SBN HOLDINGS LIMITED Annual Report 2022
ANNEXURE B - RISK AND CAPITAL MANAGEMENT continued
128
CREDIT RISK
SBN HOLDINGS LIMITED
Annual report 2022
Definition
Credit risk is the risk of loss arising out of the failure of obligors to meet their financial or
contractual obligations when due. It is composed of obligor risk (including borrowers and trading
counterparties), concentration risk and country risk.
Approach to managing and measuring
credit risk
The group's credit risk is a function of its business model
and arises from wholesale and retail loans and advances,
underwriting and guarantee commitments, as well as from the
counterparty credit risk arising from derivative and securities
financing contracts entered into with our customers and trading
counterparties. To the extent equity risk is held on the banking
book, it is also managed under the credit risk governance
framework, except in so far as approval authority rests with the
board risk committee (BRC). The management of credit risk
is aligned to the group's three lines of defence framework. The
business function owns the credit risk assumed by the group
and as the first line of defence is primarily responsible for its
management, control and optimisation in the course of business
generation.
The credit function acts as the second line of defence and is
responsible for providing independent and objective approval
and oversight for the credit risk-taking activities of business, to
ensure the process of procuring revenue, while assuming optimal
risk, is undertaken with integrity. Further second-line oversight is
provided by the group risk function through independent credit
risk assurance.
The third line of defence is provided by group internal audit (GIA),
under its mandate from the board audit committee (BAC).
Credit risk is managed through:
■ maintaining a culture of responsible lending and a robust risk
policy and control framework
■identifying, assessing and measuring credit risk across the
group, from an individual facility level through to an aggregate
portfolio level
■defining, implementing and continually re-evaluating risk
appetite under actual and stressed conditions
■monitoring the group's credit risk exposure relative to
approved limits
■ ensuring that there is expert scrutiny and approval of credit risk
and its mitigation independently of the business functions.
A credit portfolio limit framework has been defined to monitor
and control the credit risk profile within the group's approved risk
appetite. All primary lending credit limits are set and exposures
measured on the basis of risk weighting in order to best estimate
exposure at default (EAD). Pre-settlement counterparty credit
risk (CCR) inherent in trading book exposures is measured on a
potential future exposure (PFE) basis, modelled at a defined level
of confidence, using approved methodologies and models, and
controlled within explicit approved limits for the counterparties
concerned.
Credit risk mitigation
Wherever warranted, the group will attempt to mitigate credit
risk, including CCR to any counterparty, transaction, sector,
or geographic region, so as to achieve the optimal balance
between risk, cost, capital utilisation and reward. Risk mitigation
may include the use of collateral, the imposition of financial
or behavioural covenants, the acceptance of guarantees from
parents or third parties, the recognition of parental support, and
the distribution of risk.
Collateral, parental guarantees, credit derivatives and on- and
off-balance sheet netting are widely used to mitigate credit risk.
Credit risk mitigation policies and procedures ensure that risk
mitigation techniques are acceptable, used consistently, valued
appropriately and regularly, and meet the risk requirements
of operational management for legal, practical and timely
enforcement. Detailed processes and procedures are in place to
guide each type of mitigation used.
In the case of collateral where the group has an unassailable
legal title, the group's policy is such that collateral is required to
meet certain criteria for recognition in loss given default (LGD)
modelling, including that it:
■is readily marketable and liquid
■is legally perfected and enforceable
■has a low valuation volatility
■is readily realisable at minimum expense
■has no material correlation to the obligor credit quality
■has an active secondary market for resale.
The main types of collateral obtained by the group for its banking
book exposures include:
■mortgage bonds over residential, commercial and industrial
properties
■cession of book debts
■pledge and cession of financial assets
■bonds over plant and equipment
■the underlying movable assets financed under leases and
instalment sales.
Reverse repurchase agreements and commodity leases to
customers are collateralised by the underlying assets.
Guarantees and related legal contracts are often required,
particularly in support of credit extension to groups of
companies and weaker obligors. Guarantors include banks,
parent companies, shareholders and associated obligors.
Creditworthiness is established for the guarantor as for other
obligor credit approvals.
For trading and derivatives transactions where collateral support
is considered necessary, the group typically uses internationally
recognised and enforceable International Swaps and Derivatives
Association (ISDA) agreements, with a credit support annexure
(CSA).
Netting agreements, such as collateral under the CSA of an
ISDA agreement, are only obtained where the group firstly, has
a legally enforceable right to offset credit risk by way of such an
agreement, and secondly, where the group has the intention of
utilising such agreement to settle on a net basis.
Other credit protection terms may be stipulated, such as
limitations on the amount of unsecured credit exposure
acceptable, collateralisation if the mark-to-market credit
exposure exceeds acceptable limits, and termination of the
contract if certain credit events occur, for example, downgrade of
the counterparty's public credit rating.
Wrong-way risk arises in transactions where the likelihood of
default (i.e. the probability of default (PD) by a counterparty
and the size of credit exposure (as measured by EAD) to
that counterparty tend to increase at the same time. This
risk is managed both at an individual counterparty level and
at an aggregate portfolio level by limiting exposure to such
transactions, taking adverse correlation into account in the
measurement and mitigation of credit exposure and increasing
oversight and approval levels. The group has no appetite for
wrong-way risk arising where the correlation between EAD and
PD is due to a legal, economic, strategic or similar relationship
(i.e. specific wrong-way risk). General wrong-way risk, which
arises when the correlation between EAD and PD for the
counterparty, due mainly to macro factors, is closely managed
within existing risk frameworks.
To manage actual or potential portfolio risk concentrations in
areas of higher credit risk and credit portfolio growth, the group
implements hedging and other strategies from time-to-time. This
is done at individual counterparty, sub-portfolio and portfolio
levels through the use of syndication, distribution and sale of
assets, asset and portfolio limit management, credit derivatives
and credit protection.
Use of internal estimates
Our credit risk rating systems and processes differentiate and
quantify credit risk across counterparties and asset classes.
Internal risk parameters are used extensively in risk management
and business processes, including:
■setting risk appetite
■setting concentration and counterparty limits
credit approval and monitoring.
Corporate, sovereign and banking
portfolios
Corporate entities include large companies, as well as small
medium entities (SMEs) that are managed on a relationship basis.
Corporate exposures also include specialised lending (project,
object and commodity finance, as well as income-producing real
estate (IPRE) and public sector entities.
Sovereign and bank borrowers include sovereign government
entities, central banks, local and provincial government entities,
bank and non-bank financial institutions. The creditworthiness
of corporate (excluding specialised lending), sovereign and bank
exposures is assessed based on a detailed individual assessment
of the financial strength of the borrower. This quantitative
analysis, together with expert judgement and external rating
agency ratings, leads to an assignment of an internal rating to
the entity. Specialised lending's creditworthiness is assessed on
a transactional level, rather than on the financial strength of the
borrower, in so far as the group relies only on repayment from
the cash flows generated by the underlying assets financed.
Concentration risk management is performed to ensure that
credit exposure concentrations in respect of obligors, countries,
sectors and other risk areas are effectively managed. This
includes concentrations arising from credit exposure to different
entities within an obligor economic group, such as exposure to
public sector and other government entities that are related to
the same sovereign.
Credit portfolio characteristics and
metrics
Maximum exposure to credit risk
Debt financial assets at amortised cost and FVOCI as well as
off-balance sheet exposure subject to an ECL are analysed and
categorised based on credit quality using the group's master
rating scale. Exposures within stage 1 and 2 are rated between
1 to 25 in terms of the group's master rating scale. The group uses
a 25-point master rating scale to quantify the credit risk for each
borrower (corporate asset classes) or facility (specialised lending
and retail asset classes), as illustrated in the table below. These
ratings are mapped to PDs by means of calibration formulae that
use historical default rates and other data from the applicable
home services, VAF, card, personal, business lending and other
product portfolios. The group distinguishes between through-the-
cycle PDs and point-in-time PDs, and utilises both measures in
decision-making, managing credit risk exposures and measuring
impairments against credit exposures. Exposures which are in
default are not considered in the 1 to 25-point master rating scale.
Default
The group's definition of default has been aligned to its internal
credit risk management definitions and approaches. While the
specific determination of default varies according to the nature
of the product, it is generally determined (aligned to the Basel
definition) as occurring at the earlier of:
■where, in the group's view, the counterparty is considered to
be unlikely to pay amounts due on the due date or shortly
thereafter without recourse to actions such as the realisation
of security; or
■when the counterparty is past due for more than 90 days (or, in
the case of overdraft facilities in excess of the current limit).
The group will not rebut IFRS 9's 90 DPD rebuttable presumption.
A financial asset is considered to be in default when there is
objective evidence of impairment. The following criteria are used
in determining whether there is objective evidence of impairment
for financial assets or groups of financial assets:
■significant financial difficulty of borrower and/or modification
(i.e. known cash flow difficulties experienced by the borrower)
■a breach of contract, such as default or delinquency in interest
and/or principal payments
■ disappearance of active market due to financial difficulties
■it becomes probable that the borrower will enter bankruptcy or
other financial reorganisation
■where the group, for economic or legal reasons relating to the
borrower's financial difficulty, grants the borrower a concession
that the group would not otherwise consider.
Exposures which are overdue for more than 90 days are also
considered to be in default.
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