Basel II vs. Prompt Corrective Action: Which Is Best for Public Policy?

This paper evaluates Basel II as a tool for achieving public policy objectives relative to structured early intervention and resolution (SEIR) and prompt corrective action (PCA) in the U.S. It concludes that Basel II compares poorly in terms of maintaining a safe and sound banking system. Rather, Basel II resembles a "best practices" guide for banks in managing their credit risk. However, it may do damage through encouraging some large banks in the U.S. to successfully pressure their regulators to lower the capital trigger ratio for "adequately‐capitalized" status in order to benefit from any lower regulatory capital requirement that Basel II may give them.     

On the Role of Regulatory Banking Capital

In this paper the authors study the role of regulatory banking capital and analyze the incentive effects of the Basel II Accord. They argue that Basel II may become a source of systemic risk due to endogenous risk and the risk sensitivity of the capital requirements. In this context they note that financial instability may enter via the asset side of the banks' balance sheets when banks are forced to sell assets in order to maintain the capital buffer prescribed by Basel II.     

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     

On the necessity of five risk measures

The banking systems that deal with risk management depend on underlying risk measures. Following the Basel II accord, there are two separate methods by which banks may determine their capital requirement. The Value at Risk measure plays an important role in computing the capital for both approaches. In this paper we analyze the errors produced by using this measure. We discuss other measures, demonstrating their strengths and shortcomings. We give examples, showing the need for the information from multiple risk measures in order to determine a bank’s loss distribution. We conclude by suggesting a regulatory requirement of multiple risk measures being reported by banks, giving specific recommendations.     

Depositors’ Assessment of Bank Riskiness in the Russian Federation

In the period after the crises in the late 1990s, the banking industries in most emerging markets have undergone significant restructuring consistent with the Basel II Accord. The Central Bank of Russia’s efforts since 2000 have contributed to the consolidation and improvement of the banking industry. To measure the extent of market discipline in the Russian banking industry, we study the reaction of Russian depositors to excessive risk taking by large banks between 2000:1 and 2005:1. We find that during our analysis period, well-capitalized, more liquid banks significantly increase their deposits.     

A practical approach to validating a PD model

The capital adequacy framework Basel II aims to promote the adoption of stronger risk management practices by the banking industry. The implementation makes validation of credit risk models more important. Lenders therefore need a validation methodology to convince their supervisors that their credit scoring models are performing well. In this paper we take up the challenge to propose and implement a simple validation methodology that can be used by banks to validate their credit risk modelling exercise. We will contextualise the proposed methodology by applying it to a default model of mortgage loans of a commercial bank in the Netherlands.     

Does prudential regulation contribute to effective measurement and management of interest rate risk? Evidence from Italian banks

This paper contributes to prior literature and to the current debate concerning recent revisions of the regulatory approach to measuring bank exposure to interest rate risk in the banking book by focusing on assessment of the appropriate amount of capital banks should set aside against this specific risk. We first discuss how banks might develop internal measurement systems to model changes in interest rates and measure their exposure to interest rate risk that are more refined and effective than are regulatory methodologies. We then develop a backtesting framework to test the consistency of methodology results with actual bank risk exposure. Using a representative sample of Italian banks between 2006 and 2013, our empirical analysis supports the need to improve the standardized shock currently enforced by the Basel Committee on Banking Supervision. It also provides useful insights for properly measuring the amount of capital to cover interest rate risk that is sufficient to ensure both financial system functioning and banking stability.     

Capital shocks, bank asset allocation, and the revised Basel Accord

In contrast to the 1988 Basel Accord (Basel I), the revised risk-based capital standards (Basel II) propose regulatory capital requirements based on credit ratings. This paper develops a theoretical model to analyze how banks will adjust their low and high credit risk commercial loans under the proposed newer standard. Capital-constrained banks respond to an adverse capital shock by reducing high credit risk loans, while under certain circumstances, low credit risk loans may actually increase. When compared to Basel I, it is shown that high-risk loans are reduced more under Basel II, but whether a bank reduces total lending more under Basel I or under the revised standards depends on a complex interaction of factors.     

Are foreign banks more profitable than domestic banks? Home- and host-country effects of banking market structure, governance, and supervision

Using both bank- and country-level data on banking sectors from 70 countries over the period 1992-2006, this paper empirically investigates the joint home- and host-country effects of banking market structure, macroeconomic condition, governance, and changes in bank supervision on foreign bank margins. We find that foreign banks are more profitable than domestic banks when they operate in a host country whose banking sector is less competitive and when the parent bank in the home country is highly profitable. Moreover, when foreign banks operate in a host country with lower growth rates of GDP, higher interest and inflation rates, and more stringent regulatory compliance with Basel risk weights, their margins increase. Specifically, changes in bank supervision of a parent bank’s ownership restrictiveness in the home country significantly increases foreign bank margins, while supervisory changes in regulatory compliance with Basel risk weights in the host country enhances foreign bank margins.     

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。     

收益率曲线动态与银行经济价值的利率风险

本文在收益率曲线动态的主成分分析基础上,运用MonteCarlo模拟的主成分VaR方法,以我国五家商业银行为样本研究银行账户经济价值利率风险的计量方法,并与巴塞尔委员会标准久期法的结果进行比较。同时,对VaR模型的有效性进行了样本外的返回检验。研究发现,五家银行的经济价值面临的是利率上升的风险;非正态主成分VaR模型估计的经济价值利率风险,都要大于正态主成分VaR模型的结果,这反映了利率波动的厚尾特征,正态假设有可能低估风险。     

资本计量方法改革、商业银行风险偏好与信贷配置

为提高银行业风险管理水平与信贷配置效率,监管部门于2014年开展了资本管理高级方法的试点工作。本文基于上市银行2010至2016年的微观数据,与银监会公布的行业信贷风险进行匹配,采用双重差分和三重差分法,实证分析前述改革如何影响试点银行的风险偏好和信贷调配。研究发现,在资本管理高级方法实施后:(1)试点银行显著降低了风险加权资产的规模;(2)试点银行风险偏好的变化存在非线性的特征,在调减高风险行业贷款的同时,并未显著增加最安全行业的贷款,而是增加了风险略高行业的贷款,体现出试点银行对风险与收益的权衡;(3)进一步将行业划分为“虚”与“实”,研究发现试点银行减少了房地产业(“虚”)、制造业(“实”)和建筑业(“实”)贷款,显著增加了金融业(“虚”)贷款。本文研究不仅丰富了资本监管方面的文献,也对金融支持供给侧结构性改革具有启示意义。     

The regulations–risk taking nexus under competitive pressure: What about the Islamic banking system?

Does market power condition the effect of bank regulations and supervision on bank risk taking? We focus on three regulatory tools: capital requirements, the restriction of activities, and official supervisory powers. Employing 10 years of unbalanced panel data on 123 Islamic and conventional banks operating in the Middle East and Asia, we arrive at the following conclusions. First, banking market power strengthens the negative impact of capital regulation on bank risk taking. Second, our empirical results suggest that the negative effect of activity restrictions on stability is diminished when banks have greater market power. Finally, we do not find strong evidence that the negative effect of supervisory power on banks’ risk taking is conditioned by their competitive behavior. In further analysis, we differentiate between Islamic and conventional banks regarding their competition, as well as their risk behavior. The results differ according to the banking business model. These findings could be useful for bank regulators in light of the accomplishment of Islamic banks’ regulatory framework. Indeed, the adoption of Basel III represents a significant regulatory challenge, given that it does not take into account the specificities of Islamic banks.     

商业银行风险管理模型的性质及启示

随着新资本协议的实施,各种估值定价和风险计量模型开始在我国商业银行大量应用。本文对商业银行风险管理模型的五大基本性质及其衍生性质进行了研究,并进一步给出了有效防范模型风险的若干建议。     

Capital requirements under the credit risk-based framework

This work aims to study the hypothesis of lower capitalization of banks under the risk-based rules introduced in Basel II. In this sense, an assessment of the impact of these rules on the capital requirements for non-financial firms’ credit risk is performed. A comparison with Basel I is presented and intervals of variation for the risk drivers such that capital requirements exceed the ones under Basel I are established. Data for a European country supports the hypothesis of a smaller capitalization of banks under the risk-based framework, as far as credit risk in concerned.     

《银行资本充足率监管征求意见稿》的影响研究

2011年5月,银监会下发了融合《巴塞尔协议II》及《巴塞尔协议III》内关于资本计量、管理等内容的《银行资本充足率监管征求意见稿》,这标志着金融危机后我国的新监管标准即将落地。该监管新规将使国有五大行资本充足率下降。五大行可以从补充资本、降低加权风险资产、增强资本管理能力等方面应对监管新规。     

商业银行银行账户利率风险管理面临的挑战

银行账户利率风险是目前商业银行面临的主要市场风险之一。该文基于当前商业银行风险管理实践揭示其银行帐户利率风险管理在计量、运用方面面临的挑战,指出商业银行必须从制度、计量、监测、控制等方面逐步建立相应体系,以强化银行账户利率风险管理,适应监管要求和新资本协议要求。     

Do the business cycle and revenue diversification matter for banks’ capital buffer and credit risk: Evidence from ASEAN banks

We examine the association of the business cycle and revenue diversification with the banks’ capital buffer and credit risk for a sample of banks from the Association of Southeast Asian Nations (ASEAN) region from 1998 to 2018, using 2847 banking firm–year observations. We find that ASEAN region banks react anticyclically in adjusting their capital buffer levels and credit risk. We find revenue diversification benefits and that banks, through revenue diversification, can reduce their credit risk while achieving capital savings when confronting economic downturns. Our results offer support for the Basel III accord. However, the relations revealed are somewhat moderated by the regulatory quality, competition, and phase of the business cycle encountered by ASEAN region banks.     

改进的效率测算模型、影子银行与中国商业银行效率

商业银行及其效率的高低是金融供给侧结构性改革的关键环节,而可以压缩的“坏”投入和影子银行对商业银行效率产生重要影响。本文首次建立理论模型并分析影子银行影响商业银行效率的路径;方法上,同时区分投入和产出的“好”或“坏”,拓展只区分产出的“好”或“坏”的效率测算模型;实证上,首次测算并分析“坏”投入、影子银行业务对商业银行利润、风险和效率的影响。结果表明:理论上,影子银行会同时增加风险承担和利润,但无法确定经风险调整后的利润增加能否提升效率;只区分产出的模型高估了效率,尤其是显著高估四大行和股份制商业银行第一阶段的效率,大型商业银行依靠网点的扩张不利于效率的提升;影子银行业务提升了四大国有银行尤其是股份制银行的效率,但对中小型商业银行效率影响较小。总的来看,压缩“坏”投入和规范影子银行是增加有效金融供给、优化金融供给结构和提升银行效率的重要途径。     

How to make regulators and shareholders happy under Basel III

In addition to the Basel II capital ratio, Basel III requires banks to respect additional ratios, such as leverage ratio, liquidity coverage ratio and net stable funding ratio. Banks are required to be compliant with all four constraints simultaneously. Our article provides a framework for banks to help their search for an optimal transition from Basel II to Basel III. Recognizing that banks’ return and the four constraints are of linear type, this search can be formulated as a linear program and solved by standard software. Incorporating uncertainty on future defaults, risk weights and withdrawals and formulating the problem as a Chance constrained model does not only yield optimal transition strategies but also determines the internal thresholds for the Basel III-ratios. Our approach needs two standard inputs from controlling: profit margins per product and non-financial adjustment costs to expand or cut back business. The adjustment cost can be used to calibrate the model to the current business mix. This calibration can be done by bank outsiders and allows the model to be used in impact studies to replace ad hoc strategies. To highlight its practicality, we apply our model to a typical German bank with a business mix that complies with Basel II, but not with the Basel III-, capital-, leverage- and net stable funding-ratio. Assuming that its business model is optimal under Basel II, we find that this bank would achieve compliance restructuring its funding side by replacing interbank funding by capital and retail deposits. Additional uncertainty would amplify the magnitude of the changes, but would still affect the same positions. These findings are robust against alternative margin definitions and adjustment cost levels.