MHA | Why is the PRA concerned about the levels of leveraged finance…

Why is the PRA concerned about the levels of leveraged finance that some lenders are exposed to, especially those involved with VC finance?

Carlison Morris · Posted on: June 20th 2024 · read

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The Prudential Regulation Authority recently conducted a thematic review of private equity (PE) related financing activities among regulated banks and sent a letter to the banks' Chief Risk Officers (CROs) detailing their findings and expectations. The letter, dated April 23, 2024, emphasised the growing significance of PE-related financing in the banking sector and the need for robust risk management practices due to the evolving market landscape, geopolitical tensions and global economic uncertainties.

The PRA's review focused on the adequacy of banks' risk management frameworks governing their PE-linked financing businesses and related derivatives exposures. The review identified several gaps in banks' overarching risk management frameworks controlling their aggregate PE sector-related exposures.

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Key Findings and Expectations

  1. Data Aggregation and Holistic Risk Management The PRA found that many banks were unable to systematically identify and measure their combined credit and counterparty exposures linked to the PE sector. Banks often engage in various PE-linked exposures across different business lines, leading to fragmented client relationships and risk management oversight. The PRA expects banks to implement group-wide risk data aggregation tools, stress testing capabilities and consolidated management information reporting processes to manage these risks effectively. Boards must be fully involved in overseeing firm-wide strategies related to the PE sector and be informed of aggregate exposure trends in associated credit and counterparty risks.
  2. Exposures Linked to Individual Financial Sponsors The PRA noted that many banks did not calculate comprehensive consolidated exposure data to measure and control combined PE credit and counterparty risks linked to individual financial sponsors. The absence of a risk appetite framework constraining the size of combined PE exposures linked to individual sponsors was also highlighted. The PRA expects banks to systematically flag all transaction and exposure data, along with relevant collateral pledges, relating to the PE sector in their risk management systems. This data should enable the calculation and monitoring of exposures to the PE sector overall, as well as exposures linked to individual financial sponsors and PE funds.
  3. Credit and Counterparty Risk Interlinkages The review found that most banks lacked procedures to comprehensively identify, measure, combine, and record risks arising from overlapping financial claims, liens, and security interests linked to the same PE fund or portfolio company. The PRA expects credit due diligence procedures and management information processes to recognize and measure the presence of overlapping credit exposures, collateral pledges, and financial claims across all PE-related activities where performance and recovery values are interlinked.
  4. Stress Testing While some firms had developed stress testing frameworks for PE sector-linked exposures, others had not or had conducted stress tests only within individual business units or product silos. The PRA emphasises the importance of evaluating the potential for higher default and loss correlations in stress periods. Banks should conduct routine stress testing of exposures to the PE sector as a whole and PE exposures linked to individual financial sponsors. These stress tests should be modular, tailored to the specific risk profile of different products and structures, and consider theoretical scenarios beyond historical default rates and observed risk correlations.
  5. Board Level Reporting The PRA found that several banks' boards were not adequately informed about the overall scale of combined exposures linked to the PE sector or individual financial sponsors. This lack of information hindered a holistic assessment of the risks associated with these aggregate exposures. The PRA expects boards to be informed of aggregate exposures linked to the PE sector and to consider the overall business strategy concerning consolidated PE-linked activities. Boards should ensure that the scale and composition of risk exposures linked to material financial sponsor clients and the PE sector are appropriate within the context of the bank's overall risk profile.

Next Steps

The PRA has requested banks to review the findings and assess their current practices against the PRA's expectations. Banks should identify any gaps between their internal risk and governance frameworks and the PRA's expectations. Given the scale, complexity, and interconnectedness of PE-linked credit and counterparty exposures, banks are urged to prioritise improvements in their risk management approach.

Banks are required to share the output of their benchmarking exercise with their Board Risk Committee and provide a detailed analysis, along with plans to remediate any gaps in their processes, to their supervision team by Friday, August 30, 2024.

The PRA's letter serves as a reminder of the increasing importance of robust risk management practices in the context of PE-related financing activities. As the market continues to evolve, banks must adapt their risk management frameworks to effectively identify, measure, monitor, and control the associated risks. The PRA's expectations aim to enhance the resilience of the banking sector and mitigate potential vulnerabilities arising from PE-linked exposures.

The PRA's letter serves as a reminder of the increasing importance of robust risk management practices in the context of PE-related financing activities.

Partner Carlison Morris
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