Capital Management
BMO continues to manage its capital within the capital management framework described on page 69 of BMO’s 2018 Annual Report.
Third Quarter 2019 Regulatory Capital Review
BMO’s Common Equity Tier 1 (CET1) Ratio was 11.4% at July 31, 2019.
The CET1 Ratio increased from 11.3% at the end of the second quarter as retained earnings growth, lower deductions and other net positive changes more than offset business growth.
CET1 Capital was $35.7 billion at July 31, 2019, up from $34.8 billion at April 30, 2019, mainly due to retained earnings growth and lower net deductions, which were partially offset by lower accumulated other comprehensive income mainly due to the impact of foreign exchange movements. CET1 Capital increased from $32.7 billion at October 31, 2018, mainly due to retained earnings growth.
Risk-Weighted Assets (RWA) were $313.0 billion at July 31, 2019, up from $308.8 billion at April 30, 2019, mainly due to business growth, partially offset by the impact of foreign exchange movements and book quality changes. RWA were up from $289.2 billion at October 31, 2018, driven by strong business growth.
The bank’s Tier 1 and Total Capital Ratios were 13.0% and 15.3%, respectively, at July 31, 2019, up from 12.7% and 15.0%, respectively, at April 30, 2019, primarily due to the issuance of the Additional Tier 1 Capital Notes and the factors impacting the CET 1 ratio. The Tier 1 and Total Capital Ratios were 12.9% and 15.2%, respectively, at October 31, 2018. The July 31, 2019 Tier 1 and Total Capital Ratios were higher compared with October 31, 2018, mainly due to higher CET1 Capital and Additional Tier 1 capital issuances, which were largely offset by higher RWA.
The impact of foreign exchange movements on capital ratios was largely offset. BMO’s investments in foreign operations are primarily denominated in U.S. dollars, and the foreign exchange impact of U.S.-dollar-denominated RWA and capital deductions may result in variability in the bank’s capital ratios. BMO may manage the impact of foreign exchange movements on its capital ratios and did so during the third quarter. Any such activities could also impact our book value and return on equity.
BMO’s Basel III Leverage Ratio was 4.3% at July 31, 2019, up from 4.2% at April 30, 2019 and October 31, 2018, respectively, due to higher Tier 1 Capital from retained earnings growth and Additional Tier 1 capital issuances, which more than offset higher leverage exposures from business growth.
Regulatory Developments
In July 2019, the Office of the Superintendent of Financial Institutions (OSFI) revised its capital requirements for operational risk applicable to deposit taking institutions (DTIs). Currently, BMO is required to apply the higher of the Advanced Measurement Approach (AMA) and the current Standardized Approach (SA) for operational risk capital. As part of the transition to the revised Basel III Standardized Approach, DTIs that are currently approved to use AMA, which BMO is, will be required to report using the current SA effective the first quarter of fiscal 2020. We do not expect an impact to our capital ratios from this change. DTIs will be required to report using the revised Basel III Standardized Approach effective the first quarter of fiscal 2021. We are currently assessing the impact on the adoption of the revised Basel III Standardized Approach.
In June 2019, OSFI set the level of the Domestic Stability Buffer (DSB), a Pillar 2 buffer applicable toD-SIBs, at 2.0%, up from 1.75%, effective October 31, 2019. The increase reflects OSFI’s assessment of identified systemic vulnerabilities, including Canadian consumer indebtedness, asset imbalances in the Canadian market, and Canadian institutional indebtedness. The DSB, which is met with CET1 capital, can be set between 0% and 2.5% of total RWA.
In April 2019, OSFI released the final version of the Large Exposure Limits Guideline for implementation by Canadian Domestic Systemically Important Banks(D-SIBs) in the first quarter of fiscal 2020, which is not expected to have a material impact on our operations.
In January 2019, the Basel Committee on Banking Supervision (BCBS) issued final standards on the Minimum Capital Requirements for Market Risk (the Final Market Risk Framework) to address the outstanding design and calibration issues of the 2016 framework and provide further clarity to facilitate its implementation. The Final Market Risk Framework is planned to take effect on January 1, 2022, concurrent with the implementation of the final Basel III reforms published in December 2017. OSFI issued a discussion paper in July 2018 setting out its preliminary views on scope and timing of implementation of the final Basel III reforms in Canada. The requirements, which are expected to be implemented domestically in the first quarter of fiscal 2022, have the potential to increase the amount of capital we are required to hold against market risk exposures. We continue to engage with OSFI as it works to finalize the approach to domestic implementation.
In November 2018, OSFI implemented its revised Capital Adequacy Requirements (CAR) Guideline. The main revisions include the domestic implementation of the standardized approach for counterparty credit risk(SA-CCR) and the revised capital requirements for bank exposures to central counterparties, as well as a revised securitization framework. These changes resulted in a modest increase to the amount of capital we are required to hold. In November 2018, OSFI also implemented the revised Leverage Requirements Guideline to align with the changes for counterparty credit risk and the securitization framework in the revised CAR Guideline.
The CanadianBail-In Regime, including OSFI’s Total Loss Absorbing Capacity (TLAC) Guideline, came into effect on September 23, 2018. Under this regime, the bank is required to meet target TLAC requirements by November 1, 2021. The targets are currently set at a risk-based TLAC ratio of 23.5% RWA (including a 2.0% DSB) and a TLAC leverage ratio of 6.75%, which we expect to comfortably meet when effective. Since September 2018, BMO has issued $13.0 billion in TLAC-eligible funding.
In April 2019, the U.S. Federal Reserve Board issued for comment notices of proposed rulemaking on the tailoring of prudential standards for foreign banking organizations (FBOs) and revisions to resolution plan requirements for large domestic banks and FBOs. The public comment period closed on June 21, 2019.
For a more detailed discussion of regulatory developments, see the Enterprise-Wide Capital Management section on pages 69 to 75, the Liquidity and Funding Risk section on pages 100 to 108 and the Legal and Regulatory Risk section on pages 112 to 114 of BMO’s 2018 Annual Report.
11 BMO Financial Group Third Quarter Report 2019