Title: RISK MANAGEMENT IN ISLAMIC BANKING
1(No Transcript)
2RISK MANAGEMENT IN ISLAMIC BANKING
- Presentation by
- MAHMOOD SHAFQAT
- Senior Joint Director
- Islamic Banking Department
- September 01, 2008
- The views expressed in this presentation are
those of the author and do not necessarily
represent State Bank of Pakistan.
3Outline
- Definition and Introduction to Risk Management
- Is Risk Management allowed under Shariah
- Risks faced by Banks
- Unique Risks faced by Islamic Banks
- Risk mitigation tools
- Regulatory Framework for Risk Management in
Pakistan - SBP Guidelines on Risk Management in IBIs
- IFSB Standard on Capital Adequacy
4RisksBasic Concept
- Risk
- existence of uncertainty about future outcomes
- difference between expected and actual result
- Uncertainty classified as general and specific
- General ignorance of any potential outcome
- Specific when objective/subjective probabilities
can be assigned to potential outcomesthis is
usually referred to as risk.
5Definition of Financial Risk
- Financial risk in a banking organization is
possibility that the outcome of an action or
event could bring up adverse impacts. - Such outcomes could either result in a direct
loss of earnings / capital or may result in
imposition of constraints on banks ability to
meet its business objectives.
6RISK MANAGEMENT
- Risk Management involves identification,
measurement, monitoring, reporting and
controlling risks to ensure that - The individuals who take or manage risks clearly
understand it. - The organizations Risk exposure is within the
limits established by Board of Directors. - Risk taking Decisions are in line with the
business strategy and objectives set by BOD. - The expected payoffs compensate for the risks
taken - Risk taking decisions are explicit and clear.
- Sufficient capital as a buffer is available to
take risk
7Risk Management activities
- Risk management activities take place at
- Strategic level by senior management and BOD
- Definition of risks, institutions risk appetite,
formulating strategy and policies for managing
risks and establish adequate systems and controls
to ensure that overall risk remain within
acceptable level and the reward compensate for
the risk taken. - Macro Level within a business area or across
business lines - Risk reviews by middle management
- Micro Level where risks are actually created
- Activities performed by individuals who take risk
on organizations behalf such as front office and
loan origination functions. Confined to following
operational procedures and guidelines set by
management.
8Risk management process
- Identification
- Measurement
- Monitoring
- Reporting
- Mitigation and control
9- To put it simply and directly,
- if the bosses do not or cannot understand both
the risks and rewards in their products, - their firm should not be in the business. -
- William J. McDonough, President, Federal Reserve
Bank of New York
10Shariah Perspective
- No Risk No Reward principle (Al Ribh Bi Daman)
- So No Risk Management?
- Measures taken by Hazrat Yousuf (AS) for drought
(Ahsan ul Qasas) - Do not give your Amwal to Sufahaa
- Writing of contracts whether spot or deferred
(Legal risk, Documentation risk, etc) - Maqasid-e-Shariah
- Protection of Izat, Jaan, Aql, Maal, Nasl
11RISKS FACED BY BANKS AND THEIR APPLICATION ON
ISLAMIC BANKING
12Risk Dimensions
Credit
13ISLAMIC BANKING LESS RISKY?
- Islamic Banking is safer as it is not based on
INTEREST? - Depositors are liable to share losses, therefore
solvency risk is mitigated?
14Major Types of Risks in IB
- Credit Risk
- Attributed to delayed, deferred, and default in
payments by counterparties. Covers profit sharing
contracts (Mudaraba and Musharaka), receivables
and lease (Murabaha, DM and Ijara, Salam,
Istisna), and covers different stages of a
contract - Market Risk
- Adverse movements in interest rates, commodity
prices and FX rates. Commodity risk in Murabaha,
Ijara, Salam - Equity Risk
- Adverse changes in market value (and liquidity)
of equity held for investment purposes. Covers
all equity instruments including Mudaraba and
Musharaka
15Major Types of Risks in IB
- Liquidity Risk
- Adverse cash flows in situations arising mainly
out of changing market risk exposures, credit
risk exposures and operational risk exposures. - Rate of Return Risk
- Changes in account holders expectations of the
return on investment. Also related to
fluctuations in returns due to changes in
underlying factors of the contract. - Operational Risk
- Inadequacy of failed processes, people and
systems. Also includes Shariah non-compliance
Risk - Legal Risk
- Inadequate legal framework, conflict of
conventional and Islamic laws and conflict
between Shariah rulings and legal decisions
16Credit Risk Mitigating Tools
- Pledge of assets as collateral
- Inventories, Shares, Sukuk, Units, etc.
- Third party Guarantee
- Personal Guarantee
- Promise
- Charge on deposits and assets
- Takaful
- Hamish Jiddiya
- Urbun
- Khiyar / Option
- Parallel contract, if permissible
17Regulatory Framework
- Risk Management
- Guidelines on Risk Management - BSD Circular No.
7 dt. Aug. 15, 2003 - Guidelines on Internal Credit Risk Rating Systems
BSD Circular No. 8 dt. Oct. 29, 2007 - Risk Management Guidelines for IBIs IBD
Circular No. 1 dt. Jan. 2, 2008. - ICAAP Guidelines - BSD Circular 17 of 2008
- Stress Testing
- Guidelines on Stress Testing - BSD Circular No. 5
dt. Oct. 27, 2005 - Internal Controls
- Guidelines on Internal Controls - BSD Circular
No . 7 dt. May 27, 2004 and BSD Circular No. 1
dt. Jan.14, 2006 - Policy Framework in Banks/DFIs - BSD Circular 3
of 2007
18SBP RM Guidelines for IBIs
- 15 Guiding Principles
- Divided into
- General (1 Principle)
- Credit risk (4 Principles)
- Equity investment risk( 3 Principles)
- Market risk (1 Principle)
- Liquidity risk (2 Principles)
- Rate of return risk ( 2 Principles)
- Operational risk (2 Principles)
- IBIs are also exposed to reputational risk
arising from failures in governance, business
strategy and process. Negative publicity about
their business practices, particularly relating
to Shariah non-compliance in their products and
services, could have an impact upon their market
position, profitability and liquidity.
19Guiding Principles on RM
- These principles are not radically different from
those applicable to conventional banks - However, these are some fundamental differences
- Emphasis on Shariah compliance
- 6 out of 15 principles make explicit reference to
Shariah rules
201. General Requirement
- Principle 1.0 IBIs shall have in place a
comprehensive risk management and reporting
process, including appropriate board and senior
management oversight, to identify, measure,
monitor, report and control relevant categories
of risks. The process shall take into account
appropriate steps to comply with Shariah rules
and principles and to ensure the adequacy of
relevant risk reporting to the supervisory
authority.
211. General Requirement
- Board of directors (BOD) and senior management
oversight - approve the risk management objectives,
strategies, policies and procedures - approvals shall be communicated to all levels
- ensure the existence of an effective risk
management structure - Shariah Advisor to oversee that the IBIs
products and activities are Shariah compliant
221. General Requirement
- Board of directors (BOD) and senior management
oversight - approve limits on aggregate financing and
investment exposures - review the effectiveness of the risk management
activities - Senior management shall execute the strategic
direction and set clear lines of authority and
responsibility - Independence of risk management function from
risk taking activities
231. General Requirement
- Risk management process
- sound process for executing all elements of risk
management, including risk identification,
measurement, mitigation, monitoring, reporting
and control - adequate system of controls with appropriate
checks and balances - (a) comply with the Shariah rules and
principles, - (b) comply with applicable regulatory and
internal policies and procedures and - (c) take into account the integrity of risk
management processes - quality and timeliness of risk reporting
available to regulatory authorities - appropriate and timely disclosure of information
to depositors
241. General Requirement
- Application of Emergency and Contingency Plan
- Integration of Risk Management
- Risk Measurement and use of models
- Utilization of funds
- Role of Finance Administration Department
- Management Information System for board or senior
management committee - Human Resource Training and development
252. Credit Risk
- Principle 2.1 IBIs shall have in place a
strategy for financing, using various instruments
in compliance with Shariah, whereby they
recognize the potential credit exposures that may
arise at different stages of the various
financing agreements.
262. Credit Risk
- Principle 2.2 IBIs shall carry out a due
diligence review in respect of counterparties
prior to deciding on the choice of an appropriate
Islamic financing instrument. - Principle 2.3 IBIs shall have in place
appropriate methodologies for measuring and
reporting the credit risk exposures arising under
each Islamic financing instrument.
272. Credit Risk
- Principle 2.4 IBIs shall have in place
Shariah-compliant credit risk mitigating
techniques appropriate for each Islamic financing
instrument.
282. Credit risk
- These principles apply to
- Murabaha, Salam, ijara and Istisna contracts
- Mudaraba and Musharaka
- Sukuk
- For example, for working capital financing,
Salam and Mudaraba contracts could be used - In case of Salam, the bank enters into a parallel
Salam contract with a third party - What factors may effect the counterpartys
ability to repay
292. Credit risk
- The commodity price
- Dont use commodities with high price volatility
- A list of all types of applicable and approved
transaction and financing - The Islamic banks should ensure that adequate
systems and resources are available to implement
this strategy - In case of using Mudaraba contract as a working
capital tool - The choices of Mudarib company should be made
with care
302. Credit risk
- The bank must have close links with the company -
Shariah implications - Choose an appropriate trading activity for
financing - Guidelines on a realistic review of expected
future cash flow
312. Credit risk
- Transformation of risk should be taken into
account while devising a sound risk management
strategy - For example, in Murabaha contracts, the risk gets
transformed from market risk to credit risk - In Mudaraba and Musharaka contracts, equity
investment gets transformed to debt in case of
proven negligence for misconduct on part of the
Mudarib or Musharaka partners - The role of promises must be scrutinized and
recognized in the complex structures
322. Credit risk
- Clearly define risk mitigating techniques
including but not limited to - Methodology for setting Mark-up rates according
to the risk-rating of the counterparties - Permissible and enforceable collaterals and
guarantees - Clear documentation as to whether or not purchase
orders are cancelable - Clear procedure for taking a/c of governing laws
- Always try to buy the asset-to-be- financed on
sale-or-return basis
332. Credit risk
- IBIs shall assess credit risk in a holistic
manner and ensure that credit risk management
forms a part of an integrated -
- For example, in a Salam contract, changes in
market risk factors such as commodity prices, as
well as the external environment (for example,
bad weather) become key determinants affecting
the likelihood of default. -
342. Credit Risk
- The IBIs must have
- an appropriate credit strategy, including pricing
and tolerance for undertaking various credit
risks - a risk management structure with effective
oversight of credit risk management - credit policies and operational procedures
including credit criteria and credit review
processes, acceptable forms of risk mitigation,
and limit setting
352. Credit Risk
- an appropriate measurement and careful analysis
of exposures, including market- and
liquidity-sensitive exposures and - a system to
- monitor the condition of ongoing individual
credits to ensure the financings are made in
accordance with the IBIs policies and procedures,
- manage problem credit situations according to an
established remedial process and to determine
adequate provisions to be made for such losses.
363. Equity investment risk
- Equity investment risk may be defined as the risk
arising from entering into a partnership for the
purpose of undertaking or participating in a
particular financing or general purpose activity
as described in the contract, and in which the
bank shares in the business risk - Market risk
- Liquidity risk
- Credit risk
- Other risks
- Capital impairment risk
373. Equity Investment Risk
- Principle 3.1 IBIs shall have in place
appropriate strategies, risk management and
reporting processes in respect of the risk
characteristics of equity investments, including
Mudarabah and Musharakah investments.
383. Equity Investment Risk
- Principle 3.2 IBIs shall ensure that their
valuation methodologies are appropriate and
consistent, and shall assess the potential
impacts of their methods on profit calculations
and allocations. The methods shall be mutually
agreed between the IBIs and the Mudarib and/or
Musharakah partners.
393. Equity Investment Risk
- Principle 3.3 IBIs shall define and establish
the exit strategies in respect of their equity
investment activities, including extension and
redemption conditions for Mudarabah and
Musharakah investments, subject to the approval
of the institutions Shariah Advisor.
403. Equity Investment Risk
- Risk mitigation
- Define and set the objectives of, and criteria
for, investment using profit sharing instruments - Monitoring
- Evaluation of Sharia compliance, holding of
periodical meeting with partners and proper
recordkeeping of these meetings - Monitoring of transformation of risks at various
stages of investment lifecycle - Monitoring of factors affecting the expected
volume and timing of cash flows
413. Equity Investment Risk
- Valuation
- Appropriate valuation methods profit calculation
and allocation - Assessment and measurement of potential
manipulation of reported results leading to
overstatements or understatements of partnership
earnings - Independent audit and valuations
- Appropriate methods for the treatment of retained
profits - Criteria for Exit strategies
424. Market Risk
- Principle 4.1 IBIs shall have in place an
appropriate framework for market risk management
(including reporting) in respect of all assets
held, including those that do not have a ready
market and/or are exposed to high price
volatility.
434. Market Risk
- The risk that arises from fluctuations in values
of tradable, marketable or leaseable assets
(including Sukuk) and in off- balance sheet
individual portfolios - The risks relate to the current and future
volatility of market values of - Salam based assets (due to commodity prices)
- Sukuk
- Murabaha assets( purchased to be delivered)
- Market risk exposures may occur at certain times
or throughout the contract
444. Market Risk
- In operating Ijarah, a lessor is exposed to
market risk on the residual value of the leased
asset at the term of the lease or if the lessee
terminates the lease earlier (by defaulting),
during the contract. - In Ijarah Muntahia Bittamleek, a lessor is
exposed to market risk on the carrying value of
the leased asset (as collateral) in the event
that the lessee defaults on the lease
obligations. - In Salam, IBIs are exposed to commodity price
fluctuations on a long position after entering
into a contract and while holding the subject
matter until it is disposed of. - In the case of parallel Salam, there is also the
risk that a failure of delivery of the subject
matter would leave the IBIs exposed to commodity
price risk as a result of the need to purchase a
similar asset in the spot market in order to
honour the parallel Salam contract.
454. Market Risk
- IBIs shall establish a sound and comprehensive
market risk management process and information
system, which (among others) comprise - a conceptual framework to assist in identifying
underlying market risks - guidelines governing risk taking activities in
different portfolios of depositors and their
market risk limits - appropriate frameworks for pricing, valuation and
income recognition and - a strong MIS for controlling, monitoring and
reporting market risk exposure and performance
to appropriate levels of senior management.
464. Market Risk
- Market risk is closely related to other forms of
risks, and an overall measure of it can be
calculated with the help of an appropriate VAR
model - Islamic banks then should ensure that adequate
capital is held against the market risk
475. Liquidity Risk
- Principle 5.1 IBIs shall have in place a
liquidity management framework (including
reporting) taking into account separately and on
an overall basis their liquidity exposures in
respect of each category of current accounts,
unrestricted and restricted investment accounts. - Principle 5.2 IBIs shall undertake liquidity
risk commensurate with their ability to have
sufficient recourse to Shariah-compliant funds
to mitigate such risk.
485. Liquidity Risk
- Two major types of fund providers
- current account holders and
- PLS Deposit holders
- PLS Deposit holders do not share in the risks on
assets financed by current accounts, which are
borne by shareholders alone - As fiduciary agents, the IBIs are concerned with
matching their investment policies with PLS
Deposit holders and shareholders risk appetites
495. Liquidity Risk
- Linked with displaced commercial and Shariah
compliance risks - Islamic banks must maintain adequate liquidity to
meet their obligations at all times - Strategy for managing liquidity involving
effective BOD and senior management oversight - A framework for developing and implementing sound
processes for measuring and monitoring liquidity - Adequate systems in place for monitoring and
reporting liquidity exposures on a periodic basis
505. Liquidity Risk
- Adequate funding capacity, with particular
reference to the willingness and ability of
shareholders to provide additional capital when
necessary - Liquidity crisis management, fixed asset
realization and sale and leaseback arrangements
etc.
515. Liquidity Risk
- Risk mitigation
- - Diversity sources of funds
- - Reduce concentration of funding base
- - Rely on marketable assets
- Identity any future shortfalls in liquidity by
constructing maturity ladders - Known cash flows
- Murabaha, Ijara, IMB and diminishing Musharaka
receivables
525. Liquidity Risk
- Conditional but predictable cash flows
- Salam and Istisna receivables
- Conditional and unpredictable cash flows
- Musharaka investments
- Periodic cash flow analysis under different
scenarios - A normal operating environment (e.g., a steady
state condition) - Adverse circumstances (e.g., non-linear events
and chaotic conditions)
535. Liquidity Risk
- establish the maximum amounts of cumulative
liquidity mismatches they consider acceptable - Liquidation procedures must be incorporated in
the investment contracts - Liquidity contingency plans addressing various
stages of liquidity crisis
546. Rate of Return Risk
- Principle 6.1 IBIs shall establish a
comprehensive risk management and reporting
process to assess the potential impacts of market
factors affecting rates of return on assets in
comparison with the expected rates of return for
PLS Deposit holders. - Principle 6.2 IBIs shall have in place an
appropriate framework for managing displaced
commercial risk, where applicable.
556. Rate of Return Risk
- An increase in benchmark rates may result in PLS
depositors having expectations of a higher rate
of return - The actual return on assets may be under
performing as compared to the competitors rate
of returns - Displace commercial risk
- Profit Equalization Reserve
- Investment Risk Reserve
567. Operational Risk
- Principle 7.1 IBIs shall have in place adequate
systems and controls, including Shariah Advisor,
to ensure compliance with Shariah rules and
principles.
577. Operational Risk
- Principle 7.2 IBIs shall have in place
appropriate mechanisms to safeguard the interests
of all fund providers. Where PLS deposit holders
funds are commingled with the IBIs own funds, the
IBIs shall ensure that the bases for asset,
revenue, expense and profit allocations are
established, applied and reported in a manner
consistent with the IBIs fiduciary
responsibilities.
587. Operational Risk
- Shariah compliance risk
- - The risk that arises form Islamic banks
failure to comply with the Shariah rules
principles determined by the Shariah Advisor or
the relevant body in the jurisdiction in which
Islamic banks operate - Fiduciary risks
- - The risk that arises from the Islamic banks
failure to perform in accordance with explicit
and implicit standards applicable to their
fiduciary responsibilities
597. Operational Risk
- IBIs shall establish and implement a clear and
formal policy for undertaking their different and
potentially conflicting roles in respect of
managing different types of investment accounts. - IBIs shall adequately disclose information on a
timely basis to their PLS deposit holders and the
markets in order to provide a reliable basis for
assessing their risk profiles and investment
performance.
60ROLE OF SUPERVISORY AUTHORITY
- adequate understanding on the wide array of risks
and satisfy itself that the IBIs have in place an
adequate risk management and reporting process - Develop and utilise prudential regulations and
requirements to control these risks
61ROLE OF SUPERVISORY AUTHORITY
- Credit Risk
- maintain a detailed description of each financing
instrument used by the IBIs in their jurisdiction
and the risk exposures to which each instrument
gives rise - may decide to develop Shariah guidelines or
minimum documentations in respect of agreements - adequacy of the policies and procedures to be
implemented by the IBIs to mitigate risks are
subject to review by the supervisory authority in
compliance with Shariah
62ROLE OF SUPERVISORY AUTHORITY
- Equity Investment Risk
- satisfy itself that adequate policies and
procedures are in place for equity investment
risk management - ensure that the IBIs have sufficient capital when
engaging in equity investment activities - may develop regulatory guidelines for measuring,
managing and reporting the risk exposures when
dealing with non-performance financing and
providing provisions
63ROLE OF SUPERVISORY AUTHORITY
- Market Risk
- satisfy itself on the adequacy of IBIs internal
systems and controls and internal limits set by
the IBIs on their market risk management in
relation to the activities undertaken. - Supervisory authorities should require IBIs in
their jurisdictions to develop guidelines for
acceptable valuation techniques where direct
market prices are not available, and should
approve such guidelines. Alternatively, the
supervisory authorities may themselves develop
such guidelines.
64ROLE OF SUPERVISORY AUTHORITY
- Liquidity Risk
- satisfy itself that the IBIs have adequate
liquidity policies, systems and controls in place
to manage their liquidity - may establish appropriate minimum levels of
liquidity for each category - central bank in its capacity as lender of last
resort may provide Shariah compatible mechanisms
for liquidity arrangements to IBIs as per
stipulated regulations before the IBIs can resort
to seeking funds
65ROLE OF SUPERVISORY AUTHORITY
- Rate of Return Risk
- assess the capacity of the IBIs to manage the
rate of return risk may establish appropriate
minimum levels of liquidity for each category - Where the supervisory authority may have a
policy of stating an expected rate of return for
unrestricted IAH, the supervisory authority shall
establish a framework within which this is to be
undertaken by the IBIs operating in its
jurisdiction
66ROLE OF SUPERVISORY AUTHORITY Rate of Return Risk
- The ROR framework may include amongst others,
methods, applicable periods and recognisable
income and expenses, and other calculation bases
relating to the use of funds. This framework
shall assist the supervisory authority to assess
the efficiency of IBIs in terms of their
profitability and prudent management.
67ROLE OF SUPERVISORY AUTHORITY
- Operational Risk
- satisfy itself that IBIs have in place a
comprehensive and sound framework for developing
and implementing a prudent control environment
for the management of operational risks - IBIs have adequate Shariah compliance mechanisms
in place - well-defined and adequately qualified and staffed
organisational structure - clear lines of authority and accountability
- policies and procedures for approval of products
and activities
68ROLE OF SUPERVISORY AUTHORITY
- Operational Risk
- prescribe formal guidance for the IBIs to ensure
they fulfil their fiduciary duties towards their
IAH - applicable auditing standards relevant to IBIs
are being implemented correctly in respect of the
assessment of the appropriateness of allocations,
distributions and reporting of profits to IAH - The supervisory authority may require IBIs to
have an independent and regular review of
Shariah compliance in this regard.
69Risk Measurement
- Risk measurement methods
- - Traditional
- GAP analysis
- Duration analysis
- Statistical analysis
- Scenario analysis
- Modern portfolio theory
- Variation from the mean
- VAR
-
70TEN RULES TO RISK MANAGEMENT
- There is no return without risks
- Rewards go to those who take risks
- Be transparent
- Risk should be fully understood
- Seek experience
- Risk is measured and managed by people, not by
mathematical models - Know what you dont know
- Question the assumptions made
- Communicate
- Risk should be discussed openly
71TEN RULES TO RISK MANAGEMENT
- Diversify-avoid concentration
- Multiple risks will produce more consistent
rewards - Show discipline
- A consistent and rigorous approach will beat a
constantly changing strategy - Use common sense
- It is better to be approximately right, than to
be precisely wrong - Return is only half of the equation
- Decisions should be made only after considering
the risks and returns of the possibilities - Oversight must be enterprise-wide
- Risks cannot be managed in isolation
72IFSB Capital Adequacy Standard
- Overview
- Largely based on the Basel approach, with
necessary modification and adaptation to cater
for specific nature and characteristics of
Shariah compliant products and services - Uses Risk weights derived from those proposed in
Basel II because of lack of historical data to
modify risk weights - For Credit Risk - Standardized approach
- Market Risk - 1996 Market Ris Amendment
- Operational Risk - Basic Indicator approach
- CAS is structured in a Matrix format to cater for
transformation of risk at different stages of
contract - Treatment of PSIA and assets financed by PSIA in
CAR - Adoption after Impact Study by SBP
73A Word of Caution
- Risk Management of your life is important than
everything. - Would you ever think about it.
- Various risks are related with our body and Soul.
Some of them could harm a lot and some less. - Kindly Think about it .
74For Comments and Suggestions please
contact Mahmood Shafqat Senior Joint
Director Islamic Banking Department State
Bank of Pakistan I.I. Chundrigar Road,
KarachiPh 92-21-9212509, 2453741Fax
92-21-9212472E-mail mahmood.shafqat_at_sbp.org.pk
75 THANK YOU
- MAY ALLAH THE ALMIGHTY SHOW US THE RIGHT PATH,
- THE PATH OF HIS LOVED ONES (AAMEEN)