Margin requirements for non-centrally-cleared derivatives - BIS consultative document

Margin requirements for non-centrally-cleared derivatives - consultative document
BIS, July 2012
http://www.bis.org/publ/bcbs226.htm

The G20 Leaders agreed in 2011 to add margin requirements on non-centrally-cleared derivatives to the reform programme for over-the-counter (OTC) derivatives markets. Margin requirements can further mitigate systemic risk in the derivatives markets. In addition, they can encourage standardisation and promote central clearing of derivatives by reflecting the generally higher risk of non-centrally-cleared derivatives. The consultative paper published today lays out a set of high-level principles on margining practices and treatment of collateral, and proposes margin requirements for non-centrally-cleared derivatives.

These policy proposals are articulated through a set of key principles that primarily seek to ensure that appropriate margining practices will be established for all non-centrally-cleared OTC derivative transactions. These principles will apply to all transactions that involve either financial firms or systemically important non-financial entities.

The Basel Committee and IOSCO would like to solicit feedback from the public on questions related to the scope, feasibility and impact of the margin requirements. Responses to the public consultation, together with the QIS results, will be considered in formulating a final joint proposal on margin requirements on non-centrally-cleared derivatives by year-end.


Excerpts:

Objectives of margin requirements for non-centrally-cleared derivatives
Margin requirements for non-centrally-cleared derivatives have two main benefits:

Reduction of systemic risk. Only standardised derivatives are suitable for central clearing. A substantial fraction of derivatives are not standardised and will not be able to be cleared.4 These non-centrally-cleared derivatives, which total hundreds of trillions of dollars of notional amounts,5 will pose the same type of systemic contagion and spillover risks that materialised in the recent financial crisis. Margin requirements for non-centrally-cleared derivatives would be expected to reduce contagion and spillover effects by ensuring that collateral are available to offset losses caused by the default of a derivatives counterparty. Margin requirements can also have broader macroprudential benefits, by reducing the financial system’s vulnerability to potentially de-stabilising procyclicality and limiting the build-up of uncollateralised exposures within the financial system.

Promotion of central clearing. In many jurisdictions central clearing will be mandatory for most standardised derivatives. But clearing imposes costs, in part because CCPs require margin to be posted. Margin requirements on non-centrally-cleared derivatives, by reflecting the generally higher risk associated with these derivatives, will promote central clearing, making the G20’s original 2009 reform program more effective. This could, in turn, contribute to the reduction of systemic risk.

The effectiveness of margin requirements could be undermined if the requirements were not consistent internationally. Activity could move to locations with lower margin requirements, raising two concerns:
  The effectiveness of the margin requirements could be undermined (ie regulatory arbitrage).
  Financial institutions that operate in the low-margin locations could gain a competitive advantage (ie unlevel playing field).


Margin and capital

Both capital and margin perform important risk mitigation functions but are distinct in a number of ways. First, margin is “defaulter-pay”. In the event of a counterparty default, margin protects the surviving party by absorbing losses using the collateral provided by the defaulting entity. In contrast, capital adds loss absorbency to the system, because it is “survivor-pay”, using capital to meet such losses consumes the surviving entity’s own financial resources. Second, margin is more “targeted” and dynamic, with each portfolio having its own designated margin for absorbing the potential losses in relation to that particular portfolio, and with such margin being adjusted over time to reflect changes in the risk of that portfolio. In contrast, capital is shared collectively by all the entity’s activities and may thus be more easily depleted at a time of stress, and is difficult to rapidly adjust to reflect changing risk exposures. Capital requirements against each exposure are not designed to be sufficient to cover the loss on the default of the counterparty but rather the probability weighted loss given such default. For these reasons, margin can be seen as offering enhanced protection against counterparty credit risk where it is effectively implemented. In order for margin to act as an effective risk mitigant, that margin must be (i) accessible at the time of need and (ii) in a form that can be liquidated rapidly in a period of financial stress at a predictable price.

The interaction between capital and margin, however, is complex and is an area in which the full range of interactions needs further careful consideration. When calibrating the application of capital and margin, consideration must be given to factors such as: (i) differences in capital requirements across different types of entities; (ii) the effect certain margin requirements may have on the capital calculations of different types of regulated entities subject to differing capital requirements; and (iii) the current asymmetrical treatment of collateral in many regulatory capital frameworks where benefit is given for collateral received, but no cost is incurred for the (encumbrance) risks of collateral posted.


Impact of margin requirements on liquidity

The potential benefits of margin requirements must be weighed against the liquidity impact that would result from derivative counterparties’ need to provide liquid, high-quality collateral to meet those requirements, including potential changes to market functioning as result of an increasing demand for such collateral in the aggregate. Financial institutions may need to obtain and deploy additional liquidity resources to meet margin requirements that exceed current practices. Moreover, the liquidity impact of margin requirements cannot be considered in isolation. Rather, it is important to recognise ongoing and parallel regulatory initiatives that will also have significant liquidity impacts; examples of such initiatives include the BCBS’s Liquidity Coverage Ratio (LCR), Net Stable Funding Ratio (NSFR) and global mandates for central clearing of standardised derivatives.

The US SEC has pointed out that the proposed margin requirements could have a much greater impact on securities firms regulated under net capital rules. Under such rules, securities firms are required to maintain at all times a minimum level of ‘net capital” (meaning highly liquid capital) in excess of all subordinated liabilities. When calculating the “net capital”, the firm must deduct all assets that cannot be readily convertible into cash, and adjust the value of liquid assets by appropriate haircuts. As such, in computing “net capital”, assets that are delivered by the firm to another party as margin collateral are treated as unsecured receivables from the party holding the collateral and are thus deducted in full when calculating net capital.

As discussed in Part C of this consultative paper, the BCBS and IOSCO plan to conduct a quantitative impact study (QIS) in order to gauge the impact of the margin proposals. In particular, the QIS will assess the amount of margin required on non-centrally-cleared derivatives as well as the amount of available collateral that could be used to satisfy these requirements. The QIS will be conducted during the consultation period, and its results will inform the BCBS’s and IOSCO’s joint final proposal.


Macroprudential considerations

The BCBS and IOSCO also note that national supervisors may wish to establish margin requirements for non-centrally-cleared derivatives that, in addition to achieving the two principal benefits noted above, also create other desirable macroprudential outcomes. Further work by the relevant authorities is likely required to consider the details of how such outcomes might be identified and operationalised. The BCBS and IOSCO encourage further consideration of other potential macroprudential benefits of margin requirements for non-centrally-cleared derivatives and of the need for international coordination that may arise in this respect.

The (Other) Deleveraging. By Manmohan Singh

The (Other) Deleveraging. By Manmohan Singh
IMF Working Paper No. 12/179
July 2012
http://www.imfbookstore.org/IMFORG/WPIEA2012179

Summary: Deleveraging has two components--shrinking of balance sheets due to increased haircuts/shedding of assets, and the reduction in the interconnectedness of the financial system. We focus on the second aspect and show that post-Lehman there has been a significant decline in the interconnectedness in the pledged collateral market between banks and nonbanks. We find that both the collateral and its associated velocity are not rebounding as of end-2011 and still about $4-5 trillion lower than the peak of $10 trillion as of end-2007. This paper updates Singh (2011) and we use this data to compare with the monetary aggregates (largely due to QE efforts in US, Euro area and UK), and discuss the overall financial lubrication that likely impacts the conduct of global monetary policy.


Excerpts:

Deleveraging from shrinking of bank balance sheets is not (yet) taking place; however, we still find the financial system imploding.

The reduction in debt (or deleveraging) has two components. The first (and more familiar) involves the shrinking of balance sheets. The other is a reduction in the interconnectedness of the financial system (Figure 1). Most recent researchers have focused on the impact of smaller balance sheets, overlooking this ‘other’ deleveraging resulting from reduced interconnectedness. Yet, as the current crisis unfolds, key actors in the global financial system seem to be “ring fencing” themselves owing to heightened counterparty risk. While “rational” from an individual perspective, this behavior may have unintended consequences for the financial markets.

The interconnections nexus has become considerably more complex over the past two decades.  The interconnectedness of the financial system aspect may be viewed from the lens of collateral chains. Typically, collateral from hedge funds, pension, insurers, central banks etc., is intermediated by the large global banks. For example, a Hong Kong hedge fund may get financing from UBS secured by its collateral. This collateral may include, say, Indonesian bonds which will be pledged to UBS, (U.K.) for re-use. There may be demand for such bonds from, for instance, a pension fund in Chile who may have Santander as its global bank.  However, due to heightened counterparty risk, UBS may not want to onward pledge to Santander, despite demand for the collateral with UBS. Fewer trusted counterparties in the market owing to elevated counterparty risk leads to stranded liquidity pools, incomplete markets, idle collateral and shorter collateral chains, missed trades and deleveraging. In volume terms, over the past decade this collateral use has become on par with monetary aggregates like M2.

The balance sheet shrinking due to ‘price decline’ (i.e., increased haircuts) has been studied extensively [...]. But the balance sheet shrinkage is being postponed—Euro area bank balance sheets may have increased up to €500bn since the end of November, 2011 helped by the liquidity injection from ECB’s 3-year Long Term Repo Operations or LTROs (net of reduced Monthly Repurchase Operations, MROs).

However, de-leveraging of the financial system due to the shortening of ‘re-pledging chains’ has not (yet) received attention. This deleveraging is taking place despite the recent official sector support. This second component of deleveraging is contributing towards the higher credit cost to the real economy. In fact, relative to 2006, the primary indices that measure aggregate borrowing cost are well over 2.5 times in the U.S. and 4 times in the Eurozone (see Figure 2). This is after adjusting for the central bank rate cuts which have lowered the total cost of borrowing for similar corporates (e.g., in the U.S., from about 6% in 2006 to about 4% at present). Figure 3 shows that for the past three decades, the cost of borrowing for financials has been below non-financials; however this has changed post-Lehman. Since much of the real economy resorts to banks to borrow (aside from the large industrials), the higher borrowing cost for banks is then passed on the real economy.

As the “other” deleveraging continues, the financial system remains short of high-grade collateral that can be re-pledged. Recent official sector efforts such as ECB’s “flexibility” (and the ELA programs of national central banks in the Eurozone) in accepting “bad” collateral attempts to keep the good/bad collateral ratio in the market higher than otherwise. ECB’s acceptance of good and bad collateral at non market price brings Gresham's law into play. But, if such moves become part of the central banker’s standard toolkit, the fiscal aspects and risks associated with such policies cannot be ignored. By so doing, the central banks have interposed themselves as risk-taking intermediaries with the potential to bring significant unintended consequences.

Paths to Eurobonds

Paths to Eurobonds. By Stijn Claessens, Ashoka Mody, and Shahin Vallée
July, 2012
IMF Working Paper No. 12/172
http://www.imfbookstore.org/ProdDetails.asp?ID=WPIEA2012172

Summary: This paper discusses proposals for common euro area sovereign securities. Such instruments can potentially serve two functions: in the short-term, stabilize financial markets and banks and, in the medium-term, help improve the euro area economic governance framework through enhanced fiscal discipline and risk-sharing. Many questions remain on whether financial instruments can ever accomplish such goals without bold institutional and political decisions, and, whether, in the absence of such decisions, they can create new distortions. The proposals discussed are also not necessarily competing substitutes; rather, they can be complements to be sequenced along alternative paths that possibly culminate in a fully-fledged Eurobond. The specific path chosen by policymakers should allow for learning and secure the necessary evolution of institutional infrastructures and political safeguards.

Excerpts:

The European Monetary Union was purposefully designed as a monetary union without a fiscal union. History has not been kind to such arrangements, as Bordo et al. (2011) argue and as several critics had warned before the eurozone came into being (for a review of that earlier literature, see Bornhorst, Mody, and Ohnsorge, forthcoming). The ongoing crisis appears to have validated these concerns. The absence of formal pooling of resources has required the construction of additional arrangements for inter-governmental fiscal support to respond to countries in crisis. These arrangements include the European Financial Stability Facility (EFSF) and the European Stability Mechanism (ESM). And as the crisis has evolved, the European Central Bank (the ECB) has needed to play an important role in supporting banks and, indirectly, sovereigns in need.

In this context, the common issuance of debt in the euro area has been increasingly evoked— including most recently by the European Parliament and the European Council—both as an immediate response to the financial crisis and as a structural feature of the monetary union.

This paper is a review of various proposals for common debt issuance. Clearly, common instruments are not the only or necessarily the primary way to reduce financial instability or improve economic, financial and fiscal governance in the euro area. Indeed, common debt issuance is inextricably linked to the shape and form of a future fiscal union. Because a fiscal (and banking) union is likely a longer-term project, a discussion of common instruments today can help sharpen the discussion of the choices underlying a fiscal union and possibly initiate more limited forms of risk-sharing and pooling that create a valuable learning process.

In undertaking this review, we are motivated by the following questions:

* How does the proposal change incentives of governments (debtors) and creditors?  Does it offer clarity on how average and marginal costs of borrowing would be affected, and how default would be treated?

* What is the nature of the insurance that is being offered? Would the new instrument help reduce risk and improve liquidity? Who will want to hold those instruments?

* Would the (currently perverse) sovereign-bank linkages be reduced? What are effects on current financial markets (ill)functioning?

* What are the phasing-in, transitional, legal, and institutional issues?

* And, are there paths along which the different proposed instruments may be combined?

Conclusions

Common debt could bring reprieve from current financial instability. Specifically, the creation of a large safe asset can reduce flight to safety from one sovereign to another and weaken the links between banks and their respective sovereigns that are currently destabilizing. Common debt issuance could also be a structural stabilizing feature of the euro area by helping to create deeper and more liquid financial markets allowing the monetary union to capture the liquidity gains of a broader sovereign debt market. Importantly, these initiatives can serve to focus attention on the need for fiscal federalism including macroeconomic stabilization and risk-sharing mechanisms but also fiscal discipline.

But there clearly are risks associated with such common instruments. In terms of fiscal discipline, the pricing approaches, where countries’ own debt is lower ranked and hence pays a higher price, are intriguing. But the tranching creates new challenges, not least if the junior tranches replicate the instability that we are currently witnessing. Similarly, to the extent that funds are earmarked to repay the common debt, greater pro-cyclicality may ensue as earmarked resources are less available to deal with adverse shocks.

Ideally then, common debt should follow from a fundamental discussion of the long-term shape of a fiscal, financial and monetary union. The absence of a debate on fiscal union reflects in part historical concerns that one group of countries may become dependent on another group on a permanent basis. But short of addressing these fundamental issues completely, common debt issuance can initiate a political process towards this goal. If, for the moment, there is only appetite for limited and bounded fiscal risk-sharing, then the Eurobills can start a learning process. These could be scaled up if proven successful and evolve towards more ambitious structures. If the assessment is that a key task today is to bring debt-to-GDP ratios down before further progress can be made, then the Redemption Pact is the right first step. But this would take 20-25 years and delay the creation of a permanent mechanism to complete the monetary union.

Thus, addressing both the current debt overhang problem and insuring against loss of market access likely requires combining several proposals. And while a gradual phase-in provides some advantages, in particular as it can foster a political discussion about fiscal risk-sharing and transfers, the current financial crisis might call for more rapid introduction. Regardless, steps towards common debt issuance require an open political discussion given the importance of accountability and legitimacy dimensions associated with the embryonic creation of a fiscal union. Federations are not static political constructs and common debt issuance can both contribute to effective economic management and act as a catalyst for political change. In that sense, the proposals put forward are a constructive feature of the ongoing discussion, forcing a critical and focused rethinking of the EMU architecture.

Monitoring indicators for intraday liquidity management - consultative document

Basel Committee, July 2012

Intraday liquidity can be defined as funds that are accessible during the business day, usually to enable financial institutions to make payments in real time. The Basel Committee's proposed Monitoring indicators for intraday liquidity management are intended to allow banking supervisors to monitor a bank's intraday liquidity risk management. Over time, the indicators will also help supervisors to gain a better understanding of banks' payment and settlement behaviour and their management of intraday liquidity risk.

The Basel Committee welcomes comments on this consultative document. Comments should be submitted by Friday 14 September 2012 by e-mail 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 website of the Bank for International Settlements unless a comment contributor specifically requests confidential treatment. 

http://www.bis.org/publ/bcbs225.htm

Jonathan Haidt's The Righteous Mind: Why Good People Are Divided by Politics and Religion

Jonathan Haidt: He Knows Why We Fight. By Holman W Jenkins, Jr
Conservative or liberal, our moral instincts are shaped by evolution to strengthen 'us' against 'them.'
The Wall Street Journal, June 30, 2012, page A13
http://online.wsj.com/article/SB10001424052702303830204577446512522582648.html

Nobody who engages in political argument, and who isn't a moron, hasn't had to recognize the fact that decent, honest, intelligent people can come to opposite conclusions on public issues.

Jonathan Haidt, in an eye-opening and deceptively ambitious best seller, tells us why. The reason is evolution. Political attitudes are an extension of our moral reasoning; however much we like to tell ourselves otherwise, our moral responses are basically instinctual, despite attempts to gussy them up with ex-post rationalizations.

Our constellation of moral instincts arose because it helped us to cooperate. It helped us, in unprecedented speed and fashion, to dominate our planet. Yet the same moral reaction also means we exist in a state of perpetual, nasty political disagreement, talking past each other, calling each other names.

So Mr. Haidt explains in "The Righteous Mind: Why Good People Are Divided by Politics and Religion," undoubtedly one of the most talked-about books of the year. "The Righteous Mind" spent weeks on the hardcover best-seller list. Mr. Haidt considers himself mostly a liberal, but his book has been especially popular in the conservative blogosphere. Some right-leaning intellectuals are even calling it the most important book of the year.

It's full of ammunition that conservatives will love to throw out at cocktail parties. His research shows that conservatives are much better at understanding and anticipating liberal attitudes than liberals are at appreciating where conservatives are coming from. Case in point: Conservatives know that liberals are repelled by cruelty to animals, but liberals don't think (or prefer not to believe) that conservatives are repelled too.

Mr. Haidt, until recently a professor of moral psychology at the University of Virginia, says the surveys conducted by his research team show that liberals are strong on evolved values he defines as caring and fairness. Conservatives value caring and fairness too but tend to emphasize the more tribal values like loyalty, authority and sanctity.

Conservatives, Mr. Haidt says, have been more successful politically because they play to the full spectrum of sensibilities, and because the full spectrum is necessary for a healthy society. An admiring review in the New York Times sums up this element of his argument: "Liberals dissolve moral capital too recklessly. Welfare programs that substitute public aid for spousal and parental support undermine the ecology of the family. Education policies that let students sue teachers erode classroom authority. Multicultural education weakens the cultural glue of assimilation."

Such a book is bound to run into the charge of scientism—claiming scientific authority for a mix of common sense, exhortation or the author's own preferences. Let it be said that Mr. Haidt is sensitive to this complaint. If he erred, he says, it was on the side of being accessible, readable and, he hopes, influential.

As we sit in his new office at New York University, he professes an immodest aim: He wants liberals and conservatives to listen to each other more, hate each other less, and to understand that their differences are largely rooted in psychology, not open-minded consideration of the facts. "My big issue, the one I'm somewhat evangelical about, is civil disagreement," he says.

A shorthand he uses is "follow the sacred"—and not in a good way. "Follow the sacred and there you will find a circle of motivated ignorance." Today's political parties are most hysterical, he says, on the issues they "sacralize." For the right, it's taxes. For the left, the sacred issues were race and gender but are becoming global warming and gay marriage.

Yet between the lines of his book is an even more dramatic claim: The same moral psychology that makes our politics so nasty also underlies the amazing triumph of the human species. "We shouldn't be here at all," he tells me. "When I think about life on earth, there should not be a species like us. And if there was, we should be out in the jungle killing each other in small groups. That's what you should expect. The fact that we're here [in politics] arguing viciously and nastily with each other, and no guns, that itself is a miracle. And I think we can make [our politics] a little better. That's my favorite theme."

Who is Jon Haidt? A nice Jewish boy from central casting, he grew up in Scarsdale, N.Y. His father was a corporate lawyer. "When the economy opened out in the '50s and '60s and Jews could go everywhere, he was part of that generation. He and all his buddies from Brooklyn did very well."

His family was liberal in the FDR tradition. At Yale he studied philosophy and, in standard liberal fashion, "emerged pretty convinced that I was right about everything." It took a while for him to discover the limits of that stance. "I wouldn't say I was mugged by reality. I would say I was gradually introduced to it academically," he says today.

In India, where he performed field studies early in his professional career, he encountered a society in some ways patriarchal, sexist and illiberal. Yet it worked and the people were lovely. In Brazil, he paid attention to the experiences of street children and discovered the "most dangerous person in the world is mom's boyfriend. When women have a succession of men coming through, their daughters will get raped," he says. "The right is right to be sounding the alarm about the decline of marriage, and the left is wrong to say, 'Oh, any kind of family is OK.' It's not OK."

At age 41, he decided to try to understand what conservatives think. The quest was part of his effort to apply his understanding of moral psychology to politics. He especially sings the praises of Thomas Sowell's "Conflict of Visions," which he calls "an incredible book, a brilliant portrayal" of the argument between conservatives and liberals about the nature of man. "Again, as a moral psychologist, I had to say the constrained vision [of human nature] is correct."

That is, our moral instincts are tribal, adaptive, intuitive and shaped by evolution to strengthen "us" against "them." He notes that, in the 1970s, the left tended to be categorically hostile to evolutionary explanations of human behavior. Yet Mr. Haidt, the liberal and self-professed atheist, says he now finds the conservative vision speaks more insightfully to our evolved nature in ways that it would be self-defeating to discount.

"This is what I'm trying to argue for, and this is what I feel I've discovered from reading a lot of the sociology," he continues. "You need loyalty, authority and sanctity"—values that liberals are often suspicious of—"to run a decent society."

Mr. Haidt, a less chunky, lower-T version of Adam Sandler, has just landed a new position at the Stern School of Business at NYU. He arrived with his two children and wife, Jane, after a successful and happy 16-year run at the University of Virginia. An introvert by his own account, and never happier than when laboring in solitude, he nevertheless sought out the world's media capital to give wider currency to the ideas in the "The Righteous Mind."

Mr. Haidt's book, as he's the first to notice, has given comfort to conservatives. Its aim is to help liberals. Though he calls himself a centrist, he remains a strongly committed Democrat. He voted for one Republican in his life—in 2000 crossing party lines to cast a ballot for John McCain in the Virginia primary. "I wasn't trying to mess with the Republican primary," he adds. "I really liked McCain."

His disappointment with President Obama is quietly evident. Ronald Reagan understood that "politics is more like religion than like shopping," he says. Democrats, after a long string of candidates who flogged policy initiatives like items in a Wal-Mart circular, finally found one who could speak to higher values than self-interest. "Obama surely had a chance to remake the Democratic Party. But once he got in office, I think, he was consumed with the difficulty of governing within the Beltway."

The president has reverted to the formula of his party—bound up in what Mr. Haidt considers obsolete interest groups, battles and "sacred" issues about which Democrats cultivate an immunity to compromise.

Mr. Haidt lately has been speaking to Democratic groups and urging attachment to a new moral vision, albeit one borrowed from the Andrew Jackson campaign of 1828: "Equal opportunity for all, special privileges for none."

Racial quotas and reflexive support for public-sector unions would be out. His is a reformed vision of a class-based politics of affirmative opportunity for the economically disadvantaged. "I spoke to some Democrats about things in the book and they asked, how can we weaponize this? My message to them was: You're not ready. You don't know what you stand for yet. You don't have a clear moral vision."

Like many historians of modern conservatism, he cites the 1971 Powell Memo—written by the future Supreme Court Justice Lewis Powell Jr.—which rallied Republicans to the defense of free enterprise and limited government. Democrats need their own version of the Powell Memo today to give the party a new and coherent moral vision of activist government in the good society. "The moral rot a [traditional] liberal welfare state creates over generations—I mean, the right is right about that," says Mr. Haidt, "and the left can't see it."

Yet one challenge becomes apparent in talking to Mr. Haidt: He's read his book and cheerfully acknowledges that he avoids criticizing too plainly the "sacralized" issues of his liberal friends.

In his book, for instance, is passing reference to Western Europe's creation of the world's "first atheistic societies," also "the least efficient societies ever known at turning resources (of which they have a lot) into offspring (of which they have very few)."

What does he actually mean? He means Islam: "Demographic curves are very hard to bend," he says. "Unless something changes in Europe in the next century, it will eventually be a Muslim continent. Let me say it diplomatically: Most religions are tribal to some degree. Islam, in its holy books, seems more so. Christianity has undergone a reformation and gotten some distance from its holy books to allow many different lives to flourish in Christian societies, and this has not happened in Islam."

Mr. Haidt is similarly tentative in spelling out his thoughts on global warming. The threat is real, he suspects, and perhaps serious. "But the left is now embracing this as their sacred issue, which guarantees that there will be frequent exaggerations and minor—I don't want to call it fudging of data—but there will be frequent mini-scandals. Because it's a moral crusade, the left is going to have difficulty thinking clearly about what to do."

Mr. Haidt, I observe, is noticeably less delicate when stepping on the right's toes. He reviles George W. Bush, whom he blames for running up America's debt and running down its reputation. He blames Newt Gingrich for perhaps understanding his book's arguments too well and importing an uncompromising moralistic language into the partisan politics of the 1990s.

Mr. Haidt also considers today's Republican Party a curse upon the land, even as he admires conservative ideas. He says its defense of lower taxes on capital income—mostly reported by the rich—is indefensible. He dismisses Mitt Romney as a "moral menial," a politician so cynical about the necessary cynicism of politics that he doesn't bother to hide his cynicism. (Some might call that a virtue.) He finds it all too typical that Republicans abandoned their support of the individual health-care mandate the moment Mr. Obama picked it up (though he also finds Chief Justice John Roberts's bend-over-backwards effort to preserve conservative constitutional principle while upholding ObamaCare "refreshing").

Why is his language so much less hedged when discussing Republicans? "Liberals are my friends, my colleagues, my social world," he concedes. Liberals also are the audience he hopes most to influence, helping Democrats to recalibrate their political appeal and their attachment to a faulty welfare state.

To which a visitor can only say, God speed. Even with his parsing out of deep psychological differences between conservatives and liberals, American politics still seem capable of a useful fluidity. To make progress we need both parties, and right now we could use some progress on taxes, incentives, growth and entitlement reform.

Mr. Jenkins writes the Journal's Business World column.

A framework for dealing with domestic systemically important banks - consultative document

June 2012

The consultative document sets out a framework of principles covering the assessment methodology and the higher loss absorbency requirement for domestic systemically important banks (D-SIBs). The D-SIB framework takes a complementary perspective of the global systemically important bank (G-SIB) framework published by the Basel Committee in November 2011. It focuses on the impact that the distress or failure of banks will have on the domestic economy. While not all D-SIBs are significant from a global perspective, the failure of such a bank could have an important impact on its domestic financial system and economy compared to non-systemic institutions. In order to accommodate the structural characteristics of individual jurisdictions, the assessment and application of policy tools should allow for an appropriate degree of national discretion. That is why the D-SIB framework is proposed to be a principles-based approach, which contrasts with the prescriptive approach in the G-SIB framework.

The proposed D-SIB framework requires banks, which have been identified as D-SIBs by their national authorities, to comply with the principles beginning in January 2016. This is consistent with the phase-in arrangements for the G-SIB framework and means that national authorities will establish a D-SIB framework by 2016. The Basel Committee will introduce a strong peer review process for the implementation of the principles. This will help ensure that appropriate and effective frameworks for D-SIBs are in place across different jurisdictions.

The Basel Committee welcomes comments on this consultative document. Comments should be submitted by Wednesday, 1 August 2012 by e-mail 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 website of the Bank for International Settlements unless a comment contributor specifically requests confidential treatment.

Basel Committee - The internal audit function in banks - final document

June 28, 2012

The Basel Committee on Banking Supervision today issued its final document The internal audit function in banks .

 

This supervisory guidance is built around 20 principles that seek to promote a strong internal audit function within banks. Drawing on lessons learned from the financial crisis, the principles revise and update the Committee's supervisory guidance issued in 2001, also taking account of developments in supervisory practices and in banking organisations. For that purpose, the guidance addresses supervisory expectations for the internal audit function and the supervisory assessment of that function. It also encourages bank internal auditors to comply with national and international professional standards on internal auditing. Finally, it promotes due consideration of prudential issues by internal auditors. An annex to the consultative document details responsibilities of a bank's audit committee.

Mr Stefan Ingves, Chairman of the Basel Committee on Banking Supervision and Governor of Sveriges Riksbank, Sweden's central bank, noted that "an internal audit function, independent from management and composed of competent auditors, is a key component of a bank's sound governance framework. The Committee's document lays out expectations that should help banks and their supervisors strengthen professional practices in this area."

An earlier version of today's guidance was issued for consultation in December 2011. The Committee wishes to thank those who provided feedback and comments.