The Government Petroleum Fund 1998
Risk management for the Petroleum Fund

The risk associated with the management of the Government Petroleum
Fund is determined primarily by the composition of the Fund’s
portfolio. This composition in turn is to a large extent determined by the
strategy laid down by the Ministry of Finance, after submission to the
Storting. The strategy is arrived at by striking a balance between risk
and expected return, and considerable emphasis is placed on limiting risk
by diversifying investments among a very large number of securities in
many countries. The Ministry of Finance has also set a risk limit for
Norges Bank’s management operations, in the form of measured
deviation from a given benchmark portfolio.
Norges Bank has to ensure that the composition of the Petroleum Fund
at any time is within the established limits, and must also engage in risk
monitoring. This means that a full overview of the composition of the
portfolio is a fundamental requirement for satisfactory risk management.
This article describes the complex network of suppliers and recipients of
information that has been built up to make it possible to gain such an
overview. Large quantities of data are exchanged daily through the
network. The description is followed by an account of the other risk
factors Norges Bank has to deal with in its management, and of how Norges
Bank works to manage the total risk associated with management.
Information flows
The Petroleum Fund’s market and credit risk are tracked using daily
updated lists of holdings of the various financial instruments. The
process for purchases and sales of financial instruments determines what
settlement risk the Fund is exposed to. The quality of reporting and
analytical routines will be a deciding factor for operational risk.
The Petroleum Fund is a large fund composed of many securities. The Fund
is managed partly by Norges Bank, and partly by external managers under
contract with Norges Bank. All internal and external managers enter into
transactions on behalf of the Fund, which poses a considerable challenge
as regards maintaining a full overview of holdings.

Chart 1 shows the information flows that must function and be correct on
a daily basis in order for Norges Bank to know the exact composition of
the Petroleum Fund. The most important operators outside Norges Bank are
external managers and an external custodian for the whole equity
portfolio, The Chase Manhattan Bank. The latter provides safekeeping of
the securities in the Fund by acting as account manager in local
securities depositories throughout the world. The custodian also keeps
accounts of the Fund’s assets, and submits daily reports to Norges
Bank.
The managers can carry out transactions round the clock. Ideally, each
transaction should be analysed immediately to determine its effect on
overall risk. At present, this is not a realistic aim. Norges Bank now
receives full overviews of the position of the Fund once a day.
The aim of a daily overview of risk exposure is ambitious in view of the
large quantities of data to be reported. At the end of 1998, the Petroleum
Fund owned equities in more than 2 000 different companies. A number of
managers have the same equities in their portfolios, involving about 9 000
equity holdings in all. Furthermore, the Petroleum Fund owned about 500
different bonds, in addition to warrants, various types of money market
instruments, futures contracts and pure foreign exchange positions. A full
overview of all holdings is received every day.
Information about trading in equities and bonds
In the contracts with the external managers, Norges Bank requires that
the managers report all transactions continuously, and no later than at a
set time on the trading date. The reason for this requirement is that the
market risk associated with a security is transferred from seller to buyer
as soon as the transaction is agreed.
Just as important as the reporting time are the format of the reports
and the medium used. These may vary from one manager to another and from
one transaction type to the next.
The international SWIFT electronic system is used for reporting ordinary
purchases and sales of equities and bonds. A correctly completed SWIFT
report means automatic, problem-free reporting.
Information about foreign exchange transactions and cash investments
Foreign exchange transactions and cash investments are not reported
using a standard electronic notification format. Consequently, it has been
customary to fax information, which entails a considerable amount of
manual work, and hence a higher risk of error. There is no standard for
what information should be included, so it is customary only to include
what is necessary for settlement of the transaction. However, this is not
sufficient to ensure correct accounts and risk classification. Work is in
progress to establish more complete, efficient procedures.
Information about corporate actions
The most common corporate actions are the issue of warrants, dividend
payments and share splits. The Petroleum Fund’s equities are held at
a custodian bank, which is also responsible for monitoring corporate
actions and updating the Petroleum Fund’s holdings.
Corporate actions represent a twofold challenge. When a share is split
into several units, this leads to a change in the Fund’s holdings of
the share in question. If this is not recorded on the correct date, the
share value and contribution of the share to risk exposure will not be
correct. Another type of corporate action is that the Fund receives
warrants in addition to its own holdings of the share. There are a variety
of warrants, and they can be very complex. Accurate, ongoing modelling of
risk properties is therefore a demanding task.
Information about derivatives trading
Futures contracts, ie agreements on the purchase or sale of securities
at a future date, are used in management. The accounts for futures
contracts in bonds are kept internally in Norges Bank. The accounts for
futures contracts in equities have been centralised by Norges Bank at an
external custodian bank. This custodian is a member of the local financial
futures and options exchanges, and is obliged to make daily reports on
futures contracts in equities to the global custodian.
The flow of information in connection with equity futures contracts is
manual. Work on automating this process is under way.
Accounting information to Norges Bank
Updated accounts of the Petroleum Fund’s holdings of bonds and
associated derivatives instruments are kept at Norges Bank. Equity
accounts are mainly kept by the global custodian.
Data are transferred daily from the equity managers to the custodian,
where the information is used to prepare accounts for each of the
externally managed portfolios. The day after the trading day, the
accounting reports are checked and reconciled to ensure that all
information is correct. In the afternoon of the day following the trading
day, reports are sent to Norges Bank. These reports are used in risk
management.
Information flows in Norges Bank
The daily accounting reports from the global custodian and from Norges
Bank’s own accounting system are kept in a central database in Norges
Bank. Information about all the Petroleum Fund’s holdings is thus
centralised in one place. Norges Bank can extract the data from the
database in various ways, depending on what these data are to be used for.
The accounting reports in the central database are supplemented daily
with price information from external sources. As long as the securities
holdings have universal codes, this process is to a large extent
automatic. However, it is not uncommon for different sources to use
different codes for the same security, or for some securities not to be
registered in all sources. In such cases, it is necessary to compare
information from different sources to ensure that the information used is
correct.
Market risk
The value of the Petroleum Fund is constantly changing as a result of
movements in interest rates, equity prices and exchange rates. The market
risk associated with such movements is determined mainly through the
Ministry of Finance’s choice of benchmark portfolio. According to the
Ministry’s guidelines, the actual portfolio may only deviate to a
limited extent from the benchmark portfolio. In addition, the Ministry of
Finance has established absolute limits for factors such as interest rate
risk, the proportions of the Fund that can be invested in equities and
bonds, and the allocation by region. A ceiling of one per cent ownership
has also been placed on holdings in individual enterprises.
Norges Bank uses a statistical model to calculate the tracking error
relative to the benchmark. The model is based on actual securities
holdings and the composition of the benchmark portfolio. It then uses
historical price data to estimate the magnitude of the uncertainty
associated with future price changes. Finally, the model calculates
expected fluctuations in the Petroleum Fund’s absolute return, and in
the difference in return between the actual portfolio and the benchmark
portfolio.
The model simplifies this analysis by assuming that most of the
variations in the value of financial instruments can be explained by
changes in a limited number of basic risk factors. The model makes no
attempt to predict the future magnitudes of the risk factors, but uses
historical data to estimate the magnitude of previous fluctuations in the
factors. The model then calculates how sensitive the individual security
is to the risk factors. Finally, the expected fluctuation in the return on
the portfolio is calculated in absolute terms and relative to the return
on the benchmark portfolio. This is done by weighting the sensitivity of
the individual securities in relation to their share of the total market
value, and by taking account of the historical fluctuation and covariation
of the risk factors.
Monthly return figures for the past ten years indicate that the return
on the benchmark portfolio, assuming the same composition as at 1 January
1999 and measured in terms of the Fund’s currency basket, can be
expected to show a standard deviation of about 5 percentage points on an
annual basis. This means that in two out of three years the return will
lie within a band of plus/minus 5 percentage points around a normal
return. This normal return is difficult to quantify, however.
In addition to fluctuations in the return on the benchmark portfolio,
the value of the Petroleum Fund varies because the actual portfolio
deviates from the benchmark portfolio. The fluctuation in the Fund’s
total return is determined by these two factors, and by the degree of
covariation between them. If Norges Bank fully utilises the risk limit of
1.5 percentage points expected tracking error, the standard deviation of
the Petroleum Fund’s total return, measured in terms of the Fund’s
currency basket, will be approximately 5.25 per cent. It is assumed here
that the return on the deviations made is not correlated with the return
on the benchmark portfolio. We see that only a small portion of the total
market risk in the Petroleum Fund is due to decisions made by Norges Bank
as manager.
Risk limits measured by expected tracking error - The Ministry of Finance’s limit on deviations from the
benchmark portfolio takes the form of restrictions on fluctuations
in the difference between the Petroleum Fund’s actual return
and the return on the benchmark portfolio.
- The limit is expressed as the expected tracking error (standard
deviation of the difference between the return on actual investments
and the return on the benchmark portfolio). The expected tracking
error may not be higher than 1.5 percentage points on an annual
basis. Roughly speaking, this means that in two out of three years
the Petroleum Fund will have a return that does not deviate from the
return on the benchmark portfolio by more than plus/minus 1.5
percentage points, assuming that Norges Bank makes full use of this
margin.]
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Credit risk
As an owner of bonds, bank deposits etc., the Petroleum Fund is exposed
to the risk that the issuer of the security will fail to meet its
financial commitments, so that the whole or part of the capital invested
is lost. The Petroleum Fund’s exposure to credit risk is to a large
extent restricted by the Ministry of Finance’s investment guidelines.
Supplementary internal guidelines laid down by Norges Bank also apply.
The degree of credit risk is reflected in the rating assigned to a bond
by different rating agencies (Moody’s and Standard & Poor’s
are the best known). The Ministry of Finance has set minimum requirements
for bond ratings. A supplementary requirement is that securities without a
government guarantee may not account for more than one tenth of the market
value or interest rate risk of the bond portfolio. Norges Bank has drawn
up detailed internal guidelines for approved bond issuers.
The Petroleum Fund is also exposed to credit risk as an owner of bank
deposits. The Ministry of Finance has authorised Norges Bank to invest up
to one fifth of the Fund’s value in bank deposits with a maturity of
up to three months. Normally, less than five per cent will be invested in
this manner (inclusive of cash collateral for futures contracts). In
internal guidelines, Norges Bank has stipulated that deposits must only be
made in the world’s 200 largest banks, as measured by total assets.
In addition to size, these banks must satisfy certain minimum rating
requirements. Limits have also been placed on the amounts that may be
invested in any in dividual bank, depending on the size and rating of the
bank. As a result of these limits, deposits have to be spread among many
banks, so that the credit risk associated with the individual bank is
reduced.
Information from both internal and external managers is used to monitor
compliance with the limits on bank deposits.
Other risk types associated with management
In implementing the established investment strategy, the Petroleum Fund
is also exposed to risks other than credit and market risk. There is no
compensation for these types of risk in the form of a higher return, and
the aim is therefore to reduce them to a minimum. There will nevertheless
be a trade-off between the costs of limiting these risk factors and the
benefit in the form of lower risk exposure.
Settlement risk
When an agreement on the purchase or sale of a financial instrument has
been concluded, there is a risk that the counterparty will not fulfil its
part of the agreement. Breach of agreement may take place in the period
before settlement takes place, or while settlement is taking place.
Settlement risk consists of three main factors: the counterparty may fail
to fulfil its obligations in connection with settlement, so that the whole
or part of the principal is lost (counterparty risk); the counterparty may
be in breach of agreement before settlement, so that the transaction has
to be replaced by another at the current market price (repurchase risk);
the counterparty may settle accounts at a later date than the settlement
date, so that any liquidity needs have to be met by raising a loan or
selling assets (liquidity risk).
The Petroleum Fund will be exposed to settlement risk through the
transactions made. The type of settlement risk the Fund will be exposed to
will depend largely on the type of transaction. A distinction can be made
between five main types of transaction: purchase/
sale of securities, foreign exchange market transactions, collateralized
transactions, purchase/sale of listed derivatives and purchase/sale of
derivatives traded over the counter. The last type of transaction is not
used by Norges Bank. A summary is given below of the types of transaction
types mainly used in the management of the Petroleum Fund.
Purchase/sale of securities
Transactions are agreed between a portfolio manager (internal or
external) and a counterparty. Bond transactions are normally agreed
directly between buyer and seller. For transactions in the equity market a
broker is often used as an intermediary between buyer and seller. All
equities in the Petroleum Fund are listed, and the brokers used are either
direct members of the local stock exchanges, or they use local agents.
Buyer and seller send instructions to their custodians. On settlement day,
the transaction takes place in the settlement system of the country where
the security is registered.

Chart 2 presents a somewhat simplified example of the course of events in
a transaction involving the purchase/sale of a security. What is common to
equity and bond dealers is marked green , while what is particular to
equities is marked blue and what is particular to bonds is marked red.
With simple purchases/sales of securities, the best protection against
loss of payment or securities is to require that payment and security are
exchanged simultaneously. Countries with well developed capital markets
have such mechanisms which protect investors against failure on the part
of counterparties after the transaction has been agreed, but before it is
settled. Counterparty risk associated with the settlement of security
trades is therefore limited.
Since some days pass between the transaction and settlement dates, the
Petroleum Fund will always be exposed to some repurchase and liquidity
risk. Norges Bank therefore continuously evaluates the financial strength
of the counterparties and dealers used in securities transactions.
Foreign exchange transactions
Foreign exchange transactions (spot and forward) do not provide the same
degree of certainty as to the simultaneous exchange of assets as
securities transactions. Because the transactions do not involve
collateral, there is a risk that counterparties will not deliver the
agreed sum at the same time as the corresponding amount of currency is
delivered.
The counterparty risk of the Petroleum Fund is limited by imposing
certain requirements regarding the choice of counterparties and contracts.
The maturity of forward contracts is limited to a maximum of six months to
reduce repurchase risk. Monitoring procedures have been established to
ensure that the terms of the forward contracts entered into are in
accordance with the guidelines, and that counterparties satisfy credit
rating requirements.
Collateralized transactions
Repurchase agreements and loan of securities are agreements with
underlying collateral. Loans of securities take place through custodian
institutions. Repurchase agreements are made by both internal and external
managers. A repurchase agreement is a sale of securities with an agreement
to repurchase them later at an agreed price. Norges Bank can be on both
sides of such an agreement. Common to the agreements is that Norges Bank
lends out money or securities for a limited period to an approved
counterparty against acceptable collateral. Bank guarantees, securities
and cash, which is reinvested, are accepted as collateral.
In an agreement with underlying collateral, the risk of losing the
principal is associated mainly with the actual settlement. During the
contract period, the risk will be limited to one party being left with
securities/cash that have been provided as collateral if the counterparty
fails to fulfil its obligations. Because of market movements in the
intervening time, the value of the collateral may not be sufficient to
repurchase the original security.
The management of risk in agreements involving collateral takes place by
imposing restrictions when selecting counterparties. As a rule the
collateral provided by a borrower will exceed the market value of the loan
by a certain margin. The market value of the collateral is normally
evaluated and cleared on a daily basis.
Purchase/sale of listed derivatives
Norges Bank uses equity index and interest rate futures contracts in its
fund management. The contracts in question are traded on stock exchanges
and are standardised with respect to quantity, quality and delivery terms.
The following is a slightly simplified illustration of a futures
transaction: An agreement is made for the purchase/sale of a listed
contract, and collateral deposited with the clearing house. The contract
is cleared daily at market price. The clearing house functions as
counterparty to both buyer and seller for the duration of the contract.
Because of the daily clearing at market price, any credit risk arising
will be limited to one day.
As part of futures contracts Norges Bank must make margin payments to
brokers, with an associated counterparty risk. In addition, the Bank is
exposed to a custody risk in relation to the settlement broker’s
custodian bank because of the securities that have to be provided as
collateral for the initial margin.
The futures contract itself will hold a repurchase risk for Norges Bank
in the event that the financial futures and options exchange does not meet
its obligations. In the period between the actual transaction by a dealer
and its transfer to the settlement broker, the Bank is exposed to a credit
risk in relation to the dealer. The exposure is a matter of minutes, and
the risk can be regarded as marginal.
The risk associated with futures transactions is considered marginal
provided the trade takes place on stock exchanges in well functioning
capital markets, with satisfactory regulation and supervision. Norges Bank
manages the risk associated with futures activity through guarantee
requirements, restrictions with respect to which agents can be used, and
continuous monitoring of the initial margin.
Operational risk
Operational risk includes the risk of financial loss as a result of
error or irregularities in the execution of transactions, deficient
internal control (on the part of either Norges Bank or the external
managers) or through interruptions in IT systems (including information,
transaction processing and payment transfer systems). Reputational risk,
legal risk, and risk associated with inadequate qualifications, ethics or
personnel attitudes are also operational risk factors.
Internal control
The degree of operational risk will depend on the organisational
structure chosen, the procedures and technical systems used and the
expertise in the organisation. Norges Bank places emphasis on managing
this type of risk by establishing sound internal control procedures, a
sound organisation of activities with clear authorisations and a clear
distribution of responsibility, recruitment of specialists with practical
and theoretical qualifications, satisfactory training of personnel,
technical standby solutions and a sound set of legal agreements.
In the selection process for external managers, emphasis is placed on
managers having a clear, well documented investment process, where it is
made explicitly clear who is responsible for the individual decisions.
Emphasis is also placed on high-quality current risk management, and on
the integration of risk management and the investment process.
Ethical guidelines
The Regulation on the Government Petroleum Fund stipulates that external
managers used in the management of the Fund must have adequate internal
ethical guidelines for their activities. An important part of the process
of selecting external managers is precisely an evaluation of the measures
the management organisation has implemented to prevent losses due to
operational weaknesses. Norges Bank’s Executive Board has laid down
stringent guidelines for the financial transactions employees in Norges
Bank Investment Management are permitted to make, and for the employees’
relationship with existing and potential business partners.
Legal risk
Legal risk is the risk that the agreements Norges Bank has entered into
do not protect the Bank’s rights adequately in the event of a legal
process, for example if agreements are not formulated in a manner that
makes them legally binding. In managing the Petroleum Fund, Norges Bank
has made extensive use of its own legal expertise, and has also used a
recognised international firm of lawyers which specialises in the type of
legal issues involved.
Control structure
In addition to the standard control routines which are part of the line
responsibilities in Norges Bank Investment Management, a control system
has been established outside the Investment Management unit. The primary
objective of this external system is to ensure that the internal control
system functions satisfactorily. External audits are performed by a unit
in another department in Norges Bank, the Auditing Department, by the
Office of the Auditor General and by the Ministry of Finance. As
delegating authority, the Ministry uses the independent consultancy Bacon
& Woodrow to evaluate the results of Norges Bank’s management.
See also Section 7 of the report proper for a further presentation of the
external control bodies evaluating Norges Bank’s Investment
Management.