RNS Announcement
Market risk in 2015
167
Market risk in global businesses
211
Types of risk by global business
Market risk governance
Market risk measures
212
Monitoring and limiting market risk exposures
Sensitivity analysis
Value at risk
Stress testing
213
Market risk stress testing
Trading portfolios
Volcker Rule
Value at risk of the trading portfolios
Daily VaR (trading portfolios)
168
Trading VaR
Back-testing
214
Back-testing of trading VaR against hypotheticalprofit and loss for the Group
Gap risk
De-peg risk
ABS/MBS exposures
Non-trading portfolios
169
Value at risk of the non-trading portfolios
Daily VaR (non-trading portfolios)
Non-trading VaR
Equity securities classified as available for sale
215
Fair value of equity securities
Market risk balance sheet linkages
170
Balances included and not included in trading VaR
Market risk linkages to the accounting balance sheet
171
Structural foreign exchange exposures
Non-trading interest rate risk
Interest rate risk behaviouralisation
172
Balance Sheet Management
216
Third-party assets in Balance Sheet Management
Sensitivity of net interest income
Sensitivity of projected net interest income
173
Sensitivity of capital and reserves
Sensitivity of cash flow hedging reported reserves to interest rate movements
Defined benefit pension schemes
174
Additional market risk measuresapplicable only to the parent company
Foreign exchange risk
HSBC Holdings - foreign exchange VaR
Sensitivity of HSBC Holdings net interest income to interest rate movements
Interest rate repricing gap table
175
Repricing gap analysis of HSBC Holdings
1. Appendix to Risk - risk policies and practices.
There were no material changes to our policies and practices for the management of market risk in 2015.
Exposure to market risk
Exposure to market risk is separated into two portfolios:
· Trading portfolios comprise positions arising from market-making and warehousing of customer-derived positions. The interest rate risk on fixed-rate securities issued by HSBC Holdings is not included in Group VaR. The management of this risk is described on page 171.
· Non-trading portfolios comprise positions that primarily arise from the interest rate management of our retail and commercial banking assets and liabilities, financial investments designated as available for sale and held to maturity, and exposures arising from our insurance operations (see page 180).
Our objective is to manage and control market risk exposures while maintaining a market profile consistent with our risk appetite.
We use a range of tools to monitor and limit market risk exposures, including:
· Sensitivity analysis includes the sensitivity of net interest income and the sensitivity of structural foreign exchange, which are used to monitor the market risk positions within each risk type;
· Value at risk ('VaR') is a technique that estimates the potential losses that could occur on risk positions as a result of movements in market rates and prices over a specified time horizon and to a given level of confidence; and
· Stress testing: in recognition of VaR's limitations we augment VaR with stress testing to evaluate the potential impact on portfolio values of more extreme, though plausible, events or movements in a set of financial variables. Examples of scenarios reflecting current market concerns are the slowdown in mainland China and the potential effects of a sovereign debt default, including its wider contagion effects.
A summary of our market risk management framework including current policies is provided in the Appendix to Risk on page 210.
Global economic growth remained subdued in 2015, with a number of headwinds present. The slowdown of the mainland Chinese economy dampened global trade flows and caused volatility in currency and global stock markets. Market concerns persist as to the scale of the slowdown and the potential for further depreciation of the renminbi.
Performance among developed markets was uneven, with the US and UK performing better than the eurozone, where the risk of a Greek exit faded in the second half of the year and ECB monetary policy remained supportive. Emerging market economies were affected by falling commodity prices as mainland Chinese demand slowed along with the prospect of monetary policy normalisation in the US. This led to capital outflows from emerging markets and a significant depreciation in several key currencies against the US dollar.
Against this backdrop, we maintained an overall defensive risk profile in our trading businesses. Defensive positions are characterised by low net open positions or the purchase of volatility protection via options trades. Non-trading VaR increased during the year as higher interest rates, especially in US dollars, caused the duration of non-trading assets to increase.
Trading VaR predominantly resides within Global Markets. This was lower at 31 December 2015 than at 31 December 2014 due to a decrease in interest rate trading VaR. During the year, trading VaR remained relatively stable trading in a tight range, with the effects of increased market volatility on VaR offset by reduced positions.
The daily levels of total trading VaR over the last year are set out in the graph below.
Daily VaR (trading portfolios), 99% 1 day ($m)
The Group trading VaR for the year is shown in the table below.
Trading VaR, 99% 1 day29
(Audited)
Foreign exchange (FX)
Interest
rate
Equity
Credit
spread
Portfolio
and commodity
(IR)
(EQ)
(CS)
diversification 30
Total31
$m
At 31 December 2015
8.0
34.9
21.4
13.9
(24.9)
53.3
Average
14.7
46.0
19.6
15.5
(35.7)
60.1
Maximum
25.4
57.0
29.0
23.3
77.9
Minimum
6.3
32.6
11.9
9.8
47.5
At 31 December 2014
45.4
7.3
12.5
(14.3)
60.7
16.9
39.5
6.9
13.7
(17.8)
59.2
34.2
50.6
15.6
20.9
77.8
8.7
26.9
3.2
8.8
38.5
For footnotes, see page 192.
The Risk not in VaR ('RNIV') framework captures risks from exposures in the HSBC trading book which are not captured well by the VaR model. For 2015, the VaR-based RNIVs are included within metrics for each asset class whereas in 2014 they were included within portfolio diversification. Adjusting for the impact of the RNIV reclassification, portfolio diversification reduced in comparison to 2014.
In 2015, the Group experienced one profit exception, due primarily to profits from increased volatility in foreign exchange currencies arising from the sharp fall in the Chinese stock market and its effect on global markets.
There was no evidence of model errors or control failures.
The graph below shows the daily trading VaR against hypothetical profit and loss for the Group during 2015. The back-testing result excludes exceptions due from changes in fair value adjustments.
Back-testing of trading VaR against hypothetical profit and loss for the Group ($m)
Non-trading VaR of the Group includes contributions from all global businesses. There is no commodity risk in the non-trading portfolios. The increase of non-trading VaR during 2015 was due primarily to the lengthening of the duration in the non-trading book from higher interest rates, especially US rates. There was no overall trend in the non-trading VaR during the year and no significant movements. The increase in non-trading interest rate and credit spread VaR components were offset by an increase in portfolio diversification effects.
Non-trading VaR also includes the interest rate risk of non-trading financial instruments held in portfolios managed by Balance Sheet Management ('BSM'). The management of interest rate risk in the banking book is described further in 'Non-trading interest rate risk' below, including the role of BSM.
Non-trading VaR excludes the insurance operations which are discussed further on page 180.
The daily levels of total non-trading VaR over the last year are set out in the graph below.
Daily VaR (non-trading portfolios), 99% 1 day ($m)
The Group non-trading VaR for the year is shown in the table below.
Non-trading VaR, 99% 1 day
Rate (IR)
Spread (CS)
diversification
Total
114.1
72.7
(54.0)
132.8
97.5
65.7
(42.0)
121.2
131.5
89.4
156.8
70.5
52.1
91.5
88.2
62.5
(28.5)
122.2
103.3
73.3
(37.4)
139.2
147.7
91.9
189.0
83.3
49.6
92.3
Non-trading VaR excludes equity risk on available-for-sale securities, structural foreign exchange risk and interest rate risk on fixed-rate securities issued by HSBC Holdings. This section and the sections below describe the scope of HSBC's management of market risks in non-trading books.
2015
2014
$bn
Private equity holdings32
1.9
2.0
Investment to facilitate ongoing business33
1.2
Other strategic investments
2.1
7.5
At 31 December
5.9
10.7
The table above sets out the maximum possible loss on shareholders' equity from available-for-sale equity securities. The fair value of equity securities classified as available for sale reduced from $10.7bn to $5.9bn. The decrease in Other strategic investments was largely due to the disposal of the Industrial Bank investment.
The information below and on page 171 aims to facilitate an understanding of linkages between line items in the balance sheet and positions included in our market risk disclosures, in line with recommendations made by the Enhanced Disclosure Task Force.
Balancesheet
Balancesincluded intrading VaR
Balances not
included in
trading VaR
Primary
market risk
sensitivities
Assets
Cash and balances at central banks
98,934
B
Trading assets
224,837
203,194
21,643
A
Financial assets designated at fair value
23,852
Derivatives
288,476
282,972
5,504
Loans and advances to banks
90,401
Loans and advances to customers
924,454
Reverse repurchase agreements - non-trading
146,255
C
Financial investments
428,955
Liabilities
Deposits by banks
54,371
Customer accounts
1,289,586
Repurchase agreements - non-trading
80,400
Trading liabilities
141,614
130,427
11,187
Financial liabilities designated at fair value
66,408
281,071
275,007
6,064
Debt securities in issue
88,949
The table represents account lines where there is some exposure to market risk according to the following asset classes:
A Foreign exchange, interest rate, equity and credit spread.
B Foreign exchange and interest rate.
C Foreign exchange, interest rate and credit spread.
The table above splits the assets and liabilities into two categories:
· those that are included in the trading book and are measured by VaR; and
· those that are not in the trading book and/or are not measured by VaR.
The breakdown of financial instruments included and not included in trading VaR provides a linkage with market risk to the extent that it is reflected in our risk framework.However, it is important to highlight that the table does not reflect how we manage market risk, since we do not discriminate between assets and liabilities in our VaR model.
The assets and liabilities included in trading VaR give rise to a large proportion of the income included in net trading income. As set out on page 54, HSBC's net trading income in 2015 was $8,723m (2014: $6,760m). Adjustments to trading income such as valuation adjustments do not feed the trading VaR model.
Trading assets and liabilities
The Group's trading assets and liabilities are in almost all cases originated by GB&M. The assets and liabilities are classified as held for trading if they have been acquired or incurred principally for the purpose of selling or repurchasing in the near term, or form part of a portfolio of identified financial instruments that are managed together and for which there is evidence of a recent pattern of short-term profit-taking. These assets and liabilities are treated as traded risk for the purposes of market risk management, other than a limited number of exceptions, primarily in Global Banking where the short-term acquisition and disposal of the assets are linked to other non-trading related activities such as loan origination.
Financial assets designated at fair value within HSBC are predominantly held within the Insurance entities. The majority of these assets are linked to policyholder liabilities for either unit-linked or insurance and investment contracts with DPF. The risks of these assets largely offset the market risk on the liabilities under the policyholder contracts, and are risk managed on a non-trading basis.
Financial liabilities designated at fair value within HSBC are primarily fixed-rate securities issued by HSBC entities for funding purposes. An accounting mismatch would arise if the debt securities were accounted for at amortised cost because the derivatives which economically hedge market risks on the securities would be accounted for at fair value with changes recognised in the income statement. The market risks of these liabilities are treated as non-traded risk, the principal risks being interest rate and/or foreign exchange risks. We also incur liabilities to customers under investment contracts, where the liabilities on unit-linked contracts are based on the fair value of assets within the unit-linked funds. The exposures on these funds are treated as non-traded risk and the principal risks are those of the underlying assets in the funds.
Derivative assets and liabilities
We undertake derivative activity for three primary purposes; to create risk management solutions for clients, to manage the portfolio risks arising from client business and to manage and hedge our own risks. Most of our derivative exposures arise from sales and trading activities within GB&M and are treated as traded risk for market risk management purposes.
Within derivative assets and liabilities there are portfolios of derivatives which are not risk managed on a trading intent basis and are treated as non-traded risk for VaR measurement
purposes. These arise when the derivative was entered into in order to manage risk arising from non-traded exposures. They include non-qualifying hedging derivatives and derivatives qualifying for fair value and cash flow hedge accounting. The use of non-qualifying hedges whose primary risks relate to interest rate and foreign exchange exposure is described on page 171. Details of derivatives in fair value and cash flow hedge accounting relationships are given in Note 16 on the Financial Statements. Our primary risks in respect of these instruments relate to interest rate and foreign exchange risks.
The primary risk on assets within loans and advances to customers is the credit risk of the borrower. The risk of these assets is treated as non-trading risk for market risk management purposes.
Financial investments include assets held on an available-for-sale and held-to-maturity basis. An analysis of the Group's holdings of these securities by accounting classification and issuer type is provided in Note 17 on the Financial Statements and by business activity on page 398. The majority of these securities are mainly held within Balance Sheet Management in GB&M. The positions which are originated in order to manage structural interest rate and liquidity risk are treated as non-trading risk for the purposes of market risk management. Available-for-sale security holdings within insurance entities are treated as non-trading risk and are largely held to back non-linked insurance policyholder liabilities.
The other main holdings of available-for-sale assets are the ABSs within GB&M's legacy credit business, which are treated as non-trading risk for market risk management purposes, the principal risk being the credit risk of the obligor.
The Group's held-to-maturity securities are principally held within the Insurance business. Risks of held-to-maturity assets are treated as non-trading for risk management purposes.
Repurchase (repo) and reverse repurchase (reverse repo) agreements non-trading
Reverse repo agreements, classified as assets, are a form of collateralised lending. HSBC lends cash for the term of the reverse repo in exchange for receiving collateral (normally in the form of bonds).
Repo agreements, classified as liabilities, are the opposite of reverse repos, allowing HSBC to obtain funding by providing collateral to the lender.
Both transaction types are treated as non-trading risk for market risk management and the primary risk is counterparty credit risk.
For information on the accounting policies applied to financial instruments at fair value, see Note 13 on the Financial Statements.
For our policies and procedures for managing structural foreign exchange exposures, see page 215 of the Appendix to Risk.
For details of structural foreign exchange exposures see Note 33 on the Financial Statements.
For our policies regarding the funds transfer pricing process for non-trading interest rate risk and liquidity and funding risk, see page 207 of the Appendix to Risk.
Asset, Liability and Capital Management ('ALCM') is responsible for measuring and controlling non-trading interest rate risk under the supervision of the RMM. Its primary responsibilities are:
· to define the rules governing the transfer of non-trading interest rate risk from the global businesses to BSM;
· to define the rules governing the interest rate risk behaviouralisation applied to non-trading assets/ liabilities (see below);
· to ensure that all market interest rate risk that can be neutralised is transferred from the global businesses to BSM; and
· to define the rules and metrics for monitoring the residual interest rate risk in the global businesses, including any market risk that cannot be neutralised.
The different types of non-trading interest rate risk and the controls which we use to quantify and limit exposure to these risks can be categorised as follows:
· risk which is transferred to BSM and managed by BSM within a defined market risk mandate, predominantly through the use of fixed-rate liquid assets (government bonds) held in held to maturity or available-for-sale portfolios and/or interest rate derivatives which are part of fair value hedging or cash flow hedging relationships. This non-trading interest rate risk is reflected in non-trading VaR, as well as in our net interest income (see below) or economic value of equity ('EVE') sensitivity;
· risk which remains outside BSM because it cannot be hedged or which arises due to our behaviouralised transfer pricing assumptions. This risk is not reflected in non-trading VaR, but is captured by our net interest income or EVE sensitivity and corresponding limits are part of our global and regional risk appetite statements for non-trading interest rate risk. A typical example would be margin compression created by unusually low rates in key currencies;
· basis risk which is transferred to BSM when it can be hedged. Any residual basis risk remaining in the global businesses is reported to ALCO. This risk is not reflected in non-trading VaR, but is captured by our net interest income or EVE sensitivity. A typical example would be a managed rate savings product transfer-priced using a Libor-based interest rate curve; and
· model risks which cannot be captured by non-trading VaR, net interest income or EVE sensitivity, but are controlled by our stress testing framework. A typical example would be prepayment risk on residential mortgages or pipeline risk.
For our policies regarding interest risk behaviouralisation, see page 215 of the Appendix to Risk.
For our BSM governance framework, see page 216 of the Appendix to Risk.
Third-party assets in BSM decreased by 9% during 2015. Deposits with central banks reduced by $32bn, predominantly in North America and Europe, in line with reduced repo and reverse repo activity. This reduced activity is also reflected in a reduction of $29bn in non-trading reverse repurchase agreements. Financial investments increased by $29bn mainly due to increased deployment of funds into securities in Asia.
71,116
103,008
639
4,610
Loans and advances:
- to banks
42,059
53,842
- to customers
2,773
1,931
Reverse repurchase agreements
29,760
59,172
335,543
306,763
Other
4,277
2,470
486,167
531,796
The table on the next page sets out the effect on our accounting net interest income (excluding insurance) projections of a series of four quarterly parallel shocks of 25 basis points to the current market-implied path of interest rates worldwide at the beginning of each quarter from 1 January 2016. The sensitivities shown represent the change in the expected base case net interest income that would be expected under the two rate scenarios assuming that all other non-interest rate risk variables remain constant, and there are no management actions. In deriving our base case net interest income projections, the re-pricing rates of assets and liabilities used are derived from current yield curves, thereby reflecting current market expectations of the future path of interest rates. The scenarios therefore represent interest rate shocks which occur to the current market implied path of rates. The interest rate sensitivities are indicative and based on simplified scenarios. The limitations of this analysis are discussed in the Appendix to Risk on page 216.
Assuming no management response, a sequence of such rises ('up-shock') would increase expected net interest income for 2016 by $1,251m (2015: $885m), while a sequence of such falls ('down-shock') would decrease planned net interest income by $2,258m (2015: $2,089m).
The net interest income ('NII') sensitivity of the Group can be split into three key components; the structural sensitivity arising from the four global businesses excluding BSM and Markets, the sensitivity of the funding of the trading book (Markets) and the sensitivity of BSM.
The structural sensitivity is positive in a rising rate environment and negative in a falling rate environment. The sensitivity of the funding of the trading book is negative in a rising rate environment and positive in a falling rate environment, and in terms of the impact on profit the change in NII would be expected to be offset by a similar change in net trading income. The sensitivity of BSM will depend on its position. Typically, assuming no management response, the sensitivity of BSM is negative in a rising rate environment and positive in a falling rate environment.
The NII sensitivity figures on the next page also incorporate the effect of any interest rate behaviouralisation applied and the effect of any assumed repricing across products under the specific interest rate scenario. They do not incorporate the effect of any management decision to change the HSBC balance sheet composition.
See page 215 in the Risk Appendix for more information about interest rate behaviouralisation and the role of BSM.
The NII sensitivity in BSM arises from a combination of the techniques that BSM use to mitigate the transferred interest rate risk and the methods they use to optimise net revenues in line with their defined risk mandate. The figures in the table below do not incorporate the effect of any management decisions within BSM, but in reality it is likely that there would be some short-term adjustment in BSM positioning to offset the NII effects of the specific interest rate scenario where necessary.
The NII sensitivity arising from the funding of the trading book is comprised of the expense of funding trading assets, while the revenue from these trading assets is reported in net trading income. This leads to an asymmetry in the NII sensitivity figures which is cancelled out in our global business results, where we include both net interest income and net trading income. It is likely, therefore, that the overall effect on profit before tax of the funding of the trading book will be much less pronounced than shown in the figures below.
Sensitivity of net interest income34
US dollar
bloc
Rest of
Americas
Hong Kong
dollar
Asia
Sterling
Euro
Change in 2015 net interest income arising froma shift in yield curves of:
+25 basis points at the beginning of each quarter
410
72
217
369
135
49
1,251
-25 basis points at the beginning of each quarter
(691)
(74)
(645)
(290)
(528)
(30)
(2,258)
Change in 2014 net interest income arising froma shift in yield curves of:
209
(9)
245
265
321
(146)
885
(521)
(1)
(494)
(259)
(783)
(31)
(2,089)
For footnote, see page 191.
These estimates are based on certain assumptions, principally:
· all non-interest rate risk variables remain constant; and
· the size and composition of HSBC's balance sheet remains as it was at 31 December 2015.
We expect NII to rise in the rising rate scenario and fall in the falling rate scenario. This is due to a structural mismatch between our assets and liabilities (on balance we would expect our assets to reprice more quickly, and to a greater extent, than our liabilities).
We are more sensitive to both up and down shocks relative to 31 December 2014. In the up-shock we benefit from BSM positioning in US dollars. In the down-shock we lose due to larger rate decreases on deployment of US and HK dollar deposits given the higher rate environment.
Under CRD IV, available-for-sale ('AFS') reserves are included as part of CET1 capital. We measure the potentialdownside risk to the CET1 ratio due to interest rate and credit spread risk in the AFS portfolio by the portfolio's stressed VaR, using a 99% confidence level and an assumed holding period of one quarter. At December 2015, the stressed VaR of the portfolio was $2.8bn.
We monitor the sensitivity of reported cash flow hedging reserves to interest rate movements on a monthly basis by assessing the expected reduction in valuation of cash flow hedges due to parallel movements of plus or minus 100bps in all yield curves. These particular exposures form only a part of our overall interest rate exposures.
The table below describes the sensitivity of our cash flow hedge reported reserves to the stipulated movements in yield curves and the maximum and minimum month-end figures during the year. The sensitivities are indicative and based on simplified scenarios.
impact
+ 100 basis point parallel move in all yield curves
(1,235)
(1,259)
(1,137)
As a percentage of total shareholders' equity
(0.66%)
(0.67%)
(0.60%)
- 100 basis point parallel move in all yield curves
1,224
1,232
1,133
0.65%
0.60%
(1,260)
(1,478)
(1,131)
(0.78%)
1,463
1,126
0.77%
0.59%
Market risk arises within our defined benefit pension schemes to the extent that the obligations of the schemes are not fully matched by assets with determinable cash flows.
For details of our defined benefit schemes, including asset allocation, see Note 6 on the Financial Statements, and for pension risk management see page 189.
The principal tools used in the management of market risk are VaR for foreign exchange rate risk and the projected sensitivity of HSBC Holdings' net interest income to future changes in yield curves and interest rate gap repricing tables for interest rate risk.
Total foreign exchange VaR arising within HSBC Holdings in 2015 was as follows:
45.6
29.3
42.3
42.1
32.9
47.1
50.0
The foreign exchange risk largely arises from loans to subsidiaries of a capital nature that are not denominated in the functional currency of either the provider or the recipient and which are accounted for as financial assets. Changes in the carrying amount of these loans due to foreign exchange rate differences are taken directly to HSBC Holdings' income statement. These loans, and most of the associated foreign exchange exposures, are eliminated on consolidation.
HSBC Holdings monitors NII sensitivity over a five-year time horizon reflecting the longer-term perspective on interest rate risk management appropriate to a financial services holding company. These sensitivities assume that any issuance where HSBC Holdings has an option to reimburse at a future call date is called at this date. The table below sets out the effect on HSBC Holdings' future NII over a five-year time horizon of incremental 25 basis point parallel falls or rises in all yield curves worldwide at the beginning of each quarter during the 12 months from 1 January 2015.
Assuming no management actions, a sequence of such rises would increase planned NII for the next five years by $247m (2014: increase of $600m), while a sequence of such falls would decrease planned NII by $266m (2014: decrease of $539m).
Sensitivity of HSBC Holdings' net interest income to interest rate movements34
Change in projected net interest income as at 31 December arising from a shift in yield curves
of + 25 basis points at the beginning of each quarter
0-1 year
57
15
-
2-3 years
118
43
7
4-5 years
(23)
(12)
8
of - 25 basis points at the beginning of each quarter
(57)
(14)
(6)
(77)
(118)
(43)
(22)
(183)
23
(5)
78
9
2
89
281
17
34
332
138
24
179
(58)
(68)
(276)
(16)
(304)
(138)
(17)
(167)
The interest rate sensitivities tabulated above are indicative and based on simplified scenarios. The figures represent hypothetical movements in NII based on our projected yield curve scenarios, HSBC Holdings' current interest rate risk profile and assumed changes to that profile during thenext five years. Changes to assumptions concerning the risk profile over the next five years can have a significant impact on the NII sensitivity for that period. However, the figures do not take into account the effect of actions that could be taken to mitigate this interest rate risk.
The interest rate risk on the fixed-rate securities issued by HSBC Holdings is not included within the Group VaR but ismanaged on a re-pricing gap basis. The interest rate re-pricing gap table below analyses the full-term structure of interest rate mismatches within HSBC Holdings' balance sheet.
Up to
1 year
From over 1
to 5 years
From over 5
to 10 years
More than
10 years
Non-interest
bearing
Cash at bank and in hand:
- balances with HSBC undertakings
242
2,467
Loans and advances to HSBC undertakings
44,350
42,661
279
405
1,005
Financial investments in HSBC undertakings
4,285
2,985
731
569
Investments in subsidiaries
97,770
Other assets
1,080
109
971
Total assets
150,194
45,888
388
1,136
102,782
Amounts owed to HSBC undertakings
(2,152)
(781)
(1,371)
Financial liabilities designated at fair values
(19,853)
(1,741)
(3,239)
(7,032)
(4,312)
(3,628)
(2,278)
(960)
(963)
3
Other liabilities
(15,895)
(3,374)
(3,500)
(9,119)
98
Subordinated liabilities
(1,642)
Total equity
(107,414)
Total liabilities and equity
(150,194)
(2,522)
(6,613)
(11,495)
(13,332)
(116,232)
Off-balance sheet items attracting interest rate sensitivity
(22,748)
5,351
10,722
5,763
912
Net interest rate risk gap at 31 December 2015
20,618
(874)
363
(7,569)
(12,538)
Cumulative interest rate gap
19,744
20,107
12,538
249
2,771
43,910
41,603
290
1,093
924
4,073
3,010
96,264
597
147,8641
147,864
44,613
1,824
101,137
(1
(2,892)
(1,877)
(1,015)
(18,679)
(850)
(5,472)
(5,400)
(4,263)
(2,694)
(1,169)
(1,009)
(1,013)
4
(1,415)
(17,255)
(779)
(3,766)
(2,000)
(10,195)
(515)
(105,445)
(
(147,864)
(3,506)
(9,238)
(8,413)
(14,458)
(112,249)
(21,525)
7,295
7,400
1,067
Net interest rate risk gap at 31 December 2014
19,582
(1,653)
811
(8,695)
(10,045)
17,929
18,740
10,045
Operational risk
176
Operational risk management framework
Key components of HSBC's ORMF
Three lines of defence
177
Operational risk in 2015
Frequency and amount of operational risk losses
Frequency of operational risk incidents by risk category
178
Distribution of operational risk losses in US dollars byrisk category
Compliance risk
Legal risk
218
Global security and fraud risk
Systems risk
219
Vendor risk management
Responsibility for minimising operational risk lies with HSBC's management and staff. All regional, global business, country, and functional staff are required to manage the operational risks of the business and operational activities for which they are responsible.
A summary of our current policies and practices regarding operational risk is provided in the Appendix to Risk on page 217.
HSBC's Operational Risk Management Framework ('ORMF') is our overarching approach for managing operational risk. The purpose of the ORMF is to make sure we fully identify and manage our operational risks in an effective manner and remain within our targeted levels of operational risk within the Group's risk appetite, as defined by the Board. Articulating our risk appetite for material operational risks helps the organisation understand the level of risk HSBC is willing to accept. Monitoring operational risk exposure against risk appetite on a regular basis and implementing our risk acceptance process drives risk awareness in a forward-looking manner and assists management in determining whether further action is required.
Activities to strengthen our risk culture and better embed the use of the ORMF continued in 2015. In particular, we continued to streamline our operational risk management processes, procedures and tool sets to provide more forward-looking risk insights and more effective operation of the ORMF. The ORMF comprises the 14 key components set below.
HSBC has implemented an activity-based 'three lines of defence' model (an industry best practice approach) to underpin our approach to managing operational risk using the ORMF. It makes clear who does what within HSBC to manage operational risks on a daily basis.
· The first line of defence owns the risks and is responsible for identifying, recording, reporting and managing them and ensuring that the right controls and assessments are in pace to mitigate these risks.
· The second line of defence sets the policy and guidelines for managing the risks and provides advice, guidance and challenge to the first line of defence on effective risk management.
· The third line of defence is Internal Audit which helps the Board and Executive Management to protect the assets, reputation and sustainability of the Group.
During 2015, our operational risk profile continued to be dominated by compliance risk (mainly conduct-related) and we continued to incur losses relating to events from previous years. Conduct-related costs included in significant items are outlined on page 97. A range of mitigating actions are being taken to prevent future conduct-related incidents.
For further information see 'Compliance risk' on page 178 and for details of the investigations and legal proceedings see Note 40 on the Financial Statements.
Other operational risks included:
· compliance with regulatory agreements and orders: failure to implement our obligations under the US DPA could have a material adverse effect on our results and operations. The work of the Monitor is discussed on page 116, with compliance risk described below;
· level of change creating operational complexity: the Global Risk function is engaged with business management in business transformation initiatives to ensure robust internal controls are maintained as we execute our change agenda;
· fraud risks: our loss prevention performance remains strong in most markets, but the introduction of new technologies and ways of banking mean that we continue to be subject to fraud attacks as new attack vectors are developed. We continue to increase monitoring and enhance detective controls to mitigate these risks in accordance with our risk appetite;
· information security: the security of our information and technology infrastructure is crucial for maintaining our banking services and protecting our customers and the HSBC brand. As with other financial institutions and multinational organisations, we continue to be exposed to cyber threats, and the focus of attacks such as 'distribution of denial of service' which can affect the availability of customer-facing websites. Programmes of work are ongoing to strengthen internal security controls to prevent unauthorised access to our systems and network, as well as improvements to the controls and security applied to protect our customers utilising digital channels. Strong engagement and support within the industry, government agencies and intelligence providers helps to ensure we keep abreast of the current developments; and
· third-party risk management: we are strengthening our core third-party risk management capability particularly related to the management of vendor risks. A supplier performance management programme has been implemented with our most material suppliers and screening of suppliers is in place to help enable us to identify if any are on a sanctions list and if we should therefore exit the relationship.
Other operational risks are also monitored and managed through the use of the ORMF.
Further information on the nature of these risks is provided in 'Top and emerging risks' on page 110.
The profile of operational risk incidents and associated losses is summarised below, showing the distribution of operational incidents in terms of their frequency of occurrence and total loss amount in US dollars.
Operational losses were lower in 2015 than in 2014, reflecting a reduction in losses incurred relating to large legacy conduct-related events. Our total loss was driven primarily by provisions raised in respect of the mis-selling of the PPI policies, foreign exchange rate investigations and litigation.
As in previous years, the operational risk incident profile in 2015 comprised high frequency low impact events and high impact events that occurred much less frequently.
Losses due to external fraud, such as card fraud, occurred more often than other types of incident, but the amounts involved were often small in value. The value of fraud incidents in 2015 was lower than in 2014, due to the strengthened control environment.
Frequency of operational risk incidents by risk category (individual loss ≥$10k)
Distribution of operational risk losses in US dollars by risk category
Compliance risk arises from activities subject to rules, regulations, Group policies and other formal standards, including those relating to AML, counter-terrorist and proliferation financing, sanctions compliance, anti-bribery and corruption, conduct of business and other regulations.
Anti-money laundering and sanctions
Revised global AML and sanctions policies were approved in 2014. During 2015, global businesses and countries introduced new AML and sanctions procedures arising from the new policies and focused on embedding the procedures required to effect these policies in our day to day business operations globally. This supported our ongoing effort to address the US DPA requirements. These actions were in line with our strategic target to implement the highest or most effective standards globally. The work of the Monitor, who was appointed to assess the effectiveness of our AML and sanctions compliance programme is discussed on page 116 and our progress on implementing Global Standards is detailed on page 21.
Anti-bribery and corruption
It is unethical, illegal, and contrary to good corporate governance to bribe or corrupt others. The Group is committed to preventing bribery and corruption, and to consistently applying the letter and spirit of applicable anti-bribery legislation in all markets and jurisdictions in which we operate. We have implemented a strategic programme to address bribery and corruption risks and are embedding a new global suite of policies that make it clear to all staff that Group members, employees or other associated persons or entities must not engage in, or otherwise facilitate, any form of bribery, whether direct or indirect.
The anti-bribery and corruption programme, from training to risk assessment, emphasises the importance of consistent and standardised procedures to drive the principles of 'detect, deter and protect' and ensure that they are incorporated into every aspect of business-as- usual activities.
We recognise that delivering fair outcomes for our customers and upholding financial market integrity is critical to a sustainable business model. We have taken a number of steps to raise our standards and deal with historical incidents, including the following:
· we published a new Global Conduct Policy in 2015 (following the approval and implementation of the global conduct approach and framework in 2014) for the management of conduct designed to ensure that we meet our strategic commitment to deliver fair outcomes for our customers, and not disrupt the orderly and transparent operation of financial markets;
· we launched communications programmes and global mandatory training in respect of conduct and the Group's required values and behaviours;
· we enhanced the product governance process to further ensure products are designed to meet customers' needs and are sold to suitable customer groupings. Post implementation and regular reviews are undertaken to help ensure products remain appropriate;
· we reviewed sales processes and sales incentive schemes, focusing on activity and rewards linked to values-based behaviour and good conduct;
· we enhanced our surveillance capabilities and tested new technologies to strengthen our capabilities to detect suspicious trading activity and misconduct;
· we undertook proactive reviews of our involvement in the benchmarking processes for rates and commodities; and
· we reviewed our insights into customer experience, our analysis of the root cause of complaints and our complaint handling to ensure we continually improve and deliver better outcomes for our customers.
The global businesses use a broad range of measures appropriate to their specific customer base and markets to assess ongoing effectiveness of the management of conduct, and enable action to be taken where potential conduct issues arise. The measures include information relating to sales quality, customer experience and market behaviour.
The CVC provides Board oversight of the Group's multiple efforts to raise standards of conduct and embed the behavioural values the Group stands for.
For further information on the CVC, see page 272.
Further information on our conduct is provided in the Strategic Report on page 40 and for conduct-related costs relating to significant items, see page 97.
We actively encourage our employees to raise concerns and escalate issues so they can be dealt with effectively. In most cases, individuals will raise their concerns with line management or Global Human Resources. However, wherean individual believes that their normal reporting channels are unavailable or inappropriate, it is important that they have alternative channels available to them to raise concerns confidentially without fear of personal repercussions. This is referred to as 'whistleblowing'.
To make whistleblowing simpler for our employees, we launched HSBC Confidential across the Group in August 2015 to provide a global platform offering telephone, email, web and mail options for whistleblowers to bring together all our existing whistleblowing channels. We also maintain an external email address for complaints regarding accounting and internal financial controls or auditing matters ([email protected]). Matters raised are independently investigated by appropriate subject matter teams and details of investigations and outcomes including remedial action taken are reported to the CVC. Matters raised in respect of audit, accounting and internal control over financial reporting are reported to the Group Audit Committee.
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