Austria Proposal to Introduce Systemic Risk Capital Buffers Is Credit Positive
for Banks
Last Wednesday, the Austrian Financial Market Stability Board (FMSB) announced that it will propose the
introduction of systemic risk buffers and systemically important institution buffers for certain banks. These
buffers would be credit positive for Austrian banks because they would raise required common equity Tier 1
(CET1) capital levels, which are weak relative to the banks’ risk profiles and European peers, and additional
earnings retention to ensure compliance with these higher capital requirements.
The FMSB has not yet disclosed details of the capital buffers. But based on other European countries, we
expect that the additional buffers initially will not exceed 3% of CET1. Therefore, CET1 minimum
requirements for the large Austrian banks could gradually rise to 10% in 2019 from 4.5% now and 8.125%
by 2016. The three largest Austrian banks, Erste Group Bank AG (Baa2 negative, D+/ba1 negative2
),
Unicredit Bank Austria AG (UBA, Baa2 review for downgrade, D+/ba1 review for downgrade) and Raiffeisen
Bank International AG (RBI, Baa2 review for downgrade, D-/ba3 negative) reported CET1 ratios of 10%-11%
as of December 2014 (see Exhibit 1). As such, we expect that the additional buffer requirements will be
manageable for the banks, even though the higher bar sets a clear incentive for banks to further improve
their CET1 ratios to maintain a safety margin to minimum required levels.
According to the FMSB, the systemic risk buffers will account for the importance of the financial sector to
the Austrian economy, a bank’s exposure to emerging European economies, particularly Central and Eastern
Europe and the Commonwealth of Independent States, banks’ relatively low current capitalisation levels
compared with international peers, and specific, mostly private, or mutualist ownership structures that may
hinder quick emergency recapitalisations. We expect the FMSB to introduce the systemic risk buffers in
2016, adding to the 4.5% minimum CET1 ratio that will be applicable at that time and the capital
conservation buffer, which increases to 2.5% by 2019 (see Exhibit 2).
We expect the initial systemic risk buffer to be 1% for smaller domestic systemically important institutions3
and 3% for Erste, UBA and RBI. Although in theory national systemic risk buffers can be as high as 5%, none
of the eight European Union and European economic area countries that has so far announced systemic risk
buffers has chosen maximum levels greater than 3% (see Exhibit 3). National regulators can introduce
systemic risk buffers of up to 3% by notifying the European Commission, European Banking Authority,
European Systemic Risk Board and competent authorities of other relevant European Union member states,
thereby avoiding the more complex procedures and international consent requirements associated with
higher systemic risk buffer levels.