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FRB: Supervisory Letter SR 01-6 (SUP) on enhancements to public dis...

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BOARD OF GOVERNORS
OF THE
FEDERAL RESERVE SYSTEM
WASHINGTON, D. C. 20551
DIVISION OF
BANKING
SUPERVISION AND
REGULATION

SR 01-6 (SUP)
March 23,
2001
TO OFFICER IN CHARGE OF SUPERVISION AND SUPERVISORY STAFF AT
THE EACH FEDERAL RESERVE BANK AND TO EACH LARGE, DOMESTIC
BANKING ORGANIZATION SUPERVISED BY THE FEDERAL RESERVE
SUBJECT: Enhancements to Public Disclosure

The Federal Reserve has long supported meaningful public disclosure by
banking and financial organizations with the objective of enhancing market discipline
and fostering stable financial markets. Public disclosure and market discipline are
important complements to bank supervision and regulation. With sufficient
information, market participants can better evaluate counterparty risks and adjust the
availability and pricing of funds in ways that can promote more efficient financial
markets and sound practices by banks. In order to advance public disclosure efforts
and to strengthen market discipline regarding banking organizations, the Federal
Reserve has worked with other regulators, accounting authorities, users of financial
statements, and the banking industry.
Earlier this year, the private sector Working Group on Public Disclosure
issued a report recommending several enhancements to public disclosure for large
banking organizations and securities firms in the areas of credit and market risk.1 The
Working Group agreed on some broad principles, including observing that disclosures
should reflect information that is consistent with an organization's approach to risk
management. The group recommended that disclosures should explain how risk
within a firm changes over time and should evolve with innovations in a firm's risk
management practices. The group also suggested that disclosures should balance
quantitative and qualitative information and include clear discussions about a firm's
risk management processes.
In addition to these broad principles, the Working Group recommended
several specific practices that would enhance current disclosures. These include
quarterly disclosure of some market risk information now disclosed annually and
enhanced quarterly disclosures about credit concentrations and credit quality. In
particular, the Working Group recommended that firms disclose:
1. Aggregate high, average and low trading value-at-risk (VAR) over
the quarter.
2. High, average, and low trading VAR by major risk category (e.g.,
fixed income, currency, commodity, and equity) over the quarter,
including diversification effects.

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3. Quantification of how well market risk models performed (e.g.,
histogram of daily trading revenues compared to average VAR over
the quarter).
4. Current credit exposures by internal rating, reflecting the effects of
netting, collateral, and other credit protection. Firms should
provide explanatory information on their ratings, including, if
appropriate, how they compare to external ratings. Recognizing
that it might be inappropriate or not feasible to include certain
credit products in this disclosure (e.g., debt securities in trading
inventory), firms should make it clear which products are included.
Distinguishing between loan and other credit exposures also would
be helpful.
5. Information about the maturity profile of transactions giving rise to
material current credit exposures.
6. Insight into credit concentrations (e.g., industry sector and country
risk).
Private sector efforts, such as those of the Working Group, and official
regulatory initiatives can help to foster a consensus and advance thinking on what
constitutes sound or best practice regarding public disclosure. The Federal Reserve
believes that the types of disclosures recommended by the Working Group, when
properly executed, can enhance the transparency of well-managed institutions.
Accordingly, the Federal Reserve encourages each large banking organization to use
these recommendations as it seeks to enhance its disclosures and convey more
effectively information about its risk profile. The Securities and Exchange
Commission and the Office of the Comptroller of the Currency are also encouraging
large securities firms and financial institutions involved in lending and trading
activities to consider the Working Group's recommendations as they develop
enhanced disclosures. Many of the enhanced disclosures are appropriate for quarterly
and annual financial reports, though firms also may want to consider other forums
(e.g., public websites) to disclose quantitative and qualitative information outside of
routine financial reports.
Large banking organizations are encouraged to balance the need for
information on a firm's risk profile and performance over time with disclosures that
will provide a basis for reasonable comparisons across firms involved in similar
activities. In this regard, large banking organizations are encouraged to provide
meaningful information based on their particular risk management strategies and risk
profiles, recognizing that, as risk management practices evolve, opportunities will
increase to provide additional relevant information that is more comparable across
firms.
The Federal Reserve will continue its dialogue on public disclosure with
other domestic and foreign regulators and the financial industry, and is exploring
additional ways of addressing disclosure issues and encouraging sound disclosure
practices in connection with the ongoing supervisory process. In this regard,
supervisors will consider the recommendations of the Working Group in efforts under
way to improve public disclosures, including the project to revise the Basel Capital
Accord. Furthermore, the Federal Reserve plans to issue additional guidance later this

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year that addresses the role of the supervisory process in promoting sound practices
for qualitative and quantitative disclosures.
Reserve Banks are asked to distribute a copy of this SR letter to domestic
financial and bank holding companies with consolidated total assets of $10 billion or
more. Given the increased efforts to foster enhanced transparency and market
discipline at the international level, the Federal Reserve will share this guidance with
supervisors of large foreign banks, as well as members of the Basel Committee on
Banking Supervision. Questions may be directed to Gerald Edwards, Associate
Director and Chief Accountant - Supervision, at (202) 452-2741, Charles Holm,
Assistant Director, at (202) 452-3502, or Gregory Eller, Project Manager, at
(202) 452-5277.

Richard Spillenkothen
Director

Notes:
1 In April 2000, the Federal Reserve established the Working Group on Public
Disclosure with the participation of the Office of the Comptroller of the Currency and
the Securities and Exchange Commission. The Working Group’s members were
senior executives from major domestic and foreign banking organizations and
securities firms, and the group was chaired by Walter Shipley, retired chairman of
Chase Manhattan Bank. Its objective was to recommend improvements in public
disclosure by large financial institutions. This objective was fulfilled by setting forth
a number of recommendations in a letter to the federal agencies, sent on
January 11, 2001. The report and the agencies' accompanying joint press release and
response letter are available on the Federal Reserve Board's website at
www.federalreserve.gov/boarddocs/press/general/2001.
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