particularly ill-conceived accounting rules called the IFRS Standards. The rules
required banks to mark-to-market their balance sheets, creating unnecessary volatility
in the banks’ valuations and forcing them to recapitalize in most adverse market
conditions. The IFRS Standards created a terribly damaging pro-cyclical effect and
were an underrated guilty party in the financial crisis.
The history, merits and flaws of banking regulation go beyond the scope of this
book, but I encourage the interested reader to further explore the topic in order to under-
stand the macro dynamics of banking activity, which are driven in part – possibly in
large part – by reactions to regulatory rules and trends.
The crisis led to the reforms in Basel III but left operational risk rules untouched.
Since 2015, the Basel Committee has been working on a reform of pillar 1 capital
for operational risk. The standardized measurement approach (SMA) proposals have
generated numerous debates and criticisms since the first consultative document was
published in March 2016. I did not hide my reservations about the approach, which
I expressed in several articles published with like-minded peers.
1
Even though the
Basel Committee published in December 2017 the final regulatory revision including
the new SMA regime, this one remains the object of intense industry debates between
proponents and opponents. The SMA is a revised version of the standardized approach,
where regulatory capital for operational risk is equivalent to a percentage of the firm’s
gross income plus an optional penalty – down to national regulators – for firms with a
history of losses larger than the industry average.
Regardless of the reform, financial companies, especially the large ones, still
need to assess, measure and model their capital requirements for operational risk. This
chapter reviews the current structure of the regulatory capital requirements and some
of the essential concepts and practices of operational risk capital modeling.
P I L L A R 1 – R E G U L A T O R Y C A P I T A L
F O R O P E R A T I O N A L R I S K
S t a n d a r d i z e d A p p r o a c h
In standardized approaches, regulatory capital for operational risk is only determined
by the average yearly gross income of the institution over the last three years, recogniz-
ing the loosely positive relationship between operational risk and size. Gross income
is defined as the sum of the interest margin (interest received minus interest earned),
the fee income and other revenues.
1
The articles have been published as a collection in part 6 of the book
Reflections on Operational
Risk Management
, A. Chapelle, Risk Books, 2017.
80
RISK ASSESSMENT
T A B L E 8 . 1
Beta factors in the
standardized approach
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