A critical review of the Basel margin of conservatism requirement in a retail credit context

Abstract

The Basel II accord (2006) includes guidelines to financial institutions for the estimation of regulatory capital (RC) for retail credit risk. Under the advanced Internal Ratings Based (IRB) approach, the formula suggested for calculating RC is based on the Asymptotic Risk Factor (ASRF) model, which assumes that a borrower will default if the value of its assets were to fall below the value of its debts. The primary inputs needed in this formula are estimates of probability of default (PD), loss given default (LGD) and exposure at default (EAD). Banks for whom usage of the advanced IRB approach have been approved usually obtain these estimates from complex models developed in-house. Basel II recognises that estimates of PDs, LGDs, and EADs are likely to involve unpredictable errors, and then states that, in order to avoid over-optimism, a bank must add to its estimates a margin of conservatism (MoC) that is related to the likely range of errors. Basel II also requires several other measures of conservatism that have to be incorporated. These conservatism requirements lead to confusion among banks and regulators as to what exactly is required as far as a margin of conservatism is concerned. In this paper, we discuss the ASRF model and its shortcomings, as well as Basel II conservatism requirements. We study the MoC concept and review possible approaches for its implementation. Our overall objective is to highlight certain issues regarding shortcomings inherent to a pervasively used model to bank practitioners and regulators and to potentially offer a less confusing interpretation of the MoC concept