BASEL II ECONOMIC CAPITAL - Nedbank [PDF]

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Idea Transcript


Basel II, economic capital & performance measurement update – 25 September 2007 “It It would be a mistake to conclude that the only way to succeed in banking is through ever-greater size & diversity. Indeed, better Risk Management may be the only truly necessary element of success in banking” Alan Greenspan

1

Contents BASEL II z Overview & status – Pillar 1 – Pillar 2 ( ) – Pillar 3 (disclosure) z Credit quality evaluation

ECONOMIC CAPITAL z Overview & status z Compared to Basel II and IFRS (impairments)

CAPITAL IMPACT OF BASEL II & ECONOMIC CAPITAL RISK, CAPITAL AND SHAREHOLDER VALUE MANAGEMENT z End of a 5 year journey…… z New capital allocation basis (from 2008) s appetite appet te z Risk z Performance measurement (from 2008) 2

Paradigm shift in risk & capital management driven by Basel II OLD THINKING

NEW THINKING & EXECUTION

Attitude to risk

Risk is bad

Risk is a bank’s core business

Evaluation of business opportunities

Minimise risk

Price for risk; client value management

Definition of risk appetite

Qualitative

Quantitative and qualitative

Approach to risk measurement

Conservative

Objective & transparent (risk = capital)

Focus of risk monitoring

Big names

Portfolio trends & concentrations

Risk management

Minimise risk taking

Optimise risk taking & link risk with return (use risk as an enabler)

Philosophical

Functional

Strategic Involvement in business planning & strategy

3

Limited (focus on downside risk)

Fully integrated, linked to performance measurement & economic value creation (shareholder value based management)

Risk & capital management – evolved to become core strategic business partners

4

Nedbank’s Basel II implementation blueprint 2003 - 2005

2004 - 2006

2005 - 2007

RISK & CAPITAL MEASUREMENT

RISK & CAPITAL MANAGEMENT

VALUE BASED MANAGEMENT

z Credit Models & Scorecards (AIRB approach for Basel II)

z Credit Portfolio Model

(Æ AIRB approach for Basel II)

z Credit Portfolio Management (CPM)

z Market Risk Models (Trading, Investment & ALM) IMA/EPE

z Credit Process Redesign

EVE

z Operational Risk Model (TSA Æ AMA)

z Business Risk Model z Earnings Volatility Model z Other Risk Models z Capital Projection Model

z Business Cluster Risk Labs & CMVU (centres of quant excellence)

z Asset / Liability Management (ALM)

z Operational Risk Management z Market Risk Management z Capital Management z Reporting z Chief Risk Officer ERM roles

z Basel II Capital z Economic Capital z Risk Appetite z RAPM z DATA MANAGEMENT

5

(Group Risk & Clusters)

z Enterprise-wide Risk Management Framework (ERMF) (Æ risk governance & accountability)

zCredit Process Implementation (AIRB approach) zCredit Portfolio Optimisation zInsight & value-add Management Science zRisk-based Pricing zClient Value Management zRisk-based Capital Allocation zRisk & Capital Optimisation zRisk Appetite zRisk-based Strategic Planning zRAPM (linked to STI incentives)

z IT SYSTEMS, SOFTWARE & EDW

z CHANGE MANAGEMENT

Three pillars of Basel II Represent a fundamental shift in banking regulation

Basel II Capital Accord Pillar 1 Min Capital Requirements (rules based) z

z

z

Sophisticated risk measurement for larger banks More than ever before, risk management will be a true competitive titi diff differentiator ti t Pillar 1 covers: – Credit risk (stand alone) – Equity risk – Operational risk – Market trading risk

6

– Securitisation risk

Pillar 2 Supervisory Review Process (subjective) z

Significant increase in required regulatory role (esp. on-site visits)

z

Supervisors review & evaluate risk & capital management in detail

z

Regulators expected to differentiate capital ‘add add ons’ ons based on quality of risk & capital management

z

Assessment of all other major risks (e g credit concentration risk, (e.g. risk ALM) ALM), & comprehensive “Internal Capital Adequacy Assessment Process” (ICAAP) from banks & “Supervisory R i Review &E Evaluation l ti P Process”” b by regulator

Pillar 3 Market Discipline (disclosure) z

Banks required to release much more information about risk profile

z

Increased disclosure of risk measurement & management practices, capital structure & capital adequacy

z

Debt & share markets increasingly able to differentiate banks based on quality of risk & capital management risk vs. management, vs return optimisation, etc

Nedbank’s risk & capital approaches for Basel II z

Advanced Internal Ratings Based (AIRB) approach for Credit Risk ~ Pillar 1 (‘in-principle’ approval received from SARB on 29 June 2007)

z Market-based Simple Risk Weight Approach for Investment Risk (equity exposures) ~ Pillar 1 z Standardised Approach (TSA) for Operational Risk but worldclass operational risk management ~ Pillar 1 (‘in-principle’ approval received from SARB on 15 August 2007) Workstreams are far advanced for transition to the Advanced Measurement Approach (AMA) in 2009/2010 for Basel II but 2008 for Economic Capital

z Internal Model Approach (IMA) for Market Trading risk ~ Pillar 1 z Worldclass standards for Credit Concentration & ALM (Interest Rate & Liquidity) risks ~ Pillar 2 z Worldclass Internal Capital Assessment Process (ICAAP) & Capital Management ~ Pillar 2 = best practice 7

Nedbank’s AIRB credit system Quantum leap across Nedbank to world class practice in credit risk measurement & management Loan Approval Monitoring

F Framework k & Policy P li

Reporting & Disclosure

Risk-based Pricing & Client Value Management

Nedbank’s Advanced Internal Ratings Based (AIRB) Credit System

Expected p Loss & Incurred Loss (impairments)

Strategy & Business Plans

Performance P f Measurement (RAPM)

Capital Management (Economic Capital, Risk Appetite & ICAAP)

Work commenced in 2003, AIRB credit system rollout in 2005, refined in 2006/7 8

Pillar 2 obligations under requirement for risk & capital assessment (ICAAP) REQUIRED BY NEDBANK ICAAP 1 Every bank should have an ICAAP ICAAP 2 Responsibility for bank’s ICAAP ICAAP 3 Written record of ICAAP ICAAP 4 Integral part of management & d i i decision-making ki culture of a bank ICAAP 5 Proportionality ICAAP 6 Regular independent review

9

REQUIRED BY SARB

REQUIREMENTS OF THE BANKS

REQUIREMENTS OF THE REGULATOR

Principle 1 • Banks to have an Internal Capital Adequacy Assessment Process ( ICAAP) and strategy linked to their capital levels and planning.

Principle 2 • Regulators to review and evaluate bank’s ICAAP.

Principle 3 • Banks expected to hold capital in excess of the regulatory minimum.

• Regulators able to take action if not satisfied. Principle 4 • Regulators to intervene early to prevent capital falling below required minimum levels.

• Regulators with power to enforce.

INTERNAL CAPITAL ADEQUACY ASSESSMENT PROCESS (ICAAP)

Board and management oversight

Sound capital assessment

• Understand nature • Identification, and level of all measurement material risks and reporting of • Set risk appetite and all material risks tolerance • Relate capital to • Assess and risk i k ensure capital • Integrate capital adequacy with risk and • Decide overall business plans business strategy • Capital with regards to management capital • Set S t policies li i

ICAAP 7 Forward looking Forward-looking

Comprehensive risk assessment and management g process • Credit risk • Market risk • Operational risk • Interest Rate risk • Liquidity risk • Reputationall riskk • Strategic risk • Concentration risk • Procyclicality risk Economic Capital*

Monitoring and p g reporting

Internal control Review

• Evaluate level and trend of material risks • Sensitivity analysis of key assumptions • Corporate governance • Produce reports for management and board

• Internal and external audit reviews • Monitor compliance • Stress St ess testing • Identification and management of concentrations • Documentation

SUPERVISORY REVIEW AND EVALUATION PROCESS (SREP)

ICAAP 8 Risk-based

ICAAP 8 Stress tests & scenario analysis ICAAP 10 Diversification & concentration risk

ICAAP 11 Credit concentration risk ICAAP 12 Capital models

Nedbank’s ICAAP framework (Pillar 2) QUANTITATIVE RISK AND CAPITAL MEASUREMENT AND ASSESSMENT Pillar 1 risks

Credit risk (AIRB)

Pillar 2 risks

External factors

Concentration risk

Stress tests and scenario analysis

Interest rate risk

Macro-economic risks

Business risk Strategic and Reputation risks

Operational risk (TSA AMA)

INTERNAL CAPITAL ADEQUACY ASSESSMENT PROCESS (ICAAP)

Securitisation risk Settlement risk Residual risk

AIRB Credit Framework Group Credit Portfolio Management Market Risk Framework

Risk Appetite (tolerance) Capital p p planning g ((long g run)) and Capital Buffer Management Stress & Scenario Testing Framework (including macroeconomic factor model) Ri k Appetite Risk A i Framework F k

Risk-based Capital Allocation and Risk Adjusted Performance Measurement (RAPM)

Incentives (STI)

Risk Adjusted Performance Measurement Framework (RAPM)

Capital Adequacy Projection Model

Economic Capital Framework

Group Operational Risk Framework

Capital Buffer Management Framework

Strategic Capital Plan

Economic Capital Framework

Capital Management Framework

G Group’s ’ 3 year Business B i Plans Pl

ALM Framework

EDW and Data Governance Framework

10

Strategic Capital Planning

Group St G Strategic t i Planning Pl i Process (3 year business plans)

Liquidity risk Market risk (IMA)

INTEGRATION OF RISK AND CAPITAL MANAGEMENT INTO STRATEGY BUSINESS PLANS STRATEGY, AND REWARD

GOVERNANCE, QUALITATIVE ASPECTS AND SUPPORTING INFRASTRUCTURE Clearly defined roles and responsibilities for: Business Clusters (incl. Cluster financial risk labs) Group Finance and Group Capital Management Group Strategy Investor Relations Group Risk Group Internal Audit Group Exco Board of Directors Involving: Identification of risk ((risk g governance,, risk universe) Control, management and monitoring of risk Setting and managing risk appetite Optimisation of risk and capital and return Key involvement in business planning and strategy Risk reporting, communications and disclosure Risk management infrastructure Championing enterprise-wide risk management

Enterprise-wide Risk Management Framework (ERMF)

Capital Management Framework

Public disclosure from 2008 (Pillar 3) Regulation 43 of the new Basel II Regulations relating to Banks: -

“…bank shall disclose in its annual financial statements and other disclosure (e.g. quarterlyy / semi-annually) q y) to the public, p , reliable,, relevant and timelyy qualitative q and quantitative information that enable users of that information, amongst other things, to make an accurate assessment of the bank's financial condition, including its capitaladequacy position, financial performance, business activities, risk profile and riskmanagement practices…” Minister of Finance anticipated to sign new Basel II regulations into law by end O t b 2007 (for October (f effect ff t 1 January J 2008)

11

New credit risk BA returns - Basel II AIRB approach z Summary of selected credit risk related information z z z z

Total advances Impaired advances Assets bought-in Total credit impairments

– Specific credit impairments

IFRS (accounting (accounting-based) based)

– Portfolio credit impairments z z z z z z z z

Credit losses charge to income statement Total credit extended Exposure at default (EAD) Average probability of default (PD, EAD weighted) Average loss given default (LGD, EAD weighted) Total expected loss (EL) Best estimate of expected loss (BEEL) Net excess / (deficit) of total credit impairments compared to expected loss

= 2006 Annual Report 12

= Disclosure in 2008

Basel II (risk-based )

New credit risk BA returns - Basel II AIRB approach (continued) z Credit risk exposure & capital requirement – analysed by Basel II asset class z Corporate

13

exposure – Corporate C t – Specialised lending - high volatility commercial real estate (prop development) – Specialised lending - income producing real estate – Specialised lending - object finance – Specialised lending - commodities finance – Specialised lending - project finance – SME corporate z Purchased receivables - corporate z Public sector entities z Local government & municipalities z Sovereign (including central government & central bank) z Banks z Securities firms z Retail exposure – Retail mortgages – SME retail – Retail revolving credit – Purchased receivables - retail – Retail Other z Securitisation exposure

New credit risk BA returns - Basel II AIRB approach (continued) z Analysis of credit exposure, that is EAD analysed by PD band (NGR) per master rating scale; EAD weighted average LGD (%); expected loss (EL)

– Performing book in total & by PD band (NGR), & by asset class – Non-performing book / book “in default”

z EAD & credit conversion factors; Average effective maturity (EAD weighted); Analysis of expected loss & credit impairments

– By asset class

z Reconciliation of credit impairments – By balance sheet & income statement (opening to closing balance)

z Analysis of past due exposures – B By assett class l &b by d days overdue d (0 (0-30 30 d days, 31 31-61 61 d days, 61 61-90 90 d days & >90 90 d days)) Note: Basel II definition of default = more than 90 days overdue

z Counterparty credit risk – Various analysis, including over-the-counter (OTC) & securities financing transactions (SFT)

z Credit risk mitigation – By y asset class and by y type yp of credit risk mitigation g

z Restructured credit exposure (“distressed renegotiations” per IFRS 7) 14 z Credit concentration risk

Other AIRB credit disclosure

z Risk profile by NGR (PD) & NTR (EL) grades across credit portfolios / segments z Migration across grades z Portfolio migration (trends) z Regulatory & economic capital by credit portfolio, asset class, business, etc z Back testing of default rates (PDs), LGDs & EADs z Stress test results (pillar 1 [risk] & pillar 2 [capital]) z Overall performance of AIRB system including results of validation validation, changes changes, etc 15

Nedbank’s master rating scales are the new common language of credit risk Credit risk profile – as at 30 June 2007 Exposure per PD – NGR rating scale (excludes CRM / collateral)

Exposure per EL – NTR rating scale (includes CRM / collateral) % Exposure

% Exposure

30%

Primarily Retail & Business Banking

25%

20%

Primarily Wholesale Wholesale, Financial Services & Government

15%

Primarily Wholesale Financial Services & Government

25% 20%

Primarily Property Finance & Private Clients

Primarily Retail & Business Banking

15%

10%

10%

NP

NGR 25

NGR 24

NGR 23

NGR 22

NGR 21

NGR 20

NGR 19

NGR 18

NGR 17

NGR 16

NGR 15

NGR 14

NGR 13

NGR 12

NGR 11

NGR 10

NGR 09

NGR 08

NGR 07

NGR 06

NGR 05

NGR 04

NGR 03

0%

NGR 02

0%

NGR 01

5%

NGR 00

5%

NTR 01

NTR 02

NTR 03

NTR 04 Dec-05

Dec-05

Jun-06

Dec-06

NTR 05 Jun-06

NTR 06 Dec-06

Jun-07

The NGR & NTR master rating scales are comprehensively used for: z Credit approval (individual loan applications) z Credit risk management z Risk-based pricing & client value management z Management and board reporting on credit risk z Regulatory reporting & peer group comparison by SARB (from 2008) z External reporting (Pillar 3) (started in 2005 - see annual report) 16

NTR 07 Jun-07

NTR 08

NTR 09

NTR 10

New basis for credit quality assessment arising from Basel II z Definition of Default – for IRB banks – New fundamental basis for asset quality evaluation across banking industry (large banks) – Obligor overdue for more than 90 days & / or when bank is of opinion that obligor is unlikely to pay obligations in full without any recourse by bank to actions (minimum matters are specified in the new regulations – Reg 65) – Can apply for permanent condonation to use 3 monthly instalments (i.e. as = 90 days)

z Current DI 500 “Credit Risk Classification System” is retained for Standardised Approach banks only to supplement Basel II standardised approach risk weightings & requirements (for IRB banks this system is superseded by new IRB credit methodology)

z Concept of “minimum regulatory provisions” now obsolete. For IRB banks replaced by Expected p Loss ((EL)) methodology gy & a requirement q that EL be compared p with accounting g impairments under IFRS. The difference impacts qualifying capital

z Past Due Analysis up to 90 days for IRB Banks included as one supplement for credit quality analysis (0-30 days; 31-60 days; 60-90 days; >90 days – all based on EAD) 17

Levels of capital REGULATORY CAPITAL

zAmount of capital required to protect bank against regulatory insolvency

zDesigned primarily to protect d depositors it & creditors dit

18

ECONOMIC CAPITAL

zAmount of capital required to protect group against economic insolvency, tailored to Nedbank Group

zAlso used as a tool for many risk vs. return t managementt applications such as risk-based pricing, client value management, RAPM etc RAPM,

AVAILABLE CAPITAL (BOOK EQUITY)

zNet asset value, takes account of the two measures of required capital

zCompared to regulatory capital it l & economic i capital it l to t ensure solvency of both

MINIMUM CAPITAL YOU

CAPITAL YOU

CAPITAL YOU

ARE TOLD TO HAVE

ACTUALLY NEED

HAVE

Economic capital vs. Basel II Basel II Capital Accord Pillar 1 Mi i Minimum Capital C it l Requirements (rules based)

zSophisticated p risk measurement for

Pillar 2 ICAAP and d Supervisory S i Review Process (subjective)

zSignificant increase in required regulatory role (esp. on-site)

larger banks

zMore than ever before, risk management will be a true competitive differentiator z Pillar 1 covers: - Credit risk (stand alone) - Equity risk - Operational risk - Market trading risk - Securitisation risk

zSupervisors review & evaluate risk and capital management

zRegulators expected to differentiate capital ‘add ons’ based on quality of risk & capital management z Assessment of all other major risks (e.g. credit portfolio concentration risk, ALM) & a comprehensive Internal Capital Adequacy Assessment Process (ICAAP), including link to risk appetite & bank’s strategic planning.

Pillar 3 M k t Market Discipline (disclosure)

zBanks required q to release much more information about their risk profile

zImproved p o ed d disclosure sc osu e o of risk s measurement & management practices, capital structure & capital adequacy

zDebt & share markets increasingly able to differentiate banks based on quality q y of risk & capital p management, risk vs. return optimisation, etc

NEDBANK S NEDBANK’S ECONOMIC CAPITAL 19

Nedbank’s Economic Capital (substantially) = Basel II pillar 1+ pillar 2

Economic capital vs. Basel II (continued) BASEL II

ECONOMIC CAPITAL

PILLAR 1

PILLAR 2

Credit di Risk i k (stand ( d alone) l )

di Concentration i Risk i k Credit

AIRB credit approach 1

Nedbank’s Credit Portfolio Model

(ECAP)

?

Credit di Economic i Capital i l =1&2

(using KMV software) 2 Market Trading Risk

N/A

Market Trading Risk Economic Capital

Internal Model Approach (and CEM* * for counterparty credit risk) 3 N/A

=3 ALM Risks

?

ALM Economic Capital

- Interest risk rate in banking book ((Nedbank models this using g IPS Sendero and on an Economic Value of Equity (EVE) basis) 4 N/A

- Liquidity risk ?

N/A

- Currency Translation Risk (rand volatility measure) 5

20 * will implement advanced internal model methodology in 2008 / 9

=4 N/A (not practical to hold capital for this – rely entirely on ALM / ALCO process)

?

=5

Economic capital vs. Basel II (continued) BASEL II PILLAR 1 Equity Risks

ECONOMIC CAPITAL PILLAR 2

N/A

(investment and property risks)

= 6* N/A

Standardised Approach 7** N/A

Other Assets (100% risk weight) 8

Equity Risk ECap (using simple volatility measures in 2007; will align to Basel II for 2008)

Simple risk weight approach (300 / 400% vs 100% Basel 1) 6* Operational Risk

(ECAP)

Oprisk Economic Capital = 7**

Strategic, reputational and other risks N/A

Business Risk ECap (earnings volatility approach) Other Assets ECap = 8 (from 2008)

* will implement advanced internal model methodology in 2008 / 9 **will implement advanced measurement approach (AMA) in 2008 for ECap and 2009 / 2010 for Basel II ** 21

Economic capital vs. Basel II (continued) FACTOR

BASEL II

ECONOMIC CAPITAL

Measurement period (time horizon)

1 year (forward looking)

1 year (forward looking)

Confidence interval (solvency standard)

99,9% (1 in 1 000 years) or A-

99,9% (1 in 1 000 years) or A(Nedbank’s current choice)

z ‘Basel II capital formula calibrated to a

z Nedbank’s CPM measures

Diversification benefits

z Intra-risk (within a risk type, especially credit)

z Inter-risk (between risk types)

large, well diversified international bank’

z ?

portfolio correlations & thus accounts for concentrations & intrarisk diversification

z Inter-risk correlation matrix

(simple aggregation of all risks’ capital) (part of ICAAP / SREP)

AIRB credit methodology

22

z 6% scaling factor

9

X

z Downturn LGD (dLGD)

9

Through-the-cycle LGD

Economic capital vs Basel II – available capital resources CAPITAL SOURCES

BASEL I

BASEL II

ECONOMIC CAPITAL

Tier 1

Tier 1

AFR

- Share capital and reserves

3

3

3

- Minority interest

3

3 (to apply to SARB)

3

(limit 20% of tier 1) 3

(limit 25% of tier 1) 3

(no limit) 3

-

3(limit 15% of tier 1)

3(no limit)

Goodwill & impairments

(x)

(x)

(x)

Other regulatory vs. accounting (IFRS) differences & unappropriated profits

(x)

(x)

(x) 3 for unapp. profits

100% of net diff for ECap if +ve or –ve

-

-

3 or (x)

50% for Basel II if -ve (other 50% in Tier 2)

-

(x)

-

-

-

3 (50% taken)

Core

Non-core - Preference share capital - Hybrid debt / capital instruments

Impairments vs. EL - Basel II (dLGD) - ECap (TTC lgd)

Next year year’s s pre-tax pre tax profit per business plan

23

(x) = deduction

Economic capital vs Basel II – available capital resources CAPITAL SOURCE

Excess of tier 1 non-core capital

BASEL I

BASEL II

ECONOMIC CAPITAL

Ti 2 Tier

Ti 2 Tier

AFR

3

3

(limited to tier 2 total being (limited to tier 2 total being 100% of tier 1) 100% of tier 1) Subordinated debt General credit risk provision

Impairments vs. EL - Basel II (dLGD)

TOTAL

(x) = deduction 24

100% if +ve (limit to 0,6% off credit dit RWAs) 50% if –ve (other 50% in Tier 1)

No limit, all included in core capital (i.e. AFR)

3(limited to 50% of tier 1)

3(limited to 50% of tier 1)

- (N/A)

3

-

-

-

3

-

OR -

(x)

-

XXX

XXX

XXX

Basel II (expected loss) vs. IFRS (incurred loss) EXPECTED LOSS EXCEEDS INCURRED LOSS (IMPAIRMENTS)

Overlaps Book value – PV of expected future cash flows PD x LGD x EAD

25

Eligible Tier 2 Capital

IAS 39

Unexpe ected loss Expected E loss

50% of Tier 2

IIncurred loss

Capital d deduction

50% of Tier 1

Total capital requirement

Basel II

Incurred d loss

IAS 39

Unexpecte ed loss Expected d loss

Total capita al requiremen nt

Basel II

INCURRED LOSS EXCEEDS EXPECTED LOSS (IMPAIRMENTS)

Limited to 0,6% of credit RWA

Basel II (expected loss) vs. IFRS (incurred loss) (continued) BASEL II

IAS 39

Intention of estimate

z Conservative estimate of probability of

z Best estimate of likelihood & timing of

Period of measurement

z Long run historical average over whole

PDs default within next 12 months economic cycle – “through-the-cycle” through the cycle

credit losses over life of loan

z Should reflect current economic conditions – “point-in-time” point in time

LGDs Intention of estimate

z Conservative estimate is discounted value

Treatment of collection costs

z Recoveries net of direct & indirect

Discount rate

z Recoveries discounted using entity’s entity s cost

of post-default recoveries collection costs of capital

Period of measurement

z Conservative estimate of discounted value of post-default recoveries

z Recoveries net of direct, cash collection costs only

z Cash flows discounted using instrument’s instrument s original effective interest rate

z Reflects period of high credit losses z “Downturn” LGDs required

z Should reflect current economic conditions

z Based on Exposure-at-Default (EAD),

z Based on actual exposure

– “point-in-time” point in time

EL Basis of exposure

which hi h includes i l d unutilised tili d ffacilities iliti

( & off (on ff – balance b l sheet) h t)

For Nedbank’s credit economic capital, through-the-cycle LGDs are utilised as opposed to downturn LGDs for 26 Basel II

Nedbank’s economic capital model & position at 30 June 2007 2%

Rm Credit risk Market risk Trading risk ALM risk Property risk Investment risk Forex risk Operational risk Business risk Minimum ECap

15 070 3 782 416 554 906 1 873 33 464 3 522 22 838

15% 15% 8% 8%

16% 67%

4% 2% 2%

=

Minimum Economic Capital R22 838m

Capital Buffer R2 284m Economic Capital Requirement R25 122m vs. Available Financial Resources R30 040m

27

Basel II regulatory capital requirements REGULATORY MINIMUM CAPITAL REQUIREMENTS

Pillar 1

8,00%

+ Pillar 2a

1,50% (RSA systemic risk) 9 50% 9,50%

+ Pillar 2b

0,25% (may vary - idiosyncratic risk)

Minimum required capital ratio

9,75%

+ buffer (principle 3, Pillar 2)

X% (board decision)

Maximum 15% of primary capital

Maximum 50% of primary capital p

REGULATORY MINIMUM CAPITAL STRUCTURE

Minimum 75% of primary capital

Maximum 25% of primary capital

Ordinary shares & defined reserve funds Primary capital (Tier 1) minimum 7,0%

Non-redeemable noncumulative preference shares Hybrid debt instruments Other qualifying Oth lif i instruments / amounts (i.e. perpetual debt instruments, preference shares)

Maximum 100% of primary capital

Upper Tier 2 (secondary capital) 2,5%

Subordinated term debt Tertiary capital

Lower Tier 2 (secondary capital)

Total 9,5%

28

Pillar 1 & Pillar 2a 9,5%

Impact of Basel II & economic capital as at 30 June 2007

BASEL I

BASEL II

ECONO OMIC CAPITAL

CAPITAL REQUIREMENT (in Rbn)

CAPITAL RATIOS

29

Basel I

ECONOMIC C CAPITAL

BASEL I

BASEL II

CAPITAL RESOURCES (in Rbn)

Basel II

Tier 1

8.3%

7.9%

Total

12.4%

11.6%

Economic Capital R4.9bn surplus (i.e. after 10% buffer)

Strategic capital management z Nedbank will be capitalised at greater of Basel II & Economic Capital: Target range for Basel II Total ratio ratio:: 11% - 12% (min 9.75%) Target range for Basel II Tier 1 ratio ratio:: 8% - 9% (min 7%)

Confirmed using macromacro economic factor model to stresstest (ALCO & Board approved)

Target Economic Capital = AA- debt rating + 10% buffer

z Plans are advanced to issue hybrid debt capital in Q4 2007 (qualifying as Tier 1 on 01/01/2008) z Management actions executed over past 3 years have removed excess risk on B/S & aligned risk profile with Board’s risk appetite

z Strategic capital planning & dynamic capital management in place since 2005 2005, for example Subordinated debt maturity profile 4 500

Redeemed Debt

Debt in Issue

NED 2

4 000 3 500

R 'm

3 000 2 500 2 000

NED 1

NED 6 NED 5

1 500

NED 9 NED 8

NED 7 NED 10

NED 11

1 000 NED 4

500 0 2006

30

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

Creating a Nedbank yield curve & diversifying internationally

Journey to worldclass risk & capital management BASEL II

CAPITAL MANAGEMENT

2003//2004 2004 2003

ECONOMIC CAPITAL

RISK APPETITE

2006 2006

2007 2007

2005 2005

RAPM

INCENTIVES 2008 2008

FINALISE (100%) BUILD RISK AND (incl EDUCATE, FINEFine TUNE, FULL FULL PERFORMANCE Build capabilities Educate,USE, use, SHADOW shadow reporting, refine and tune, measure, Finalise (100%), READY FOR 2008 REFINE INTEGRATE CAPITAL MEASUREMENT & CAPITAL AIRB credit system) y ) andREPORTING, g into 3-year y &strategic g p planning g REPORTING p and measure, , monitor, and , capital p allocation on risk integrate monitor,,&report FULLreport APPLICATION introduce new concepts (first time) STRATEGIC PLANNING reward (begin) and reward adjusted aALLOCATION djusted (ECap/EP) basis INTO 3-YEAR CAPABILITIES & REWARD (FIRST ON RISK (FIRST TIME) INTRODUCE THE TIME) ADJUSTED (RAPM) BASIS NEW CONCEPTS

SHAREHOLDER VALUE

Strategic steering & pricing based on Economic Profit Groupwide capital steering & optimisation

Risk Portfolio & Capital Optimisation Capital Allocation based on Economic Profit ( (using Economic Capital) C l) Economic Profit = new KPI for Nedbank Group

Capital Management Risk & capital integrated into strategy

Strategic Capital Management Strategic Capital

Management RAPM (linking risk to return)

Risk Appetite quantification Capital Management Framework

Economic Capital

Economic Capital quantification quantification (consistent, bottom up measurement of all material risks) Risk Governance Risk Governance (ERMF) (ERMF)

Risk Identification

Governance, risk measurement & quantification (Nedbank Group’s Basel II Programme as the catalyst) Risk Management

Completed in 2004 Introduced in 2005 On track to be fully “business as usual” from 2008

RISK & CAPITAL MANAGEMENT SOPHISTICATION

31

Capital management framework – rolled out in 2005 CAPITAL MANAGEMENT FRAMEWORK STAKEHOLDERS

RISK vs. CAPITAL ADEQUACY (Solvency)

Depositors Debt-holders Rating agencies Regulators

CAPITAL RISK

Business Clusters

SENIOR MANAGEMENT

Shareholders Analysts General public Clients

(Profitability)

MANAGEMENT

Capital

Capital

Capital

Capital

Investment

Structuring

Allocation

Optimisation

Group ALM

STAKEHOLDERS

RISK vs. RETURN

GROUP CAPITAL MANAGEMENT

STRATEGY

RISK ADJUSTED PERFORMANCE MEASUREMENT (RAPM) Economic FTP Capital

Group Finance, Group Strategy & Business Clusters

AJTP

Investor Relations

METHODOLOGIES, POLICIES, PROCESSES, GOVERNANCE & INDEPENDENT ASSURANCE ENTERPRISE-WIDE RISK MANAGEMENT OBJECTIVES Optimise business opportunities

Protect against unforeseen losses

Ensure earnings stability

RISK = OPPORTUNITY

RISK = THREAT

RISK = UNCERTAINTY

We believe we now have worldclass enterprise-wide risk and capital management in place 32

Shareholder value creation A vital aspect of our focus on value based management is the clear line of sight between creating value for shareholders, portfolio risk management at the centre & day to day decisions in our businesses Shareholder value based management

Internal view i Primary objective = ECONOMIC VALUE CREATION

ERM analytical capabilities, p processes, p management, control, etc z Portfolio risk management z Active capital management z Day to day decision making

33

z Establish performance expectations of shareholders

Shareholder return requirements (share price + dividends) Long term Short term

z Define consistent internal view of economic value Line of sight L

External view

Delivering shareholder value based management

z z z z

measurement, creation & reward across Nedbank based on concept of economic profit (EP) Risk based capital allocation & RAPM (using ECap) Risk appetite setting Effective reporting & communication of risk using Economic Capital (ECap) Align Nedbank’s ERM management processes & metrics (EP & ECap) with Group’s primary strategic objectives j and business p planning gp process

z Create culture of considering economic value

z

creation / destruction when taking decisions at all levels (e.g. proper risk-based pricing & client value management) Economic-based performance measurement (using RAPM) & reward accordingly

Economic (& Basel II) capital a sophisticated quantitative enterprise-wide measurement of risk

By major risk type

By business Unit

R MM

Total Risk

=

Total Capital Requirement

Investment Risk Property Risk Operational Risk Business Risk ALM Risk Trading Risk Transfer Risk Credit Risk

Is the inherent volatility or potential fluctuation in a Nedbank Group's net asset value

Portfolio measurement and Inter-risk & Intra-risk diversification Credit Risk 67%

Issuer Risk

Counter-Party Risk s

Market Risks 16%

Transfer Risk (Sovereign) (So e eg )

ALM Risk 2% %

Trading Risk 2% %

Investment Risk 8%

Operating Risks 17%

Property Risk 4% %

Operational Risk 2% %

Business Risk 15% 5%

Nedbank Corporate

Nedbank Capital

Nedbank Retail

Imperial Bank

ALM

Other

Economic Capital provides a scientific apples-to-apples quantification / measurement & comparison of risk across all businesses & major risk types in Nedbank Group. This also enables ‘capital’ to be allocated to th various the i business b i units it & their th i return t measured d on a proper ‘risk ‘ i k vs. return’ t ’ basis b i (i.e. (i RAPM), RAPM) & a ffocus on both downside risk & upside potential 34

New 2008 risk based capital allocation methodology TO END 2007

2008 ONWARDS

Capital allocated using 10% of Basel I RWAs

Economic Capital allocated, aligned to Group’s ord d shareholders’ h h ld ’ equity it (i.e. (i core Tier Ti 1 capital) it l)

z Non-core tier 1 (prefs) not allocated

z Excess cost of prefs, hybrids and sub-debt

z Tier 2 (debt) not allocated

z Goodwill not allocated

allocated to clusters

Basel I Capital Rbn*

Economic Capital Rbn*

4 013

4 080

14 184

9 783

7 658

8 471

Imperial (50,1%)

888

1 223

Operating Units

26 743

23 557

Excluding goodwill

23 274

23 274

Including goodwill

26 979

26 979

Nedbank Capital Nedbank Corporate Nedbank Retail

NEDBANK GROUP BOOK EQUITY

* Based on current estimates

2007 year end results will be reported on both the old & the new basis 35

Risk appetite Risk appetite is an articulation of risk capacity or quantum of risk Nedbank Group is willing to accept in pursuit of its strategy, duly set & monitored by the board, & integrated into strategy & business plans NEDBANK’S GROUP-LEVEL RISK APPETITE METRICS Group metrics

Definition

Measurement methodology

Targets*

Earnings at risk (EAR)

Pre-tax economic earnings potentially lost over a one year period

Measured as a 1-in-10 year event (i.e. 90% confidence level)

Less than 100%

9

Chance of regulatory insolvency

Event in which losses would result in Nedbank being undercapitalised relative to minimum regulatory capital ratios (both Tier 1 & Total capital ratios)

Utilises earnings at risk, & compares to capital buffer above regulatory minimum - a 1-in-x years chance of regulatory insolvency

Better than 1 in 20 years

9

Chance of experiencing a loss

Event in which Nedbank Group experiences an annual loss (on an economic basis)

Utilises Earning at Risk by comparing to expected profit over the next year

Basel II basis: 1 in 20-30 years by 2007, thereafter 1 in 30 30–50 50 years

9

Economic capital q y adequacy

Nedbank adequately capitalised on an economic basis to its current target debt g rating

Measured by comparing available capital to Economic Capital q requirement

Equivalent rating of A- or better

9

* Set in 2004, will be revised in Q4 2007 for 2008 – 2010 business plans

36

Within targets

Performance measurement from 2008 Communicated since 2005 that RAPM will be applied (i.e. for remuneration ~ STI) from 2008 onwards, following the end of Nedbank’s 3 year recovery & Basel II going live in RSA

37

z

Primary P i ffocus off performance f measurementt att Group G & Business B i Unit U it level l l will ill switch it h tto an absolute shareholder value add (SVA) measure from the current relative measure (i.e. from % RoE to Rv Economic Profit (EP), & specifically delta EP (ΔEP)

z

RoE is fine during a recovery period but: – RoEs (or RAROCs) can be achieved by clusters shrinking the business or lower growth (& ∴lower capital usage) while destroying EP for the Group – Out-performance profitable growth at same or slightly lower RoE is not rewarded

Performance measurement from 2008 (continued) z

Strongest correlation of Total Shareholder Return (TSR) is with Δ EP growth I di t ffor TSR: Indicator TSR

C Compare

ROE vs. TSR

R2= 3%

∆ROE vs. TSR

R2= 29%

EP vs vs. TSR

R2= 33%

∆EP vs. TSR

R2= 73%

(TSR = value created for shareholders through share price appreciation & dividends)

Source: Oliver Wyman

38

z

At GROUP level,, IFRS earnings g & average g book equity q y will be the basis for ΔEP p performance measurement

z

At BUSINESS CLUSTER level this will be ΔEP using: – IFRS earnings (not “risk risk-adjusted adjusted” earnings but will report / monitor both bases) – Allocated excess costs of non-core equity (i.e. prefs / hybrids / tier 2 debt) – Allocated group capital endowment benefit in clusters’ ECap % ratios – Unallocated goodwill funding costs (i (i.e. e goodwill held at the centre) – Target average economic capital allocation (per business plans) – Group diversification benefits are allocated / incorporated in economic capital allocation – Target capital buffer % allocation (only as necessary to align total economic capital allocation with the Group’s book equity; otherwise buffer capital held at the centre)

Performance measurement from 2008 (continued) z Business clusters target RoE %s used in setting hurdle rates (i.e. differentiated by cluster) z Reforecasts / revisions to targets: – Quarterly reforecasting process already in place – Capital p Management g Committee underpins p Group p Opcom p and ALCO – Agreement with business clusters to ‘take back’ or ‘allocate more’ capital depends on whether their request is EP enhancing to the Group – Clusters’ must manage target economic capital as requested per business plan no longer conveniently plan, con enientl based on act actual, al flfluctuating ct ating usage sage – Overs / unders to Group’s target capital not allocated (Group Capital Management’s responsibility to manage) 39

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