A Critique of Revised Basel II

This paper critiques the revised Basel II capital requirements for banks. To provide a framework for analysis, the XYZ theory of regulatory capital is formulated. Independent of the XYZ theory, we argue that the revised Basel II capital rule for credit risk is not a good approximation to the ideal rule. Based on this, and using the XYZ theory, we argue that: (1) the revised Basel II rules should not replace the existing approaches for determining minimal capital standards, but should be used in conjunction with them, and (2) that calibrating the capital rules to maintain aggregate market capital is a prudent procedure.     

Potential Competitive Effects of Basel II on Banks in SME Credit Markets in the United States

We examine the likely competitive effects of implementation of Basel II capital requirements on banks in the market for credit to SMEs in the U.S. Similar competitive effects from Basel II may occur for other credits and financial instruments in the U.S. and other nations. We address whether reduced risk weights for SME credits extended by large banking organizations that adopt the Advanced Internal Ratings-Based (A-IRB) approach of Basel II might significantly adversely affect the competitive positions of other organizations. The analyses suggest only relatively minor competitive effects on most community banks because the large A-IRB adopters tend to make very different types of SME loans to different types of borrowers than community banks. However, there may be significant adverse effects on the competitive positions of large non-A-IRB banking organizations because the data do not suggest any strong segmentation in SME credit markets among large organizations. JEL classification: G21, G28, G38, L51     

Competitive effects of Basel II on US bank credit card lending

We analyze the potential competitive effects of the proposed Basel II capital regulations on US bank credit card lending. We find that bank issuers operating under Basel II will face higher regulatory capital minimums than Basel I banks, with differences due to the way the two regulations treat reserves and gain-on-sale of securitized assets. During periods of normal economic conditions, this is not likely to have a competitive effect; however, during periods of substantial stress in credit card portfolios, Basel II banks could face a significant competitive disadvantage relative to Basel I banks and nonbank issuers.     

Credit Risk Versus Capital Requirements under Basel II: Are SME Loans and Retail Credit Really Different?

Under Basel II, retail and SME credit (R&SME) receive special treatment because of a supposedly smaller exposure to systemic risk. Most research on this issue has been based on parameterized credit risk models. We present new evidence by applying Carey's (Carey, Mark. “Credit Risk in Private Debt Portfolios.” Journal of Finance 53, no. 4 (1998), 1363–1387.) nonparametric Monte-Carlo resampling method to two banks' complete loan portfolios. By exploiting that a sub-sample of all borrowers has been assigned an internal rating by both banks, we can compare the credit loss distributions for the three credit types, and compute both economic and regulatory capital under Basel II. We also test if our conclusions are sensitive to the definitions of R&SME credit. Our findings show that R&SME portfolios are usually riskier than corporate credit. Special treatment under Basel II is thus not justified. JEL classification: C14, C15, G21, G28, G33.     

次贷危机对中国推行新巴塞尔协议的启示

通过分析次贷危机中商业银行扮演的角色,以及新旧资本协议的比较,说明新资本协议的制度先进性、适应性和前瞻性.次贷危机不仅未否认新资本协议,反而进一步凸现了全面实施新资本协议的重要性.严格执行新资本协议未必能阻止金融危机的爆发,但至少可以缓解危机的破坏力,从而提升金融系统的稳定性.中国宜加快推进新巴塞尔协议,资产证券化是一个很好的切入点.     

Internal loss data collection implementation: evidence from a large UK financial institution

The paper conducts a critical analysis of internal loss data collection implementation in a UK financial institution. We use elite semi-structured interviews, with a sample of 15 operational risk consultants from a leading international financial institution. Using content analysis, the data covers a wide range of business areas, with particular attention drawn towards the development of internal loss collection and operational risk management. The results suggest that the development of operational risk management as a function stems from external compliance (Basel II) and the internal pressure to add value to the business portfolio. This need for compliance was augmented as a driver of internal loss data collection; however, participants also recognised that the function of loss data collection is a tool of solid internal risk management and enhances managerial decision-making. The research also highlights the problems in cleansing data in order to ensure that all information implemented in the capital allocation model is valid and reliable.     

Financial Innovation,Basel Accord III,and Bank Value

I examine how financial innovation and Basel III capital requirements in Taiwan respond differently to banking crises and market competition. My panel data set comprises data from thirty-four banks for 2000-2012. I find a significant negative relationship between derivatives and the value of a bank and significant positive relationships among the capital adequacy ratio, bank-specific variables, and the value of a bank. Larger bank size and operational diversification tend to be positively associated with a bank's value, the holding of a relatively high amount of capital requirements, and nonperforming loans that are large. The latter result may simply reflect the scale of economy and improvement of efficiency in terms of financial innovation in the banking sector.     

次贷危机对新资本协议实施的影响

本文以风险管理为切入点,讨论次贷危机与新资本协议之间的关系,试图回答业界对新资本协议制度合理性的某些质疑。与1988年资本协议相比,新资本协议建立了更具灵活性、适应性和前瞻性的资本监管制度,赋予资本充足率更加丰富的风险管理内涵,为商业银行改进风险管理提供了正向激励;次贷危机不仅未否认新资本协议的合理性,反而进一步凸现了全面实施新资本协议的重要性;新资本协议应顺应金融创新的趋势,吸取次贷危机的教训,做出适应性调整;虽然实施新资本协议不可能阻止金融危机再度发生,但可以提升银行体系应对外部冲击的能力,至少可以缓解未来金融危机的破坏力,从而提高社会福利。     

Bank Portfolio Allocation: The Impact of Capital Requirements, Regulatory Monitoring, and Economic Conditions

This paper develops a structural, dynamic model of a banking firm to analyze how banks adjust their loan portfolios over time. In the model, banks experience capital shocks, face uncertain future loan demand, and incur costs based on their proximity to regulatory minimum capital requirements and the intensity of regulatory monitoring. Implications of the model then are estimated using panel data on large U.S. commercial banks operating continuously between December 1989 and December 1997. The estimated model is used to simulate the optimal bank response to (1) past and proposed changes in capital requirements, (2) changes in regulatory monitoring intensity, and (3) economic downturns. The simulation results are used to shed light on the decline in loan growth and the rise in bank capital ratios witnessed over a decade ago as well as the possible impact of the current proposed modification to capital requirements.     

Effects of the New Basel Capital Accord on Bank Capital Requirements for SMEs

Using data from three countries (US, Italy and Australia) and surveying related studies from several other countries in Europe, we investigate the effects of the New Basel Capital Accord on bank capital requirements for small and medium sized enterprises (SMEs). We find that, for all the countries, banks will have significant benefits, in terms of lower capital requirements, when considering small and medium sized firms as retail customers. But they will be obliged to use the Advanced IRB approach and to manage them on a pooled basis. For SMEs as corporate, however, capital requirements will be slightly greater than under the existing Basel I Capital Accord. We believe that most eligible banks will use a blended approach (considering some SMEs as retail and some as corporate). Through a breakeven analysis, we find that for all of our countries, banking organizations will be obliged to classify as retail at least 20% of their SME portfolio in order to maintain the current capital requirement (8%). JEL classification: G21, G28     

The Impact of Basel II on Lending to Small- and Medium-Sized Firms: A Regulatory Policy Assessment Based on Spanish Credit Register Data

The objective of this paper is to evaluate the impact on bank credit exposures to small- and medium-sized Spanish firms of the current proposal for reform of the 1988 Capital Accord using information from the Spanish Credit Register. Capital requirements for exposures to those firms, according to the various revisions of the proposed capital reform (from the January 2001 consultative document to the April 2003 one), are calculated to analyze whether the existing pattern of bank financing of small- and medium-sized firms might be altered. Finally, the incentives for individual banks to adopt the advanced internal ratings-based approach proposed by Basel II are evaluated.     

新巴塞尔资本协议与商业银行操作风险量化管理

由于<新巴塞尔资本协议>把风险区分为市场风险、信用风险和操作风险,同时把操作风险纳入到资本充足率的计算之中;使得金融界对它的关注显著提高,并对量化操作风险提出了迫切要求.值得注意的是,国际上一些大银行在量化和度量操作风险管理上已经积累了较为丰富的经验,并取得一定的成就.目前我国的金融机构缺乏风险意识,尤其是在操作风险方面基本没有什么量化操作风险的科学方法,不能正确反映所承受的风险,操作风险的管理水平亟待提高.面对加入WTO之后国际金融机构在国内市场上的激烈竞争,我国金融机构应广泛借鉴国外商业银行的成功经验,加强操作风险的量化管理和研究.     

Procyclicality,Bank Lending,and the Macroeconomic Implications of a Revised Basel Accord

Bank regulators are in the process of implementing revised regulatory capital standards. However, the macroeconomic effects of a revised Basel Accord are uncertain. Examining the various channels through which the revised Accord may influence economic output suggests that making the buffer stock of capital positively related to the business cycle is necessary to reduce procyclicality. This can be accomplished by bank regulators using either enhanced supervisory powers or increased financial disclosure.     

发挥资本导向整合银行风险管理体制

近年来,资本管理在商业银行中的地位越来越重要,这是监管部门强调资本约束原则的效果,也是商业银行自身控制风险的重要手段。文章指出,作为商业银行风险管理工作的重要抓手,资本管理的核心是计量能力的提升,对于资本分配应掌握总量控制的原则。中国银行业应以资本管理为导向,逐步完善自身的风险管理体系。     

Minimizing Basel III Capital Requirements with Unconditional Coverage Constraint

The new Basel III framework increases the banks’ market risk capital requirements. In this paper, we introduce a new risk management approach based on the unconditional coverage test to minimize the regulatory capital requirements. Portfolios optimized with our new minimum capital constraint successfully reduce the Basel III market risk capital requirements. In general, portfolios with value-at-risk and conditional-value-at-risk objective functions and underlying empirical distribution yield better portfolio risk profiles and have lower capital requirements. For the optimization we use the threshold-accepting heuristic and the common trust-region search method.     

The cyclical effects of the Basel II capital requirements

Capital requirements play a key role in the supervision and regulation of banks. The Basel Committee on Banking Supervision is in the process of changing the current framework by introducing risk sensitive capital charges. Some fear that this will unduly increase the volatility of regulatory capital. Furthermore, by limiting the banks’ ability to lend, capital requirements may exacerbate an economic downturn. The paper examines the problem of capital-induced lending cycles and their pro-cyclical effect on the macroeconomy in greater detail. It finds that the capital buffer that banks hold on top of the required minimum capital plays a crucial role in mitigating the impact of the volatility of capital requirements.     

Bank Capital Regulation of Trading Portfolios: An Assessment of the Basel Framework

In setting minimum capital requirements for trading portfolios, the Basel Committee on Banking Supervision (1996, 2011a, 2013) initially used Value‐at‐Risk (VaR), then both VaR and stressed VaR (SVaR), and most recently, stressed Conditional VaR (SCVaR). Accordingly, we examine the use of SCVaR to measure risk and set these requirements. Assuming elliptically distributed asset returns, we show that portfolios on the mean‐SCVaR frontier generally lie away from the mean‐variance (M‐V) frontier. In a plausible numerical example, we find that such portfolios tend to have considerably higher ratios of risk (measured by, e.g., standard deviation) to minimum capital requirement than those of portfolios on the M‐V frontier. Also, we find that requirements based on SCVaR are smaller than those based on both VaR and SVaR but exceed those based on just VaR. Finally, we find that requirements based on SCVaR are less procyclical than those based on either VaR or both VaR and SVaR. Overall, our paper suggests that the use of SCVaR to measure risk and set requirements is not a panacea.     

巴塞尔Ⅲ下市场风险资本框架的改革及中国商业银行的应用

本次金融危机中众多欧美大型银行因市场风险控制不力而遭受巨大损失。为此,巴塞尔委员会对原有的市场风险监管框架做出修订,并以此构成了巴塞尔Ⅲ的重要组成部分。本文基于对巴塞尔市场风险监管框架发展的思路和脉络分析,研究和评价了金融危机后巴塞尔Ⅲ下市场风险资本框架的改革。最后结合我国商业银行实践,分析了我国市场风险管理的发展及对巴塞尔市场风险监管框架的应用。     

Credit risk transfer and financial sector stability

In this paper, we study credit risk transfer (CRT) in an economy with endogenous financing (by both banks and non-bank institutions). Our analysis suggests that the incentive of banks to transfer credit risk is aligned with the regulatory objective of improving stability, and so the recent development of credit derivative instruments is to be welcomed. Moreover, we find the transfer of credit risk from banks to non-banks to be more beneficial than CRT within the banking sector. Intuitively, this is because it allows for the shedding of aggregate risk which must otherwise remain within the relatively more fragile banking sector. Therefore, regulators should act to maximize the benefits from CRT by encouraging the development of instruments favorable to the cross-sectoral transfer of aggregate credit risk (including basket credit derivatives such as collateralized debt obligations). Finally, we derive the optimal regulatory stance for banks relative to non-bank financial institutions. We show that a level playing field approach is sub-optimal. Regulatory stances should be set to actively encourage cross-sector CRT, first because of the higher fragility of the banking sector and second to induce banks to incur the costs of CRT which otherwise lead them to undertake an insufficient amount of CRT.