Saturday, June 28, 2014

Basel IV and SAP Bank Analyzer.

Dear.
No, the title is not a mistake.

If you look at the dates of publication of the three first international solvency agreements, you will see that Basel I was published on 1988 and enforced by law on 1992. Basel II agreement was published on 2004 and Basel III on 2011.
Following that progression, we should have a new international solvency agreement for banks very soon.

But beyond that, there're a number of signals that make me think that Basel 4 is closer than expected.

Several countries, including the US and the Eurozone are implementing higher capital requirements for banks than Basel 3 requirements.

There’s a growing feeling amongst regulators against giving bank’s risk executives liberty for implementing Internal Rating methods for calculating the bank’s Risk Weighted Assets, and consequently the regulatory capital, advocating for more simple, easier to audit models.

A new simple, leverage ratio, it is been implemented for compensating the difficulties on auditing the bank’s internal models.

In general, the tendency is increasing the capital requirements of banks and disclosure capabilities of their risk management information systems. This is just a consequence of the systemic crisis; remember that natural resources scarcity and global debt are limiting global economic growth.

Limited growth means scarce capital; in a fractional reserve banking system (like today’s), lack of capital produces financial instability. As a consequence regulators increase the bank’s capital requirements for recognizing the critical value of this growth generating resource.

I understand that some of you don’t share my opinion; for those of you who think that the new regulation is just a temporary fashion, let me remind you that some authorized voices, like Eugene Fama, 2013 Nobel Prize in Economics, is advocating for capital requirements for banks which should be around 40 or 50% of the bank’s assets; 4 times what currently Basel 3 agreement requires.

http://baselinescenario.com/2010/06/02/eugene-fama-too-big-to-fail-perverts-activities-and-incentives/

This scenario, which represents a threat for the old banking model, is a great opportunity for those who understand the driver of the new model.

If efficient capital management is the priority in the new model, capital optimization must be at the center of the bank’s strategic decisions.

Capital optimization requires first, an integrated vision of all capital consumption activities of a bank, offering an accurate measure of the capital consumed in each of them. In a second step it requires optimizing the capital consumed in every activity, and prioritizing those activities which offer a better return weighted by consumed capital.

Capital consumption is embedded in every banking activity; from maintaining dynamically the free-line of a revolving loan, to measuring accurately the probability of default of a counterpart, and taking pre-emptive actions before the default event happens.

An integrated vision of all the capital consuming activities of the bank requires an integrated information system, and the most holistic integrated information system for banks is SAP.

SAP does not have a capital optimizer yet, but it has the Bank Analyzer system which is capable of collecting, storing and managing the capital consumed in every banking activity.

The Integrated Financial and Risk Architecture of Bank Analyzer offers those capabilities and I’m explaining them to my customers in my daily work; and in these internet activities for the last 6 years.

In my opinion, it’s a matter of time that SAP sees the opportunity and develops a capital optimizer on top of the Integrated Financial and Risk Architecture, the systemic change is bringing the requirement and developing a market eager to implement it.

Looking forward to read your opinions.
K. Regards,
Ferran.

Thursday, June 19, 2014

Profit Centre Accounting, Business Segments Accounting and SAP Bank Analyzer.

Dear,
I’ve worked as SAP consultant for 18 years, in many areas like Finance, Controlling, Transactional and Analytical Banking, Data-warehousing, etc.; and one of the first lessons I learned is that SAP is about integrated processes that must be modelled from an End to End perspective.

There’re many ways of modelling a process, but there’s always an optimal modelization, and finding it requires looking at all its implications from an End to End perspective.

Some time ago, I was requested by a customer to make a proposal for covering IFRS-8 reporting regulatory requirements.
http://www.ifrs.org/IFRSs/Documents/IFRS8en.pdf

Simplifying, IFRS-8 main requirement for a corporate is disclosing financial information about their operating segments, products and services, the geographical areas in which they operate, and their major customers. Typically, an operating (or business) segment must involve around 10% of the company income, assets, etc.

We have two functional elements in SAP (including Bank Analyzer) that potentially support the IFRS-8 financial regulatory reporting requirements.

The first option is the profit centre; SAP Bank Analyzer and SAP Enterprise Core Components, support the complete disclosure of the accounting position of a Profit Centre (Balance Sheet and Profit/Losses). This makes Profit Centre Accounting a suitable candidate for building IFRS-8 reporting requirements.

On the other hand, SAP also offers another functional element for covering IFRS-8 regulatory requirements; the Business Segment. Business Segments Accounting is also available in Bank Analyzer and in SAP-ECC, and it also provides with the capacity of disclosing the Financial Statements of the Business Segments.

If both Profit Centre and Business Segments Accounting provide the functionalities of IFRS-8, can we use indistinctly one or the other?

Not really, a more detailed analysis can help on detecting the advantages of one approach in front of the other.

Profit Centre Accounting is an Internal Management Accounting functionality, which gives the answer of how well or bad, the company’s areas of responsibility are performing. The final objective is taking corrective measures for improving the performance, and incentivating with bonuses the managers with better performance.

On the other hand, Business Segments Accounting is oriented to provide external financial disclosure (typically IFRS-8), but as IFRS-8 requirements literally refer to “internal management reports”, the overlapping with Profit Centre Accounting can become confusing.
Some hints for helping on the decision of implementing Profit Centre Accounting, Business Segments Accounting or both.

Bank Analyzer standard delivery of Internal costs calculation is done on Profit Centre level; Funding Costs, Standard Process costs, Standard Capital costs, etc. are initially calculated in Profit Centre level.

Profit Centre Accounting provides a full valuation approach of the company performance, including Transfer Prices for representing the internal valuation of intra-group transactions. The Transfer Prices of these intra-group transactions can differ of the market invoicing prices. It can be sensitive to report this information in the audited IFRS-8 financial statements.

Additionally, as Business Segments are required for reporting those operations involving more than 10% of the company income, the number of business segments is typically around (or less) than 10.

And as Profit Centres represent areas of responsibility whose performance must be estimated, their typical number can be hundreds, or even thousands in big Financial Institutions.

We can discuss about the effort of building the double reporting framework of Profit Centre Accounting and Business Segments accounting, but SAP gives some tools to reduce the necessary customizing activities. We’ll talk about them in a future post.

K. Regards,
Ferran.
 

Monday, June 2, 2014

Attention CIOs, SAP Banking is the answer to the question you´re about to be asked.

Dear,
This week, Mr. Mohamed El-Erian, Chief Economic Advisor at Allianz http://www.allianz.com/, former chief executive officer at Pimco http://www.pimco.com/ and chairman of Barack Obama's Global Development Council published the following article in Bloomberg.

http://www.bloombergview.com/articles/2014-05-30/the-new-paradigm-for-banks

Just the title is clear enough; "The New Paradigm for Banks".

A paradigm change is a big thing, what are the root causes?

Mr. El-Erian names three; weak economy, central bank policies and regulation.
I
can´t agree more. Those of you who have read this community posts in the last 6 years already know what´s my opinion about it.

We´re in the middle of a Systemic Crisis which is driving a major change on the Financial System, from a model based in volume to a model based in efficient Capital Management.

Natural resources scarcity and global debt have reduced the world's potential growth, and this has deep implications for the Financial System.

Three years ago, you could read it here.

http://blogs.sap.com/banking/2011/12/07/its-growth-stupid/

We're in a Fractional Reserve Banking System; a Financial System which only requires a limited amount of capital (around 8-10% of Risk Weighted Assets); or in other words, a highly leveraged Financial System.

Leverage produces a multiplying effect in a growing economy but it´s unsustainable in a non-growing or limited-growing economy.

Governments know this, and as Mr. El-Erian mentions, they come with a two steps proposal:

- Regulation to drive capital management efficiency.

- Central Banks policies to borrow the necessary time to implement the new regulatory framework.

This is not new information, Mr. Jaime Caruana, General Manager of the Bank for International Settlements (Central Bank of the Central Banks) made it very clear one year ago.

http://www.bis.org/speeches/sp130623.htm

Paradigm change of the Financial System is going to happen and it's going to be challenging.

Let´s imagine for a minute that we're sitting at the executive board of a Tier 1 or Tier 2 Bank; as the bank can´t fulfill the increasing capital requirements, the chairman brings a critical request to his team.

What can you offer to improve the bank's capital ratio?

Barclay´s example that we discussed some weeks ago is giving us some answers.

http://sapbank.blogspot.com/2014/05/why-barclays-is-good-example-of.html

- The Chief Financial officer will propose a plan for toxic assets liquidation.

- The Chief human resources officer will come with a headcount reduction.

And the Chief Information Offer will have to bring a proposal for efficient capital management; let´s help him with it.

Efficient Capital Management requires:

- Determining the long term sustainable value of the bank´s portfolio.

- Matching accurately bank´s assets and liabilities by maturity bands.

- Proactive and effective implementation of hedging risk strategies.

- Integrated and multidimensional portfolio stress testing.

And overall, an Integrated and Financial Risk Architecture which offers a holistic vision of all the banks rights and obligations; assets, liabilities and collaterals.

These are the shapes that capital takes; modeling them in an integrated architecture is the basic requirement for building the IT proposal to the paradigm change.

After the crisis, financial institutions will have to live in a very different world of scarce and expensive capital which will make efficient capital management the main priority.

Combining Bank Analyzer Integrated Financial and Risk Architecture with the in-memory capabilities of SAP HANA, makes the foundation of a Capital Optimization model in which I have been working for the last six years, as I described briefly in the post below.

http://blogs.sap.com/banking/2012/02/01/capital-optimization-sap-hana/

Looking forward to bring your opinions.
K. Regards,
Ferran.