Basel II and the Crisis - 15 Recommendations to the Banks That (Sort Of) Use Stress Testing

Recommendations to banksinto account system-wide interactions and feedback
1. Stress testing should form an integral part of theeffects.
overall governance and risk management culture of9. Tests should be geared towards the events
the bank. It should be actionable, with the results fromcapable of generating most damage whether through
analyses impacting decision making at the appropriatesize of loss or through loss of reputation.
management level, including strategic businessA programme should also determine what scenarios
decisions of the board and senior management.could challenge the viability of the bank (reverse stress
Board and senior management involvement is essentialtests) and thereby uncover hidden risks and
for its effective operation.interactions among risks.
2. A bank should operate a stress testing programme10. As part of an overall programme, a bank should
that: promotes risk identification and control; provides aaim to take account of simultaneous pressures in
complementary risk perspective to other riskfunding and asset markets, and the impact of a
management tools; improves capital and liquidityreduction in market liquidity on exposure valuation.
management; and enhances internal and external11. The effectiveness of risk mitigation techniques
communication.should be systematically challenged.
3. Stress testing programmes should take account of12. The programme should explicitly cover complex
views from across the organisation and should coverand bespoke products such as securitised exposures.
a range of perspectives and techniquesTests for securitised assets should consider the
4. A bank should have written policies and proceduresunderlying assets, their exposure to systematic market
governing the programme. The operation of thefactors, relevant contractual arrangements and
programme should be appropriately documented.embedded triggers, and the impact of leverage,
5. A bank should have a suitably robust infrastructureparticularly as it relates to the subordination level in the
in place, which issufficiently flexible to accommodateissue structure.
different and possibly changing tests at an appropriate13. The programme should cover pipeline and
level of granularity.warehousing risks.
6. A bank should regularly maintain and update itsA bank should include such exposures in its tests
framework.regardless of their probability of being securitised.
The effectiveness of the programme, as well as the14. A bank should enhance its testing methodologies to
robustness of major individual components, should becapture the effect of reputational risk.
assessed regularly and independently.The bank should integrate risks arising from
7. Stress tests should cover a range of risks andoff-balance sheet vehicles and other related entities in
business areas, including at the firm-wide level. A bankits programme.
should be able to integrate effectively across the15. A bank should enhance its testing approaches for
range of its testing activities to deliver a completehighly leveraged counterparties in considering its
picture of firm-wide risk.vulnerability to specific asset categories or market
8. Programmes should cover a range of scenarios,movements and in assessing potential wrong-way risk
including forward-looking scenarios, and aim to takerelated to risk mitigating techniques.