Bassabikova Margarita, Smoleyeva Ludmila (Kazakh-British Technical University)

“Risk Management in the 2nd tier banks of Kazakhstan

Abstract.

The research is devoted to the consideration of risk management techniques employs in the 2nd tier banks in Kazakhstan. The information obtained via questionnaires and interviews covers both philosophy and practice of financial risk management. The current research outlines the standard current practices used by management and tries to analyse why a certain techniques is employed.

Introduction

For the recent years, Kazakhstan has demonstrated solid singes of the successful economic development. Indeed, according to the official statistics, the GDP growth was 10, 5% for year 2006 (URL: www.wikipedia.com) and 9.7% for the half of 2007. (URL: www.caucaz.com) In order to sustain so rapid growth, that might be compared with other emerging countries, such as China, Malaysia, etc. the Republic has to have a developed financial market, in general, and a banking sector, in particular.

The past decade has seen dramatic losses in the banking industry. Firms that had been performing well suddenly announced large losses due to credit exposures that turned sour, interest rate positions taken, or derivative exposures that may or may not have been assumed to hedge balance sheet risk. In response to this, commercial banks have almost universally embarked upon an upgrading of their risk management and control systems.

Regardless of the sophistication of the measures, banks often distinguish between expected and unexpected losses. Expected losses are those that the bank knows with reasonable certainty will occur (e.g., the expected default rate of corporate loan portfolio or credit card portfolio) and are typically reserved for in some manner. Unexpected losses are those associated with unforeseen events (e.g. losses experienced by banks in the aftermath of nuclear tests, losses due to a sudden down turn in economy or falling interest rates, etc.) (Alexander, 2002).

The risk is the integral characteristic of bank activity. It plays a defining role in formation of financial bank activity results, serves as an important characteristic of bank assets and liabilities quality, and, thus, should be used in the comparative analysis of their financial condition and its position in the bank services market. Bank risk is the uncertainty in the relation of future cash flows, possibility of losses or limited gains in comparison with expected and the probability of unexpected expenses occurrence while realization of banking operations, presented in cash equivalents (Saunders, 1996).

Risk Management is a discipline at the core of every financial institution and encompasses all the activities that affect its risk profile. It involves identification, measurement, monitoring and controlling risks. The acceptance and management of financial risk is inherent to the business of banking and banks’ roles as financial intermediaries. Risk management as commonly perceived does not mean minimizing risk; rather the goal of risk management is to optimize risk-reward tradeoff (Ibid.). Notwithstanding the fact that banks are in the business of taking risk, it should be recognized that an institution need not engage in business in a manner that unnecessarily imposes risk upon it: nor it should absorb risk that can be transferred to other participants. Rather it should accept those risks that are uniquely part of the array of bank’s services. Originally, banks only accepted deposits, they have quickly ripened, becoming intermediaries in means transfer, and have taken up other risks, for example credit. The credit became a basis of banking activity and the one that the bank was judged about the quality and work by. The special attention is devoted to managerial credit risk process, because the success of bank’s performance depends on its quality. The principal cause of banks’ bankruptcies all over the world was a poor quality of assets.

The development of banking system should focus on such an issue, as the presence of variety of risks. The money market concerns with the circulation sphere, and modern Kazakhstani commercial banks are the most active and mobile part there. Commercial banks are professional participants in the financial market and in various sectors. Banks aspire to keep the reached level of profitability, therefore first of all they are anxious about the problems a rational combination of profitability, liquidity and minimization of risks. Commercial banks form not only the market of credits, a securities market and the currency market of the country, but also take part in creation and functioning of commodity, share and currency stock exchanges. They are owners of the available information about a financial position of the enterprises and the organizations, a conjuncture of the share, credit and currency markets of Kazakhstan.

As the activity experience of the largest, dynamic and profitable credit institutes of Kazakhstan shows, their profitable work is based on following major factors:

·   flexible market strategy;

·   high reliability;

·   constant improvement of service quality (Lavrushin, 1995:37).

The expansion of clientele, increase of competitiveness and growth of financial results are substantially promoted to grant more preferential conditions for clients of settlement-cash service, opening of some new branches, commercial banks’ organizational structure optimization, new bank products introduction, active work with commercial banks’ actions on a secondary securities market, carrying out of successful operations with the state securities and in the market of short-term credits.

The credit stimulates the development of productive forces, accelerates formation of the capital sources for reproduction expansion. It is impossible to provide the fast and civilized establishment of facilities, enterprises, introduction of other kinds of enterprise activity on interstate and external economic space without credit support. On the other hand, crediting is connected with the certain risk, especially under conditions of developing market economy. In literature reviews two types of risk is considered: 1) unary risk (where any activity is considered separately); 2) portfolio risk (where the activity is a part of a portfolio) (Alexander, 2002:19). Another point that only portfolio risks exist aspires banks to diversify their assets; therefore it is impossible to consider each activity separately.

It is known, that the key elements of efficient control are: well developed credit policy and procedures; good portfolio management; an effective credit control; and, that is the most important - well trained personnel. Banks and similar financial institutions need to meet forthcoming regulatory requirements for risk measurement and capital. However, it is a serious mistake to think that meeting regulatory requirements is the one or the most important reason for establishing a sound, scientific risk management system. Managers need reliable risk measures to assign direct capital to activities with the best risk/reward ratios. They need estimates of the size of potential losses to stay within limits imposed by required level of liquidity, by creditors, customers, and regulators. They need mechanisms to monitor positions and to create incentives for prudent risk-taking by divisions and individuals.

The main objectives of the research are:

·   to find out what types of risks are considered by the Kazakhstani banks;

·   risks, which are the most typical for our banks;

·   what is undertaken by the management to mitigate or eliminate these risks.

In addition, the emphasis is made on risk management techniques, applied by the banks.

The backbone of the work is a survey of banks of Kazakhstan on the matter of risk management and techniques used for risk prevention or at least its limitation. The work represents a qualitative research that is characterized by an emphasis on describing, understanding, and explaining complex phenomena – banking risks management and the context in which risks occur. The focus is on understanding the full multi-dimensional, dynamic picture of the subject. The survey was conducted in the form of a questionnaire that was sent out to thirty three banks of Kazakhstan. In addition to the survey, a comprehensive analysis of the banking risk management theory was conducted with the help of the interviews.

Risk classification

The leading principle in commercial banks’ activity is the aspiration of greater profit reception. Thus, the size of possible profit is directly proportional to risk (Gitman, 2003). Risks in banking sphere are an opportunity of bank’s losses due to occurrence of certain adverse events. Similar risks can be as bank’s ones, connected with the credit organization functioning, and as external. Acceptance of risks is a basis of banking sphere. Banks are successful when risks, accepted by them, are reasonable, controllable, are within the limits of their financial opportunities as well as competence.

There are three leading criteria, which banks consider in the process of their activity: liquidity, profitability and safety (Lavrishin, 1995). In practice, banks are based on the identical importance of these three criteria or assume maximization of profit at maintenance of liquidity and the safety account as a basis. The maintenance, classification, and methods of the analysis are constantly exposed to changes in connection with constant change of market structure, an aggravation of competition, fluctuation of interests, caused by the external factors, amplifying clients’ requirements, etc. During their operations, banks face various types of risks, which differ by a place and time of occurrence; external and internal factors that influence their magnitude; way of risk analysis and methods of their description. Besides, all kinds of risks are interconnected and influence a bank’s activity. Change of one type of risk causes change of almost all others. That complicates analysis of method choice at a concrete risk level.

In the research it was suggested that the risk level increases, if:

·    problems arise suddenly and contrary to expectations;

·    the new tasks mismatching the last bank’s experience;

·    management is not able to take necessary and urgent measures that can lead to financial damage (deterioration of necessary reception opportunities and\or additional profit);

·     existing rules of bank’s activity or the legislation imperfection hind to some optimum measures acceptance for a concrete situation.

Consequences of incorrect risks estimations or absence of an opportunity, along with effective methods, may be the most unpleasant down to full bankruptcy of a bank. Therefore, analysing risks of the Kazakhstani banks at the present stage, it is important to consider:

·    destabilization of real estate market;

·    increase in mortgage and consumer credits;

·    absence or imperfection of some basic acts, discrepancy between legal base and really existing situation;

·    inflation, etc.

Bank risks cover all banks’ activities: external as well as internal. Usually, external risks consist of:

• Country risk;

• Legal risk;

• Social risk;

• Risk of competition;

• Branch risk ( Saunders, 1996:62).

Internal risks result from a bank’s activity and depend on operations, performed by it, and are connected with:

• bank’s assets (credit & currency market, settlement, leasing, factoring, cash, etc.);

• bank’s liabilities (risks on depositary operations);

• bank’s quality management of its assets and liabilities (interest rate risk, risk of unbalanced liquidity);

• a process of financial service realization (operational risks, technological risks, personnel risks) (Ibid.)

As bank’s activity inherently assumes a “game” on interest rate changes, exchange rate, etc., none of the mentioned above risks can be eliminated completely. Therefore, the primary goal of the bank is an achievement of an optimum combination of risk and return.

The risks associated with the bank's principal activities, i.e., those involving its own balance sheet and its basic business of lending and borrowing, are not all borne by the bank itself. In many instances the institution will eliminate or mitigate the financial risk associated with a transaction by proper business practices. In others, it will shift the risk to other parties through a combination of pricing and a product design.

The banking industry recognizes that an institution does not need to be engaged neither in business with that unnecessarily imposes risk, nor should it absorb risk that can be efficiently transferred to other participants. Rather it should only manage risks at the firm’s level that are more efficiently managed there than by the market itself, or by their owners in their own portfolios. In short, banks should accept only those risks that are uniquely a part of the bank's array of service. It is argued that risks facing all financial institutions can be segmented into three separable types, from a management perspective. They are risk that can be:

·    eliminated or avoided by simple business practices,

·    transferred to other participants, and,

·    actively managed at the firm level (Mishkin, 2004:16).

The risk avoidance practice is the standardization of process, contracts and procedures to prevent inefficient or incorrect financial decisions. Another practice is the construction of portfolios that benefit from diversification across borrowers and that reduce the effects of any loss experience. Finally, the implementation of incentive-compatible contracts with the institution’s management requires that employees be held accountable.

It seems appropriate for discussion of risk management procedures to begin with considerations of why the firms manage risk. According to economic theory, managers of value maximizing firms ought to maximize expected profit without regard to the variability around its expected value (Hoffman, 2002). In fact, at least four distinct rationales are offered for active risk management. These include: managerial self-interest, the non-linearity of the tax structure, the costs of financial distress and the existence of capital market imperfections (Salkind, 2000:26).

Risk measurement involves the quantification of certain risk exposures for the purpose of comparison to a company-defined risk tolerance. The risks, which a firm is subject to, can change because of change in the composition of a company's assets or liabilities, or as a result of external factors affecting the cash-flows. These external factors include: interest rates, exchange rates, prices for inputs, or other economic variables. The risk management process of a firm will always be targeted at decision variables (e.g., hedge ratios) that affect at least one dimension of the firm's financial condition: value, cash-flows, or earnings. The risk management process is a dynamic one. A properly functioning risk management process includes risk audit, exposure oversight, and “fine tuning” of the process itself. This includes external audits of risk management policies and procedures, and internal reviews of quantitative exposure measurement models.

In light of the above, what are the necessary procedures that must be in place to carry out adequate risk management? In essence, what techniques are employed to both limit and manage the different types of risk, and how are they implemented in each area of risk control?

After reviewing the procedures employed by leading firms, an approach emerges from an examination of large-scale risk management systems. The management of the banking firm relies on a sequence of steps to implement a risk management system. They consist of the following four parts:

 (i) standards and reports,

(ii) position limits or rules,

(iii) investment guidelines or strategies,

(iv) incentive contracts and compensation (Santomero, 1995:69).

In general, these tools are established to measure risk exposure, define procedures to manage these exposures, limit individual positions to acceptable levels, and encourage decision makers to manage risk in a manner that is consistent with the firm's goals and objectives.

Risk can be managed, i.e. some measures might be undertaken to decrease a degree of risk, allowing, to some extent, to predict the risky event occurrence. Efficiency of the risk management organization in many respects depends on a risk classification. It is necessary to understand a distribution of risk to specific groups as classification of risk to the certain attributes for objects achievement.

Due to tome and resources constraints, current research is devoted to consideration only financial types of risk. In the bank risks system financial risks occupy a special place. They lead to unforeseen changes in volumes, profitability, structure of assets and liabilities, changing one into another. They directly influence the end results of bank activity: parameters of profitability and liquidity and, finally, the capital size and solvency. The scope of financial risk includes: credit risk, liquidity risk, market risk, interest rate risk, currency risk, inflation risks, insolvency risks, functional risks, strategic risks, technological risks, risk of inefficiency, inclination risk.

Risk Measurement Techniques

The banking industry has a long viewed problem of risk management as a need to control five of the above mentioned risks, which make up most, if not all, of their risk exposure. While banks recognize counterparty and legal risks, they view risks as less central to their concerns. Some banking firms would also list regulatory and reputation risk in their set of concerns. Nonetheless, all would recognize the first five as key, and all would devote most of their risk management resources to constraining these key areas of exposure.

Where counterparty risk is significant, it is evaluated using standard credit risk procedures, and often within the credit department itself. Likewise, most bankers would view legal risks as arising from their credit decisions or, more likely, a proper process not employed in financial contracting. Accordingly, the study of a bank’s risk management processes is essentially an investigation of how they manage these five risks. Thus, various analytical techniques are trying to quantify these risks as possible. To illustrate how this is achieved, this review of firm-level risk management begins with a discussion of risk management controls.

Most widely used techniques covers the Value at Risk (VAR) method (Jorion, 2003:73), risk budgeting and hedge ratio approach (Hofman, 2002), effective duration and effective convexity measure (Fabozzi & James, 2000), scoring method for clients’ identification (Churchill et al., 1977), credit risk structure (Caouette at al., 1998). The measurement methodology of the operational risk framework provides a way of calcu­lating the measures of risk for the factors defined through the business unit analysis. The operational risk measurement methodology is called Delta-EVT™ (Kaufman, 2002:136). It involves the use of two analytical techniques:

·    the delta method and Extreme Value Theory (EVT)

·    the calculation of a threshold.

The measures of the Delta-EVT are loss measures from the two loss-generating sources -value adding processes and rare events, and include the following:

·    Excess Value at Risk (EVAR)

·    Earnings at Risk (EAR) (Vinichenko, 1998:240).

Probably, the most popular approach in performance measurement was developed by “Bankers Trust” (now “Deutsche Bank”) in the 1980s (Ibid.). It is known as a Risk Adjusted Return on Capital (RAROC). It gives an economic basis to measure all the relevant risks consistently and gives managers tools to make the efficient decisions regarding risk/return tradeoff in different assets. As economic capital protects financial institutions against unexpected losses, it is vital to allocate capital for various risks that these institutions face. RAROC analysis shows how much economic capital different products and businesses need and determines the total return on capital of a firm. Though, RAROC can be used to estimate the capital requirements for market, credit and operational risks, it is used as an integrated risk management tool.

RAROC = Risk-adjusted Return / Risk Capital,

where risk-adjusted return equals total revenues less expenses and expected losses (EL), and risk capital is that reserved to cover the unexpected loss given the confidence level. While the expected loss is factored in the return (as loan loss provision), the unexpected loss is equivalent to the capital required to absorb the loss [Crouhy et al, 2001).

Besides, the securitization is used, where the bank pools a group of income-earning assets (like mortgages) and sells securities against these in the open market, thereby transforming illiquid assets into tradable asset-backed securities (Caouttee at al., 1998). However, a special attention is paid to the variety of hedging instruments. There are two methods of hedging: structural and derivatives (Asaf, 1972). Structural hedging represents the decrease or elimination of interest rate risk with the help of equivalence of percentage asset profit and expenses on an interest paid. The emergence of substantial markets in forwards/futures, options, swaps, and other Derivative Financial Instruments (DFIs) have altered the conduct of financial management and investment activities substantially. Credit Default Swaps (CDSs) have emerged as one of the primary building blocks of the bond and loan sectors, serving as a vital tool for banks to manage credit risk or accept exposure to lucrative opportunities.

Methodology and data collection

The current research was represented both in two types of data: primary and secondary. The literature review was presented in secondary type of the research as the authors use expressions and definitions of other people and the analytical part represents primary data as the authors collecting data via questionnaires and interviews. Moreover, the positivistic approach might be considered as the approach of the work, as it uses a survey as the main methodology. The research questions generated by the current work and stated above allow to define the current research as an exploratory study, because there is not a great deal of information about bank risk management techniques in Kazakhstan. The aim of the survey was to find out what kinds of risks Kazakhstani banks face, how they are prevented and are there any risk management techniques, used by banks. In other words what is going on with bank risk management at current moment? In addition, the research has a rather qualitative emphasis, because it is based on people’s views of the reasons of bank risks’ occurrence. The study helps to identify how bank risks are managed and why that procedures are needed.

The first part of the survey has descriptive nature, because the researcher tries to identify types of risks and existing practices in bank risks management. A sample of risks is supposed to be generalised on the whole number of banks operating in Kazakhstan. The second part has analytical nature as it tries to analyse the reasons of risks occurrence, the expected influence on banking industry and those techniques, which are applied in Kazakhstani banks.

Despite all efforts to come across a similar research conducted previously, it was not possible to find any published surveys on the specific management methods on bank risk mitigation in Kazakhstan. The data collection was conducted in the form of a questionnaire that was sent to the Chief Executive Officers (CEOs) of all 33 banks of Kazakhstan licensed by the Agency of the Republic of Kazakhstan on regulation and supervision of financial market and financial organizations (AFN). The lists of licensed banks, pension funds and insurance companies were retrieved from the official website of the AFN. The response rate of the survey is similar to surveys conducted by researchers (58%). However, due to a relatively small number of respondents – 19 out of 33, the results of the survey still cannot be fully generalized. At the same time, the research gives a possibility to have a general view on the current situation, make some analysis and try to draw some conclusions. Furthermore, it lays ground for further research in the area of bank risks management improvement.

The questionnaire was compiled in English and then translated into Russian. Respondents had an option to fill out questionnaires in either language. Seventeen respondents chose to complete the questionnaire in Russian while only two stick to the English version.

Individual results in the questionnaires were kept confidential, and the data was only used in the aggregate form. However, 3 out of 19 respondents omitted some of the questions. Therefore, the number of responses to straightforward questions varied from 16 to 19. For the tabulation of the survey results, percentages were calculated based on the number of responses to each question.

To obtain the relevant information for the research a 3-page questionnaire was designed with the total of 20 questions. Responses to the questions are carefully analyzed in the following paragraphs of this chapter. The questionnaire had 5 sections: background information, overall bank risks, market risk, credit risk, operational risk.

Most of the questionnaires (13,68%) were completed by credit risk analysts. The others were completed by credit risk managers (3,16%), financial analysts (2,11%), and a financial manager (1,5%). Moreover, more than half of the respondents (13 or 68%) held a bachelor degree. Five of the respondents (27%) indicated that they held a master’s degree. No respondents reported that they held less than a bachelor degree. Most respondents (16 or 84%) indicated their field of study was finance. Two respondents (11%) stated that management was their major and the only one (5%) has economics as the field of study. The majority of the respondents (12 or 63%) had less than five years' experience, while 6 respondents (32%) had more than 5 years experience in their work. This information suggests that the respondents, who completed the questionnaire, were, in general, well placed to contribute knowledgeably to this research as they are closely connected with the sphere of risk management.

Analysis of results.

The second section of the questionnaire was specifically designed to determine types of risks faced by banks, extent of exposure to these risks and instruments used to manage this exposure. There were a total of 7 questions in this section and the primary focus was on specific techniques used for the mitigation or limitation of risks. The attention was paid to the type of risk analysis presentation, its regularity and models applied. First of all, respondents were supposed to range types of risks and extent of the exposure. The main focus here was on tree types of risks: credit, market and operational. Other types of risks were chosen for comparative purposes and obtaining the whole picture of risk exposure in the industry. Exposure of banks to 8 main types of risk is shown in Figure 1.

As it was expected, financial risks were the risks of the greatest concern to most banks in Kazakhstan that include market, credit, interest rate and currency risks. They also may contain risks of financial controls failing, treasury risks, lack of counter-party or credit assessment, sophisticated financial fraud, and the effect of changes in macroeconomic factors.

Interest rate risk arises when interest rates start to change. These changes affect loan and investment structure of an organization’s assets. It is especially true for banks that acquire money through deposits and issuing bonds and invest them at a higher rate. If loans and investments are not balanced, the change in interest rates might cause big losses for an organization.

However, more than half of the answers (12,63%) assume that interest rate risk has moderate exposure to their financial institution. Six (32%) out 19 respondents claimed that they were highly exposed to interest rate risk, while only one responded indicated low exposure.

Figure 1. Exposure to different types of risks

Source: compiled by the authors

As it was examined above, credit risk can be considered as the largest risk inherent in bank activity and arises when the borrower does not pay the principal amount and interests on it in conformity with the terms and conditions of a credit management. As the study has proven, all respondents face credit risk, where the majority of banks – 13 (68%) have moderate exposure, 2 (11%) – high exposure and 4 (21%) – a quite low.

Another main risk that Kazakhstani banks face is a currency risk. This risk arises from the change in price of one currency against another. Whenever investors or companies have assets or business operations across national borders, they face currency risk. Kazakhstan actively participates in the international trade, it is one of the largest exporters of raw materials and agricultural products. Furthermore, the country is going to join the World Trade Organization (WTO) that will mean a greater participation in international exchange and the world economy. Such involvement into the international trade means that Kazakhstani financial sector would need to be able to provide services in the international operations to the whole economy. Besides, Kazakhstani financial organizations have started to expand abroad and participate in the foreign markets which will, in turn, lead to the further internalization of the country’s financial industry. Moreover, nowadays investments into the foreign currency assets are one of the tools most actively utilized by Kazakhstani financial organizations (Gribanova, 2007).

According to the perceptions of the respondents, currency risk exposure was ranked quite low relative to other types of risk exposure. The results show that 17 out of 19 respondents admitted that their company was exposed to currency risk to some extent. Out of those 17, 3 identified it as moderate exposure and 14 – as low exposure. Only 2 respondents alleged they were not exposed to the currency risk. The strange outcome is probably connected with misunderstanding of currency risk management tools as well as the absence of such tools at all. Though, the concrete currency risk management analysis determined a high rate of the risk.

High rate of a currency risk exposure is dangerous if not managed properly. Recent decades have seen a number of regional and world currency crises. Asian Crisis in 1998 lead to a depression of the financial system of the whole region, which adversely affected the world economy. Such crises will continue to appear with effects on the world financial system because of the rapid globalization processes. Even without crises, there is a high volatility of world currencies reveals a high level of currency exposure of companies, especially in the financial industry.

As it was previously discussed, market risk encompasses liquidity risk and price risk, both of which arise in the normal course of business of a global financial intermediary. Liquidity risk is the risk that some entity, in some location and in some currency, may be unable to meet a financial commitment to a customer, creditor, or investor when due. Price risk is the risk to earnings that arises from changes in interest rates, foreign exchange rates, equity and commodity prices, and in their implied volatilities. Price risk arises in non-trading as well as trading portfolios.

Not surprisingly, that many financial institutions identified market risk influence as moderate, because prices volatility and inflation rate instability may cause rise of other types of risks, connected with market risk (liquidity risk and other two, which were mentioned above). Only 5 (26%) respondents regarded market risk as one with moderate exposure and 2 (11%) – as low one. However, 12 (63%) indicated that they do not know about the extent of market risk.

Closely connected with the market risk, liquidity risk arises from situations in which a party interested in trading an asset cannot do it because nobody in the market wants to trade that asset. Liquidity risk becomes particularly important to parties, who are about to hold or currently hold an asset, since it affects their ability to trade. If one party cannot find another party interested in trading the asset, this can potentially be only a problem of the market participants with finding each other. This is why liquidity risk is usually found higher in the emerging or low-volume markets.

Kazakhstani financial market can be considered as a low-volume or even emerging market and, though, liquidity risk is fairly low. According to the survey results, 4 respondents (21%) noted a low exposure to liquidity risk, 5 respondents (26%) marked no exposure. Unfortunately, most do not know what the extent of liquidity risk is and some (3, 16%) left this field unmarked. This makes it possible to conclude that many banks do not have operations in the open market or, probably, people are not able just to identify what the liquidity risk is.

Compared to previously analyzed types of risks, country risk was not regarded as relatively important for Kazakhstani banks. Country risk measures the stability of the country in terms of legislation base and political strain and the stability of the counterparts as well. This risk arises from the possibility of the government to change laws or regulations that might adversely affect a company’s position. Kazakhstan is still in the process of developing an effective legal base in a financial sphere, and therefore, there are going to be changes in laws and regulations governing the financial activity in Kazakhstan. As the study has proven, financial organizations are aware that the Kazakhstani legal base will continue to change. However, all respondents marked low exposure to the country risk. Seven respondents out of 19 (37%) indicated that their organizations had low exposure, while 12 (63%) marked it as no exposure respectively.

Until recently, Kazakhstani banks increased volumes of crediting mainly in the home market, however, last two years their strategy is more often aimed at the expansion of operations in Russia, Kyrgyzstan, Uzbekistan, Ukraine and the other CIS countries by means of assets purchase. Among banks of the CIS, Kazakhstani banks are considered as the most advanced as they raise the capitalization due to more favorable regulation, wider services offer, and also access to cheaper and long-term resources. Expansion to the foreign markets can be considered as a way of risk diversification. However, these foreign markets have a much higher level of economic, political and structural risks in comparison with Kazakhstan.

Operational risks include risks of human error or omission, design mistakes, unsafe behaviour, employee practices risks, and sabotage. Although operational risk applies to any organization in business, it is of particular relevance to financial organizations, which are responsible for establishing safeguards to protect against systemic failure of the financial system and the economy. It is relatively difficult to identify or assess levels of operational risk and its many sources. Historically, organizations have accepted operational risk as an unavoidable cost of doing business.

Probably, that is why all 16 respondents agreed that their organizations face at least some level of exposure to operational risk, where 10 (53%) face a high exposure and 6 (32%) - moderate. It is very important for financial organizations to identify this type of risk and minimize it through the implementation of strict risk management standards, internal regulations and controls.

As it was expected, 15 (79%) banks out of 19 has no exposure to strategic risk, while 4 (21%) just do not know the rate of its influence. Strategic risks include risks of plans failing, poor corporate strategies, weak marketing strategies, poor acquisition strategies, and changes in consumer behaviour. It is possible to say that corporate strategy and planning are highly regulated by Kazakhstani banks.

The results of the questionnaire show that our banks do use different types of risk analysis to mitigate or avoid its influence. All respondents indicate that their banks provide risk analysis both quantitatively by using Rates of Return calculation, risk management ratios and standard deviations and qualitatively, using ranking systems and normal distribution diagrams. This makes it possible to conclude that banks pay a special attention to the risky situations that might occur. 17 (89%) banks provide simulation (stress testing) analysis, 5 (or 26%) of which develop it quarterly and 12 (or 64%) - semi-annually. All respondents stated that they usually model basic risks and some (2, 11%) model political risks as well. It is not surprising, that all Kazakhstani banks subscribe to existing agencies for interest rate forecasts and apply a quantitative model for their simulations. Thus, 4 banks develop its own in-house models, when 15 (79%) out of 19 use both possibilities – in-house and acquire from outside sources.

The most interesting part was to determine what indices banks use for overall risk measurement. The answers provided following results: almost all banks (17,89%) employ the Value at Risk (VaR) as overall risk measure The RAROC is used by 15 (79%) organizations, Sharpe ratio is applied by 4 (21%) and only one bank uses Beta coefficient (systematic risk measure). As can be seen from the results, most of banks use two and sometimes even three indices for risk estimation. The special emphasis was made on coefficient of determination (R2), while using Beta (b), but this question was missed by all respondents. This might mean that banks use Beta as provided by other resources, such as the level of Treasury securities. The only bank, which uses Beta, applies special procedures to lower it, when the value of Beta is higher than interval from 1.51 to 2. As it can be seen from the analysis, Beta coefficient is not used well, probably, because banking personnel do not see the need to use a complex approach in risk management as well as the trust to Treasury bills and their level. The level of Beta 1.5 is generally acceptable, thus, if it appears higher, banks will have to apply some techniques to mitigate its influence. Figure 2 summarizes information about those indices used by Kazakhstani banks in its risk management.

Figure 2. Indices for overall risk management

            Source: compiled by the authors

As it was discussed in previous part, banks pay a close attention to the interest rates forecasts and have a quite perceptible influence of its fluctuations, therefore, all interrogated banks have a special method for the interest rate risk estimation. As the answers showed, some financial institutions have more than one technique for risk determination. The results of findings are presented in Figure 3.

Figure 3. Interest rate risk measure

Source: compiled by the authors

Duration is a value and time weighted measure of maturity of all cash flows and represents the average time needed to recover the invested funds. It is used by 8 (42%) Kazakhstani banks. Gap analysis, which focuses on the potential variability of net-interest income over specific time intervals, is provided by 6 (32%) banks out of 19. The most popular measure of interest rate risk is the VaR method, which indicates how much a firm can loose or make with a certain probability in a given time horizon, is applied by the majority – 12 (63%) banks. Among those that use different approaches 3 (18%) make analysis daily, 7 (37%) – monthly and 9 (47%) quarterly. This indicates that time interval before the next estimation is small enough, that gives the opportunity to control interest rate risk. The movement in market prices is calculated by banks by reference to the market data from the last two years. Aggregation of the VAR from different types of risk is based upon the assumption of independence between risk types. The model assumes that changes in risk factors follow a normal distribution. This may not be the case in reality and may lead to an underestimation of the probability of the extreme market movements. The model uses a ten-day holding period and assumes that all positions can be liquidated or hedged in ten days. This may not fully reflect the market risk arising from times of severe liquidity, when a ten-day holding period may be insufficient to fully liquidate or hedge all positions. Among the respondents, the VAR model uses a 99 percent confidence level, and does not taking account any losses that might occur beyond this level of confidence.

Figure 4 shows how much of the assets of financial companies are invested into foreign currencies. 5 out of 19 respondents (26%) had 26-50% of assets invested in foreign currencies, 7 (37%) invested 1-25% of their assets in foreign currencies, and another 37% do not know this information. It is not surprising that given this statistics the financial companies were quite exposed to the currency risk. As it was derived from the interviews, the quite stable rate of tenge and most deposits and credits are held in the national currency, therefore, the currency risk is manageable and moderate.

Figure 4. Proportion of assets invested in foreign currency

 Source: compiled by the authors

It was found out, that the majority of banks – 12 (63%) use hedging instruments to mitigate currency risk versus 7 (37%) out of 19, that do not use these instruments at all. Those, who mentioned the positive answer on hedging instruments use, had to provide the analysis of what types of derivatives are used by their banks. The reasons for not managing the currency risk exposure were market underdevelopment and legal limitations preventing from using instruments for mitigating the currency risk. Many respondents claimed that their organization did not use instruments involving the currency risk.

Currency forwards, futures, options and swaps are excellent instruments for mitigating currency risk. The research showed, however, that they were not commonly used by our financial organizations. As can be seen from Figure 5, out of 19 respondents, 4 used forwards, 3 – futures, financial options were used by 5 banks and 4 used swaps.

It is very interesting that nobody among respondents indicated full hedge of the currency risk. Most banks use hedging instruments partially (10 out of 12) and the rest (2) do not know to what extent the instruments are used. Figure 6 shows the result of hedging volume.

Figure 5. Hedging of currency risk exposure

Source: compiled by the authors

This data says that Kazakhstani banks try to mitigate currency risk with the help of swaps, options, futures and forwards, however the sphere of usage is quite small or it is difficult to evaluate how it is used.

According to the answers of bank employees, credit risk management process relies on corporate-wide standards to ensure consistency and integrity, with business-specific policies and practices to ensure applicability and ownership. It arises principally from lending, trade finance, treasury, and leasing activities (Markova, 1995).

Figure 6. Level of currency risk exposure management by banks

Source: compiled by the author

For corporate clients and investment banking activities across the organizations, the credit process is grounded in a series of fundamental policies, including:

·   ultimate business accountability for managing credit risk;

·   independent risk management responsibility for establishing limits and risk management practices;

·   single centre of control for each credit relationship that coordinates credit activities;

·   portfolio limits, including obligor limits by risk rating and by maturity, to ensure diversification;

·   a minimum of two authorized credit-officer signature requirements on extensions of credit – one from a sponsoring credit officer in the business and one from a credit officer in independent credit risk management;

·   uniform risk measurement standards, including risk ratings, which must be assigned to every obligor;

·   consistent standards for credit origination, measurement, and documentation, as well as problem recognition, classification, and remedial action.

As it was expected, client scoring method is widely used among Kazakhstani banks. More than two third of respondents 15 (79%) out of 19 positively answered the question about adoption of the method when analyzing and ranging clients. Unfortunately, only 10 banks are informed about the numerical scale range of their clients. 7 (37%) adopted 8 scale range system, while 3 out of 19 use 10 range system. The rest did not answer the question and supposed that client scoring method is used, however every client does not usually have its own number. All the respondents review the numerical scale of their clients every month when preparing monthly reports to the National Bank. It is also surprising that more than half of banks (11, 58%) do not have Required Rate of Return (RRR) for clients, and only 8 (42%) do really have. The RRR is set depending on clients’ range, sum of the loan and purposes for money needed. Therefore, the standard procedures used by many banks in Kazakhstan to mitigate credit risks are the volume of primary payment, income verification, the difference between market and mortgage cost of property.

Another interesting fact about banking activities, connected with overall macroeconomic risk, is borrowing abroad. A lot is being discussed now by the government and the National Bank about the limitation and special restrictions on borrowing abroad as it promotes the increase of the country’s external debt. In more details, this information and banks’ policies will be examined later in section 3.2. According to the questionnaire, all banks, 19 out of 19, do borrow abroad. This situation has some advantages as well as disadvantages and is closely connected with currency and country risks.

The results showed that operational risk takes the integral part of every-day bank activity and, nowadays, more and more attention is paid to operational risk management. 18 banks out of 19 provide framework to identify, control, monitor, measure, and report operational risks in a consistent manner across the company. The core operational risk principles, which are applied without exception to all bank businesses, are:

·   senior managers are accountable for managing operational risk;

·   all respondents have a special system of checks and balances in place for operational risk management, including an independent oversight function, reporting to the director of credit and risk department, and an independent audit and risk review function;

·   every department must have approved specific policies and procedures for managing operational risk including risk identification, mitigation, monitoring, measurement, and reporting, as well as processes for ensuring compliance with corporate policies and applicable laws and regulations. (King, 2001).

It is not surprising that all banks have a special backup system for prevention of information loss and in the case of incorrect utilization by people. As there is a law about obligatory annual external audit, all banks are audited annually. However, there is a small difference concerning internal audit. Special attention is paid to the management of a loan’s problem. Regular audits of bank’ credit processes are undertaken by internal audit function. Such audits include consideration of the completeness and adequacy of credit manuals and lending guidelines, together with in-depth analysis of a representative sample of accounts in the portfolio to assess the quality of the loan book and other exposures. Individual accounts are reviewed to ensure that the facility grade is appropriate, that the credit procedures have been properly followed, and that where an account is non-performing, provisions are adequate. Internal audit discuses any facility grading it considers should be revised at the end of the audit and its subsequent recommendations for the revised grades must then be assigned to the facility. 13 (68%) respondents conduct internal audit annually and only 6 (32%) – semi-annually.

Another interesting fact of borrowings abroad was commented by interviewees. As the growth of involved deposits lags behind the growth of crediting, large banks actively attract means in the international financial markets and the debt instruments markets for credit operations financing. Despite all benefits of foreign resources attraction (low interests, long time to maturity), it creates a danger of resource base concentration and refinancing risks occurrence. Moreover, there is a threat of assets deterioration as a result of probable tenge rate downturn as the majority of given credits are nominated in the foreign currency and are counterbalanced by conterminous currency resources. Eight people out of 13 interviewed noted that banks borrow much, but place abroad much money as well. This does not mean that all money, which come to Kazakhstan, create a bigger rate of inflation, and it is not obvious that banks are guilty in inflationary pressure. Anyway, banks of Kazakhstan will go on its growth, whether using own resources, or borrowing abroad. It is possible to grow, using own means, however, the rate of growth will affect the decrease of a market share. Internal means are not enough to prevent market share from shortening. Thus, even if it is too costly, banks will continue to borrow abroad as it is competition requirement.

While the interviews were being conducted, the question of latest Kazakhstani market liberalization for foreign banks has been raised. It is possible to assume that foreign banks have some advantages over the national banks, especially because of high ratings and cheaper funding over Kazakhstani banks. However, the local banks are able to compete by the better market knowledge and clients’ needs understanding. Anyway, risks are possible, but the local banks are able to compete and to get some foreign experience from the foreign banks.

All the information provided by respondents with the help of interviews assisted the researcher in understanding the phenomena of borrowings and credit risk management situation. It will make possible to give some general recommendations and to make a relevant conclusion of the research.

 

Recommendations and conclusions

        Analysis of the information provided by questionnaires and interviews allow suggesting that during the years of independence Kazakhstani banking industry has undergone some development. There are several types of risks that cannot be eliminated completely; therefore they have to be managed correctly. Survey indicates that overall risk management processes in Kazakhstani financial institutions are employed. The results indicate that while banks have established a relatively good risk management environment, the measuring, mitigating and monitoring processes and internal controls needs to be continuously upgraded.

First of all, the main attention should be paid on internal risk control. Some improvements have to be taken by a bank’s board of directors concerning internal audit, because appearing problems must be determined by a bank itself as soon as possible. In house regulations on internal audit and risk management should be designed so that departments are administratively independent of each other and accountable to the bank's board of directors and senior management individually within the scope of the internal control function. Each bank should improve their organizational structure and cooperation procedures for their internal audit system and risk control and management system provided.

Secondly, as the results of the questionnaire show, a lot is being done to determine the level of risks and there are some general risk mitigation measures. Besides, it is possible to advise to use risk management techniques in complex, because only this approach allows measuring risks with certain precision. It sounds optimistic that Kazakhstani banks use internationally admitted methods for risk identification, while some missing elements throughout our banks were found. Number of banks applies different techniques complexly, but others use only one of them. In the international practice, banks give their clients a numerical scale range to easily identify the clients’ risk category. Surprisingly, banks of Kazakhstan do not have such a practice. Along with scoring method usage, credit-rating system should be adopted by banks, because of the real estate market destabilization, credit risks are able to be eliminated by adequately estimation and formation of adequate provisions. Along with scoring method integration, it is needed to develop a new system of assets classification.

Thirdly, the most pessimistic result was derived from the fact that Kazakhstani banks partially use some methods of risk mitigation. This includes lack of instruments (like short-term financial assets and derivatives) and money markets. Financial companies do use over-the-counter derivatives like forwards, options and swaps, yet the use of derivatives by financial companies is very low. Low usage of derivatives can be explained by the fact that Kazakhstani financial organizations do not have access to liquid derivatives markets. In order to make the derivatives market successful, a proper legal base should be in place. For that purpose, a working group consisting from representatives of governmental bodies and private financial companies should be assembled. This group would have to develop a project of a law on derivatives market. Innovations would have to include a creation of or rather delegation of supervising power to the AFC. This calls for more research in these areas to develop risk management instruments and procedures that are compatible with regulation standards.

A main focus was made on the operational risk management. First of all, requirements needed for operating risk management should be applied by the board and top management, and then transmitted to every department. Management need to evaluate the adequacy of countermeasures, both in terms of their effectiveness in reducing the probability of a given operational risk, and of their effectiveness in reducing the impact should it occur. Where necessary, steps should be taken to design and implement cost-effective solutions to reduce the operational risk to an acceptable level. It is essential that ownership for these actions be assigned to ensure that they are initiated. Risk management and internal control procedures should be established by the business units, though guidance from the risk function may be required, to address operational risks. While the extent and nature of the controls adopted by each institution will be different, very often such measures encompass areas such as Code of Conduct, Delegation of authority, Segregation of duties, audit coverage, compliance, succession planning, mandatory leave, staff compensation, recruitment and training, dealing with customers, complaint handling, record keeping, physical controls, etc. Operational risk metrics or “Key Risk Indicators” (KRIs) should be established for operational risks to ensure the escalation of significant risk issues to appropriate management levels. KRIs are most easily established during the risk assessment phase. Regular reviews should be carried out by internal audit, or other qualified parties, to analyze the control environment and test the effectiveness of implemented controls, thereby ensuring business operations are conducted in a controlled manner.

Finally, banks should have in place contingency and business continuity plans to ensure their ability to operate as going concerns and minimize losses in the event of severe business disruption.

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