Risk Management Manual of Examination Policies - FDIC

INTERNATIONAL BANKING Section 11.1
to establish and maintain a special reserve when the value
of international loans has been impaired by a protracted
inability of the borrowers in a country to make payments
on external indebtedness or no definite prospects exist for
orderly restoration of debt service. ILSA requires that the
special reserves established by a charge against current
income be segregated from the bank's general Allowance
for Loan and Lease Losses (ALLL), and not be included as
a part of bank capital. ILSA also directs each appropriate
Federal banking agency to require a banking institution to
establish and maintain a special reserve whenever in the
judgment of the appropriate Federal banking agency:
1. The quality of such banking institution's assets has been
impaired by a protracted inability of public or private
borrowers in a foreign country to make payments on
their external indebtedness as indicated by such factors
as: (i) a failure by such public or private borrowers to
make full interest payments on external indebtedness;
(ii) a failure to comply with the terms of any
restructured indebtedness; or (iii) a failure by the
foreign country to comply with any International
Monetary Fund (IMF) or other suitable adjustment
program; or
2. No definite prospects exist for the orderly restoration of
debt service.
The banking agencies refer to this special reserve as the
Allocated Transfer Risk Reserve (ATRR). ATRR
requirements are established on an interagency basis
through the ICERC program. When applicable, ICERC
assigns ATRR requirements to country exposures classified
as Value Impaired. Banks have also the option of charging
off the required amount in lieu of establishing an ATRR.
ATRR requirements are posted on the International Section
website after each ICERC meeting. Examiners should
refer to this website to determine if any of the bank’s
country exposures are subject to an ATRR.
Country Exposure Concentrations
The Federal banking agencies recognize that
diversification is the primary method of moderating
country risk. Diversification is especially relevant to
international lending because the assessment of country
risk involves major uncertainties and is subject to
considerable margin for error. Diversification provides the
best protection against a dramatic change in the economic
and/or political fortunes of any particular country.
The adequacy of diversification within a bank's
international portfolio is determined by comparing
individual country exposure to the bank's capital.
Depending on the economic and political situation within a
country and the structure of the bank's portfolio within that
country, different concentration levels are used to identify
significant country exposures.
The March 2002 Statement notes that concentrations of
exposures to individual countries that exceed 25 percent of
the institution’s Tier 1 capital plus the ALLL are
considered significant; however, in the case of particularly
troubled countries, lesser degrees of exposure may also be
considered to be significant. Report of Examination
instructions explain how to use this basic criterion for
preparing report commentary and the concentrations
schedule. In addition, similar to the March 2002 Statement
advice for banks to consider limiting exposures on a
broader (i.e. regional) basis, examiners may wish to
identify in the Report of Examination concentrations of
exposure to broader country groupings when bank or
market analyses have identified linkages between countries
to which the bank is exposed.
Other ILSA Provisions
In addition to transfer risk reserve requirements, as
described above, ILSA and implementing regulations
contained within Subpart C of Part 347 of the FDIC Rules
and Regulations address several other requirements and
matters relating to U.S. banks’ international lending. For
example, they set forth requirements for accounting for
fees on international loans and reporting and public
disclosure of international assets. As with other loan fees,
Part 347 requires banks to follow generally accepted
accounting principles (GAAP) for the amortization of fees
on international loans. Regarding disclosures on
international loans, Part 347 references reporting
requirements for FFIEC Form 009 (see Country Risk
Exposure Report below).
Country Risk Exposure Report
One of the tools used in monitoring a bank's country risk
exposure is the FFIEC’s Country Risk Exposure Report
(Form 009), which must be filed quarterly by banks that
meet certain conditions. Those conditions, as well as the
detailed instructions for compiling the report, can be found
on the FFIEC webpage under Instructions for Preparing the
Country Exposure Report (FDIC Form 6502/03). The
examination process should include assurances that banks
adhere to reporting requirements, and that such reports are
accurate. However, examiners may wish to note that a
bank’s internal measures of country exposure may be
different from that required by the Form 009. This is
acceptable. The bank should be able to explain the
DSC Risk Management Manual of Examination Policies 11.1-5 International Banking (12-04)
Federal Deposit Insurance Corporation