Tuesday, January 17, 2012

CPSS-IOSCO's Requirements for OTC derivatives data reporting and aggregation: final report

Requirements for OTC derivatives data reporting and aggregation: CPSS-IOSCO publishes final report
January 17, 2012
http://www.bis.org/press/p120117.htm

The Committee on Payment and Settlement Systems (CPSS) and the Technical Committee of the International Organization of Securities Commissions (IOSCO) have published their final report on the OTC derivatives data that should be collected, stored and disseminated by trade repositories (TRs).

The committees support the view that TRs, by collecting such data centrally, would provide authorities and the public with better and more timely information on OTC derivatives. This would make markets more transparent, help to prevent market abuse, and promote financial stability.

The final report reflects public comments received in response to a consultative version of the report published in August 2011. Following the consultation exercise, the report was expanded to elaborate on the description of possible options to address data gaps.

The report was also updated to reflect recent international developments in data reporting and aggregation requirements stemming from the Legal Entity Identifier (LEI) workshop in September 2011 and other efforts under the auspices of the Financial Stability Board (FSB), in support of a request by the G20 at the Cannes Summit, to advance the development of a global LEI.

As the report indicates, some questions remain regarding how best to address current data gaps and define authorities' access to TRs. As requested by the G20, two internationally coordinated working groups will address these questions in the coming year. The FSB will establish an ad hoc group of experts to further consider means of filling current data gaps, while the CPSS and IOSCO will establish a joint group to examine authorities' access to trade repositories.


Report Background

The report addresses Recommendation 19 in the October 2010 report of the FSB, Implementing OTC derivatives market reforms, which called on the CPSS and IOSCO to consult with the authorities and the OTC Derivatives Regulators Forum in developing:

(i)    minimum data reporting requirements and standardised formats, and

(ii)   the methodology and mechanism for data aggregation on a global basis. A final report is due by the end of 2011.

The requirements and data formats will apply both to market participants reporting to TRs and to TRs reporting to the public and to regulators. The report also finds that certain information currently not supported by TRs would be helpful in assessing systemic risk and financial stability, and discusses options for bridging these gaps.

Issues relating to data access for the authorities and reporting entities are discussed, including methods and tools that could provide the authorities with better access to data. Public dissemination of data, it is noted, promotes the understanding of OTC derivatives markets by all stakeholders, underpins investor protection, and facilitates the exercise of market discipline.

The report also covers the mechanisms and tools that the authorities will need for the purpose of aggregating OTC derivatives data.


Notes to editors

  • This report was originally published in August 2011 as a consultative report.
  • The CPSS serves as a forum for central banks in their efforts to monitor and analyse developments in payment and settlement arrangements as well as in cross-border and multicurrency settlement schemes. The CPSS secretariat is hosted by the Bank of International Settlements (BIS).
  • IOSCO is an international policy forum for securities regulators. The Technical Committee, a specialised working committee established by IOSCO's Executive Committee, comprises 18 agencies that regulate some of the world's larger, more developed and internationalised markets. Its objective is to review major regulatory issues related to international securities and futures transactions and to coordinate practical responses to these concerns.
  • Both committees are recognised as international standard-setting bodies by the Financial Stability Board (www.financialstabilityboard.org)

Saturday, January 7, 2012

The sustainability of pension schemes

The sustainability of pension schemes, by Srichander Ramaswamy
BIS Working Papers No 368
http://www.bis.org/publ/work368.htm


Abstract

Poor financial market returns and low long-term real interest rates in recent years have created challenges for the sponsors of defined benefit pension schemes. At the same time, lower payroll tax revenues in a period of high unemployment, and rising fiscal deficits in many advanced economies as economic activity has fallen, are also testing the sustainability of pay-as-you-go public pension schemes. Amendments to pension accounting rules that require corporations to regularly report the valuation differences between their defined benefit pension assets and plan liabilities on their balance sheet have made investors more aware of the pension risk exposure for the sponsors of such schemes. This paper sheds light on what effects these developments are having on the design of occupational pension schemes, and also provides some estimates for the post-employment benefits that could be delivered by these schemes under different sets of assumptions. The paper concludes by providing some policy perspectives.


8  Summary and policy issues (edited)

A weak macroeconomic environment and unusually low real interest rates in many countries have put the funding challenges faced by occupational and public pension schemes in the spotlight. This paper took a simple actuarial model to quantify how the cost of funding DB pension schemes increase as the real rate of return in asset markets falls. If real returns on pension assets are assumed to be lower by 0.5% compared to their historical averages, service costs of DB schemes would be 15% higher than in the past for the same benefit payments. Converting final salary pension schemes to career average schemes (and not altering the percentages applied) would lower pensions by 20–25% assuming that real wages grow at the rate of 1–1.5% per annum.

Declining mortality rates will put further upward pressure on the contribution rates needed to fund these schemes. When the expected increases in longevity are priced into the actuarial model for computing the service cost, this cost is likely to be 10% higher than estimates presented in the paper. Increasing longevity as well as demographic changes that point to a rise in the old-age dependency ratio poses challenges to the sustainability of PAYG schemes. The projected increase in old-age dependency ratio suggests that in many countries the contributions to PAYG schemes have to increase by 20% from current levels in 2020 to pay pensions. But as PAYG schemes that service current pensions from employee contributions and taxes do not report the contractual pension liabilities, estimating the funding shortfalls these schemes might face going forward is a challenge.

In contrast to PAYG schemes and some funded public pension schemes, occupational DB schemes have to comply with accounting standards to report the market value of their pension liabilities and the assets that back them so that potential funding shortfalls faced by these schemes can be quantified. Unusually low real interest rates and poor financial market returns in the past decade have had an adverse impact on the coverage ratio of these schemes through the valuation effects on liabilities and lower returns on pension assets. Estimates of the coverage ratio of occupational DB schemes based on these returns would point to a funding deficit of 10 to 20 per cent against their pension liabilities. The size of any deficit that eventually materialises over the long lives of these schemes, however, would depend on future returns – which are unknown.

For occupational DB schemes that face large funding shortfalls, employer contributions will have to rise to improve the coverage ratio of these schemes. At the same time, increasing longevity and falling real yields against the backdrop of a weak macroeconomic environment are raising the service costs of DB schemes and adding to the upward pressures on required contribution rates. Recent amendments to pension accounting standards, which require companies to provide more disclosures in their financial statements on the risks the DB scheme poses to the entity and to report the net gains or losses from their DB pension plans on their balance sheet, are likely to accelerate the shift out of occupational DB plans into DC plans. This is because DC plans limit the contractual liabilities of employers to the contribution rates to be paid for the current service period of the employee.

A progressive shift from DB to DC schemes can have material implications for post-employment benefits because it exposes employees to the investment risks on the pension assets. In addition to this risk, beneficiaries of DC plans will also be exposed to the principal risk factors that determine annuity payments, namely level of real interest rates and the projections of mortality rates into the future when the actual annuity payments will be made. Using a simple model to estimate the retirement income from DC schemes, the numerical results presented in Table 2 showed that when contributions to DC schemes are 18% of salaries over a 30-year period and the returns net of administrative expenses on plan assets are 2% higher than the rate at which wages grow, post-employment benefits from a DC scheme would roughly be 43% of the final salary. The excess return assumption of 2% is based on the following input variables in the model to compute retirement income for DC plans: real yield on long-term bonds is 2%; equity risk premium over the returns on long-term government bonds is 3%; plan assets have an equal share of bonds and equities; administrative expenses are 0.5% of plan assets; and the annual real wage growth rate is 1.25%.

The quantitative analysis presented in this paper provides some insights on the possible trade-offs that may be available for public policy on the design of sustainable pension schemes. For example, the internal rate of return on the notional assets of PAYG schemes will be approximately equal to the rate of real GDP growth of the local economy, which is expected to be 2% or lower in advanced economies. The actuarial model showed that service cost of a pension scheme will be high when the rate of return on the pension assets is low. A funded public pension scheme, on the other hand, will be able to raise the level of return on pension fund assets by investing them in higher growth markets. Estimates using the actuarial model suggest that a 50 basis points increase in real returns lowers the service cost of the pension scheme by 15%. Funded pension schemes therefore offer the prospect of lowering service costs and to be able to better align the pension benefits offered by these schemes to the contribution rates received.

Public policy may also be needed to develop efficient markets for pricing annuity risk as occupational DC plans become the preferred post-employment benefit scheme offered by employers. Efficient markets for pricing annuities will in turn depend on how the market for managing and hedging longevity risk develops. As more employers progressively shift towards DC schemes for providing post-employment benefits, regulatory policies might be needed to restrict the range of permissible investment options available for plan assets to avoid unintended risks being taken by the plan beneficiaries, and to set mandatory minimum contribution rates for participating in DC schemes. Finally, considering that plan beneficiaries in DC schemes are exposed to interest rate risk at the time of converting plan assets into an annuity, the pros and cons of providing insurance policies that guarantee a minimum real yield at which these assets can be converted into an annuity will have to be examined.

Wednesday, December 21, 2011

BCBS: Application of own credit risk adjustments to derivatives - consultative document

Application of own credit risk adjustments to derivatives - Basel Committee consultative document
December 21, 2011
http://www.bis.org/press/p111221.htm

The Basel Committee today issued a consultative document on the application of own credit risk adjustments to derivatives.

The Basel III rules seek to ensure that a deterioration in a bank's own creditworthiness does not at the same time lead to an increase in its common equity as a result of a reduction in the value of the bank's liabilities. Paragraph 75 of the Basel III rules requires a bank to "[d]erecognise in the calculation of Common Equity Tier 1, all unrealised gains and losses that have resulted from changes in the fair value of liabilities that are due to changes in the bank's own credit risk".

The application of paragraph 75 to fair valued derivatives is not straightforward since their valuations depend on a range of factors other than the bank's own creditworthiness. The consultative paper proposes that debit valuation adjustments (DVAs) for over-the-counter derivatives and securities financing transactions should be fully deducted in the calculation of Common Equity Tier 1. It briefly reviews other options for applying the underlying concept of paragraph 75 to these products and the reasons these alternatives were not supported by the Basel Committee.

The Basel Committee welcomes comments on all aspects of this consultative document by Friday 17 February 2012. Comments should be sent to baselcommittee@bis.org. Alternatively, comments may be submitted to the following address: Basel Committee on Banking Supervision, Bank for International Settlements, Centralbahnplatz 2, 4002 Basel, Switzerland. All comments may be published on the BIS website unless a commenter specifically requests confidential treatment.


Summary (http://www.bis.org/publ/bcbs214.htm, edited):

A deterioration in a bank's own creditworthiness can lead to an increase in the bank's common equity as a result of a reduction in the value of its liabilities. The Basel III rules seek to prevent this. Paragraph 75 of the Basel III rules requires a bank to "[d]erecognise in the calculation of Common Equity Tier 1, all unrealised gains and losses that have resulted from changes in the fair value of liabilities that are due to changes in the bank's own credit risk". The application of paragraph 75 to fair valued derivatives is not straightforward since their valuations depend on a range of factors other than the bank's own creditworthiness. The consultative paper proposes that debit valuation adjustments (DVAs) for over-the-counter derivatives and securities financing transactions should be fully deducted in the calculation of Common Equity Tier 1. It briefly reviews other options for applying the underlying concept of paragraph 75 to these products and the reasons these alternatives were not supported by the Basel Committee.

PDF: http://www.bis.org/publ/bcbs214.pdf

2011: A Year of Important Pharmacological Advances for Patients

2011: A Year of Important Pharmacological Advances for Patients
December 21, 2011
http://www.innovation.org/index.cfm/NewsCenter/Newsletters?NID=193

New advances in biopharmaceuticals came as welcome good news for U.S. patients. In recent years, despite increasing investments in R&D, fewer medicines have recieved approval, reminding us just how difficult drug discovery is. But in 2011 there were more new medicines approved than in recent years and these approvals represented important advances in many areas.

The Food and Drug Administration reported in November that in fiscal year 2011 (10/1/10–9/30/11) there were 35 new medicines approved,[i] among the highest in the last decade. According to the FDA report, "few years have seen as many important advances for patients." The final tally of medicines approved in calendar year 2011 waits to be seen but it is clear that 2011 has been a great year for advancing the fight on many disease fronts. Below is information on some of the treatments highlighted in the FDA report.

Cancer: With improvements in early detection and a steady stream of new and enhanced treatments cancer can be more effectively managed and even beaten. Two new personalized medicines for lung cancer and melanoma now provide effective options for patients with tumors expressing certain genetic markers.[ii] The personalized melanoma treatment and another new melanoma medicine became the first new approvals for the disease in 13 years. Read about continued efforts to improve cancer treatment and the 887 medicines currently in development.

Rare Diseases: An estimated 25-30 million Americans suffer from rare or "orphan" diseases, which are often among the most devastating to patients and complex for researchers.[iii] However, advances in science have allowed us to hone in on the causes of many rare diseases and translate those findings into new treatments. Between January 1st and December 7th 2011, eleven new medicines to treat rare diseases were made available to patients for diseases such as the genetic defect congenital Factor XIII deficiency, several cancers, and scorpion poisoning.[iv] A record 460 new medicines are in clinical trials or awaiting FDA review.[v] Read more about the ongoing commitment to improve treatment for rare diseases.

Lupus: Lupus is a serious and potentially fatal autoimmune disease that attacks healthy organs and tissues of the body. For the approximately 300,000 to 1.5 million lupus sufferers in the U.S. the last approved drug came in 1955. This year a newly approved medicine ended that drought with a new approach to treating lupus. Read more about medicines in development for autoimmune diseases.

Hepatitis C: Hepatitis C is a chronic viral disease that affects the liver and can lead liver cancer and liver failure. It affects approximately 3 million people in the United States. Two new medicines approved this year are the first in a new class and offer a greater chance of cure for some patients compared with existing therapies. For more information on medicines in development for infectious diseases, click here.

This is only a partial list of the many advances approved in 2011, for a more complete listing visit www.FDA.org.

Looking ahead to 2012, biomedical research continues to draw us in new directions and helps us to better understand the cause and progression of disease. Coupled with innovative approaches at the bench and in the clinic, we can better prevent, detect, and treat disease to save and improve lives.


References
[i]US Food and Drug Administration, FY2011 Innovative Drug Approvals, (November 2011) http://www.fda.gov/AboutFDA/ReportsManualsForms/Reports/ucm276385.htm

[ii]US Food and Drug Administration, FY2011 Innovative Drug Approvals, (November 2011) http://www.fda.gov/AboutFDA/ReportsManualsForms/Reports/ucm276385.htm

[iii]PhRMA, Orphan Drugs in Development for Rare Diseases (February 2011) http://www.phrma.org/sites/default/files/878/rarediseases2011.pdf

[iv]US Food and Drug Administration, CDER New Drug Review: 2011 Update (December 2011) http://www.fda.gov/downloads/AboutFDA/CentersOffices/OfficeofMedicalProductsandTobacco/CDER/UCM282984.pdf

[v]PhRMA, Orphan Drugs in Development for Rare Diseases (February 2011) http://www.phrma.org/sites/default/files/878/rarediseases2011.pdf

BCBS: revised "Core principles for effective banking supervision" - consultative paper

Consultative paper on revised "Core principles for effective banking supervision" issued by the Basel Committee
December 20, 2011
http://www.bis.org/press/p111220.htm

The Basel Committee on Banking Supervision today issued for public comment its revised "Core principles for effective banking supervision" [http://www.bis.org/publ/bcbs213.htm].

The consultative paper updates the Committee's 2006 "Core principles for effective banking supervision" [http://www.bis.org/publ/bcbs129.htm] and the associated "Core principles methodology" [http://www.bis.org/publ/bcbs130.htm], and merges the two documents into one. The Core Principles have also been re-ordered, highlighting the difference between what supervisors do themselves and what they expect banks to do: Principles 1 to 13 address supervisory powers, responsibilities and functions, focusing on effective risk-based supervision, and the need for early intervention and timely supervisory actions. Principles 14 to 29 cover supervisory expectations of banks, emphasising the importance of good corporate governance and risk management, as well as compliance with supervisory standards.

Among other things, the revision of the Core Principles builds on the lessons of the last financial crisis. The Core Principles have been enhanced to strengthen supervisory practices and risk management. In addition, the revised Core Principles respond to several key trends and developments that emerged during the last few years of market turmoil: the need for greater intensity and resources to deal effectively with systemically important banks; the importance of applying a system-wide, macro perspective to the microprudential supervision of banks to assist in identifying, analysing and taking pre-emptive action to address systemic risk; and the increasing focus on effective crisis management, recovery and resolution measures in reducing both the probability and impact of a bank failure.

Ms Sabine Lautenschläger, Co-chair of the Core Principles Group and Vice-President of the Deutsche Bundesbank, noted that "the revised Core Principles contribute to the broader ongoing effort by the Basel Committee to raise the bar for banking supervision in the post-crisis era". She added that "the Committee has achieved a lot in terms of rule-making over the past five years and this work will be instrumental in firmly entrenching many of the supervisory lessons and regulatory developments since the Core Principles were last revised".

The latest revision ensures the continued relevance of the Core Principles in providing a benchmark for supervisory practices that will withstand the test of time and changing environments. The total number of Core Principles has increased from 25 to 29; 36 new essential and additional criteria have been introduced and another 33 additional criteria have been upgraded to essential criteria that represent minimum baseline requirements for all countries.

The Core Principles are the de facto framework of minimum standards for sound supervisory practices and are universally applicable. The Committee believes that implementation of the revised Core Principles by all countries will be a significant step towards improving financial stability domestically and internationally, and provide a good basis for further development of effective supervisory systems.

"With the advent of various policy measures for addressing both bank-specific and broader systemic risks, the key challenge in this revision of the Core Principles has been to uphold their relevance for different jurisdictions and banking systems," stated Ms Teo Swee Lian, Co-chair of the Core Principles Group and Deputy Managing Director of the Monetary Authority of Singapore. "As highlighted in the paper, a proportionate approach achieves this through advocating risk-based supervision and supervisory expectations that are commensurate with a bank's risk profile and systemic importance."

The revised Core Principles represented the collective efforts between the Basel Committee and other banking supervisors from around the world, as well as the International Monetary Fund and the World Bank.

For information purposes, a document comparing the 2006 assessment methodology with the revised version has also been posted. This document is provided to facilitate a direct comparison between the two versions of assessment criteria.

The Basel Committee welcomes comments on the revised Core Principles. Comments should be submitted by Tuesday 20 March 2012 by email to: baselcommittee@bis.org. Alternatively, comments may be sent by post to the Secretariat of the Basel Committee on Banking Supervision, Bank for International Settlements, CH-4002 Basel, Switzerland. All comments may be published on the Bank for International Settlements's website unless a commenter specifically requests confidential treatment.


PDF: http://www.bis.org/publ/bcbs213.pdf (84 pages)

Tuesday, December 20, 2011

BCBS: Proposed regulatory capital disclosure requirements

Proposed regulatory capital disclosure requirements issued by the Basel Committee

December 19, 2011
http://www.bis.org/press/p111219a.htm

The Basel Committee on Banking Supervision today published for consultation a set of requirements for banks to disclose the composition of their regulatory capital. These aim to improve the transparency and comparability of banks' capital bases, including on a cross border basis.

During the financial crisis, market participants and supervisors attempted to undertake detailed assessments of the capital positions of banks and make cross jurisdictional comparisons. These efforts were often hampered by insufficiently detailed disclosure and a lack of consistency in reporting between banks and across jurisdictions. A lack of clarity on the quality of capital may have contributed to uncertainty during the financial crisis.

In addition to improving the quality and level of required capital, Basel III established certain high level disclosure requirements to improve transparency of regulatory capital and enhance market discipline. The Basel Committee noted that it would issue more detailed Pillar 3 disclosure requirements in 2011. Today's publication sets out these detailed requirements for consultation.

The Basel Committee welcomes comments on the proposed consultative document. Comments should be submitted by Friday 17 February 2012 by email to: baselcommittee@bis.org. Alternatively, comments may be sent by post to the Secretariat of the Basel Committee on Banking Supervision, Bank for International Settlements, CH-4002 Basel, Switzerland. All comments may be published on the Bank for International Settlements's website unless a commenter specifically requests confidential treatment.

Monday, December 19, 2011

Joint Forum: Consultative paper on "Principles for the supervision of financial conglomerates"

Consultative paper on "Principles for the supervision of financial conglomerates" released by the Joint Forum
December 19, 2011

The Joint Forum released today a consultative paper on Principles for the Supervision of Financial Conglomerates.

The proposed principles, which revise the Joint Forum's 1999 principles, provide national authorities, standard setters and supervisors with a set of internationally agreed principles that support consistent and effective supervision of financial conglomerates and in particular those financial conglomerates that are active across borders.

Mr Tony D'Aloisio, Chairman of the Joint Forum, stated that "these principles should, over time, help strengthen the global financial system through more effective and consistent oversight and supervision of financial conglomerates notably including risks arising from unregulated financial activities and entities".

The financial crisis that began in 2007 exposed situations in which regulatory requirements and oversight did not fully capture all the activities of financial conglomerates or fully consider the impact and cost that these activities may pose to the financial system. The principles issued today address complexities and gaps resulting from cross-sectoral activities with a scope of application based on a revised and broader definition of a financial conglomerate.

The proposed principles are organised into five sections and expand on and supplement the 1999 Principles in a number of ways:


Supervisory powers and authority

The principles are directed to both policy makers and supervisors highlighting the need for a clear legal framework that provides supervisors with the necessary powers, authority and resources to perform, with independence and in coordination with other supervisors, comprehensive group-wide supervision.


Supervisory responsibility

The principles reaffirm the importance of supervisory cooperation, coordination and information exchange. They clarify the importance of identifying a group-level supervisor whose responsibility is to focus on group-level supervision and the facilitation of coordination between relevant supervisors. New principles have been included which relate to the role and responsibilities of supervisors in implementing minimum prudential standards, monitoring and supervising activities of financial conglomerates and taking corrective action as appropriate.


Corporate governance

The principles reaffirm the importance of fit and proper principles and also provide, through a series of new principles, guidance for supervisors intended to ensure the existence of a robust corporate governance framework for financial conglomerates. These new principles relate to the structure of the financial conglomerate, the responsibilities of the board and senior management, the treatment of conflicts of interest and remuneration policy.


Capital adequacy and liquidity

The principles highlight the role of supervisors in assessing capital adequacy on a group basis, taking into account unregulated entities and activities and the risks they pose to regulated entities. They include new principles on group-wide capital management. The principles also provide guidance on internal capital planning processes that rely on sound board and management decisions, incorporate stressed scenario outcomes, and are subject to adequate internal controls. A new principle on liquidity assessment and management is also introduced - providing guidance for supervisors intended to ensure that financial conglomerates properly measure and manage liquidity risk.


Risk management

The principles set out the need for a financial conglomerate to have a comprehensive risk management framework to manage and report group-wide risk concentrations and intra-group transactions and exposures. Greater emphasis is placed on the financial conglomerate's ability to measure, manage and report all material risks to which it is exposed, including those stemming from unregulated entities and activities. The principles focus on group-wide risk management culture and appropriate tolerance levels; addressing risks associated with new business areas and outsourcing; group-wide stress-tests and scenario analyses for the prudent aggregation of risks; bringing off-balance sheet activities within the scope of group-wide supervision.


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The consultative report is available on the websites of the Bank for International Settlements (www.bis.org), IOSCO (www.iosco.org) and the IAIS (www.iaisweb.org). Comments on this consultative report should be submitted by Friday 16 March 2012 either by email to baselcommittee@bis.org or by post to the Secretariat of the Joint Forum (BCBS Secretariat), Bank for International Settlements, CH-4002 Basel, Switzerland. All comments may be published on the websites of the Bank for International Settlements, IOSCO (www.iosco.org) and the IAIS (www.iaisweb.org) unless a commenter specifically requests confidential treatment.

Link to this press release: http://www.bis.org/press/p111219b.htm
Link to the PDF: http://www.bis.org/publ/joint27.pdf

Friday, December 16, 2011

Bank Competition and Financial Stability: A General Equilibrium Exposition

Bank Competition and Financial Stability: A General Equilibrium Exposition. By Gianni De Nicolo' & Marcella Lucchetta
IMF Working Paper No. 11/295
Dec 16, 2011

Summary: We study versions of a general equilibrium banking model with moral hazard under either constant or increasing returns to scale of the intermediation technology used by banks to screen and/or monitor borrowers. If the intermediation technology exhibits increasing returns to scale, or it is relatively efficient, then perfect competition is optimal and supports the lowest feasible level of bank risk. Conversely, if the intermediation technology exhibits constant returns to scale, or is relatively inefficient, then imperfect competition and intermediate levels of bank risks are optimal. These results are empirically relevant and carry significant implications for financial policy.

Excerpts:
The theoretical literature offers contrasting results on the relationship between bank competition and financial stability. Yet these results arise from models with three important limitations: they are partial equilibrium set-ups; there is no special role for banks as institutions endowed with some comparative advantage in screening and/or monitoring borrowers; and bank risk is not determined jointly by the borrower and the bank. This paper contributes to overcome these limitations. A more general assessment of the relationship between bank competition, financial stability and welfare is not only important per se, but it is also essential to evaluate whether “granting” banks the ability of earning rents may reduce their risk-taking incentives.

We study the relationship between bank competition, financial stability and welfare in versions of a general equilibrium banking model with moral hazard, where the choice of “systematic” risk by either banks or firms is unobservable. In our set-up, risk-neutral agents specialize in production at the start date, choosing to become entrepreneurs, bankers, or depositors, and at a later date they make their financing and investment decisions. In this risk-neutral world, the welfare criterion is total surplus, defined as total output net of effort costs. We consider two versions of the model. In the first version, called “basic”, the bank is a coalition of entrepreneurs that are financed by depositors. In the second version, called “extended”, the “firm” is a coalition of entrepreneurs that is financed by the “bank”, which is a coalition of bankers financed by depositors. The firm, the bank and depositors can be also viewed as representing the business sector, the banking sector and the household sector.

In both versions, we consider two specifications of the bank’s screening and/or monitoring technology, called the “intermediation technology”. In the first specification, the intermediation technology exhibits constant returns to scale: the effort cost of screening and/or monitoring is proportional to the size of investment. In the second specification, this technology exhibits increasing returns to scale: the effort cost of screening and/or monitoring is independent of investment size. This second specification captures in a simple form the essential role of banks in economizing on monitoring and screening costs identified by a well-known literature briefly reviewed below.

In the basic model the bank chooses (systematic) risk, this choice is unobservable to outsiders, and there is competition in the deposit market only, indexed by the opportunity costs of depositors to invest in the bank. The results of this model differ strikingly depending on whether the intermediation technology exhibits constant or increasing returns to scale.  Under constant returns to scale, as competition in the deposit market increases, bank risk increases, bank capital declines, and welfare is maximized for some intermediate degree of competition. Thus, perfect deposit market competition is sub-optimal, as it entails excessive bank risk-taking and sub-optimally low levels of bank capitalization. However, allocating large shares of surplus (or rents) to banks is not optimal either, as it results in sub-optimally low levels of bank-risk taking and excessive bank capitalization.

When the intermediation technology exhibits increasing returns to scale, however, results are totally reversed: as competition increases, bank risk declines, capitalization increases, perfect deposit market competition is optimal, and the lowest feasible level of bank risk is best. This reversal is simply explained as follows. As competition increases, a ceteris paribus increase in the cost of funding induces the bank to take on more risk. But at the same time the increase in the supply of funds to the bank reduces the costs of the intermediation technology owing to increasing returns to scale: this offsets the negative impact of higher funding costs on bank’s expected profits, inducing the bank to take on less risk. This result is remarkable for two reasons: it is obtained under a standard assumption about the bank’s intermediation technology, and without modeling loan market competition. Thus, introducing loan market competition, as in Boyd and De Nicolo’ (2005), is not necessary—albeit it may be sufficient—to yield a positive relationship between bank competition and financial stability.

The extended model depicts the more realistic case in which there is competition in both lending and deposit markets, bank risk is jointly determined by borrowers and banks, and setting up the intermediation technology entails set-up costs. Here, bank competition is indexed by the opportunity costs of depositors to invest in the bank, and the opportunity costs of the firm to be financed by the bank. In this model, the relationship between bank competition, financial stability, and welfare becomes complex in a substantial economic sense, since double-sided competition determines how total surplus, whose size is endogenous, is shared by three sets of agents, rather than two, as in the basic model. When the degree of competition in lending and deposit markets differs, we illustrate several results suggestive of a rich comparative statics, which in some cases overturn simple conjectures on the relationship between bank risk, firm risk and capital.

Focusing on changes of competition in both loan and deposit markets, we obtain the following main results. If the bank intermediation technology is relatively inefficient, as defined as one that entails high monitoring and screening costs but relatively low set-up costs, then a level of competition lower than perfect competition is optimal, corresponding to an “intermediate” optimal levels of bank risk. However, if the bank intermediation technology is relatively efficient, defined as one that entails low monitoring and screening costs but relatively large set-up costs, then perfect competition is optimal, and the optimal level of bank risk turns out to be the lowest attainable. Notably, these results are independent of whether the intermediation technology exhibits constant or increasing returns to scale in screening and/or monitoring effort.

We discuss below the empirical relevance of some of our results. Furthermore, we believe these results throw a new light on the important policy question regarding the desirability of supporting bank profits, or banks’ “charter value”, with some “rents” in order to guarantee financial stability: what seems to matter are not necessarily rents per se, but what are their sources and how banks might exploit them.

Conclusions:
We studied versions of a general equilibrium banking model with moral hazard in which the bank’s intermediation technology exhibits either constant or increasing returns to scale. In the basic version of the model under constant returns of the intermediation technology we showed that as deposit market competition increases, bank risk increases, capitalization declines, and “intermediate” degreed of deposit market competition and bank risk are best..The result that the lowest attainable level of bank risk is not optimal echoes Allen and Gale’s (2004b) result that a positive degree of financial ”instability” can be a necessary condition for optimality. Yet, the efficiency of the intermediation technology matters. If this technology exhibits increasing returns to scale, then the implications of this model for bank risk, capitalization and welfare are totally reversed: as competition increases, bank risk declines, capitalization increases, perfect deposit market competition and the lowest attainable level of bank risk are optimal.

Subsequently, we studied the more realistic version of the model where there is competition in both lending and deposit markets and bank risk is determined jointly by the bank and the firm. The key results of the extended model pertain to the role of the efficiency of the intermediation technology in relationship to the level of competition in both lending and deposit markets. We showed that independently of whether the intermediation technology exhibits constant or increasing returns, perfect competition and the lowest attainable level of bank risk are optimal if the bank intermediation technology is relatively efficient. When such technology is relatively inefficient, however, perfect competition is suboptimal, and intermediates levels of competition and bank risk are best.

The theoretical results or our study are empirically relevant. Several studies present evidence consistent with a positive relationship between bank competition and financial stability.  Jayaratne and Strahan (1998) find that branch deregulation resulted in a sharp decrease in loan losses. Restrictions on banks’ entry and activity have been found to be negatively associated with some measures of bank stability by Barth, Caprio and Levine (2004), Beck (2006a and 2006b), and Schaeck et al. (2009). Furthermore, Cetorelli and Gambera (2001) and Cetorelli and Strahan (2006) find that banks with market power erect an important financial barrier to entry to the detriment of the entrepreneurial sector of the economy, leading to long-term declines in a country’s growth prospect. Lastly, Corbae and D’Erasmo (2011) present a detailed quantitative study of the U.S. banking industry based on a dynamic calibrated version of Boyd and De Nicolo’ (2005) model, finding evidence of a positive association between competition and financial stability. It is apparent that these results are consistent with the predictions of the basic model with increasing returns, and those of the extended model in which banks use relatively efficient intermediation technologies.

Under a policy viewpoint, we believe that our results provide an important insight with regard to the question of whether supporting bank profits with some rents—or, in a dynamic context, supporting banks’ charter values—is a desirable public policy option. A substantial portion of the literature and the policy debate maintains that preserving bank profitability through rents enhancing bank profitability—or banks’ charter values—may be desirable, as it induces banks to take on less risk. As we have shown, however, this argument ignores how these rents are generated, or how they may be eventually used once granted.

Our results suggest that supporting bank profitability (or charter values) with rents that are independent of bank’s actions aimed at improving efficiency may be unwarranted. If rents accrue independently of banks’ efforts to adopt more efficient intermediation technologies and, more generally, to provide better intermediation services, then rents are suboptimal and do not guarantee banking system stability. In this light, competitive pressures may be an effective incentive for banks to adopt more efficient intermediation technologies. In a competitive environment, rents would need to be earned by investing in technologies that provide banks a comparative advantage in providing intermediation services, rather than been derived from some market power enjoyed “freely”.
Source: http://www.imf.org/external/pubs/cat/longres.aspx?sk=25439.0

Saturday, December 3, 2011

BCBS: The internal audit function in banks - consultative document

The internal audit function in banks - consultative document
The Basel Committee on Banking Supervision, December 2, 2011

The Basel Committee on Banking Supervision is issuing this revised supervisory guidance for assessing the effectiveness of the internal audit function in banks, which forms part of the Committee's ongoing efforts to address bank supervisory issues and enhance supervision through guidance that encourages sound practices within banks. The document replaces the 2001 document Internal audit in banks and the supervisor's relationship with auditors. It takes into account developments in supervisory practices and in banking organisations and incorporates lessons drawn from the recent financial crisis.

The document builds on the Committee's Principles for Enhancing Corporate Governance [http://www.bis.org/publ/bcbs176.htm] which require banks to have an internal audit function with sufficient authority, stature, independence, resources and access to the board of directors. Independent, competent and qualified internal auditors are vital to sound corporate governance.

As a strong internal control framework including an independent, effective internal audit function is part of sound corporate governance. Banking supervisors must be satisfied as to the effectiveness of a bank's internal audit function, that effective policies and practices are followed and that management takes appropriate corrective action in response to internal control weaknesses identified by internal auditors. An effective internal audit function provides vital assurance to a bank's board of directors and senior management (and bank supervisors) as to the quality of the bank's internal control system. In doing so, the function helps reduce the risk of loss and reputational damage to the bank.

The document is based on 20 principles, organised in three sections: A) Supervisory expectations relevant to the internal audit function, B) The relationship of the supervisory authority with the internal audit function, and C) Supervisory assessment of the internal audit function. This approach seeks to promote a strong internal audit function within banking organisations and addresses supervisory expectations for the internal audit function and the supervisory assessment of that function. It also encourages bank internal auditors to comply with and to contribute to the development of national and international professional standards, such as those issued by The Institute of Internal Auditors, and it promotes due consideration of prudential issues in the development of internal audit standards and practices. An annex to the consultative document details responsiblities of a bank's audit committee.

The Basel Committee welcomes comments on the proposed consultative document. Comments should be submitted by Friday 2 March 2012 by email to: baselcommittee@bis.org. Alternatively, comments may be sent by post to the Secretariat of the Basel Committee on Banking Supervision, Bank for International Settlements, CH-4002 Basel, Switzerland. All comments may be published on the Bank for International Settlements's website unless a commenter specifically requests confidential treatment.

You can download the PDF from here: http://www.bis.org/publ/bcbs210.htm


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Press release: Banks' internal audit function - consultative paper issued by the Basel Committee
December 2, 2011
http://www.bis.org/press/p111202.htm

The Basel Committee on Banking Supervision issued today a consultative paper on The internal audit function in banks.

The objective of the proposed guidance, which revises the Committee's 2001 document Internal Audit in Banks and the Supervisor's Relationship with Auditors, is to help supervisors assess the effectiveness of a bank's internal audit function. The guidance reflects developments in supervisory and banking practices and incorporates lessons drawn from the financial crisis.

The proposed guidance is built around a set of principles that seek to promote a strong internal audit function within banks. The principles cover supervisory expectations related to the internal audit function as well as the supervisory assessment of that function. The principles also review the relationship between a supervisory authority and a bank's internal audit function.

The Basel Committee welcomes comments on the proposed consultative documents. Comments should be submitted by Friday, 2 March 2012 by email to: baselcommittee@bis.org. Alternatively, comments may be sent by post to the Secretariat of the Basel Committee on Banking Supervision, Bank for International Settlements, CH-4002 Basel, Switzerland. All comments may be published on the Bank for International Settlements's website unless a commenter specifically requests confidential treatment.

The Committee is now in the process of developing supervisory guidance on external audit. This guidance will build on existing Basel Committee guidance on this topic, including The relationship between bank supervisors and external auditors (2002) and External audit quality and banking supervision (2008). The Committee expects to publish a consultative version of its external audit guidance in 2012.

Wednesday, November 30, 2011

Over 900 Biotechnology Medicines in Development, Targeting More than 100 Diseases

Over 900 Biotechnology Medicines in Development, Targeting More than 100 Diseases
September 14, 2011
http://www.innovation.org/index.cfm/FutureOfInnovation/NewMedicinesinDevelopment/Biotechnology_Medicines

Biotechnology has opened the door to the discovery and development of new types of human therapeutics. Advancements in both cellular and molecular biology have allowed scientists to identify and develop a host of new products. These cutting-edge medicines provide significant clinical benefits, and in many cases, address therapeutic categories where no effective treatment previously existed.

Innovative, targeted therapies offer enormous potential to address unmet medical needs of patients with cancer, HIV/AIDS, and many other serious diseases. These medicines also hold the potential to help us meet the challenge of rising healthcare costs by avoiding treatment complications and making sure each patient gets the most effective care possible.

Approved biotechnology medicines already treat or help prevent heart attacks, stroke, multiple sclerosis, leukemia, hepatitis, congestive heart failure, lymphoma, kidney cancer, cystic fibrosis, and other diseases. These medicines use many different approaches to treat disease as do medicines currently in the pipeline.

America's biopharmaceutical research companies have 901 biotechnology medicines and vaccines in development to target more than 100 debilitating and life- threatening diseases, such as cancer, arthritis and diabetes, according to a new report [http://www.phrma.org/sites/default/files/1776/biotech2011.pdf] by the Pharmaceutical Research and Manufacturers of America (PhRMA). The medicines in development—all in either clinical trials or under Food and Drug Administration review—include 353 for cancer and related conditions, 187 for infectious diseases, 69 for autoimmune diseases and 59 for cardiovascular diseases.

The biotechnology medicines now in development make use of these and other state-of- the-art approaches. For example:

•A genetically-modified virus-based vaccine to treat melanoma.
•A monoclonal antibody for the treatment of cancer and asthma.
•An antisense medicine for the treatment of cancer.
•A recombinant fusion protein to treat age-related macular degeneration.


SELECTED BIOTECHNOLOGY MEDICINES IN DEVELOPMENT

Autoimmune Diseases: Autoimmunity is the underlying cause of more than 100 serious, chronic illnesses, targeting women 75 percent of the time. Autoimmune diseases have been cited in the top 10 leading causes of all deaths among U.S. women age 65 and younger, representing the fourth largest cause of disability among women in the United States.


Blood Disorders: Hemophilia affects 1 in 5,000 male births. About 400 babies are born with hemophilia each year. Currently, the number of people with hemophilia in the United States is estimated to be about 20,000, based on expected births and deaths since 1994.


Sickle cell disease is an inherited disease that affects more than 80,000 people in the United States, 98 percent of whom are of African descent.


Von Willebrand disease, the most common inherited bleeding condition, affects males and females about equally and is present in up to 1 percent of the U.S. population.


Cancer: Cancer is the second leading cause of death by disease in the United States—1 of every 4 deaths—exceeded only by heart disease. This year nearly 1.6 million new cancer cases will be diagnosed, 78 percent of which will be for individuals ages 55 and older.


Cardiovascular Diseases (CVD): CVD claims more lives each year than cancer, chronic lower respiratory diseases, and accidents combined. More than 82 million American adults—greater than one in three—had one or more types of CVD. Of that total, 40.4 million were estimated to be age 60 and older.


Diabetes: In the United States, 25.8 million people, or 8.3 percent of the population, have diabetes. An estimated 18.8 million have been diagnosed, but 7 million people are not aware that they have the disease. Another 79 million have pre-diabetes. Diabetes is the seventh leading cause of death in the United States.


Genetic Disorders: There are more than 6,000 known genetic disorders. Approximately 4 million babies are born each year, and about 3 percent-4 percent will be born with a genetic disease or major birth defect. More than 20 percent of infant deaths are caused by birth defects or genetic conditions (e.g., congenital heart defects, abnormalities of the nervous system, or chromosomal abnormalities).


Alzheimer’s Disease: In 2010 there were an estimated 454,000 new cases of Alzheimer’s disease. In 2008, Alzheimer’s was reported as the underlying cause of death for 82,476 people. Almost two-thirds of all Americans living with Alzheimer’s are women.


Parkinson's Disease: This disease has been reported to affect approximately 1 percent of Americans over age 50, but unrecognized early symptoms of the disease may be present in as many as 10 percent of those over age 60. Parkinson's disease is more prevalent in men than in women by a ratio of three to two.

Asthma: An estimated 39.9 million Americans have been diagnosed with asthma by a health professional within their lifetime. Females traditionally have consistently higher rates of asthma than males. African Americans are also more likely to be diagnosed with asthma over their lifetime.


Skin Diseases: More than 100 million Americans—one-third of the U.S. population—are afflicted with skin diseases.

Tuesday, November 22, 2011

Has the global banking system become more fragile over time?

Has the global banking system become more fragile over time? By Deniz Anginer & Asli Demirguc-Kunt
http://www-wds.worldbank.org/external/default/WDSContentServer/WDSP/IB/2011/11/08/000158349_20111108124433/Rendered/PDF/WPS5849.pdf

Abstract: This paper examines time-series and cross-country variations in default risk co-dependence in the global banking system. The authors construct a default risk measure for all publicly traded banks using the Merton contingent claim model, and examine the evolution of the correlation structure of default risk for more than 1,800 banks in more than 60 countries. They find that there has been a significant increase in default risk co-dependence over the three-year period leading to the financial crisis. They also find that countries that are more integrated, and that have liberalized financial systems and weak banking supervision, have higher co-dependence in their banking sector. The results support an increase in scope for international supervisory co-operation, as well as capital charges for "too-connected-to-fail" institutions that can impose significant externalities.

Excerpts:
Introduction

The last decade has seen a tremendous transformation in the global financial sector. Globalization, innovations in communications technology and de-regulation have led to significant growth of financial institutions around the world. These trends had positive economic benefits and have led to increased productivity, increased capital flows, lower borrowing costs, and better price discovery and risk diversification. But the same trends have also led to greater linkages across financial institutions around the world as well as an increase in exposure of these institutions to common sources of risk. The recent financial crisis has demonstrated that financial institutions around the world are highly inter-connected and that vulnerabilities in one market can easily spread to other markets outside of national boundaries.

In this paper we examine whether the global trends described above have led to an increase in co-dependence in default risk of commercial banks around the world. The growing expansion of financial institutions beyond national boundaries over the past decade has resulted in these institutions competing in increasingly similar markets, exposing them to common sources of market and credit risk. During the same period, rapid development of new financial instruments has created new channels of inter-dependency across these institutions. Both increased interconnections and common exposure to risk makes the banking sector more vulnerable to economic, liquidity and information shocks. There is substantial theoretical literature that models the various channels through which such shocks can culminate in a systemic banking crisis (see for instance Bhattacharya and Gale 1987, Allen and Gale 2000, Diamond and Rajan 2005; and focusing on the recent crisis, Brunnermeier 2009, Danielsson, Shin, and Zigrand 2009, Battiston et al. 2009 among others.) To examine whether the global banking sector has become more interdependent and more fragile to shocks, we construct a default risk measure for all publicly traded banks using the Merton (1974) contingent claim model. We compute weekly time series of default probabilities for over 1,800 banks in over 60 countries and examine the evolution of the correlation structure of default risk over the 1998 – 2010 time period.

Our empirical findings show that there has been a substantial increase in co-dependence in default risk of publicly traded banks starting around the beginning of 2004 leading up to the global financial crisis starting in the summer of 2007. Although we observe an overall trend towards convergence in default risk globally, this trend has been much stronger for North American and European banks. We also find that increase in co-dependence has been higher for banks that are larger (with greater than 50 billion in assets). We also examine variation in co-dependence across countries. We find that countries that are more integrated, have liberalized financial systems and weak banking supervision have higher co-dependence in their banking sector.

Increased co-dependence in credit risk in the banking sector has important implications for capital regulations. In the aftermath of the sub-prime crisis of 2007/08, there has been renewed interest in macro-prudential regulation and supervision of the financial system. There has also been a growing consensus to adjust capital requirements to better reflect an individual bank‟s contribution to the risk of the financial system as a whole (Brunnermeier, Crockett, Goodhart, Persaud, and Shin 2009, Financial Stability Forum 2009a, 2009b). Recently a number of papers have tried to measure and quantify systemic risk inherent in the global banking sector. Adrian and Brunnermeier (2009), Huang, Zhou, and Zhou (2009), Chan-Lau and Gravelle (2005), Avesani et al. (2006), and Elsinger and Lehar (2008), use a portfolio credit risk approach to compute the contribution of an individual bank to the risk of a portfolio of banks. Our paper is related to this strand of literature, but our focus is not on quantifying systemic risk of large financial institutions but rather to examine time series trends for a large cross-section of banks. A number of papers have examined the correlation structure of equity returns of a subsample of banks. De Nicolo and Kwast (2002) find rising correlations between bank stock returns in the U.S. from 1988 and 1999. Schuler (2002) find similar results for Europe using a sample from 1980 to 2001. Hawkesby, Marsh and Stevens (2005) analyze co-movements in equity returns for a set of US and European large complex financial institutions using several statistical techniques and find a high degree of commonality. This paper is also related to the literature that studies contagion in financial markets (see among others Forbes and Rigobon 2002, Kee-Hong Bae and Stulz 2003) and also the literature that examines the impact of globalization on convergence of asset prices (Bekeart and Wang 2009, Longin and Solnik 1995, Bekaert and Harvey 2000, and Bekaert, Hodrick and Zhang 2009).

This paper differs from the existing literature in three respects. First, our empirical analyses cast a wider net than the existing literature which focuses only in a particular region or a country and covers a shorter time period. Second we examine time series trends in co-dependence and test for structural changes over time. Finally, we examine cross-country differences in co-dependence and link the differences to measures of financial and economic openness and regulatory frameworks in different countries.

Policymakers may be able to draw important implications from our analysis. Co-dependence in bank default risk has important consequences for systemic stability. We find increasing co-dependence in banks located in different national jurisdictions. Although we do find that strong banking supervision tends to reduce co-dependence in a given country, our results call for banking supervisory co-operation at a global level. This is especially true for larger banks which have grown more interconnected over the past decade.

President Obama can't win by running a constructive campaign, and he won't be able to govern if he does win a second term

The Hillary Moment. By Patrick H Caddell & Douglas E Schoen
President Obama can't win by running a constructive campaign, and he won't be able to govern if he does win a second term.
http://online.wsj.com/article/SB10001424052970203611404577041950781477944.html

When Harry Truman and Lyndon Johnson accepted the reality that they could not effectively govern the nation if they sought re-election to the White House, both men took the moral high ground and decided against running for a new term as president. President Obama is facing a similar reality—and he must reach the same conclusion.

He should abandon his candidacy for re-election in favor of a clear alternative, one capable not only of saving the Democratic Party, but more important, of governing effectively and in a way that preserves the most important of the president's accomplishments. He should step aside for the one candidate who would become, by acclamation, the nominee of the Democratic Party: Secretary of State Hillary Clinton.

Never before has there been such an obvious potential successor—one who has been a loyal and effective member of the president's administration, who has the stature to take on the office, and who is the only leader capable of uniting the country around a bipartisan economic and foreign policy.

Certainly, Mr. Obama could still win re-election in 2012. Even with his all-time low job approval ratings (and even worse ratings on handling the economy) the president could eke out a victory in November. But the kind of campaign required for the president's political survival would make it almost impossible for him to govern—not only during the campaign, but throughout a second term.

Put simply, it seems that the White House has concluded that if the president cannot run on his record, he will need to wage the most negative campaign in history to stand any chance. With his job approval ratings below 45% overall and below 40% on the economy, the president cannot affirmatively make the case that voters are better off now than they were four years ago. He—like everyone else—knows that they are worse off.

President Obama is now neck and neck with a generic Republican challenger in the latest Real Clear Politics 2012 General Election Average (43.8%-43.%). Meanwhile, voters disapprove of the president's performance 49%-41% in the most recent Gallup survey, and 63% of voters disapprove of his handling of the economy, according to the most recent CNN/ORC poll.

Consequently, he has to make the case that the Republicans, who have garnered even lower ratings in the polls for their unwillingness to compromise and settle for gridlock, represent a more risky and dangerous choice than the current administration—an argument he's clearly begun to articulate.

One year ago in these pages, we warned that if President Obama continued down his overly partisan road, the nation would be "guaranteed two years of political gridlock at a time when we can ill afford it." The result has been exactly as we predicted: stalemate in Washington, fights over the debt ceiling, an inability to tackle the debt and deficit, and paralysis exacerbating market turmoil and economic decline.

If President Obama were to withdraw, he would put great pressure on the Republicans to come to the table and negotiate—especially if the president singularly focused in the way we have suggested on the economy, job creation, and debt and deficit reduction. By taking himself out of the campaign, he would change the dynamic from who is more to blame—George W. Bush or Barack Obama?—to a more constructive dialogue about our nation's future.

Even though Mrs. Clinton has expressed no interest in running, and we have no information to suggest that she is running any sort of stealth campaign, it is clear that she commands majority support throughout the country. A CNN/ORC poll released in late September had Mrs. Clinton's approval rating at an all-time high of 69%—even better than when she was the nation's first lady. Meanwhile, a Time Magazine poll shows that Mrs. Clinton is favored over former Massachusetts Gov. Mitt Romney by 17 points (55%-38%), and Texas Gov. Rick Perry by 26 points (58%-32%).

But this is about more than electoral politics. Not only is Mrs. Clinton better positioned to win in 2012 than Mr. Obama, but she is better positioned to govern if she does. Given her strong public support, she has the ability to step above partisan politics, reach out to Republicans, change the dialogue, and break the gridlock in Washington.

President Bill Clinton reached a historic agreement with the Republicans in 1997 that led to a balanced budget. Were Mrs. Clinton to become the Democratic nominee, her argument would almost certainly have to be about reconciliation and about an overarching deal to rein in the federal deficit. She will understand implicitly the need to draw up a bipartisan plan with elements similar to her husband's in the mid-to-late '90s—entitlement reform, reform of the Defense Department, reining in spending, all the while working to preserve the country's social safety net.

Having unique experience in government as first lady, senator and now as Secretary of State, Mrs. Clinton is more qualified than any presidential candidate in recent memory, including her husband. Her election would arguably be as historic an event as the election of President Obama in 2008.

By going down the re-election road and into partisan mode, the president has effectively guaranteed that the remainder of his term will be marred by the resentment and division that have eroded our national identity, common purpose, and most of all, our economic strength. If he continues on this course it is certain that the 2012 campaign will exacerbate the divisions in our country and weaken our national identity to such a degree that the scorched-earth campaign that President George W. Bush ran in the 2002 midterms and the 2004 presidential election will pale in comparison.

We write as patriots and Democrats—concerned about the fate of our party and, most of all, our country. We do not write as people who have been in contact with Mrs. Clinton or her political operation. Nor would we expect to be directly involved in any Clinton campaign.

If President Obama is not willing to seize the moral high ground and step aside, then the two Democratic leaders in Congress, Sen. Harry Reid and Rep. Nancy Pelosi, must urge the president not to seek re-election—for the good of the party and most of all for the good of the country. And they must present the only clear alternative—Hillary Clinton.

Mr. Caddell served as a pollster for President Jimmy Carter. Mr. Schoen, who served as a pollster for President Bill Clinton, is author of "Hopelessly Divided: The New Crisis in American Politics and What It Means for 2012 and Beyond," forthcoming from Rowman and Littlefield.

Thursday, November 17, 2011

How Coca-Cola Manages 90 Emerging Markets

How Coca-Cola Manages 90 Emerging Markets, by William J. Holstein
The world’s largest beverage company has delegated major decision making to individual markets, but it maintains its global brand strategy through collaborative practices.
November 7, 2011
http://www.strategy-business.com/article/00093?pg=all

Ahmet C. Bozer, president of the Coca-Cola Company’s Eurasia and Africa Group, has spent his career demonstrating how a large international company can build a strategy and structure itself to compete in emerging markets. Coca-Cola is one of the most globally active international companies, deriving 80 percent of its sales from outside the U.S., and it is therefore one of the most experienced in tackling emerging markets, including Egypt and Pakistan, where political tension renders the business environment uncertain and Coca-Cola’s strategy has proven resilient.

Bozer, who was born and raised in Turkey, has worked for Coca-Cola since 1990 in various capacities, including operations and finance, as well as leading the Coca-Cola bottling company in Turkey. He is currently based in Istanbul, where he oversees 90 markets, ranging geographically from India and South Asia through the Middle East and all of Africa, across Turkey and the Caucasus into the countries of the former Soviet Union. This territory accounted for 16 percent of Coke’s sales last year, for a retail value of US$10 billion, and Bozer expects that number to grow rapidly during the next decade. Like four other regional presidents, Bozer reports directly to Coca-Cola Chairman and CEO Muhtar Kent in Atlanta, Ga. Bozer sat down with us at the Coca-Cola offices in New York.

S+B: Your late CEO Roberto Goizueta charged the company to “think global, act local” in its strategy. How do you accomplish this?

BOZER: I wish it was as easy as repeating the slogan. The key for international companies is finding the right mix of global and local in their operations. The Coca-Cola brand is global, but it must be locally relevant. We may be giving the same happiness message, the same brand architecture may be communicated, but it has to be done differently in each country.

S+B: Your structure has strong regional managers such as yourself, but headquarters in Atlanta maintains global responsibility for sales, finance, and marketing — and for specific product lines like water or juices. How do you manage this?

BOZER: We are a franchise system. Our bottlers are primarily local. In Turkey, for example, we have a Turkish bottler. So the effectiveness of our company depends on the effectiveness of our relationships with the bottlers and our brands. To manage franchise relationships, you have to have a geographic orientation. Therefore our organization is primarily geographic. Globally, we have five operating groups: North America, Latin America, Europe, Eurasia and Africa, and Pacific.

At the same time, the juice business requires a different organizational structure than the sparkling beverages business. The raw material costs are high and fluctuate a lot, and there are opportunities to innovate more quickly; we may introduce four or five new variants of a juice in a given year. Thus, there is a matrix. A functional group in Atlanta is in charge of juices worldwide, but they work through the geographic organizations.

We are still evolving in finding the best local and global combination that works for us. When it comes to franchise relations with the bottlers, that is local. We have to make decisions in the local context with the right speed. Quality standards are both local (we adhere to all local government safety regulations) and global (we have our own global, rigorous, quality control standards). But we take advantage of our global properties and collaborate as a global team, bringing the best resources to bear on a specific issue.

S+B: How do you manage disagreements between the field and headquarters?
 
BOZER: We have been working on it for many years. We all understand that nothing is as black-and-white as we’d like. Let’s say I’m hiring a function leader. I am the ultimate decision maker, but I know that any function leader must operate as part of the global team. He or she must be able to collaborate globally, and the global organization has to be comfortable with that candidate. This is where maturity is important. We emphasize a collaborative process because it makes the decision better. But our culture is purely focused on making the right choice, rather than defining my turf versus your turf. That allows us to make these decisions quickly.

S+B: How do you manage the dramatic variations in cultures and politics among your 90 markets?
 
BOZER: It’s not as difficult as it might seem. I have six business units, based in South Africa, Kenya, Turkey, Russia, India, and Dubai. And I have a functional team in Istanbul with finance, marketing, and strategy capabilities. The functional team works as part of the global team to come up with strategic plans for each market. We share those with the business units, and we expect them to enrich [the plans] and add value to them by adapting them to their own needs.
Russia might say, “Well, iced tea is a big category here, so here’s how we are going to compete [with that product].” There is a clear thread of consistency among all the regions; we stay connected to the global team in Atlanta through the finance and marketing communities.

S+B: What do you see as the greatest opportunity in your 90 markets?
 
BOZER: If you project the demographics of today into 2020, you will find that about half of the favorable changes will be located in Eurasia and Africa: new entrants into the middle class, an increase in the number of teenagers, urbanization. A few of these countries have very high per capita consumption of our beverages. South Africa is about 250 drinks per year per person, which is above the global average. Turkey is higher than 150. But when you take those relatively well-developed markets out and look at India, Pakistan, sub-Saharan Africa, Russia, and central Asia, those markets have very low per capita consumption — for the whole industry. In India, just 4 or 5 percent of the beverages consumed are packaged. People drink tap water, tea, and dairy; vendors squeeze juice on the street. When people start having a bit more money and a middle class emerges, demand for packaged beverages will increase.
In that context, our strategy is not very complicated. We know how to grow “Brand Coke.” It’s about locally relevant brand building with consumers — the right pricing and packaging, with small packs, large packs, or take-home packs. We place new coolers in the market and invest in people, putting “feet on the street,” and activate outlets one by one. At the same time, there is a flourishing juice business and a flourishing water business, and in some of our markets, teas and energy drinks are developing.

S+B: How do you make yourself “locally relevant?”
 
BOZER: We have very strong consumer marketing teams. We invest a lot in understanding the psyche of the local consumer. In Egypt, during the Arab Spring [uprisings], our marketing people were able to tap into the psyche of the public — especially the teenagers. We understood that despite the uncertainty they were going through, they wanted to create a bright future. Our brand promise is happiness and optimism. Our team quickly put together some excellent consumer communication with the message that if everybody came together, the Egyptian people could build a better future. That message was delivered in a wonderful ad in which the skies over Tahrir Square in Cairo are quite overcast and dark, but people get together and throw ropes to the clouds and start pulling the ropes. The clouds open up and the sun appears. That type of communication resonated extremely well. We tapped into the feelings and emotions that were most relevant to the Egyptian people.
We try to do this kind of thing everywhere. We have good marketers in each country who have access into consumer insight data, and who work with very good agencies, while at the same time working with robust global processes.

S+B: Doesn’t political and social upheaval create a problem for you?
 
BOZER: Not really. I was in Pakistan recently. When you read the papers and watch television, you hear about terrorism, earthquakes, floods, and sectarian violence. It’s all negative. But we’ve been there for more than 50 years and we have not experienced any problems in running our business. In fact, our business is thriving there. Over the past four years, we have been growing extremely well. The same holds true for the Arab Spring countries.
In our external environment, we may have many headwinds, but we sell simple moments of pleasure that get consumed a million times a day, and that business continues to be vibrant. It’s a very simple product. Yes, growth slows when you go through major political changes, but things settle down and life goes back to normal. Then you start building from there.

S+B: You have a tremendous variation in the type and sophistication of bottlers you work with, ranging from a giant like SABMiller in South Africa to mom-and-pop-type bottlers in other markets. How do you adapt to their different styles and capabilities?
 
BOZER: This is the bread and butter of our business: being effective with our partnerships. Our partners may be multi-country bottlers, or they may operate within a single country. They may be public or private. In some countries we work with multiple bottlers. We have all kinds of relationships.

With each one, we first establish a shared vision. We have a one-page road map that portrays a very clear destination for 2020, a clear framework about our strategic pillars and metrics. That road map is actually prepared with our bottlers. It guides all our business planning.
Then it comes to capability. Does the bottler have the capability to execute these plans with us?

At the end of the day, we’re trying to create value for the overall system of the Coca-Cola Company and its bottlers, not just ourselves. Otherwise, the system won’t be sustainable in terms of our results.

One of the best examples is our bottler in Turkey, which I used to run. The bottler was built by the Coca-Cola Company and sold to a local shareholder who now owns a majority. It’s a public company with a market value of more than €2.5 billion (US$3.5 billion). It has great alignment with the Coca-Cola Company. It is now 10 times the size of when it started in 1994. This model really works.

S+B: How do you support your partners? Do you train them or lend them money?
 
BOZER: It depends on the needs of the bottler. The bottlers that operate in multiple countries tend not to need our help. But there might be some emerging area of knowledge — for example, about how to do better category management, in which case we have centers of excellence that the bottlers can access. We have websites where they can download best practices or get our help in building their capabilities. We sometimes support bottlers financially as well, if we are aligned on a fairly aggressive growth plan and want to invest in marketing to build the brands with more intensity. And let’s not forget, we own about 30 percent of our bottlers around the world.

S+B: How do you allow a local bottler and local business unit to differentiate the mix of products they offer?
 
BOZER: We don’t work in a way whereby every time a business unit wants to launch a product, they have to get my approval. Instead, we share the strategic framework. We have strategy discussions and business plan discussions, and we have other guidelines and rules.
For example, it is understood within the group that I want to know your top three priorities. If you want to launch a new product, but you need to take away [resources] from one of those core priorities to launch that product, then you shouldn’t do it. And if your bottler doesn’t have the capabilities to handle that product, you shouldn’t launch it. But if you can figure out how to do all of that in a way that still funds your core, if you have followed the right process, and if you are in the right marketplace with the right capabilities on the marketing side, then by all means go ahead.

We have Maaza juice in India, for example. The local team wanted to launch a Maaza milkshake, which is a wonderful mango dairy product. Dairy is a very relevant category in India, and Maaza milkshakes were received extremely well by consumers. My group function heads and the global function heads contributed to this by supporting the local team. This is not a bureaucratic approval–based system. Of course, there are approvals, but once the strategy and business plan are approved, local teams can execute.

S+B: Have you had much reverse innovation, in which a local group comes up with an idea that you take to other markets?
 
BOZER: Yes. One innovation that came out of India is the solar-powered coolers. We’re looking to expand that to other markets. There’s great engineering talent in India. Another product that shows promise is Minute Maid’s Pulpy, an orange juice with pulp that did extremely well in China. We expanded it into many countries. We have also taken communications elsewhere. Turkey, for example, had a very successful Ramadan communication to celebrate the holy month in Muslim countries. We took that to other Muslim countries in our group.

S+B: How do you recruit the talent you need?
 
BOZER: We look for critical experiences and functional competencies. And we ask about candidates: Do they represent the values of the company? We’re about optimism. A pessimistic person wouldn’t work out.
The nationality and gender don’t really matter. On my group leadership team of 18 people, I have 12 nationalities represented, including individuals from Zimbabwe, Scotland, the United States, Turkey, South Africa, India, Croatia, and elsewhere.
The most important competency is leadership. It takes very strong leadership to be able to explain the environment, establish a vision, and rally the troops. Command and control, in most cases, does not work. If you try to control everything, the system won’t work.

CGFS: The macrofinancial implications of alternative configurations for access to central counterparties in OTC derivatives markets

November 17, 2011
The Committee on the Global Financial System (CGFS) has today released a report on The macrofinancial implications of alternative configurations for access to central counterparties in OTC derivatives markets. It was prepared by a study group chaired by Timothy Lane of the Bank of Canada.

Various alternative access arrangements are under consideration for the central clearing of OTC derivatives trades. Several jurisdictions are exploring the establishment of domestic central counterparties (CCPs) and the possible benefits of establishing links between them.

The conditions under which market participants obtain access to central clearing could have important implications for financial stability and efficiency. The report concludes that:
  • expanding direct access to CCPs may reduce the concentration of risk in the largest global dealers. As direct access is broadened, it is essential that CCPs' risk management procedures be adapted appropriately to ensure their continued effectiveness;
  • both large global and smaller regional or domestic CCPs will probably play a role in meeting G20 commitments. In both cases, developing and adopting international standards will be essential to avoid regulatory arbitrage and promote effective cross-border monitoring of infrastructure and participants; and
  • CCPs and authorities should consider enhancements where needed to strengthen the safety and efficiency of indirect clearing that comply with international standards. Effective segregation, as well as portability of positions and collateral belonging to a direct clearer's clients, will be needed to realise the benefits of systemic risk reduction.
CGFS Chairman Mark Carney, in presenting the report, said that it "provides relevant and timely input to international initiatives related to CCP access arrangements and configurations."

Tuesday, November 15, 2011

Algeria: structural and other reasons for regime stability

Kal writes:
Richard Phelps argues that Algeria has not seen a popular uprising this year on broad structural lines (‘An Algerian Exception?‘ CMEC Blog): ‘Algerian regime does not have an identifiable leader with whom political power truly lies’.

[...]

And the government has focused its strategy toward them based on this reality and avoided the provocative showings of ‘symbolic’ violence that gave fuel to protest movements in Tunisia and Libya and Syria and Egypt (part of this is owed to the government’s relationships with the private media as well). Official and unofficial media has not covered demonstrations extensively to the extent that protesters in one city would necessarily be aware of those in another. The massive showing of ‘force’ at the February demonstrations — which were quite small, using barely a few thousand people if that — was a show of bodies more than anything else, and while protesters were manhandled and some beaten few or none were shot or killed in the way their counterparts elsewhere in the Arab world were. The government issued reforms, after long deliberations, and statements of intent to reform on a range of issues. It acted quickly to buy off organizers and potential participants or to contain and frustrate them rather than making public ‘examples’ of children or attempting to use overwhelming and direct force. The ‘crackdowns’ on protesters in Algeria this year were in large measure qualitatively different from those elsewhere, as were the demonstrations themselves.

Structurally it is important to understand that Algeria’s politics do operate in a diffuse manner, that power is spread through regional and professional and bureaucratic networks which often compete with one another but are also sometimes dependent on one another. (One might quibble with any comparison of the Algerian presidency to the power of any single office in Lebanon or to even its strongest Lebanese za’im; the perception and reality of the president’s power in Algeria is an interesting thing to follow and to try an gage at any one time but the presidency has frequently overwhelmed the military under Bouteflika.) The business class and the military officers and the technocrats and local notables intersect and it would be difficult to ‘purge’ the government as the Tunisians are now trying to do and it would also be difficult to make removing Bouteflika in a coup appear to Algerians as a symbolic act with and the armed forces a trusted ‘care taker’ of some transition process (let alone a ‘savior’) as the Egyptian Army did with Mubarak, since Algerians are generally more cynical and probably distrust their military and opposition more than their cousins in the rest of the region. It is also important to understand the field in which these various networks and factions (‘clans’) interact, overlap and struggle; it involves a great deal of both external and internal opacity and risk. There are enormous uncertainties involved. Longtime Algeria hand John Entelis wrote in September that change of some kind would wind up taking place in Algeria, if only so that the country’s elite could keep its own interests, and that  ’[w]hether this process develops peacefully or violently is ultimately in the hands of le pouvoir’.


But structural reasons are not the only ones Algeria has not seen an uprising. The Algerian military and political class has dealt with uprisings and transitions before and probably had a better idea of how to deal with such problems technically given its experience in the 1988-1990 period and the youth uprising in 2001 and the tens of thousands of youth riots which have struck the country in the last decade. In other words, it is important to recognize that the Algerian regime — like its counterparts elsewhere — made choices this year.

Read the whole post at http://themoornextdoor.wordpress.com/2011/11/16/exceptions-agency-structure/

Monday, November 14, 2011

IMF Calls for Further Reforms in China’s Financial System

IMF Calls for Further Reforms in China’s Financial System
Press Release No. 11/409
November 14, 2011 

http://www.imf.org/external/np/sec/pr/2011/pr11409.htm


China’s financial system is robust overall, but faces a steady build-up in vulnerabilities. While significant progress has been made towards developing a more commercially-oriented financial sector, and supervision and regulation are being strengthened, risks stem from the growing complexity of the system and the uncertainties surrounding the global economy. Further reforms are needed to support financial stability and encourage strong and balanced growth, the International Monetary Fund (IMF) says in its first formal evaluation of China’s financial sector published today.

The IMF’s first Financial Sector Assessment Program (FSAP) review of China was carried out jointly with the World Bank. China is one of 25 systemically important countries that have agreed to mandatory assessments at least once every five years. The FSAPs are part of the IMF’s activities in financial surveillance and the monitoring of the international monetary system.

“China’s banks and financial sector are healthy, but there are vulnerabilities that should be addressed by the authorities,” says Jonathan Fiechter, deputy director of the IMF’s Monetary and Capital Markets Department and the head of the IMF team that conducted the FSAP. “While the existing structure fosters high savings and high levels of liquidity, it also creates the risk of capital misallocation and the formation of bubbles, especially in real estate. The cost of such distortions will only rise over time, so the sooner these distortions are addressed the better.”

Risks
According to the FSAP report, China’s financial sector is confronting several near-term risks: deterioration in loan quality due to rapid credit expansion; growing disintermediation by shadow banks and off-balance sheet exposures; a downturn in real estate prices; and the uncertainties of the global economic scenario. Medium-term vulnerabilities are also building and could impair the needed reorientation of the financial system to support the country’s future growth. Moving along this path will pose additional risks, so priority must be given to establishing the institutional and operational preconditions that are crucial for a wide-ranging financial reform agenda.

The main areas of reform should include:
  • Steps to broaden financial markets and services, and developing diversified modalities of financial intermediation that would foster healthy competition among banks;
  • A reorientation of the role of government away from using the banking system to carry out broad government policy goals and to allow lending decisions to be based on commercial goals;
  • Expansion of the use of market-based monetary policy instruments, using interest rates as the main instrument to govern credit expansion, rather than administrative measures;
  • An upgrading of the financial infrastructure and legal frameworks, including strengthening the payments and settlement systems, as well as consumer protection and expansion of financial literacy.
The Chinese authorities have begun to move on many of its recommendations, and the IMF stands ready to provide technical cooperation in areas relating to strengthening the financial stability framework in China.

Stress Tests
Stress tests conducted jointly by the Fund and Chinese authorities of the country’s largest 17 commercial banks indicate that most of them appear to be resilient to isolated shocks, which include: a sharp deterioration in asset quality (including a correction in the real estate markets), shifts in the yield curve, and changes in the exchange rate. If several of these risks were to occur at the same time, however, the banking system could be severely impacted, the report warns.

About the FSAP
The Financial Sector Assessment Program, established in 1999, is an in-depth analysis of a country’s financial sector. The IMF conducts mandatory FSAPs for the 25 jurisdictions with systemically important financial sectors, and any member countries that request it. Assessments in developing and emerging market countries are conducted jointly with the World Bank. FSAPs include two components: a financial stability assessment, which is the responsibility of the Fund; and, in developing and emerging market countries, a financial development assessment, conducted by the World Bank.

To assess the stability of the financial sector, IMF teams examine the soundness of the banking and other financial sectors; rate the quality of bank, insurance, and capital market supervision against accepted international standards; and evaluate the ability of supervisors, policymakers, and financial safety nets to respond effectively to a systemic crisis. While FSAPs do not evaluate the health of individual financial institutions and cannot predict or prevent financial crises, they identify the main vulnerabilities that could trigger one.

In September 2010, the IMF made financial stability assessments under the FSAP a mandatory part of IMF surveillance every five years for jurisdictions deemed systemically important based on the size of the financial sector and their global interconnectedness. The countries affected by this decision are: Australia, Austria, Belgium, Brazil, Canada, China, France, Germany, Hong Kong SAR, Italy, Japan, India, Ireland, Luxembourg, Mexico, the Netherlands, Russia, Singapore, South Korea, Spain, Sweden, Switzerland, Turkey, the United Kingdom, and the United States.

For more information on FSAPs, see Press Release No. 10/357

CGFS: Global liquidity - concept, measurement and policy implications

Global liquidity - concept, measurement and policy implications
CGFS Publications No 45
November 2011

Abstract

Global liquidity has become a key focus of international policy debates over recent years. This reflects the view that global liquidity and its drivers are of major importance for international financial stability. The concept of global liquidity, however continues to be used in a variety of ways and this ambiguity can lead to unfounded and potentially destabilising policy initiatives.

This report analyses global liquidity from a financial stability perspective, using two distinct liquidity concepts. One is official liquidity, which can be used to settle claims through monetary authorities and is ultimately provided by central banks. The other concept is private (or private sector) liquidity, which is created to a large degree through cross-border operations of banks and other financial institutions.

Understanding the determinants of private liquidity is of particular importance. As many financial institutions provide liquidity both domestically and in other countries, globally, private liquidity is linked to the dynamics of gross international capital flows, including cross-border banking or portfolio movements. This international component of liquidity can be a potential source of instability because of its own dynamics or because it amplifies cyclical movements in domestic financial conditions and intensifies domestic imbalances.

Policy responses to global liquidity call for a consistent framework that considers all phases of global liquidity cycles, countering both surges and shortages. Measures to prevent unsustainable booms in private liquidity are linked with micro- and macroprudential policies as well as the financial reform agenda. Country-specific or regional liquidity shocks, in turn, may effectively be addressed through self-insurance in the form of precautionary foreign exchange reserves holdings and existing arrangements which essentially redistribute liquidity. However, truly global liquidity shocks necessitate direct interventions in amounts large enough to break downward liquidity spirals. Only central banks have this ability.

Download PDF file at http://www.bis.org/publ/cgfs45.htm or ask us for the PDF file.

Saturday, November 5, 2011

Global systemically important banks: Assessment methodology and the additional loss absorbency requirement

Global systemically important banks (G-SIBs): Assessment methodology and the additional loss absorbency requirement
Nov 04, 2011


The rules text sets out the Basel Committee's framework on the assessment methodology for global systemic importance, the magnitude of additional loss absorbency that global systemically important banks (G-SIBs) should have and the arrangements by which the requirement will be phased in. The cover note to the rules text sets out the Committee's summary and evaluation of the public comments received on the July 2011 consultative document. The rules text was finalised following a careful review of the public comments received. The work of the Basel Committee forms part of a broader effort by the Financial Stability Board to reduce the moral hazard of global systemically important institutions.

The rationale for the policy measures set out in the rules text is to deal with the cross-border negative externalities created by G-SIBs which current regulatory policies do not fully address. The measures will enhance the going-concern loss absorbency of G-SIBs and reduce the probability of their failure. 

The assessment methodology for G-SIBs is based on an indicator-based approach and comprises five broad categories: size, interconnectedness, lack of readily available substitutes or financial institution infrastructure, global (cross-jurisdictional) activity and complexity.

The additional loss absorbency requirements will range from 1% to 2.5% Common Equity Tier 1 (CET1) depending on a bank's systemic importance with an empty bucket of 3.5% CET1 as a means to discourage banks from becoming even more systemically important.

The higher loss absorbency requirements will be introduced in parallel with the Basel III capital conservation and countercyclical buffers, ie between 1 January 2016 and year end 2018 becoming fully effective on 1 January 2019.