Capital Management
BMO continues to manage its capital within the capital management framework described on page 59 of BMO’s 2019 Annual Report.
First Quarter 2020 Regulatory Capital Review
BMO’s Common Equity Tier 1 (CET1) Ratio was 11.4% as at January 31, 2020.
The CET1 Ratio was unchanged from the fourth quarter of fiscal 2019, as retained earnings growth was offset by impacts from business growth, regulatory changes, and the adoption of IFRS 16,Leases.
CET1 capital was $37.1 billion as at January 31, 2020, up from $36.1 billion as at October 31, 2019, mainly due to retained earnings growth and to a lesser extent, lower deduction for deferred tax assets and higher unrealized gains from securities fair valued through accumulated other comprehensive income.
Risk-Weighted Assets (RWA) were $325.6 billion as at January 31, 2020, up from $317.0 billion as at October 31, 2019, mainly due to business growth, regulatory changes and the adoption of IFRS 16.
The bank’s Tier 1 and Total Capital Ratios were 13.0% and 15.2%, respectively, as at January 31, 2020, unchanged from October 31, 2019, as higher capital from increase in CET1, as discussed above, was 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 current quarter. Any such activities could also impact our book value and return on equity.
BMO’s Basel III Leverage Ratio was 4.3% as at January 31, 2020, unchanged from the fourth quarter of fiscal 2019, as higher Tier 1 Capital was offset by higher leverage exposures from business growth.
Regulatory Developments
The Basel III reforms package, finalized by the Basel Committee on Banking Supervision (BCBS) in December 2017, for implementation on January 1, 2022 includes: revised standardized and internal ratings-based approaches for credit risk, revisions to the credit valuation adjustment (CVA) framework, revised standardized approach for operational risk which replaces the existing standardized and advanced measurement approaches, revised leverage ratio framework and an output floor for RWA to be phased in over a five-year period. The preliminary view of the Office of the Superintendent of Financial Institution (OSFI) on the scope and timing of implementation of the Basel III reforms in Canada is set out in its discussion paper issued for consultation in July 2018. While the BCBS outlined a five-year transition period for the RWA output floor from 50% in 2022 to 72.5% in 2027, OSFI’s discussion paper proposes to set the output floor at 72.5% upon implementation of the reforms in the first quarter of fiscal 2022.
The Minimum Capital Requirements for Market Risk (the Final Market Risk Framework), part of the Basel III reforms, was finalized by the BCBS in January 2019, with a proposed implementation date of January 1, 2022.
The Basel III reforms are expected to increase the amount of capital we are required to hold. We continue to engage with OSFI as it works to finalize the timing and approach to domestic implementation.
In January 2020, OSFI revised its capital requirements for operational risk applicable to deposit-taking institutions, reflecting the final Basel III revisions published by the BCBS in December 2017. OSFI has decided that the domestic implementation of the revised Basel III operational risk capital requirements will move from the first quarter of fiscal 2021 to the first quarter of fiscal 2022 to coincide with the implementation of the final Basel III credit risk and leverage ratio requirements.
In December 2019, OSFI set the level of the Domestic Stability Buffer (DSB), a Pillar 2 buffer applicable to Canadian domestic systemically important banks(D-SIBs) at 2.25%, up from 2.0%, effective April 30, 2020. The increase reflects OSFI’s view that key vulnerabilities toD-SIBs remain elevated, and in some cases show signs of increasing, including Canadian household indebtedness, asset imbalances and institutional indebtedness, as well as global vulnerabilities which could increase the chance of a spillover of external risks into the Canadian financial system. The DSB, which is met with CET1 capital, can be set between 0% and 2.5% of total RWA. OSFI’s long-term objective is to ensure the effectiveness of the DSB. Within that context, OSFI will review the0%-2.5% range to determine if it is appropriate.
In the first quarter of fiscal 2020, the expiry of transitional arrangements provided by OSFI for the standardized approach for counterparty credit risk and the revised securitization framework, resulted in a modest increase in the amount of capital we are required to hold.
IFRS 16,Leases was effective November 1, 2019 and resulted in a downward adjustment to opening retained earnings on adoption. The most significant impact for BMO is the recording of real estate leases on the balance sheet.
The combined impact of IFRS 16, and the expiry of transitional arrangements was 16 basis points on our CET1 Ratio in the first quarter of fiscal 2020.
The implementation of the final version of the Large Exposure Limits Guideline, applicable toD-SIBs, in the first quarter of fiscal 2020, did not have a significant impact on our operations.
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 23.75% RWA (including a 2.25% DSB) and a TLAC leverage ratio of 6.75%. At January 31, 2020, our risk-based TLAC was 20.8% and our TLAC leverage ratio was 6.9%.
For a more detailed discussion of regulatory developments, see the Enterprise-Wide Capital Management section on pages 59 to 65, the Liquidity and Funding Risk section on pages 91 to 99 and the Legal and Regulatory Risk section on pages 103 to 104 of BMO’s 2019 Annual Report.
11 BMO Financial Group First Quarter Report 2020