Systemically important banks must hold more regulatory capital than other banks (known as going concern capital) to make them more resilient to unexpected losses from their ongoing business activities and allow absorption of these losses. They must also provide additional loss-absorbing funds or “gone concern” capital for a crisis. The going and gone concern capital together represent the bank’s total loss-absorbing capacity (TLAC).
In line with the international standards, there are two types of capital requirement in Switzerland. The weighted requirements are calculated as a percentage of the risk-weighted assets (RWA ratio). In addition there is a requirement for the unweighted capital ratio, the leverage ratio (LR), which is calculated as a percentage of total exposures. The LR requirement is designed to act as a safety net.
The large banks are required to fulfil capital requirements at the following levels in their group structures:
At Zürcher Kantonalbank (ZKB) there are consolidated requirements for the group and at a solo level for the parent bank. Similarly, at Raiffeisen there are requirements both for the group at a consolidated level and for Raiffeisen Schweiz Genossenschaft as the central organisation in the co-operative association. At PostFinance, only the requirements for the parent bank are relevant, as it does not have any material group companies requiring consolidation.
The going concern capital requirements for all systemically important banks consist of the following three elements:
At the end of 2020 these add-ons were 1.44% on the RWA ratio and 0.5% on the leverage ratio for Credit Suisse and an RWA ratio of 1.08% and leverage ratio of 0.375% for UBS. At Raiffeisen the equivalent amounts are 0.36% on the RWA ratio and 0.125% on the leverage ratio. Zürcher Kantonalbank (ZKB) and PostFinance do not currently have any add-ons. The countercyclical capital buffer to be applied as per year-end 2020 depends on the size of the bank’s specific credit positions.
The gone concern capital requirements for the domestic systemically important banks amount to a minimum of 40% of their going concern capital. The Swiss entities of the two large international banks are required to hold gone concern capital equal to 62% of their going concern requirements, while the gone concern requirements at group level are 100% of going concern capital less rebates granted by FINMA for improvements in their resolvability beyond the statutory requirements. The gone concern requirements for the parent companies of the large banks at solo level are the sum of the following elements:
The 30% requirement of the consolidated gone concern requirements at the parent company level is a buffer designed to be available flexibly in the event of a crisis, for example to recapitalise subsidiaries.
The going concern requirements must be largely met with common equity tier 1 (CET1) capital. Only a maximum of 4.3% of the RWA ratio and 1.5% of the leverage ratio can be met with additional Tier 1 (AT1) capital. These are perpetual debt instruments that are contractually written down or converted to CET1 capital if the bank’s CET1 capital falls below 7% of RWAs. They are commonly referred to as high-trigger contingent convertible / write-off bonds (HT CoCos) and normally absorb losses before a bail-in.
The gone concern requirements are normally fulfilled with bail-in bonds. These are debt instruments that can be converted into equity as part of a resolution procedure. Bail-in bonds are only eligible if they meet certain criteria. In particular, they must be issued by the group holding company under Swiss law and with jurisdiction of the Swiss courts, and may not be offsettable or secured. Furthermore, they must contain an irrevocable clause whereby the bondholders agree to accept a conversion or a full or partial write-down (i.e. a bail-in), if ordered by the supervisory authority. Bail-in bonds may not be sold in small denominations to prevent these high-risk instruments from being bought by retail investors. Under the Capital Adequacy Ordinance (CAO), the banks may alternatively opt to meet all or a portion of their gone concern requirements with CET1 or AT1 instruments. These capital types are multiplied by a factor of 1.5 if used to meet a gone concern requirement.
Systemically important banks must be able to meet their payment obligations even in extraordinarily stressed conditions. In addition to the requirements that apply to all banks, they should meet more stringent liquidity requirements.
Like other banks, systemically important banks are obliged to limit concentration risks. The standard upper limit for such positions is 25% of Tier 1 capital. The difference for systemically important banks is that the concentration risk vis-à-vis other Swiss or global systemically important banks is limited to 15% of Tier 1 capital.