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             1. Double and multiple gearing
             2. Undercapitalised unregulated holding ...
             3. Minority interest and double gearing
             4. Inadequate distribution of capital
             5. Suitability of capital structure
             6. Quality of capital










 

Illustrative examples

2. Undercapitalised unregulated holding company

This example illustrates a situation of an undercapitalised group resulting from an undercapitalised unregulated parent holding company as described in paragraphs 23 and 25 of the Capital Adequacy Principles paper.

An unregulated holding company with two regulated 100% subsidiaries and one unregulated 100% subsidiary. Both regulated entities meet their solo requirements.

Unregulated Holding Company A1

Assets Liabilities
Book-value participations in:
Bank B1
  Capital 300
800 Other liabilities
(long term loan)
800
Insurance company B2 200    
Leasing company B3 100    
Total 1,100 Total 1,100

Bank B1 (Subsidiary)

Assets Liabilities
Loans 900 Capital 800
Other assets 400 Other liabilities 500
Total 1,300 Total 1,300

Insurance Company B2 (Subsidiary)

Assets Liabilities
Investments 7,000 Capital 200
    General reserves 100
    Technical provisions 6,700
Total 7,000 Total 7,000

Unregulated Leasing Company B3 (Subsidiary)

Assets Liabilities
Leases 2,000 Capital 100
    Other liabilities 1,900
Total 2,000 Total 2,000

Group (consolidated)

Assets Liabilities
Bank loans 900 Capital 300
Other bank assets 400 General reserves 100
Insurance investments 7,000 Other bank liabilities 3,200
Leases 2,000 Technical provisions 6,700
Total 10,300 Total 10,300

(i) Assume the solo capital requirements/solvency margins of the regulated companies are as follows:

Requirement Actual Capital Surplus/(Deficit)
Bank B1 100 800 700
Insurance Company B2300 300 0
"notional" capital proxy for the Leasing Company B3 150 100 (50)

(ii) Under the building-block prudential approach, the aggregated solo capital requirements and proxies (B1 : 100; B2 : 300; B3 : proxy of 150: Total : 550) are to be compared with the consolidated capital (300 +100 = 400). The group has a solvency deficit of 550 - 400 = 150.

(iii) Under the risk-based aggregation method, the solo capital requirements and proxies are again aggregated (550); the total requirements are compared to the sum of the capital held by the parent and its subsidiaries, deducted from the amount of the intra-group holding of capital [300 (parent) + 800 (B1) + 300 (B2) + 100 (B3) - 1,100 (participations) = 400]. Again, the group has a solvency deficit of 150.

(iv) Under the risk-based deduction method, in the balance sheet of the parent the book value of each participation is replaced by its surplus or deficit value, i.e. total assets minus liabilities and minus capital requirement/proxy of the subsidiary. The book-values of B1 (800), B2 (200) and B3 (100) are replaced by the solo surplus/deficit identified under (i): B1 (700), B2 (0), B3 (-50).

The revised balance sheet of the parent holding company is then as follows:

Assets Liabilities
Participations in:      
B1 700 Capital -150
B2 0 Other liabilities 800
B3 -50    
Total 650 Total 650

Again, the result of the calculation shows a group solvency deficit of 150.

(v) When there is an unregulated holding company, the total deduction method is not applicable.

(vi) Conclusions Although both regulated entities meet their own solo or sector solvency requirements, the financial conglomerate on a group-wide basis is undercapitalised. The explanation is twofold: first, there is excessive leverage in the group, as the parent has downstreamed debt to its subsidiaries in the form of equity capital, and secondly there is an undercapitalised unregulated entity in the group. As explained in the main text, the undercapitalisation of the group is a potential risk for both regulated entities. As shown in the example, the undercapitalisation can be revealed by applying appropriate measurement techniques for the assessment of capital adequacy at group level.

Risk Library * Documents by Author * Committees at the Bank for International Settlement (BIS) * Supervision of Financial Conglomerates * Supplement to the Capital Adequacy Principles paper * Illustrative examples