraced it and it has assumed the position of an international
benchmark to measure capital adequacy of banks. From the non-OECD
country perspective, it is, hence, desirable to make adjustments in it to
enable it to fulfil the needs of the developing countries as well.
ii. Default risk also depends on maturity of the facility, longer maturity
assets being more risky as compared to the shorter maturity. Therefore,
regulatory capital requirements, which give lesser risk weight to assets
of short-term maturity, could have encouraged the flow of such capital
as compared to the more stable source of longer-term capital. This
consideration needs to be built-in the regulatory standards.
iii. At the time of its adoption, the Accord was truly revolutionary in
aligning capital with the relative risks of assets. During the past decade a
number of new risks have arisen, new methods of risk management have
been innovated and put into practice. There has been an unprecedented
٣٨
The Basel Committee issued a consultative document on the New Accord in June 1999.
After consultations the documents of the proposed New Accord was launched in January
2001. The Committee initially planned to finalize the agreement on the Accord during 2001
and its implementations from 2004. But, the response to the invitation for consultations was
so overwhelming that the Basel Committee now plans to finalize the agreement on the
document during 2002 and the agreement is supposed to become effective from 2005. The
New Accord comprises of three pillars, namely, capital adequacy, supervisory review process
and market discipline.
88
advancement in computing and information. E-banking and other
information and technology intensive services have bypassed regulatory
jurisdictions. Rapid consolidation has taken place in the financial
services industry. All these changes need to be taken into account while
measuring the real capital adequacy requirement of banks.
iv. The Accord has also encouraged capital arbitrage opportunities,
particularly by encouraging off-balance sheet and trading activities. The
merits of this have been tremendous, however it has provided an
opportunity for “capital arbitrage” (CA) and “cherry picking”. Through
securitization good quality assets have been taken away from the
balance sheets of banks and sold for raising additional funds without
removing the corresponding liabilities from the balance sheets. As a
result, additional funds are raised with the same amount of capital,
thereby reducing the overall quality of assets and making the banks
riskier.
v. The proposed New Accord by covering some of these and other
pertinent considerations aims at aligning bank capital and risk
management systems more strongly. It aims to encourage and give
incentives for risk management systems by keeping the capital
requirement under the Internal Rating Board (IRB) approach lesser than
the standardized approach. It also aims at enhancing disclosures about
risk management systems and other important information so that
market discipline can be strengthened. The proposed Accord also aims at
making bank supervision more risk-based and dynamic.
4.2.1.3 Treatment of Credit Risk under the Proposed New Accord
The consultative document for the proposed New Accord offers three
approaches to determine risk-weighted capital for credit risk, namely the
standardized approach, foundation IRB approach and advanced IRB approach.
The objective of offering alternative approaches is to encourage risk
management culture in banks by requiring lesser regulatory capital from those
banks which have put in place standard risk management systems. The risk
management systems of banks who will opt to adopt the IRB approaches will be
verified by supervisors. Depending on the supervisory risk assessment, banks
can graduate from the standard approach to the foundation IRB approach and
89
from there to the advanced IRB approach taking benefit from the regulatory
capital relief offered.
Treatment of Credit Risk under the standardized approach
The main proposal is to replace the risk weighting method of the 1988
Accord with a risk weighting of assets based on the ratings of external credit
assessment agencies according to the risk weights given in table 4.2.
90
Table 4.2
External credit assessment based risk weighting system
Assessment39
Claims on AAA A+ to BBB+ to BB+ to Below Not
to AA- A- BBB- B- B- rated
Sovereigns 0% 20% 50% 100% 150% 100%
Option 11 20% 50% 100% 100% 150% 100%
Option 22
20% 50%3 50%3 100%3 150% 50%
Banks Long-term
Option 2
3 20% 20% 20% 50% 150% 20%
Short-term
Corporations 20% 100% 100% 100% 150% 100%
1 Risk weighting based on risk weighting of the sovereign in which the bank is incorporated.
2 Risk weighting based on the assessment of individual banks.
3 Claims on banks of a short original maturity, for example, less than six months.
Source: Taken from BCBS 2001 (The New Basel Accord).
This risk weighting system implies, for example, that if the sovereign
counterparty of an asset, which is worth $ 100 million, is rated for example,
AAA+ to AA-, the asset will be treated as default risk-free and it will not require
any capital. But if the rating of the sovereign is BB+ to B-, the asset requires
100% capital protection (i.e. minimum 4 %, $ 4 million tier–1 capital and 8%, $
8 million total capital shall be kept by the bank against the asset). If the
sovereign counterparty is rated below B-, for capital requirements, the $ 100
million asset will be treated as $ 150 million and total capital requirement will
be 8% of $ 150 million.
Collateral, guarantee, credit derivatives and netting arrangements are the
most important instruments to mitigate credit risk. Based on the quality of these,
supervisors can give relief in the capital requirements under certain conditions
and subject to the satisfactory utilization of standard risk management
٣٩
Risk weights for claims secured by residential property 50%, commercial real estate
100%. Claims on multilateral development banks, case by case approach based on minimum
0% for AAA - AA- with very strong shareholder structure, paid in and callable capital. For
risk weights of off-balance sheet items, the risk weights of the 1995 modified Accord are
maintained with some modifications for maturity of the facility.
91
techniques and systems by banks. These are treated uniformly in the
standardized approach and in the foundation approach of internal rating.
i. Collateral is most important among the four techniques to control credit
risks. Cash, debt securities, equities, mutual fund units and gold can be
used as collateral. The actual strength of collateral depends on the loss in
the collateral value due to various risks. The estimate of this loss is
called ‘haircut’. Normally, the haircut of treasury bills is 0%, if the
collateral is equity, the haircut is 30%, if the collateral is an asset under
default, the haircut is 100% - total loss. Therefore, the proposed New
Accord provides the possibility of a supervisory relief of risk capital
allocation subject to the quality (haircut) of collateral. A methodology
for determining the haircut under various approaches is provided in the
New Accord.
ii. In addition to collateral, on-balance sheet netting, credit derivatives and
guarantees are recognized by the Accord as credit risk mitigants and
eligible for supervisory relief for risk capital allocation. These are,
however, subject to a number of conditions and existence of risk
management systems, disclosures and subject to other details given in
the Accord document.
Treatment of Credit Risk under the IRB Approach
An internal rating system, in the simplest form, can be considered as an
inventory of all assets of a bank keeping in view the future value of these assets.
In this way an IRB maps all assets of a bank in accordance with the risk
characteristics of each asset. All banks have some systems of internal ratings in
place for provisioning loan loss reserves, but an increasing number of banks are
putting in place formal systems of IRB often based on computerized models.
Internal rating systems can be instrumental in filling the gaps in the existing risk
management systems of a bank. Therefore, these are expected to enhance the
risk assessment of an institution by the external credit assessment as well as
supervisory risk assessment agencies leading to lesser capital requirements and
reducing the cost of funds.
The IRB approach to credit risk management has a number of
advantages. First, it makes the regulatory capital requirement more risk sensitive
- riskier banks will need more capital, less risky ones lesser capital. The IRB
approach is expected to be effective in this regard. Second, it is expected that the
92
IRB approach will provide incentives for risk management systems. As an
incentive for banks to develop their own internal system of risk management, the
New Accord recognizes internal ratings for credit risk capital allocation. The
Accord offers two alternative types of approaches to internal rating, namely, a
foundation approach and an advanced approach
The foundation approach is suitable for less sophisticated institutions
and the advanced one is open for use by the sophisticated institutions. Under
both approaches, the exposures of an institution are classified into corporations,
banks, sovereigns, retail, project finance and equity. These exposures are
specifically defined in the foundation and advanced approaches, but both the
approaches are based on five key concepts as determinants of credit risk. These
are probability of default (PD), loss given default (LGD), exposure at default
(EAD), maturity of facility (MOF) and granularity. Each one is briefly described
here.
i. Probability of Default (PD): The PD of a client is the measure of credit
risk faced by the bank. The works of rating agencies provide the vital
information about the PD of counterparties. The results of the S&P’s
default studies40 provide a number of factual information about the
historical characteristics of PDs. First, the higher the ratings, the lower
the probability of default, lower ratings always correspond to higher
default rates. Second, the lower the initial rating of a party, the sooner
the party faces default. An initial B rated company defaults in a period
of 3.6 years, AA company defaults in a period of 5 years from the
initial rating. A company downgraded to CCC defaults in an average
period of less than 6 months. Third, higher ratings are longer-lived. A
company rated AAA has the 90.3% chance to be rated AAA+ a year
later. This chance for the same initial rating is 84.3% for a BBB and
53.2% for a CCC. Thus, ratings provide reliable and systematic
information about credit risk. Financial institutions can measure their
credit risk by calculating a PD information and maintaining it overtime.
In all approaches individual banks must calculate their PDs for
corporate, bank and sovereign categories. In addition bank supervisors
will also calculate the PDs of clients of individual banks in order to
verify the accuracy of the PDs provided by banks.
٤٠
See, Standard & Poor S (2001).
93
ii. Loss Given Default (LGD): The LGD is a measure of the dollar value
of loss to the portfolio given a particular default. The PD is specific to a
given borrower, the LGD is specific to a given credit facility. Together,
the PD and the LGD make a better measure of the credit risk. Some
banks may not be able to calculate the LGDs of their facilities reliably
while others may be able to do so. After reviewing the individual
banks’ risk management systems, supervisors have the discretion to
decide whether to allow banks to use their own LGD calculations or to
assign their facilities supervisory LGD characteristics. Those banks,
which qualify for the use of their own LGD calculations will graduate
to the advanced IRB approach and those banks which are required to
use the supervisory assigned LGDs will be put in the foundation IRB
approach. Under the foundation IRB approach, supervisors will decide
the LGDs of various facilities with a supervisory benchmark of 50%
LGD for an unsecured facility, and with a 75% LGD value for
subordinated exposures (Table 5.1 provides the regulatory risk weights
given the benchmark LGD of 50%). For secured collateralized
transactions, supervisors will decide the LGD values using the
collateral haircut standards set under the standardized approach to the
capital allocation for credit risk. Under the advanced IRB approach,
banks will be allowed to use their own LDG estimates for various
facilities in allocating capital for credit risk. Banks are expected to use
scientific and verifiable processes for LGD calculation across facilities,
across collateral, across borrowers and across exposures. Supervisors
have the discretion to decline the use of their own LGDs by banks, i.e.
forcing them to follow the basic IRB approach.
iii. Exposure at Default (EAD): Like the LGD, EAD is also facility
specific. It is the measure of the total exposure of the facility at the time
of default. If the commitment is for example, for a $100 facility to be
utilized in two years drawn in 4 equal amounts and if the default
happens at the end of the first year, the EAD is $50. Indeed, the default
event will also have an impact on future exposures of the remaining
$50 of the facility. Like the LGD, under the basic IRB approach,
supervisors will calculate EADs, for individual banks, using set
supervisory rules. Under the advanced IRB approach, banks are entitled
to calculate their own EAD values for various facilities. The qualitative
94
characteristics of the system will be the same as described under the
LGD.
iv. Maturity of Facility (MOF): MOF is an important determinant of credit
risk. As shown in the above S&P default studies, a longer maturity
facility has higher probability of default for all rating classes. Banks are
required to provide a complete information about maturity of their
facilities.
v. Granularity: Granularity is the measure of a single borrower
concentration in the banks’ credit portfolio. The more spread is the
credit portfolio among borrowers, the more the non-systematic risks of
the borrowers are diversified and the less the credit risk and capital
requirement is. The benchmark granularity is the average for the
market. Granularity above the benchmark will require more capital and
below the benchmark less capital. This evaluation of granularity is
required to make each facility’s credit risk different for each other
facility so that capital can be allocated for each facility differently. The
IRB approach requires that the risk of each facility shall be measured
separately. The bank’s credit portfolio should not be exposed too much
to the non-systematic risk of a borrower by loan concentrations.
4.2.1.4 Regulatory Treatment of Market Risk
As discussed above market risks include interest rate, commodity price,
exchange rate risk and equity price risks faced by the banks’ asset portfolios as a
result of their trading positions. As mentioned earlier, the original 1988 Basel
Accord does not require capital for these risks. The risks were brought under the
regulatory umbrella by the 1996 amendment to the Accord and the amendment
became effective in 1998. The amendment introduces two approaches41 to
regulatory assessment of market risks:
i) The standardized approach; and
ii) The internal ratings-based approach.
٤١
The amendment in fact brought three fundamental changes to the original Accord, namely,
the market-risks are brought under the regulatory capital requirements, tier-3 capital was
introduced to cover market risks; and two approaches standardized and internal ratings
approaches were introduced.
95
The choice of an approach is a supervisory discretion based on review
and understanding of risk management systems and processes existing in banks.
Supervisors may also encourage banks to use both approaches simultaneously.
Capital requirements of banks in the first category are meant to be higher than
the second category. The objective of these alternative approaches is to
introduce an effective incentive system for better risk management by setting
lower capital requirements opting for internal ratings and relatively higher
capital requirements for the standardized approach. In fact this incentive system
proved to be successful and has triggered a revolutionary enhancement of risk
management culture in banks in a short period of time. Impressed by the benefits
of the alternative approaches, as discussed in case of credit risk, the New Accord
suggests adopting the internal ratings approach for credit risk as well. Therefore,
the New Accord, in some sense is an extension of the approaches of 1996
Accord to cover credit risks. In other words as far as market risks are concerned,
the 1996 amendments to the 1988 Accord will continue beyond 2005 with minor
modifications.
In the standardized approach the capital charge for each market risk is
first determined separately following standardized methods for each risk. After
that these capital charges are added to determine the total capital requirements.
Interest rate risk is subdivided into specific and general risks. Specific capital
charges are designed to capture the risk underlying any net position due to the
non-systematic risks of the counterparty and hence more specific to positions in
individual instruments. General risk refers to the risk of loss arising from the
changes in the market interest rates. Two methods: “maturity ladder” and
“duration” are allowed to banks to choose for allocating risk weights. The
underlying principle of the more commonly practiced maturity ladder approach
is the fact that longer maturity requires higher risk weights and short maturity
lower risk weights. For this specific general principle, it is alleged that the
regulatory framework is biased against long-maturity systemically stable sources
of funding and favors short maturity unstable sources of funding. As a result,
the system might have contributed to the flow of short-term of funds and the
resultant financial instability. The internal ratings approach is essentially based
on value at risk technique as briefly discussed in section two of this paper.
4.2.1.5 Banking Book Interest Rate Risk
96
The banking book42 interest rate risk refers to income or asset value loss
due to a change in the market rates of interest. This is recognized to be an
important risk, which warrants allocation of capital. However, the risk greatly
varies from bank to bank, therefore, it is not possible to set uniform standards for
capital allocation. Therefore, the New Accord keeps the allocation of capital for
this risk in the discretion of bank supervisions under pillar-2 of the Accord that
gives the framework for the supervisory review process. Supervisions are in
particular required to be attentive to the problem of “outlier” banks – banks
whose interest rate risk can lead to the decline in its asset value equal to 20% or
more of its tier-1 and tier-2 capital. Supervisors also need to carefully assess and
review bank’s internal risk assessment and management systems.
4.2.1.6 Treatment of Securitization Risk
Since securitization takes away assets from the balance sheet of a bank
and puts them in the balance of a special purpose vehicle as discussed in section
two, its risks need to be regulated at balance sheets of the two entities. The 1988
Accord is widely known to have caused capital arbitrage by giving capital relief
to securitized assets, particularly first ignoring market risks and afterwards
assigning lower risk weights on the trading book positions. The New Accord
while appreciating the benefits of securitization tries to minimize capital
arbitrage by trying to ensure that:
i. The securitizing (originator) bank must reach a “clean break” which is: a)
the asset transfer must be through a legal and transparent sale and b) the
bank shall not hold any control on the assets securitized.
ii. If the originator is obliged for first credit losses enhancement, it must do
so by deducting from its capital and
iii. If the originator is obliged for a second credit loss enhancement, the
position to be treated as a direct credit substitute.
4.2.1.7 Treatment of Operational risks
Operational risks are considered to be important in banking organizations.
However, it is only in the New Accord that a specific capital charge is proposed
to cover operational risk. Alternative methodologies are suggested for measuring
this risk:
٤٢
Banking book in this case covers also all those positions which due to any reason cannot
be sold.
97
a) Basic Indicator Approach (BIA);
b) Standardized Approach (SA);
c) Internal Management Approach (IMA), and
d) Loss Distribution Approach (LDA).
This menu of approaches is given in order of the level of sophistication
of a bank – starting from a simple bank using the BIA and the most advanced
banks opting for IMA or LDA in the future. Under the BIA, banks will be
required to maintain capital for operational risk equal to a fixed percentage of
gross income set by supervisions. Under the SA banks’ activities will be divided
into business lines. Capital charges will be set as Beta fractions for each line as
given in table 4.3. The same set of business lines and beta fractions are further
refined in the IMA, adding additional indicators by the supervisors such as
exposure indicators, loss event probability, given the expected loss etc. Suitable
approaches will be assigned to banks by supervisors after reviewing the
preferences as well as the state of risk management processes existing in banks.
Table 4.3
Proposed operational risk indicators in the New Accord
Business Business Lines Indicator Capital
Units factors
Investment Corporate finance Gross income β1
banking Trading and sales Gross income (or VAR) β2
Banking Retail banking Annual average assets β3
Commercial Annual average assets β4
banking
Retail banking Annual average assets β5
Payment and Annual settlement through β5
settlement put
Others Retail brokerage Gross income β6
Asset management Total funds under β7
management
Source: The New Basel Accord Document
4.2.2 Effective Supervision
Effective bank supervision is the key to achieve financial efficiency and
stability. The objectives of bank supervision can be summarized in a few
sentences.
98
i. The key objective of supervision is to maintain stability and confidence
in the financial system, thereby reducing the risk of loss to depositors
and other creditors.
ii. Supervisors should encourage and pursue market discipline by
encouraging good corporate governance (through an appropriate
structure and set of responsibilities for a bank’s board of directors and
senior management) and enhancing market transparency and
surveillance.
iii. In order to carry out its tasks effectively, a supervisor must have
operational independence, the means and powers to gather information
both on and offsite, and the authority to enforce its decisions.
iv. Supervisors must understand the nature of the business undertaken by
banks and ensure to the extent possible that the risks incurred by banks
are being adequately managed.
v. Effective banking supervision requires that the risk profile of individual
banks be assessed and supervisory resources allocated accordingly.
vi. Supervisors must ensure that banks have resources appropriate to
undertake risks, including adequate capital, sound management, and
effective control systems and accounting records; and
vii. Close cooperation with other supervisors is essential, particularly where
the operations of banking organizations cross national boundaries.43
Effective supervision of banks ensures that banks function safely and
soundly, so that the financial system can attain the full confidence of savers and
investors. This enables the removal of the constraints imposed by the self-
financing system and increases the monetization of transactions. An increased
level of savings efficiently put into investments ensures economic development
and welfare. Supervisory systems are expected to depend on the socio-political
and legal frameworks prevailing in different countries. Hence there cannot be a
standardized supervisory system to be followed in all jurisdictions. Different
countries use different method and approaches to assess bank risks. These
approaches are however, converging on one important point, namely, risk-based
formal and systematic supervision shall gradually be adopted in order to make
43
Core Principles' document, pp.8-9.
99
supervision effective. The approaches to supervisory risk assessment as used in
different countries can be grouped into four.
a) Supervisory bank rating systems (such a CAMELS)
b) Financial ratio and peer group analysis systems
c) Comprehensive bank risk assessment systems and
d) Statistical models
The generic features of each approach are summarized in table 4.4.44
Table 4.4
Salient Features of Bank Supervisory Risk Assessment Systems
Assessment of Specific focus
Approaches Forecasting Use of
Inclusion of Links with
current quantitative
to Bank
future analysis and qualitative on risk formal
financial financial statistical supervisory
supervision condition condition procedures assessments categories action
Supervisory
Ratings
On-site *** * * *** * ***
Off-site *** * ** ** ** *
Financial ratio
and peer group
analysis *** * *** * ** *
Comprehensive
bank risk
assessment *** ** ** ** *** ***
systems
Statistical
models ** *** *** * ** *
- Not significant ** significant *** very significant
Despite the prevalence of different approaches to supervision in
different jurisdictions, a broadly acceptable framework of some of the core
principles for effective supervision can be equally relevant across different
countries. Such principles provide a widely recognized benchmark for effective
٤٤
See Sahajwala and Bergh (2000).
100
supervision, provide for a recognition for the minimum precondition for
effective supervision, define supervisory role in identifying risks and mitigating
them, and increase cooperation between supervisors of different countries to
enhance consolidated supervision. Due to these and other considerations, the
BCBS issued the Core Principle for Effective Banking Supervision document in
1997. The main features of these core principles are highlighted in table 4.5.
101
Table 4.5
Core Principles and Assessment Methodology of Banking Supervision
CLASSIFICATION COVERAGE* ASSESSMENT OF
OF CORE COMPLIANCE**
PRINCIPLES*
Principle – 1 Existence of sound economic Are the roles and duties of
Preconditions for policies, public infrastructure, different agencies clearly
Effective Banking market discipline, procedures for defined? Is there a coordination of
Supervision effective resolution of problems, activities? Is there suitable legal
sound public safety nets. framework for banking? Are
supervisors empowered?
Principles 2-5 Permissible activities to be Is the term bank clearly defined in
Licensing and licensed to banks, powers of laws? Are banking activities
Structure licensing authorities, methods of clearly defined in laws? Are
procedures of licensing owners, licensing authorities competent,
plans to operate and manage honest and well informed? Are
risks, competence and integrity they empowered to block any
of senior management, financial subsequent ownership control,
matters including capital activity changes, mergers, etc.?
required other approvals, transfer Are they in full contact with such
of control, major acquisition or authorities in other jurisdictions?
investment by banks.
Principles 6-15 Adequacy of risk-based capital, Are the authorities empowered to
Prudential Regulations credit risk management, asset set regulatory capital
and Requirements quality assessment, large requirements and to implement
exposures and risk concentration, these fully? Have they the
connected lending, country and required rules, regulations in
transfer risks, market risks, other place? Have they the required
risk (interest rate, liquidity, technical expertise to evaluate the
operational risk), internal control risk existing in banks? Are they
systems. empowered to take prompt
corrective measures?
Principles 16-20 Supervisory risk assessment Have they the conceptual and
Methods of on-going systems (offsite surveillance and technical expertise for
Banking Supervision on-site inspection), external audit supervisory risk assessment? Do
reports, consolidated they have the resource for onsite
supervision. inspection? Do they have
information for offsite
supervision?
Principle 21 Information disclosure, Are accounting and auditing
Information accounting standards periodicity systems in place? Are banks using
Requirements and accuracy of reports, valuation methods, which are
confidentiality of information. reliable? Is the required
information properly disclosed? Is
confidentiality kept?
Principle 22 Prompt corrective measures, Are supervisors equipped with the
Formal Powers of liquidation procedures. power and resources for prompt
Supervisors corrective measures? Are laws in
place to enforce liquidation?
Principle 23-25 Responsibilities of law and host Is consolidated supervision in
Cross Border Banking country supervisors. place? Is there cooperation with
supervisors from outside?
- This information is extracted from the Core Principles (1997) document of the BCBS.
102
- This information is based on the Core Principles Methodology (1999) document of the BCBS.
103
If the main objective of the Core Principles of effective banking
supervision is enhancing financial stability, technical assessment of the
compliance with these principles can provide useful insight in increasing the
effectiveness of various policies. A recent study conducted by the IMF staff
concludes that indicators of credit risks and bank soundness are primarily
influenced by macroeconomic and macro-prudential factors and that the direct
influence of the compliance with the Core Principles is insignificant in this
regard. The study suggests that the compliance could indirectly influence risk
through the transmission mechanism of effecting the macroeconomic variables45.
However, it may be noted that the existence of sound macroeconomic policies
and conditions is considered as one of the important pre-conditions for effective
banking supervision.
4.2.3 Risk Disclosures: Enhancing Transparency about the Future
The market mechanism functions efficiently with complete information.
Information cannot be considered complete unless it is transparent and timely.
There are many channels of disclosing such information to clients, shareholders,
debtors, supervisors and regulators and above all to the market. These channels
are annual reports, supervisory and regulatory review reports, external credit
assessment reports whenever available, periodic regulatory reports, reports of
market intelligence, stock market information and debt-market information etc.
The set of information provides a critical input to investors for allocating their
investment in accordance with their appetite for risk adjusted returns.
Transparency reduces moral hazard and adverse selection and enhances
efficiency and integrity of the markets and strengthens market discipline. Market
discipline is strengthened not only by the timely availability of appropriate
information about the risk level of a firm, but it is also effected by the
information about the firm’s risk management processes. Hence disclosure of
information is effective only if (a) it provides information about the risk of the
firm and (b) it provides information about the risk management processes of the
firm.
The traditional channels of information have been effective in providing
information about the levels of risks faced by a firm in the past as accounting
standards can largely cover these risks. However, due to a number of reasons, it
is difficult to set standards for disclosure of future risks and risk management
٤٥
See, Sundrarajan, Marston and Basu (2001).
104
processes across firms, across market segments and overtime. Some of these
factors are:46
a. The risk management technologies are changing rapidly due to
innovations making it difficult to set rigid standards.
b. The financial services industry is itself changing fast and financial
conglomerations are emerging blurring the difference between the risk of
various segments of the industry - insurance companies, investment
banks, commercial banks, etc.
c. Financial instruments are also changing fast due to the financial
engineering process, making standardized valuation of these instruments
almost impossible.
d. Due to e-banking, a totally new scenario has developed particularly in
relation to the control of the banks on their own banking infrastructure.
The Internet-based banking networks surpass regulatory jurisdictions.
The infrastructure providers practically control all the e-banking
information. Above all, the technology changes very fast.
e. There are borrower incentives for not disclosing full information. These
incentives range from hiding information from competitors, tax evasion,
and conflict of interests among shareholders and providers of funds, etc.
These factors are so strong that a recent survey of risk disclosure by
leading international banks found that the quality of disclosures provided
in the annual reports about risk management practices is far short of the
expectations. The survey recommends that there must be standardized
framework for disclosure of risks to enhance comparability of systems
across firms. Disclosures can be improved in almost all areas, but a lot
more improvement is needed in non-trading activities as well as credit
risk in trading activities. Disclosures also need improvement in the use of
models, internal rating system and safety procedures of using
computers.47
Since “one size fits for all” standards are not possible due to the fast
pace of innovation, management of financial institutions can be most effective in
46
See, Ribson, Rajna, “Rethinking the Quality of Risk Management Disclosure Practices”
http///newrisk.ifci.ch/146360.html
47
See, IFCI-Arthur Andersen, "Risk Disclosure Survey", http///newrisk.ifci.ch/ifci-
AASurvey.html
105
integrating the risk management systems with their annual reports. This requires
the evolution and adoption of:
One) risk-based accounting systems,
Two) risk-based auditing systems,
Three) risk-based management information
systems, and
Four) risk-based inventories of all assets of banks.
The common goal of these processes is to disclose information about the
risks that the firm is expected to face in the future in addition to the traditional
information which relates to the past risks. Once these processes are developed,
the annual reports will not only provide information about the risks faced by
financial institutions in the past but will also disclose sufficient information
about the risk management processes of the institutions and their risks in the
future.
Disclosures about risk in an institution and the risk management
processes adopted by the institution are so important that the international
regulatory standard setters have produced several reports and guidelines on the
subject.48 Keeping in view the increasing nature of cross-segment activities in
the financial industry, the risks which such activities are bound to pose,
regulators of various sectors need to enhance coordination of their activities to
enhance disclosure and strengthen market discipline. Keeping this consideration
in view a Multidisciplinary Working Group on Enhanced Disclosure was
established in June 1999 jointly by the BCBS, IOSCO, IAIS and Committee on
the Global Financial System of the G-10 Central Banks. The report of the
Working Group was released on April 26, 2001.
The report makes it clear that there are two complementary types of
disclosures: disclosures about the risks of the institution as given in the
traditional statistical information provided in annual reports about the current
48
These reports include: BCBS (1999a) Sound practices for Loan Accounting and
Disclosure, BCBS (1999b) Best Practices for Credit Risk Disclosures, BCBS (1998),
Enhancing Bank Transparency, Euro-Currency Standing Committee (1994) Public Disclosure
of Market and Credit Risks by Financial Intermediaries, BCBS & IOSCO (1999)
Recommendations for Public Disclosure and Derivative Activities of Banks and Securities
Firms, BCBS (1997) Core Principles of Effective Banking Supervision, BCBS (1999) the
New Basel Accord (Pillar-3 Market Discipline). In addition to the www.bis.org most
resources can be accessed from http://newrisk.ifci.ch/DocIndex/.
106
health of the institutions, and disclosure about the risk management processes of
the institution. The second type of disclosure, which is the subject matter of the
report, is classified into these groups.
a. A specific minimum level of disclosure must be a part of the
traditional periodic reports provided by the institution to its
shareholders, investors, creditors and counterparties.
b. Disclosure that could be useful, but their costs and benefits are yet
to be settled.
c. Certain statistical information could be disclosed which can fill the
gaps in disclosures of risk management systems. Again this type of
information needs to be studied further before making it a part of
the disclosure requirements.
The study concludes that in order to make disclosures transparent and
supportive to enhanced market discipline there should be:
a. A balance between quantitative and qualitative disclosures,
b. Disclosures should basically aim at reflecting the firm’s own true risk.
To achieve this the comparability (with other firms) may at times be
sacrificed, and
c. Appropriate disclosure of risk management system can be achieved by
providing information about intra-period risk exposure instead of the
traditional system of period-end data.
The report also recommends to the international standard setters to
consider enhancement of guidelines on disclosures on risk concentration, credit
risk mitigation and the evolution of overall risk management systems in financial
institutions. These recommendations increase the role of supervisors in
enhancing such disclosures in the framework of risk-based supervision49.
To achieve financial stability, disclosure requirements for banks can be
effective only if other agents participating in the economic and financial system
also comply with the respective standards. The set of international standards
cover a wide range of important areas such as monetary and financial policy
49
For more details see, Working Group (2001), Multidisciplinary Working Group on
Enhanced Risk Disclosures; Final Report to BCBS, CGFS, IOSCO and IAIS.
107
transparency, fiscal policy transparency, data dissemination, accounting,
auditing, payments settlements, market integrity etc50.
4.3 REGULATION AND SUPERVISION OF ISLAMIC BANKS
There could be no disagreement on the statement that the risk
management systems in the Islamic banks shall meet the required international
standards. However, as mentioned above a number of risks faced by the Islamic
banks are different as compared to the risks of traditional banks. Therefore,
some international standards meant for traditional banks may not be relevant for
the Islamic banks due to their different nature. Hence the effective supervision of
Islamic banks requires the study of the risks of Islamic banks and formulating
suitable guidelines for the effective supervisory oversight of Islamic banks.
Chapra and Khan (2000) undertake a survey of regulation and supervision of
Islamic banks. Some pertinent conclusions of that study are presented here.
4.3.1 Relevance of the International Standards for Islamic Banks
a. The Core Principles document sets pre-conditions for effective
banking supervision. In addition to these pre-conditions, there are
also a number of other pre-conditions specific for effective Islamic
banking supervision. One set of these preconditions has to be
fulfilled by bank regulators and supervisors. These include
providing a leveled playing field for competition, licensing
facilities, lender of last resort facility acceptable to the mandate of
Islamic banks, proper legal framework, proper Sharī‘ah
supervision, etc. The other set of preconditions has to be met by
the Islamic banks themselves. These include development of inter-
bank market and instruments, resolution of a number of unresolved
Fiqh related issues, development of proper internal control and risk
management systems, etc.
b. As for as the Core Principles for effective banking supervision and
the disclosure and transparency requirements are concerned, these
are equally relevant for the Islamic banks. Due to the risk sharing
٥٠
For international standards see, Financial Stability Forum, International Standards and
Codes to Strengthen Financial Systems, (www.fsforum.org/standards/keystds.htm). In
addition, the Accounting and Auditing Organization for the Islamic Financial Institutions
(AAOIFI) needs to be mentioned specially as it is the sole standard setter for the Islamic
financial industry.
108
nature of Islamic banks, these banks need even more effective
systems of supervision and transparency.
c. The difficulty in applying the international standards to Islamic
banks lies in applying capital adequacy standards. First, due to the
risk sharing nature of their modes of finance, Islamic banks need
more not lesser capital as compared to traditional banks. Second,
there is a need to separate the capital of current and investment
accounts. Third, the need to adapt the international standards for
the Islamic banks has prompted efforts towards establishing the
establishment of the Islamic Financial Services Supervisory Board.
Finally, the supervisory risk assessment systems like CAMELS51
are equally relevant for Islamic banks and these can be adapted
without difficulty.
d. A number of advantages of the IRB approach discussed in the
previous section are relevant for the Islamic banks. First, the
approach allows mapping the risk profile of each asset
individually. Since the Islamic modes of finance are diverse, the
IRB approach suits these modes more than the standardized
approach. Second, the IRB approach aligns the actual risk
exposure of banks with their capital requirements. This is
consistent with the nature of Islamic banks. Third, the IRB
approach is expected to encourage and motivate banks to develop a
risk management culture and thereby reduce the risks in the
banking industry and enhance stability and efficiency. Fourth, it is
expected to generate reliable data and information and enhance
transparency and market discipline. Fifth, it will use external credit
assessment as benchmark, and thus truly integrate internal and
external information to generate more reliable data. This is
important because external credit assessment may not have the full
set of reliable information that an internal-ratings system can have,
and internal-rating systems may lack the objectivity of external
ratings. This information, used in harmony with incentives for risk
51
The CAMELS rating system refers to capital adequacy, assets quality, management
quality, earnings, liquidity, and sensitivity to market risks (in some countries also systems
for internal controls).
109
management, will be instrumental in controlling moral hazard and
capital arbitrage.
4.3.2 The Present State of Islamic Banking Supervision
Most Islamic banks are located in the member countries of the IDB. The
study mentioned above identifies a number of issues regarding the present state
of Islamic banking supervision.
a. A growing number of these countries are in the process of adopting and
effectively implementing the international standards, namely, Core
Principles, minimum risk-weighted capital requirements and the
international accounting standards. In applying the risk-weighting
methodologies to Islamic banks, there are difficulties reported due to the
diverse nature of the Islamic modes of finance. Compliance with the
standards set by the Accounting & Auditing Organization for Islamic
Financial Institutions (AAOIFI), has not yet fully materialized. Only
Bahrain and Sudan have so far adopted these standards.
b. Some countries including Iran, Pakistan and Sudan are undertaking
financial sector reform programs. Strengthening the capital of banks is
an important part of these programs. Since most Islamic banks are very
small, some countries have announced a program of mandatory merger
of Islamic banks to strengthen their capital base.
c. An increasing number of countries where there are Islamic banks
located, are putting in place both Off-site and On-site supervisory
systems. The famous On-site supervisory risk assessment system,
namely, CAMELS is also being used in some countries. Islamic banks
are generally being supervised within the framework of the prevailing
international commercial banking supervisory systems. In some
countries special laws have been introduced to facilitate Islamic
banking, while in others no such laws exist. Islamic banking operations
in the latter group of countries are performed under the guidelines issued
by their respective central banks.
d. In almost all those countries where Islamic banks are operating,
commercial banking functions are segregated from securities and
insurance businesses, and distinct authorities are assigned the
supervisory task. Malaysia is the only exception, where banks and
110
insurance companies are supervised by the central bank. However, the
global trend is inclined towards the concept of universal banking with
emphasis on supervision by a single mega-supervisor. Moreover,
commercial banks in these countries are supervised by central banks.
However, the emerging trend in the world is to segregate the monetary
policy framework of macroeconomic management from the
microeconomic considerations of bank soundness. As a result of this
segregation, banking supervision is being separated from monetary
policy and being assigned to a specialized authority. In cases where
different supervisory authorities specialize in supervising different
banking and non-banking financial institutions, the need for cooperation
and coordination between these authorities increases.
e. In some countries conventional banks are allowed to open Islamic
windows, while in other countries this is not allowed.
f. Most private banks have their own Sharī‘ah supervisory boards.
However, in Malaysia, Pakistan and Sudan the central banks have a
central Sharī‘ah board. In Pakistan the Council of Islamic Ideology and
the Federal Shariat Court are empowered to review all laws in the light
of the Sharī‘ah. The Federal Shariat Court has declared interest to be a
form of Ribā.
g. A number of characteristics of Islamic banks require that the existing
international standards need to be properly adapted to apply these to
Islamic banking supervision effectively. The risk sharing nature of
investment deposits, the risks of various Islamic products, the
availability of risk management instruments, the presence of institutional
support such as lender of last resort facility and deposit protection are
some of the most important among these factors.
4.3.3 Unique Systemic Risk of Islamic Banking
Transmission and mixing of risks between different segments of the
financial services industry can be a source of improper identification of risks and
lack of their effective mitigation. Each segment of the financial services industry
is specialized in specific types of risks. For example, the insurance industry in
general deals with risks, which are of long-term in nature. Banks on the other
hand are good in managing short-term risks. The banking book of a bank
constitutes those risks, which profile the risk appetite of its depositors. The
111
trading book and fund management activities cater for the risk preferences of
investors. Hence specialization by financial institutions in different types of risks
enhances efficiency in identifying, pricing and mitigating the various risks.
Cross-segment transmission of the various risks can thus cause the mixing of
these various risks, and can trigger a conflict in the risk profile of the various
users of financial services and can weaken the customers confidence in the
overall financial intermediation system. This could cause macroeconomic
inefficiency as well as systemic instability. Therefore, most regulatory regimes
attempt to block such transmission of risks either by preventing cross-segment
activities of different institutions or by requiring separate capital and other
firewalls between the risks of activities of a bank in different sectors.
4.3.3.1 Preventing Risk Transmission
The raisons d’être of Islamic banking is conducting business practices
consistent with the religious prohibition of Ribā. Ribā is a return (interest)
charged in a loan (Qar) contract. This religious injunction has sharpened the
differences between current accounts (interest free loans taken by owners of the
Islamic bank) and investment deposits (Muārabah funds). In the former case,
the repayment on demand of the principal amount is guaranteed without any
return. In case of investment deposits, neither the principal nor a return is
guaranteed. The owners of current accounts do not share with the bank in its
risks. Whereas, the owners of investment accounts participate in the risks and
share in the bank’s profits on pro rata basis. The contracts of Qar and
Muārabah are thus the fundamental pillars of Islamic banking and their
characteristics must fully be protected for the preservation of the uniqueness of
Islamic banks.
In all Islamic banks sizeable proportion of funds under management are
comprised of current accounts. In some Islamic banks these accounts constitute
more than 75% of total funds under management. Thus current accounts are the
strength of Islamic banks as these are a vital source of their free money. The use
of funds of investment deposits (Muārabah money) along side such huge
proportion of borrowed money is unprecedented in the history of the Islamic
financial system. It poses at least two important challenges to Islamic banks,
namely the challenge of systemic risk and the challenge of barriers to market
entry.
112
The current account holders need to be fully protected against the
business risks of the bank. The investment account holders need to fully
participate in the business risks of the bank. But the current accounts are
guaranteed only theoretically in the sense that in case of a confidence problem,
the Islamic bank is not in a position to return all the accounts on demand. The
more an Islamic bank relies on these funds the more serious this systemic
problem is. This means that in case of crisis, the risks of the assets of investment
deposits will be borne by the current account holders. Since most Islamic banks
operate in jurisdictions where deposit insurance and lender of last resort facilities
are not available, this systemic risk is serious in nature.
Even though investment deposits are theoretically assumed to share the
business risks of the bank to the extent that investment deposits finance the
businesses, these deposits are also not immune to the systemic risks posed by the
current accounts. Current accounts tend to increase the leverage of the Islamic
banks, their financial risks and hence adversely affect their overall stability.
Thus in a crisis situation, the risks of one type of deposits cannot be separated
from the risks of the other type of deposits. This is not only systemically
unstable but also against the basic premises of Qar and Muārabah – the two
pillars of the unique nature of Islamic banking. A number of suggestions are
made to prevent the confidence problem, which may arise due to the
transmission of risks between the two accounts.
a. Some researchers suggest a 100% reserve requirement for current
accounts. As mentioned earlier current accounts are a vital source of
strength of Islamic banks. The drastic measure of 100% reserve
requirement will no doubt enhance systemic stability, but it imposes an
unreasonable cost on the Islamic banks due to which they may not be
able to even survive in the competitive markets.
b. The BMA has introduced prudential rules whereby it is mandatory to
disclose all assets financed by current accounts separately and all assets
financed by investment deposits separately.
c. In some regulatory jurisdictions the reserve requirements for current
accounts are much higher as compared to investment deposits.
d. Some other regulatory regimes combine the requirements as mentioned
in the second and third cases.
113
e. The AAOIFI has suggested a more elaborate and systematic procedure
to tackle the subject. The AAOIFI scheme is worth of discussing in more
detail.
The AAOIFI’s main concern has been to develop accounting, auditing
and income recognition standards for the Islamic financial institutions so that
transparency and disclosures can be enhanced in these institutions, which is an
Islamic requirement for conducting fair and honest business. In the process of
developing the standards, AAOIFI found that most Islamic banks are reporting
their investment deposits as off-balance sheet items. After a thorough technical
analysis, AAOIFI reached two crucial conclusions.
a. There is a need to differentiate two types of investment deposits; those
restricted to a specific use and general-purpose unrestricted deposits.
The magnitude of the first type of deposits is very small as compared to
the second type of deposits. While the Islamic banks can continue
keeping the first type of deposits off-balance sheet, the second type of
deposits shall be kept on-balance sheet. In all our discussion, investment
deposits imply this type of deposits.
b. The bank while managing investment deposits must face fiduciary and
displaced commercial risks. Fiduciary risk can be caused by breach of
contract by the Islamic bank. For example, the bank may not be able to
fully comply with the Sharī‘ah requirements of various contracts. While,
the justification for Islamic banking is the compliance with the Sharī‘ah,
an inability to do so or not doing so willfully can cause a serious
confidence problem and deposit withdrawal. Displaced commercial risk
implies that the bank though may operate in full compliance with the
Sharī‘ah requirements, yet may not be able to pay competitive rates of
return as compared to its peer group Islamic banks and other
competitors. Depositors will again have the incentive to seek
withdrawal. To prevent withdrawal, the owners of the bank will need to
apportion part of their own share in profits to the investment depositors.
The AAOIFI thus suggests that the Islamic bank’s capital shall bear the
risks of all assets financed by current accounts and capital. In addition,
the capital shall also bear the risks of 50% of assets financed by the
investment deposits. The risks of the remaining half of the assets
financed by the investment deposits shall be borne by the investment
depositors.
114
The results of our survey reported in section three of the paper show that
the risk of withdrawal is in fact a nightmare for the managers of Islamic banks.
This risk is indeed more serious in Islamic banks as compared to conventional
banks. This is because, neither the principal nor a return is guaranteed in Islamic
banks’ investment deposits unlike the deposits of conventional banks. Although
the nature of Islamic banks’ investment deposits does introduce market
discipline, it also causes a potential confidence problem as compared to
traditional bank deposits. Therefore, Chapra and Khan (2000) show reservations
about the AAOIFI suggestion to make capital responsible for the risks of only
50% of assets financed by investment deposits, as this will weaken the capital of
Islamic banks. They argue that due to the confidence problem mentioned above
Islamic banks in fact should need more capital as compared to conventional
banks. A stronger capital base coupled with the market discipline introduced by
the nature of investment deposits can indeed make Islamic banks more stable
and efficient.
4.3.3.2 Preventing the Transmission of Risks to Demand Deposits
The main concern of AAOIFI namely, the prevention of the
transmission of risks of investment deposits to current accounts is of a
fundamental nature. To strengthen this concern, Chapra and Khan (2000)
suggest for the consideration of standard setters that the capital requirement for
demand deposits must be completely separated from the capital requirement for
investment deposits. Islamic banks can thus have two alternatives with respect to
capital adequacy requirements as given in Figure 4.1. The first alternative would
be to keep demand deposits in the banking book and investment deposits in the
trading book with separate capital adequacy requirements for the two books. The
second alternative would be to pool investment deposits into a securities
subsidiary of the bank with separate capital adequacy requirement. There could
be other subsidiaries, of an Islamic bank but all with separate capital
requirements. These alternatives are expected to introduce a number of benefits
over the existing systems.
a. These will align the capital requirements of the two different deposits to
their respective risks. Demand deposits are the main source of leverage
of the Islamic banks as a source of free money. These depositors
therefore, need more protection as compared to investment account
115
holders. Therefore, the capital as well as statutory reserve requirements
must be substantially higher for demand deposits.
116
Figure 4.1
Proposed Capital Adequacy Alternatives for Islamic Banks
THE EXISTING SYSTEM
BANK
Capital
Current Accounts
Investment Accounts
PROPOSED ALTERNATIVE - 1
BANK
TRADING BOOKBANKING BOOK
Capital Capital
Current Accounts Investment Accounts (Mutual Fund)
SUBSIDIARIES
Capital
PROPOSED ALTERNATIVE - 2
BANK
Capital
Current Accounts
INVESTMENT SUBSIDIARY OTHER SUBSIDIARIES
Capital Capital
Investment Accounts (Mutual
Fund)
117
b. As for as the risk-return tradeoff is concerned, investment deposits and
mutual funds are not much different. However, mutual funds are
considered to be more transparent, liquid, and efficient in the allocation
of returns to risks. Therefore, several policy oriented writings, judgment
of courts and research works have called for establishing mutual funds
of various types. Capital requirements provide a strong incentive to
establish mutual funds. There is also evidence on this in many regulatory
jurisdictions. In these regimes, regulatory capital have played an
important role in creating incentives for securitization by requiring lower
capital for trading activities as compared to banking book activities of
financial institutions. As a result, the size of banking book activities of
banks has declined sharply overtime, and that of trading book activities
has widened.52 This incentive effect of regulatory capital can be
replicated in Islamic banks so that the investment accounts of these
banks get gradually transformed into mutual funds. The relatively lower
capital adequacy requirement on investment accounts (mutual funds) can
provide a strong incentive to Islamic banks to develop mutual funds,
enhance PLS financing and ensure efficient risk sharing, market
discipline and transparency in the distribution of returns.
c. As mentioned above, the uniqueness of Islamic banking lies in the fact
that the owners of Islamic banks raise demand deposits as interest-free
loans (Qar) and investment deposits as Muārabah funds. Unless the
transmissions of any risks between the two types of deposits are
completely prevented, this unique characteristic of Islamic banking
cannot be preserved. In this regard, separate capital adequacy standards
will serve the firewalls and safety net requirements of major regulatory
and supervisory jurisdictions around the world. Furthermore, these
alternatives will also help eliminate the difficulty of treating investment
accounts while applying the international capital adequacy standards. In
addition, segregation of the depository function of Islamic banks from
their investment function, will make these banks more credible and
acceptable under almost all jurisdictions, thus enhancing the growth of
Islamic finance. This will enhance acceptability of Islamic banking in
majority regulatory regimes and will remove barrier to market entry.
52
See for example, European Commission (1999), and Dale (1996).
118
4.3.3.3 Other Systemic Considerations
a. Transmission of the risk of permissible income and impermissible
income is a serious systemic risk in conventional banks offering Islamic
banking windows. This risk can be controlled if the Islamic banking
windows of these banks are brought under separate capital.
b. Establishment of specialized subsidiaries with separate capital can also
enhance the level of diversification of the business of Islamic banks.
Such a diversification can contribute to proper control of their business
risks. However, it is also prudent to ensure consolidated supervision of
the Islamic banks like traditional banks.
c. The unique risks of Islamic modes of finance, the nonexistence of
financial instruments, restrictions on sale of debts, and other special
features of Islamic banking force the Islamic banks to maintain a high
level of liquidity. This naturally affects their income adversely. As a
result, the withdrawal risk is strengthened. In this manner, unless these
risk factors are properly managed, they can culminate into a serious
systemic instability.
119
V
RISK MANAGEMENT:
FIQH RELATED CHALLENGES
5.1 INTRODUCTION
The discussion of the previous sections shows that Islamic banks can be
expected to face two types of risks – risks that are similar to the risks faced by
traditional financial intermediaries and risks that are unique due to their
compliance with the Sharī‘ah. Consequently the techniques of risk identification
and management available to the Islamic banks could be of two types. The first
type comprises of standard techniques, such as risk reporting, internal and
external audit, GAP analysis, RAROC, internal rating, etc., which are consistent
with the Islamic principles of finance. The second type consists of techniques
that either need to be developed or adapted keeping in view the requirements for
Sharī‘ah compliance. Hence the discussion of risk management techniques vis-
à-vis Islamic banking is a challenging one. In a study like this, these challenges
can neither be identified fully, nor can these be resolved even partially. The
objective of this section is to initiate a discussion on some aspects of the unique
risks faced by Islamic banks with a view to highlight the challenges and
prospects of mitigating these within the framework of the Islamic principles of
finance. However, in the outset, we briefly discuss the attitude of Islamic
scholars towards risk.
5.1.1 Attitude towards Risk
Risk is assigned significant importance in Islamic finance. Both the two
foundational Fiqhī axioms of Islamic finance, namely, a) al khirāju bi al-amān
and b) al ghunmu bi al-ghurm are in fact risk-based. Together the two axioms
can be described to mean that entitlement to the returns from an asset is
intrinsically related to the responsibility of loss of that asset53. Interest-based
financial contracts separate entitlement to return from the responsibility of loss
by protecting both the principal amounts of a loan as well as a fixed return on it.
Hence, these contracts transfer the risks of loans to the borrower while the lender
retains the ownership of the funds. Islamic finance prohibits the separation of
53
See, Kahf and Khan (1992) for an elaborate discussion of this premises.
120
entitlement to return from the responsibility for ownership. By doing so risk
transferring is discouraged and risk sharing is encouraged.
This does not however mean that the individual’s attitude towards risk is
subjected to any rigid rules. Due to their natural inclinations, some individuals
may like to take more risks than others do and others may like to avoid risk at
all. The universal principle of risk aversion, that expected return from an
investment depends on the level of the investment’s risk – higher risks warrant
the expectation for higher returns and lower risks warrant the expectation for
lower returns is also accepted by the Islamic scholars.
However, the rule of non-separation of entitlement to returns from the
ownership risks led Islamic economists to theorize that most needs of an Islamic
economy would be met by the risk sharing arrangements; leaving no role for
debt finance to play54. Hence within the framework of an interest-free (profit and
loss sharing – PLS) economy the effect of leverage on asset growth and the
resultant financial risks were ignored in the initial theoretical literature. If a bank
is financed only by risk sharing, the dollar value of its assets will be equal to the
dollar value of its equity; a dollar of equity capital will bear the burden of risks
of a dollar in assets. For a 100% equity-based firm, this risk can be referred to as
its normal business risk. As soon as the firm inducts debt finance, the dollar
value of its assets start exceeding the dollar value of its equity by the amount of
the debt finance inducted. In this case, a dollar of the equity capital of the firm
faces the risks of assets in excess of a dollar. This excess burden of risks faced
by the equity capital is due to the debt-financed assets and this can be referred to
the firm’s financial risk. The theoretical literature characterizes the Islamic
economy mainly PLS based, hence it ignores the fundamental difference
between the two types of risks and its implications for stability of Islamic
financial institutions.
It is in the nature of the banking business that assets exceed bank capital
several times. The Islamic banks are not an exception to this general rule
particularly due to their utilization of demand deposits for financing assets.
Islamic scholars agree that under such a condition, banks working on behalf of
depositors need to be very cautious about risks55.
54
See, e.g. Siddiqi (1983).
55
See, Zarqa (1999).
121
From this brief discussion we can derive two important conclusions
regarding the attitude of Islamic scholars towards risk. First, liabilities and
returns of an asset cannot be separated from each other. Indeed, this condition
has a far-reaching implication for all Islamic financial contracts. Second,
common people do not like risk; banks working on their behalf must be cautious
and avoid excessive risk taking.
5.1.2 Financial Risk Tolerance
Is it desirable for the Islamic banks to carry the same level of financial
risks as their peer group conventional banks carry? Or should one expect that
due to the nature of Islamic modes of finance, the Islamic banks should be
exposed to more risks as compared to conventional banks?
It is hard to bring practice and theory together for an answer to these
questions. From a practical perspective, banks should eliminate their financial
risks if possible. For example, without credit risks they will not be required to
apportion part of their current income in loan loss reserves. They can use their
capital more efficiently to accumulate assets, and maximize their rates of return
on equity. This can enable the Islamic banks to pay higher returns to the
investment deposit holders who take more risks as compared to the depositors of
traditional banks. Hence the Islamic banks can maintain their competitive
efficiency. Therefore, the existence of financial risk is an undesirable cost for the
Islamic banks, exactly in the same manner as it is undesirable for the
conventional banks. If the Islamic banks have to carry the same level of financial
risks as their peer group traditional banks, they require simplifying and refining
the Islamic modes of finance to make the risk profile of these modes exactly at
par with the risk profile of interest-based conventional credits.
However, from the theoretical perspective, in this regard, the challenge
is that as a result of such an oversimplification and refinement the Islamic modes
of finance can lose their Islamic characteristics and hence their raison d’être.
Thus from the perspective of the mandate of the Islamic banks, such a
refinement and simplification may not be possible. This is because all Islamic
modes of finance are based on undertaking real transactions and banks are
expected to take a certain degree of ownership risks in order to justify a return
on finance. To the extent of the existence of this inevitable level of additional
risks in the Islamic banks as compared to conventional banks, the Islamic banks
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will need to keep additional capital and develop more rigorous internal control
and risk management techniques.
5.2. CREDIT RISKS
Credit risk is the most important risk faced by banks, because defaults
can also trigger liquidity, interest rate, downgrade and other risks. Therefore, the
level of a bank's credit risk adversely affects the quality of its assets in place. Do
the Islamic banks face more credit risks as compared to conventional banks or
less? A preliminary answer to this question depends on a number of factors, such
as:
One) General credit risk characteristics of Islamic financing,
Two) Counterparty risk characteristics of specific Islamic modes of
finance,
Three) Accuracy of expected credit loss calculation, and
Four) Availability of risks mitigating techniques.
The first two points have been discussed in sections two and three of the
paper. Here we discuss the last two points in more detail.
5.2.1 Importance of Expected Loss Calculation
The process of credit risk mitigation involves estimating and minimizing
expected credit losses. Calculation of expected credit losses, requires the
calculation of probability of default, maturity of facility, loss given default,
exposure at default and the sensitivity of the assets’ value to systematic and non-
systematic risks. Expected loss calculation is relatively easier for simple and
homogenous contracts as compared to relatively complex and heterogeneous
contracts. Since the Islamic financial contracts are relatively complex as
compared to the interest-based credit, the accurate calculation of expected losses
is supposed to be relatively challenging for the Islamic contracts. The lack of
consensus in dealing with a defaulter, illiquid nature of debts etc., add to the
complexity of this matter.
This challenge can be overcome by adapting the foundation IRB
approach as suggested in section four of this paper. Although our survey results
in section three reveal that most Islamic banks, who responded to the
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questionnaire, already use some form of internal rating systems, it is early for the
Islamic banks to qualify for the IRB approach for regulatory capital allocation.
Nevertheless, the presence of some form of internal ratings in these banks
implies they can enhance their systems with an objective to gradually qualify for
the IRB approach. If that happens, these banks will be expected to initially
follow the supervisory benchmark LGD and the risk weights as given in Table-
5.156. Gradually, the banks can develop their own systems of calculating the
LGD and can graduate to the advanced IRB approach.
Table 5.1
Benchmark Regulatory Risk Weights
(Hypothetical, LGD 50%)
Probability of Default % Corporate Exposures Retail Exposures
0.03 14 6
0.05 19 9
0.1 29 14
0.2 45 21
0.4 70 34
0.5 81 40
0.7 100 50
1 125 64
2 192 104
3 246 137
5 331 195
10 482 310
15 588 401
20 625 479
30 - 605
Source: The New Basel Accord
5.2.2 Credit Risk Mitigation Techniques
A number of standard systems, methods, and procedures for credit risk
mitigation are also relevant for the Islamic banks. In addition, there is also a
need to keep in view the unique situation of these banks. A number of the
standard systems and some additional considerations are discussed here in
relation to the credit risk management of Islamic banks.
5.2.2.1 Loan Loss Reserves
56
It needs to be emphasized that at this stage the New Basel Accord is only a proposal. But it
is expected that the IRB approach will remain as an important part of the final document.
124
Sufficient loan loss reserves offer protection against expected credit
losses. The effectiveness of these reserves depends on the credibility of the
systems in place for calculating the expected losses. Recent developments in
credit risk management techniques have enabled large traditional banks to
identify their expected losses accurately. The Islamic banks are also required to
maintain the mandatory loan loss reserves subject to the regulatory requirements
in different jurisdictions. However, as discussed above the Islamic modes of
finance are diverse and heterogeneous as compared to the interest-based credit.
These require more rigorous and credible systems for expected loss calculation.
Furthermore, for comparability of the risks of different institutions there is also a
need for uniform standards for loss recognition across modes of finance,
financial institutions and regulatory jurisdictions. The AAOIFI Standards # 1
provides for the basis of income and loss recognition for the Islamic modes of
finance. However, except for a few institutions, banks and regulatory
organizations do not apply these standards.
In addition to the mandatory reserves some Islamic banks have established
investment protection reserves. The Jordan Islamic Bank has pioneered the
establishment of these reserves. The reserves are established with the
contributions of investment depositors and bank owners. The reserves are aimed
at providing protection to capital as well as investment deposits against any risk
of loss including default. However, investment deposit holders are not
permanent owners of the bank. Therefore, contributions to the reserve by old
depositors can be a net transfer of funds to new depositors and to the bank
capital. In this manner these reserves cannot ensure justice between old and new
depositors and between depositors and bank owners. This problem can be
overcome by allowing the depositors to withdraw their contributions at the time
of final withdrawal of deposits. However, such a facility will not be able to
provide a protection in the case of a crisis.
5.2.2.2 Collateral
Collateral is also one of the most important security against credit loss.
Islamic banks use collateral to secure finance, because al-rahn (an asset as a
security in a deferred obligation) is allowed in the Sharī‘ah. According to the
principles of Islamic finance, a debt due from a third party, perishable
commodities and something, which is not protected by the Islamic law as an
asset, such as an interest-based financial instruments are not eligible for use as
collateral. On the other hand, cash, tangible assets, gold, silver and other
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precious commodities, share in equities, etc., and debt due from the finance
provider to the finance user are assets eligible for collateral. We discuss a
number of general characteristics of the collateral, which is available in the
Islamic financial industry.
a) As discussed in section four, in the proposed New Basel Accord some
types of collateral are given regulatory capital relief depending on the
quality of the collateral and subject to the standardized regulatory
haircuts as given in Table 5.2. These standards show that cash and
treasury bills are the most valuable collateral and can be given very high
regulatory capital relief. Suppose two clients offer collateral of dollars
100 each, e.g., US treasury bills of one-year maturity and the main index
equities, respectively. The haircut for the first collateral is 0.5% (the
collateral value after this haircut is dollars 95). In the second case, the
collateral haircut is 20% (collateral value is dollars 80). In the first case,
the capital requirement will be lesser as compared to the second case.
The Islamic banks not being able to take the first type of collateral, will
be considered more risky.
b) There may be some assets, which from the Islamic banks’ point of view
are good collateral and deserve a regulatory capital relief. For example, a
carefully selected asset financed by the Islamic bank may be at least as
good a collateral as a 5-year maturity bond issued by a BBB corporate
entity. Since the Islamic bank’s asset is not in the list of eligible
collateral, it is subject to a 100% haircut; the BBB-bond in this case is
subject to only a 12% haircut. For the purpose of regulatory capital
relief, the Islamic bank’s asset is worth nothing, whereas the bond is
worth dollars 88 (considering the collateral value as dollars 100).
c) Due to restrictions on sale of debts, there are no liquid Islamic debt
instruments. However, in view of their liquid nature debt instruments
like treasury bills etc., are generally considered as good collateral. These
assets are not available to the clients of Islamic banks to offer.
d) The Islamic banks have limited recourse to the assets they finance. As
compared to this the conventional banks can have unlimited recourse to
the assets of their clients. On a stand-alone basis, a particular asset
financed by the Islamic bank may depreciate fast even though during the
same time the firm’s assets may gain value in general. Thus due to its
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limited recourse nature, the quality of the Islamic banks’ collateral may
in fact be lower as compared to the collateral of the peer group
conventional banks. Moreover, the value of limited recourse collateral is
normally highly correlated with the exposure of the credit. If the credit
goes bad, the collateral value depreciates too. Good quality collateral
should not have such a characteristic. Furthermore, if stand-alone
collateral depreciates faster in value as compared to the firm’s other
assets; there is an incentive to default.
Table 5.2
Standard Supervisory Haircuts for Collateral in % of Collateral Value
Issue rating for debt Residual Maturity Sovereigns Banks/
securities Corporates
≥ 1 year 0.5 1
AAA/AA > 1 year, ≤ 5 years 2 4
> 5 years 4 8
≥ 1 year 1 2
A/BBB > 1 year, ≤ 5 years 3 6
> 5 years 6 12
≥ 1 year 20
BB > 1 year, ≤ 5 years 20
> 5 years 20
Main index equities 20
Other equities listed on a recognized exchange 30
Cash 0
Gold 15
Surcharge for foreign exchange risk 8
Source: The New Basel Accord
e) The legal systems in the jurisdictions in which Islamic banks operate do
not support the qualitative aspects of a good collateral as in most cases it
is very difficult to obtain control of the asset and convert it into liquidity
without a high cost. This state worsens further due to the fact that the
supporting institutional infrastructure for Islamic banking is still in the
early stages of development. There are no uniform standards to
recognize a default event, to treat a default event when it happens and to
litigate disputes.
127
This discussion shows that due to a number of reasons the collateral
available to the Islamic banking industry in general is not eligible for regulatory
capital relief under the proposed international standards. This may be due to the
fact that the Islamic banks are not represented in the standard setting bodies.
They can however, carefully study the consultation documents distributed by the
standard setters and present their own points of view like other institutions.
Furthermore, the industry-wide general quality of collateral depends on a
number of institutional characteristics of the environment as well as the products
offered by the industry. An improvement in the institutional infrastructures and a
refinement of the Islamic banking products can be instrumental in enhancing the
collateral quality and reducing credit risks.
5.2.2.3 On-Balance Sheet Netting
On-balance sheet netting implies the matching out of mutual gross
financial obligations and the accounting for only the net positions of the mutual
obligations. For example, bank A owes to bank B $ 2 million resulting from a
previous transaction. Independent from this obligation, bank B owes to A $ 2.2
millions. In a netting arrangement, the $ 2 million mutual obligations will match
each other out so that $ 0.2 million will be settled by B as a net amount. There
could be several considerations in this arrangement including the maturity of the
two obligations, and the currencies and financial instruments involved. The
netting process could therefore include discounting, selling and swapping the
gross obligations.
Carefully prepared, netting overcomes credit risk exposures between the
two parties. With the participation of a third party, playing as a clearinghouse for
the obligations, the arrangement becomes a powerful risk mitigating technique.
Regulators recognize that role but also supervise the netting activities of banks.
The Islamic banks so far have not designed any such mechanism. It can be
considered as an important area for future cooperation between the Islamic
banks particularly, if the market for two-step contracts as discussed in this
section expands in which banks will have more mutual obligations.
5.2.2.4 Guarantees
Guarantees supplement collateral in improving the quality of credit.
Commercial guarantees are extremely important tools to control credit risk in
conventional banks. Those banks whose clients can provide good commercial
guarantees and who can fulfill other requirements can qualify for regulatory
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capital relief under the proposed New Basel Accord. Although some Islamic
banks also use commercial guarantees, the general Fiqh understanding goes
against their use. In accordance with the Fiqh, only a third party can provide
guarantees as a benevolent act and on the basis of a service charge for actual
expenses. Due to this lack of consensus, therefore, the tool is not effectively
used in the Islamic banking industry.
Multilateral Development Banks (MDBs) enjoy special status in the
jurisdiction of their respective member countries. This status has a particular
privilege during times of financial crisis in a member country. Financial crisis
exposes banks’ credit to a country or an institution in its jurisdiction to serious
credit risks. In terms of their foreign exchange reserves some countries are
always in a crisis-like situation. Credit exposure to entities in such jurisdictions
is always risky. This also has an implication for the borrower’s cost of capital in
terms of foreign exchange. The cost of capital in getting finance in local
currency being always lower than the cost of capital in getting finance from
outside.
Participation in MDB-led syndication provides an automatic guarantee
to a participating commercial bank against the risks as mentioned. Thus it
enhances the finance user’s credit quality often to the extent that the cost
differential between borrowing at home and borrowing abroad is almost
eliminated. This implies that by participating in the MDB-led syndication
schemes, the commercial banks can mobilize funds in foreign currency at the
cost of mobilizing funds in local currency. The syndication generally takes the
form of Figure 5.157.
Figure 5.1
Fund Flows in an MDB-led Syndication
MDB Own Resources
MDB-led
Facility Users of
MDB fund flows funds
Commercial flows
57
See for example, (Hussain 2000), Standards & Poor’s (2001), Asian Development
Bank (2001).
129
Commercial Co-financiers
Based on these arguments, Hussain (2000) suggests that the IDB shall
play a more active role in providing syndicated facilities by strengthening its
existing facilities. By benefiting from the IDB’s preferred status in the member
countries the participating Islamic banks will be able to mitigate their foreign
exchange as well as country risk exposures substantially.
5.2.2.5 Credit Derivatives and Securitization
As discussed in section two, through credit derivatives the underlying risk
of a credit is separated from the credit itself and sold to possible investors whose
individual risk profile may be such that the default risk attracts their investment
decision. This new mechanism has already been described earlier. It has become
so effective that under certain conditions it is expected to fully protect banks
against credit risks. Therefore, the use of credit derivatives as a risk-mitigating
instrument is on a rapid rise.
However, at the present, the Islamic banks are not using any equivalent
of credit derivatives. The development of comparable instruments depends on
the permissibility of sale of debts, which is prohibited by almost a consensus
except for Malaysia. In addition to the Malaysian practice, there are a number of
proposals under discussion to overcome the sale of debt issue.
a. Some studies call for making a distinction between a fully secured debt
and an unsecured debt. It is argued that external credit assessment makes
the quality of a debt transparent. Moreover, credit valuation techniques
have improved drastically. Furthermore, all Islamic debt financing are
asset-based and secured financing. In view of these developments,
restrictions on sale of debt may be re-considered (Chapra and Khan
2000).
b. Some scholars suggest that although sale of debt is not possible as such,
but the owner of a debt can appoint a debt collector. For example, if the
due debt is $ 5 million58 and the owner considers that as a result of
default 0.5 million may be lost. The owner can offer some amount lesser
than this estimated loss, say for example 0.4 million to a debt collector.
The arrangement will be organized on the basis of Wakālah (agency
58
See, Al-Jarhi and Iqbal (forthcoming).
130
contract) or Ju‘ālah (service contract). There seems to be no Fiqhī
objection to this.
c. Debt can be used as a price to buy real assets. Suppose, bank A owes
debts worth $1m to bank B, which are due after 2 years. Meanwhile
bank B needs liquidity to buy real assets worth $1m from a supplier C
on deferred basis for 2 years. In this case, subject to the acceptance of C,
the payments for bank B’s installment purchase can be made by bank A.
Due to installment sale from C to B, C will charge Murāba ah profit of
say, 5%. This profit can be adjusted in two ways. First, upon mutual
agreement the supplier may supply goods worth $0.95 million to bank B
and the supplier will receive $1m cash from bank A in 2 years. Or as a
second option, C will receive $1m from A and $0.05m directly from B.
The implication of this is important. B receives assets worth $1m at the
present instead of receiving $1m after 2 years, but after paying 5%. As a
result, in net terms, B receives $0.95m today for $1m after 2 years. Thus
the arrangement facilitates a Fiqh compatible discount facility. The flow
of funds and goods resulting from the first case are given in Figure 5.2.
Figure 5.2
Sale of Debt for Real Assets
Bank A owes to Bank B, buys from
bank B, $ 1m in 2 supplier C on credit for 2
years years worth $ 0.95m
Supplier C, receives
from A, $1m in 2
years
The example cited above is based on the permission of the use of debts
in buying goods, services and other real assets. This permission can further be
extended to design quasi debt (equity) financial instruments by embedding
convertibility options. For instance in writing an Islamic debt contract, the user
of funds can inscribe a non-detachable option in the contract that subject to the
preference of the financier the receivables can be used to buy real assets or
131
shares from the beneficiary. This option in fact changes the nature of collateral
from a limited recourse to a full recourse as the option can be utilized depending
on the will of the financier. In this manner, it enhances the quality of credit
facility by reducing its risk. The potential of these instruments increases in the
framework of two-step contracts. However, the Islamic banks at the present do
not write such instruments.
5.2.2.6 Contractual Risk Mitigation
Gharar (uncertainty of outcome caused by ambiguous conditions in
contracts of deferred exchange) could be mild and unavoidable but could also be
excessive and cause injustices, contract failures and defaults. Appropriate
contractual agreements between counterparties work as risk control techniques.
A number of these can be cited as an example.
a) Price fluctuations after signing a Salam contract may work as a
disincentive for fulfilling contractual obligations. Hence if the price of,
for example, wheat appreciates substantially after signing the contract
and receiving the price in advance, the wheat grower will have an
incentive to default on the contract. The risk can be minimized by a
clause in the contract showing an agreement between the two parties that
a certain level of price fluctuation will be acceptable, but beyond that
point the gaining party shall compensate the party, which is adversely
effected by the price movements. In Sudan, such a contractual
arrangement known as Band al-I sān (beneficence clause) has now
become a regular feature of the Salam contract.
b) In Isti nā‘, contract enforceability becomes a problem particularly with
respect to fulfilling the qualitative specifications. To overcome such
counterparty risks, Fiqh scholars have allowed Band al-Jazāa (penalty
clause).
c) Again in Isti nā‘ financing, disbursement of funds can be agreed on a
staggered basis subject to different phases of the construction instead of
lumping them towards the beginning of the construction work. This
could reduce the banks’ credit exposure considerably by aligning
payments with the progress of the work.
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d) In Murāba ah, to overcome the counterparty risks arising from the non-
binding nature of the contract, up-front payment of a substantial
commitment fee has become permanent feature of the contract.
e) In several contracts, as an incentive for enhancing re-payment, a rebate
on the remaining amount of mark-up is given.
f) Due to non-presence of a formal litigation system, dispute settlement is
one of the serious risk factors in Islamic banking. To overcome such
risks, the counterparties can contractually agree on a process to be
followed if disputes become inevitable. This is particularly significant
with respect to settlement of defaults, as interest-based debt re-
scheduling is not possible.
g) It can be proposed that to avoid the default by the client in taking
possession of the ordered goods, the contract shall be binding on the
client and not binding on the bank. This suggestion assumes that the
bank will honor the contract and supply the goods as contractually
agreed, even if the contract is not binding on it. An alternative proposal
could be to establish a Murāba ah clearing market (MCM) to settle
cases, which may not be cleared due to the non-binding nature of the
Murāba ah contract.
h) Since the Murāba ah contract is approved with the condition that the
bank will take possession of the asset, at least theoretically the bank
holds the asset for some time. This holding period is almost eliminated
by the Islamic banks by appointing the client as an agent for the bank to
buy the asset. Nevertheless, the raison d’être of approving the contract is
the responsibility of the bank for the ownership risk. For this risk
therefore, capital needs to be allocated.
All these features of contracts serve to mitigate counter party default
risks. Similar features can enhance the credit quality of contracts in different
circumstances. It is desirable to make a maximum benefit of such features
wherever new contracts are being written.
5.2.2.7 Internal Ratings
All banks undertake some form of internal evaluation and rating of their
assets and clients, particularly, for maintaining the regulatory loan loss
provisions. Depending on the sophistication of banks, these systems can be
133
different in different banks. Some banks have recently developed formal internal
rating systems of the client and/or the facility. As discussed above, in a general
sense an internal rating system can be described to be a risk-based inventory of
individual assets of a bank.
These systems identify credit risks faced by the banks on an asset-to-
asset basis in a systematic and planned manner instead of looking at bank's risk
on an entire portfolio basis. The asset-to-asset coverage of the system makes it
more relevant for banks whose asset structures are less homogenous. The
Islamic modes of finance are diverse and have different risk characteristics. For
example, a credit facility extended to a BBB rated client on the basis of
Murāba ah, Isti nā‘, leasing and Salam will have different not uniform risks
exposures. The risk exposure is expected to be different not only across modes
of finance but also across clients. For example, if there are two clients both rated
as BBB, due to the different nature of the businesses of the two clients, risk
exposure of the same mode can be different for the different clients. In addition,
different maturity can have different implication for risk across modes and
across clients. Therefore, due to the diversity of the Islamic modes of finance, it
is appropriate for the Islamic banks to measure the risk of each asset separately.
Developing a system of internal ratings can be instrumental in doing this.
Various banks use different systems. For establishing a basic internal
rating system in a bank, two basic information are required - maturity of the
facility and credit quality of the client. Maturity of facility is known in all cases
of funding. Credit quality of the client can be assessed by various means. The
client may have a previous record with the bank, it may be rated by rating
agencies and it must have audited reports. Moreover, the general reputation of
the client, and the type of collateral provided can also be helpful. Putting all
these and other relevant information together wherever available, bank staff can
judgmentally assess the clients’ credit quality.
Once this information is available, each client can be assigned an
expected probability of default. After having information about the maturity of
each facility and expected default probability for each client, as a first step, this
information needs to be mapped together as in Table – 5.359. As a second step, a
benchmark credit risk weight is assigned. In Table – 5.3 this benchmark credit
risk weight (100%) is for a probability of default of 0.17% - 0.25% for a facility
59
The table is based on ISDA (2000).
134
with a maturity of 3 years. With the same probability of default, the credit risk
weight for a facility of 2 years’ maturity will be 20% less than the benchmark
and for a 4 years’ maturity 18% more than the benchmark.
135
Table 5.3
Hypothetical Internal Rating Index Relative to 3 Year Asset with
(Default Probability of 0.17% - 0.25% = 100%)
Probability
of default % 0.5 Ysr 0.5-1Yrs 1-2Yrs 2-3Yrs 3-4Yrs 4-5Yrs 5-6Yrs 6-7Yrs 7-8Yrs 8-9Yrs > 9Yrs
0.00- 6 8 12 17 21 25 28 32 36 40 43
0.025
0.025- 9 12 17 23 29 35 40 46 51 56 60
0.035
0.165- 48 69 80 100 118 134 149 164 178 191 203
0.255
0.255- 72 86 108 130 150 168 186 202 216 230 241
0.405
Most Islamic banks are technically capable to initiate some form of
internal credit risk weighting of all their assets separately. In the medium and
longer-run these could evolve into more sophisticated systems. Initiation of such
a system can be instrumental in filling the gaps in the risk management system
and hence enhancing the rating of these by the regulatory authorities and
external credit assessment agencies.60
At this stage, it is too early for the Islamic banks to qualify for even the
foundation IRB approach for regulatory capital allocation. However, one needs
also to reemphasize that the IRB approach is more consistent with the nature of
Islamic modes of finance. It is with this background that the Islamic banks need
to initiate programs for developing systems of internal rating. Regulatory
authorities will recognize these systems only if these are found to be robust.
5.2.2.8 RAROC
RAROC is used for allocating capital among different classes of assets
and across business units by examining their associated risk-return factors. An
application of RAROC in Islamic finance would be to assign capital for various
modes of financing. Islamic financial instruments have different risk profiles.
For example Murāba ah is considered less risky than profit-sharing modes of
60
Chapra and Khan (2000) recommend the Islamic banks to adopt this system. Bank Nagara
Malaysia (2001) calls for the BCBS to make this as the primary approach for regulation.
136
financing like Muārabah and Mushārakah. Using historical data on different
modes of financing for investments, one can estimate the expected loss and
maximum loss at a certain level of confidence for a given period for different
financial instruments. Then this information can be used to assign risk capital for
different modes of financing by Islamic financial instruments.
The concept of RAROC can also be used to determine the rate of return
or profit rate on different instruments ex-ante by equating their RAROCs as
shown below.
RAROCI = RAROCj ,
or (Risk Adjusted Return)I /(Risk capital)i =(Risk Adjusted Return)j/(Risk
capital)j
where i and j represents different modes of financing (e.g., Muārabah and
Mushārakah respectively). Thus if instrument j is more risky (i.e., has a larger
denominator) then the financial institution can ask for a higher return to equate
RAROC of the instrument with that of instrument i.
5.2.2.9 Computerized Models
Due to the revolutionary developments in the area of mathematical and
computational finance and the use of computers, banks are increasingly using
computerized models of risk management. These models are actually refined
versions of the internal ratings systems. In the internal ratings systems
information can be based on qualitative judgment, models are actually based on
quantitative data. A number of credit risk management models are now available
in the market such as the KMV, CreditMetrics, CreditPortfolioView, CreditRisk
etc. In future these models are going to be more important for risk management.
Therefore, there is a need for the Islamic banks to make planned and conscious
strategies towards developing advanced systems wherever feasible.
5.3 MARKET RISKS
As mentioned before, market risks comprise of interest rate risks,
exchange rate risks, and commodity and equity price risks. These are briefly
discussed here in perspective of Islamic banks.
5.3.1 Business Challenges of Islamic Banks: A General Observation
It is generally accepted that the non-availability of financial derivatives
to Islamic banks is a major hindrance in their way to manage market risks as
137
compared to the conventional banks. The direct competitors of Islamic banks are
however, Islamic banking windows of conventional banks. Obviously, due to
religious restrictions, the Islamic banks cannot enter the conventional banking
market. But the conventional banks are offering the Islamic products
simultaneously with their own products. Competition no doubt enhances
efficiency and a leveled playing field is a prerequisite for a healthy competitive
environment. A leveled playing field for competition between Islamic and
conventional banks in this regard cannot be ensured without a complete
separation of the risks of the Islamic products from the risks of conventional
banks’ other operations. There are a number of difficulties in separating these
risks effectively.
As discussed earlier regulators have been trying to bring as many risks
under the cover of capital as possible. Since capital is the ultimate protection
against risks, it is a prudent policy, for banks to manage the risks of the
organization at the group level. Particularly, derivatives for hedging purposes are
used to control the risks of the banking organization at the group level rather
than using these separately for activities of different units. This implies that the
positions of an Islamic banking unit can be left open to comply with the
requirements of the Sharī‘ah supervisors. But at the group level, the bank may
not leave any position open without hedging using interest-rate derivatives. As a
result, controlling the use of derivatives for hedging the group level positions are
beyond the reach of Sharī‘ah supervisors of an Islamic window in a
conventional bank.
In addition to supervisors, owners, credit assessment agencies and
depositors are expected to influence the activities of banks. Unlike the owners of
Islamic banks, the owners of most conventional banks cannot be expected to
offer Islamic products as a result of their own religious beliefs. These products
are offered as a result of pure business decisions. External rating agencies also
rate banks only on the basis of their financial soundness not on the basis of
religious commitment.
Clients, directly or through the Sharī‘ah boards can also be expected to
effect the decisions of banks. The prime concern of Islamic depositors is to
avoid any mixing of permissible and impermissible incomes. The clients of
Islamic banking windows of conventional banks are mostly on the asset side. In
most countries where Islamic banking windows are allowed, mutual funds are
offered as an alternative to investment deposits. Islamic depositors in such
138
systems will keep only current accounts. Since current account holders are not
entitled to any income, they will have no incentive in monitoring the
management or income earning activities of banks.
Thus, there is no effective mechanism to prevent the conventional banks
from using derivatives for managing the risks of their Islamic products. As a
result, Islamic banks competing with the Islamic banking windows of
conventional banks are in a serious competitive disadvantage as for as the use of
derivatives are concerned. This poses to the Islamic banks the most serious
business risk – that of competing on a playing field, which is not leveled. As
discussed in section four, this playing field can effectively be leveled only if
separate capital is required for the Islamic banking operations of a conventional
bank.
There is a need to distinguish the environment as described above from
an environment where all operations of banks could be subject to the principles
of Islamic finance. If the entire banking system is brought under Islamic
principles, the nature of this risk will change. In the ongoing dialogue in
Pakistan about the introduction of a comprehensive Islamic banking system, the
apprehension of local banks has been that as a result of introducing PLS
deposits, there would be a quick migration of funds from the weaker (local)
banks to the stronger (foreign) banks. This could prompt the collapse of local
banks. The apprehension in fact highlights the potential market discipline which
withdrawal risk of Islamic banking can introduce if the system is applied
economy-wide. In countries where banks are mostly in the public sector, the
subject of market discipline is however, not much relevant.
5.3.2 Composition of Overall Market Risks
The above discussion necessitates some analysis of the nature of
important risks for which derivatives are used and the types of most dominant
derivatives. There is no statistical information, which can tell us exactly about
the proportion of each of the various risks in the total global financial risk.
However, since derivatives are primarily used for the mitigation of risks, we can
use the data on derivative markets to gauge the actual intensity of the various
risks in the financial markets.
By end of December 2000, the total notional amount of the outstanding
volumes of OTC traded derivative contracts was US dollars 64.6 trillion for
interest rate derivatives and 15.6 trillions for FX derivatives. This makes the
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interest rate contracts 78% of the total notional amount of derivatives, and FX
contracts 19% of the total. The remaining 2% of the total were in equity-linked
derivatives and 1% in commodity-based derivatives. A further narrowing down
of the composition of the most important derivative market, namely the interest
rate derivatives into its different components shows that 75% of these are in
swaps, 15% in options and 10% in forward rate agreements61.
From this information we can conclude that interest rate risk and foreign
exchange risk are the most important risks. The event of credit default in
addition to creating an immediate liquidity problem magnifies the risk of the
bank through two more channels. As a result of the delay in repayment, the
effect of changes in the market prices will be adverse for the net income of the
bank. Furthermore, as a result of the default the firm will be downgraded, again
having a negative implication for the bank’s net income. Conventional banks
effectively use this decomposition of credit risk in mitigating the risks through
credit derivatives. Credit derivatives are not available to Islamic banks.
Moreover, due to default, the Islamic banks cannot reschedule the debt on the
basis of the mark-up rate. Hence these banks are also more exposed to default
triggered interest-rate risks as compared to their conventional counterparts62.
5.3.3 Challenges of Benchmark Rate Risk Management
Among interest rate derivatives, swaps are the most dominant contracts.
Swaps facilitate dual cost reduction role simultaneously. On one hand these
contracts enable financial institutions to utilize their comparative advantages in
fund raising and exchanging the liabilities according to their needs. Thus, the
contract minimizes the funding costs of participating institutions. On the other
hand, they are used as effective hedging instruments to cut the costs of
undesirable risks. Thus, the effective utilization of swaps undisputedly enhances
competitive efficiency. Since swaps are primarily interest-based contracts, these
have not attracted the attention of Islamic scholars.
Although Islamic banks do not undertake interest-based transactions
they however, use the London inter-bank borrowing rate (LIBOR) as a
benchmark in their transactions. Thus, the effects of interest rate changes can be
transmitted to Islamic banks indirectly through this benchmark. In case of a
61
For the year 2000 as a whole, the turnovers of exchange traded derivatives were recorded
as US dollars 383 trillion (interest 339 trillion, equity 41 trillion, and currency 2.6 trillion).
62
The interrelationship between credit and market risk is an important area of current
research. But there are still no reliable measures of this relationship.
140
change in the LIBOR, the Islamic banks could face this risk in the sense of
paying more profits to future depositors as compared to receiving less income
from the users of long-term funds. Hence it is only more prudent to consider that
the assets of Islamic banks can be exposed to the risk of change in the LIBOR.
Chapra and Khan (2000) argue that the nature of investment deposits on
the liability side of the Islamic banks adds an additional dimension to this risk.
Profit rates to be paid to Muārabah depositors by the Islamic bank will have to
respond to the changes in the market rate of markup. However, as profit rates
earned on assets reflect the markup rates of the previous period, these cannot be
raised. In other words, any increase in new earnings has to be shared with
depositors, but it cannot be re-adjusted on the assets side by re-pricing the
receivables at higher rates particularly, due to restrictions on the sale of debts.
The implication is that the net Murāba ah income of the Islamic bank is
exposed to the markup price risk. Some techniques to mitigate the Murāba ah
(mark-up) price risk are discussed below.
5.3.3.1 Two-step Contracts and GAP Analysis
One of the most common and reliable tools to manage interest rate risk
is the technique of GAP analysis63 as discussed in section two. The GAP
analysis technique is used to measure the net income and its sensitivity with
respect to a benchmark. Risk management tools then target at ideally making the
net income immune to any changes in the benchmark rate, i.e., a target net
income is achieved whatever the market benchmark may be. If such an objective
is achieved, an increase in the benchmark will not pose any risks to the targeted
net income. The cash flows of the bank remain stable at a planned level ensuring
stability of net income
The effectiveness of interest rate risk management depends on the re-
price-ability of assets and liabilities. As for as the Islamic banks are concerned,
investment deposits are perfectly re-price-able as the expected rate of return
increases and decreases depending on the market rate of return. On the other
hand most of the assets of Islamic banks are perfectly non-re-price-able due to
restrictions on sale of debts. The effectiveness of a GAP management strategy
for the Islamic banks requires flexibility from the two extremes on both liability
and assets sides. On the asset side the Islamic banks’ managers need to have
more re-price-able assets. The list of probable financial instruments as given in
63
See, Koch (1995).
141
Table 5.4 are expected to make the asset side of Islamic banks more liquid in
future.
The re-price-ability of instruments on the liability side shall be in the
control of asset and liability managers; the re-price-ability of investment
deposits is not in their control. This goal is always very difficult to achieve.
However, the availability of more options is always expected to be helpful. One
of such options is available to Islamic banks in the form of two-step contracts.
In a two-step contract, the Islamic bank can play the role of a guarantor
in facilitating funds to the users. Since guarantee cannot be provided as a
commercial activity, in a two-step contract, it can be provided by the Islamic
bank’s participation in the funding process as an actual buyer. In the existing
Murāba ah contracts the bank makes an up-front payment to the suppliers on
behalf of the client. In the two-step contract the bank will have two Murāba ah
contracts, as a supplier with the client and as a buyer with the actual supplier
(see Figure 5.3). The bank will hence not make an up-front payment to the actual
supplier. The two-step Murāba ah contract will have a number of implications
for the banks.
Figure 5.3
Two-Step Contracts
Client Bank Supplier
Client-Bank Murāba ah Contract Bank-Supplier Murāba ah Contract
a. It can serve as a source of funds. In a longer maturity contract,
such funds can be considered as tier-2 capital of the bank, based on
the criteria allocated to such capital by the Basel Accord.
b. The contracts will enhance the banks' resources under
management. This will have both good and adverse implications.
The adverse implications will arise from the increased amount of
financial risks. If these risks are managed properly, the contracts
can prove to be instrumental in enhancing the net income and
hence competitiveness of Islamic banks.
142
c. This will enhance the liquidity position of Islamic banks. Although
liquidity is not the immediate problem of Islamic banks, the
availability of liquidity always enhances stability.
d. It will provide flexibility in liability management by offering
different maturity of liabilities. The banks can match the maturity
of their liabilities and assets more efficiently.
e. The banks will actually guarantee the re-payment of the funds by
the clients. Hence guarantee is provided in a more acceptable and
transparent manner.
f. The concept of the two-step contracts is not restricted to
Murāba ah, it is equally applicable to Isti nā‘, leasing and Salam.
g. Finally, the new contracts would be an addition to the available
financial instruments thus paving the way for developing further
instruments.
5.3.3.2 Floating Rate Contracts
Fixed rate contracts such as long maturity installment sale are normally
exposed to more risks as compared to floating rate contracts such as operating
leases. In order to avoid such risks therefore, floating rate leases can be
preferred. However, leases will expose the bank to the risk of equipment price
risks as discussed below.
5.3.3.3 Permissibility of Swaps
As mentioned above the basic economic rationale of a swap contract is
to cooperate in minimizing the cost of funds by reducing the borrowing cost and
by reducing the cost of undesirable risks for both parties. In this manner a swap
is a win-win contract for both participating parties. To start with, it is obvious
that one cannot expect any Fiqhī objections to such a cooperative strategy. It is
the process of implementing the swap contract, which may not be permissible.
Particularly, as all swaps are interest-based, there is no possibility for the Islamic
banks to use such contracts. To design Sharī‘ah compatible swaps the following
conditions need to be fulfilled.
a. There is a party whose credit rating is low because it holds long maturity
(illiquid) assets and short maturity liabilities. Because, of the shorter
maturity of liabilities, this party faces uncertainties in the short-run.
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Since its assets are long-term it needs to borrow long-term, but its long-
term borrowing cost is high due to its low rating. Due to non-availability
of such cheaper and long-term funds, it actually borrows short-term at a
higher cost.
b. There is another party whose liabilities are long-term but assets are more
liquid as a result its credit rating is very good. It has no uncertainties in
the short-term but has uncertainties in the long run at the time of the
maturity of liabilities. It can borrow long-term at cheaper cost, but its
borrowing preference is for short-term to match its asset-liability
maturity. These two scenarios simplify the real world situation.
Obviously, the Fiqh cannot have an objection to these quite natural
situations.
c. There exists a fixed-income financial instrument, which is used for
raising long-term funds and there also exists a floating income financial
instrument, which is used for raising short-term funds.
The third prerequisite for having an acceptable swap depends on the
availability of suitable Sharī‘ah compatible instruments. At the present, there are
no fixed and floating income Islamic financial instruments available in the
secondary markets. However, ideas have been substantially conceptualized and
efforts are underway to make institutional arrangements for making such
instruments available. Once such instruments become available, the Islamic
banks will be empowered with one of the most powerful tools of market risk
management, namely, swaps.
As discussed in section two, the objective of a swap is to exchange the
costs of raising funds on the basis of comparative advantages. It has been shown
there that by means of swap both parties end up with a net financial gain as well
as paying in consistency with their own asset and liability structures. Thus the
argument for a swap is exactly the same as the argument for free international
trade on the basis of comparative advantages. Since swaps are arranged in
trillions of US dollars in real life, they are hence the practical manifestation of
the theory of gains from comparative advantages under free trade.
The last question in evaluating a swap contract from the Islamic finance
perspective is, is it permissible for two parties to pay the funding costs of each
other? As shown, a swap is basically a win-win contract. Both parties are better
off and hence there could not be any objection from the Sharī‘ah point of view.
144
Thus we conclude that there is a great need for swap contracts. There apparently
are no Sharī‘ah restrictions in developing swap contracts as such. The limitation
is that of the availability of Sharī‘ah compatible financial instruments suitable
for using in swap contracts.
5.3.3 Challenges of Managing Commodity and Equity Price Risks
In general, fluctuations in the prices of commodities and equities is not
of any serious concern for bank asset-liability managers. The statistical
information on derivatives provided earlier confirms this fact. However, banks
may consider investment in commodities particularly gold and equities as a
source of income for their clients and themselves. Banks’ exposures in this
regard are normally marginal and are included in the trading books. There are
however, some special considerations involved in conceptualizing these risks,
particularly commodity price risks, in Islamic banks. First we briefly discuss
these considerations. After that the challenges of controlling the risks are
discussed.
While conceptualizing commodity price risks in Islamic banking there is
a need to clarify a number of points.
a. The Murāba ah price risk and commodity price risk must be clearly
distinguished. In Islamic banking there could be a misconception about
the treatment of mark-up price risk as commodity price risk. The basis of
the mark-up price risk is LIBOR. Furthermore, it arises as a result of the
financing not trading process. Therefore, in our understanding it shall
conceptually be treated as an equivalent of interest (benchmark) rate risk
as discussed in the previous section.
b. In contrast to mark-up price risk, commodity price risk arises as a result
of the bank holding commodities for some reason. Some good examples
of such reasons are: a) The Islamic bank developing an inventory of
commodities for selling, b) Developing inventories as a result of Salam
financing, c) gold and real estate holdings and d) holding of equipment
particularly for operating leases. There is always a possibility that in
leases ending with ownership, the benchmark rate risk and equipment
price may not be properly identified and separated. This could be one of
the reasons due which the Fiqh scholars do not recommend such leases.
145
c. Commodity price risk arises as a result of ownership of a real
commodity or asset. Mark-up price risk arises as a result of holding a
financial claim, which could be the result of deferred trading. Therefore,
under leasing, the equipment itself is exposed to commodity price risk
and the overdue rentals are exposed to interest-rate risks. Similarly, if
the lease contract is a long one and the rental is fixed not floating, the
contract faces interest rate risk. Thus, a fixed rental, based on a long
operating lease is exposed to dual edged risks – commodity and mark-up
price. In order to avoid such risks banks shall prefer leases ending with
ownership possibly price fixed in the beginning and rentals periodically
re-priced. Such a lease would actually be an installment sale contract
based on a floating rate mark-up. In this case, the banks can actually
minimize their exposure to both the mark-up and commodity price risks.
Our survey results reveal that there is a tendency among Islamic banks
to prefer such contracts. However, neither such a lease nor such an
installment sale is compatible with the Sharī‘ah.
Thus we can conclude that the Murāba ah and Isti nā‘ transactions are
exposed to Murāba ah (mark-up price) or benchmark rate risk and Salam and
leases are exposed to both Murāba ah price and commodity price risks. Due to
Salam, and operating leases, commodity price risk exposure of Islamic banks is
expected to be higher as compared to their peer group conventional banks. We
discuss here some of the techniques which may be useful in managing the
commodity and equipment price risks.
5.3.3.1 Salam and Commodity Futures
Futures contracts enable their users to lock-in future prices of their own
expectations. For example, a wheat grower typically faces price risk - a
deviation of actual future wheat prices from the expected future wheat prices. A
farmer whose wheat will be ready for market in six months time may expect its
price to be some amount per bushel; after six months the price may actually
turnout to be more or less than that. If the farmer dislikes the uncertainty related
to the future prices of wheat, he simply has to find a future buyer on the basis of
Salam who would pay him the expected price per bushel now. If the deal is
reached, the farmer has removed the uncertainty by selling the wheat at the price
of his own expectations. Removal of the future wheat price risk enables the
farmer to project his business forecasts more accurately, particularly, if he had to
pay significant amount of debts.
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The potential of futures contracts in risk management and control is
tremendous. Conventional banks manage risks by utilizing commodity forwards
and futures contracts. In these contracts, unlike Salam payment of the price of
the commodity is postponed to a future date. In the traditional Fiqh postponing
both the price and the object of sale is not allowed. Therefore, the Islamic banks
at the present do not utilize the commodity futures contracts in a large scale.
Nevertheless, by virtue of a number of Fiqh Resolutions, conventions, and new
research, the scope for commodity futures is widening in Islamic financing64. In
the future these contracts may prove to be instrumental in managing the risks of
commodities.
5.3.3.2 Bai‘ al-Tawrīd with Khiyār al-Shar
As mentioned above the objection of Islamic scholars to delaying both
the price and the object of sale is softening. An important reason for this has
been the need and sometimes inevitability of such transactions in the real life.
The classical example given about Bay‘ al Tawrīd as a long-term contract is the
supply of milk by the milkman. At the time of signing the contract, the milk
buyer and the milkman (the two parties) agree on the quantity of milk to be
delivered daily, the duration of the contract, the time of delivery and the price.
The milk is not present at the time of the contract and the price is mostly paid
periodically, normally on monthly basis. Public utilities provide a modern
example for the case. Public utilities are consumed and the bill is paid when it
comes in a future date. In this way, both the price and the service are not present
in the beginning. There are numerous other examples from real life where the
postponement of the two actually enhances efficiency and convenience and
sometimes the postponement becomes in fact inevitable.
The example of the milkman provides an important basis for extending
the postponement of both the price and the object to banking. Any type of
64
The OIC Fiqh Academy in its Resolution # 65/3/7 has resolved that in Isti nā‘ both the
price and its object of sale can be delayed. Isti nā‘ is the most dynamic mode of Islamic
finance. Thus, such delayed payment Isti nā‘ are expected to increase in volume. The
Fiqh Academy has also resolved on the acceptability of ‘arboon. Since, in ‘arboon most
part of the price is delayed as well as the object of sale is also delayed this also falls in the
framework of the definition of a forward sale. Islamic banks are using a special variant of
‘arboon in which the client pays small part of the price up-front and payment of the price
and the object of sale are both delayed. For all Resolutions of the Academy see IRTI-
OICFA (2000). Bay‘ al-tawrīd (continuous supply-purchase relationship with known but
deferred price and object of sale) is a popular contract among the Muslims of our time,
particularly in public procurements and finally, some prominent Islamic banks are already
using currency forwards and futures.
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Islamic banking contract with a predetermined price, quantity and long duration
and in which the price and object are both postponed will have an analogy to the
example. In such contracts, both the two parties are exposed to price risk. The
risk is that immediately after the contract, of a fixed price and a fixed quantity,
the two parties may experience a noticeable change in the market price of the
commodity. If the market price declines the buyer will be at a loss by continuing
with the contract. If market price rises, the seller will lose by continuing with the
contract. Thus, in such contracts of continuous-supply-purchase, a Khiyār al-
Shar (option of condition) for rescinding the contract will make the contract
more just and will reduce the risk for both parties. In Figure 5.4, if the agreed
price is P0, and the two parties are uncertain about the future market prices, they
can mutually determine the upper and lower boundaries for the acceptable
movements in market prices. Beyond these boundaries they can agree to rescind
the contracts65.
Figure 5.4
Khiyār al-Shar with respect to future prices
Upper ceiling of
market price
appreciation
beyond which Future market prices
the supplier can
rescind the
contract
Price of the
Lower ceiling contract
of market price
beyond which
the buyer can Future market prices
rescind the
contract
5.3.3.3 Parallel Contracts
65
For more detailed discussion, see Obaidullah (1998).
148
Price risk can either be due to transitory changes in prices of specific
commodities and non-financial assets or due to a change in the general price
level or inflation. Inflation poses risk to the real values of debts (receivables),
which are generated as a result of Murāba ah transactions. However, as a result
of inflation it is expected that the prices of the real goods and commodities,
which the banks acquire as a result of Salam transactions will appreciate. This
divergent movement of asset values created as a result of Murāba ah and Salam
has the potential to mitigate the price risks underlying these transactions.
Although permanent shifts in assets’ prices cannot be hedged against, however,
the composition of receivable assets on the balance sheet can be systematically
adjusted in such a way that the adverse impact of inflation is reduced as
explained in Figure 5.5 (A).
Suppose that an Islamic bank has sold assets worth $100 on Murāba ah
basis for six months, it can fully hedge against inflation by buying $100 worth
on Salam basis. If for example, 10% of the value of the previous assets is wiped
out by inflation, its Salam-based receivables can become valuable by the same
percentage. Moreover, as for as the Salam is concerned, it can be fully hedged
by the bank by adopting an equivalent parallel Salam contract as a supplier.
Figure 5.5 (B) also explains this possibility.
Figure 5.5 (A):
Parallel Contracts: Implications for Inflation Risk Mitigation
Panel A. Trader as a Seller Panel B. Trader as a Buyer
Price Deferred Sale Object Deferred Purchase
(Receivables: Debts) (Receivables: Real Assets)
(Inflation 10 %)
149
Value of Debts (-10) Value of Real Assets (+10)
150
Figure 5.5 (B)
Managing Receivables as a Hedge Against Inflation
Panel A Panel B
Dollar Value of Price Deferred Sales Dollar Value of Object Deferred
Purchase
$100 $100
Total Receivables: Unadjusted for inflation $ 200
Inflation adjusted Inflation adjusted
Value of receivable value of receivables
$90 $110
Value of total receivables
adjusted for inflation $ 200
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5.3.4 Equity Price Risks and the use of Bay‘ al-‘arboon
Options are another powerful risk management instrument. However, a
Resolution of the OIC Fiqh Academy prohibits the trading in options. Therefore,
the scope for the utilization of options by the Islamic banks, as risk management
tool is limited at the present. Nevertheless, some Islamic funds have successfully
utilized -‘arboon (down payment with an option to rescind the contract by
foregoing the payment as a penalty) to minimize portfolio risks in what are now
popularly known in the Islamic financial markets as the principal protected funds
(PPFs).
The PPF arrangement roughly works in the following manner; 97% of
the total funds raised are invested in low risk (low return) but liquid Murāba ah
transactions. The remaining 3% of the funds are used as a down payment for
‘arboon to purchase common stock in a future date. If the future price of the
stock increases as expected by the fund manager, the ‘arboon is utilized by
liquidating the Murāba ah transactions. Otherwise the ‘arboon lapses incurring
a 3% cost on the funds. This cost is however, covered by the return on the
Murāba ah transactions. Thus, the principal of the fund is fully protected. In this
way, ‘arboon is utilized effectively in protecting investors against undesirable
down side risks of investing in stocks while at the same time keeping an
opportunity for gains from favorable market conditions
5.3.5 Challenges of Managing Foreign Exchange Risk
Foreign exchange risk can be classified into economic risk, transaction
risk and translation risk. Economic risk is the risk of losing relative
competitiveness due to changes in relative exchange rates. For instance, an
appreciation of local currency will increase the relative price of exported goods
directly as well as indirectly. There is no better hedge against such a risk except
for having subsidiaries in countries of significant markets. This is a crucial
matter for non-financial firms, but financial firms at the same time cannot ignore
it either. In fact, the dominant Islamic groups of financing have such subsidiaries
in important markets.
Translation risk occurs only in the accounting sense. If the subsidiary of
a bank is operating in a country, where it may make a 13% profit during a year.
If the currency of these earnings depreciates by 10% during the period against
the home country currency, the earnings translated into the home country
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currency actually increase by 3%. Hence this risk does not affect the value of
assets in place.
Transaction risks originate from the nature of the bank’s deferred
delivery transactions. Typically the implication of transaction risk is similar to
that of transitory changes in commodity prices. The currency in which
receivables are due (or assets in general are held) may depreciate in the future
and the currency in which payables (or liabilities in general) are held may
appreciate, thus posing a risk to the overall value of the firm.
This risk could have adverse and severe consequences for a business.
Therefore, it must be minimized by various techniques. Any remaining risk must
be hedged by using currency futures and forwards. Some of the possible
methods of reducing currency transaction risks are briefly discussed here.
5.3.5.1 Avoid Transaction Risks
On the banking book, the most sensible method to avoid transaction risk
is to avoid undertaking such transactions, which require dealing in unstable
currencies. However, this is not always possible, as by rigidly following this
strategy market share can be lost. Banks have to decide carefully to find an
optimal trade-off between market shares and possible transaction risks.
5.3.5.2 Netting
On-balance sheet netting is another method used to minimize the
exposure of risks to the net amount between the receivables and payables to
counterparty. Netting is more suitable for payments between two subsidiaries of
a company. With non-subsidiary counterparties, the currency position of
receivables and payables can generally be matched so that the mutual exposures
are minimized.
5.3.5.3 Swap of Liabilities
Exchange of liabilities can also minimize exposure to foreign exchange
risk. For instance, a Turkish company needs to import rice from Pakistan, and a
Pakistani company needs to import steel from Turkey. The two parties can
mutually agree to buy the commodities for each other, bypassing the currency
markets. If the dollar amount of the two commodities is the same, this
arrangement can eliminate transaction risk for both parties. If the ratings of the
153
two companies are good in their own home countries as compared to the other
country, this swap will also save them some of the cost of finance.
5.3.5.4 Deposit Swap
Islamic banks have been using the technique of deposit swaps. In this
method, two banks in accordance with their own expected risk exposures agree
to maintain mutual deposits of two currencies at an agreed exchange rate for
agreed period of time. For example, a Saudi bank will open a six months account
for SR 50m in a counterpart Bangladeshi bank. The Bangladeshi bank will open
the TK amount of the SR deposit in the Saudi bank for the same period. The
SR/TK exchange rate will be mutually agreed and will be effective for the
deposit period. After the six months both banks will withdraw their deposits. In
this way the risk exposure for the value of the deposits for the currency involved
are minimized according to the two banks’ own perceptions.
There are at least two Sharī‘ah objections to this contract. The exchange
rate cannot be any rate except the spot rate. In this case the rate is fixed for a
period during which there could be a number of spot rates not only one. The
exchange of deposits is also questionable. These deposits are supposed to be
current accounts, which are treated as Qar. There cannot be mutual Qar.
Further, Qar in two different currencies cannot be exchanged.
5.3.5.5 Currency Forwards and Futures
Forwards and futures are the most effective instruments of hedging
against currency risks. Most Islamic banks who have significant exposures to the
FX risk do use currency forwards and futures for hedging purposes as required
by regulators. However, all Fiqh scholars unanimously agree that such contracts
are not allowed in the Sharī‘ah. Keeping this apparent contradiction in view and
the tremendous difference between the stability of the present and past markets,
Chapra and Khan (2000) make a suggestion to the Fiqh scholars to review their
position and allow the Islamic banks to use these contracts for hedging. Such a
change in position will remove the contradiction between the practices of
Islamic banks and the existing Fiqhī positions on one hand and will empower the
Islamic banks on the other hand. Furthermore, it may be noted that hedging is
not an income earning activity. Since Ribā is a source of income and hedging
does not generate income, there is no question of involvement of Ribā. On the
other hand hedging actually reduces Gharar. It is important to note that this a
personal opinion of the two writers. The consensus among Fiqh scholars is that
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currency futures and forwards are another form of Ribā which have been
prohibited by the Sharī‘ah.
5.3.5.6 Synthetic Forward
As an alternative to the currency forwards and future, Iqbal (2000)
proposes a synthetic currency forward contract. The purpose is to design a
currency forward without using the currency forward contracts. The synthetic
forward can be designed given a number of conditions. These conditions are the
need for hedging against foreign exchange rate risk, the existence of an equal
tenure local Murāba ah investment and foreign Murāba ah investment. The
existence of a known rate of return on the Murāba ah-based investments is
another condition. Finally, that the foreign bank, which invests in dollar-based
Murāba ah, is willing to collaborate with the local bank, which invests in the
local currency-based Murāba ah. The dollar amount of the two investments
must be the same66.
5.3.5.7 Immunization
Once the net exposure is minimized the possibility exists that the
exposure can be hedged. Suppose an Islamic bank has to pay in three months
time $1 million for a contract, which it has signed when the exchange rate is
Rs.60/$. The risk is that after three months, the dollar will appreciate as
compared to the initial exchange rate. The bank can protect against this risk, by
raising three months’ PLS deposit in Rupees for the dollar value of 1m and
buying with this amount $1m at the spot rate. These dollars can then be kept in a
dollar account for three months. After the three months and at the time of
making the payment, the PLS deposit will mature and the bank can share the
earning on the dollar deposit with the rupee deposit holders. Thus, the dollar
exchange rate risk for the three months’ period is fully hedged by the bank.
5. 4 LIQUIDITY RISK
As mentioned earlier, liquidity risk is the variation in a bank's net
income due to the bank's inability to raise capital at a reasonable cost either by
selling its assets in place (asset liquidity problem) or by borrowing through
issuing new financial instruments (funding liquidity problem). All other risks of
a bank culminate into liquidity crunch before bringing a problem bank down.
Operationally, a bank fails when its cash inflows from repayments of credits,
66
For details of the arrangement see, Iqbal (2000).
155
sale of assets in place and mobilization of additional funds fall short of its
mandatory cash outflows, deposit withdrawals, operating expenses, and meeting
its debt obligations.
A recent study commissioned by the Bahrain Monetary Agency (BMA
2001) shows that in general Islamic banks are facing the phenomenon of excess
liquidity. The total assets of the Islamic banks in the sample were 13.6 billion
dollars and 6.3 billion dollars were found to be in liquid assets. For Islamic
financial institutions with a combined asset of 40 billion dollars, the liquid assets
are calculated to be 18.61 billion dollars. The study shows that the peer group
conventional counterparts of the Islamic banks in the sample, in average, keep
46.5% less liquidity as compared to the Islamic institutions.
On the average, conventional banks are expected to maintain the bare
minimum liquidity, which can satisfy regulatory requirements. The liquidity
position of Islamic banks is much in excess of the regulatory requirements. This
means that these liquid funds are either not earning any return at all or earning a
return much lesser than the market rates. Thus the excess liquidity position of
the Islamic banks generates for these banks a serious business risk as it adversely
affects the rates of returns offered by them as compared to their conventional
competitors. Furthermore, in most cases these banks largely rely on current
accounts, which is a more stable source of free liquidity.
However, for a number of reasons, Islamic banks are prone to face
serious liquidity risks.
a. There is a Fiqh restriction on the securitization of the existing assets of
Islamic banks, which are predominantly debt in nature. Thus, the assets
of Islamic banks are not liquid as compared to the assets of conventional
banks.
b. Due to slow development of financial instruments, Islamic banks are
also not able to raise funds quickly from the markets. This problem
becomes more serious due to the fact that there is no inter-Islamic banks
money market.
156
Table 5.4
List of Islamic Financial Instruments
CERTIFICATE BRIEF DESCRIPTION
Declining participation Redeemable Mushārakah certificates were designed by the IFC for providing
certificates funds to the Modaraba companies in Pakistan.
Based on Muārabah principle, the proceeds of these certificates are meant for
Islamic Deposit Certificates
general purpose utilization by the issuing institution.
Installment sale debt certificate is proposed to finance big-ticket purchases by
Installment sale debt making a pool of smaller contributions. The certificate represents the principal
certificates amount invested plus the Murāba ah income. These are issued mostly in
Malaysia as Islamic debt certificates.
Islamic Investment Similar to Islamic deposit certificates, but the proceeds are meant to be utilized
certificates in a specific project.
Like the installment sale debt certificate, this certificate represents the investors’
Isti nā‘ debt certificates principal amount investment in the Isti nā‘ project plus the Murāba ah income
and is proposed for financing infrastructure projects.
Leasing certificate represents ownership of usufructs leased out for a fixed
Leasing certificates rental income. Since usufructs are marketable, this certificate can be bought and
sold.
Muārabah certificate represents ownership in the beneficiary company without
Muārabah certificates
a voting right issued so far by several institutions.
Muqaradah certificate is a hybrid between Muārabah certificate and declining
participation certificates to be issued by the government for the development of
Muqāraa certificates
public utility projects. A muqāraa certificate law was enacted in Jordan during
the early Eighties, but these certificates were never issued.
Mushārakah certificates are common stocks of companies doing Sharī‘ah
compatible business. In Iran the government for financing infrastructure projects
Mushārakah certificates
issues these certificates. In Sudan these are issued as an instrument of monetary
policy.
National participation certificates are proposed by the IMF staff as an
instrument for mobilizing resources for the public sector. These proposed
National participation
instruments are based on the concept of Mushārakah certificates are issued in
certificates
Iran. The certificates are assumed to represent as an ownership title in public
sector assets of a country.
Property income Property income certificate is a Muārabah income note with a secure stream of
certificates income from an ownership in a property without a voting right.
Participation term certificates were issued by the Bankers’ Equity Pakistan in
Participation term
the Eighties. These had some common characteristics of declining Mushārakah
certificates
and Muqarada certificates.
The holder of this certificate shares in the rental income of the asset against
Rent sharing certificates
which the certificate has been issued.
Revenue sharing Revenue sharing certificates were issued in Turkey for re-financing the
certificates privatized infrastructure projects.
The holder of a Salam certificate claims commodities, goods and services in a
Salam certificates
specified future date against the payments the holder has made.
Two-step contracts –
In these contracts the bank pays to the suppliers in installment and creates a
Leasing, Murāba ah,
fixed liability in its balance sheet instead of paying up-front to the suppliers.
Isti nā‘, Salam
Hybrid instruments allow the holder of any of the debt certificates to exchange
Hybrid certificates the certificate for other assets of the issuing entity or in any other entity subject
to the offer prescribed on the hybrid certificate.
157
c. The specific objective of Lender of Last Resort (LLR) facilities is to
provide emergency liquidity facility to banks whenever needed. The
existing LLR facilities are based on interest, therefore, Islamic banks
cannot benefit from these and,
d. Due to the non-existence of a liquidity problem at the present, these
banks do not have formal liquidity management systems in place. Hence
there is a large potential to develop financial instruments (see Table 5.4
for a list of potential instruments) and markets, which can utilize the
excess utility of the Islamic banks for income earning. The project on the
Islamic Capital Markets sponsored by the IDB, BMA and Bank Nagara
Malaysia is expected to formally launch a facility for tapping the
potential.
158
159
VI
CONCLUSIONS
The previous sections of this paper covered a number of important areas
concerning risk management issues in the Islamic financial industry. The
introductory section covered among others, the systemic importance of the
Islamic financial industry. An overview of the various concepts of risks and the
industry standards of risk management techniques were discussed in section two
along with the discussion of some of the unique risks of the Islamic modes of
finance. The perception of the Islamic banks about various risks were surveyed
through a questionnaire and analyzed in section three. In section four the
emerging regulatory concerns with risk management have been discussed and
some conclusions were drawn for the Islamic banking supervision. The Sharī‘ah
related challenges concerning risk management were analyzed in section five. In
the present section we summarize the main conclusions of the paper.
6.1 The Environment
Islamic financial industry has come a long way during its short history.
The future of these institutions, however, will depend on how they cope with the
rapidly changing financial world. With globalization and informational
technology revolution, activities of different financial institutions have expanded
beyond national jurisdictions. As a result, the financial sector in particular has
become more dynamic, competitive, and complex. Moreover, there is a rapidly
growing trend of cross-segment mergers, acquisitions and financial
consolidation, which blurs the unique risks of the various segments of the
financial industry. As a result, the general premise of universal banking is
becoming more dominant. Furthermore, there has been an unprecedented
development in computing, mathematical finance and innovation of risk
management techniques. All these developments are expected to magnify the
challenges that Islamic financial institutions face particularly as more well-
established conventional institutions have started to provide Islamic financial
products. Islamic financial institutions need to equip themselves with the up-to-
date management skills and operational systems to cope with this environment.
One major factor that will determine the survival and growth of the industry is
how well these institutions manage the risks generated in providing Islamic
financial services.
160
6.2 Risks Faced by the Islamic Financial Institutions
The risks faced by the Islamic financial institutions can be classified into
two categories – risks which they have in common with traditional banks as
financial intermediaries and risks which are unique due to their compliance with
the Sharī‘ah. Majority of the risks faced by conventional financial institutions
such as credit risk, market risk, liquidity risk, operational risk, etc., are also
faced by the Islamic financial institutions. However, the magnitudes of some of
these risks are different for Islamic banks due to their compliance with the
Sharī‘ah. In addition to these risks commonly faced by traditional institutions,
the Islamic institutions face other unique risks. These unique risks stem from the
different characteristics of the assets and the liabilities. Other than the risks that
conventional banks face, the profit-sharing feature of Islamic banking introduces
some additional risks. In particular, paying the investment deposits a share of the
bank’s profits introduces withdrawal risk, fiduciary risk, and displaced
commercial risks. In addition, the various Islamic modes of finance have their
own unique risk characteristics. Thus, the nature of some risks that Islamic
financial institutions face is different from their conventional counterparts.
6.3 Risks Management Techniques
Consequent on the common or unique nature of risks faced by the
Islamic financial institutions, the techniques of risk identification and
management available to these institutions are of two types. The standard
traditional techniques that are not in conflict with the Islamic principles of
finance are equally applicable to the Islamic financial institutions. Some of these
are, for example, GAP analysis and maturity matching, internal rating systems,
risk reports, and RAROC. In addition there is a need for adapting the traditional
tools or developing new techniques that must be consistent with the Sharī‘ah
requirements. Similarly, the processes, internal control systems, internal and
external audits as used by the conventional institutions are equally applicable to
Islamic financial institutions. There is, however, a need to develop these
procedures and processes further by the Islamic financial institutions to tackle
the additional unique risks of the industry.
6.4 Risk Perception and Management in Islamic Banks
Results from a survey of 17 Islamic institutions from 10 different
countries reveals the bankers’ perspectives on different risks and issues related
to the risk management process in Islamic financial institutions. The results
161
confirm that Islamic financial institutions face some risks arising from profit-
sharing investment deposits that are different from those faced by conventional
financial institutions. The bankers consider these unique risks more serious than
the conventional risks faced by financial institutions. The Islamic banks feel that
the returns given on investment deposits should be similar to that given by other
institutions. They strongly believe that the depositors will hold the bank
responsible for a lower rate of return and may cause withdrawal of funds by the
depositors. Furthermore, the survey shows that the Islamic bankers judge profit
sharing modes of financing (diminishing Mushārakah, Mushārakah and
Muārabah) and product-deferred sale (Salam and Isti nā‘) more riskier than
Murāba ah and Ijārah.
We found the overall risk management processes in Islamic financial
institutions to be satisfactory. We apprehend, however, that this may be because
the banks that have relatively better risk management systems have responded to
the questionnaires. The results from risk management process shows that while
Islamic banks have established a relatively good risk management environment,
the measuring, mitigating and monitoring processes and internal controls needs
to be further upgraded.
The survey also identifies the problems that Islamic financial institutions
face in managing risks. These include lack of instruments (like short-term
financial assets and derivatives) and money markets. At the regulatory level, the
financial institutions apprehend that the legal system and regulatory framework
is not supportive to them. The results indicate that the growth of Islamic
financial industry will to a large extent depend on how bankers, regulators, and S
Sharī‘ah scholars understand the inherent risks arising in these institutions and
take appropriate policies to cater to these needs. This calls for more research in
these areas to develop risk management instruments and procedures that are
compatible with Sharī‘ah.
6.5 Regulatory Concerns with Risks Management
The primary concern of regulatory and supervisory oversight standards
is to ensure a) systemic stability, b) protect the interest of depositors and c)
enhance the public’s confidence on the financial intermediation system. The
Islamic banks could not be an exception to these public policy considerations.
Due to the new risks introduced by the Islamic banks, it is expected that
162
regulatory and supervisory concerns will increase with the expansion of the
Islamic products.
6.6 Instruments of Risk-based Regulation
The instruments used for the regulation and supervision of financial
institutions can broadly be classified into three categories:
a. Ensuring the maintenance of a minimum level of risk-based capital.
b. Putting in place an effective system of risk-based supervision, and
c. Making certain the timely disclosure of correct information about risk
management systems and processes.
These three instruments constitute the three pillars of the New Basel
Accord, which primarily aims at developing risk management culture in the
financial institutions by providing capital incentives for good systems and
processes. By issuing a consultative document and by inviting comments on the
document all financial institutions are provided an opportunity to participate in
the process of setting these standards. The Islamic banks must participate in the
process so that the standards can cater for their special needs.
6.7 Risk-based Regulation and Supervision of Islamic Banks
Adopting international standards for the regulation and supervision of
Islamic banks will increase the acceptance of these institutions in the
international markets and hence will prove to be instrumental in making the
institutions more competitive. Some standards could be applied without any
difficulty. However, there is a difficulty in applying in particular the risk
weighting standards to Islamic banks due to the different nature of the Islamic
modes of finance. This limitation is overcome by the internal ratings-based
approach of the New Basel Accord. It is early for the Islamic banks to qualify
for using internal ratings for regulatory capital allocation. However, by opting
for this approach in the future, the Islamic banks will not only be able to comply
with the international standards but will also be developing risk management
systems suitable for the Islamic modes of finance. Moreover, the nature of the
Islamic banks’ current and investment accounts creates a unique systemic risk,
namely, the transmission of risks of one account to the other. In the Islamic
banking windows of traditional banks, this systemic risk could be in the form of
risk transmission between permissible and impermissible sources of income.
163
These two systemic risks can be prevented by requiring separate capital for the
current and investment accounts of an Islamic bank as well as for traditional and
Islamic banking activities of a conventional bank.
6.8 Risk Management: Sharī‘ah -based Challenges
Risk management is an ignored area of research in Islamic finance. The
present paper is one of the few written in this area so far. Therefore, a number
of challenges are still being confronted in this area. These challenges stem from
different sources. First, a number of risk management techniques are not
available to Islamic financial institutions due to requirements for the Sharī‘ah
compliance. In particular, these are credit derivatives, swaps, derivatives for
market risk management, commercial guarantees, money market instruments,
commercial insurance, etc. Due to lack of research efficient alternatives to these
techniques have not been explored. Second, there are a number of Sharī‘ah
positions which effect the risk management processes directly. Some of these are
lack of effective means to deal with willful default, prohibition of sale of debts
and prohibition of currency forwards and futures. Third, lack of standardization
of Islamic financial contracts is also an important source of the challenges in this
regard.
A number of ideas have been discussed and analyzed in the paper which
can be considered to constitute an agenda for further research and deliberations
by researchers, practitioners and Sharī‘ah scholars. For their practical relevance
the ideas discussed in the paper must attain the consensus of the Sharī‘ah
scholars. There is a great need to enhance the process of consensus formation on
a priority basis so that the Islamic financial institutions can develop Sharī‘ah
compliant risks management systems as early as possible.
164
165
VII
POLICY IMPLICATIONS
Based on what has been reported in this study, a number of policy
implications can be suggested for the development of risk management culture
in the Islamic financial institutions. Some of these are mentioned here.
7.1 Management Responsibility
A risk management culture in Islamic banks can be introduced by
involving all the departments/sections in the risk management process discussed.
In particular, the Board of Directors can create the risk management
environment by clearly identifying the risk objectives and strategies. The
management needs to implement these policies efficiently by establishing
systems that can identify, measure, monitor, and manage various risk exposures.
To ensure the effectiveness of the risk management process, Islamic banks also
need to establish a proficient internal control system.
7.2 Risk Reports
Risk reporting is extremely important for the development of an
efficient risk management system. We consider that the risk management
systems in Islamic banks can be substantially improved by allocating resources
to preparing the following periodic risk reports. The sketches of some of the
reports are given in Appendix-2.
a. Capital at Risk Report
b. Credit Risk Report
c. Aggregate Market Risk Report
d. Interest Rate Risk Report
e. Liquidity Risk Report
f. Foreign Exchange Risk Report
g. Commodities and Equities Position Risk Report
h. Operational Risk Report
i. Country Risk Report
166
7.3 Internal Ratings
At initial stages of its introduction an internal rating system may be seen
as a risk-based inventory of individual assets of a bank. Such systems have
proved highly effective in filling the gaps in risk management systems, hence
enhancing the external rating of the concerned institutions. This contributes to
cutting the cost of funds. Internal rating systems are also very relevant for the
Islamic modes of finance. Most Islamic banks already use some form of internal
ratings. However, these systems need to be strengthened in all Islamic banks.
7.4 Risk Disclosures
Disclosures about risk management systems are extremely important for
strengthening the systems. Introducing a number of risk-based systems as given
here can enhance risk disclosures.
a. Risk-based Management Information System
b. Risk-based Internal Audit Systems
c. Risk-based Accounting Systems and
d. Risk-based Asset Inventory System
7.5 Supporting Institutions and Facilities
The risks existing in the Islamic financial industry can be reduced to a
great extent by establishing a number of Sharī‘ah compatible supporting
institutions and facilities such as:
a. Lender of last resort facility,
b. Deposit protection system,
c. Liquidity management system,
d. Legal reforms to facilitate Islamic banking and dispute settlement etc.,
e. Uniform Sharī‘ah standards,
f. Adoption of AAOIFI standards, and
g. Establishing a supervisory board for the industry.
167
7.6 Participation in the Process of Developing the International Standards
The Islamic financial industry being a part of the global financial
markets is effected by the international standards. In fact compliance with these
standards wherever relevant and feasible is expected to enhance the endorsement
of the Islamic financial institutions by the international standard setters. This in
turn is expected to enhance the growth and stability of the industry. It is thus
imperative for the Islamic financial institutions to follow-up the process of
standard setting and to respond to the consultative documents distributed in this
regard by the standard setters on a regular basis.
7.7 Research and Training
Risk management systems strengthen financial institutions. Therefore,
risk management needs to be assigned as a priority area of research and training
programs. Given the nascent nature of the Islamic financial industry there is a
need to develop Sharī‘ah compatible risk management techniques and organize
training programs to disseminate these among the Islamic banks. In the present
research we have made an attempt to cover a number of issues. These and other
issues can constitute an agenda for future research and training in the area. The
training programs need to be designed for Sharī‘ah supervisors, regulators and
managers of the Islamic financial institutions.
168
APPENDIX 1: LIST OF FINANCIAL
INSTITUTIONS INCLUDED IN THE STUDY
Name Country Type
ABC Islamic Bank Bahrain Offshore
Abu Dhabi Islamic Bank U.A.E. Commercial, Investment,
Retail, and Foreign
exchange dealers
Al-Ameen Islamic Financial & India Non-Banking Finance
Investment Corporation Company
AlBaraka Bank Bangladesh Limited Bangladesh Commercial
AlBaraka Islamic Bank Bahrain Commercial, Offshore, and
Investment
Al-Meezan Investment Bank Pakistan Investment
Limited
Badr Forte Bank Russia Commercial
Bahrain Islamic Bank Bahrain Commercial
Bank Islamic Malaysia Berhad Malaysia Commercial
Citi Islamic Investment Bank Bahrain Investment
First Islamic Investment Bank Bahrain Investment
Investors Bank Bahrain Investment
Islami Bank Bangladesh Limited Bangladesh Commercial
Islamic Development Bank Saudi Development
Arabia
Kuwait Turkish Evkaf Finans House Turkey Commercial, Investment,
and Foreign Exchange
dealers
Shamil Bank of Bahrain E.C. Bahrain Commercial and Offshore
Tadamon Islamic Bank Sudan Commercial, Investment,
and Foreign exchange
dealers
Note: We could not include two banks in the study for reasons mentioned here. Faisal
Islamic Bank Egypt - because of receiving the questionnaire at a very late stage of
the study. Al-Barakah Turkish Finance House - because of data gaps.
169
170
APPENDIX 2:
SAMPLES OF RISK REPORTS
We outline some sample risk reports used by financial institutions here.67 While
the actual reports can be complicated, the examples given here represent the basic format
of these reports.
1. Bank Level Credit Quality
In this report, the bank ranks all its receivables (different types of consumer and
commercial loans, leases, etc.) and contingent claims (like unused commitments, stand-
by letters of credit, commercial letters of credit, swaps, etc.) according to an internal risk
rating criterion. The averages of these risk ratings give an indication of the quality of
loans and overall portfolio. Note that internal risk ratings for various institutions are
based on different scales. The example below uses a five-point scale.
A Sample of Bank Level Credit Quality Report
Risk Rating
Receivables/Commitments 1 2 3 4 5 Total
Receivables
-Consumer Loans
-Commercial Loans
-Leases
.
.
Contingent Exposures
- Unused Commitments
- Standby Letters of Credit
- Swaps
.
.
Total
2. Credit Risk Exposure by Industry Sectors
In this report, all assets are categorized according to different industries and the
exposure of these industries are examined by taking some external rating agency’s
ranking of these industries (like Moody’s). This report not only gives an idea of the
concentration of the investments and commitments in different industries, but also
identifies the risks involved in these categories.
A Sample of Credit Exposure by Industry Groups Report
Industry Group Outstanding Commitments
% of Term to Risk % of Term to Risk
Total Maturity Rating Total Maturity Rating
Automobile
Banking
Beverage and
67
The basic formats of the risk reports are adapted from Santomero (1997).
171
Food
3. Net Interest Margin Simulation
In this report the effect of changes in the interest rate on the net income is
summarized. The effect of interest changes on net interest income (i.e., interest income
on assets-interest payable on liabilities) is estimated for different scenarios. A limit that
represents the maximum acceptable change in net income is also indicated.
A Sample of Interest Rate Simulation Report
Rate Scenario
Unchanged +100 +200 Limit -200 Limit
bps bps bps
12 Month Net Interest
Income
Total Earning Assets
-Change in Net Interest
Income
-%Net Interest Income
Portfolio Equity
Market Value
Change in Market Value
% Shareholder’s Equity
4. GAP Report
The GAP report estimates interest rate risk by distributing assets and liabilities
in time bands according to their maturity for fixed rate assets and first possible repricing
time for flexible rate assets. For each time bucket the GAP is calculated as the difference
between assets and liabilities. If the financial institution uses interest rate swaps, these
are factored in to find the Adjusted GAP.
A Sample of GAP Report
0-3 >3-6 >6-12 >1-5 Non- Total
Months Months Months Years Market
Assets
-Commercial
Loans
-Consumer Loans
-Lease financing
.
.
Total Assets
Liabilities
-Interest-bearing
Checking
Deposits
-Savings Deposits
-Savings
Certificates
.
.
Total Liabilities
GAP before
Interest rate
172
Derivatives
Interest-rate
Swaps
Adjusted GAP
5. Duration Analysis
Duration analysis compares the market value of assets and liabilities resulting
from changes in the interest rate. The formula for calculating duration is given in
Chapter 2 (Section 6). It is the time-weighted measure of cash flows representing the
average time needed to recover the invested funds. After the duration of assets and
liabilities are estimated the Duration-GAP can be calculated.
Sample of Duration Analysis Report
On-Balance Sheet
Balance Rate Effective
Duration Years
Assets
Variable Rate Assets
.
Fixed Rate Assets
.
Total Assets
Liabilities
Variable Rate Liabilities
.
Fixed Rate Liabilities
.
.
Total Liabilities
6. Operational Risk Report
Operational risk may arise from different sources and is difficult to measure.
The risk management unit of a financial institution can, however, use judgements
regarding different kinds of operational risks based on all the available information. The
list of sources used to gather information to measure operational risk is given in Table
below. From this information, the risk management unit can classify the different
sources of operational risks as low, medium, and high. A sample of a typical operational
and strategic risk report is shown below.68
Sample of Operating Risk Report
Category Risk Profilea
1. People Risk
- Incompetence
- Fraud
2. Process Risk
1st. Model Risk
-Model/methodology error
2nd. Transaction Error
68
These reports are adapted from Crouhy et.al. (2001, Chapter 13).
173
- Execution Error
- Booking Error
- Settlement Error
- Documentation/Contract Risk
3rd. Operational Control Risk
- Exceeding Limits
- Security Risk
- Volume Risk
3. Technology Risk
- System Failure
- Programming Error
- Telecommunication Failure
Total Operational Risk
Strategic Risk
- Political Risk
- Taxation Risk
- Regulatory Risk
Total Strategic Risk
a- Risk Profile can be Low, Medium, and High.
Sources of Information used as input to Measure Operational Risk
Assessing Likelihood of Occurrence Assessing Severity
- Audit Reports - Management interviews
- Regulatory Reports - Loss history
- Management Reports
- Business plans
- Budget plans
- Operational plans
- Business Recovery plan
- Expert Opinion
174
APPENDIX – 3
QUESTIONNAIRE
ISLAMIC DEVELOPMENT BANK
ISLAMIC RESEARCH & TRAINING INSTITUTE
PROJECT ON “A SURVEY OF RISK MANAGEMENT ISSUES IN ISLAMIC
FINANCIAL INDUSTRY”
Questionnaire for Islamic Banking and Financial Institutions
I. GENERAL
1. Name and location of the Bank:__________________________
2. Year of Establishment: _________________________________
3. Respondent’s Name: __________________
Position:_____________
4. Number of Branches:
5. Number of Employees__________
6. Legal Status of the Bank:
Public limited Company ________Private limited company ___________
Partnership ____________ Other (please specify) __________
7. How many shareholders do you have at present? ____________
8. What is the largest percentage share of a single share-holder? ____________
9. Name of the Chief Executive: ________________________________
10. Names of the Sharī‘ah Board:
11. Nature of Activities: (Please mark the appropriate boxes with U)
Commercial Banking F Investment Banking
F
Offshore Banking F Foreign Exchange dealers F
Investment (including funds) F Stock Brokers F
Insurance F Others (please specify) F
II. FINANCIAL INFORMATION
1. Most Recent Basic Balance Sheet Figures: Year ______________
Local Currency US Dollars
Total Assets
Total Liabilities
Equity (Capital)
2. Term Structure of the Assets (% Distribution)
Less that 6 Months % 6-12 months %
12-36 months % More than 36 Months %
175
3. Profit-Sharing ratio between the bank and the depositors
Depositors Share on:
Investment Accounts of Savings Accounts of
a) Less than 6 months ________ _______
b) 6-12 months ________ _______
c) 12-24 months ________ _______
d) More than 24 months ________ _______
4. Geographical Distribution of Investment
Foreign
Year Domestic Total US, Japan Middle Asia & Other
Foreign Canada -East Africa
&
Europe
1996
1997
1998
1999
2000
5. Details of Default
Year Total No. of Total Value No. of Cost of Average
Default Cases of Default litigation cases Litigation time lost in
litigation
1996
1997
1998
1999
2000
6. Comparative Rates of Return (in percentage) for Depositors and Equity
Holders
1996 1997 1998 1999 2000
Your Bank’s Equity Holders (dividend
share %)
Deposits of your bank (average)
Deposits of competing Islamic Banks
(average)
Deposits of Competing Commercial
Banks (average)
NOTE: Information on questions 6,7, and 8 can be skipped if you can provide us with the Annual
Reports of the latest two years (1999 and 2000).
176
7. Structure of the Assets (US$ Millions)
Year Total Reserves Debts Deposits Securities Physical Others
& Cash due with other Assets
in Vaults banks
1996
1997
1998
1999
2000
8. Capital and Structure of the Liabilities (US$ Millions)
Year Total Total Total Investment Saving Current Deposits
Capital Liabilities Deposits Accounts Account Accounts of Other
Banks
1996
1997
1998
1999
2000
8. Modes of Finance:
Year Total Murāba ah Mushā Muāra- Leasing Isti nā‘/S Other
Financial /Install. Sale -rakah bah alam s
Operations
1996
1997
1998
1999
2000
III. ISSUES IN RISK MANANGEMENT: A SURVEY
1. Severity of Various Types of Risks in Different Financial Instruments
(Can you please rank the seriousness of the following overall and instrument
specific risks in the tables below. Please mark the appropriate boxes with U)
Credit Risk Not Critically
Serious Serious
(The risk that counterparty will 1 2 3 4 5 N. A.
fail to meet its obligations timely
and fully in accordance with
agreed terms)
1. Overall Risk
2. Murāba ah
3. Muārabah
4. Mushārakah
5. Ijārah
6. Isti nā‘
7. Salam
177
8. Diminishing Mushārakah
Markup (Benchmark) Rate Risk Not Critically
Serious Serious
(The risk arising from 1 2 3 4 5 N. A.
changes in the level of
market interest rate or
benchmark rate)
1. Overall Risk
2. Murāba ah
3. Muārabah
4. Mushārakah
5. Ijārah
6. Isti nā‘
7. Salam
8. Diminishing Mushārakah
Liquidity Risk Not Critically
Serious Serious
(The risk of insufficient liquidity in 1 2 3 4 5 N.A.
meeting normal operating
requirements and taking growth
opportunities)
1. Overall Risk
2. Murāba ah /Bai-muajjal
3. Muārabah
4. Mushārakah
5. Ijārah
6. Isti nā‘
7. Salam
8. Diminishing Mushārakah
Market Risk Not Critically
Serious Serious
(Risk incurred on instruments 1 2 3 4 5 N. A.
traded in well-traded markets,
e.g., commodities and equities)
1. Overall Risk
2. Murāba ah
3. Muārabah
4. Mushārakah
5. Ijārah
6. Isti nā‘
7. Salam
8. Diminishing Mushārakah
178
Operational Risk Not Critically
Serious Serious
(The risk of losses from 1 2 3 4 5 N.A.
inadequate or failed internal
processes, people, or systems)
1. Overall Risk
2. Murāba ah
3. Muārabah
4. Mushārakah
5. Ijārah
6. Isti nā‘
7. Salam
8. Diminishing Mushārakah
Please list below any other risks that you think affects your institution:
Not Serious Critically
Serious
Other Risks 1 2 3 4 5 N. A.
1.
2.
3.
4.
5.
A Survey of Issues related to Islamic Banking
(Please mark the appropriate boxes with U)
Not Serious Critically
Serious
How would you rate the following 1 2 3 4 5 N. A.
issues according to their seriousness
1.A low rate of return on deposits will
lead to withdrawal of funds?
2.Depositors would hold the bank
responsible for a lower rate of return
on deposits?
3.The rate of return on deposits has to be
similar to that offered by other banks.
4.Lack of short-term Islamic financial
assets that can be sold in secondary
markets
5.Lack of Islamic money markets to
borrow funds in case of need.
6.Inability to re-price fixed return assets
(like Murāba ah) when the benchmark
rate changes.
7.Inability to use derivatives for hedging.
8.Lack of legal system to deal with
defaulters.
9.Lack of regulatory framework for
Islamic Banks.
0.Lack of understanding of risks
involved in Islamic modes of
financing.
179
3. Please Rank the top ten (10) risks faced by your organization in order of severity
1. _______________________________ 6. ______________________________
2. _______________________________ 7. __________________________
2. ___________________________ 8. ______________________
3. ____________________________ 9. _______________________
4. ____________________________ 10. ________________________
ISSUES IN RISK MANAGEMENT: GENERAL
Please mark the appropriate boxes with U.
YES NO
1. Do you have a formal system of Risk Management
in place in your organization?
2. Is there a section/committee responsible for
identifying, monitoring, and controlling various risks?
3. Does the bank have internal guidelines/rules and concrete
procedures with respect to the risk management system?
4. Does the bank have in place an internal control
system capable of swiftly dealing with newly
recognized risks arising from changes in environment,
etc.?
5. Does the bank have in place a regular reporting
system regarding risk management for senior officers
and management?
Is the Internal Auditor responsible to review and
rify the risk management systems, guidelines, and risk
orts?
7. Does the bank have countermeasures (contingency
plans) against disasters and accidents?
8. Does your organization consider that the risks of
investment depositors and current accounts shall not
mix?
9. Is your bank of the view that the Basel Committee
standards should be equally applicable to Islamic
banks?
10. Is your organization of the view that
supervisors/regulators are able to assess the true risks
inherent in Islamic banks?
11. Positions and profit/losses are assessed:
Every Business Day F Weekly F Monthly F
12. Would you prefer repricing of leased assets?
Periodically (e.g., monthly) F Continuously (benchmark rate + markup) F
13. Do you think that the capital requirements for Islamic banks as compared to
conventional banks should be
More F Same F Less F
180
ISSUES IN RISK MANANGEMENT: MEASUREMENT AND MITIGATION
Please mark the appropriate boxes with U.
YES NO
1. Is there a computerized support system for estimating the
variability of earnings and risk management?
2. Is there a clear policy promoting asset quality?
3. Does the bank have in place a support system for assessing
borrowers’ credit standing quantitatively?
4. Has the bank adopted and utilized guidelines for a loan approval
system?
5. Are credit limits for individual counterparty set and are these
strictly monitored?
6. Are mark-up rates on loans set taking account of the loan
grading?
7. Does the bank have in place a system for managing problem
loans?
8. Does the bank regularly (e.g. weekly) compile a maturity ladder
chart according to settlement date and monitor cash position
gaps?
9. Does the bank regularly conduct simulation analysis and
measure bench-mark (interest) rate risk sensitivity?
10. Does the bank have backups of software and data files?
11. Does the bank use securitization to raise funds for specific
investments/projects?
12. When a new risk management product or scheme is introduced,
does the bank get clearance from the Sharī‘ah Board?
13. Is your bank actively engaged in research to develop Islamic
compatible Risk Management instruments and techniques?
14. Is there a separation of duties between those who generate risks
and those who manage and control risks?
15. Do you have a reserve that is used to increase the profit share
(rate of return) of depositors in low-performing periods.
16. Does the bank produce the following reports at regular intervals?
YES NO
One) Capital at Risk Report
Two) Credit Risk Report
Three) Aggregate Market Risk Report
Four) Interest Rate Risk Report
Five) Liquidity Risk Report
Six) Foreign Exchange Risk Report
Seven) Commodities & Equities Position Risk Report
Eight) Operational Risk Report
Nine) Country Risk Report
Ten) Other Risk Reports (Please Specify)
17. Do you use any of the following procedures/methods to analyze risks?
181
YES NO
One) Credit Ratings of prospective investors
Two) Gap Analysis
Three) Duration Analysis
Four) Maturity Matching Analysis
Five) Earnings at Risk
Six) Value at Risk
Seven) Simulation techniques
Eight) Estimates of Worst Case scenarios
Nine) Risk Adjusted Rate of Return on Capital
(RAROC)
Ten) Internal Rating System
Eleven) Other (Please Specify)
YES NO
18. Does the bank have a policy of diversifying investments across:
(a) Different countries?
(b) Different sectors (like manufacturing, trading etc.)
(c) Different Industries (like airlines, retail,
etc.)
19. Do the accounting standards used by the bank comply with
a) International standards?
b) AAOIFI standards?
c) Other (please specify)
___________________________________________
Regularly Occasionally Never
20. Does the bank periodically
reappraise collateral (asset)?
21. Does the bank confirm a guarantor’s
intention to guarantee loans with a
signed document?
22. If loans are international, does the
bank regularly review country
ratings?
23. To keep the rate of return in line
with other banks, do you transfer
profit from shareholders to
depositors?
24. Does the bank monitor the
borrower’s business performance
after loan extension?
182
25. Does the bank engage in the spot market and any of the following derivatives for
hedging (risk management) purposes?(Please mark the appropriate boxes with U)
Spot Forwards Futures Options Swaps None
Currency
Commodity
Equity
Interest Rate
26. Does the bank engage in the spot market and any of the following derivatives for
income generation? (Please mark the appropriate boxes with U)
Spot Forwards Futures Options Swaps None
Currency
Commodity
Equity
Interest Rate
27. We will appreciate if you could share with us any Islamic compatible Risk
Management instruments and techniques that your institution uses.
183
184
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ABOUT THE AUTHORS
TARIQULLAH KHAN HABIB AHMED
Born in Chitral, Pakistan (1954), is a Born in Chittagong, Bangladesh (1959) is an
member of IRTI’s research staff since Economist at the Islamic Research and
Muharram 1404H (October 1983). Before Training Institute (IRTI) of the Islamic
joining IRTI, he was in the faculty of the Development Bank. He has an M.A.
Economics Department, Gomal (Economics) from University of Chittagong,
University, Pakistan (1976-81), and Bangladesh, Cand. Oecon. (M.Econ.) from
International Institute of Islamic University of Oslo, Norway, and Ph.D. from
Economics, International Islamic University of Connecticut, USAUnited States of America. Before
University, Pakistan (1981-83), teaching joining IRTI in February 1999, he taught at
in particular, monetary, development and the University of Connecticut, USAUnited States of America, Eastern
international economics. He has an M.A. Connecticut State University, USAUnited States of America, National
(Economics) degree from the University University of Singapore, and University of
of Karachi, Pakistan, and a Ph.D. degree Bahrain. He taught various courses on
from the Loughborough University, Economics including Business Cycles and
United Kingdom. At IRTI, his research Forecasting, Economic Development,
interest has been in the area of theoretical International Finance, Macroeconomics,
developments in Islamic finance and its Money and Banking, and Quantitative
practical challenges in an international, Economics. He has published articles in
mixed and competitive market and international refereed journals such as
regulatory environments. In this area, Applied Economics, Applied Economics
some of his recent research works Letters, Contemporary Economic Policy,
published by IRTI include: “Demand for Economics Letters, Journal of Economics
and Supply of Mark-up and PLS Funds in and Business, Journal of International Trade
Islamic Banks” (1995), Performance and and Economic Development, and Savings and
Practices of Modaraba Companies With Development. His current research interests
Special Reference to Pakistan (1996), are Islamic Economics and Finance. Couple
Interest-free Alternatives for External of his recent publications in Islamic
Resource Mobilization with Special Economics and Finance include Exchange
Reference to Pakistan (1997), Regulation Rate Stability: Theory and Policies from an
and Supervision of Islamic Banks (2000) Islamic Perspective and “Incentive
with M. Umer Chapra and “Islamic Quasi Compatible Profit-Sharing Contracts: A
Equity (Debt) Instruments” (2000). Theoretical Treatment”.
E-mail: [email protected] E-mail: [email protected]
ISLAMIC DEVELOPMENT BANK
ISLAMIC RESEARCH AND TRAINING INSTITUTE
Postal Address: P.O. Box 9201, Jeddah 21413
Kingdom of Saudi Arabia
Cable Address: BANKISLAMI-Jeddah Telephone: 6361400
Telex: 601137/601945 Facsimile: 6378927 / 6366871
E. Mail: [email protected] Home Page: http://www.irti.org/
Legal Deposit no.2113/22
ISBN: 9960-32-109-6
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