The Central Bank has informed me that their independent loan loss exercise, conducted by BlackRock Solutions ("BRS"), as part of the Financial Measures Programme 2011 ("FMP") and the Prudential Capital Assessment Review ("PCAR") was used to inform the capital requirements of the PCAR banks. The loan losses assumed by BRS were on the basis of nominal expected losses which banks might incur under base and adverse macro-economic scenarios over a three year horizon and assumed significant levels of collateral repossession. However, loan loss provisions recognised in the financial statements of the banks are based on the incurred loss approach (actual loss outcomes based on accounting rules) rather than on an expected loss approach. The Central Bank published in December 2011 new Impairment Provisioning and Disclosure guidelines which required the Covered Institutions to:
1. Recognise their incurred loan losses as early as possible within the context of International Financial Reporting Standards ("IFRS");
2. Adopt a more conservative approach to the measurement of impairment provisions across all loan portfolios; and
3. Significantly improve the number and granularity of their asset quality and credit risk management disclosures which will enhance users understanding of their asset quality profiles and credit risk management practices.
The Central Bank considers that the level of loan loss provisions at end-2011 is a result of both increasing arrears and the more conservative approach to impairment provisioning which has resulted in a front-loading of provisions. Notwithstanding the additional and significant provisions recognised in 2011 financial statements, loan arrears on aggregate remain within the PCAR 2011 stress case parameters.
The Central Bank continues to monitor arrears levels, impairment provisions and capital adequacy as well as implementing a number of arrears related work-streams.