Showing posts with label banks. Show all posts
Showing posts with label banks. Show all posts

Thursday, March 28, 2013

Cyprus: Some Early Lessons. By Thorsten Beck

Cyprus: Some Early Lessons. By Thorsten Beck
World Bank Blogs, Mar 28, 2013

The crisis is Cyprus is still unfolding and the final resolution might still have some way to go, but the events in Nicosia and Brussels already offer some first lessons. And these lessons look certainly familiar to those who have studied previous crises.  Bets are that Cyprus will not be the Troika’s last patient, with one South European finance minister already dreading the moment where he might be in a situation like his Cypriot colleague.  Even more important, thus to analyze the on-going Cyprus crisis resolution for insights into where the resolution of the Eurozone crisis might be headed and what needs to be done.

1. A deposit insurance scheme is only as good as the sovereign backing it

One of the main objectives of deposit insurance is to prevent bank runs. That was also the idea behind the increase of deposit insurance limits across the Eurozone to 100,000 Euro after the Global Financial Crisis. However, deposit insurance is typically designed for idiosyncratic bank failures, not for systemic crises.  In the latter case, it is important that public back stop funding is available.  Obviously, the credibility of the latter depends on a solvent sovereign. As Cyprus has shown, if the solvency of the sovereign is itself in question, this will undermine the confidence of depositors in a deposit insurance scheme.  In the case of Cyprus, this confidence has been further undermined by the initial idea of imposing a tax on insured deposits, effectively an insurance co-payment, contradicting maybe not in legal terms but definitely in spirit the promise of deposit insurance of up to 100,000 Euros. The confidence that has been destroyed with the protracted resolution process and the back-and-forth over loss distribution will be hard to re-establish. A banking system without the necessary trust, in turn, will be hard pressed to fulfill its basic functions of facilitating payment services and intermediating savings. Ultimately, this lack of confidence can only be overcome by a Eurozone wide deposit insurance scheme with public back-stop funding by ESM and a regulatory and supervisory framework that depositors can trust.

2. A large financial system is not necessarily growth enhancing

An extensive literature has documented the positive relationship between financial deepening and economic growth, even though the recent crisis has shed doubts on this relationship (Levine, 2005, Beck, 2012).  However, both theoretical and empirical literature focus on the intermediation function of the financial system, not on the size of the financial system per se. Very different from this financial facilitator view is the financial center view, which sees the financial sector as an export sector, i.e. one that seeks to build a nationally centered financial center stronghold based on relative comparative advantages such as skill base, favorable regulatory and tax policies, (financial safety net) subsidies, etc. Economic benefits of such a financial center might also include important spin-offs coming from professional services (legal, accounting, consulting, etc.) that tend to cluster around the financial sector.

In recent work with Hans Degryse and Christiane Kneer (2013) and using pre-2007 data, we have shown that a large financial system might stimulate growth in the short-term, but comes at the expense of higher volatility. It is the financial intermediation function of finance that helps improve growth prospects not a large financial center, a lesson that Cyprus could have learned from Iceland.

3. Crisis resolution as political distribution fight

Resolution processes are basically distributional fights about who has to bear losses.   The week-long negotiations about loss allocation in Cyprus are telling in this respect.  While it was initially Eurozone authorities that were blamed for imposing losses on insured depositors, there is an increasingly clear picture that it was maybe the Cypriot government itself that pushed for such a solution in order to avoid imposing losses on large, (and thus most likely) richer and more connected depositors.

While the Cypriot case might be the most egregious recent example for the entanglement of politics and crisis resolution, the recent crises offer ample examples of how politically sensitive the financial system is.  Just two more examples here:  First, even during and after the Global Financial Crisis of 2008 and 2009, there was still open political pressure across Europe to maintain or build up national champions in the respective banking systems, even at the risk of creating more too-big-to-fail banks.  Second, the push by the German government to exempt German small savings and cooperative banks from ECB supervision and thus the banking union can be explained only on political basis and not with economic terms, as the "too-many-to-fail" is as serious as the "too-big-to-fail" problem.

4. Plus ca change, plus c'est la meme chose

European authorities and many observers have pointed to the special character of each of the patients of the Eurozone crisis and their special circumstances. Ireland and Spain suffered from housing booms and subsequent busts, Portugal from high current account deficits stemming from lack of competitiveness and mis-allocation of capital inflows, Greece from high government deficit and debt and now Cyprus from an oversized banking system. So, seemingly different causes, which call for different solutions!
But there is one common thread across all crisis countries, and that is the close ties between government and bank solvency. In the case of Ireland, this tie was established when the ECB pushed the Irish authorities to assume the liabilities of several failed Irish banks. In the case of Greece, it was the other way around, with Greek banks having to be recapitalized once sovereign debt was restructured.  In all crisis countries, this link is deepened as their economies go into recession, worsening government’s fiscal balance, thus increasing sovereign risk, which in turn puts balance sheets of banks under pressure that hold these bonds but also depend on the same government for possible recapitalization. This tie is exacerbated by the tendency of banks to invest heavily in their home country’s sovereign bonds, a tendency even stronger in the Eurozone’s periphery (Acharya, Drechsler and Schnabl, 2012).  Zero capital requirements for government bond holdings under the Basel regime, based on the illusion that such bonds in OECD countries are safe from default, have not helped either.

5. If you kick the can down the road, you will run out of road eventually 

The multiple rounds of support packages for Greece by Troika, built on assumptions and data, often outdated by the time agreements were signed, has clearly shown that you can delay the day of reckoning only so long. By kicking the can down the road, however, you risk deteriorating the situation even further. In the case of Greece that led eventually to restructuring of sovereign debt. Delaying crisis resolution of Cyprus for months if not years has most likely also increased losses in the banking system.  A lesson familiar from many emerging market crises (World Bank. 2001)!  On a first look, the Troika seemed eager to avoid this mistake in the case of Cyprus, forcing recognition and allocation of losses in the banking system early on without overburdening the sovereign debt position. However, the recession if not depression that is sure to follow in the next few years in Cyprus will certainly increase the already high debt-to-GDP ratio and might ultimately lead to the need for sovereign debt restructuring.

6. The Eurozone crisis — a tragedy of commons

The protracted resolution process of Cyprus has shown yet again, that in addition to a banking, sovereign, macroeconomic and currency crisis, the Eurozone faces a governance crisis. Decisions are taken jointly by national authorities who each represent the interest of their respective country (and taxpayers), without taking into account the externalities of national decisions arising on the Eurozone level. It is in the interest of every member government with fragile banks to "share the burden" with the other members, be it through the ECB’s liquidity support or the Target 2 payment system. Rather than coming up with crisis resolution on the political level, the ECB and the Eurosystem are being used to apply short-term (liquidity) palliatives that deepen distributional problems and make the crisis resolution more difficult. What is ultimately missing is a democratically legitimized authority that represents Eurozone interests.

7. Learning from the Vikings

In 2008, Iceland took a very different approach from the Eurozone when faced with the failure of their oversized banking system. It allowed its banks to fail, transferred domestic deposits into good banks and left foreign deposits and other claims and bad assets in the original banks, to be resolved over time.  While the banking crisis and its resolution has been a traumatic experience for the Icelandic economy and society, with repercussions even for diplomatic relations between Iceland and several European countries, it avoided a loss and thus insolvency transfer from the banking sector to the sovereign.  Iceland's government has kept its investment rating throughout the crisis. And while mistakes might have been made in the resolution process (Danielsson, 2011), Iceland’s banking sector does not drag down Iceland’s growth any longer and might eventually even make a positive contribution.

The resolution approach in Cyprus seems to follow the Icelandic approach. While the Cypriot case might be a special one (as part of the losses fall outside the Eurozone and Cypriot banks are less connected with the rest of the Eurozone than previous crisis cases), there are suggestions that future resolution cases might impose losses not just on junior and maybe senior creditors of banks, but even on depositors to thus reduce pressure on government’s balance sheets.  A move towards market discipline, for certain; whether this is due to learning from experience, tighter government budgets across Europe or for political reasons remains to be seen.

8. Banking union with just supervision does not work

The move towards a Single Supervisory Mechanism has been hailed as major progress towards a banking union and stronger currency union.  As the case of Cyprus shows, this is certainly not enough.  The holes in the balance sheets of Cypriot banks became obvious in 2011 when Greek sovereign debt was restructured, but given political circumstances, the absence of a bank resolution framework in Cyprus and — most importantly — the absence of resources to undertake such a restructuring, the problems have not been addressed until now.  Even once the ECB has supervisory power over the Eurozone banking system, without a Eurozone-wide resolution authority with the necessary powers and resources, it will find itself forced to inject more and more liquidity and keep the zombies alive, if national authorities are unwilling to resolve a failing bank.

9. A banking union is needed for the Eurozone, but won't help for the current crisis!

While the Eurozone will not be sustainable as currency union without a banking union, a banking union cannot help solve the current crisis. First, building up the necessary structures for a Eurozone or European regulatory and bank resolution framework cannot be done overnight, while the crisis needs immediate attention. Second, the current discussion on banking union is overshadowed by distributional discussions, as the bank fragility is heavily concentrated in the peripheral countries, and using a Eurozone-wide deposit insurance and supervision mechanism to solve legacy problems is like introducing insurance after the insurance case has occurred. The current crisis has to be solved before banking union is in place. Ideally, this would be done through the establishment of an asset management company or European Recapitalization Agency, which would sort out fragile bank across Europe, and also be able to take an equity stake in restructured banks to thus benefit from possible upsides (Beck, Gros and Schoenmaker, 2012).  This would help disentangle government and bank ties, discussed above, and might make for a more expedient and less politicized resolution process than if done on the national level.

10. A currency union with capital controls?

The protracted resolution process of the Cypriot banking crisis has increased the likelihood of a systemic bank run in Cyprus once the banks open, though even if the current solution would have been arrived at in the first attempt, little confidence in Cypriot banks might have been left.  As in other crises (Argentina and Iceland) that perspective has led authorities to impose capital controls, an unprecedented step within the Eurozone. Effectively, however, this implies that a Cypriot Euro is not the same as a German or Dutch Euro, as they cannot be freely exchanged via the banking system, thus a contradiction to the idea of a common currency (Wolff, 2013).

However, these controls only formalize and legalize what has been developing over the past few years: a rapidly disintegrating Eurozone capital market.  National supervisors increasingly focus on safeguarding their home financial system, trying to keep capital and liquidity within their home country (Gros, 2012).  Anecdotal evidence suggests that this does not only affect the inter-bank market but even intra-group transaction between, let’s say, Italian parent banks and their Austrian and German subsidiaries.  Another example of the tragedy of commons, discussed above.

11. Finally, there is no free lunch

This might sound like a broken disk, but the Global Financial Crisis and subsequent Eurozone crisis has offered multiple incidences to remind us that you cannot have the cake and eat it.  This applies as much to Dutch savers attracted by high interests in Icesave and then disappointed by the failure of Iceland to assume the obligations of its banks as to Cypriot banks piling up on Greek government bonds promising high returns even in 2010 when it had become all but obvious that Greece would require sovereign debt restructuring.  On a broader level, the idea that a joint currency only brings advantages for everyone involved, but no additional responsibilities in term of reduced sovereignty and burden-sharing and insurance arrangements also resembles the free lunch idea.

On a positive note, the Cyprus bail-out has shown that Eurozone authorities have learnt from previous failures by forcing an early recognition of losses in Cyprus and by moving towards a banking union, even if very slowly. As discussed above, however, there are still considerable political constraints and barriers to overcome, so that it is ultimately left to each observer to decide whether the glass is half full or half empty.


References:

Acharya, Viral, Itamar Drechsler and Philipp Schnabl. 2012. A tale of two overhangs: the nexus of financial sector and sovereign credit risks. Vox 15 April 2012
Beck, Thorsten. 2012. Finance and growth: lessons from the literature and the recent crisis. Paper prepared for the LSE growth commission.
Beck, Thorsten, Hans Degryse and Christiane Kneer. 2012. Is more finance better?
Disentangling intermediation and size effects of financial systems. Journal of Financial Stability, forthcoming.
Beck, Thorsten, Daniel Gros, Dirk Schoenmaker (2012): Banking union instead of Eurobonds — disentangling sovereign and banking crises, Vox 24 June 2012.
Danielsson, Jon. 2011. How not to resolve a banking crisis: Learning from Iceland’s mistakes  Vox, 26 November 2011
Gros. Daniel. 2012. The Single European Market in Banking in decline — ECB to the rescue? Vox , 16 Ocotber 2012
Levine, Ross. 2005. Finance and growth: theory and evidence. In Handbook of Economic
Growth, ed. Philippe Aghion and Steven N. Durlauf, 865–934. Amsterdam: Elsevier.
Wolff, Guntram. 2013. Capital controls are a grave risk to the eurozone. Financial Times 26 March 2013.
World Bank. 2001. Finance For Growth: Policy Choices in a Volatile World. Policy Research Report


Full article:
http://blogs.worldbank.org/allaboutfinance/cyprus-some-early-lessons


Wednesday, March 27, 2013

How Effective are Macroprudential Policies in China? By Bin Wang and Tao Sun

How Effective are Macroprudential Policies in China? By Bin Wang and Tao Sun
IMF Working Paper No. 13/75
March 27, 2013
http://www.imf.org/external/pubs/cat/longres.aspx?sk=40425.0

Summary: This paper investigates macroprudential policies and their role in containing systemic risk in China. It shows that China faces systemic risk in both the time (procyclicality) and cross-sectional (contagion) dimensions. The former is reflected as credit and asset price risks, while the latter is reflected as the links between the banking sector and informal financing and local government financing platforms. Empirical analysis based on 171 banks shows that some macroprudential policy tools (e.g., the reserve requirement ratio and house-related policies) are useful, but they cannot guarantee protection against systemic risk in the current economic and financial environment. Nevertheless, better-targeted macroprudential policies have greater potential to contain systemic risk pertaining to the different sizes of the banks and their location in regions with different levels of economic development. Complementing macroprudential policies with further reforms, including further commercialization of large banks, would help improve the effectiveness of those policies in containing systemic risk in China.


ISBN/ISSN: 9781484355886 / 2227-8885

Supervisory framework for measuirng and controlling large exposures

Supervisory framework for measuirng and controlling large exposures
BCBS, Mar 2013
http://www.bis.org/publ/bcbs246.htm

The Basel Committee on Banking Supervision has today published a proposed supervisory framework for measuring and controlling large exposures.

 One of the key lessons from the financial crisis is that banks did not always consistently measure, aggregate and control exposures to single counterparties across their books and operations. And throughout history there have been instances of banks failing due to concentrated exposures to individual counterparties (eg Johnson Matthey Bankers in the UK in 1984, the Korean banking crisis in the late 1990s). Large exposures regulation has arisen as a tool for containing the maximum loss a bank could face in the event of a sudden counterparty failure to a level that does not endanger the bank's solvency.

A separate key lesson from the crisis is that material losses in one systemically important financial institution (SIFI) can trigger concerns about the solvency of other SIFIs, with potentially catastrophic consequences for global financial stability. The Committee is of the view that the large exposures framework is a tool that could be used to mitigate the risk of contagion between global systemically important banks, thus underpinning financial stability.

Finally, the consultation paper presents proposals to strengthen the oversight and regulation of the shadow banking system in relation to large exposures.  In particular, the proposals include policy measures designed to capture bank-like activities conducted by non-banks that are of concern to supervisors.

The proposed new standard aims to ensure greater consistency in the way banks and supervisors measure, aggregate and control exposures to single counterparties. Acting as a backstop to risk-based capital requirements, the standard would supplement the existing risk-based capital framework by protecting banks from substantive losses caused by the sudden default of a counterparty or group of connected counterparties. The consultative paper would replace the Basel Committee's 1991 guidance Measuring and controlling large credit exposures.

Saturday, March 23, 2013

Basel: Consultative document on recognising the cost of credit protection purchased

Basel Committee issues consultative document on recognising the cost of credit protection purchased
March 22, 2013
http://www.bis.org/press/p130322.htm

The Basel Committee on Banking Supervision has today published a proposal that would strengthen capital requirements when banks engage in certain high-cost credit protection transactions.

The Committee has previously expressed concerns about potential regulatory capital arbitrage related to certain credit protection transactions. At that time it noted that it would continue to monitor developments with respect to such transactions and would consider imposing a globally harmonised minimum capital Pillar 1 requirement if necessary. After further consideration, the Committee decided to move forward with a more comprehensive Pillar 1 proposal.

While the Committee recognises that the purchase of credit protection can be an effective risk management tool, the proposed changes are intended to ensure that the costs, and not just the benefits, of purchased credit protection are appropriately recognised in regulatory capital. It does this by requiring that banks, under certain circumstances, calculate the present value of premia paid for credit protection, which should be considered as an exposure amount of the protection-purchasing bank and be assigned a 1,250% risk weight.


---
Recognising the cost of credit protection purchased

The proposal set out in this consultative document would strengthen capital requirements when banks engage in certain high-cost credit protection transactions. The Committee has previously expressed concerns about potential regulatory capital arbitrage related to certain credit protection transactions. At that time it noted that it would continue to monitor developments with respect to such transactions and would consider imposing a globally harmonised minimum capital Pillar 1 requirement if necessary. After further consideration, the Committee decided to move forward with a more comprehensive Pillar 1 proposal.

While the Committee recognises that the purchase of credit protection can be an effective risk management tool, the proposed changes are intended to ensure that the costs, and not just the benefits, of purchased credit protection are appropriately recognised in regulatory capital. It does this by requiring that banks, under certain circumstances, calculate the present value of premia paid for credit protection, which should be considered as an exposure amount of the protection-purchasing bank and be assigned a 1,250% risk weight.

 
---
Full text of the consultative doc: http://www.bis.org/publ/bcbs245.pdf

Friday, March 22, 2013

Basel Committee: supervisory guidance on external audits of banks (consultation)

Basel Committee publishes for consultation supervisory guidance on external audits of banks
March 21, 2013
http://www.bis.org/press/p130321.htm

The Basel Committee on Banking Supervision has today published supervisory guidance on External audits of banks for consultation along with a letter to the International Auditing and Assurance Standards Board (IAASB).

The consultative paper aims to enhance and supersede the existing guidance that was published by the Basel Committee in 2002 on the relationship between banking supervisors and banks' external auditors and in 2008 on external audit quality and banking supervision. The evolution of bank practices and the introduction of new standards and regulations over the last 10 years warranted a thorough revision of the Committee's supervisory guidance. In addition, the recent financial crisis has highlighted the need to improve the quality of external audits of banks. The proposed enhanced guidance sets out supervisory expectations of how:
  • external auditors can discharge their responsibilities more effectively;
  • audit committees can contribute to audit quality in their oversight of the external audit;
  • an effective relationship between external auditors and supervisors can lead to regular communication of mutually useful information; and
  • regular and effective dialogue between the banking supervisory authorities and relevant audit oversight bodies can enhance the quality of bank audits.
The Committee's letter to the IAASB calls for enhancing the International Standards on Auditing (ISAs) to include more authoritative guidance relating to the audit of banks. It sets out specific areas where the Committee believes the ISAs should be improved.

Commenting on today's publications, Stefan Ingves, Chairman of the Basel Committee and Governor of Sveriges Riksbank, said, "The Committee has developed guidance that builds on recent experience and will help raise the bar with regard to what supervisors expect of banks' external auditors and audit committees. We also recognise the great importance of audit standards and are keen to support the IAASB in enhancing audit quality."

Comments on the proposals should be submitted by Friday 21 June 2013 by e-mail to: baselcommittee@bis.org. Alternatively, comments may be sent by post to: Secretariat of the Basel Committee on Banking Supervision, Bank for International Settlements, CH-4002 Basel, Switzerland. All comments may be published on the website of the Bank for International Settlements unless a comment contributor specifically requests confidential treatment.

Monday, March 18, 2013

Tracking Global Demand for Advanced Economy Sovereign Debt

Tracking Global Demand for Advanced Economy Sovereign Debt. Prepared by Serkan Arslanalp and Takahiro Tsuda
IMF Working Paper No. 12/284
December 2012
http://www.imf.org/external/pubs/cat/longres.aspx?sk=40135.0

Recent events have shown that sovereign, just like banks, can be subject to runs, highlighting the importance of the investor base for their liabilities. This paper proposes a methodology for compiling internationally comparable estimates of investor holdings of sovereign debt. Based on this methodology, it introduces a dataset for 24 major advanced economies that can be used to track US$42 trillion of sovereign debt holdings on a quarterly basis over 2004-11. While recent outflows from euro periphery countries have received wide attention, most sovereign borrowers have continued to increase reliance on foreign investors. This may have helped reduce borrowing costs, but it can imply higher refinancing risks going forward. Meanwhile, advanced economy banks’ exposure to their own government debt has begun to increase across the board after the global financial crisis, strengthening sovereign-bank linkages. In light of these risks, the paper proposes a framework— sovereign funding shock scenarios (FSS)—to conduct forward-looking analysis to assess sovereigns’ vulnerability to sudden investor outflows, which can be used along with standard debt sustainability analyses (DSA). It also introduces two risk indices—investor base risk index (IRI) and foreign investor position index (FIPI)—to assess sovereigns’ vulnerability to shifts in investor behavior.

Wednesday, March 13, 2013

A Framework for Macroprudential Bank Solvency Stress Testing: Application to S-25 and Other G-20 Country FSAPs

A Framework for Macroprudential Bank Solvency Stress Testing: Application to S-25 and Other G-20 Country FSAPs. By Andreas A Jobst, Li Ong, and Christian Schmieder

IMF Working Paper No. 13/68
March 13, 2013
http://www.imf.org/external/pubs/cat/longres.aspx?sk=40390.0

Summary: The global financial crisis has placed the spotlight squarely on bank stress tests. Stress tests conducted in the lead-up to the crisis, including those by IMF staff, were not always able to identify the right risks and vulnerabilities. Since then, IMF staff has developed more robust stress testing methods and models and adopted a more coherent and consistent approach. This paper articulates the solvency stress testing framework that is being applied in the IMF’s surveillance of member countries’ banking systems, and discusses examples of its actual implementation in FSAPs to 18 countries which are in the group comprising the 25 most systemically important financial systems (“S-25”) plus other G-20 countries. In doing so, the paper also offers useful guidance for readers seeking to develop their own stress testing frameworks and country authorities preparing for FSAPs. A detailed Stress Test Matrix (STeM) comparing the stress test parameters applie in each of these major country FSAPs is provided, together with our stress test output templates.

Friday, March 8, 2013

Rules, Discretion, and Macro-Prudential Policy. By Itai Agur and Sunil Sharma

Rules, Discretion, and Macro-Prudential Policy. By Itai Agur and Sunil Sharma
March 08, 2013
IMF Working Paper No. 13/65
http://www.imf.org/external/pubs/cat/longres.aspx?sk=40379.0

Summary: The paper examines the implementation of macro-prudential policy. Given the coordination, flow of information, analysis, and communication required, macro-prudential frameworks will have weaknesses that make it hard to implement policy. And dealing with the political economy is also likely to be challenging. But limiting discretion through the formulation of macro-prudential rules is complicated by the difficulties in detecting and measuring systemic risk. The paper suggests that oversight is best served by having a strong baseline regulatory regime on which a time-varying macro-prudential policy can be added as conditions warrant and permit.

Monday, February 25, 2013

Taxation, Bank Leverage, and Financial Crises. By Ruud de Mooij, Michael Keen, and Masanori Orihara

Taxation, Bank Leverage, and Financial Crises. By Ruud de Mooij, Michael Keen, and Masanori Orihara
IMF Working Paper No. 13/48
Feb 25, 2013
http://www.imf.org/external/pubs/cat/longres.aspx?sk=40341.0

Summary: That most corporate tax systems favor debt over equity finance is now widely recognized as, potentially, amplifying risks to financial stability. This paper makes a first attempt to explore, empirically, the link between this tax bias and the probability of financial crisis. It finds that greater tax bias is associated with significantly higher aggregate bank leverage, and that this in turn is associated with a significantly greater chance of crisis. The implication is that tax bias makes crises much more likely, and, conversely, that the welfare gains from policies to alleviate it can be substantial—far greater than previous studies, which have ignored financial stability considerations, suggest.


Introduction excerpts:

The onset of the financial crisis of 2008 quickly prompted many assessments of the role that taxation might have played.1 Their consensus was clear, but vague: tax distortions did not trigger the crisis, but may have increased vulnerability to financial crises. Prominent among the reasons given for this was ‘debt bias’: the tendency toward excess leverage induced, in almost all countries, by the deductibility against corporate taxation of interest payments but not of the return to equity.2 By encouraging firms to finance themselves by debt rather than equity, this might have made them more vulnerable to shocks and so increased both the likelihood and intensity of financial crises. The point applies in principle to all firms, but is a particular concern in relation to financial institutions; and these are the focus here.

This potential link from tax design to financial crises is now widely recognized. But analysis has not progressed beyond metaphor and speculation. Shackelford, Shaviro, and Slemrod (2010, p. 784), for instance, stress “the possibility that the tax biases served…as extra gasoline intensifying the explosion once other causes lit the match”, and the European Commission that “The welfare costs related to debt bias might not be negligible [because] excessive debt levels increase the probability of default” (European Commission, 2011; p. 7), with both the ‘might’ and the ‘not negligible’ leaving much doubt and imprecision.  This paper aims to provide a first attempt to establish and quantify an empirical link between the tax incentives that encourage financial institutions (more precisely, banks, the group for which we have data) to finance themselves by debt rather than equity and the likelihood of financial crises erupting; and then to try to quantify the welfare gains that policies to address this bias might consequently yield.

The approach is to combine two elements in a causal chain. The first is that between the statutory corporate tax rate and banks’ leverage. This has received substantial attention in relation to nonfinancial firms,3 but very little in relation to the financial sector. Keen and De Mooij (2011), however, show that for banks too a higher corporate tax rate, amplifying the tax advantage of debt over equity finance, should in principle lead to higher levels of leverage; the presence of capital regulations does not affect the usual tax bias applying, so long as it is privately optimal for banks to hold some buffer over regulatory requirements (as they generally do). Empirically too, Keen and de Mooij (2012) find that, for a large crosscountry panel of banks, tax effects on leverage are significant—and, on average, about aslarge as for nonfinancial institutions. These effects are very much smaller, they also find, for the largest banks, which generally account for the vast bulk of all bank assets. One task in this paper is to explore these findings further, using data now available to extend coverage into the crisis period that began in 2008—enabling a comparison of tax impacts pre- and post-onset—and applying the same estimation strategy to country-level data for the OECD.

Importantly, the finding that tax distortions to leverage are small for the larger banks, which are massively larger than the rest, does not mean that the welfare impact of tax distortions is in aggregate negligible: even small changes in the leverage of very large banks could have a large impact on the likelihood of their distress or failure, and hence on the likelihood of financial crisis.

This is where the second link in the causal chain explored here comes in: that between the aggregate leverage of the financial sector and the probability of financial crisis.4 We estimate such a relationship for OECD countries, applying the estimation strategy of Barrell et al.  (2010) and Kato, Kobayashi, and Saita (2010) but, in contrast to these earlier studies, capturing data on the recent financial crisis from Laeven and Valencia (2010). The results suggest sizeable and highly nonlinear effects of aggregate bank leverage on the probability of financial crisis.

Combining the results from these two estimating equations enables simple calculations of the impact of a variety of tax reforms on the likelihood of financial crisis. Linking this, in turn, with estimates of the output loss that is historically associated with such crises gives some rough sense of the potential welfare gains from policies that mitigate debt bias in the financial sector. Putting aside the overarching debate as to the proper roles of taxation and regulation in addressing the potential for excess leverage in the financial sector,5 we consider three tax reforms that would reduce the tax incentive to debt finance: a cut in the corporate tax rate; adoption of an Allowance for Corporate Equity form of corporate tax (which would in principle eliminate debt bias); and a ‘bank levy’ of broadly the kind that a dozen or so countries have introduced since the crisis.6

All this gives a very different perspective on the nature and possible magnitude of the welfare costs associated with debt bias. Previous work, which has not reflected considerations of financial stability, has concluded that these are small: Gordon (2010) estimates the total efficiency loss from debt bias in the U.S. to be less than 1 percent of corporate income tax (CIT) revenue and concludes that: “tax distortions from corporate financial policy are not an important consideration when setting tax policy”; Weichenrieder and Klautke (2008) put the marginal welfare loss from debt bias somewhat higher, but still only at 0.06–0.16 percent of the capital stock. The question here is whether considerations of financial stability imply much higher welfare losses—and the conclusion will be that it seems they do.


Conclusion

The analysis here is in several respects simplistic and limited. In particular, we have not uncovered a direct link between tax incentives favoring debt finance and the probability of financial crisis. But the evidence presented here does suggest the real possibility of such a connection. If debt bias leads to higher aggregate bank leverage than would otherwise be the case—and it seems that it does—and if higher aggregate bank leverage makes financial crisis more likely—and it seems that it does—then debt bias increases the chances of financial crisis. This, in turn, can imply welfare gains from mitigating debt bias far higher than the small amounts found in previous work: noticeably more, in some of the calculations reported here, than 1 percent of GDP. Regulation, of course, has historically had the dominant role in addressing such problems of excess leverage in the financial sector, and the higher and tighter capital requirements of Basel III should to some degree reduce the welfare costs of debt bias. How much comfort is taken from this will depend on one’s evaluation of these reforms. What the evidence assembled here suggests, however, is that the tax incentive encouraging banks to use debt finance is not just an inelegant inconsistency with regulations intended to do the exact opposite, but a potential risk to be recognized, and, as need be, addressed, in the pursuit of financial stability.

Saturday, February 16, 2013

BCBS: Supervisory guidance for managing risks associated with the settlement of foreign exchange transactions

BCBS: Supervisory guidance for managing risks associated with the settlement of foreign exchange transactions
February 15 2013
http://www.bis.org/publ/bcbs241.htm

The purpose of this guidance is to provide updated guidance to supervisors and the banks they supervise on approaches to managing the risks associated with the settlement of FX transactions. This guidance expands on, and replaces, the BCBS's Supervisory guidance for managing settlement risk in foreign exchange transactions published in September 2000.

Since the BCBS's Supervisory guidance for managing settlement risk in foreign exchange transactions (2000) was published, the foreign exchange market has made significant strides in reducing the risks associated with the settlement of FX transactions. Substantial FX settlement-related risks remain, however, not least because of the rapid growth in FX trading activities.

The document provides a more comprehensive and detailed view on governance arrangements and the management of principal risk, replacement cost risk and all other FX settlement-related risks. In addition, it promotes the use of payment-versus-payment arrangements, where practicable, to reduce principal risk.

The guidance is organized into seven "guidelines" that address governance, principal risk, replacement cost risk, liquidity risk, operational risk, legal risk, and capital for FX transactions. The key recommendations emphasize the following:
  • A bank should ensure that all FX settlement-related risks are effectively managed and that its practices are consistent with those used for managing other counterparty exposures of similar size and duration.
  • A bank should reduce its principal risk as much as practicable by settling FX transactions through the use of FMIs that provide PVP arrangements. Where PVP settlement is not practicable, a bank should properly identify, measure, control and reduce the size and duration of its remaining principal risk.
  • A bank should ensure that when analysing capital needs, all FX settlement-related risks should be considered, including principal risk and replacement cost risk and that sufficient capital is held against these potential exposures, as appropriate.
  • A bank should use netting arrangements and collateral arrangements to reduce its replacement cost risk and should fully collateralise its mark-to-market exposure on physically settling FX swaps and forwards with counterparties that are financial institutions and systemically important non-financial entities.
An annex to the final guidance provides detailed explanation of FX settlement-related risks and how they arise.

Wednesday, February 13, 2013

A Banking Union for the Euro Area. IMF Staff Discussion Note

A Banking Union for the Euro Area. By Rishi Goyal, Petya Koeva Brooks, Mahmood Pradhan, Thierry Tressel, Giovanni Dell'Ariccia, Ross Leckow, Ceyla Pazarbasioglu, and an IMF Staff Team
IMF Staff Discussion Note 13/01
February 13, 2013
http://www.imf.org/external/pubs/cat/longres.aspx?sk=40317.0

Summary: The SDN elaborates the case for, and the design of, a banking union for the euro area. It discusses the benefits and costs of a banking union, presents a steady state view of the banking union, elaborates difficult transition issues, and briefly discusses broader EU issues. As such, it assesses current plans and provides advice. It is accompanied by three background technical notes that analyze in depth the various elements of the banking union: a single supervisory framework; a single resolution and common safety net; and urgent issues related to repair of weak banks in Europe.

ISBN/ISSN: 9781475521160 / 2221-030X
Stock No: SDNEA2013001


Executive summary:
  • A banking union—a single supervisory-regulatory framework, resolution mechanism, and safety net—for the euro area is the logical conclusion of the idea that integrated banking systems require integrated prudential oversight.
  • The case for a banking union for the euro area is both immediate and longer term. Moving responsibility for potential financial support and bank supervision to a shared level can reduce fragmentation of financial markets, stem deposit flight, and weaken the vicious loop of rising sovereign and bank borrowing costs. In steady state, a single framework should bring a uniformly high standard of confidence and oversight, reduce national distortions, and mitigate the buildup of concentrated risk that compromises systemic stability. Time is of the essence.
  • Progress is required on all elements. A single supervisory mechanism (SSM) must ultimately supervise all banks, with clarity on duties, powers and accountability, and adequate resources. But without common resolution and safety nets and credible backstops, an SSM alone will do little to weaken vicious sovereign-bank links; they are necessary also to limit conflicts of interest between national authorities and the SSM. A single resolution authority, with clear ex ante burden-sharing mechanisms, must have strong powers to close or restructure banks and be required to intervene well ahead of insolvency. A common resolution/insurance fund, sized to resolve some small to medium bank failures, with access to common backstops for systemic situations, would add credibility and facilitate limited industry funding.
  • The challenge for policymakers is to stem the crisis while ensuring that actions dovetail seamlessly into the future steady state. Hence, agreeing at the outset on the elements, modalities, and resources for a banking union can help avoid the pitfalls of a piecemeal approach and an outcome that is worse than at the start. The December 2012 European Council agreement on an SSM centered at the European Central Bank (ECB) is an important step, but raises challenges that should not be underestimated. Meanwhile, to delink weak sovereigns from future residual banking sector risks, it will be important to undertake as soon as possible direct recapitalization of frail domestically systemic banks by the European Stability Mechanism (ESM). Failing, non-systemic banks should be wound down at least cost, and frail, domestically systemic banks should be resuscitated by shareholders, creditors, the sovereign, and the ESM.
  • A banking union is necessary for the euro area, but accommodating the concerns of non-euro area European Union (EU) countries will augur well for consistency with the EU single market.

Tuesday, February 12, 2013

Mortgage insurance: market structure, underwriting cycle and policy implications - Consultative paper released by the Joint Forum

Mortgage insurance: market structure, underwriting cycle and policy implications - Consultative paper released by the Joint Forum

February 2013
This consultative report on Mortgage insurance: market structure, underwriting cycle and policy implications examines the interaction of mortgage insurers with mortgage originators and underwriters. The report sets out the following recommendations directed at policymakers and supervisors with the aim of reducing the likelihood of mortgage insurance stress and failure in such tail events.
  1. Policymakers should consider requiring that mortgage originators and mortgage insurers align their interests;
  2. Supervisors should ensure that mortgage insurers and mortgage originators maintain strong underwriting standards;
  3. Supervisors should be alert to - and correct for - deterioration in underwriting standards stemming from behavioural incentives influencing mortgage originators and mortgage insurers;
  4. Supervisors should require mortgage insurers to build long-term capital buffers and reserves during the valleys of the underwriting cycle to cover claims during its peaks;
  5. Supervisors should be aware of and mitigate cross-sectoral arbitrage which could arise from differences in the accounting between insurers' technical reserves and banks' loan loss provisions, and from differences in the capital requirements for credit risk between banks and insurers; and
  6. Supervisors should apply the FSB Principles for Sound Residential Mortgage Underwriting Practices ("FSB Principles") to mortgage insurers noting that proper supervisory implementation necessitates both insurance and banking expertise.
Comments on this consultative report should be submitted by Tuesday 30 April 2013 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 (www.bis.org), IOSCO (www.iosco.org) and the IAIS (www.iaisweb.org) unless a commenter specifically requests confidential treatment.

Wednesday, January 23, 2013

Liquidity and Transparency in Bank Risk Management. By Lev Ratnovski

Liquidity and Transparency in Bank Risk Management. By Lev Ratnovski
IMF Working Paper No. 13/16
http://www.imf.org/external/pubs/cat/longres.aspx?sk=40258.0

Summary: Banks may be unable to refinance short-term liabilities in case of solvency concerns. To manage this risk, banks can accumulate a buffer of liquid assets, or strengthen transparency to communicate solvency. While a liquidity buffer provides complete insurance against small shocks, transparency covers also large shocks but imperfectly. Due to leverage, an unregulated bank may choose insufficient liquidity buffers and transparency. The regulatory response is constained: while liquidity buffers can be imposed, transparency is not verifiable. Moreover, liquidity requirements can compromise banks' transparency choices, and increase refinancing risk. To be effective, liquidity requirements should be complemented by measures that increase bank incentives to adopt transparency.

Conclusion

The paper emphasized that both liquidity buffers and — in a novel perspective — bank transparency (better communication that enhances access to external refinancing) are important in bank liquidity risk management. In a liquidity event, a liquidity buffer can cover small withdrawals with certainty. Transparency allows the bank to refinance large withdrawals too, but it is not always effective. Banks may choose insufficient liquidity and transparency; the optimal policy response is constrained by the fact that bank transparency is not verifiable.

The paper offers important policy implications, particularly for the ongoing liquidity regulation debate. The results caution that the focus on liquidity requirements needs to be complemented by measures to improve bank transparency and access to market refinancing. Without such measures, liquidity requirements may not achieve the full potential of improvements in social welfare, and under some conditions may have unintended effects. We also highlight the need for better corporate governance as a way to improve bank transparency, and the scope to use net stable funding ratios to increase the effectiveness of liquidity requirements.

Friday, January 18, 2013

Relying on financial models to set loan-loss reserves could hurt small banks and their customers

Bank Reform Takes One Flawed Step Forward. By Eugene A Ludwig and Paul A Volcker
Relying on financial models to set loan-loss reserves could hurt small banks and their customers.The Wall Street Journal
January 18, 2013, on page A15
http://online.wsj.com/article/SB10001424127887323468604578245421482083936.html

The Financial Accounting Standards Board finished 2012 on a high note, issuing a draft new rule to change the way banks build reserves against losses on loans. It is a major step forward from our current system. Still, FASB's proposed rule is flawed conceptually and in its application, and in itself it cannot achieve the international consistency that is desirable.

The good news: The board recognizes that its existing rules on the Allocation for Loan and Lease Losses may have worsened the 2008 financial crisis. These rules limited bank reserves to those that are already "incurred." This all but ensures that banks' rainy day funds will be too skinny, particularly in periods when credit markets are under stress. Worse yet, limiting loss estimates to events that have already occurred makes the allowance for loan and lease losses procyclical—reported earnings are too high in good times and losses hit hardest in bad times.

The FASB's draft proposal to reform these rules incorporates what is known as the "Current Expected Credit Loss Model." It is meant to expand reserves to reflect losses that are expected over the life of the loan, and it is a big improvement over the existing regime. But as it stands, the proposal could create risks for the financial system.

In an effort to ensure that everything is "auditable," the proposal ties the loan-loss reserve to what the accounting profession will decide is an acceptable "model." While the proposal is well-intentioned and makes clear that various models can be used, this model-driven approach is dangerous.

Modeling by its very nature is backward looking. It would push bankers to address only risks that are readily and historically quantifiable. It would discourage them from acting on forward-looking but less well-defined risks, like broader economic trends, that can be just as damaging.

A focus on modeling also unnecessarily favors large institutions. Banks with smaller loan books and more hands-on experience have some advantages when setting their reserves. But what community bank has a sufficient data set, a team of "modelers," or complex statistical analysis software on hand? The FASB proposal could hurt small banks and their customers.

That is not to say that some quantitative models have no place in establishing reserves. Some institutions may choose to use models, even slavishly. But this should not be a requirement, unless experience and judgment lead the bank's prudential regulator to think otherwise.

There are other ways to go about setting reserves. A bank can follow a rigorous, board-approved process, for example by drawing on well-documented reviews from its CEO, chief credit officer, and the credit committee of the board of directors. The assumptions used in these judgmental reviews can be audited by regulators and outside accountants, and implementation of the process itself can be audited. This approach can be honest and effective without relying entirely on mathematical models.

The FASB proposal may have at least one smaller-scale but serious flaw. Although the text is unclear, the proposal appears to base reserves on cash flows above all other credit factors, such as collateral. We understand that this is not what was intended, and that "cash flows" is meant to include monies derived from collateral liquidation too. If this is the case, the language should be clarified.

While we do believe it is critical to allow bankers to use their expertise in estimating losses for reserve purposes, we also believe it is critical that they disclose to regulators and the public both the methodology they employ to set reserves and the quarter-by-quarter decisions on reserves they actually make. That way investors can follow a bank's net revenue picture before and after loan reserves are set aside, and the methods they use to establish these reserves.

It would be highly desirable to have one international rule in this area, as with accounting standards in the financial services area generally. The International Accounting Standards Board is preparing a new standard for bank reserves. Both the FASB and the IASB approaches will be open to comment. The goal should be to achieve consistency along the broad lines opened by the FASB proposal.

In sum, the FASB's draft proposal is a positive step. But it will require revision so that small banks are not put at a disadvantage, and so that all banks can employ rational and effective methods to set aside their rainy day funds.

Mr. Ludwig, CEO of Promontory Financial Group, was comptroller of the currency from 1993 to 1998. Mr. Volcker was chairman of the Federal Reserve System from 1979-1987.

Monday, January 14, 2013

Incentive Audits: A New Approach to Financial Regulation

Incentive Audits: A New Approach to Financial Regulation. By Martin Cihak
World Bank Blogs, Jan 14, 2012
http://blogs.worldbank.org/allaboutfinance/incentive-audits-a-new-approach-to-financial-regulation

Economists often disagree on policy advice. If you ask 10 of them, you may get 10 different answers, or more. But from time to time, economists actually do agree. One such area of agreement relates to the role of incentives in the financial sector. A large and growing literature points to misaligned incentives playing a key role in the run-up to the global financial crisis. In a recent paper, co-authored with Barry Johnston, we propose to address the incentive breakdowns head-on by performing “incentive audits”.

The global financial crisis has highlighted the destructive impact of misaligned incentives in the financial sector. This includes bank managers’ incentives to boost short-term profits and create banks that are “too big to fail”, regulators’ incentives to forebear and withhold information from other regulators in stressful times, credit rating agencies’ incentives to keep issuing high ratings for subprime assets, and so on. Of course, incentives play an important role in many economic activities, not just the financial ones. But nowhere are they as prominent, and nowhere can their impact get as damaging as in the financial sector, due to its leverage, interconnectedness, and systemic importance. A large body of recent literature examines these issues in depth. For example, Caprio, Demirgüç-Kunt and Kane (2008) show that incentive conflicts explain how securitization went wrong and why credit ratings proved so inaccurate; Barth, Caprio and Levine (2012) highlight incentive failures in regulatory authorities. Incentives were not the only factor – they were accentuated by problems of insufficient information, herd behavior, and so on – but breakdowns in incentives had clearly a central role in the run-up to the crisis.

Despite the broad agreement among economists, the focus of financial sector regulation and supervision has often been on other things, leaving incentives to be addressed indirectly at best. At the global level, substantial efforts have been devoted to issues such as calibrating risk weights to calculate banks’ minimum capital requirements. Numerous outside observers have called for more concerted efforts to address the incentive breakdowns that led to the crisis (e.g., LSE 2010; Squam Lake Working Group 2010; and Beck 2010). At the individual country level, regulatory changes have taken place in recent years, but in-depth analyses show a major scope to better address incentive problems (see ÄŒihák, Demirgüç-Kunt, Martínez Pería, and Mohseni 2012, based on data from the World Bank’s 2011–12 Bank Regulation and Supervision Survey). The World Bank’s 2013 Global Financial Development Report also called for more vigorous steps to address incentive issues, rather than leaving them as an afterthought.

In a recent paper, joint with Barry Johnston, we propose a pragmatic approach to re-orienting financial regulation to have at its core addressing incentives on an ongoing basis. The paper, which of course represents our views and not necessarily those of the World Bank, proposes “incentive audits” as a tool to help in identifying incentive misalignments in the financial sector. The paper is an extended version of an earlier piece recognized by the International Centre for Financial Regulation and the Financial Times among top essays on “what good regulation should look like“.
The incentive audit approach aims to address systemic risk buildup directly at its source. While traditional, regulation-based approaches focus on building up capital and liquidity buffers in financial institutions, the incentive-based approach seeks to identify and correct distortions and frictions that contribute to the buildup of excessive risk. It goes beyond the symptoms to their source. For example, the buildup of massive risk concentrations before the crisis could be attributed to information gaps that prevented the assessment of exposures and network risks, to incentive failures in the monitoring of the risks due to conflicts of interest and moral hazard, and to regulatory incentives that encouraged risk transfers. Building up buffers can help, but to address systemic risk effectively, it is crucial to tackle the underlying incentives that give rise to it. Focusing on increasingly complex capital and liquidity charges has the danger of creating incentives for circumvention, and can run into limited capacity for implementation and enforcement. In the incentive-based approach, more emphasis is given on methods for identifying incentive failures resulting in systemic risk. The remedies go beyond narrowly defined prudential tools and include also other measures, such as elimination of tax incentives that encourage excessive borrowing.

What would an incentive audit involve? It would entail an analysis of structural and organizational features that affect incentives to conduct and monitor financial transactions. It would comprise a sequenced set of analyses proceeding from higher level questions on market structure, government safety nets and legal and regulatory framework, to progressively more detailed questions aimed at identifying the incentives that motivate and guide financial decisions (Figure 1). This sequenced approach enables drilling down and identifying factors leading to market failures and excessive risk taking.
Figure 1. The Design of Incentive Audits
The incentive audit is a novel concept, but analysis of incentives has been done. One example is the report of a parliamentary commission examining the roots of the Icelandic financial crisis. The report (Special Investigation Commission 2010) notes the rapid growth of Icelandic banks as a major contributor of the crisis. It documents the underlying “strong incentives for growth”, which included the banks’ incentive schemes and the high leverage of their owners. It maps out the network of conflicting interests of the key owners, who were also the largest debtors of these banks. Another example of work that is close to an incentive audit is the analysis by Calomiris (2011). He examines incentive failures in the U.S. financial market, and identifies a subset of reforms that are “incentive-robust,” that is, they improve market incentives, market discipline, and incentives of regulators and supervisors by making rules and their enforcement more transparent, increasing credibility and accountability. These examples illustrate that an incentive audit is doable and useful.

Who would perform incentive audits? Our paper offers some suggestions. The governance of the institution performing the audits is important--its own incentives to act need to be appropriately aligned. Also, to be effective, incentive audits would have to be performed regularly, and their outcomes would have to be used to address incentive issues by adapting regulation, supervision, and other measures. In Iceland, the analysis of incentives was a part of a “post mortem” on the crisis, but it is feasible to do such analysis ex-ante. Indeed, much of the information used in the above mentioned report was available even before the crisis. The Commission had modest resources, illustrating that incentive audits need not be very costly or overly complicated to perform. As the Commission’s report points out, “it should have been clear to the supervisory authorities that such incentives existed and that there was reason for concern,” but supervisors “did not keep up with the rapid changes in the banks’ practices”. Instead of examining the reasons for the changes, the supervisors took comfort in banks’ capital ratios exceeding a statutory minimum and appearing robust in narrowly-defined stress tests (ÄŒihák and Ong 2010).

An incentive audit needs to be complemented by other tools. It needs to be combined with quantitative risk assessment and with assessments of the regulatory, supervisory, and crisis preparedness frameworks. The audit provides an organizing framework, putting the identification and correction of incentive misalignments front and center.

Incentive audits are not a panacea, of course. Financial markets suffer from issues that go beyond misaligned incentives, such as limited rationality, herd behavior and so on. But better identifying and addressing incentive misalignments is a key practical step, and the incentive audits can help.

References
Barth, James, Gerard Caprio, and Ross Levine. 2012. Guardians of Finance: Making Regulators Work for Us, MIT Press.
Beck, Thorsten (ed). 2010. Future of Banking. Centre for Economic Policy Research (CEPR). Published by vox.eu.
Caprio, Gerard, Asli Demirgüç-Kunt, and Edward J. Kane. 2010. “The 2007 Meltdown in Structured Securitization: Searching for Lessons, not Scapegoats.” World Bank Research Observer 25 (1): 125-55.
Calomiris, Charles. 2011. Incentive‐Robust Financial Reform, Cato Journal  31 (3): 561–589.
ÄŒihák, Martin, Asli Demirgüç-Kunt, Maria Soledad Martínez Pería, and Amin Mohseni. 2012. “Banking Regulation and Supervision around the World: Crisis Update.” Policy Research Working Paper 6286, World Bank, Washington, DC.
ÄŒihák, Martin, Asli Demirgüç-Kunt, and R. Barry Johnston. 2013. “Incentive Audits: A New Approach to Financial Regulation.” Policy Research Working Paper 6308, World Bank, Washington, DC.
ÄŒihák, Martin, and Li Lian Ong. 2010. “Of Runes and Sagas: Perspectives on Liquidity Stress Testing Using an Iceland Example.” Working Paper 10/156, IMF, Washington, DC.
London School of Economics. 2010. The Future of Finance: The LSE Report. London: London School of Economics.
Special Investigation Commission. 2010. Report on the collapse of the three main banks in Iceland. Icelandic Parliament, April 12.
Squam Lake Working Group. 2010. Regulation of Executive Compensation in Financial Services. Squam Lake Working Group on Financial Regulation
World Bank. 2012. Global Financial Development Report 2013: Rethinking the Role of the State in Finance, World Bank, Washington DC.

Thursday, January 10, 2013

BCBS Principles for effective risk data aggregation and risk reporting

BCBS Principles for effective risk data aggregation and risk reporting
January 2013
http://www.bis.org/publ/bcbs239.htm

The financial crisis that began in 2007 revealed that many banks, including global systemically important banks (G-SIBs), were unable to aggregate risk exposures and identify concentrations fully, quickly and accurately. This meant that banks' ability to take risk decisions in a timely fashion was seriously impaired with wide-ranging consequences for the banks themselves and for the stability of the financial system as a whole.

The Basel Committee's Principles for effective risk data aggregation will strengthen banks' risk data aggregation capabilities and internal risk reporting practices. Implementation of the principles will strengthen risk management at banks - in particular, G-SIBs - thereby enhancing their ability to cope with stress and crisis situations.

An earlier version of the principles published today was issued for consultation in June 2012. The Committee wishes to thank those who provided feedback and comments as these were instrumental in revising and finalising the principles.

Objectives (excerpted):

The adoption of these Principles will enable fundamental improvements to the management of banks. The Principles are expected to support a bank’s efforts to:

• Enhance the infrastructure for reporting key information, particularly that used by the board and senior management to identify, monitor and manage risks;
• Improve the decision-making process throughout the banking organisation;
• Enhance the management of information across legal entities, while facilitating a comprehensive assessment of risk exposures at the global consolidated level;
• Reduce the probability and severity of losses resulting from risk management weaknesses;
• Improve the speed at which information is available and hence decisions can be made; and
• Improve the organisation’s quality of strategic planning and the ability to manage the risk of new products and services.

Tuesday, January 8, 2013

Capital Requirements for Over-the-Counter Derivatives Central Counterparties

Capital Requirements for Over-the-Counter Derivatives Central Counterparties. By Li Lin and Jay Surti
IMF Working Paper No. 13/3, January 08, 2013
http://www.imf.org/external/pubs/cat/longres.aspx?sk=40220.0

Summary: The central counterparties dominating the market for the clearing of over-the-counter interest rate and credit derivatives are globally systemic. Employing methodologies similar to the calculation of banks’ capital requirements against trading book exposures, this paper assesses the sensitivity of central counterparties’ required risk buffers, or capital requirements, to a range of model inputs. We find them to be highly sensitive to whether key model parameters are calibrated on a point-in-time versus stress-period basis, whether the risk tolerance metric adequately captures tail events, and the ability—or lack thereof—to define exposures on the basis of netting sets spanning multiple risk factors. Our results suggest that there are considerable benefits from having prudential authorities adopt a more prescriptive approach to for central counterparties’ risk buffers, in line with recent enhancements to the capital regime for banks.

ISBN: 9781475535501
ISSN: 2227-8885
Stock No: WPIEA2013003

Sunday, January 6, 2013

Group of Governors and Heads of Supervision endorses revised liquidity standard for banks

Group of Governors and Heads of Supervision endorses revised liquidity standard for banks
January 6, 2013
http://www.bis.org/press/p130106.htm

The Group of Governors and Heads of Supervision (GHOS), the oversight body of the Basel Committee on Banking Supervision, met today to consider the Basel Committee's amendments to the Liquidity Coverage Ratio (LCR) as a minimum standard. It unanimously endorsed them. Today's agreement is a clear commitment to ensure that banks hold sufficient liquid assets to prevent central banks becoming the "lender of first resort".

The GHOS also endorsed a new Charter for the Committee, and discussed the Committee's medium-term work agenda.

The GHOS reaffirmed the LCR as an essential component of the Basel III reforms. It endorsed a package of amendments to the formulation of the LCR announced in 2010. The package has four elements: revisions to the definition of high quality liquid assets (HQLA) and net cash outflows; a timetable for phase-in of the standard; a reaffirmation of the usability of the stock of liquid assets in periods of stress, including during the transition period; and an agreement for the Basel Committee to conduct further work on the interaction between the LCR and the provision of central bank facilities.

A summary description of the agreed LCR is in Annex 1. The changes to the definition of the LCR, developed and agreed by the Basel Committee over the past two years, include an expansion in the range of assets eligible as HQLA and some refinements to the assumed inflow and outflow rates to better reflect actual experience in times of stress. These changes are set out in Annex 2. The full text incorporating these changes will be published on Monday 7 January.

The GHOS agreed that the LCR should be subject to phase-in arrangements which align with those that apply to the Basel III capital adequacy requirements. Specifically, the LCR will be introduced as planned on 1 January 2015, but the minimum requirement will begin at 60%, rising in equal annual steps of 10 percentage points to reach 100% on 1 January 2019. This graduated approach is designed to ensure that the LCR can be introduced without disruption to the orderly strengthening of banking systems or the ongoing financing of economic activity.

The GHOS agreed that, during periods of stress it would be entirely appropriate for banks to use their stock of HQLA, thereby falling below the minimum. Moreover, it is the responsibility of bank supervisors to give guidance on usability according to circumstances.

The GHOS also agreed today that, since deposits with central banks are the most - indeed, in some cases, the only - reliable form of liquidity, the interaction between the LCR and the provision of central bank facilities is critically important. The Committee will therefore continue to work on this issue over the next year.

GHOS members endorsed two other areas of further analysis. First, the Committee will continue to develop disclosure requirements for bank liquidity and funding profiles. Second, the Committee will continue to explore the use of market-based indicators of liquidity to supplement the existing measures based on asset classes and credit ratings.

The GHOS discussed and endorsed the Basel Committee's medium-term work agenda. Following the successful agreement of the LCR, the Committee will now press ahead with the review of the Net Stable Funding Ratio. This is a crucial component in the new framework, extending the scope of international agreement to the structure of banks' debt liabilities. This will be a priority for the Basel Committee over the next two years.

Over the next few years, the Basel Committee will also: complete the overhaul of the policy framework currently under way; continue to strengthen the peer review programme established in 2012 to monitor the implementation of reforms in individual jurisdictions; and monitor the impact of, and industry response to, recent and proposed regulatory reforms. During 2012 the Committee has been examining the comparability of model-based internal risk weightings and considering the appropriate balance between the simplicity, comparability and risk sensitivity of the regulatory framework. The GHOS encouraged continuation of this work in 2013 as a matter of priority. Furthermore, the GHOS supported the Committee's intention to promote effective macro- and microprudential supervision.

The GHOS also endorsed a new Charter for the Basel Committee. The new Charter sets out the Committee's objectives and key operating modalities, and is designed to improve understanding of the Committee's activities and decision-making processes.

Finally, the GHOS reiterated the importance of full, timely and consistent implementation of Basel III standards.

Mervyn King, Chairman of the GHOS and Governor of the Bank of England, said, "The Liquidity Coverage Ratio is a key component of the Basel III framework. The agreement reached today is a very significant achievement. For the first time in regulatory history, we have a truly global minimum standard for bank liquidity. Importantly, introducing a phased timetable for the introduction of the LCR, and reaffirming that a bank's stock of liquid assets are usable in times of stress, will ensure that the new liquidity standard will in no way hinder the ability of the global banking system to finance a recovery."

Stefan Ingves, Chairman of the Basel Committee and Governor of the Sveriges Riksbank, noted that "the amendments to the LCR are designed to ensure that it provides a sound minimum standard for bank liquidity - a standard that reflects actual experience during times of stress. The completion of this work will allow the Basel Committee to turn its attention to refining the other component of the new global liquidity standards, the Net Stable Funding Ratio, which remains subject to an observation period ahead of its implementation in 2018."
Listen to the press conference

To listen to introductory remarks from GHOS Chairman Mervyn King and the Basel Committee on Banking Supervision's Chairman Stefan Ingves as well as the question and answer session which followed, please dial +41 58 262 07 00 and enter the following access code: 2641523333.

 
Translations in German, Spanish, French and Italian will be published soon.

Thursday, December 20, 2012

IMF's "European Union: Financial Sector Assessment," Preliminary Conclusions

"European Union: Financial Sector Assessment," Preliminary Conclusions by the IMF Staff
Press Release No. 12/500
Dec 20, 2012
http://www.imf.org/external/np/sec/pr/2012/pr12500.htm

A Financial Sector Assessment Program (FSAP) team led by the Monetary and Capital Markets Department of the International Monetary Fund (IMF) visited the European Union (EU) during November 27–December 13, 2012, to conduct a first-ever overall EU-wide assessment of the soundness and stability of the EU’s financial sector (EU FSAP). The EU FSAP builds on the 2011 European Financial Stability Exercise (EFFE) and on recent national FSAPs in EU member states.

The mission arrived at the following preliminary conclusions, which are subject to review and consultation with European institutions and national authorities:

The EU is facing great challenges, with continuing banking and sovereign debt crises in some parts of the Union. Significant progress has been made in recent months in laying the groundwork for strengthening the EU’s finacial sector. Implementation of policy decisions is needed. Although the breadth of the necessary agenda is significant, the details of the agreed frameworks need to be put in place to avoid delays in reaching consensus on key issues.

The present conjuncture makes management of the situation particularly difficult. The crisis reveals that handling financial system problems at the national level has been costly, calling for a Europe-wide approach. Interlinkages among the countries of the EU are particularly pronounced, and the need to provide more certainty on the health of banks has led to proposals for establishing a single supervisory mechanism (SSM) associated with the European Central Bank (ECB), initially for the euro area but potentially more widely in the EU.


The mission’s recommendations include the following:

Steps toward banking union
The December 13 EU Council agreement on the SSM is a strong achievement. It needs to be followed up with a structure that has as few gaps as possible, including with regard to the interaction of the SSM with national authorities under the prospective harmonized resolution and deposit guarantee arrangements. The SSM is only an initial step toward an effective Banking Union—actions toward a single resolution authority with common backstops, a deposit guarantee scheme, and a single rulebook, will also be essential.

Reinvigorating the single financial market in Europe
Harmonization of the regulatory structure across Europe needs to be expedited. EU institutions should accelerate passage of the Fourth Capital Requirements Directive, the Capital Requirements Regulation, the directives for harmonizing resolution and deposit insurance, as well as the regulatory regime for insurance Solvency II at the latest by mid–2013, thus enabling the issuance of single rulebooks for banking, insurance, and securities. Moreover, the European Commission should increase the resources and powers of the European Supervisory Authorities as needed to successfully achieve those mandates, while also enhancing their operational independence.

Improved and expanded stress testing
European stress testing needs to go beyond microprudential solvency, and increasingly serve to identify other vulnerabilities, such as liquidity risks and structural weaknesses. Confidence in the results of stress tests can be enhanced by an asset quality review, harmonized definitions of non-performing loans, and standardized loan classification, while maintaining a high level of disclosure. Experience suggests that the benefits of a bold approach outweigh the risks.

Splitting bank and sovereign risk
Measures must be pursued to separate bank and sovereign risk, including by making the ESM operational expeditiously for bank recapitalizations. Strong capital buffers will be important for the banks to perform their intermediating role effectively, to stimulate growth, and so safeguard financial stability.

Effective crisis management framework to minimize costs to taxpayers
Taxpayers’ potential liability following bank failures can be reduced by resolution regimes that include statutory bail-in powers. A common deposit insurance fund, preferably financed ex ante by levies on the banking sector, could also reduce the cost to taxpayers, even if it takes time to build up reserves. Granting preferential rights to depositor guarantee schemes in the creditor hierarchy could also reduce costs, particularly while guarantee funds are being built.

The European Commission and member states should assess the costs and benefits of the various plans for structural measures aimed at reducing banks’ complexity and potential taxpayer liability with a view towards formulating a coordinated proposal. If adopted, it would be important to ensure that such measures are complementary to the international reform agenda, not cause distortions in the single market, and not lead to regulatory arbitrage.

Lastly, the mission would like to extend their thanks to European institutions for close cooperation and assistance in completing this FSAP analysis.

Wednesday, December 19, 2012

The future of financial globalisation - BIS Annual Conference

The future of financial globalisation
http://www.bis.org/publ/bppdf/bispap69.htm

The BIS 11th Annual Conference took place in Lucerne, Switzerland on 21-22 June 2012. The event brought together senior representatives of central banks and academic institutions, who exchanged views on the conference theme of "The future of financial globalisation". This volume contains the opening address of Stephen Cecchetti (Economic Adviser, BIS), a keynote address from Amartya Sen (Harvard University), and the available contributions of the policy panel on "Will financial globalisation survive?". The participants in the policy panel discussion, chaired by Jaime Caruana (General Manager, BIS), were Ravi Menon (Monetary Authority of Singapore), Jacob Frenkel (JP Morgan Chase International) and José Dario Uribe Escobar (Banco de la Repubblica).

The papers presented at the conference and the discussants' comments are released as BIS Working Papers 397 to 400:

Financial Globalisation and the Crisis, BIS Working Papers No 397
by  Philip R. Lane
Comments by Dani Rodrik

The global financial crisis provides an important testing ground for the financial globalisation model. We ask three questions. First, did financial globalisation materially contribute to the origination of the global financial crisis? Second, once the crisis occurred, how did financial globalisation affect the incidence and propagation of the crisis across different countries? Third, how has financial globalisation affected the management of the crisis at national and international levels?


The great leveraging, BIS Working Papers No 398
by  Alan M. Taylor
Comments by Barry Eichengreen and Dr. Y V Reddy 

What can history can tell us about the relationship between the banking system, financial crises, the global economy, and economic performance? Evidence shows that in the advanced economies we live in a world that is more financialized than ever before as measured by importance of credit in the economy. I term this long-run evolution "The Great Leveraging" and present a ten-point examination of its main contours and implications.


Global safe assets, BIS Working Papers No 399
by Pierre-Olivier Gourinchas and Olivier Jeanne
Comments by Peter R Fisher and Fabrizio Saccomanni

Will the world run out of 'safe assets' and what would be the consequences on global financial stability? We argue that in a world with competing private stores of value, the global economic system tends to favor the riskiest ones. Privately produced stores of value cannot provide sufficient insurance against global shocks. Only public safe assets may, if appropriately supported by monetary policy. We draw some implications for the global financial system.


Capital Flows and the Risk-Taking Channel of Monetary Policy, BIS Working Papers No 400
by Valentina Bruno and Hyun Song Shin
Comments by Lars E O Svensson and John B Taylor

This paper examines the relationship between low interests maintained by advanced economy central banks and credit booms in emerging economies. In a model with crossborder banking, low funding rates increase credit supply, but the initial shock is amplified through the "risk-taking channel" of monetary policy where greater risk-taking interacts with dampened measured risks that are driven by currency appreciation to create a feedback loop. In an empirical investigation using VAR analysis, we find that expectations of lower short-term rates dampen measured risks and stimulate cross-border banking sector capital flows.