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A. Business Model Analysis (BMA) and Strategic Risk

C 52/2017 STA Effective from 1/4/2021

54. Business model analysis embodies the risk that the bank has failed to structure its organisation and operations (expertise, systems, and processes) in a way that leads to achieving its primary business and strategic objectives.

55. Strategic risks arise when the bank’s business model, organisation structure, operations, and/or strategy are no longer adequate to deliver the objective of the bank as specified by the Board.

56. The bank should conduct regular business model analysis (BMA) to assess its business and strategic risks to determine:

 
(i)The ability of the bank’s current business model to deliver suitable results over the following 12 months;
 
(ii)The sustainability of the bank’s strategy and its ability to deliver suitable/ acceptable results over a forward-looking period of at least three (3) to five (5) years, based on the strategic plans and financial planning;
 
(iii)The sustainability and sufficient diversification of income over time (three (3) to five (5) years). This analysis should consider the sources and levels of income and expenses; and
 
(iv)The ability of the bank to deliver total financial data across the group and for each of its key business units (includes forward-looking performance and profitability).
 

57. An effective BMA contains a through-the-cycle view of the sustainability of the business model in its current state and against a projected view of the bank’s funding structure, return on equity (ROE), capital supply, and capital demand, the effect this has on the product, service pricing, and resource requirements. The business planning should be clear, aligned, and integrated with the bank’s strategy, governance, risk-appetite statement, recovery plans, internal controls, stress tests, and internal reporting (MIS).

58. Each bank should elaborate on the linkage and consistency between their strategic decisions, risk appetite, and the resources allocated for achieving those strategies. The bank should articulate the frequency of monitoring and quantifying changes in its financial projections (e.g. balance sheet, profit and loss, and concentrations) regularly to verify that they are consistent with the business model, risk appetite, and the achievement of the bank’s strategic goals.

59. An effective BMA enables banks to identify vulnerabilities at an early stage and assess their ability to adapt to changes in their specific operating environment therefore helps to promote the safety and soundness of banks. A well-designed and comprehensive BMA approach provides banks with the basis to understand, analyse, assess the sustainability of their business models, enhance proactive, forward-looking operations, and strategy evaluation.

60. Each bank’s business model should be based on analyses and realistic assumptions (stress tests, scenario analyses, and driver analyses, etc.) about the effect of strategic choices on financial and economic outcomes of operations performed. This will enable the bank and the Central Bank to understand the nature of the business model and the inherent risks. Each bank should perform an analysis that involves identifying, challenging the dependency of strategies on uncontrollable external factors, and assumptions (e.g. market interest rates, demand growth in the target customer markets, degree of competition in the markets, cost of entry, and compliance costs).

61. An effective BMA addresses the banks’ ability to produce aggregate financial data across the banking group as a whole, and the bank solo level, for each of its main business units and business lines. Moreover, to make the best use of this data and transform it into relevant inputs, banks need to develop and use analytical tools including stress tests, peer group assessments, profitability forecasts and analysis, and scenario analyses.

62. The documentation provided in support of the business model should contain an overview of the business activities of the bank and an overview of the structure/organisational details of the bank. For example a brief description of the business model, present financial condition, any expected changes in the present business model, the expected future business environment, business plans, and the projected financial condition for the following year.

63. The following additional information and documentation should be referenced (if not part of) the ICAAP report:

 
(i)Bank’s strategic plan(s) with current-year, forward-looking forecasts, and underlying economic assumptions;
 
(ii)Financial reporting (e.g. profit and loss (P&L), and balance sheet), covering the most recent period and the whole (forward-looking) ICAAP reporting period;
 
(iii)Internal reporting (e.g. management information, capital reporting, liquidity reporting, and internal risk reporting);
 
(iv)Recovery plans, including the results of resolvability assessment, if any, and identification of critical functions;
 
(v)Third-party reports (e.g. audit reports, and reports by equity/credit analysts), states their main concerns and issues;
 
(vi)A descriptive report on the main business lines generating revenues broken down by main products, services, other activities, geographies, and market position; and
 
(vii)Peer group analysis segregated by competitor bank, product, or business lines targeting the same source of profits and customers (e.g. credit card businesses targeting consumers at a particular economic stratum in a specific country.
 

64. Business model analysis may act as a base for the development of Reverse Stress Test scenarios.