2.2. Financial Regulation

Report
Part 2: Policy responses
1. Rationale for financial regulation
2. Financial regulation
3. Topical issues
2.1. Rationale for financial regulation and macro-prudential policies
Lessons from the recent crisis
Effects
Household
leverage
Initial shock
(subprimes)
Bank risk taking
Bank capital
channel
Liquidity spirals
Global banking
channel
Regulation
Excess leverage ex ante
Loan to Value, Debt
to Income ratios
Too little capital ex ante (skin
in the game)
Basel III Capital
regulation
Leverage cycles
Market liquidity
channel
Funding liquidity
channel
Lessons/inefficiencies
Market runs
Liquidity hoarding
Too little liquid assets, too
much common exposures ex
ante
Too much wholesale funding
ex ante
Basel III Liquidity
regulation
International spillovers,
Regulation on SIFIs,
How to resolve global banks?
global banks defaults
living wills
2.1. Rationale for financial regulation and macro-prudential policies
Lessons from the recent crisis
• Moral hazard: gives rise to borrowing constraints where the borrowing limits may depend on
asset prices (Kiyotaki and Moore, 1998)
• “Pecuniary” (e.g. fire sale) externalities arise when (i) banks face borrowing constraints, (ii)
the borrowing limit depends on asset prices, (iii) assets are held by “experts” (e.g. industry
peers)
• Banks are hit by an adverse shock that eats up their capital. To maintain their capital ratio
constant (moral hazard) they sell assets to pay back some debt. These assets are held by
peers, so price goes down. Additional capital losses call for another round of sales. Banks
could otherwise raise equity. But they don’t because they do not internalize the fire sale
• Because of fire sale externalities, the asset supply curve may be downward sloping, give rise
to multiple equilibria, and coordination failures (e.g. Diamond and Dybvig, 1983)
2.1. Rationale for financial regulation and macro-prudential policies
Lessons from the recent crisis
• Address the market failures that make the banking sector as a whole (i) at the origin of
adverse shocks, (ii) more exposed to shocks, (iii) less resilient to shocks
• (i) calls for risk prevention policies
• (ii) calls for risk absorption policies
• Micro-prudential policies, which aim at protecting individual financial institutions, is
not only ill-equipped but may even at times destabilize the financial system as a whole
• Need for a dynamic, general equilibrium, coordinated, macro-prudential approach
2.2. Financial Regulation
Institutional architecture
Group of 20 Ministers and CB Governors (G20)
Basel Committee on Banking Supervision
High-level discussion of policy issues pertaining to
the promotion of international financial stability
Provides a forum for regular cooperation on banking
supervisory matters. Formulates supervisory
standards and recommendations on best practice in
banking supervision in the expectation that member
authorities and other nations' authorities will take
steps to implement them through their own national
systems. The purpose of BCBS is to encourage
convergence toward common approaches and
standards.
European Union
• The CRD IV package transposes – via a
Regulation and a Directive – the new global
standards on bank capital (e.g. Basel III-Capital)
into the EU legal framework (July 2013)
• European banking Authority and Banking
Union:
• Single Supervisory Mechanism (SSM)
• Single Resolution Mechanism (SRM)
• European Deposit Guarantee (DGS)
Basel III:
• Capital: “ A global regulatory framework for more
resilient banks and banking systems”
• Liquidity: “The Liquidity Coverage Ratio and
liquidity risk monitoring tools”
2.2. Financial Regulation
Institutional architecture
2.2. Financial Regulation
Institutional architecture
2.2. Financial Regulation
Institutional architecture
2.2. Financial Regulation
Institutional architecture
2.2. Financial Regulation
Roadmap
• Basel Accord (1988): micro-prudential regulation, with the objective is to safeguard
individual financial institutions from idiosyncratic shocks. Banks must hold regulatory
capital
• Basel II (2008, in EA): Enhanced Basel Accord, with three pillars:
• Pillar 1: Risk-sensitive minimum capital requirement, takes into account credit risk
and operational risk, banks have their own risk evaluation models
• Pillar 2: Supervisory review, evaluate banks’ internal procedures
• Pillar 3: disclosure and market discipline
• Basel III (2013-, in EA): Enhanced Basel II, with higher quality capital requirements,
capital buffer, liquidity requirements, macro-prudential approach (counter-cyclicality),
with the objective to take into account the interaction between financial institutions.
General equilibrium approach
2.2. Financial Regulation
Roadmap
2.2. Financial Regulation
Basel Accord (1988)
• Improve the soundness of the international banking sector
• “Level playing field”, international coordination: banks must hold
• Banks are required to have “Tier 1” capital above 4% of assets and “Tier 2” capital
above 8% of assets
• Assets are weighted based on their types
Asset types
Weights
Cash
0%
OECD banks
20%
Mortgages
50%
Corporates,…
100%
Tier 1 capital
Tier 2 capital
Common shares
Loan loss provisions
Retained earnings
Subordinated debt
2.2. Financial Regulation
Basel II (2008)
• Risk weights are based on credit risks, not on asset types
• Standardized approach (risks evaluated by Rating Agencies) or Advances Internal
Ratings Based (IRB) approach (risks evaluated internally)
Corporates
Credit rating
AAA to AA-
A+ to A-
BBB+ to BB-
Below BB-
Unrated
Risk weight
20%
50%
150%
150%
100%
2.2. Financial Regulation
Basel III (2013-)
• Raise the quality of the capital required, supplement capital ratio with a simple
leverage ratio
• Reduce pro-cyclicality capital regulation (macro-prudential aspect of Basel III):
• Forward looking provisioning
• Capital conservation buffer
• Counter-cyclical buffer
• Enhance risk coverage (capital, market liquidity risk, funding liquidity risk)
2.2. Financial Regulation
Basel III (2013-) – Capital quality
• Tier 1 = Common shares and retained earnings
• No hybrid instruments (e.g. bonds convertible into equity) in Tier 1
• Change the weights: raise capital requirement for the trading book and complex
securitization exposures. More weights on OTC derivatives (exposures) not cleared
through CCP (against counterparty credit risk)
• Additional capital charge for potential mark-to-market losses associated with a
deterioration in the creditworthiness of a counterparty
2.2. Financial Regulation
Basel III (2013-) – Capital quality
Timetable
Common
equity/TWA
Tier 1/TWA
Total capital/TWA
January 2013
3.5%
4.5%
8%
January 2014
4%
5.5%
8%
January 2015
4.5%
6%
8%
2.2. Financial Regulation
Basel III (2013-) – Capital conservation buffer
• Banks have to build up capital buffers, i.e. hold capital above and beyond the 8%
regulatory capital, outside periods of stress
• When buffers have been drawn down, one way banks should look to rebuild them is
through reducing discretionary distributions of earnings. This could include reducing
dividend payments, staff bonus payments.
• A capital buffer of 2.5%, comprised of Core Tier 1 capital, is established above the Tier
1 regulatory minimum (i.e. above 4.5%). Dividend distribution constraints will be
imposed on a bank that falls within this range. But strong incentives more than
constraint (otherwise would be in effect a minimum requirement)
2.2. Financial Regulation
Basel III (2013-) – Capital conservation buffer
Common equity
ratio (Tier 1)
Share of earnings
4.5%-5.125%
100%
5.125%-5.75%
80%
5.75%-6.375%
60%
6.375%-7.0%
40%
>7.0%
0%
Timetable
Common
equity/TWA
January 2016
0.625%
January 2017
1.25%
January 2018
1.875%
January 2019
2.5%
2.2. Financial Regulation
Basel III (2013-) – Counter-cyclical buffer
• Banks have to build up more capital in good times, less in bad times (when they need
it)
• The CCB aims to ensure that capital requirements take account of the macroeconomic environment
• Based on credit growth and other indicator that may signal a build-up of systemic risk,
banks may be required to hold an 2.5% countercyclical buffer, comprised of common
equity capital Tier 1
• Banks are force to retain earnings if they do not meet the CCB requirement
2.2. Financial Regulation
Basel III (2013-) – Counter-cyclical buffer
Common equity
ratio (Tier 1)
Share of earnings
4.5%-5.75%
100%
5.75%-7.0%
80%
7.0%-8.25%
60%
8.25%-9.5%
40%
>9.5%
0%
Timetable
Counter-cyclical
capital/TWA
January 2016
0.625%
January 2017
1.25%
January 2018
1.875%
January 2019
2.5%
2.2. Financial Regulation
Basel III (2013-) – Counter-cyclical buffer
• Banks have to build up more capital in good times, less in bad times
• The CCB aims to ensure that capital requirements take account of the macroeconomic environment
• Based on credit growth and other indicator that may signal a build-up of systemic risk,
banks may be required to hold an 2.5% countercyclical buffer, comprised of core Tier 1
capital
• Banks are force to retain earnings if they do not meet the CCB requirement
2.2. Financial Regulation
Basel III (2013-) – Counter-cyclical buffer
2.2. Financial Regulation
Basel III (2013-) – Liquidity Coverage Ratio (LCR)
• Banks are required to hold liquid assets, have an adequate stock of unencumbered
high-quality liquid assets (HQLA) that can be converted easily and immediately into
cash to meet their liquidity needs for a 30 day liquidity stress scenario
  
> 100%
  ℎ   ℎ  30  
2.2. Financial Regulation
Basel III (2013-) – Liquidity Coverage Ratio (LCR)
• Prevent runs and increase resilience of banks to adverse funding liquidity shocks
• Prevent fire sales and increase resilience to adverse market liquidity shocks
• Liquid assets are not claims issued by industry peers
• Flight to quality (“safe heaven” assets), like banknotes, central bank reserves,
sovereigns
• The liquid buffer may be used in period of stress (i.e. the LCR may fall below 100%),
another macro-prudential aspect of Basel III
• Net cash outflows based on banks’ stress tests
2.2. Financial Regulation
Basel III (2013-) – Liquidity Coverage Ratio (LCR)
Timetable
Mininum LCR
January 2015
60%
January 2016
70%
January 2017
80%
January 2018
90%
January 2019
100%
2.2. Financial Regulation
Basel III (2013-) – Net Stable Funding Ratio (NSFR)
• Banks are required to have a minimum amount of stable sources of funding relative to
the liquidity profile of their assets over a one year horizon
• The longer the maturity of the assets, the more stable funding need to be, so as to
avoid too big a “maturity mismatch”
    
> 100%
    
2.2. Financial Regulation
Basel III (2013-) – Net Stable Funding Ratio (NSFR)
• Stable funding: Tier 1 and Tier 2 capital, term deposits
• Unstable funding: unsecured wholesale funding
• Liquid assets (as defined for the LCR) do not require as much stable funding as nonmarketable assets
2.2. Financial Regulation
Basel III (2013-) – Net Stable Funding Ratio (NSFR)
Timetable
Not before 2019
Mininum LCR
proposal issued for
comments by
April 2014
2.2. Financial Regulation
Basel III (2013-) – Other features
• Capital surcharges for SIFIs to increase the loss absorbing capacity of global banks
• Capital incentives for banks to use central counterparties for OTC derivatives
• Higher capital requirements for trading and derivative activities, as well as for complex
and off-balance sheet exposures
• Higher capital requirements for inter-sectoral exposures
• …
2.2. Financial Regulation
Basel III (2013-) – Remember the leverage cycle
Liabilities
Assets
Retail loans to NFCs
Equity
Retail loans to HHs
Retail deposits from
non-financial sector
Non-financial securities
Government bonds
Wholesale funding
Wholesale lending
2.2. Financial Regulation
Basel III (2013-) – Remember the liquidity spirals
Liabilities
Assets
Retail loans to NFCs
Equity
Retail loans to HHs
Retail deposits from
non-financial sector
Non-financial securities
Government bonds
Wholesale funding
Wholesale lending
2.3. Topical Issues
The European Banking Union
• The European Central Bank (ECB) is preparing to take on new banking supervision tasks as
part of a single supervisory mechanism (SSM)
• The SSM will create a new system of financial supervision comprising the ECB and the
national competent authorities of participating EU countries
• The main aims of the single supervisory mechanism will be to ensure the safety and
soundness of the European banking system and to increase financial integration and
stability in Europe
• The ECB will be responsible for the effective and consistent functioning of the single
supervisory mechanism, cooperating with the national competent authorities of
participating EU countries
2.3. Topical Issues
The European Banking Union
2.3. Topical Issues
The European Banking Union
2.3. Topical Issues
The European Banking Union
2.3. Topical Issues
The European Banking Union
2.3. Topical Issues
Central bank as bank supervisor? Cons
• Loss of independence: the central bank could become more prone to political capture
as its role gains importance, thereby undermining its independence
• Credibility and reputational risks for the central bank: credibility risk is greater in the
area of financial stability as only failures are observed and there is no quantitative
objective.
• Regulatory forbearance: at times where the economy is weak and on the brink of
deflation, the central bank may not allow unsound banks to fail
• Conflicts of interest: to the extent that higher rates may harm banks, the central bank
may not raise interest rates to fight inflation
2.3. Topical Issues
Central bank as bank supervisor? Cons (Di Noia and Di Giorgio, 1999)
2.3. Topical Issues
Central bank as bank supervisor? Cons (Ioannidou, 2003)
2.3. Topical Issues
Central bank as bank supervisor? Pros
• Coordination is necessary, ex: there is an house price bubble and the financial
regulator wants to raise capital requirements; this has a negative effect on inflation;
the central bank may lower rates; this has a positive effect on house prices… (“pushme pull-you” behaviors )
• Financial stability is crucial for the conduct of monetary policy (e.g. interbank market)
• Information on banks is crucial, notably if the central bank is a lender of last resort
2.3. Topical Issues
Central bank as bank supervisor? Pros (Peek, Rosengren, Tootel, 1999)
2.3. Topical Issues
Should macro-prudential supervision be centralized? Cons
• National supervisors have better knowledge of domestic financial conditions
• Large, federal regulators may be more prone to lobbying
2.3. Topical Issues
Should macro-prudential supervision be centralized? Pros
• To the extent that macro-prudential and monetary policies complement each other, in
a monetary union (where monetary policy is centralized) macro-prudential policy too
should be centralized
• National macro-prudential regulations may generate (negative) externalities that only
a centralized authority can internalize, e.g. global banks and cross-border capital flows
• A centralized macro-prudential authority may be less prone to regulatory capture by
private interests
• Federal regulators are found to be tougher on banks
2.3. Topical Issues
Should macro-prudential supervision be centralized? Pros (Agarwal et al., 2013)
2.3. Topical Issues
Coordination between micro- and macro-prudential supervisors
• Micro- and macro-supervisors have the same tools (capital ratios, liquidity ratios, etc)
but…
• …they have different objectives (bank versus system stability)
• …they do not use the tools the same way (granular versus uniform)
• There maybe conflicts of interest: tougher macro-prudential rules in good times may
imply more bank defaults; tougher micro-supervision in bad times may amplify the
recession due to lack of general equilibrium perspective
• Conflicts are probably more acute during recessions
2.3. Topical Issues
Coordination between micro- and macro-prudential supervisors
• Macro-prudential supervision must not necessarily prevail over micro-prudential
supervision, though
• Because it pays attention to collective (macro) behaviors, macro-prudential
supervision tends to be counter-cyclical and subject to collective moral hazard
• Paradoxically, banks may collectively take risks in good time anticipating bail out in
bad times (gambles). Ex: If all banks hold more liquid assets in good times, then
the assets may paradoxically become illiquid in bad times due to industry exposure
• Macro-pru policies only have a bite if market failures come from the banking
sector
• In contrast, micro-prudential supervision does not pay attention to collective behavior,
and may punish the banks that take more risk than average
2.3. Topical Issues
The political economy of financial regulation
• Government intervention (regulation) corrects market inefficiencies to maximize social
welfare
• Regulation may sometimes be the outcome of private interests who use the coercive
power of the state to extract rents at the expense of other groups
• Benmeleck and Moskowitz (2007): “The evidence suggests regulation is the outcome
of private interests, highlighting the endogeneity of financial development and
growth”
• Usury law in the 19th century (US): by limiting the interest rate charged by banks,
usury laws cause credit rationing and give a competitive edge to wealthier (low
rates) borrowers
• Voting restrictions based on wealth are highly correlated with tight usury laws
2.3. Topical Issues
The political economy of financial regulation (Benmeleck and Moskowitz, 2007)
2.3. Topical Issues
The political economy of financial regulation
• What about Basel III? The membership of the BCBS was extended to G20 countries in
March 2009, to include emerging market economies
• Public consultations and Quantitative Impact Studies on the new regulatory standards
• Bengtsson (2013): “Our findings indicate that the changes in the governance structure
and influence of private actors seem to have led the BCBS to develop a capital accord
that is relatively less beneficial for large international banks and the traditional BCBS
member countries. This suggests that a tilting of power in favour of emerging markets
has occurred in the political economy of banking regulation”
2.3. Topical Issues
The political economy of financial regulation

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