Banking COVID-19 frequently asked questions
APRA has published the following frequently asked questions (FAQs) to provide authorised deposit-taking institutions (ADIs) with up-to-date guidance on supervisors’ expectations, during the period of disruption driven by COVID-19.
These FAQs will be updated periodically over the coming weeks and months, and we encourage ADIs to check the page regularly. APRA announcements in response to COVID-19 are available here.
Updated: 13 August 2020
Loans impacted by COVID-19
1. How are APRA and ASIC coordinating their approach to loans impacted by COVID-19?
APRA’s primary focus is ensuring prudently safe and sound practices, whilst ASIC’s primary focus is on ensuring fair outcomes for borrowers. In pursuing our respective mandates, APRA and ASIC share a common goal to provide clarity of regulatory expectation so that ADIs can easily engage with their borrowers both prudently and fairly for the benefit of the broader economy. APRA and ASIC will continue to co-ordinate the monitoring of loans impacted by COVID-19, engaging with banks and sharing data and information. Aligned with APRA’s approach, ASIC will publish guidance on its expectations of retail lenders for when loan repayment deferrals end.
2. What is the prudential treatment of loans impacted by COVID-19?
APRA’s treatment of loans impacted by COVID-19 is outlined in a new attachment, to Prudential Standard APS 220 Credit Quality (APS 220). The new Attachment E will operate on a time-limited basis, and modifies the application of APS 220 requirements for loans affected by COVID-19. The main adjustments to APRA’s capital treatment cover: loans offered temporary repayment deferrals; and loans that have been restructured to return to a regular repayment schedule.
3. Do ADIs need to review loans at the three month point?
With the exception of small business loans, ADIs should conduct a check at the end of the initial three month deferral period. The check should determine whether there is any objective evidence that it is no longer appropriate to maintain the regulatory capital approach, given for example more permanent changes in the borrower’s financial circumstances. ADIs should not be avoiding recognition of losses where inevitable.
This check is not expected to involve a full credit risk assessment, but nor should it be an automatic decision to extend the regulatory capital approach. ADIs can use information gathered through proprietary sources, credit reporting agencies and inquiries with borrowers where necessary to inform the check. There should also be a record to evidence the check.
4. What are APRA’s expectations regarding credit assessments for loans impacted by COVID-19?
To the extent possible, ADIs should follow their existing credit policies and procedures. For borrowers that confirm that they are able to return to making payments at the end of a deferral period, a credit assessment is not necessarily required. For all other circumstances, APRA expects that an ADI would conduct an appropriate assessment consistent with ASIC’s expectations (see FAQ 1) and existing prudential standards. For repayment deferrals offered after 30 September 2020 (including extensions to existing deferral arrangements), the temporary capital treatment may only be applied where the ADI is satisfied that the borrower has a reasonable prospect of being able to repay the loan (on original or restructured terms) when the repayment deferral period ends.
5. What should ADIs be publicly disclosing and reporting on loans that have been impacted by COVID-19?
Given the level of relief provided and to promote transparency on a matter of broad public interest, APRA intends publishing entity level data from a subset of ADIs on loans affected by COVID-19. APRA’s reporting requirements are detailed in Reporting Standard ARS 923.2 Repayment Deferrals (ARS 923.2).
The APRA publications are not, however, a substitute for appropriate disclosure by individual ADIs. APRA expects that ADIs will provide appropriate public disclosures of these loans and, where there are material volumes, this should include additional information to that contained in the APRA publication. Appropriate disclosure would cover the scale, trends and overall risk profile of loans subject to repayment deferrals.
Residential mortgage lending
6. What are APRA’s expectations on serviceability assessments for borrowers making changes to loan conditions?
As outlined in Prudential Practice Guide APG 223 – Residential Mortgage lending (APG 223) paragraph 25, APRA’s guidance on better practice in residential mortgage lending has been that there should be a full serviceability assessment for borrowers where there is a material change in loan conditions.
In the current environment, APRA acknowledges that there may be operational challenges for ADIs in evaluating the long-term impact of economic stress on borrowers due to COVID-19. However, this should not prevent changes to loan conditions where these are otherwise assessed to be prudent.
Over the period to 31 March 2021, APRA therefore accepts that some ADIs may not be able to complete a full serviceability assessment for borrowers seeking a change in their loan conditions. Such changes may include converting from principal and interest to interest only, or for the extension of a loan term. Where changes to loan conditions are made that result in an interest-only period being granted without a normal serviceability assessment, APRA expects that a reasonable period for such an arrangement would not exceed 12 months. This guidance also applies to loans that are transitioning off temporary repayment deferrals.
7. How should ASIC’s recent clarifications on responsible lending be interpreted in regards to APRA’s guidance in APG 223?
ASIC has confirmed that responsible lending obligations apply to new lending or increases to contractual credit limits for existing lending, and should not be considered by lenders as a barrier to making other appropriate changes to the terms of existing loans in response to hardship situations.1
Appropriately assessing a borrower’s ability to service and repay a loan continues to be an important component of new residential mortgage lending. APRA notes ASIC’s clarifications on the range of circumstances that lenders can consider when assessing a borrower’s current and likely future capacity to meet repayment obligations. This is consistent with APG 223 (paragraph 38), which states that, as part of its serviceability assessment, an ADI would typically assess and verify a borrower’s income and expenses having regard to the particular circumstances of the borrower.
1 ASIC responds to lenders’ request for clarification on lending during the COVID-19 pandemic, 29 April 2020.
Market risk capital requirements
8. From mid-March to mid-April 2020, markets experienced heightened levels of volatility across several asset classes due to the effects of COVID-19. This is expected to lead to increases in capital requirements for ADIs that use internal models to determine their capital requirement under APS 116 Capital Adequacy: Market Risk. What are APRA’s expectations for reflecting this in capital requirements?
An inherent part of the APS 116 Market Risk framework is that where there is increased risk, there is an increased capital requirement. Increased volatility experienced during March and April 2020 is consequently and appropriately expected to result in increased market risk capital.
One aspect of the market risk internal model capital framework relates to model reliability being confirmed through back-testing of model results to actual outcomes. Where model reliability falls, capital requirements are appropriately adjusted. Through mid-March to mid-April 2020, internal modelling banks are likely to have experienced an unusually high number of VaR back-testing exceptions. APRA’s view is that many of the exceptions experienced during that period are not evidence of deficiencies in an ADI’s model.
Accordingly, APRA will allow modelling ADIs to:
- disregard back-testing exceptions that occurred in the months of March and April 2020 in determining a plus factor for an ADI (under paragraph 85 of APS 116); and
- disregard those exceptions in determining whether to apply a plus factor of one (under paragraph 86 of APS 116).
APRA believes this measure will prevent capital requirements from increasing in a way that is not consistent with the intent of the prudential standard. Modelling ADIs must still include exceptions from March and April 2020 in the number that is compared to a threshold of 10 exceptions (under paragraph 86 of APS 116) to determine whether to submit an analysis of exceptions to APRA.
Credit risk capital requirements
9. What are APRA's expectations for revaluing residential properties, for the purpose of measuring capital requirements under the standardised approach?
ADIs are currently required to revalue property used as security for residential mortgage exposures for the purposes of measuring regulatory capital, when they become aware of a material change in the value of property in an area or region. This is a requirement in Prudential Standard APS 112 Capital Adequacy: Standardised Approach to Credit Risk (APS 112) Attachment C, paragraph 6.
APRA has previously proposed to remove this requirement as part of broader revisions to the prudential standards on regulatory capital. This was foreshadowed in APRA’s consultation on revisions to the ADI capital framework in June 2019.
The rationale for this change in part recognised that the calibration of the residential mortgage risk weights in APS 112 already includes an allowance for increases in the risk of residential mortgage exposures, including from house price movements. Additional movements in risk weights from the revaluation of residential mortgage properties has the potential to be excessively pro-cyclical in amplifying ADI capital requirements.
Given these considerations and the intention to remove the revaluation requirement, APRA is clarifying that ADIs will not be expected to revalue residential mortgage properties for the purpose of meeting APS 112 Attachment C paragraph 6. This applies with immediate effect. ADIs may, however, consider it appropriate to continue to conduct revaluations for broader risk management and other purposes, and nothing in this FAQ is intended to discourage ADIs from doing so where they consider it prudent.
10. What are APRA’s expectations for revaluation of Commercial Property securities under both the Standardised and IRB approaches?
APRA's requirements on valuations for commercial property collateral are set out in Prudential Standard APS 113 Capital Adequacy: Internal Ratings-based Approach to Credit Risk (APS 113) and Prudential Standard APS 220 Credit Quality (APS 220). These requirements are an important part of risk management and the capital framework. APS 220 requires regular assessment of values. APS 113 requires ADIs to monitor the value of the collateral on at least an annual basis, and more frequently where the market is subject to significant changes in value.
From a practical perspective, the COVID-19 environment is creating challenges for ADIs in regard to updating commercial property valuations (in some instances relating to physical access, and more generally because of a high degree of uncertainty around valuation fundamentals, recent sales evidence and market outlook). This uncertainty is more pronounced for some asset classes and geographies than others.
APRA therefore accepts that ADIs may consider deferring revaluations for existing commercial property collateral (which fall due under their valuation policies), where the challenges noted above would impact obtaining a reliable updated valuation in the current environment.
APRA expects that any deferral will only be for a limited period, until the ADI is confident that the updated valuations can be obtained and will reasonably reflect current market conditions. ADIs should not defer valuations that are due after 31st March 2021, and should complete previously deferred valuations within 6 months after this point. ADIs may, however, continue to conduct revaluations for broader risk management and other purposes, and nothing in this FAQ is intended to discourage ADIs from doing so where they consider it prudent.
This approach applies to existing commercial property collateral only. In most cases, APRA expects ADIs to continue to obtain updated valuations where material new lending is to be provided, or where a commercial property secured exposure has either defaulted or is assessed as being at significant risk of default. Depending on the applicable capital framework, APRA will review whether a capital overlay is required as at 31 March 2021, taking into account an ADI’s level of deferred valuations outstanding and any material adverse movements in commercial property markets apparent at that time.
11. What are APRA’s expectations for securitised loans on repayment deferrals?
APRA is aware that some Authorised Deposit-taking Institutions (ADIs) have or intend to repurchase loans from their securitisations due to COVID-19 repayment deferrals (or loan restructuring either after a repayment deferral or as an alternative to a repayment deferral).
Prudential Standard APS 120 Securitisation (APS 120) permits ADIs to repurchase loans from capital relief and funding-only securitisations only in limited circumstances, including where the borrower is granted a further advance (or similar purpose) and if the loan is not in default. It is not the intent of APS 120 for these provisions to facilitate the repurchase of loans on COVID-19 repayment deferrals (or loan restructuring either after a repayment deferral or as an alternative to a repayment deferral).
For the purposes of APS 120, APRA considers a ‘further advance’ to be monies advanced rather than the loan balance being increased due to the capitalisation of interest, expenses or other costs. Similarly, any extensions in loan terms associated with COVID-19 repayment deferrals (or loan restructuring either after a repayment deferral or as an alternative to a repayment deferral) is not considered a ‘similar purpose’.
Any ADI that has or intends to repurchase loans from a securitisation due to COVID-19 repayment deferrals (or loan restructuring either after a repayment deferral or as an alternative to a repayment deferral) should consult APRA, and where appropriate prior to repurchasing, to confirm how they will comply with APS 120. APRA does not expect to provide any concessions in regard to APS 120 compliance. Where APRA identifies ADIs that are in breach of APS 120, supervisors will review the capital and other implications of actions taken.
These Frequently Asked Questions (FAQs) are published for discussion purposes only. The content of these FAQs is not legal advice. Users are encouraged to obtain professional advice about the application of any legislation or prudential standard to their particular circumstances. Users should exercise their own skill and care when relying on any material contained in the FAQs. APRA disclaims any liability for any loss or damage arising out of any use of or reliance on these FAQs. The FAQs may include links to external websites that are beyond APRA’s control. APRA accepts no responsibility for the accuracy, completeness or currency of the content of these FAQs.