Estimating the Costs of Financial Regulation. By Andre Santos and Douglas Elliott
IMF Staff Discussion Notes No. 12/11
September 11, 2012
ISBN/ISSN: 978-1-61635-435-0 / 2221-030X
This study shows that financial reform will likely result in a modest increase in bank lending rates in the United States, Europe, and Japan in the long term. Higher safety margins in terms of capital and liquidity will lead to an increase in lenders’ operating costs, affecting bank customers, employees, and investors. Yet banks appear to have the ability to adapt to the regulatory changes without actions that would harm the wider economy. In response to the estimated rise in regulatory costs, average bank lending rates are likely to increase by 28 bps in the United States, 17 bps in Europe, and 8 bps in Japan in the long term. By comparison, the smallest increment by which major central banks adjust their short-term policy rates is 25 bps, which tends to have a small effect on economic growth.
A simple framework is used to estimate the likely increase in lending rates. These rates reflect the cost of allocated capital, other funding costs, credit losses, administrative costs, and several other factors. There is considerable uncertainty about these cost assumptions, but a sensitivity analysis shows that reasonable changes in assumptions do not dramatically alter the conclusions of this study. Cost estimates are based on several references, including academic theory, empirical analyses from industry and official sources, as well as financial disclosures by large banks.
The findings are based on methodologies that were used in previous studies by academics and the official sector. This study, however, estimates that lending rate increases will likely be significantly smaller, for the following reasons. First, the baseline scenario implies a smaller regulatory effect, with market forces accounting for some of the expected increases in safety margins. Second, banks are expected to absorb part of the higher costs by cutting expenses. Third, investors are expected to reduce their required rate of return on bank equity modestly as a result of the safety improvements. Debt investors are expected to follow suit, although to a much lesser extent.
There are important limitations to the analysis presented here. It does not address the potential transition costs as banks adjust to the new regulations. Nor does it assess the economic benefits of financial reforms. A number of regulatory reforms are not modeled; judgment has been required in making many of the estimates; and the modeling approach is relatively simple. Nevertheless, the results appear to be a balanced, albeit rough, assessment of the likely effects on bank lending. Further research would be useful to translate these credit impacts into effects on economic output.