Management of Banking and Financial Services
by Paul Justin, Suresh Padmalatha
Management of Banking and Financial Services, 4th Edition
- Cover
- About Pearson
- Title Page
- Contents
- Foreword
- Preface to the Fourth Edition
- Overview
- Acknowledgements
- About the Authors
- 01 Managing Banking and Financial Services—Current Issues and Future Challenges
- SECTION I THE SETTING
- SECTION II CHANGE IS IN THE AIR….IS THE FINANCIAL SYSTEM BEING REVOLUTIONISED?
- Fintech
- Digital currencies
- Climate change and financial system
- SECTION III THE GLOBAL FINANCIAL SYSTEM – AFTER THE FINANCIAL CRISIS
- A Rewind to the Financial Crisis of 2007–08
- The Causes of the Crisis
- Prevalent models of banking
- Investment banks, Commercial banks and Universal banks – What is the difference?
- Macroeconomic and Financial Stability—Understanding the Linkages
- The Role of ‘Trust’ in Financial Stability
- The Role of Regulation in Ensuring Financial Stability
- The Objectives of Financial Regulation
- Financial Stability—the Over-arching Agenda for the Future
- SECTION IV THE INDIAN FINANCIAL SYSTEM—AN OVERVIEW
- Financial Stability in India
- SECTION V THE INDIAN BANKING SYSTEM—AN OVERVIEW
- The Financial Institutional Structure in India
- Who Owns the Commercial Banks in India?
- Public Sector Banks
- Private Sector Banks
- Small Finance Banks (SFB)
- Payments Banks
- Foreign Banks
- Indian Banks Operating Overseas
- Regional Rural Banks (RRBs)
- Non Banking Financial Institutions (NBFI)
- Non Banking Finance Companies (NBFC)
- Housing Finance Companies (HFC)
- Co-operative Credit Institutions
- Banking Models in India
- The Indian Financial Code (2015)
- The Way Forward…
- Technology the - game changer
- Annexure I: Banking Sector Reforms
- Annexure II: Committee on Financial Sector Reforms—2009: Main Proposals of the Raghuram Rajan Committee
- Annexure III: Select Major Policy and Legal Reforms Since 1991–92
- 02 Monetary Policy—Implications For Bank Management
- SECTION I BASIC CONCEPTS
- A Macroeconomic View
- Central Bank Tools to Regulate Money Supply
- The Impact of OMOs on Other Tools of Monetary Policy
- Central Bank Signaling Through the ‘Policy Rate’
- Popularity of the ‘Repo’ Rate as the Policy Rate
- Other Factors that Impact Monetary Base and Bank Reserves
- SECTION II APPLICATION OF THE MONETARY POLICY TOOLS IN INDIA
- The Monetary Base in India
- Measuring Money Supply in India
- Operation of Reserve Requirements in India
- Net Demand and Time Liabilities
- Operation of the Bank Rate in India
- Open Market Operations in India
- Repo Market Instruments Outside the LAF
- SECTION III MONETARY POLICY TOOLS IN SELECT COUNTRIES
- The United States of America
- Net Transaction Accounts
- The Eurosystem
- Other Developed and Developing Countries
- Annexure I: Computation of the NDTL for the Banking System in India
- Annexure II: An introduction to the money market in India
- Annexure III: Case Study: European Central Bank’s decision to bail out Greece
- 03 Banks’ Financial Statements
- SECTION I BASIC CONCEPTS
- Bank Liabilities
- Bank Assets
- Contingent Liabilities
- The Income Statement
- SECTION II FINANCIAL STATEMENTS OF BANKS OPERATING IN INDIA
- Bank Liabilities
- Bank Assets
- Income Statement of Indian Banks
- Other Disclosures to be Made by Banks in India
- SECTION III ANALYZING BANKS’ FINANCIAL STATEMENTS
- Annexure I: Moving to Wards Risk Based Assessment of Banks
- Annexure II: Key Performance Indicators (KPI) for Banks
- Annexure III: Some Alternative Models for Bank Financial Statement Analysis
- Annexure IV: Case Study: Analysis of Profitability—A Du Pont Analysis of Bank Groups in India
- Annexure V: Indian Accounting Standards (IndAS) for Banks and Other Financial Institutions
- 04 Sources of Bank Funds
- SECTION I BASIC CONCEPTS
- SECTION II BANK LIABILITIES—DEPOSITS
- Protecting the Depositor—Deposit Insurance
- Deposit Insurance in India
- SECTION III PRICING DEPOSIT SERVICES
- The Need to Price with Precision
- Some Commonly Used Approaches to Deposit Pricing
- Marginal Cost of Funds Approach
- New Cost of Funds Analysis
- Deposits and Interest Rate Risk
- SECTION IV BANK LIABILITIES—NON-DEPOSIT SOURCES
- The Funding Gap
- The Indian Scenario
- SECTION V BANK DEPOSITS IN INDIA—SOME IMPORTANT LEGAL ASPECTS
- ‘Banking’ Defined
- Who is a Customer?
- Who is Eligible to be a Customer?
- General Guidelines for Opening Deposit Accounts
- Termination of Banker–Customer Relationship
- Types of Deposit Accounts
- SECTION VI DESIGN OF DEPOSIT SCHEMES—SOME ILLUSTRATIONS
- Recurring Deposit Scheme (RD)
- Reinvestment Deposit Scheme
- Fixed Deposit Scheme
- Cash Certificates
- Annexure I: Some Important Non-Deposit Funding Sources for Banks in India and the USA
- Annexure II: Some Important Legal Provisions Relevant for Bankers
- Annexure III: A Summary of Important Legal Aspects of Bank Deposits in India
- Annexure IV: Anti-Money Laundering and Know Your Customer Guidelines—International Best Practices and Guidelines for Indian Banks
- 05 Uses of Bank Funds—The Lending Function
- SECTION I BASIC CONCEPTS
- Introduction
- Banks’ Role as Financial Intermediaries
- Gains from Lending
- Who Needs Credit?
- Features of Bank Credit
- Types of Lending
- SECTION II THE CREDIT PROCESS
- Constituents of the Credit Process
- SECTION III FINANCIAL APPRAISAL FOR CREDIT DECISIONS
- Financial Ratio Analysis
- Common Size Ratio Comparisons
- Cash Flow Analysis
- SECTION IV FUND BASED, NON-FUND BASED AND ASSET BASED LENDING—FEATURES AND POPULAR FORMS
- Fund Based Lending
- Non-fund Based Lending
- Asset Based Lending
- SECTION V LOAN PRICING AND CUSTOMER PROFITABILITY ANALYSIS
- Step 1: Arrive at Cost of Funds
- Step 2: Determine Servicing Costs for the Customer
- Step 3: Assess Default Risk and Enforceability of Securities
- Step 4: Fixing the Profit Margin
- Some More Models of Loan Pricing
- Annexure I: Risk Classification Criteria
- Annexure II: The Importance and Role of Credit Rating Agencies (CRAS)
- Annexure III: Credit Appraisal—Some Commonly Used Financial Ratios
- Annexure IV: Income Statement-Based Cash Flow Analysis
- Annexure V: Case Study: LIBOR – The Benchmark and the Manipulation
- 06 Banks in India—Credit Delivery and Legal Aspects of Lending
- SECTION I MODES OF CREDIT DELIVERY
- Cash Credit
- Loan System for Delivery of Bank Credit—The Working Capital Demand Loan
- Overdrafts
- Bills Finance
- Pricing of Loans
- Exemptions
- SECTION II LEGAL ASPECTS OF LENDING
- What are Unsecured Loans?
- What are Secured Loans?
- What is a ‘Security’?
- Annexure I: Types of Borrowers and Modes of Lending
- Annexure II: Reclassification of Borrowers’ Financial Statements for Credit Appraisal
- Annexure III: Some Common Securities for Bank Loans
- Annexure IV: Case Study — Credit Appraisal
- 07 Credit Monitoring, Sickness and Rehabilitation
- SECTION I BASIC CONCEPTS
- The Need for Credit Review and Monitoring
- Triggers of Financial Distress
- Financial Distress Models—The Altman’s Z-Score
- Some Alternate Models Predicting Financial Distress
- The Workout Function
- SECTION II CREDIT INFORMATION COMPANIES IN INDIA
- CIBIL and Loan Approval
- Other Credit Information Companies in India
- Debt Restructuring and rehabilitation of sick firms in India—the Workout function
- What is Restructuring?
- Criteria for Considering Restructuring
- Relief Measures under Restructuring
- Valuation of Restructured Advances
- Annexure I: Warning Signs that Banks Should Look out for—An Illustrative Checklist
- Annexure II
- Annexure III: Case Studies: CDR and SDR
- 08 Managing Credit Risk—An Overview
- SECTION I BASIC CONCEPTS
- Expected Versus Unexpected Loss
- Defining Credit Risk
- International guidelines and standards for Credit Risk management – The Basel Committee on Banking Supervision (BCBS)
- Classifying ‘Impaired’ Loans
- Loan Workouts and Going to Court for Recovery
- Credit Risk Models
- SECTION II MEASURING CREDIT RISK— INTRODUCTION TO SOME POPULAR CREDIT RISK MODELS
- A Basic Model
- Modeling Credit Risk
- SECTION III CREDIT RISK TRANSFERS— SECURITIZATION, LOAN SALES, COVERED BONDS AND CREDIT DERIVATIVES
- SECURITIZATION
- Asset Reconstruction Companies (ARC)
- Covered Bonds
- Legislation on covered bonds—select countries
- Credit Derivatives
- Some Basic Credit Derivative Structures
- SECTION IV TREATMENT OF CREDIT RISK IN INDIA—SOME IMPORTANT EXPOSURE NORMS, PRUDENTIAL NORMS FOR ASSET CLASSIFICATION, INCOME RECOGNITION AND PROVISIONING
- Some Important Exposure Norms
- Large Exposures Framework (LEF)
- Prudential Norms for Asset Classification, Income Recognition and Provisioning
- Income Recognition
- Asset Classification
- SECTION V TREATMENT OF CREDIT RISK IN INDIA—SECURITIZATION AND CREDIT DERIVATIVES
- Securitization—The Act
- Securitization—the Guidelines
- Sale of Assets by Banks not Involving SC/RC
- Strengthening the securitization framework in India
- Asset Reconstruction companies in India
- How do ARCs work?
- Securitization—The Indian Experience
- India’s Securitization market in 2016
- Credit Derivatives in India
- Annexure I: Basel Committee Documents on Credit Risk Management
- Annexure II: Salient Features of Securitization
- Annexure III: Case Study: Kingfisher Airlines –A High Profile NPA
- 09 Managing Credit Risk—Advanced Topics
- SECTION I BASIC CONCEPTS
- Estimating PD, EAD and LGD—The Issues
- Why Do We Need Credit Risk Models?
- Credit Risk Models—Best Practice Industry Models
- SECTION II SELECT APPROACHES AND MODELS—THE CREDIT MIGRATION APPROACH
- The Credit Migration Approach (Used by Credit Metrics)
- Model Applied to Loan Commitments
- Calculation of Portfolio Risk
- The Credit Migration Approach (Used by CreditPortfolioView)
- SECTION III SELECT APPROACHES AND MODELS—THE OPTION PRICING APPROACH
- The KMV Model
- Improvements Made to the Basic Structural Model in the Current Version EDF8.0
- SECTION IV SELECT APPROACHES AND MODELS—THE ACTUARIAL APPROACH
- Credit Risk+™ Model
- SECTION V SELECT APPROACHES AND MODELS—THE REDUCED FORM APPROACH
- Kamakura Risk Manager Version 8.0 and Kamakura Public Firm Models Version 5.0
- A Brief Description of the Approaches Follows
- Which Model is Better—Structured or Reduced Form?
- SECTION VI PRICING CREDIT DERIVATIVES
- Pricing Credit Default Swaps—Understanding the Cash Flows
- Pricing Credit Default Swaps—Grasping the Basics
- Pricing Collateralized Debt Obligations—The Basics
- SECTION VII CREDIT RISK MEASUREMENT AFTER THE FINANCIAL CRISIS
- The Financial Crisis—An Overview and Analysis
- Current Developments and Regulatory Changes
- Some developments
- SECTION VIII A NOTE ON DATA ANALYTICS AND BUSINESS SIMULATION
- Business Simulations: 5 Reasons Why Business Simulations Are Great Learning Tools
- Annexure I: Case Study-The Global Credit Crisis—A Brief Chronology of Events in 2007–08
- 10 Managing Market Risk—Banks’ Investment Portfolio
- SECTION I BASIC CONCEPTS
- The Treasury Functions
- Risks and Returns of Investment Securities
- SECTION II MEASURING MARKET RISK WITH VAR AND EXPECTED SHORTFALL (ES)
- Approaches to VaR Computation
- ES and VaR – a comparison
- SECTION III BANKS’ INVESTMENT PORTFOLIO IN INDIA—VALUATION AND PRUDENTIAL NORMS’
- Classification of the Investment Portfolio
- Valuation of Investments
- Investment Reserve
- Determination of ‘Market Value’ While Marking to Market (HFT and AFS Categories)
- ‘Non-Performing’ Investments
- Income Recognition
- Annexure I: Case Study—LTCM Collapse and Link with VaR
- Annexure II: Summary of Regulatory Responses to Market Risk Measurement Practices by Banks After the Global Financial Crisis
- 11 Capital—Risk, Regulation and Adequacy
- SECTION I BASIC CONCEPTS
- Why Regulate Bank Capital?
- To What Should Capital be Linked to Ensure Bank Safety?
- The Concept of Economic Capital
- The Concept of Regulatory Capital
- SECTION II RISK-BASEDCAPITAL STANDARDS—REGULATORY CAPITAL
- Demystifying the Basel Accords I, II and III
- Basel Accord I
- Basel Accord II
- Basel Accord III
- Basel IV –or is it Basel 3.5? Move to More Regulatory Approaches to Risk Measurement
- SECTION III APPLICATION OF CAPITAL ADEQUACY TO BANKS IN INDIA
- Capital Components–Banks in India
- Capital Funds of Banks Operating in India
- Counter Cyclical Capital buffer (CCCB)
- Leverage Ratio
- Capital Measure
- Exposure Measure : General Measurement Principles
- Calculating Capital Charges and Risk-Weighted Assets
- SECTION IV ILLUSTRATIVE PROBLEMS ON CALCULATING CAPITAL ADEQUACY
- Steps for Computing Risk-Weighted Assets
- Annexure I: Determination of Risk Weighted Assets Under the Basel Norms
- Annexure II: The Financial Crisis of 2007—Basel II and the Blame Game
- Annexure III: Pillars II and III of Basel III Accord and Their Application to Indian Banks
- Annexure IV: Capital Adequacy Ratios of Indian Banks—Some Comparative Charts
- 12 Managing Interest Rate and Liquidity Risks
- SECTION I THE CHANGNG FACE OF BANKING RISKS
- SECTION II ASSET LIABILITY MANAGEMENT
- SECTION III INTEREST RATE RISK MANAGEMENT
- Interest rate risk in the banking book - Basel committee standards - Salient features
- Types of risks
- Revised Principles for IRRBB
- The standardised framework
- Overall structure of the standardised framework
- Components of the standardised framework
- Calculation of change in Economic Value of Equity (ΔEVE)
- Calculation of change in projected Net Interest Income (ΔNII)
- Components of interest rates
- IRRBB and CSRBB
- Measuring Interest Rate Risk
- Managing Interest Rate Risk—A Strategic Approach
- Interest Rate Risk or Model Risk?
- Alternative Methods to Reduce Interest Rate Risk
- SECTION IV MANAGING INTEREST RATE RISK WITH INTEREST RATE DERIvATNES
- Swaps
- Interest Rate Futures
- Forward Rate Agreements (FRAs)
- Interest Rate Options
- Interest Rate Guarantees
- Swaptions
- Arbiloans
- Derivatives Market Growth—The Issues
- SECTION V LIQUDITY RISK MANAGEMENT AND BASEL III
- Sources of Liquidity Risk
- Modern Approaches to Liquidity Risk Management
- Approach to Managing Liquidity for Long-Term Survival and Growth
- Approach to Managing Liquidity in the Short Term— Some Tools for Risk Measurement
- Basel III—The International Framework for Liquidity Risk Measurements, Standards and Monitoring
- SECTION VI APPLICABILITY TO BANKS IN INDIA
- Interest Rate Derivatives in India
- The Exchange Traded Interest Rate Derivatives in India
- ALM Framework for Indian Banks
- Liquidity Risk Management in Indian Banks
- Annexure I: Theories of Interest Rates
- Annexure II: Concept of Duration and Convexity
- Annexure III: Features of a Sound Liquidity and Funds Management Policy and Symptoms of Potential Liquidity Risk
- Annexure IV: Management of Liquidity Risk in Financial Groups—Key Findings
- Annexure V: ALM in India—Classification of Bank Liabilities and Assets According to Rate Sensitivity and Maturity Profile
- Annexure VI: Case Study—Northern Rock Liquidity Crisis
- 13 Banking Functions, Retail Banking and Laws in Everyday Banking
- SECTION I BASIC CONCEPTS
- Negotiable Instruments
- Types of Deposits
- Non-Resident Indian (NRI) Accounts
- Mandates and Power of Attorney
- SECTION II RETAIL BANKING-NATURE AND ScoPE
- Why Banks Focus on Retail Business
- Emerging Issues in Handling Retail Banking
- SWOT Analysis of Retail Banking
- Strategies for Success in Retail Banking
- SECTION III CUSTOMER RELATIONSHIP MANAGEMENT (CRM)
- Marketing—Coin
- CRM Strategies/Steps
- Three Tip Questions for Managers
- Image-Building Exercises
- Blending Tradition with Technology
- SECTION IV LAWS IN EVERYDAY BANKING
- Key Acts That Govern the Functioning of the Banking Sector
- Different Customers—Different Laws
- Bank-Customer Relationship
- Rights of a Banker
- Obligations of a Banker
- Case Study: Savings Account is Not an Investment Tool
- 14 Banking System—Services and Innovations
- SECTION I COMMERCIAL BANKING SYSTEM AND STRUCTURE
- Globalization and Innovations
- SECTION II CASE STUDIES OF BANKS
- The ICICI Bank
- HSBC Bank
- The State Bank of India (SBI)
- SECTION III CASE IN DETAT—HSBC BANK
- Accounts
- Credit Cards
- Standard Privileges for HSBC Card Holders
- Loans
- Wealth Management
- Insurance
- Special Offers
- Case Questions
- Case Study: Interest Rates and Prof Bond
- 15 International Banking—Foreign Exchange and Trade Finance
- INTRODUCTION
- SECTION I BASIC CONCEPTS
- Exchange Rates
- FOREX Market
- Transfer Systems
- Direct and Indirect Quotations
- Functioning of Foreign Exchange Market
- SECTION II INTER-BANK MARKET AND FOREX DEALING
- Forex Dealing Room Operations
- Spot, Forward, Cash, TOM Rates in an Inter-Bank Market
- Bid and Offer Rates
- Foreign Exchange Market
- SECTION III TRADE FINANCE —LETTERS OF GREDIT
- Financing International Trade Through Letters of Credit
- Flowchart Depicting a Typical Import Transaction with Letter of Credit
- SECTION IV TRADE FINANCE — FINANCING EXPORTERS
- Features of Packing Credit in Local Currency
- Features of Pre-Shipment Credit in Foreign Currency (PCFC)
- Post-Shipment Finance
- SECTION V FOREIGN CURRENCY LOAN (FCL)
- Features of Foreign Currency Loans
- 16 High-Tech Banking—E-Payment Systems and Electronic Banking
- SECTION I BASIC CONCEPTS
- Why Do We Need Technology in Banking?
- Benefits of Electronic Banking
- SECTION II E-PAYMENTS
- The Importance of Payments and Settlement Systems
- International Standards and Codes for Payment and Settlement Systems
- SECTION III RETAIL PAYMENT SYSTEMS
- Paper-Based Instruments in Retail Payment Systems—An Overview
- Electronic Retail Payment Systems—An Overview
- SECTION IV PLASTIC MONEY AND E-MONEY
- Credit Cards
- Debit Cards
- Credit and Debit Cards in India
- Other Payment Channels/Products
- SECTION V SECURITY ISSUES IN E-BANKING
- 17 Understanding Financial Services
- SECTION I NON-BANKING FINANCIAL COMPANY
- SECTION II VENTURE CAPITAL AND PRIVATE EQUITY
- Stages in Venture Capital (VC) Investing
- SECTION III CREDIT CARDS
- Major Parties Involved in Credit Card Transaction
- Working of Credit Cards
- Charges and Profits in Credit Card Transactions
- SECTION IV HOUSING FINANCE
- SECTION V IPO (INITIAL PUBLIC OFFERING)
- SECTION VI MICROFINANCE
- Challenges
- SECTION VII Pension Funds
- Pension Funds in India
- SECTION VIII Alternate investments
- Commodities
- Hedge Funds
- SECTION IX CONSUMER RIGHTS AND PROTECTION APPLICABLE TO FINANCIAL SERVICES
- Consumer Protection and Regulation in India
- 18 Insurance Services
- SECTION I BASIC CONCEPTS
- Basic Features of Insurance Contracts
- Benefits of Insurance
- Types of Insurance Products
- SECTION II INDIA'S INSURANCE SECTOR-AN OVERVIEW
- The Insurance Sector
- Changing Scenario of the Life Insurance Sector
- Insurance Regulatory Development Authority (IRDA)
- IRDA Regulations
- Life Insurance Corporation of India
- Export Credit Guarantee Corporation of India (ECGC)
- SECTION III BANKS AND INSURANCE SERVICES-BANCASSURANCE IN INDIA
- How Does Bancassurance Help Banks?
- How Does Bancassurance Help Insurance Companies?
- How Does Bancassurance Help Customers?
- SECTION IV GLOBAL INSURANCE INDUSTRY, OPPORTUNITIES AND CHALLENGES
- The Industry After the Financial Crisis
- Challenges
- Opportunities
- Convergence
- The Growth of Insurance Demand
- 19 Mutual Funds, Securities Trading, Universal Banking and Credit Rating
- SECTION I MUTUAL FUNDS
- Advantages of Mutual Funds
- Types of Mutual Funds
- Important Terms
- SECTION II TRADING IN SECURITIES/SHARES
- Factors Behind Growth of Online Trading
- Impact on Securities Market
- SECTION III UNIVERSAL BANKING
- Size and Market Power
- Diversification—Insurance and Securities
- Core of Universal Banking
- Impartial Investment Advice
- Benefits to Banks
- Benefits to Customers
- Challenges
- SECTION IV CREDIT RATING SERYICES
- Credit Rating—An Overview
- Information to Investors
- Benefits to Issuers
- Benefit to the Regulators
- Differences of Opinion in the Credit Rating Industry
- 20 Cash Management and Demand Forecasting in ATMs
- SECTION I INTRODUCTION
- SECTION II THE CASE OF BHARATH BANK
- Outsourced Agents for ATMs
- SECTION III THE CASE OF GLOBAL BANK
- Information Flow in the Supply Chain—Role of IT Infrastructure
- SECTION IV CASH DEMAND FORECASTING
- Time Series Analysis of Cash Withdrawals from ATMs
- Sales Trends and Other Factors
- Annexure I: ATM—Post- and Pre-Installation Activities
- 21 Mergers and Acquisitions in the Banking Sector
- 22 Innovations in Products and Services—Cases of Three Banks
- CASE STUDY I BARCLAYS BANK
- UK Banking
- Barclay Card
- Barclays Capital
- Barclays Global Investors
- Barclays Wealth Management
- Performance and Governance
- Products and Services
- Other Services
- Savings and Investment
- Recent Initiatives
- Barclays Strategy
- Case Questions
- CASE STUDY II ING VYSYA BANK
- Milestones of the Bank Over the Long Years of Its Services
- The Origin of ING Group
- The New Identity: ING Vysya Bank
- Customer Relationship Management
- IT Implementation for Quick Customer Response
- Retail Banking
- ING Vysya Bank’s Retail Banking Strategy
- Case Questions
- CASE STUDY III STATE BANK OF INDIA
- Features of the State Bank of India
- Primary Activities
- Secondary Activities
- Products and Services
- Case Questions
- 23 Innovations in Products and Services in Banking—Cases of Public and Private Sector Banks
- CASE STUDY I CORPORATION BANK
- Personal Banking
- Loan Schemes
- Cards
- High-Tech Banking Products and Services
- Products and Services for Non-Residents
- Important Services
- Case Questions
- CASE STUDY II SOUTH INDIAN BANK
- Introduction
- SIB Deposit Schemes
- Loans and Advances
- NRI Schemes
- Other Service Features Offered by SIB
- Case Questions
- Appendix: Objective-Type Questions on Commercial Banking
- Index
- Copyright
* The final standards for measuring market risk were published in January 2016 (http://www.bis.org/bcbs/publ/d352.pdf) and explanatory notes in January 2017 (http://www.bis.org/bcbs/publ/d395.pdf)
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