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Title[ Part 3: The Second Pillar - Supervisory Review Process

Section[ Principle 3




Principle  3:  Supervisors  should  expect   banks  to   operate  above  the   minimum regulatory capital ratios and should have the ability to require banks to hold capital in excess of the minimum.


757.     Pillar 1 capital requirements will include a buffer for uncertainties surrounding the Pillar 1 regime that affect the banking population as a whole. Bank-specific uncertainties will be treated under Pillar 2. It is anticipated that such buffers under Pillar 1 will be set to provide reasonable assurance that a bank with good internal systems and controls, a well-diversified risk profile and a business profile well covered by the Pillar 1 regime, and which operates with capital equal to Pillar 1 requirements, will meet the minimum  goals for soundness embodied in Pillar  1.  However, supervisors  will need  to consider whether the  particular features of the markets for which they are responsible are adequately covered. Supervisors will typically require (or encourage) banks  to operate with a buffer, over and above the Pillar 1 standard. Banks should maintain this buffer for a combination of the following:


(a)        Pillar  1  minimums  are  anticipated  to  be  set  to  achieve  a  level  of  bank creditworthiness in markets that is below the  level of creditworthiness sought by many banks for their own reasons. For example, most international banks appear to prefer to be highly rated by internationally recognised rating agencies. Thus, banks are likely to choose to operate above Pillar 1 minimums for competitive reasons.


(b)        In the normal course of business, the type and volume of activities will change, as will the different risk exposures, causing fluctuations in the overall capital ratio.


(c)        It may be costly for banks to raise additional capital, especially if this needs to be done quickly or at a time when market conditions are unfavourable.


(d)        For banks to fall below minimum regulatory capital requirements is a serious matter. It may place banks in breach of the relevant law and/or prompt non-discretionary corrective action on the part of supervisors.


(e)        There may  be risks, either specific to individual banks, or more generally to an economy at large, that are not taken into account in Pillar 1.


758.     There are several means available to supervisors for ensuring that individual banks are operating with adequate levels of capital. Among other methods, the supervisor may set trigger  and  target  capital  ratios  or  define  categories  above  minimum  ratios  (e.g.  well capitalised and adequately capitalised) for identifying the capitalisation level of the bank.


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