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Risk Management Program · CoreTrack
1Risk, Treasury & Financial Control
iRisk Foundations
Risk Appetite, Tolerance, Capacity…The Risk Taxonomy and UniverseRisk Register vs Risk MatrixStress TestingScenario Analysis vs Stress TestingImpact and LikelihoodLikelihoodThe Risk EventRisk Assessment
iiEnterprise Risk Management
Enterprise Risk ManagementThe Four Risk TreatmentsRisk CultureRisk MaturityRisk Monitoring
iiiRisk Governance
Risk GovernanceHow to set a…The Risk PolicyThe Risk OwnerThe Risk Committee and Its CharterThe Risk Limit FrameworkRisk EscalationHow to set a…
ivCredit and Counterparty Risk
Collateral AgreementsCollateral vs NettingProbability of DefaultExposureCounterparty ExposureConcentration Risk vs Wrong Way RiskCounterparty Risk vs Credit RiskHow to assess Counterparty ExposureHow to assess Concentration Risk
vMarket Risk
Market RiskSensitivity MeasuresThe Hedging PolicyInterest Rate Risk in the Banking BookIRRBB vs Market RiskExpected ShortfallEconomic Value of EquityVaR BacktestingOpen PositionValue at RiskValue at Risk and Expected ShortfallEconomic Value SensitivityFX ExposureValue at Risk vs Expected ShortfallEarnings at Risk vs…FX Transaction Risk vs…How to measure Interest…How to measure Foreign…
viLiquidity Risk
Liquidity Stress TestingLiquidity Gap vs Liquidity BufferMaturity MismatchThe Debt Maturity ProfileFunding ConcentrationSurvival HorizonThe Contingency Funding PlanNet Stable Funding RatioLiquidity Risk vs Funding RiskLiquidity Coverage RatioLiquidity Gap and BufferHow to run a Liquidity Gap Analysis
viiOperational Risk
Operational LossThe Loss EventRisk and Control Self AssessmentException ManagementInformation Security as a…Segregation of DutiesIssue ManagementThe Near MissRoot Cause Analysis in RiskThe Fraud TriangleCyber Risk vs Third Party RiskHow to run a…How to assess Third…
viiiRisk Reporting, Data and Model Risk
Model RiskModel Validation vs BacktestingHow to run Model ValidationData Governance in RiskModel Risk vs Data RiskKey Risk IndicatorsManagement InformationRisk ReportingRisk ScoreEarnings at RiskRisk Adjusted ReturnEarly Warning IndicatorsHow to build a KRI Dashboard
ixTreasury
Corporate TreasuryAsset Liability ManagementIntragroup FundingThe Treasury PolicyThe Treasury Management SystemThe Cash ForecastCash Pooling and ConcentrationHow to build a Cash Forecast
xFinancial Controls and Assurance
Control AssuranceThe Control LifecycleThe Assurance MapThe Audit FindingIssue RemediationInternal Financial ControlsControl Design vs Control EffectivenessHow to map Internal Financial ControlsHow to test Control…Control DeficiencyMaterial Weakness
xiOperational Resilience
Operational ResilienceBusiness Continuity and Disaster RecoveryBusiness Continuity vs Operational…Crisis ManagementDisaster RecoveryIncident Management

Risk Appetite, Tolerance, Capacity and Limits

Capacity is arithmetic: the most an institution could lose before it reaches its own capital floor. Appetite is a choice made inside capacity. Tolerance is a band around that choice. A limit is the cap given to the business, set below appetite on purpose. Profile is what actually happened. Here they run Rs 2,400 crore, Rs 900 crore, Rs 1,080 crore, Rs 810 crore and Rs 648 crore.

Four of these words get used as though they meant the same thing, and one of them, the profile, gets used as though it were a plan rather than a measurement. The confusion between the five words is not a vocabulary problem. Loose vocabulary is what lets an institution say it is comfortable when all it means is that it has not yet hit anything. The five words have to be settled before any exposure can be examined.

The five separate cleanly only when all five are stated on one number. The number is annual credit loss at Vindhya Commercial Bank Limited, an invented bank, chosen because five words need one scale to be held apart on. Credit risk and the other risk types are covered separately, and every figure below is one invented bank's own setting rather than a requirement of anybody.

Why are four words that sound like synonyms not synonyms?

Start with the everyday version. The bank version is the same shape at a larger scale. A household earns Rs 90,000 a month and, after everything that has to be paid, could survive a fall of Rs 24,000 a month before it starts missing an instalment. Nobody chose that Rs 24,000. The figure fell out of the income and the commitments. Because it wants room, the household then decides, sitting at the kitchen table, that it will not let its spending on anything uncertain go past Rs 9,000 a month. The household also agrees that Rs 10,800 in a bad month is survivable without a fresh conversation. The household tells the person who does the shopping that the cap is Rs 8,100. And at the end of the month, the figure actually spent was Rs 6,480.

Five numbers, five different kinds of thing. The first was computed, the second and third were decided, the fourth was granted to somebody, and the fifth was measured after the fact. The single most useful habit is asking of any risk number presented which of those four kinds it is. A computed number does not care whether anybody likes it. A decided number can be argued with. A granted number can be exceeded by somebody doing exactly the job they were told to do. A measured number can only be wrong if the measurement is wrong.

Four words, four claims, four different people

Now the same five at Vindhya Commercial Bank Limited, on one metric, with the mistake each pair invites. Confusing capacity with appetite makes a board think its own choice was forced on it. Confusing appetite with a limit makes a business think its cap is the whole of what the board will live with. Confusing tolerance with appetite removes the institution's ability to say whether a small overshoot needs anybody to do anything. And confusing the profile with any of the other four is how an institution ends up describing what it did as what it intended.

FIVE WORDS, ONE METRIC, AND A DIFFERENT KIND OF NUMBER IN EVERY COLUMN Annual credit loss at Vindhya Commercial Bank Limited, invented. Rs crore. Every figure is the bank's own. CAPACITY Rs 2,400 crore THE QUESTION IT ANSWERS How much could the bank lose before it reaches its own capital floor? WHO ANSWERS IT the balance sheet WHAT KIND OF NUMBER arithmetic HOW OFTEN IT MOVES when capital or risk weighted assets move APPETITE Rs 900 crore THE QUESTION IT ANSWERS How much is the bank willing to lose in a year? WHO ANSWERS IT the board WHAT KIND OF NUMBER a choice HOW OFTEN IT MOVES once a year, when it is approved TOLERANCE Rs 900 crore to Rs 1,080 crore THE QUESTION IT ANSWERS How far past that will the bank live with before anybody has to act? WHO ANSWERS IT the board, again WHAT KIND OF NUMBER a choice, as a band HOW OFTEN IT MOVES with appetite LIMIT Rs 810 crore THE QUESTION IT ANSWERS What cap does the business actually get? WHO ANSWERS IT the body that grants it WHAT KIND OF NUMBER an authorisation HOW OFTEN IT MOVES measured every day the business trades PROFILE Rs 648 crore THE QUESTION IT ANSWERS What is the bank actually carrying right now? WHO ANSWERS IT whoever measures it WHAT KIND OF NUMBER an observation HOW OFTEN IT MOVES at each reporting date Only the last column is a measurement. The first is a computation and the middle three are decisions somebody made.
The five figures at the invented bank on one metric, each with the question it answers and the person or process that answers it, showing that only the profile of Rs 648 crore is an observation while the other four are one computation and three decisions.
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What is risk capacity, and why is it arithmetic rather than a choice?

Risk capacityThe most an institution could absorb before it reaches its own floor, computed from capital rather than chosen. is the one figure in the set that nobody votes on. Capacity is the most an institution could lose in a year before its capital reaches a level it has decided it will not go below. Three inputs produce it, and once those three are fixed the answer is fixed with them. Capacity is therefore the right place to start: everything after it is a decision made inside a boundary that was already there.

Risk Capacity: worked from capital, risk weighted assets and the institution's own floor

At Vindhya Commercial Bank Limited the three inputs are total capital of Rs 9,000 crore, risk weighted assets of Rs 60,000 crore, and an internal capital floorThe lowest capital ratio an institution will allow itself to reach. Here it is set by the bank itself and is not a stated requirement of anybody. of 11.0 per cent that the bank set for itself. Eleven per cent of Rs 60,000 crore is Rs 6,600 crore, and that much capital is reserved before any loss is contemplated at all. The capital left over is Rs 9,000 crore less Rs 6,600 crore, or Rs 2,400 crore. The remaining Rs 2,400 crore is the bank's risk capacity on this metric, and no meeting produced it.

Little discretion sits inside it. The bank cannot argue with its own capital. The balance sheet states it. The same holds for its risk weighted assets. The only element it chose is the floor, and the floor is a policy about how close to the edge it is prepared to run rather than a view about lending. So the honest description is that capacity is arithmetic with one policy variable in it, and the simulation below moves exactly that variable and shows what happens.

CAPACITY IS WHAT IS LEFT OF CAPITAL ONCE THE FLOOR HAS TAKEN ITS SHARE Vindhya Commercial Bank Limited, invented. Rs crore. The 11.0 per cent floor is the bank's own and is not a requirement. TOTAL CAPITAL Rs 9,000 CRORE RESERVED BY THE BANK'S OWN INTERNAL FLOOR 11.0 per cent of Rs 60,000 crore of risk weighted assets = Rs 6,600 crore CAPACITY Rs 2,400 crore Rs 0 Rs 6,600 crore Rs 9,000 crore Nobody chose the green block. It is 9,000 less 6,600, and the only thing anybody decided in it is the floor of 11.0 per cent. Capacity is 26.7 per cent of total capital here, so almost three quarters of the capital is not available to absorb a loss at all.
Total capital of Rs 9,000 crore at the invented bank split by its own 11.0 per cent internal floor, leaving Rs 2,400 crore of risk capacity, which is 26.7 per cent of the capital and a figure no meeting produced.
Try it out

A colleague says the board set this bank's capacity at Rs 2,400 crore. What is wrong with that sentence?

What the capacity figure ignores, and by how much

Here is the part most treatments leave out, and leaving it out is worse than not giving the figure at all. The computation above holds risk weighted assets at Rs 60,000 crore while the loss is being taken. In life they would not stay there. When an exposure goes bad and is written off, it stops being an asset that carries a risk weight, so the denominator falls at the same time the capital does. A computation that moves only the numerator has understated how much loss the institution could actually take.

How much does it understate it by? Answering it needs an assumption the bank has not made, and an assumption that changes the answer has to be visible: suppose the exposure written off carried a risk weight of 100 per cent, so risk weighted assets fall rupee for rupee with the loss. Then the question becomes: what loss takes the ratio exactly to 11.0 per cent when both sides move? Solve 9,000 less the loss, over 60,000 less the loss, equal to 11.0 per cent. The solution gives 2,400 equal to 0.89 times the loss, so the loss is Rs 2,696.6 crore. Check it: Rs 6,303.4 crore of capital over Rs 57,303.4 crore of risk weighted assets is 11.00 per cent exactly.

So the locked Rs 2,400 crore is the conservative reading, and it is too low by about 12.4 per cent under that one stated assumption. The 12.4 per cent matters less as a number than as a habit. Knowing which direction a simplification errs in is most of what makes the simplification usable. A figure that ignores something and says so can be relied on in one direction. A figure that ignores something silently cannot be relied on in either. Rs 2,400 crore stays the bank's capacity throughout this guide; the Rs 2,696.6 crore is an illustration of what the simplification costs and is not a figure of the bank.

THE LOSS THAT REACHES THE FLOOR, COMPUTED TWO WAYS Rs crore. Both bars end where total capital over risk weighted assets equals the bank's own 11.0 per cent internal floor. RISK WEIGHTED ASSETS HELD AT Rs 60,000 CRORE the locked figure Rs 2,400 crore RISK WEIGHTED ASSETS FALLING WITH THE LOSS the illustrative assumption Rs 2,696.6 crore Rs 296.6 cr Check on the upper bar: 6,600 over 60,000 is 11.00 per cent. Check on the lower bar: 6,303.4 over 57,303.4 is also 11.00 per cent. The 100 per cent risk weight is an illustrative assumption and not the bank's. Rs 2,400 crore remains the bank's capacity figure.
The loss that reaches the invented bank's own 11.0 per cent floor is Rs 2,400 crore when risk weighted assets are held still and Rs 2,696.6 crore when they fall with the loss, so the locked figure understates capacity by 12.4 per cent under the stated assumption.
Try it out

The capacity computation holds risk weighted assets at Rs 60,000 crore while the losses are being taken. Does that make the Rs 2,400 crore too high or too low?

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What is risk appetite, and who decides it?

Now the choice. Risk appetiteThe amount and type of risk an institution says it is willing to take in pursuit of its objectives, decided rather than computed. is what a board says it is willing to lose, and at this bank it is Rs 900 crore a year on this metric. Every part of that sentence matters. A board says it, not a risk function and not a business. The figure is stated as an amount, so it can be tested. And it is a willingness rather than a forecast: nobody is predicting a Rs 900 crore loss, they are saying that if one arrived they would not consider the institution to have gone outside what it signed up for.

Risk Appetite: a choice made inside capacity, and the refusal is the statement

Rs 900 crore against capacity of Rs 2,400 crore is 37.5 per cent. Read that the other way round and the meaning turns over. The board has declined to use Rs 1,500 crore of its own capacity, being 62.5 per cent of it, and that refusal is the entire content of an appetite statement. A board that set appetite equal to capacity would have declined nothing, and would have written a document that says nothing at all. The interesting number was never the Rs 900 crore on its own. The fraction was the number all along.

And it genuinely was a choice. Rs 600 crore would have been inside capacity. So would Rs 1,200 crore. So would Rs 2,399 crore, uncomfortably. The board picked one point on a line where every point was available, and a reader who cannot see that line will read Rs 900 crore as though it had been handed down. It was not. Somebody sat in a room and argued for it, and somebody else argued for a different figure, and the minute of that meeting is where the reasoning lives.

Two warnings attach before the fraction is carried anywhere. First, 37.5 per cent of capacity is this invented bank's setting on one metric in one year and is not a normal, a benchmark or a target for anybody. Second, capacity itself moves, so the same appetite figure is a different fraction next year if capital or risk weighted assets change. The statement is a claim about a moment, and it is re-approved for that reason.

PRODUCED BY ARITHMETIC One answer. Nobody in the room can change it. Total capital Rs 9,000 crore Risk weighted assets Rs 60,000 crore The bank's own floor 11.0 per cent CAPACITY Rs 2,400 crore Change any input and the answer changes. Change nobody's mind and it does not. PRODUCED BY A DECISION Every point on this line was inside capacity. The board could have named any figure from zero to Rs 2,400 crore and still been inside capacity. CHOSEN: Rs 900 crore 0 600 900 1,200 2,400 Rs 1,500 crore declined 62.5 per cent of capacity
Capacity of Rs 2,400 crore falls out of three inputs, while appetite of Rs 900 crore is one point chosen from a line on which every point was available, and the Rs 1,500 crore shaded above it is the 62.5 per cent of capacity the board declined to use.
Try it out

The board set appetite at Rs 900 crore against a capacity of Rs 2,400 crore. What has it actually said?

What is risk tolerance, and why is it a band when appetite is a point?

Appetite gave one number. One number cannot answer what comes next: the loss for the year comes in at Rs 950 crore, Rs 50 crore past the stated appetite. Has anything happened? With only a point, the answer is either yes, in which case a fifty crore overshoot on a nine hundred crore statement triggers a board conversation, or no, in which case nobody knows how much past the point is allowed and the point means nothing. An institution that states only a point cannot tell a rounding error from a problem.

Risk Tolerance: a band around the appetite point

Risk toleranceThe range around the appetite point an institution will live with before it is obliged to act. is the answer to that. At this bank the tolerance runs from Rs 900 crore to Rs 1,080 crore, appetite plus 20.0 per cent, so the band is Rs 180 crore wide. Inside the band, the institution is somewhere it did not aim for and is willing to be, a different state from either being on target or being outside its statement. The Rs 950 crore year sits there: above the point, inside the band, and therefore a note in a paper rather than a decision by the board.

The household had this too, and it is worth naming because most people already run a band without calling it one. The kitchen table figure was Rs 9,000 a month, and Rs 10,800 in a bad month was survivable without a fresh conversation. Nobody wrote that down. The bank writes it down, and writing it down is the whole difference: an unwritten band is renegotiated every time it is tested, always downward in the moment and always upward in hindsight.

Two things this band is not. The band is not a second appetite. The institution is not indifferent between Rs 900 crore and Rs 1,080 crore, and the point remains where it wants to be. The band is not permission to run at the ceiling either. A position that lives at Rs 1,080 crore all year has quietly turned the band into the target, and turning the band into the target is the most common way a tolerance band stops doing its job.

A POINT IS ONE PLACE ON THE LINE. A BAND IS A STRETCH OF IT. Annual credit loss at the invented bank, Rs crore. Every figure is the bank's own and none is a requirement. TOLERANCE CEILING Rs 1,080 crore a position at Rs 950 crore above the point, inside the band 800 1,200 APPETITE Rs 900 crore, a point and the band starts here The band is Rs 180 crore wide, being appetite plus 20.0 per cent.
Appetite is one point at Rs 900 crore while tolerance is the Rs 180 crore stretch running to Rs 1,080 crore, so a position at Rs 950 crore is above the point and inside the band, which is a note rather than a decision.
Try it out

Appetite is a point. Tolerance is a what, and what does this bank's run to?

What is a risk limit, and why does it sit below appetite on purpose?

Everything so far has happened in a board room. A risk limitAn operational cap given to a business, expressed as a number somebody can measure against a position every day. is the first object in the set that a person at a desk can actually use. A limit is a cap, expressed in the same units as the thing being capped, granted to somebody named, and measured against a live position at a stated frequency. If any of those four is missing, what remains is a sentence rather than a limit.

Risk Limit: the operational cap the business is actually given

The limit on the metric at this bank is Rs 810 crore, or 90.0 per cent of appetite. Ask why it is not Rs 900 crore. The answer is what separates a limit from an appetite statement. A limit sits below appetite so that a business filling its cap is not, by that single act, a board breaching its own statement. A business at its cap and a board past its statement are two different failures, and an institution needs them to stay different sizes. One is an operational matter settled between a business and the body that granted the cap. The other is a board matter that reaches the appetite statement itself.

With the limit at Rs 810 crore, a business that runs all the way to its cap has consumed 90.0 per cent of appetite. There is still Rs 90 crore of the board's own statement intact, and beyond that a band running to Rs 1,080 crore. The institution has room to notice, ask, and decide, and none of that room exists if the two figures are the same number.

The word that appears next to every limit is utilisationWhat is actually running against a cap, stated as a percentage of the cap.. Utilisation is simply the position divided by the cap. At Rs 648 crore against Rs 810 crore this bank is at 80.0 per cent utilisation on the metric. Utilisation above 100 per cent is a breach. How a cap like this is derived from an appetite clause, who grants it, what happens the day it is crossed and how the excess is escalated are all a separate subject, covered by the material on risk governance and the limit framework.

Try it out

Why is the limit Rs 810 crore rather than Rs 900 crore, when appetite is Rs 900 crore?

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What is a risk profile, and how is it different from the other four?

The last of the five is the only one that is neither computed from the balance sheet nor decided by anybody. A risk profileThe risk actually being carried at a point in time, measured rather than decided. is the risk an institution is actually carrying, measured at a reporting date. At this bank the profile on the metric is Rs 648 crore.

Risk Profile: the only one of the five that is an observation

Say the four kinds out loud one more time. The profile is where they get mixed up most often. Capacity was computed. Appetite and tolerance were chosen. The limit was granted. The profile was measured, and a measurement can only be argued with by arguing about the measurement. Nobody can say the profile should have been lower; they can only say it was mismeasured, or that something should have been done earlier to make it lower.

Which is why the most useful thing to do with a profile is to state it against each of the other four rather than on its own. Rs 648 crore is 80.0 per cent of the limit, 72.0 per cent of appetite and 27.0 per cent of capacity. Three sentences, three different audiences. The business hears the first, the board hears the second, and anybody asking whether this institution is close to trouble hears the third. The same rupee figure answers all three because it is the only one of the five that is an observation about the world.

The trap is the sentence "our risk profile is Rs 900 crore" said by somebody who means the appetite. The substitution happens constantly, it sounds harmless, and it converts an intention into a fact. An institution that describes what it did as what it intended has lost the only figure in the set that could have told it it was wrong.

Try it out

Which of the five figures is an observation rather than a decision, a grant or a computation?

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How do the four words differ when they are put side by side?

Risk Appetite vs Tolerance vs Capacity vs Limit: the question each answers and the person who answers it

Definitions read one at a time always sound compatible. Put them in one table and the differences stop being shades of meaning. Read the table by column rather than by row: the column that separates these four fastest is not the figure and not the definition, it is who is entitled to change it.

WordThe figure hereThe question it answersWho can change itWhat it is
CapacityRs 2,400 croreHow much could the bank lose before it reaches its own floor?Nobody directly. Only capital, risk weighted assets or the floorArithmetic
AppetiteRs 900 croreHow much is the bank willing to lose in a year?The board, at approvalA choice
ToleranceRs 900 to 1,080 croreHow far past that will the bank live with before anybody must act?The board, with appetiteA choice, stated as a band
LimitRs 810 croreWhat cap does the business actually get?The body that grants itAn authorisation
ProfileRs 648 croreWhat is the bank carrying right now?Nobody. It is measuredAn observation

Three pairings are worth saying out loud because each is a real confusion with a real cost. Capacity against appetite is arithmetic against a decision, and running them together makes a board believe its own choice was imposed, removing the reason to revisit it. Appetite against a limit is a statement against an authorisation, and running them together makes a business believe its cap is the whole of what the institution will bear. Tolerance against appetite is a band against a point, and running them together leaves the institution unable to say whether a small overshoot needs anybody to do anything at all.

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How do the five figures nest inside each other?

With all five set on one scale, the nesting is the object worth carrying away. Rs 648 crore of profile sits inside a Rs 810 crore limit, the limit inside a Rs 900 crore appetite, appetite inside a tolerance ceiling of Rs 1,080 crore, and the ceiling inside Rs 2,400 crore of capacity. Every gap on that ladder is a real distance and each one was put there by a different person for a different reason.

Read it downward and it is a series of deliberate narrowings. Read it upward and the ladder becomes a set of multiples, the form a board can actually use: the limit is 1.25 times the profile, appetite is 1.111 times the limit, the tolerance ceiling is 1.20 times appetite, and capacity is 3.70 times the profile. The last multiple is the single most useful sentence the ladder produces: this year would have to be 3.70 times worse before capital reached the floor the bank set for itself. A gap of Rs 1,752 crore says the same thing and travels badly. The gap stops being comparable the moment the balance sheet grows. The multiple keeps working.

One caution about the picture below, and it is the reason the note is drawn on it. The five figures are five stated points. Nothing in between them is a graded zone: this bank has not published a scale of comfort running from Rs 648 crore to Rs 2,400 crore, and a ladder like this invites the reader to imagine one. The white space between two rungs is a distance, not a rating.

THE NESTED CHAIN ON ONE METRIC, ANNUAL CREDIT LOSS, Rs CRORE Vindhya Commercial Bank Limited, invented. All five figures are the bank's own and none of them is a requirement. CAPACITY arithmetic Rs 2,400 crore Rs 1,500 crore of capacity the board declined TOLERANCE a band, not a bar Rs 900 crore to Rs 1,080 crore APPETITE a choice Rs 900 crore, 37.5 per cent of capacity LIMIT an authorisation Rs 810 crore, 90.0 per cent of appetite PROFILE an observation Rs 648 crore, 80.0 per cent of the limit Rs 0 Rs 2,400 crore The bank states these five figures and nothing between them: the space between two rows is a distance, not a grading. No scale of comfort runs from Rs 648 crore to Rs 2,400 crore, and this figure does not draw one. Reading up: the limit is 1.25 times the profile and appetite is 1.111 times the limit. The tolerance ceiling is 1.20 times appetite, and capacity is 3.70 times the profile.
The five figures nested on one scale, with the profile of Rs 648 crore inside a Rs 810 crore limit inside Rs 900 crore of appetite inside a Rs 1,080 crore ceiling inside Rs 2,400 crore of capacity, and the Rs 1,500 crore the board declined shaded on the top row.
Try it out

The profile is Rs 648 crore and capacity is Rs 2,400 crore. How much worse would the year have to be before capital reached the bank's own floor?

There is one loose thread left in the ladder, and it is the floor. Capacity looked like a fact about the institution, but the only element of it anybody chose was the 11.0 per cent the bank set for itself. So what does the ladder look like if that one number moves? Predicting the answer before the control is touched is where the learning is.

Try it out

The bank's internal capital floor is 11.0 per cent and its capacity is Rs 2,400 crore. Before the control below is moved: what happens to capacity if the floor rises to 12.0 per cent?

Play with it

Move the bank's own capital floor and watch capacity fall through the chain

Total capital stays at Rs 9,000 crore and risk weighted assets stay at Rs 60,000 crore. Only the floor moves. The four tiles below are the fixed chain figures: the profile of Rs 648 crore, the limit of Rs 810 crore, appetite of Rs 900 crore and the tolerance ceiling of Rs 1,080 crore. A tile reads covered while capacity is still large enough to absorb that figure.

INTERNAL FLOOR 11.00 PER CENT
RISK CAPACITY AT THE SELECTED FLOOR Capacity is Rs 9,000 crore of total capital less the floor applied to Rs 60,000 crore of risk weighted assets. Rs crore. Every figure is the invented bank's own and none is a requirement of anybody. Rs 2,400 crore the four chain figures, Rs 648 crore to Rs 1,080 crore, shown as tiles below 0 1,050 2,100 3,150 4,200 PROFILE Rs 648 crore COVERED LIMIT Rs 810 crore COVERED APPETITE Rs 900 crore COVERED TOLERANCE CEILING Rs 1,080 crore COVERED
Internal floor
11.00 per cent
Risk capacity
Rs 2,400 crore
Capacity over appetite
2.67 times

At an internal floor of 11.00 per cent, this bank's capacity is Rs 2,400 crore, which is 2.67 times its appetite of Rs 900 crore, and it covers all four figures in the chain.

Educational illustration. Invented figures throughout. The 11.0 per cent floor is the bank's own choice, not a minimum set by anybody. The computation holds risk weighted assets at Rs 60,000 crore while the loss is taken, so it carries the same simplification already named above and understates capacity in a known direction. Every 1.0 percentage point on the floor is 1.0 per cent of Rs 60,000 crore, being Rs 600 crore of capacity: at 10.0 per cent capacity is Rs 3,000 crore, at 11.0 per cent Rs 2,400 crore and at 12.0 per cent Rs 1,800 crore.

Five crossings are worth writing down, and every one of them is exact rather than rounded. Capacity equals the tolerance ceiling of Rs 1,080 crore at a floor of 13.20 per cent, appetite of Rs 900 crore at 13.50 per cent, the limit of Rs 810 crore at 13.65 per cent, the profile of Rs 648 crore at 13.92 per cent, and reaches zero at 15.00 per cent. The last crossing deserves a second look. The bank's actual total capital ratio is 15.0 per cent. So a bank that set its internal floor at the ratio it happens to be running today would have written itself a capacity of nothing at all, and every figure in the chain below it would be outside what the balance sheet could absorb. A floor is a decision about how much room an institution wants, and setting it flush against where it is standing leaves none.

CAPACITY IS A STRAIGHT LINE IN A NUMBER THE INSTITUTION SETS FOR ITSELF 0 1,000 2,000 3,000 4,000 CAPACITY, Rs CRORE 1 2 3 4 5 8.0 9.0 10.0 11.0 12.0 13.0 14.0 15.0 THE BANK'S OWN INTERNAL TOTAL CAPITAL FLOOR, PER CENT THE FIVE CROSSINGS, ALL EXACT 1 13.20 per cent capacity equals the tolerance ceiling of Rs 1,080 crore 2 13.50 per cent capacity equals appetite of Rs 900 crore 3 13.65 per cent capacity equals the limit of Rs 810 crore 4 13.92 per cent capacity equals the profile of Rs 648 crore 5 15.00 per cent capacity is zero, and 15.00 per cent is this bank's current total capital ratio
Capacity falls in a straight line of Rs 600 crore for every percentage point added to the bank's own internal floor, crossing the tolerance ceiling at 13.20 per cent, appetite at 13.50, the limit at 13.65, the profile at 13.92 and zero at 15.00 per cent.
Ratio Analysis That Says Something teaches you to choose ratios that answer a question rather than fill a template.

What does an appetite statement look like when it is written down?

An appetite statementThe written document in which a board records what it is willing to be exposed to, clause by clause. is not a paragraph of intent. A statement is a numbered list of testable sentences. The statement at this bank runs to eight clauses, A1 to A8, and the useful thing about seeing them laid out is how ordinary they look: each names a subject, states a threshold in a unit somebody can measure, and sits beside the position the bank is actually at.

The test of a clause is whether anybody could tell, today, whether it is being met. Every one of these eight passes that test, and passing is the minimum rather than the achievement. Notice that they are not all in rupees: one is in days, one is in percentage points of advances, one is a survival period, and one is about a reporting obligation. An appetite statement is not a single number and never was. The clauses are one document because each says the same kind of thing: how much of one exposure the institution is willing to carry, in whatever unit that exposure is naturally measured in.

THE APPETITE STATEMENT AS AN ARTEFACT: EIGHT NUMBERED, TESTABLE SENTENCES Vindhya Commercial Bank Limited, invented. Every threshold and position is the bank's own and none is a requirement of anybody. CLAUSE SUBJECT WHAT THE CLAUSE CLAIMS CURRENT LIMIT BENEATH A1 capital Total capital ratio stays above the bank's own 11.0 per cent floor 15.0 per cent none A2 earnings volatility Net interest income does not fall by more than Rs 360 crore minus Rs 336 crore limit L8 A3 counterparty concentration No one borrower group above 60.0 per cent of tier 1 capital 80.0 per cent used limit L2 A4 sector concentration No one sector above 12.0 per cent of gross advances 13.0 per cent limit L3 A5 asset quality Gross non-performing assets stay below 3.5 per cent of advances 3.0 per cent none A6 liquidity Survives thirty days of the bank's own severe scenario 34 days none A7 operational loss Net operational loss below Rs 60 crore over rolling twelve months Rs 43.8 crore limit L11 A8 conduct Any breach of a statutory obligation reported within 5 working days in force none Four clauses carry a limit beneath them and four do not, which is the subject of the next block. Each threshold is stated in a unit somebody can measure, which is the minimum a clause has to be.
The eight clauses A1 to A8 of the invented bank's appetite statement, each naming a subject, a measurable threshold and the current position, with four of the eight carrying a limit beneath them and four carrying none.
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What can an appetite statement not do?

Three things, and the first one is arithmetic that can be checked on the artefact above. Of the eight clauses, four carry a limit beneath them and four do not. A2 sits above limit L8, A3 above L2, A4 above L3 and A7 above L11. A1 on capital, A5 on asset quality, A6 on liquidity and A8 on conduct have nothing beneath them at all. So on half its own clauses, this board's statement is measured when the board next meets and at no other time. The gap is not the same as nobody looking at capital or liquidity; it means no cap, granted to anybody, is being read against those four clauses between meetings.

The second thing it cannot do is cover what cannot be measured. A clause has to be testable to be a clause, so anything that resists measurement never enters the document. Frank Knight drew the line this depends on in Risk, Uncertainty and Profit in 1921, separating the risk that can be given a number from the uncertainty that cannot, and an appetite statement lives entirely on the first side of it. Clause A8 shows the craft involved: an institution cannot measure whether it has a tolerance for a conduct failure, so it writes down something it can measure instead: any such breach reaches the board's risk committee within 5 working days. The substitute clause is honest work, and it carries a warning inside it. The proxy is what gets managed, so the choice of proxy is a decision about behaviour and not a formatting detail.

The third thing is the simplest. A statement cannot stop anything. The statement is one sentence in a document approved once a year. A position stops growing only against a cap that somebody measures against a live number and has to explain when it is crossed. Frequency rather than size is where the difference shows: the five objects are not read at the same rate, and the gaps in the reading are where an institution loses sight of itself.

THE FIVE ARE NOT READ AT THE SAME RATE, AND THAT IS THE POINT Twelve numbered months at the invented bank. Each mark is one reading of that figure. CAPACITY with capital and assets changes whenever either input changes, which is not on a calendar at all APPETITE approved once a year TOLERANCE moves with appetite LIMIT every business day PROFILE at each reporting date 1 2 3 4 5 6 7 8 9 10 11 12 The two rows with one mark each are the board's own words. The row with the most marks is the only one a person at a desk uses. Marks show frequency and not a count of readings: the limit row stands for every business day of the year. The annual approval is drawn at month 12 because that is this bank's reporting date.
Appetite and tolerance are set once at month 12 and read again only at the next approval, while the limit is measured on every business day and the profile once a month, so the board's own words are the least frequently tested objects in the set.
Try it out

The bank's appetite statement has eight clauses and only four of them have a limit beneath them. What follows?

The limit set at appetite, and the day it costs something

Suppose this bank had given the business a limit of Rs 900 crore rather than Rs 810 crore, on the reasonable-sounding argument that appetite is Rs 900 crore so why hold anything back. Nothing changes on any ordinary day. The profile is Rs 648 crore and sits comfortably inside either figure, every report reads the same, and for as long as nothing is tested the two designs are indistinguishable.

The failure appears only on the day the business fills its cap, and then it appears all at once. With the limit at Rs 810 crore, a business running at its authorisation has consumed 90.0 per cent of appetite: the board still holds Rs 90 crore of its own statement, and a band beyond that running to Rs 1,080 crore. Somebody can ask a question, and the answer can be no, and nothing has yet gone outside anything the board said. With the limit at Rs 900 crore, a business that has done exactly what it was authorised to do has taken the institution to the precise edge of what the board said it was willing to lose, and the first rupee past the authorisation is also the first rupee past the appetite statement.

The cost is exactly Rs 90 crore, being 10.0 per cent of appetite, and what it buys is the ability to tell a small problem from a large one. A limit equal to appetite has not made the business tighter. Setting the cap at appetite has collapsed two different failures into one event, so the institution now finds out about both at the same moment and has to treat a routine operational excess as a board matter or a board matter as a routine excess. The institution will do one or the other, and neither is what it wanted.

AS THIS BANK SET IT: LIMIT Rs 810 CRORE IF THE LIMIT HAD BEEN SET AT APPETITE Rs 90 crore of room profile Rs 648 cr limit Rs 810 cr appetite Rs 900 cr ceiling Rs 1,080 cr no room at all profile Rs 648 cr limit and appetite, both Rs 900 cr ceiling Rs 1,080 cr On the left, a business at its cap has used 90.0 per cent of appetite and two different failures are still two different sizes. On the right, the first rupee past the authorisation is also the first rupee past the board's own statement. Both scales run from Rs 600 crore to Rs 1,150 crore.
Setting the limit at Rs 810 crore leaves Rs 90 crore between an operational excess and a breach of the board's statement, while setting it at appetite collapses the two marks onto one point and removes the institution's ability to tell the two failures apart.
Four appetite clauses carry nothing beneath them. See what a cap does.

Who actually reads these five figures, and what do they do with them?

Different people read different rungs, and most of them never see the whole ladder. Knowing which rung somebody is standing on is what tells the reader what their sentence means.

A board member reads the profile against appetite and asks for one multiple. Rs 648 crore against Rs 900 crore is 72.0 per cent, a comfortable-sounding sentence and, on its own, almost useless. The other question earns its place in the meeting: how much worse would the year have to be before capital reached the bank's own floor? The answer, 3.70 times, survives the balance sheet growing, survives a change of scale and can be asked again next year against a different set of figures.

A business head reads utilisation against the limit and, in most institutions, never sees capacity at all. Rs 648 crore against Rs 810 crore is 80.0 per cent, and the relevant fact for that reader is how much room is left before an authorisation is exhausted. Seeing only the cap is exactly as it should be. The gap between the limit and appetite has to exist for that reason: a reader who only ever sees the cap has no way of knowing how much of the institution's own statement their cap represents.

An analyst outside the institution cannot see any of these figures, and can still test the document. Where a bank publishes the shape of its appetite statement, the testable questions are whether each clause is stated in a unit somebody could measure, whether a current position is given beside it, and whether anything at all sits underneath it between board meetings. A statement of eight clauses where four have nothing beneath them tells an outside reader something real about how the institution runs, and it does so without a single confidential number changing hands.

And the same five objects exist wherever somebody is deciding how much of something they are willing to carry. Nirjhar Industries Limited, invented, the steel and alloys maker that is this bank's largest single exposure, runs its own treasury with caps of exactly this kind: TL1 holds exposure to any one bank to Rs 180 crore and TL5 requires at least Rs 120 crore of liquidity at all times. TL1 and TL5 are limits in precisely the sense settled above, granted to a named treasurer and measured against a live position, and how a corporate treasury sets and runs them is covered separately. The household from the opening of this guide has all five as well. The household never writes the fourth one down, and that is why the person doing the shopping renegotiates it every month.

India

What is named here, and where the binding version lives

Total capital of Rs 9,000 crore, risk weighted assets of Rs 60,000 crore, the 11.0 per cent floor, the eight clauses A1 to A8, the limits named as L2, L3, L8 and L11, and all five figures in the chain belong to Vindhya Commercial Bank Limited alone, and not one of them is a requirement set by anybody. The 11.0 per cent floor in particular is the bank's own internal choice about how much room it wants and is not a minimum set by anybody.

The idea that capital is measured against risk weighted assets, and the standards behind how that measurement works, originate with the Basel Committee on Banking Supervision at the Bank for International Settlements, bis.org. Naming only the global standard is the confident and common error. A standard is not what binds an Indian bank. What actually binds a bank in India on capital, including what counts as capital, how risk weighted assets are computed and what ratio must be held from what date, comes from the Reserve Bank of India at rbi.org.in.

The fractions used here, including 37.5 per cent of capacity as appetite and 90.0 per cent of appetite as a limit, are one invented bank's settings on one metric in one year rather than a normal for anybody. The binding ratios, minimums, buffers and effective dates sit in the Reserve Bank of India's own directions, and only those directions state them.

Capacity, appetite, tolerance, a limit and a profile are settled above, along with where each sits relative to the others. How a limit framework cascades from an appetite clause down to a desk, who grants each limit, what a risk policy contains, who the risk owner is, what a committee charter says, how an excess is escalated and what happens the day a limit is crossed are all the subject of the material on risk governance and the limit framework. Holding every risk type in one view, the four ways of treating a risk, culture, maturity and monitoring are covered separately. Credit, market, liquidity and operational risk are four separate subjects covered elsewhere; the credit loss metric appears only because five words need one scale to be held apart on. Instruments are named and explained separately, and how capital adequacy itself is computed sits outside this material entirely.

Sources

SourceDocumentSite
Reserve Bank of IndiaWhat actually binds a bank in India on capital, risk weighted assets and risk management arrangementsrbi.org.in
Bank for International SettlementsThe Basel Committee standards behind measuring capital against risk weighted assets, named as the origin of the mechanismbis.org
Frank KnightRisk, Uncertainty and Profit, 1921, where measurable risk is separated from the uncertainty that cannot be measuredHoughton Mifflin

Vindhya Commercial Bank Limited and Nirjhar Industries Limited are invented.
Educational material. Not advice on any investment, tax, budget or market position.

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