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      The finalisation of the Basel III framework - known as Basel IV - is imminent: on 27 October 2021, the European Commission presented the draft of an EU banking package that is to implement Basel IV into European law, including CRR III (Capital Requirements Regulation). The European Council (October 2022) and the European Parliament (January 2023) have now also published their positions, meaning that the final negotiations can begin.

      Basel IV is the collective term for regulatory changes to further develop the capital adequacy framework for banks in accordance with the requirements of the Basel Committee on Banking Supervision (BCBS). In addition to the general objective of ensuring financial stability, the finalisation of Basel III in the EU is also intended to strengthen the risk-based capital framework, focus on ESG risks and harmonise supervisory powers and instruments.

      While CRR II still had a moderate impact on the calculation of RWA (risk-weighted assets), CRR III will result in significant changes to RWA and capital requirements. For European banks in particular, it means potential changes in profitability, in the design of individual products and their pricing as well as in the implementation of significant requirements for IT and reporting solutions.

      The most important changes for institutions relate in particular to the requirements for calculating RWA for credit risk, operational risk, CVA risk (credit valuation adjustment) and, in some cases, market risk. The gradual introduction of the so-called output floor, which limits the possible relief effects of users of internal models on RWA, is also moving into focus. In future, they will have to apply all standardised approaches in parallel alongside the internal models.

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      Client Case

      In our client story, you will learn which factors are important for successfully implementing Basel IV in your company.

      Focus on Basel IV

      The so-called output floor has been introduced to reduce model risk and utilise room for manoeuvre. This limits the risk-weighted assets (RWA) calculated by the banks on the basis of internal models to a minimum percentage of 72.5% of the capital requirement calculated using the standardised approach. The gradual introduction of the output floor from 2025 will result in significantly higher minimum capital requirements, depending on how the institution is affected. Its effects can be mitigated by adequately mapping the output floor in overall bank management and preparatory RWA optimisation measures.

      Your contact

      Dr. David Nicolaus

      Senior Manager, Financial Services

      KPMG AG Wirtschaftsprüfungsgesellschaft

      Due to the high dependence on external ratings, lack of risk sensitivity and lack of comparability with the IRBA exposure classes, the CRSA was revised. However, it has retained its basic structure and must be applied by all institutions due to the output floor rule. The new regulations include adjustments to the assignment of exposure classes, changes to the risk weighting of real estate and specialised lending and simplifications to the CRMT framework. The impact on capital requirements varies greatly depending on the portfolio/business model and is associated with a variety of procedural challenges.

      Your contacts

      Thilo Kasprowicz

      Partner, Financial Services

      KPMG AG Wirtschaftsprüfungsgesellschaft

      Christian Heichele

      Partner, Advisory

      KPMG AG Wirtschaftsprüfungsgesellschaft

      As part of the new framework, the scope of application of internal credit risk models (IRBA) will be significantly restricted: for example, the use of the advanced IRB approach (A-IRB) will be limited with regard to certain exposure classes (including specialised lending). In addition, the methods for estimating the IRBA model parameters will be restricted. The removal of the so-called exit threshold, on the other hand, also opens up the possibility for new users to only benefit from internal models in Pillar 1 for parts of the loan portfolio. Existing users can rethink their modelling landscape.

      Your contacts

      Christian Heichele

      Partner, Advisory

      KPMG AG Wirtschaftsprüfungsgesellschaft

      Dr. Jürgen Ringschmidt

      Partner, Financial Services, Head of Credit Risk Management & Validation

      KPMG AG Wirtschaftsprüfungsgesellschaft

      The draft of a new framework for determining capital requirements for operational risks published by the Basel Committee in March 2016 replaces all existing measurement approaches. The new non-model-based calculation method (standardised measurement approach, SMA) is intended to ensure comparability across all institutions. The relevant business indicator is derived from balance sheet and income statement items that reflect special features in the commission, interest and trading business. Under the new standardised approach, requirements for the collection of loss data only apply for disclosure purposes for institutions with a business indicator of >EUR 750 million.

      Your contacts

      Markus Quick

      Partner, Financial Services

      KPMG AG Wirtschaftsprüfungsgesellschaft

      Daniela Klotzbach

      Senior Manager, Financial Services, Lead Specialist, Regulatory & Compliance

      KPMG AG Wirtschaftsprüfungsgesellschaft

      As part of CRR III, ESG reporting and ESG disclosure are facing a comprehensive upheaval: new requirements are standardising and expanding the existing reporting to the supervisory authority and the public. From 2025, all institutions will have to publish qualitative and quantitative information on ESG risks and mitigating measures in specific disclosure and reporting forms. Further adjustments relate, for example, to the consideration of energy efficiency measures in collateral for commercial and residential property. In addition, there will be more comprehensive disclosure requirements for exposures to companies operating in fossil fuel sectors.

      Your contacts

      Thilo Kasprowicz

      Partner, Financial Services

      KPMG AG Wirtschaftsprüfungsgesellschaft

      Daniela Klotzbach

      Senior Manager, Financial Services, Lead Specialist, Regulatory & Compliance

      KPMG AG Wirtschaftsprüfungsgesellschaft

      With the implementation of Basel IV, the framework for determining CVA risks will be revised again from 2025. The basic and standardised approaches will be updated and counterparty credit spread risks and the market risk of the portfolio will be taken into account.

      The new regulations as part of the Fundamental Review of the Trading Book (FRTB) also include a stricter separation of positions between the trading and banking book, the "arming" of a new standardised approach for market price risks and revised regulations on the use of internal models.

      Your contact

      Franz Lorenz

      Director, Financial Services

      KPMG AG Wirtschaftsprüfungsgesellschaft



      German banks particularly affected by the challenges

      German banks in particular will be heavily affected by these changes, as many rely to a large extent on internal models and their activities are often focussed on areas with previously lower risk weightings. Accordingly, the revised standards can often result in higher capital requirements and high implementation costs for the institutions.

      These include the development of new methods to comply with the new standards, compliance with the imposed disclosure requirements and the adaptation of systems and processes. Against the backdrop of strong competition within the sector and constant regulatory changes, institutions are facing major challenges overall - including when it comes to integrating the effects into pricing.

      Familiarisation with the new regulations at an early stage helps to assess the impact on risk-weighted assets and the resulting amount of regulatory capital that banks must hold under Basel IV. In particular, the internal processes in the banks and the interactions between the reporting units (including the reporting system) and the back office and credit departments must be strengthened and expanded.

      Our expertise

      KPMG is a market leader in supporting the implementation of Basel IV and CRR III requirements. We support our clients with detailed knowledge of Pillar 1 and Pillar 2 capital requirements and their interactions. Extensive experience in covering the broad range of topics and in-depth regulatory expertise (KPMG ECB Office) ensure customised solutions for your company on the way to implementing the banking package.

      We offer you established calculation and benchmarking tools from ongoing implementation projects to analyse the potential impact of RWA changes and potential design decisions. In addition, we bring proven tools, methods and EU-wide implementation experience for the best possible success to ensure the reporting capability of your bank under CRR III in high quality - including technical adjustments to the delivery routes - in the reporting system.


      Publication series

       

      We are pleased to provide you with a series of brochures on CRR III below.

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      CRR III – Neuerungen im Kreditrisiko-Standardansatz

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      Finalisierung des EU-Bankenpakets

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      EU-Bankenpaket und CRR III

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      CRR III als wesentlicher Teil des EU-Bankenpakets



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      Further publications

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      Aktualisierte Meldevorgaben durch die CRR III

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      Basel IV/CRR III

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      The Travel Rule - Transfer of Crypto Assets in Germany and the European Union


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