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Friday, June 30, 2017

After the BPI Computer Glitch, the New BSP Cyber-Security Guidelines May Be Ignoring the Ticking Time Bomb in the Heart of Philippine Banks

On June 28, 2017, the Bangko Sentral ng Pilipinas (BSP) said that it would roll out tighter rules on the information technology (IT) systems of banks by next month.  These rules would update BSP 2013 Circular # 808, BSP's main framework for IT risk management and security. Circular #808 directs banks "to ensure that banks implement security controls to adequately protect their information assets from unauthorized access, and deliberate misuse or fraudulent modification, insertion, deletion, or substitution." The new framework would continue to focus on cyber-security but be updated to include new technologies such as cloud computing and higher encryption standards.

While it's true that cyber-security is an ever-increasing risk in the banking industry, the new BSP framework might be ignoring an equally growing risk - that of legacy IT systems. After all, the last two computer glitches, the one at the Bank of Philippine Islands (BPI) at the start of June 2017 as well as the one at Security Bank last June 21, 2017 were not caused by hacking per se but by errors in their internal systems, human or otherwise. It was only BDO Unibank that admitted to have lost money due to ATM skimming.

In the House and Senate Hearings on these computer malfunction incidents, both BPI and BSP officials cited similar snafus taking place in other countries such as in the United Kingdom as well as Singapore.   The computer outages that took place in the Royal Bank of Scotland (RBS) in 2012 and 2013 (leading to a record fine of GBP 56 million pound sterling) as well as a similar outage in the Development Bank of Singapore (DBS) in 2010 were not products of hacking or external breaches in their computer systems but were internal to their respective firms.

Royal Bank of Scotland

The RBS cases are particularly instructive. Their numerous mishaps were attributed to human error as well as a failed batch processing upgrade. The U.K.'s Financial Conduct Authority (FCA) pinned RBS computer failure to deficiencies in the bank's IT risk management and control. There was an: 

  • Inadequate focus on IT resilience;
  • Insufficient identification, understanding or mitigation of the risk of a batch scheduler failure;
  • Measures to reduce the risks and subsequent effects of computer outages such as separating batch processing systems were not in place;
  • IT risk management policies were focused on recovering from a low probability but high impact events such as the total loss of a data center rather than smaller but more probable disruptions like software failure.

But the RBS computer outage could also have been due to the dismal state of its core legacy IT systems. The basic bank process software, "the back-end", may have been left untouched due to years of under-investment. Instead, management may have treated the legacy core system as a "black box" that is wrapped in snazzy new shell or front-end (customer-interface) applications such as real-time banking services such as mobile banking and/or internet banking (which show customers their up to the minute bank balances) even though their actual bank balances are batch-processed overnight. Hence, there is a divergence between what a customer thinks his balance is and what the bank thinks their customer's bank balance is until the two balances are reconciled with the overnight batch processing. This momentary divergence makes the bank's data vulnerable to data corruption.  Over time, because of competitive pressures, the shell of applications sitting on top of the core legacy system may become more larger and more complex and increase the risk of incompatibility and connectivity of the newer shell applications with the older core technology.

Compounding this basic problem is the complex integration of one bank's legacy IT system with another bank's legacy IT system. The modern RBS itself is a result of the merger of the old RBS with Natwest in 2000. Post merger, "a decision was taken to ditch Natwest more advanced computer systems and migrate all of the enlarged group's IT onto RBS's smaller IBM-based platform" because RBS's mainframe system was considered more cost-efficient solution at that time.

Although European banks spend a sizable amount on IT, most of the money is spent on patching and maintaining increasingly creaky and fragmented legacy systems.  As mentioned by Frances Coppola, a banking systems analyst, "core system replacement is very expensive... Very expensive IT infrastructure projects simply aren't acceptable to management or staff when the system may break down and their jobs are on the line." Bank management may like to move to new systems but system migration of this magnitude has been likened to "trying to change the engines on an aeroplane while it is in flight." There is the very real risk that everything can go horribly (and expensively) wrong. More often than not, bank management prefers to make incremental changes, resulting in a system that is ever more complex, diverse, and unstable.  Hence, the operational risk of a major IT failure remains a very distinct possibility at many banks.


Bank of the Philippine Islands (BPI)

Like RBS, BPI is an old bank. In fact, it is the oldest bank in the Philippines. Like RBS, the modern BPI is a product of a series of mergers since the late 1990s:
  1. City Trust Banking Corporation, the retail banking arm of Citibank Philippines, in 1996;
  2. Far East Bank & Trust Company (FEBTC) in 2000 (the larger banking merger at that time); 
  3. Three major life, non-life and reinsurance companies in 2000; as well as
  4. Prudential Bank in 2005.
BPI has been known to be a leader in the field of banking technology. For instance, it was the first to introduce Automated Teller Machines into the country in the 1980s. As such, it may have a number of core legacy systems remaining.

Like RBS, and as indicated by its Executive Vice President Ramon Locsin Jocson (BPI's Head of Enterprise Services) during the Senate and Congressional Hearings, the bank was prepared for a low probability event such as total loss of data instead of a higher probability event such as the software malfunction it suffered last June 7, 2017.

Like RBS (as well as Security Bank), it suffered a batch processing failure. The failure occurred internally and was not due to an external computer breach or hack. The error was pinned on a programmer who inputted the wrong date range on a batch reconciliation report and who deviated from procedure to rush the report, resulting in errors in as many as 1.5 million accounts and resulted in a system wide shutdown of its ATM, Cash Acceptance, and Point of Sale systems for almost two days.

Although the bank spends a significant amount on IT - around Php 5.3 billion (roughly US$100 million) on IT investments, it is not clear as to how much investment goes to new systems as to patching and maintaining its core legacy system. It is also not clear as to how much of this yearly investment goes into front-end or shell applications versus the more mission-critical core or back-end systems.

The bank, however, did indicate that it is, by far, the leading Philippine bank in terms of the absolute size of its IT infrastructure investments (roughly 8% of 2016 bank revenues) and it has been spending at least Php 400 million a year in terms of research and development. It also indicated that it spends at least Php 300 million a year in terms of cyber-security. Why so much investment in IT? Because it aims to "catch up" with the technological capabilities of its rivals within the ASEAN region.

So what then?

If BPI is one of the leaders in Philippine banking technology and this "glitch" happened to them, then what does this say about the state of the core legacy systems of the rest of the Philippine banking system? By the very fact that BPI is playing catch up to its regional rivals, perhaps the bank has realized that it has reached a "tipping point where the costs of and risk of doing nothing outweigh the cost and risk of taking action."

To paraphrase banking analyst Frances Coppola, it is high time then that the BSP focus on the increasing fragility of the legacy IT systems of Philippine banks. Unless this is addressed, we run the risk of a major systems failure in one or more banks at some point. The BPI/BDO/Security Bank failures are warnings. Banking regulators need to address this problem before there is a real disaster.

Monday, June 19, 2017

A Simple Stress Test of Philippine Banks as of December 31, 2016

Editor's Note: This is an updated version of an earlier blog post A Simple Stress Test of Philippine Banks as of September 30, 2016

Editor's Note: For the purposes of this article, Philippine Banks or the Philippine Banking System refers to the Philippine Commercial and Universal Banking System and the Philippine Thrift Banking System.  We are ignoring the Philippine Rural and Cooperative Banking System whose asset base is tiny in comparison to the whole banking system (Php 211.93 billion or 1.56% of the Php 13,591.20 billion in assets held in the Philippine Banking System as of December 31, 2016).


In an April 9, 2012 article entitled "Stress Test Proves Strength of PH Banks", "Philippine banks are seen to survive a disaster in which the various lenders are forced to write off loans as large as PhP 36 billion without asking shareholders, the central bank, or the national government for bailout money."  This assertion stems from a recent stress test conducted by the Bangko Sentral ng Pilipinas (BSP) on all 55 regular and commercial and expanded license banks.

For Philippine Banks, these NPLs currently comprise PhP 144.16 billion or 9.31% of the PhP 1,548.09 billion in Stockholders Equity (SE) as of December 31, 2016.  So, writing off 50% of the Philippine Banks NPLs would reduce their aggregate stockholder's equity by a little less than 5%.

Naturally, some banks would be more affected than others. For more information regarding this, please read The Top Distressed Philippine Banks as of December 31, 2016).

The stockholder's equity of seven banks would be severely affected.  These banks are:


  1. Philippine Postal Savings Bank Inc (104.92% decline in SE)
  2. World Partners Bank (88.86% decline in SE)
  3. Luzon Development Bank (77.65% decline in SE)
  4. Equicom Savings Bank (46.12% decline in SE)
  5. Legazpi Savings Bank Inc (89.86% decline in SE)
  6. Enterprise Bank Inc (42.47% decline in SE)
  7. Maritime Savings Bank Corporation (33.18% decline in SE)


Philippine Banking System
NPL as % of SE
December 31, 2016









NPL SE NPL/SE
Bank (In PHP) (In PHP) (In %)
PHIL POSTAL SAVINGS BANK INC 2,105,663,775.71 1,003,426,168.74 209.85%
WORLD PARTNERS BANK (A THRIFT BANK) 107,415,667.13 60,443,031.24 177.71%
LUZON DEVELOPMENT BANK 544,175,490.99 350,396,970.60 155.30%
EQUICOM SAVINGS BANK INC 601,715,967.86 652,349,264.94 92.24%
LEGAZPI SAVINGS BANK INC 447,417,498.87 497,881,105.80 89.86%
ENTERPRISE BANK INC (A THRIFT BANK) 232,694,561.97 273,953,562.02 84.94%
MARITIME SAVINGS BANK CORPORATION 24,652,054.39 37,146,334.12 66.36%
MALAYAN BANK SAVINGS AND MORT BANK INC 574,727,293.20 1,004,218,467.21 57.23%
PHILIPPINE RESOURCES SAVINGS BANKING CORPORATION (PR SAVINGS 955,755,336.48 1,915,584,496.80 49.89%
CHINA BANK SAVINGS INC 4,293,974,170.33 9,156,290,253.10 46.90%
PHILIPPINE VETERANS BANK 1,898,738,872.12 4,139,442,922.32 45.87%
BATAAN DEVELOPMENT BANK 31,340,481.42 77,178,559.44 40.61%
THE PALAWAN BANK (PALAWAN DB) INC 14,849,692.88 39,202,654.77 37.88%
STERLING BANK OF ASIA INC (A SAVINGS BANK) 936,700,031.78 2,495,553,616.49 37.53%
PAMPANGA DEVELOPMENT BANK 49,744,868.65 133,860,245.35 37.16%
NORTHPOINT DEV'T BANK INC 122,915,455.83 343,580,397.41 35.77%
RCBC SAVINGS BANK INC 3,715,336,441.78 10,404,065,960.55 35.71%
UCPB SAVINGS BANK 975,156,384.32 2,742,614,192.92 35.56%
BANK OF MAKATI (A SAVINGS BANK) INC 2,243,073,464.02 6,358,015,586.16 35.28%
UNITED COCONUT PLANTERS BANK 5,989,286,726.79 17,592,468,014.29 34.04%
METRO CEBU PUBLIC SAVINGS BANK 21,100,005.39 64,435,089.21 32.75%
PENBANK INC (A PDB) (FORMERLY: PENINSULA RB INC) 146,519,151.74 457,096,842.49 32.05%
BPI DIRECT BANKO INC A SAVINGS BANK 547,319,743.95 1,791,106,416.26 30.56%
BPI FAMILY SAVINGS BANK INC 7,497,941,572.20 25,553,872,912.78 29.34%
DUNGGANON BANK (A MICROFINANCE THRIFT BANK) INC 28,178,352.90 106,910,119.62 26.36%
STANDARD CHARTERED BANK 2,123,003,347.70 8,629,977,138.18 24.60%
VILLAGE BANK INC (A THRIFT BANK) 20,037,722.29 81,902,520.23 24.47%
MALASIQUI PROGRESSIVE SLB, INC 12,713,229.25 52,140,796.94 24.38%
PHIL SAVINGS BANK 4,531,110,557.04 18,768,152,432.53 24.14%
EAST WEST BANKING CORP 8,227,387,109.25 34,222,509,373.79 24.04%
1ST VALLEY BANK INC A DEVELOPMENT BANK 346,548,011.68 1,442,686,809.84 24.02%
HIYAS BANKING CORPORATION 34,826,424.16 152,412,656.01 22.85%
PHIL BANK OF COMMUNICATIONS 2,259,014,990.06 10,241,013,449.75 22.06%
LIFE SAVINGS BANK INC 14,205,894.15 66,516,103.17 21.36%
PHIL STAR DEVELOPMENT BANK INC 19,238,385.28 93,400,200.78 20.60%
PRODUCERS SAVINGS BANK CORPORATION 311,505,684.33 1,585,786,138.30 19.64%
FARMERS SAVINGS & LOAN BANK INC 22,696,612.39 119,179,639.67 19.04%
WEALTH DEVELOPMENT BANK CORPORATION 240,199,722.90 1,311,900,631.99 18.31%
UNIVERSITY SAVINGS BANK INC 72,145,206.72 412,031,156.93 17.51%
MAYBANK PHILIPPINES INCORPORATED 2,036,189,716.30 11,719,746,835.36 17.37%
BUSINESS AND CONSUMERS BANK (A DB) 13,970,890.80 84,502,772.49 16.53%
CITYSTATE SAVINGS BANK INC 119,756,629.16 737,224,113.70 16.24%
FIRST CONSOLIDATED BANK INC (A PDB) 590,763,111.01 3,875,459,099.11 15.24%
CITY SAVINGS BANK INC 1,530,120,230.40 10,416,035,951.50 14.69%
PHILIPPINE BUSINESS BANK INC A SAVINGS BANK 1,322,295,019.15 9,727,579,253.15 13.59%
UNION BANK OF THE PHILS 7,778,178,634.93 62,333,297,322.59 12.48%
INTER-ASIA DEVELOPMENT BANK 7,566,983.61 62,495,742.15 12.11%
BANK OF COMMERCE 1,777,798,286.62 15,364,502,813.09 11.57%
YUANTA SAVINGS BANK PHILIPPINES INC 112,039,320.83 992,092,118.96 11.29%
DEVELOPMENT BANK OF THE PHIL 4,802,651,348.83 44,124,381,091.38 10.88%
CORDILLERA SAVINGS BANK INC 14,588,524.39 135,032,013.61 10.80%
OPTIMUM DEVELOPMENT BANK INC 90,959,273.89 851,577,817.81 10.68%
ANZ BANKING GROUP LTD 404,087,064.26 4,150,338,569.51 9.74%
PHIL NATIONAL BANK 8,771,559,273.58 101,836,861,242.86 8.61%
BANGKO KABAYAN INC (A PRIVATE DEVELOPMENT BANK) 39,444,210.03 460,453,624.72 8.57%
LAND BANK OF THE PHILIPPINES 7,173,190,275.55 85,380,060,082.56 8.40%
SUN SAVINGS BANK INC 15,103,167.59 183,535,477.61 8.23%
DUMAGUETE CITY DEV BANK INC 20,850,370.14 262,995,356.70 7.93%
BANK OF CHINA LIMITED-MANILA BRANCH 189,040,895.91 2,532,809,223.93 7.46%
BDO UNIBANK INC 15,854,555,894.59 216,327,723,797.18 7.33%
PNB SAVINGS BANK 829,192,484.27 11,498,657,172.27 7.21%
CARD SME BANK INC A THRIFT BANK 48,473,003.59 709,899,560.31 6.83%
CITIBANK, N.A. 869,608,224.33 12,835,851,416.84 6.77%
CTBC BANK (PHILIPPINES) CORP 460,786,467.63 6,904,788,639.67 6.67%
CHINA BANKING CORP 3,728,985,069.67 57,408,773,230.53 6.50%
ASIA UNITED BANK CORPORATION 1,475,266,303.18 23,274,345,137.40 6.34%
ROBINSONS BANK CORPORATION 691,088,663.30 11,896,303,900.32 5.81%
HONGKONG & SHANGHAI BANKING CORP 797,673,955.04 14,640,228,446.42 5.45%
PHIL TRUST COMPANY 1,172,897,983.43 23,045,761,182.07 5.09%
BANK OF THE PHIL ISLANDS 7,688,633,689.58 160,549,310,710.50 4.79%
BANK ONE SAVINGS AND TRUST CORP. 23,101,952.55 575,219,918.21 4.02%
LEMERY SAVINGS & LOAN BANK, INC. 2,987,856.52 79,181,809.28 3.77%
CENTURY SAVINGS BANK CORPORATION 34,734,041.96 971,015,155.84 3.58%
HSBC SAVINGS BANK(PHILS) INC 63,448,045.28 1,797,588,220.73 3.53%
QUEEN CITY DEVELOPMENT BANK INC OR QUEENBANK A THRIFT BANK 22,071,051.75 658,121,861.20 3.35%
BATAAN SAVINGS AND LOAN BANK 1,808,578.20 58,266,576.10 3.10%
RIZAL COMM'L BANKING CORP 1,913,419,749.01 62,605,257,771.28 3.06%
MERCHANTS SAVINGS & LOAN ASSN INC 15,291,332.84 623,919,318.51 2.45%
AL-AMANAH ISLAMIC INVESTMENT BANK OF THE PHILS 6,509,512.97 298,726,619.97 2.18%
SECURITY BANK CORP 1,956,583,647.77 96,540,680,277.62 2.03%
METROPOLITAN BANK & TCO 3,683,099,014.74 187,399,541,656.32 1.97%
KEB HANA BANK - MANILA BRANCH 28,022,199.88 1,641,319,668.78 1.71%
BANGKOK BANK PUBLIC CO LTD 43,936,941.43 3,164,745,771.55 1.39%
QUEZON COCONUT BANK INC (A THRIFT BANK) 440,570.84 58,788,484.15 0.75%
ING BANK N.V. 101.44 2,462,697,042.68 0.00%
BANK OF AMERICA N.A. 0.00 2,091,322,952.20 0.00%
BDO PRIVATE BANK, INC. 0.00 5,143,261,112.34 0.00%
CATHAY UNITED BANK CO LTD - MANILA BRANCH 0.00 2,114,994,246.49 0.00%
DEUTSCHE BANK AG 0.00 3,115,188,633.13 0.00%
FIRST COMMERCIAL BANK LTD MANILA BRANCH 0.00 2,061,230,424.92 0.00%
INDUSTRIAL BANK OF KOREA MANILA BRANCH 0.00 2,198,377,005.93 0.00%
ISLA BANK(A THRIFT BANK) INC 0.00 664,937,840.86 0.00%
JP MORGAN CHASE BANK NATIONAL ASSN. 0.00 1,387,778,439.51 0.00%
MEGA INT'L COMM'L BANK CO LTD 0.00 1,841,609,590.34 0.00%
MIZUHO BANK LTD - MANILA BRANCH 0.00 5,512,514,270.26 0.00%
SHINHAN BANK - MANILA BRANCH 0.00 2,168,774,838.27 0.00%
SUMITOMO MITSUI BANKING CORPORATION-MANILA BRANCH 0.00 12,851,999,724.51 0.00%
THE BNK OF TOKYO-MITSUBISHI UFJ LTD 0.00 4,679,489,410.20 0.00%
Grand Total 130,563,795,522.67 1,463,519,874,590.22 8.92%

Are NPLs the Right Numbers to Look At?

In a financial crisis, a loan that is current can very well become past due, and a past due loan can become a non-performing loan, and a non-performing loan can become a loan write-off.  The real number to look at are the loans that the banks and BSP already consider doubtful: Classified Loans.

Investopedia.com defines "Classified Loans" as:

"Any bank loan that is in danger of default. Classified loans have unpaid interest and principal outstanding, and it is unclear whether the bank will be able to recoup the loan proceeds from the borrower. Banks usually categorize such loans as adversely classified assets on their books."

The US Federal Deposit Insurance Corporation (FDIC), similar to our very own Philippine Deposit Insurance Corporation (PDIC), defines Classified Loans as:

"Loans classified Loss are considered uncollectible and of such little value that their continuance as bankable assets is not warranted. This classification does not mean that the loan has absolutely no recovery or salvage value but rather it is not practical or desirable to defer writing off this basically worthless asset even though partial recovery may be effected in the future."

In Circular #0247 dated May 19, 2000, BSP defines Classified Loans as loans which possess the following characteristics:
  1. Loans especially mentioned because they have potential weaknesses that deserve Management's close attention;
  2. Substandard Loans are loans which appear to involve a substantial and unreasonable degree of risk to the institution because of unfavorable record or unsatisfactory characteristics;
  3. Doubtful Loans are Substandard Loans with the added characteristics that existing facts, conditions, and values make collection or liquidation in full highly improbable and in which substantial loss is probable;
  4. Loss loans are loans that are considered uncollectible or worthless and are of such little value that their continuance as bankable assets is not warranted although the loans may have some recovery or salvage value.
The circular mandates that an allowance for probable losses should be set up in accordance with the following schedule:
  1. Loans Especially Mentioned: 5%
  2. Substandard - Secured: 6% - 25%
  3. Substandard - Unsecured: 25%
  4. Doubtful: 50%
  5. Loss: 100%
As of December 31, 2016, "Classified Loans and Other Risky Assets" of the Philippine Banks amounted to PhP 343.19 billion or almost 3 times the size of the Philippine Banking System's NPLs of PhP 130.56 billion for the same period.  Consequently, any write-offs of Classified Loans will have three times the impact of an NPL write-off.


Philippine Banking System
Classified Loans vs. NPLs
December 31, 2016







Classified Loans/NPL
Bank Classified Loans Gross NPLs (In %)
ING BANK N.V. 40,000,000.00 101.44 39432176.66%
BANK OF CHINA LIMITED-MANILA BRANCH 15,103,128,485.26 189,040,895.91 7989.34%
INTER-ASIA DEVELOPMENT BANK 236,168,695.34 7,566,983.61 3121.04%
QUEZON COCONUT BANK INC (A THRIFT BANK) 12,142,369.67 440,570.84 2756.05%
QUEEN CITY DEVELOPMENT BANK INC OR QUEENBANK A THRIFT BANK 221,987,127.82 22,071,051.75 1005.78%
YUANTA SAVINGS BANK PHILIPPINES INC 1,056,171,182.20 112,039,320.83 942.68%
BANK ONE SAVINGS AND TRUST CORP. 204,239,198.39 23,101,952.55 884.08%
VILLAGE BANK INC (A THRIFT BANK) 171,691,000.00 20,037,722.29 856.84%
CITIBANK, N.A. 5,167,048,362.39 869,608,224.33 594.18%
KEB HANA BANK - MANILA BRANCH 159,898,935.21 28,022,199.88 570.62%
DUMAGUETE CITY DEV BANK INC 117,490,000.00 20,850,370.14 563.49%
BANGKO KABAYAN INC (A PRIVATE DEVELOPMENT BANK) 221,605,766.24 39,444,210.03 561.82%
METROPOLITAN BANK & TCO 19,945,341,081.96 3,683,099,014.74 541.54%
PHIL TRUST COMPANY 5,784,000,000.00 1,172,897,983.43 493.14%
SECURITY BANK CORP 9,018,000,000.00 1,956,583,647.77 460.91%
CORDILLERA SAVINGS BANK INC 64,689,076.01 14,588,524.39 443.42%
BANK OF COMMERCE 7,836,421,529.56 1,777,798,286.62 440.79%
RIZAL COMM'L BANKING CORP 7,742,581,334.23 1,913,419,749.01 404.65%
PHIL NATIONAL BANK 32,765,210,227.83 8,771,559,273.58 373.54%
CHINA BANKING CORP 13,491,147,877.52 3,728,985,069.67 361.79%
BATAAN DEVELOPMENT BANK 102,400,000.00 31,340,481.42 326.73%
ASIA UNITED BANK CORPORATION 4,784,481,341.54 1,475,266,303.18 324.31%
METRO CEBU PUBLIC SAVINGS BANK 66,150,726.24 21,100,005.39 313.51%
PHIL SAVINGS BANK 14,149,535,551.21 4,531,110,557.04 312.28%
MALAYAN BANK SAVINGS AND MORT BANK INC 1,680,015,585.65 574,727,293.20 292.32%
BDO UNIBANK INC 46,117,189,189.88 15,854,555,894.59 290.88%
UNION BANK OF THE PHILS 22,483,146,694.29 7,778,178,634.93 289.05%
MAYBANK PHILIPPINES INCORPORATED 5,866,903,788.74 2,036,189,716.30 288.13%
UNITED COCONUT PLANTERS BANK 17,194,349,897.69 5,989,286,726.79 287.09%
LAND BANK OF THE PHILIPPINES 19,660,424,623.82 7,173,190,275.55 274.08%
CENTURY SAVINGS BANK CORPORATION 85,057,345.70 34,734,041.96 244.88%
PHILIPPINE RESOURCES SAVINGS BANKING CORPORATION (PR SAVINGS 2,284,053,366.60 955,755,336.48 238.98%
DEVELOPMENT BANK OF THE PHIL 11,375,879,210.17 4,802,651,348.83 236.87%
UCPB SAVINGS BANK 2,181,355,529.00 975,156,384.32 223.69%
ROBINSONS BANK CORPORATION 1,526,179,000.00 691,088,663.30 220.84%
WORLD PARTNERS BANK (A THRIFT BANK) 233,248,015.31 107,415,667.13 217.15%
AL-AMANAH ISLAMIC INVESTMENT BANK OF THE PHILS 14,086,000.00 6,509,512.97 216.39%
PENBANK INC (A PDB) (FORMERLY: PENINSULA RB INC) 296,385,376.07 146,519,151.74 202.28%
LEGAZPI SAVINGS BANK INC 883,980,000.00 447,417,498.87 197.57%
BANK OF THE PHIL ISLANDS 14,630,469,098.69 7,688,633,689.58 190.29%
RCBC SAVINGS BANK INC 6,940,955,925.00 3,715,336,441.78 186.82%
PHILIPPINE BUSINESS BANK INC A SAVINGS BANK 2,367,490,000.00 1,322,295,019.15 179.04%
PHILIPPINE VETERANS BANK 3,271,497,966.53 1,898,738,872.12 172.30%
PHIL STAR DEVELOPMENT BANK INC 32,992,244.19 19,238,385.28 171.49%
FIRST CONSOLIDATED BANK INC (A PDB) 981,354,730.42 590,763,111.01 166.12%
DUNGGANON BANK (A MICROFINANCE THRIFT BANK) INC 44,956,037.73 28,178,352.90 159.54%
PRODUCERS SAVINGS BANK CORPORATION 494,118,240.10 311,505,684.33 158.62%
UNIVERSITY SAVINGS BANK INC 112,414,705.89 72,145,206.72 155.82%
CHINA BANK SAVINGS INC 6,532,320,468.89 4,293,974,170.33 152.13%
BPI FAMILY SAVINGS BANK INC 11,133,243,024.45 7,497,941,572.20 148.48%
STERLING BANK OF ASIA INC (A SAVINGS BANK) 1,313,560,000.00 936,700,031.78 140.23%
MARITIME SAVINGS BANK CORPORATION 34,367,927.90 24,652,054.39 139.41%
BANK OF MAKATI (A SAVINGS BANK) INC 3,007,263,665.45 2,243,073,464.02 134.07%
CTBC BANK (PHILIPPINES) CORP 604,025,971.98 460,786,467.63 131.09%
OPTIMUM DEVELOPMENT BANK INC 117,462,232.76 90,959,273.89 129.14%
PHIL POSTAL SAVINGS BANK INC 2,577,567,462.70 2,105,663,775.71 122.41%
EQUICOM SAVINGS BANK INC 731,313,376.49 601,715,967.86 121.54%
PNB SAVINGS BANK 1,006,106,182.06 829,192,484.27 121.34%
CITY SAVINGS BANK INC 1,747,962,369.63 1,530,120,230.40 114.24%
LUZON DEVELOPMENT BANK 619,258,583.26 544,175,490.99 113.80%
BPI DIRECT BANKO INC A SAVINGS BANK 583,639,711.06 547,319,743.95 106.64%
EAST WEST BANKING CORP 8,692,840,178.42 8,227,387,109.25 105.66%
1ST VALLEY BANK INC A DEVELOPMENT BANK 364,645,536.93 346,548,011.68 105.22%
LIFE SAVINGS BANK INC 14,820,094.54 14,205,894.15 104.32%
STANDARD CHARTERED BANK 2,166,958,692.61 2,123,003,347.70 102.07%
LEMERY SAVINGS & LOAN BANK, INC. 2,991,989.08 2,987,856.52 100.14%
BANGKOK BANK PUBLIC CO LTD 43,936,941.43 43,936,941.43 100.00%
BATAAN SAVINGS AND LOAN BANK 1,808,578.20 1,808,578.20 100.00%
HIYAS BANKING CORPORATION 34,826,424.16 34,826,424.16 100.00%
MALASIQUI PROGRESSIVE SLB, INC 12,713,229.25 12,713,229.25 100.00%
SUN SAVINGS BANK INC 14,982,841.40 15,103,167.59 99.20%
PAMPANGA DEVELOPMENT BANK 47,394,335.63 49,744,868.65 95.27%
WEALTH DEVELOPMENT BANK CORPORATION 187,556,440.55 240,199,722.90 78.08%
HONGKONG & SHANGHAI BANKING CORP 456,693,409.61 797,673,955.04 57.25%
PHIL BANK OF COMMUNICATIONS 1,065,744,487.21 2,259,014,990.06 47.18%
HSBC SAVINGS BANK(PHILS) INC 25,345,617.93 63,448,045.28 39.95%
ANZ BANKING GROUP LTD 800,875.76 404,087,064.26 0.20%
BUSINESS AND CONSUMERS BANK (A DB) 0.00 13,970,890.80 0.00%
CARD SME BANK INC A THRIFT BANK 0.00 48,473,003.59 0.00%
CITYSTATE SAVINGS BANK INC 0.00 119,756,629.16 0.00%
ENTERPRISE BANK INC (A THRIFT BANK) 0.00 232,694,561.97 0.00%
FARMERS SAVINGS & LOAN BANK INC 0.00 22,696,612.39 0.00%
MERCHANTS SAVINGS & LOAN ASSN INC 0.00 15,291,332.84 0.00%
NORTHPOINT DEV'T BANK INC 0.00 122,915,455.83 0.00%
THE PALAWAN BANK (PALAWAN DB) INC 0.00 14,849,692.88 0.00%
BANK OF AMERICA N.A. 2,184,000.00 0.00 NA
BDO PRIVATE BANK, INC. 0.00 0.00 NA
CATHAY UNITED BANK CO LTD - MANILA BRANCH 0.00 0.00 NA
DEUTSCHE BANK AG 0.00 0.00 NA
FIRST COMMERCIAL BANK LTD MANILA BRANCH 0.00 0.00 NA
INDUSTRIAL BANK OF KOREA MANILA BRANCH 0.00 0.00 NA
ISLA BANK(A THRIFT BANK) INC 0.00 0.00 NA
JP MORGAN CHASE BANK NATIONAL ASSN. 0.00 0.00 NA
MEGA INT'L COMM'L BANK CO LTD 531,088,408.21 0.00 NA
MIZUHO BANK LTD - MANILA BRANCH 251,875,357.82 0.00 NA
SHINHAN BANK - MANILA BRANCH 0.00 0.00 NA
SUMITOMO MITSUI BANKING CORPORATION-MANILA BRANCH 0.00 0.00 NA
THE BNK OF TOKYO-MITSUBISHI UFJ LTD 38,183,490.00 0.00 NA
Grand Total 343,185,514,345.46 130,563,795,522.67 262.85%


This level of classified loans should be measured against the bank's "capital cushion" or its ability to absorb losses.  Capital Cushion is normally defined as a bank's "Tangible Common Equity" plus its Loan Loss Reserves.  Tangible Common Equity (TCE) refers to the subset of shareholders' equity that is not preferred equity and not intangible assets.  So it excludes such items as Hybrid equity (like preferred shares) and goodwill.

By this measure, the level of "Classified Loans and other Risky Assets" amounts to Php 343.19 billion or 22.43% of the Php 1.53 trillion in Total Capital Cushion of Philippine Banks as of December 31, 2016.

Philippine Banking System
Classified Loans as % of Total Capital Cushion
December 31, 2016









Classified Loans Total Capital Cushion Classified Loans/Total Capital Cushion
Bank (In Php) (In Php) (In %)
BANK OF CHINA LIMITED-MANILA BRANCH 15,103,128,485.26 2,672,347,692.15 565.16%
INTER-ASIA DEVELOPMENT BANK 236,168,695.34 60,760,898.70 388.69%
UNITED COCONUT PLANTERS BANK 17,194,349,897.69 8,061,344,680.37 213.29%
PHIL POSTAL SAVINGS BANK INC 2,577,567,462.70 1,362,809,795.55 189.14%
VILLAGE BANK INC (A THRIFT BANK) 171,691,000.00 98,485,627.30 174.33%
MALAYAN BANK SAVINGS AND MORT BANK INC 1,680,015,585.65 1,283,661,051.68 130.88%
BATAAN DEVELOPMENT BANK 102,400,000.00 96,657,335.55 105.94%
LEGAZPI SAVINGS BANK INC 883,980,000.00 882,809,922.80 100.13%
WORLD PARTNERS BANK (A THRIFT BANK) 233,248,015.31 234,701,101.62 99.38%
EQUICOM SAVINGS BANK INC 731,313,376.49 758,995,198.35 96.35%
YUANTA SAVINGS BANK PHILIPPINES INC 1,056,171,182.20 1,105,008,705.94 95.58%
LUZON DEVELOPMENT BANK 619,258,583.26 658,520,505.27 94.04%
PHILIPPINE RESOURCES SAVINGS BANKING CORPORATION (PR SAVINGS 2,284,053,366.60 2,476,919,001.92 92.21%
METRO CEBU PUBLIC SAVINGS BANK 66,150,726.24 91,015,811.52 72.68%
CHINA BANK SAVINGS INC 6,532,320,468.89 9,234,578,383.26 70.74%
PHIL SAVINGS BANK 14,149,535,551.21 22,178,636,172.40 63.80%
UCPB SAVINGS BANK 2,181,355,529.00 3,428,720,199.39 63.62%
RCBC SAVINGS BANK INC 6,940,955,925.00 11,602,333,846.39 59.82%
PENBANK INC (A PDB) (FORMERLY: PENINSULA RB INC) 296,385,376.07 550,531,931.42 53.84%
BANGKO KABAYAN INC (A PRIVATE DEVELOPMENT BANK) 221,605,766.24 454,943,864.25 48.71%
MARITIME SAVINGS BANK CORPORATION 34,367,927.90 71,452,966.96 48.10%
PHILIPPINE VETERANS BANK 3,271,497,966.53 6,903,137,432.84 47.39%
DUMAGUETE CITY DEV BANK INC 117,490,000.00 270,074,160.98 43.50%
CORDILLERA SAVINGS BANK INC 64,689,076.01 148,912,543.90 43.44%
MAYBANK PHILIPPINES INCORPORATED 5,866,903,788.74 13,538,862,099.91 43.33%
BANK OF COMMERCE 7,836,421,529.56 18,193,111,829.37 43.07%
STERLING BANK OF ASIA INC (A SAVINGS BANK) 1,313,560,000.00 3,126,545,761.22 42.01%
BANK OF MAKATI (A SAVINGS BANK) INC 3,007,263,665.45 7,370,251,259.05 40.80%
UNIVERSITY SAVINGS BANK INC 112,414,705.89 289,016,791.59 38.90%
BPI FAMILY SAVINGS BANK INC 11,133,243,024.45 28,771,568,606.47 38.70%
DUNGGANON BANK (A MICROFINANCE THRIFT BANK) INC 44,956,037.73 121,524,055.84 36.99%
UNION BANK OF THE PHILS 22,483,146,694.29 62,809,305,314.47 35.80%
BANK ONE SAVINGS AND TRUST CORP. 204,239,198.39 575,561,384.50 35.49%
QUEEN CITY DEVELOPMENT BANK INC OR QUEENBANK A THRIFT BANK 221,987,127.82 681,047,909.21 32.59%
PHIL STAR DEVELOPMENT BANK INC 32,992,244.19 101,975,258.53 32.35%
PAMPANGA DEVELOPMENT BANK 47,394,335.63 154,884,142.04 30.60%
PRODUCERS SAVINGS BANK CORPORATION 494,118,240.10 1,617,773,988.39 30.54%
CITIBANK, N.A. 5,167,048,362.39 17,086,459,291.36 30.24%
BPI DIRECT BANKO INC A SAVINGS BANK 583,639,711.06 2,019,573,463.87 28.90%
PHIL NATIONAL BANK 32,765,210,227.83 118,157,606,806.42 27.73%
STANDARD CHARTERED BANK 2,166,958,692.61 8,180,830,061.99 26.49%
PHIL TRUST COMPANY 5,784,000,000.00 23,130,994,453.97 25.01%
FIRST CONSOLIDATED BANK INC (A PDB) 981,354,730.42 3,925,892,000.89 25.00%
LAND BANK OF THE PHILIPPINES 19,660,424,623.82 78,898,242,798.67 24.92%
1ST VALLEY BANK INC A DEVELOPMENT BANK 364,645,536.93 1,509,636,707.55 24.15%
EAST WEST BANKING CORP 8,692,840,178.42 36,402,000,855.23 23.88%
MEGA INT'L COMM'L BANK CO LTD 531,088,408.21 2,231,943,410.87 23.79%
DEVELOPMENT BANK OF THE PHIL 11,375,879,210.17 48,427,385,550.96 23.49%
PHILIPPINE BUSINESS BANK INC A SAVINGS BANK 2,367,490,000.00 10,268,291,322.69 23.06%
LIFE SAVINGS BANK INC 14,820,094.54 67,261,879.66 22.03%
MALASIQUI PROGRESSIVE SLB, INC 12,713,229.25 59,092,503.42 21.51%
CHINA BANKING CORP 13,491,147,877.52 64,449,112,327.99 20.93%
BDO UNIBANK INC 46,117,189,189.88 222,129,864,926.92 20.76%
QUEZON COCONUT BANK INC (A THRIFT BANK) 12,142,369.67 58,896,033.08 20.62%
CITY SAVINGS BANK INC 1,747,962,369.63 8,488,295,958.79 20.59%
ASIA UNITED BANK CORPORATION 4,784,481,341.54 24,213,265,697.34 19.76%
HIYAS BANKING CORPORATION 34,826,424.16 181,272,201.82 19.21%
WEALTH DEVELOPMENT BANK CORPORATION 187,556,440.55 1,391,408,552.86 13.48%
OPTIMUM DEVELOPMENT BANK INC 117,462,232.76 872,676,014.05 13.46%
RIZAL COMM'L BANKING CORP 7,742,581,334.23 61,237,910,163.72 12.64%
ROBINSONS BANK CORPORATION 1,526,179,000.00 13,328,883,285.32 11.45%
KEB HANA BANK - MANILA BRANCH 159,898,935.21 1,582,723,292.43 10.10%
PHIL BANK OF COMMUNICATIONS 1,065,744,487.21 10,859,291,581.53 9.81%
SECURITY BANK CORP 9,018,000,000.00 92,876,035,419.44 9.71%
METROPOLITAN BANK & TCO 19,945,341,081.96 212,212,640,479.13 9.40%
BANK OF THE PHIL ISLANDS 14,630,469,098.69 158,859,660,704.92 9.21%
CENTURY SAVINGS BANK CORPORATION 85,057,345.70 969,488,170.41 8.77%
PNB SAVINGS BANK 1,006,106,182.06 12,062,171,039.90 8.34%
CTBC BANK (PHILIPPINES) CORP 604,025,971.98 7,571,131,213.35 7.98%
SUN SAVINGS BANK INC 14,982,841.40 196,444,008.63 7.63%
MIZUHO BANK LTD - MANILA BRANCH 251,875,357.82 5,749,964,606.89 4.38%
AL-AMANAH ISLAMIC INVESTMENT BANK OF THE PHILS 14,086,000.00 354,263,955.59 3.98%
LEMERY SAVINGS & LOAN BANK, INC. 2,991,989.08 81,920,093.91 3.65%
HONGKONG & SHANGHAI BANKING CORP 456,693,409.61 13,976,676,208.74 3.27%
BATAAN SAVINGS AND LOAN BANK 1,808,578.20 59,861,620.72 3.02%
ING BANK N.V. 40,000,000.00 2,606,771,914.09 1.53%
HSBC SAVINGS BANK(PHILS) INC 25,345,617.93 1,862,329,637.76 1.36%
BANGKOK BANK PUBLIC CO LTD 43,936,941.43 3,464,889,177.00 1.27%
THE BNK OF TOKYO-MITSUBISHI UFJ LTD 38,183,490.00 4,967,420,166.75 0.77%
BANK OF AMERICA N.A. 2,184,000.00 2,123,761,205.20 0.10%
ANZ BANKING GROUP LTD 800,875.76 4,502,641,749.66 0.02%
BDO PRIVATE BANK, INC. 0.00 5,065,100,238.11 0.00%
BUSINESS AND CONSUMERS BANK (A DB) 0.00 95,724,586.04 0.00%
CARD SME BANK INC A THRIFT BANK 0.00 620,521,098.74 0.00%
CATHAY UNITED BANK CO LTD - MANILA BRANCH 0.00 2,137,548,971.18 0.00%
CITYSTATE SAVINGS BANK INC 0.00 756,794,369.28 0.00%
DEUTSCHE BANK AG 0.00 2,127,918,284.06 0.00%
ENTERPRISE BANK INC (A THRIFT BANK) 0.00 382,097,130.25 0.00%
FARMERS SAVINGS & LOAN BANK INC 0.00 129,294,538.69 0.00%
FIRST COMMERCIAL BANK LTD MANILA BRANCH 0.00 2,119,950,000.00 0.00%
INDUSTRIAL BANK OF KOREA MANILA BRANCH 0.00 2,181,032,346.27 0.00%
ISLA BANK(A THRIFT BANK) INC 0.00 666,976,418.68 0.00%
JP MORGAN CHASE BANK NATIONAL ASSN. 0.00 1,406,989,114.78 0.00%
MERCHANTS SAVINGS & LOAN ASSN INC 0.00 702,306,744.45 0.00%
NORTHPOINT DEV'T BANK INC 0.00 424,608,422.63 0.00%
SHINHAN BANK - MANILA BRANCH 0.00 2,205,330,996.00 0.00%
SUMITOMO MITSUI BANKING CORPORATION-MANILA BRANCH 0.00 13,084,187,806.49 0.00%
THE PALAWAN BANK (PALAWAN DB) INC 0.00 40,515,065.36 0.00%
Grand Total 343,185,514,345.46 1,529,842,565,877.60 22.43%

Stress Test Scenarios

Aggregate

So how will a 10%, 20%, 30%, 40%, and even 50% write-off of Classified Loans affect the Total Capital Cushion of the Philippine Banking System?

In the aggregate, if Classified Loans amount to 22.43% of the banking system's Total Capital Cushion, then it follows that a 10% write-off of Classified Loans will reduce the total capital by 2.24% and a 50% write-off of classified loans will reduce the banking system's Total Capital Cushion by 11.22%.

Individual Banks

A 10% write-off of Classified Loans would severely impact (by 30% or more) the Total Capital Cushion of two banks (severely affected banks highlighted in yellow).
  1. Bank of China Limited - Manila Branch (56.52% reduction in Total Capital Cushion)
  2. Inter-Asia Development Bank (38.87% reduction in Total Capital Cushion)

A 20% write-off of Classified Loans will totally wipe out the Total Capital Cushion of one bank and severely impact the Total Capital Cushion of four more banks:


  1. Bank of China Limited - Manila Branch (113.03% reduction in Total Capital Cushion)
  2. Inter-Asia Development Bank (77.74% reduction in Total Capital Cushion)
  3. United Coconut Planters Bank (42.66% reduction in Total Capital Cushion)
  4. Philippine Postal Savings Bank Inc (37.83% reduction in Total Capital Cushion)
  5. Village Bank Inc (34.87% reduction in Total Capital Cushion)


A 30% write-off of Classified Loans will totally wipe out the Total Capital Cushion of two banks and severely affect (reduce by 30% or more) the Total Capital Cushion of six other banks:

  1. Bank of China Limited - Manila Branch (169.55% reduction in Total Capital Cushion)
  2. Inter-Asia Development Bank (116.61% reduction in Total Capital Cushion)
  3. United Coconut Planters Bank (63.99% reduction in Total Capital Cushion)
  4. Philippine Postal Savings Bank Inc (56.74% reduction in Total Capital Cushion)
  5. Village Bank Inc (52.30% reduction in Total Capital Cushion)
  6. Malayan Bank Savings and Mortgage Bank Inc (39.26% reduction in Total Capital Cushion)
  7. Bataan Development Bank (31.78% reduction in Total Capital Cushion)
  8. Legazpi Savings Bank Inc (30.04% reduction in Total Capital Cushion)


A 40% write-off of Classified Loans will totally wipe out the Total Capital Cushion of two banks and severely affect (reduce by 30% or more) the Total Capital Cushion of eleven more banks:

  1. Bank of China Limited - Manila Branch (226.07% reduction in Total Capital Cushion)
  2. Inter-Asia Development Bank (155.47% reduction in Total Capital Cushion)
  3. United Coconut Planters Bank (85.32% reduction in Total Capital Cushion)
  4. Philippine Postal Savings Bank Inc (75.65% reduction in Total Capital Cushion)
  5. Village Bank Inc (69.73% reduction in Total Capital Cushion)
  6. Malayan Bank Savings and Mortgage Bank Inc (41.37% reduction in Total Capital Cushion)
  7. Bataan Development Bank (42.38% reduction in Total Capital Cushion)
  8. Legazpi Savings Bank Inc (40.05% reduction in Total Capital Cushion)
  9. World Partners Bank (39.75% reduction in Total Capital Cushion)
  10. Equicom Savings Bank Inc (38.54% reduction in Total Capital Cushion)
  11. Yuanta Savings Bank Philippines Inc (38.23% reduction in Total Capital Cushion)
  12. Luzon Development Bank (37.62% reduction in Total Capital Cushion)
  13. Philippine Resources Savings Banking Corporation (36.89% reduction in Total Capital Cushion)

A 50% write-off of Classified Loans will totally wipe out the Total Capital Cushion of three banks and severely affect (reduce by 30% or more) the Total Capital Cushion of fourteen more banks:


  1. Bank of China Limited - Manila Branch (282.58% reduction in Total Capital Cushion)
  2. Inter-Asia Development Bank (194.34% reduction in Total Capital Cushion)
  3. United Coconut Planters Bank (106.65% reduction in Total Capital Cushion)
  4. Philippine Postal Savings Bank Inc (94.57% reduction in Total Capital Cushion)
  5. Village Bank Inc (87.17% reduction in Total Capital Cushion)
  6. Malayan Bank Savings and Mortgage Bank Inc (65.44% reduction in Total Capital Cushion)
  7. Bataan Development Bank (52.97% reduction in Total Capital Cushion)
  8. Legazpi Savings Bank Inc (50.07% reduction in Total Capital Cushion)
  9. World Partners Bank (49.69% reduction in Total Capital Cushion)
  10. Equicom Savings Bank Inc (48.18% reduction in Total Capital Cushion)
  11. Yuanta Savings Bank Philippines Inc (47.79% reduction in Total Capital Cushion)
  12. Luzon Development Bank (47.02% reduction in Total Capital Cushion)
  13. Philippine Resources Savings Banking Corporation (46.11% reduction in Total Capital Cushion)
  14. Metro Cebu Public Savings Bank (36.34% reduction in Total Capital Cushion)
  15. China Bank Savings Inc (35.37% reduction in Total Capital Cushion)
  16. Philippine Savings Bank (31.90% reduction in Total Capital Cushion)
  17. UCPB Savings Bank (31.81% reduction in Total Capital Cushion)
Please bear in mind that a number of these banks are already very weak and are in distress.  Please see a previous blog post: "The Top Distressed Philippine Banks as of December 31, 2016".  Moreover, their capital can be overstated.  See a previous blog post "Overstated Capital of Philippine Banks as of December 31, 2016".  As such, any reduction in their capital cushion could knock down an already weak bank.

Source: www.bsp.gov.ph