the current risk management framework in use by … · (kuran: 2003) blames the inheritance system...
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THE CURRENT RISK MANAGEMENT FRAMEWORK IN USE BY ISLAMIC BANKS CAN BE IMPROVED. IMPROVEMENTS MADE ARE ESSENTIALLY BENEFICIAL TO THE GLOBAL FINANCIAL SYSTEM.
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The current risk management framework in use by Islamic Banks can be improved.
Improvements made are essentially beneficial to the global financial system.
Ariffhidayat Ali
INCEIF
Author Note
Ariffhidayat Ali, PHD Candidate, Matric No: - 0900320
Term Paper for Risk Management for Islamic Financial Institutions
(TK 6413) Semester January 2011
Supervisor: - Datuk Prof. Dr. Kamaruddin Sharif
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Abstract
This paper demonstrates that the current Risk Management framework in Islamic Banks (IBs)
needs improvement. The current “value-free” framework can be improved since presently
guided by a single worldview. This worldview shapes and influences the on-going realities of
the global financial system including IBs. The paper’s approach is moderately abstract
employing philosophical, religious, historical and socio-political analysis. The modified
“value driven” framework must reflect goals that are tangible and measurable. The twin
notions of “ijtihad” and “jihad” need to be employed; essentially it is knowledge and action
working in concert. Stakeholders within IB remain the conduit shaping the current and future
framework. This is seen as an industrial, institutional down to a leadership/managerial
challenge. There is logic in using the risk management framework as the conduit for Shariah
values. Bring this together with human resource development and the use of technology and
we essentially have the foundation of knowledge in Islam namely reason, experience and
revelation. A well-functioning Islamic financial system transcends the Muslim world leading
to a “win-win” for humanity.
Key terms: Risk Management, Shariah, Knowledge, Worldview, Ijtihad, Jihad, Values,
Technology and Human Resource.
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The current risk management framework in use by Islamic Banks can be improved.
Improvements made are essentially beneficial to the global financial system.
The Islamic finance industry has grown at a tremendous double digit annual growth
(estimates of between 15% - 25% dependent on the sources) and has surpassed the USD 1
trillion figure. It has also become a permanent fixture within the global financial landscape.
Due to this and arising out of globalization, any stabilizing and de-stabilizing events resulting
from within the industry affects the system. Nevertheless it remains a “David” compared to
the “Goliath” of the conventional industry. A feature of banking is that it deals in risk which
is essentially a feature of our existence. Banking is and continues to become more complex
and thus demand any framework of risk management to be exceptionally robust.
The existing framework is and continues to being “shaped by” and “is shaping”
developments within capitalism or the worldview shaping capitalist behaviour and
orientation. At a philosophical level, it is essentially “man-centric”, knowledge as
epistemologically grounded in reason and experience; which is essentially rational. This gave
rise to the supremacy of science, which is “value-free”, subject to empirical testing, reduced
to theories (constructs that can be either proven or falsified) or consistent in terms of logic
and/or in its mathematics. Our departure comes from the premise that in dealing with
anything “Islamic” we must look towards having values. More importantly the objectives that
these values orientate towards must be tangible and measurable. At present there are certain
dislocations within Islamic Banking that has not been given its due attention, partially
undermined by the current restrictive framework.
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However, the risk management function is by far the most suitable in pushing this agenda
since we are all cognizance of the risk-reward relationship, a relationship that most agree
must be in balance, the risk management function encapsulates most if not all areas within a
banking institution and this function is seen as an important “cog” in ensuring the on-going
viability of a banking institution.
To begin with, a proposal for reform must essentially in essence explain any deficiencies
within the existing framework. A major one has been mentioned above, namely the “value-
free” foundation. However for something to gain acceptance must essentially arise out of
certain “pull” or “push” factors. These factors are elaborated in the paper. Some are related to
the exegesis surrounding rise of modern capitalism and banking, to the nature of Islam itself,
to the rise and fall of the Islamic civilization, replaced by the West and how this has shaped
the present global economic system.
In approaching all of the above, the essential ingredients of the existing framework is
discussed, the transmission of the framework, its institutionalization, the interest/preferences
of major stakeholders, how these factors has shaped their roles in theory and practice.
The paper concludes that what is good for the Islamic financial system namely to be “value”
driven with clear, tangible and measurable Shariah objectives (founded on “ijtihad” and
“jihad”) will be good for Islam. A robust Islamic financial system plays a stabilizing role not
only by mitigating against “systemic” risk but more so in contributing towards social and
political stability globally. The West need not fear an Islamic resurgence and must essentially
look beyond misinterpreting the use of certain concepts especially “jihad”.
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Literature Review
This has been intentionally divided into two sections. The 1st section addresses subjects that
serve as bedrock to our main discussion on risk. The subject matter of risk will be dealt in the
2nd section.
Section 1: Major philosophical and historical developments shaping present
economic realities
Practice precedes attempts to fully understand a phenomenon. Economics in all its
complexities was rendered only as a “science of the household” if we refer to Aristotle’s
Politics. Hellenistic philosophy seen by most as the foundation of Western civilization didn’t
escape the scrutiny of Arab philosopher (Adamson & Taylor e.d.: 2005)
Trading and commercial activities is sine qua non with the growth of Islam. Mekah’s
location, status and thus influence shaped the course of the religion (Holt e.d.: 2008). The
expansion of Islam into South-East Asia to a large extend coincided with the arrival of
Islamic traders to our shores. (Ricklefs: 2002). The richness of literature on fiqh muamalat
transcended all the mazhabs and much revolved around the Islamic contracts in existence at
that time (Hidayat Buang: 2007)
Natural if we look at nature, water falling from the higher point. A superior civilization
essentially nourishes the inferior civilization. Thus knowledge essentially flowed from the
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Islamic world to the West (Makdisi: 1999). Some of these debts were acknowledged whilst
some were not.
The ascendancy of a civilization does not last (Kennedy: 1989). From perhaps the middle of
the 15th century) onwards, Islam went into decline. Numerous theories for explaining the
decline have been ventured. (Hidayat Buang: 2007) saw the decline as a result of Muslims’
indifferent attitude towards the application of the Shariah. (Schacht: 1964) saw this being due
to “the closing of the gates of Ijtihad” as a factor for the decline. (Kuran: 2003) blames
the inheritance system for Muslim economic underdevelopment.
Banking is relatively more difficult to place in the context of Islamic history.
The existence of the Baitulmal could at least be traced to the time of Sayiddina
Umar al Khattab (Azmi: 2002). Based on Wikipedia, Western claims to banking
are perhaps stronger, the word itself is Western andthe oldest bank still in existence is
Monte dei Paschi di Siena, headquartered in Siena, Italy, and has been operating continuously
since 1472. More pertinent is on the institution of usury or “riba”. An early detractor was
Aristotle and Christianity itself held out till around the 17th century.
Essentially the growth of banking is synonymous with an expansionist Europe
(the United States arrived much later). Banks mostly in private hands became
conduits to finance the expensive business of war fought increasingly by
professional soldiers. Early bankers were believed to include the Knight
Templars connecting the Church and the various European states. War became
merely an extension of political action (Von Clausewitz: 1827)
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The aberrations of the Church sparked events such as the Reformation, the
Inquisition and the Enlightenment. In the end the Church’s credibility were left
in tatters. It led to the rise of a secular West, where religion underwent
desacralization and the supremacy of science over dogma. The epistemology of
knowledge was to be grounded on reason and experience. Man now possesses the
necessary implements to chart his own destiny. Rational thought, empiricism,
logical positivism or variants of these laid down the foundation of all sciences
deemed value-free since the constructs of the hypotheses, models and theories
are based on largely observable, testable but more importantly grounded in logic
and mathematics. The above essentially shapes the conventional worldview.
Growth of capitalism globally introduced the sceptre of economic crises be it
affecting the real economy, the financial sector as well as the banking industry
per se. Since crises became global, trans-national institutions came into being
and the role of Central Banks also changed. Both international and domestic
economic stability needed to be secured. Banking specific tools like deposit
insurance, legislation such as the Glass-Steagall Act and the Basel initiatives
which came later were introduced. (Just to name a few).
Suffice to say that the above are efforts to manage risk collectively. Islam
meanwhile continued in slumber with some periodic awakenings. The revival
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gathered pace in the late 19th and the early 20th century in the Middle East and
the Asian sub-continent. The revival was multi-factorial and the focus was multi-
dimensional. Names such as Hassan al Banna, Muhammad Abduh, Jamal Al-Din
Afghani and Sayyid Qutb sprang forth from either religious or educational
establishments. Later the Cold War arrived and being “neutral” was not an
option. (Baqir as-Sadar: 1982) saw this and discussed both these conflicting
ideologies. More importantly, he re-emphasized the concept of the “Ummah”
arising above state and regional interests.
Some identified the malaise affecting Muslims worldwide as a crisis of
identity due to millennia of decline in all areas. A remedy which became
known as the Islamization of Knowledge (IOK) initiative was championed by
the likes of Al-Attas and Ismail al-Faruqi. Much literature has been expended
by supporters and detractors alike. IOK is closely related to worldview and
much has been written on the subject (Waleed: 2008, Sardar: 2002, Al-Attas: 1978) as
compared to the conventional. Most are within the context of philosophy, politics and
economics. None approaches it from the risk management angle; the closest brush is
perhaps on accounting via works of Shahul Hameed. Islamic banking (essentially “banking
without riba”) continues to be seen as an important clog within Islamic economics. Mit-
Ghamr Bank (Egypt), Pilgrims Funds Board (Malaysia) was seen as the first IBs. Other
major impetus and results of the revival was the Oil Crisis in the early 70s, the Iranian
Revolution in 1979, the support of governments in Pakistan, Sudan and Malaysia.
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Section 2: Risk and risk management
Risk is synonymous with existence. It may be inferred from Darwin, dealt with
in any version of the Bible. The Al-Quran also is littered with reference to the
ideas of risk, profit and loss namely Q2:155, Q3:142 and many others.
(Saiful Azhar Rosly & Mohammad Ashadi: 2010) referring to Elgari and then
Shelagh renders uncertainties leading to loss or personal injury as risk based on the
Arabic word mutakharah, as the situation that involves the probability of deviation from the
path that leads to the expected or usual result. This is somewhat similar to the definition
espoused by proponents of conventional finance, i.e. risk is the volatility or SD of net cash
flows of the firm. We must cite “al ghunmu bil ghurm” (profit is linked to loss) or “al-kharaj
bid-daman” (Entitlement to revenue is based on corresponding liability for bearing loss) as
being the sole basis for legitimate profit in Islamic finance. No discussion on risk is complete
without mentioning Frank Knight namely his discussion on the notion of uncertainty vis a vis
risk and the justification of profit for the entrepreneur for assuming the challenges posed by
uncertainty (Knight: 1921)
Risk management is the process by which managers identify key risks, obtaining consistent,
understandable, operational risk measures, choosing which risks to reduce and which to
increase and by what means, and establishing procedures to monitor the resulting risk
position (Pyle: 1997)
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Dealing with risk has always been the raison d’etre of financial intermediation and its
underlying principle (Scholtens and van Wensveen, 2000, p. 1247) as such risk management
in banking and insurance is not a new phenomenon (Schroeck, 2002). According to Nocco
and Stulz (2006), to create shareholder value, every enterprise should have an integrated,
holistic approach to risk management. Maximizing shareholder value is the mantra within
finance, reflected by most corporate finance textbooks. Risk management is more important
in the financial sector than in other parts of the economy (Carey, 2001) as it is a cornerstone
of prudent banking practice as banking is, in fact, a business of risk; therefore, efficient risk
management is vital (Al-Tamimi and Al-Mazrooei, 2007).
(Furash: 1996) saw that comprehensive risk management is important in managing large,
diverse, and complex financial services companies especially banks. In Islamic banking, risk
management and ability to manage different risks is seen as one of the critical factors in
providing better returns to the shareholders (Akkizidis and Khandelwal, 2008, Khan and
Ahmed, 2001). The challenges of globalization necessitate effective and efficient risk
management (Sundararajan and Errico, 2002). Essentially this is demonstrated by the growth
of standard setting bodies like AAOIFI and IFSB, various academia led research institutes,
central banks activism down to concern bloggers in cyberspace.
Whilst the above represents the rationale, the following represents the current dynamics
permeating the area. Risk management in Islamic Banking is not significantly different from
conventional banking (Thijs: 2010). There is also no special risk management approaches
required in Islamic banking, only the analysis and identification of the risk environment (van
Greuning and Iqbal: 2008). There are unique risks in Islamic banking vis a vis the application
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of the various Islamic contracts, the measurement of these risks needs improvements by
applying for examples value-at-risk (VAR) methodology (Sundararajan: 2007). There has
also been burgeoning interests in measuring the performance of Islamic banks against
conventional banks applying various measures with both business and risk management
implications (Iqbal and Molyneux (2005), Iqbal and Llewellyn (2002). However compared to
conventional risk management and especially in areas identified below the research from the
Islamic perspective has been relatively abbreviated in length and technical analysis.
The several areas on risk management researched from the conventional perspective are:
1. Theoretical side of risk management (e.g. Schmith and Roth, 1990; Santomero and
Babbel, 1997 and Oldfield and Santomero, 1997).
2. Risk management in banking (e.g. Santomero, 1997; Oldfield and Santomero, 1997; and
Boston Consulting Group, 2001).
3. Credit risk management (e.g. Avery and Berger, 1991; Drzik, 1998 and SAS and Risk
Magazine, 2004)
The recent financial crisis has essentially contributed to again shifting the risk management
agenda to the forefront of the industry’s concern. Islamic banking is seen as either being
exposed to additional risks as compared to conventional banking, certain risk areas within the
industry needs reassessment whilst at the same time dealing with present and future Basel
related initiatives. The likes of Siddiqi, Chapra, Mirakhor and others have commented on the
risk issues facing IBs.
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The questions that we plan to address are as follows:-
1) Islamic banking have been extensively reviewed and commented on. Can
we identify the major areas covered under the “circle of concern” for
Islamic Banking?
Without a doubt, to answer the above means essentially threading into the
minefield of subjectivity. For a start, where does one draw the appropriate
timeline and demarcate the literature. Secondly what constitutes an objective
review or comment (as initial filter supervisor, regulator or industry insider
comments and review is to be critically assessed). Does one look to frequency,
controversy or any other notion that implies concern or importance? Lastly does
one take the micro approach or macro approach in putting the circle together
bearing in mind the interlocking and permeable lines that exist?
For this the author identified the Profit Loss Sharing (PLS) the divergence
between theory and reality as within the circle. (Mirakhor: 1987), Siddiqi earlier
works and Chapra have written on this. It fits in term of its length of time in
discussion, being reviewed by veterans of the industry, it has frequency, also
controversy and some regulators have commented on this issue.
The second item to be included within the circle is the relevance and continuing
importance of the subject matter of “the prohibition of interest (riba) in Islam”
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which continues to attract reviews, comments and studies from different
perspectives.
The third item to be included within the circle is perhaps demonstrative of the
micro/macro approach and the interlocking areas of concern. This relates to the
product and solutions that have been delivered, in use, in production, pending
delivery to the market. Concerns range from the perspective of issues on
“financial engineering”, on “form versus substance”, “asset backed versus asset
backed”, “the role of Shariah advisors and Shariah boards” and other approach
one may decide to pursue. One may then struggle to frame the item within the
circle effectively. For this purpose, classifying this under “competitive
positioning” is deemed appropriate.
2) Has risk management been recognized within the circle and the major
determinants affecting this?
The first fallacy to be avoided is the notion that recognizing the existence of risk
and the ability to classify risks into types of risks constitutes risk management.
The preceding identifies risk as a noun; risk management is a verb, a series of
activities that is circular and without end. Essentially the environment this
activity has taken shape in the context of Islamic banking are essentially
influenced and identified as per below.
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Z = Factors shaping the risk management activity/environment surrounding IBs
Z = f (Ijtihad in the history of fiqh muamalat prior to the 20th century, modern
day ijtihad applied in Islamic Banking and the resulting “fit” of Islamic banking
within Islamic Economics*, state of industrial maturity linked to the
development of risk management practices in conventional banking*, role of
both internal and external stakeholders. *, ∞) * signifies a dynamic state.
Ijtihad in the history of fiqh muamalat prior to the 20th century
As a concept, Ijtihad is representative of the foundation of knowledge in Islam. It is
systematic, guided by rules down to the persons qualified to exercise ijtihad and non-
speculative. On the law of contract, Western commentators pointed to the lack of a so-called
general theory of contract. (Saleh: 1990) referred to fiqh being casuistic not dogmatic, it is meant
to solve cases whilst declining to devise theories from the solution given to those cases. Fiqh
muamalat dealt with realities of actual business and risk management was predominantly tackling
the gharar elements within the sale (bay’) contract. Another feature of the “gharar” discussion
remains the diversity of opinions even at the conceptual level as opposed to the discussion on
“riba”. On regulation, historical precedents exist in the practice of the Prophet s.a.w as well as in the
institution known as “hisba”. An important feature needs stressing is that the early fuqahas never
co-existed peacefully or at best were neutral towards the state.
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Modern day Ijtihad applied in Islamic Banking and the resulting “fit” of
Islamic banking within Islamic Economics
Modern jurists and practitioners are subject to the external environment often describe as a state of
emergency or “Daruriyyah” at the inception of Islamic Banking. Mit Ghamr itself was modelled on
the German savings bank and did not label itself as an Islamic bank. The historical imperative was
to ensure a “riba” free beginning and this took centre stage. From the onset, Islamic Banks adopted
the conventional model in terms of organizational structure, similar set of financial accounts barring
some adjustments, embraced technology designed for conventional banking and the list of
similarities goes on. The differentiator was the emergence of Shariah advisors, Shariah boards
(internal and external to the IBs) and other stakeholders (to include academia, the public, standard
setting bodies etc.). Without doubt, the basic framework of risk management was adopted from the
conventional model. The question of “fit” should be clear based on the above. A feature that needs
mentioning was the role governments in pushing the agenda as either owners/influencing
supervisors. This is essentially an unsettling heritage since it remains questionable whether the right
foundations were established. Examples, as mentioned Mit Ghamr and others were nationalized by
Nasser several years later. The Iranian Revolution also saw state control of the economy. Another
was Khurshid Ahmad experiment in establishing an Islamic economics system in Zia-ul-Haq’s
Pakistan. Lastly we cite Tun Mahathir’s “Inculcating Islamic Values” initiative in Malaysia. Some
saw this merely as UMNO responding to PAS in trying to win the Malay majority. Also it was seen
as a ploy to lure the firebrand ABIM leader, Anwar Ibrahim who later became his deputy. Lastly
we need to bring up how politicized the banking industry can be in Malaysia where pre-
consolidation certain banks were identified as being flagships of either MCA or UMNO.
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State of industrial maturity and development of risk management practices
in conventional banking
Islamic banking is a new phenomenon, and modelling itself on conventional
banks and modelling risk management practices on conventional banking is
preferred and efficient. However there is a need to realize two important facts.
One, the focus on risk management in conventional banking in itself is a new
phenomenon. We may want to identify the starting point as being the
Depression; some may point to the rise of volatility in the financial world since
the mid-1970s and who is to argue if we point towards Basel 1 introduction in
1988. Secondly, one theme must be stressed from the above, major regulatory
responses arise mainly due to events. It can be single event driven, some as
response to cumulative events, some maybe termed as crises regardless whether
it is regional or the worst of its kind a global crises. Since Islamic banking is
part of the global financial system there is no running away from being affected
by events or more importantly choosing to opt out (if this option is indeed
possible) from implementing risk management practices.
Based on recent developments, we can be positive in stating that risk
management has steadily made headway within the circle of concern but its
agenda has been catapulted further due to emphasis being put on it against by the
likes of Siddiqi, Chapra and Mirakhor etc.
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Role of both internal and external stakeholders
Survey any organization chart of a bank and the risk management function
occupies an important position within the hierarchy often with an independent
reporting line. However banks are by nature a business driven organization
where profit centres are seen in a different light compared to cost centres. One of
the aspects of modern organizations is the agency relationship that describes the
relationship between managers and the business owners. Whether managers serve
the owners interest in maximizing shareholders value or maximizing their own
perks (most performance related to profit/revenue measures) remains an on-
going subject for research. A single time series study conducted over an eight
period between January 1, 1992 and December 31, 1999 showed a selected list of European
banks having underperformed compared to the broad market index on which they are listed
on does raise eyebrows but the author does not want to infer too much into this (Schroeck
2002). Suffice to point out that bank management may not necessarily be at the forefront of
the industry in creating value.
A feature of the globalization and liberalization of the financial system was namely the rise of
mega-banks formed mostly via mergers and acquisition (M&A). It has become an undeniable
fact that organic growth has come to be seen by some as a “slow” growth strategy and M&A
activities maybe preferred. Often institutions with a higher market capitalization/share value
initiate the takeover of a smaller rival. Recent examples were the Royal Bank of Scotland
taking over National Westminster Bank in 2000 and ABN AMRO Bank N.V. in 2007.
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Risk management as a function are cost centres and classified as a
backroom/business support function. Some suffer the indignity of being subject
to a lower remuneration program. A feature recognized by Jamie Diamond at JP
Morgan which he addressed (Tett: 2009). In good times, in the context of credit
risk, these risk managers are often ridiculed as “naysayers”. During downturns,
some gloat at being proven right but often having to do the thankless job of debt
recovery or debt restructuring involving negotiations with either hostile,
recalcitrant or desperate customers. There is absolutely no doubt that the above
legacy is reflected in most IBs.
External stakeholders can be classified as government political, economic and
trade blocs, Central Banks (CB), International organizations, standard setting
bodies, Development Banks, Research institutes, Universities, Legal and
accounting firms, Jurisdiction specific bodies, Industry/Trade Associations and
Law enforcement bodies.
The above plethora of stakeholders influences the risk management landscape.
The ability to influence can be expressed as
Z = Factors affecting the ability to influence
Z = f (legitimacy, goal congruent, subject matter expertise, resource availability,
ability to reward and/or sanction, ∞)* regardless whether these are “real” or
“perceived” and * signifies a dynamic state
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By far the largest influence remains the Basel Capital Accords.
The Basel Committee came into the existence when the members of the G-10
nations decided it needed to check the increasing volatility of the global
financial system. This volatility in part related to the expanded use of technology
in the financial markets, the growing interrelatedness of financial centres, and
the introduction of new financial products. However matters came to the boil
when Bankhaus Herstatt collapsed in 1974 and since then counterparty
settlement risk became referred as Herstatt risk (Horcher: 2005) . Event driven
regulation has been addressed but more important is the time span of 14 years
the countries to agree on Basel 1 which was a 26 pager document. Secondly the
committee agreed that “equity capital and disclosed reserves” as the key element
of capital common to all banking systems. Basel II had a shorter gestation
period, from 2001. A comprehensive version was ready by mid-2004 (the final
version came up to 251 pages was issued in July 2006). Then came the global
economic crisis and as a respond to this Basel III came into existence in late
2010.
3) What was the response of the Islamic Banking industry to the
introduction of Basel I and Basel II initiatives?
It must be pointed out that adoption by non G-10 members depended on the state
of readiness to be assessed by each nation’s supervisory authority. Essentially, it
was realized that sooner or later adoption is necessary if all banks (including
Islamic Banks) are to be seen as a legitimate player in the global financial
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markets. This message was succinctly put across by certain supervisors to
industry players.
On a positive note, this helped to build and maintain the focus on risk
management. In terms of costs, the logic behind it is that sooner or later it will
have to be incurred.
More importantly is the learning curve involved both at the supervisor and at the
IB level. To reflect the below was obtained from CIMB Bank and was
subsequently applied to CIMB Islamic Bank. This transplant is not peculiar to
CIMB alone.
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This showed a process that took approximately 4 years from application to
approval. A diagram like the above does not necessarily reflect the challenges in
terms of conceptualizing the framework at an abstract level, to develop it within
a fluid environment, handling what essentially is change and the dissonance that
is for certain will arise within an organization. The processes involved are the
subject of various texts written by academia.
Ground realities forced credit managers to re-adjust to the new framework
(assuming they had experienced Basel I) and personnel within operations met the
framework for the first time. New technology, system, manuals and
communication flowed through the environment. External to the IB, technology
solution providers began looking at either new system design or looked into the
possibilities of “customizing” their existing offerings. Risk management
consultants also jumped on the bandwagon recognising the revenue potential of
managing Basel II implementation projects in the banks.
Academics as well as supervisors meanwhile started to review the potential
impact of compliance on the competitiveness of IB as a whole. This in itself was
fraught with danger and carried various consequences. The Basel initiatives dealt
with “real” risks events. Academia looking at IB dealt with “real” risks minus
the events and also “perceived” or “hypothetical” risks. These risks arise out of
the theoretical differences between IB and conventional banking (CB), the
divergence between the “theoretical” and the “actual” practices in IB and the
growing convergence between the “actual” practices of IB and CB.
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The early fuqahas only dealt with “real” risks events and thus their “ijtihad”
arise out of a sound methodological approach.
Current analyses meanwhile varied in their approach as reflected by the
following and others nevertheless conclusions reached are somewhat similar.
(Hassan & Dicle: 2005) though Islamic banks offer profit and loss sharing accounts and
therefore expose limited risk of insolvency, systemic risks still exist. The nature of different
types of accounts becomes the center of the issue. High ratio of current accounts and their
utilization with the profit and loss accounts require regulatory concern. Investment account
holders’ rights within the organization compared to equity holders is another regulatory
concern. Deposit insurance schemes for Islamic banks are an issue of recent academic debate.
On the one hand, it helps the competition with conventional banks and brings financial
stability. On the other hand, it is objected due to religious concerns. The risks associated
with Islamic credit transactions, their illiquid nature, lack of lender of last resort and inability
to utilize short term money markets are some of the risks that do not exist for the existing
financial intermediaries. Basel II introduces a new approach to evaluating credit risk.
(Ahmad: 2008) The Islamic financial system is based on participatory approach and risk
sharing. Islamic banks face many challenges to be able to comply with international standards
and guidelines for risk management. Islamic banks face unique and somewhat extra risks,
compared to conventional banks. Basel II with certain modifications can be adopted subject
to addressing the distinct nature of Islamic financial activities, with accommodating
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differences in liability side with special treatment to investments account holders (IAH) and
devising different risk weights for assets.
(Kahf: 2005) Islamic bank have qualitatively similar credit risk to conventional banks.
Equity must be interpreted to include the equity of shareholders and the equity of the owners
of unrestricted deposits because the latter carry their share of the risk of losses by virtue of
the Mudarabah contract. Elements of fairness must be taken into consideration in distributing
the losses as well as in distributing equity charges between the shareholders and owners of
unrestricted deposits. The portion of operational-risks minimum capital charges to share
holders in Islamic banks is apparently lower than their counterpart in the conventional banks.
Here again the reason is the Mudarabah contract that does not charge the Mudarib for losses
not-resulting from negligence, fraud or violation of contract including violation of normal
and customary professional standard practices. This means that while the parameters of
operational risk weighing and minimum equity calculation in Islamic banks may be the same
as in their conventional counterpart, the capital burden on shareholders should be lower than
that in conventional banks. Although the supervisory authorities in countries where there are
Islamic banks did not yet fully apply the review procedures suggested in Pillar 2 of the New
Basel Accord, the application of these proposals does not pose any theoretical or practical
impediment to Islamic banking or to Islamic modes of financing.
The above can be confusing. Positive statements (grounded in research) which may or may
not represent the theoretical foundation of IB intertwined with hypotheses of varying degrees
of validity and maybe interspersed with “value” or “normative” statements.
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The confused landscape of discussion have forced the industry especially
supervisors to embark on the path of least resistance namely in introducing
standards that are essentially complimentary to the Basel framework whilst
taking cognizance of recommendations from academia and other stakeholders in
terms of clear theoretical differences that exist in IB thus the modified
framework.
4) What are the on-going challenges posed by the current framework?
We have alluded above to the organizational challenge for IBs as well as for the
supervisors/standard setting bodies in bringing the framework to life. The
modified framework with its varying approaches (there remain question marks
whether there is methodology or its offshoot namely methods being applied) has
somewhat managed to adequately identify the risk types and is operational in
some banks. The remaining challenges namely to satisfy the whole gamut of
requirements which eventually leads to the ability to measure thus allowing for
mitigation This is an area where the particular IBs have influence, thus can
either recognized or ignore the need for risk management activities. To ignore
raises questions of transparency, accountability and corporate governance.
The ability to influence is the capacity to have an effect on the character, development, or
behaviour of someone or something. In our particular case the intended effect is the
successful measurement of a risk type in terms of probability of loss and potential size of
loss. One way influence can be enhanced is by ensuring the availability of both hygiene-
motivation factors. Hygiene factors entail continuous investment in risk management tools
adopting technologies that support risk management. Most risk management mantra revolves
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around the use of value at risk (VAR) to be complemented by usage of stress testing. These
methods are essentially favoured by both industry and regulators alike in conventional banks
activities. The types of risk being measured have expanded over the years. To embark on this
journey a medium-longer term outlook is required and essentially reflects the circular and
never ending activities that constitute risk management. One concern remains namely
whether all Islamic banks have access to adequate resources to support this activity. The
likes of CIMB, HSBC, OCBC and many others have side-stepped this by depending on
conventional support. Standalone entities may have to wander in the wilderness for a while
all but they still need to make the transition. Being in a competitive industry subject to also
banking secrecy laws, direct co-operation or sharing of best practices is an uncommon
feature.
We must recognize that the framework is not a destination but is a continuing journey thus
what comes after implementation is as important or perhaps more important than reaching the
goal of implementation.
The circle of influence must grow and this relates to another drawback facing IBs namely the
lack of data supporting rigorous testing. IBs thus find themselves within the Knightian
Uncertainty – Risk continuum. Banks are in the business of risk taking and this sit well with
the legal maxim: Al Ghonm Bil Ghonm (No risk no gain).
What does not sit well is growing dependencies on models devoid of data. On this we refer to
the derivatives team at JP Morgan who invented the initial Credit Default Swap (CDS)
instrument. We may not buy-in to the idea of derivatives and the team at Morgan did push the
envelope as far as derivatives were concern however when faced with unreliable data
pertaining mortgages they turn down several opportunities (Tett: 2010). One was to caution
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that the VAR should be treated only as a tool box and not a black box. Too much reliant on
models designed by quants, namely experts in financial modeling can be disastrous. The most
renowned as of recent years was the inventor of the Gaussian copula, David X. Li. The
copula was relied upon by bankers and was partially to blame for the recent crisis.
A safeguard within the current framework revolves around transparency, accountability and
corporate governance. The Islamic banking environment would surely be where these values
are more permeable. Arising from the differing approaches some academics has questioned
this and data remains scant. Another has been the perception that Islamic Banking tends to be
riskier than conventional banking. Some justify by virtue that IBs are exposed to additional
risks such as Shariah and Displaced Commercial Risk. Others have opined that the asset-
liability structure of IB is what makes it riskier. Further studies are required so as not to
divert resources to minor areas of concern.
5) Is there any more room for improvement within the existing framework?
Up to this instance, the author has worn the hat that supports the existing framework and
mainstream thought. Going forward, both the framework and the underlying thought are
questioned. It outlines the impact of such on IB and also points out what needs to be done.
Firstly, the three major religions have had a shared history of collaboration in enriching
human understanding and knowledge. Thus suffice knowledge is not a monopoly of any
religion and IBs should be open to adopt Western practices and technology that brings utility
to them.
Still we must recognize that the framework is essentially designed as a response to issues
besetting the global financial system. Essentially it is a reflection of the conventional
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worldview. It also shapes the debate within capitalism shaping preferences for large over
small banks, financial supermarkets, deregulation over regulation and believe in free markets
economics of the Chicago School. Linking this to the financial crisis the following are
relevant. One, the supervisors believed that the 3 pillars will go a long way in helping
starved off crises. However the framework covers only a portion of the financial system
namely the commercial banks. It does not cover the “shadow” banking system, the hedge
funds, the monoline insurers and various other entities that were instrumental in plunging the
world economy into the abyss. Secondly the recent crisis is what some called the appearance
of a “black swan” or a “fat tail event”. These events essentially bring markets to a standstill.
It does not matter whether an institution is well capitalized, undercapitalized, liquid or
illiquid, solvent or insolvent it is just a matter that the deficit in terms of “trust and
confidence” is insurmountable. Thirdly we need to consider the so-called derivatives and
securitization instruments namely the CDOs, CDS, BISTROs etc. Whilst these products came
later with the advent of technology, the supervisors were already busy at work looking at the
volatile markets of the exchange rates and other traded instruments. Similar to physics, action
begets reaction. Thus imposing capital adequacy requirements, sets the tone to invent new
products that essentially transfers risk (thus the need for capital) off the balance sheet of the
banks. At the onset, the supervisors were playing catch-up to the derivative boom. They
essentially relied on the industry to firstly explain these products, the upside and the models
to measure exposure/risks to the banks and thus make these products safe. Apart from
embracing the models, the supervisors also allowed the industry to agree and issue guidelines
to ensure a level playing field. Having been satisfied, they permitted the industry to regulate
itself not forgetting the “revolving door” of regulators joining the industry and vice-versa. All
the preceding is part of what that has become known as “regulatory arbitrage”. Recently
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Western commentators have opined that these products were not inherently defective,
institutions and people were to blame for inappropriate handling of these products. Lastly on
the models themselves, (Crouchy: 2009) saw reliance on oversimplified models, non-linearity
in the subprime CDO tranches, over-reliance on suspicious ratings, lack of data and inability
to calibrate the models and huge reliance on off-balance sheet funding. Notwithstanding all of
the above and let’s add to Roubini’s Crisis Economics, the takeaway for all is that capitalism
may have its weaknesses, as a machine its break down time to time, some minor parts needs
replacement and the application of lubricant. Once this is done, it can start on its run again.
Whether defective or not, the framework has been accepted for IB use by most supervisors
and academia subject to modification. We infer there is some form of goal congruent since
the sub-system is not viable if it does not work within the system. More often than not the
status quo is preferred. This however perpetuates various existing dislocations already
existing within Islamic Banking.
The dislocations are as follows:-
i) The risk management framework consumes resources within the IB. In most countries
the supervisory regime decides the timeline thus prioritizing goals becomes
imperative. It may undermine items already low on the agenda of the IB. One is with
respect to the PLS preference in Islamic Banking. IBs prioritize and so does
supervisors. Most supervisors rank national policy agenda higher e.g. in Malaysia was
to build the local banking industry within the framework of the New Economic Policy
(NEP). Seldom there is imperative to support the PLS agenda anywhere in the Muslim
world. At present, IBs get scot-free since they claim that could not manage/quantify
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risk of PLS which is essentially due to their failure to even consider such venture.
Essentially this is a “chicken and egg” situation.
ii) The existing framework entails adhering to market disclosure, transparency,
accountability and corporate governance. Whilst this must apply to IBs, supervisors
must play its role and complicity to hide or downplay events does not augur well with
openness. The following case is cited. The local subsidiary of Kuwait Finance House
(KFH) declared substantial losses in 2009 and 2008. MD Salman Younis left
unannounced on 31 May 2009. The new MD, Jamilah Jamaluddin (who is a merchant
banker by training) came back from RHB Islamic on 9 February 2010. For nearly 8
months KFH did not have an MD. At the same time almost a dozen commercial
bankers were suspended including the acting MD (a veteran of HSBC of over 20
years). In the end 6 out of the 12 were asked to leave. No media coverage except for
unrelated but adverse news in the Star. BNM as the supervisory authority kept matters
under wraps and raises speculation. The earlier massive losses incurred by Bank Islam
needed new foreign equity injection escaped much scrutiny since the losses were
incurred in Labuan thus covered under a different jurisdiction.
iii) Claims by academics on the lack of accountability, transparency and corporate
governance in Islamic banks have been mentioned above. Supervisor acquiescence
may explain this. Perhaps this is related to the shareholdings structure and ownership
of these banks. We must take cognizance that most Islamic banks are owned or
closely linked to governments. 6 out of the 10 largest Islamic Banks in the world are
located in Iran with or having previous ties with the Iranian government. Being
subject to international sanctions does not give any incentive to these banks to be
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transparent. The next contender in terms of size is from Saudi Arabia namely the Al-
Rajhi Banking Group. However it is still family owned whilst other banks in the GCC
have certain mixture of private, government, quasi-government and royal family ties
in the U.A.E (Al-Hassan, Khamis and Oulidi: 2010) This is an anomaly compared to
conventional banking but not necessarily to business entities in the Middle East (take
SaudiBinLaden group for example). Even proud partnerships e.g. Goldman Sachs
needed to embrace the public. Structures akin to Al Rajhi also limit expansion. A
recurring theme is the opinion that IBs are still miniscule compared to conventional
banks. Although size is not akin to being better, sufficient scale must still be in place.
It also makes sense from the risk management angle. Conventional risk management
approaches the above from mere disclosure angle. From the equity/welfare
perspective this is ignored since this is a value loaded issue.
iv) The “values” that needs imparting are values that ensure the attainment of “justice” or
“adl” as envisage by Islam. To achieve this, it is essentially the avoidance of
transgression or “zulm”. We are reminded that the first transgression by Man was
essentially an economic kind, namely the “unlawful consumption” of Allah’s
property. Thus we infer the importance of avoiding “zulm” in whatever form
especially in economic matters. At the same time, these values that are cherished are
also “universal”.
v) Related to the above the author wants to bring into the discussion that Islam as a
religion best described as an orthopraxy. (Orthopraxy is a term derived from Greek
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meaning "correct action/activity", and is a religion that places emphasis on conduct,
both ethical and liturgical, as opposed to faith or grace etc. This contrasts with
orthodoxy, emphasizing a correct belief, and, the use of rituals (Google Dictionary)
Based on the above, can the industry and/or its defenders claim that the journey (of avoiding
“zulm” and championing “adl”) so far is “real” or “perceived” based on the following.
a) Shariah risk - the term “Shariah Compliance” litters most guidelines issued. Tangible
proof of compliance remains the sign-off by the Shariah advisors/Shariah boards for the
products. No emphasis is in place to employ a “yardstick” and design “units” that we
could carve into the “yardstick” to measure how far we have travelled so far.
At the most basic level, the question to be posed who essentially owns the industry that
has exceeded USD 1 trillion. Is it Muslim investors, non-Muslim investors, governments
etc. In the recent talk held at the Securities Commission of Malaysia, Prof. Volker
Nienhaus remarked that the government/government linked corporations etc. owns over
90% of the 20% targeted IB share of the total banking asset in Malaysia. Déjà vu
considering this happened also with regards to the NEP.
b) Credit risk – The current approach to credit use in conventional banking and Islamic
Banking is similar. Since PLS contracts are negligible, what remain are short term
working capital facilities where types, quantum and tenor are determined largely by
analysis of financial statements and discussions with the clients. The process is similar to
the conventional approach. Some IBs have managed to outsource the risk management
function to their conventional counterparts. The similarities have even found its way
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down to the identical credit syllabus of the Certified Credit Professional and the Certified
Credit Professional-i. The current risk management framework plays down emphasis on
customer training and engagement. Credit is evaluated, credit is approved or rejected.
Approved facilities are subjected to yearly review. In the interim the client may or may
not be supported in terms of any advisory services. If there are fundamental differences
between how Islam approaches banking relationships the above has essentially nullified
it.
c) Legal risk – This is by far perhaps the largest risk faced by Islamic banking and one
furthest away from its circle of influence. The author in an earlier paper (unpublished)
essentially identified four types of jurisdictional hurdles faced by Islamic finance namely
fiqh related, issues pertaining governing laws, internationalization of laws and lastly the
role other professionally designed standards such as accounting and other regulatory
influences.
The plethora of cases just from Malaysia is lengthy. We then add Shamil Bank of Bahrain v
Beximco Pharmaceuticals Ltd and Others, EC [2004] EWCA Civ 19, The Investment Dar
Company KSCC v Blom Development Bank SAL, [2009] EWHC 3545 (Ch), The East
Cameron Sukuk etc.
Notwithstanding all of the above, the efforts of academia, trained in economics and Shariah
must not go unappreciated. Despite the varying approach/methodologies most issues have
never escaped attention. The struggle to discover the methodology that will rightly guide
Islamic economics and finance is fraught with difficulties since it needs to go back to the
original sources of knowledge in Islam, namely the Al-Quran and the Sunnah. This requires
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qualifications approximating a “mujtahid” and then the knowledge has to be synthesized with
knowledge of modern economics and finance.
At present, even in the absence of a guiding methodology, most observers including
academics are fully aware of the issues. Some refrain from participating in the “blame” game,
some points to “this party” or “that party” whilst other couched their position in abstraction.
The above is out of “fear” but another critique of the academic world is the “elitist” and
“theoretical” approach to even the most basic of ideas. This is representative even in the use
of words in PHD thesis writing. While sophisticated it does not transmit well even to the
undergraduate level. Some strands of the Islamization of Knowledge (IOK) venture is
perhaps most representative of this.
Without academia providing the intellectual foundation, this agenda maybe short-lived.
Besides this academic push, “social” pressure should also be brought to bear on stakeholders
thus in creating the awareness the language of framing the issues should be as vernacular for
local consumption but global in outlook.
This brings the author to the notion of “jihad” and Prophet Muhammad (S.A.W.) said: “The
most excellent type of Jihad is speaking a true word in the presence of a tyrant
ruler.” {Reported by Imams Abu Daood, At-Tirmithi and Ibn Majah.}
It is hoped that the agenda can be pursued without resulting in too many casualties in terms of
the careers of either academics, bankers, supervisors and other stakeholders. However
remaining silent, choosing deep thought is no longer an option. Sayyid Qutb’s Milestones
embodied this call for action.
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They of the first generation did not approach the Qur'an for the purpose of acquiring culture
and information, nor for the purpose of taste or enjoyment. None of them came to the Qur'an
to increase his sum total of knowledge for the sake of knowledge itself or to solve some
scientific or legal problem, or to remove some defect in his understanding. He rather turned
to the Qur'an to find out what the Almighty Creator had prescribed for him and for the group
in which he lived, for his life and for the life of the group. He approached it to act on what
he heard immediately, as a soldier on the battle- field reads "Today's Bulletin" so that he
may know what is to be done.
6) Why has the risk management framework been chosen as the conduit of values?
Is it not the instrument of the Basel Committee and will it not again be brow beaten by the
supervisors. An interesting object lesson from history comes to mind. It was Nixon, the
epitome of “anti-communism” that engaged the People’s Republic of China. Historians have
come to view the actions of “hawkish” presidents in extending the olive branch to enemies as
being actions grounded on objective thought.
The risk management function is the most suited to play this role. It existence at least in
theory is as a countervailing force to unbridled enthusiasm of business. Its so-called
“independence” can be made true. It is “goal oriented” and more importantly adept in control
and supervision. It is authoritative in its current role and can be this also in the future. It need
however to be more communicative as well as consultative. Its obvious strength is that it has
access across all functions within the IB. It also has or eventually will gain access to an
enormous array of data and most banks have or will support this with expenditure on various
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information systems. The current framework has also seen to the emphasis on documentation
whether it is rules, policy or procedures.
The risk management function also plays an allocative function especially in the area of
credit risk dealing e.g. controlling exposure size and/or industry concentration. We foresee
that this will also apply when it embarks on its new role. This function executed properly
secures a “peace and acceptance” dividend for the Bank. In light of present developments
perhaps this dividend is worth securing and the “ijtihad” put in would be rewarding.
The “value” driven framework is not expected to hit the ground running although it must
yield tangible results. On credit risk, the framework is expected to bring new meaning to the
terms partnership and intermediation. Both are expected to generate value and this need not
necessarily be in monetary terms. Essentially it is to leverage the expertise of the IB in terms
of know-how. If clients are rejected due to poor credit, IBs without exception should
endeavour at the minimum to reason out the issue as well as rendering advice on how the
client should address the “credit standing” matter into the future. The enhanced framework
should also be tasked into looking at instilling deeper meaning to the cliché of “Knowing
Your Customer”.
Meanwhile on operational risks, the enhanced framework is tasked with reinforcing what
essentially has been documented on paper. The framework is to replace mere “reading” with
“understanding and practice”. Similar to managing credit risk, this is an evolutionary
process.
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Nevertheless, there remain limitations to the enhanced framework. Moral hazard, asymmetric
information is still abound bearing in mind the external environment and counterparties that
IBs or its clients deal with. Thus the changes within IB must in itself be supported with a
change in conduct of its own supervisors and its external stakeholders. Essentially this
involves the effort to handle legal risk. Unless there are fundamental disagreements, it is most
likely that IBs globally will see value of the framework. This will lay a firmer ground for
Muslim parties/nations to engage in alternative dispute resolution (ADR) solutions like
arbitration and mediation. Whilst these are positives, rooting out “Non-Shariah” compliance
defences as done in the Shamil Bank and the Investment Dar should be high on the list of
priorities of supervisors/govt. A “value” driven framework cannot tolerate attempts to
undermine it or weaken the “moral” high ground that the framework captures.
Present commentators would ask why we insist to impart what may be deemed extraneous
social imperatives on IBs. Aren’t such roles the responsibilities of the government and/or
Development Financial Institutions (DFIs)? The economically inclines will point out that it
creates bureaucracy, inefficient leading to reduce profitability of IBs (studies showing that
IBs are more profitable if compared to their conventional counterparts). Is it not a distortion,
a regulation that increases the cost of doing business for IBs?
Before answering this, the author would regurgitate how previous Western scholars have
framed this question. They questioned the preoccupation of the early fuqahas on commercial
contracts. They saw certain fatwas as essentially being in favour of merchants. One such was
Imam Hanafi who a cloth merchant. However being inundated with values, the Imam was
reported to have knocked on every door in Baghdad to recover a set of defective material
mistakenly sold to a customer by his assistant. The Imam died in prison having been poisoned
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and he going to prison for failing to recognize an “unjust” ruler. All the above simply points
to values driven action.
To answer the present firstly it needs to be pointed out that all the concerns are couched in the
language of the conventional worldview. There are no satisfactory answers since the
foundations or belief-system leading up to the question differs. Some may opine that the
above does not deserve an answer since it shows the failure to understand Islam. Islam being
a religion grounded in values and Muslims are not ashamed of embracing values (this
essentially explains why academia could not run away from the normative as mentioned
above). Even if Muslims agree with rational self-interest, our maximization principle is
different. Ours will be geared at maximizing infaq and not consumption. Even Western
thought has questioned the “maximization” principle e.g. Herbert Simon’s “satisficing”
principle. In reality, we cite altruism e.g. Bill and Melinda Gates Foundation and Warren
Buffet charitable ventures. Next, there have always opinions calling for the need to review
Economics as a “value-free” science based on the works of Amartya Sen. Thirdly, the notion
of a “value-free” science is questionable since it can be argued that having no value is in
itself a value.
Our approach is the “socialization of private gains” and not to be mistaken as socialism. This
epistemologically is enshrined in the scriptures. Historically, this has also been demonstrated
via the institution of the “waqf”. It is also good to point out that the “waqf” influenced the
English “trust” system. Richard the First took an interest in it when he was not busy waging
war against Saladin. The “trust” system was used to finance the development of Merton
College, Oxford (Merton himself was a member of the clergy).
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From the standpoint of economic and political stability, The Pew Forum on Religion &
Public Life (2009) estimated that there 1.57 billion Muslims in the world making up 23% of
the world population. More than 60% of the global Muslim population is in Asia and about
20% is in the Middle East and North Africa. Two-thirds of all Muslims worldwide are living
in 10 countries, six are in Asia (Indonesia, Pakistan, India, Bangladesh, Iran and Turkey),
three are in North Africa (Egypt, Algeria and Morocco) and one is in Sub-Saharan Africa
(Nigeria). Although most of these have a functioning IB system (except India having
postponed IB implementation), most are still poor, not for lack of resources but through
plunder via corruption. And historically they share a common theme (dictatorship or military
rule). More recently we can tag instability to the ones in Italics. Leftist thought maybe incline
to apply Marxist interpretation. Superiority of Islamic knowledge have dealt with this over
1200 years before Marx e.g. do not let wealth circulate among the few, within the property of
the rich there exist the right of the deserving and so on and so forth.
The three paragraphs above simply state that the West or even Muslims must not see the
Islamic world from Western perspective. That why the notion of “regime change” is so
abhorrent to some. Also there is a clear vision of what Islam demands i.e. the methodology is
already there, it is the methods that we are searching for.
THE CURRENT RISK MANAGEMENT FRAMEWORK IN USE BY ISLAMIC BANKS CAN BE IMPROVED. IMPROVEMENTS MADE ARE ESSENTIALLY BENEFICIAL TO THE GLOBAL FINANCIAL SYSTEM.
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Conclusion
Muslim life is essentially both mundane and spiritual. Values transcend both spheres. A
“value-free” system impoverishes not only Muslims but the global financial system itself. In
the long run none or only few Muslim states will go “cap in hand” to the IMF asking for aid
as did Pakistan. Also this resolve the issue with two education systems that exist i.e.
government run schools and the “madrasahs’ “ associated with breeding terrorism. Terrorism
imposes financial costs to all. Less will there be projects costing x million becoming x + y
million. The “y” is the cost of corruption paid out. The poor has no time to observe
“environmental” niceties. Sustainable “balance” and “value-driven” development (the
Prophet s.a.w. perhaps was the first environmentalist essentially advising against the cutting
of trees) mean less clean-up cost. Again this was over 1200 years before the book Silent
Spring by Rachel Carson. It was mentioned that knowledge flowed from the Islamic world to
the West. This was cost savings to Western civilization. Again Muslim philosophers and
scientists did not do this on an “empty” stomach. It is only the rich that have time to
contemplate and analyse subjects/objects. It was also the rich Muslim traders that drew bills
of exchanges (Suftaja), letters of credit and the cheque (Sakk). These were the same Muslim
traders that sailed into Malacca (subjected to the vagaries of the weather) spreading the
religion whilst trading. Can this analogy be applied to the merchant bankers flying 1st
Class to London and New York marketing their “sukuk”?
In the final analysis, Islamic civilization was all “value” driven. Not making the risk
management framework conduit for “values” essentially deprives Muslims as well as
humanity. In doing this, Islam and the West must come to points of agreement as well to
points where both “agree to disagree” without having to tear the bonds of humanity asunder.
THE CURRENT RISK MANAGEMENT FRAMEWORK IN USE BY ISLAMIC BANKS CAN BE IMPROVED. IMPROVEMENTS MADE ARE ESSENTIALLY BENEFICIAL TO THE GLOBAL FINANCIAL SYSTEM.
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