Bank regulation and international financial stability: A case against the 2006 Basel framework for controlling tail risk in trading books

In attempting to promote international financial stability, the Basel Committee on Banking Supervision (2006) provided a framework that sought to control the amount of tail risk that large banks around the world would take in their trading books relative to their corresponding minimum capital requirements. However, many of these banks suffered significant trading losses during the recent financial crisis. Our paper examines whether the Basel framework allowed banks to take substantive tail risk in their trading books without a capital requirement penalty. We find that it allowed banks to do so and that its minimum capital requirements can be notably procyclical. Hence, focusing on the way the Basel framework sought to control the amount of tail risk in trading books relative to their corresponding minimum capital requirements, our paper supports the view that it was not properly designed to promote financial stability. We also discuss alternative regulatory frameworks that would potentially be more effective than the Basel framework in preventing banks from taking substantive tail risk in their trading books without a capital requirement penalty.     

Assessing Systemic Risk Exposure from Banks and GSEs Under Alternative Approaches to Capital Regulation

A key function of capital regulation is to mitigate the potential for systemic financial risk by maintaining public confidence in the ability of regulated market participants to honor their financial obligations in times of market stress. While it is well known that the portfolios of banks and non-banks, especially those intermediaries specializing in mortgage securitization or in specialized mortgage lending, differ in important respects, debate over alternative capital regulations has yet to recognize the implications of these differences, despite the increasing importance of non-bank intermediaries in risk-sharing markets. This paper uses a simple two-date discrete state space exchange economy with opportunities for moral hazard on the part of financial intermediaries to investigate the design of capital regulations to control systemic risk. Holding constant asset risks, we show that intermediaries that issue contingent liabilities may exhibit low or no risk of insolvency while holding significantly less capital than deposit-taking institutions because banks primarily issue claims that promise fixed payments in all states of nature. We also show that, rather than raising capital requirements, the control of systemic risk may involve lowering capital requirements and extending guarantees to liability-holders, without a necessary increase in expected subsidy payments, if such requirements account for shareholder incentives. Specifically, we analyze an example of regulatory policy in which lower capital requirements and an ex post penalty schedule reduce systemic risk by increasing the volume of tradable securities exchanged and by offering a credible mechanism by which intermediaries can signal the true riskiness of their portfolios to liability-holders.     

Incorporating Systemic Influences Into Risk Measurements: A Survey of the Literature

Procyclicality has emerged as a potential drawback to adoption of risk-sensitive bank capital requirements. Systematic risk factors may result in increases (decreases) in bank capital requirements when the economy is depressed (overheated), thereby decreasing (increasing) bank lending capacity and exacerbating business cycle fluctuations. Procyclicality may result from systematic risk emanating from common macroeconomic influences or from interdependencies across firms as financial markets and institutions consolidate internationally. We survey the literature on cyclical effects on operational risk, credit risk and market risk measures.     

Partial equilibria with convex capital requirements: existence,uniqueness and stability

We consider several risk-averse financial agents who negotiate the price of a bundle of contingent claims in an incomplete semimartingale model of a financial market. Assuming that the agents’ risk preferences are modeled by convex capital requirements, we define and analyze their demand functions and propose a notion of a partial equilibrium price. In addition to sufficient conditions for the existence and uniqueness, we also show that the equilibrium prices are stable with respect to misspecifications of agents’ risk preferences.     

The impact of imposing capital requirements on systemic risk

This paper examines the impact of imposing capital requirements on systemic risk. We use a static model on financial institutions’ risk-taking behavior to quantify the systemic risk in the cross-sectional dimension in both regulated and unregulated systems. Although imposing a capital requirement can lower individual risk, it simultaneously enhances systemic linkage within the system. By using a proper systemic risk measure combining both individual risk and systemic linkage, we show that systemic risk in a regulated system can be higher than that in an unregulated system. In addition, we analyze a sufficient condition under which the systemic risk in a regulated system is always lower.     

Leaving the darkness: The emergence of shadow banks

This paper studies the interaction between bank capital regulation, moral hazard and co-existence of traditional and shadow banks. Bank managers can choose between traditional banking and off-balance sheet special purpose vehicles (SPV), in a setup with deposit insurance and moral hazard. We first show that in the absence of SPV intermediation, capital requirements are ineffective at preventing the moral hazard problem originated by deposit insurance. We find that shadow banks can improve financial stability, when there is full information sharing. Finally, we analyze the case of neglected tail risk. We find that under such circumstances, the SPV will increase financial risk by exposing the system to extreme events.     

Bubbles and capital flow volatility: Causes and risk management

Emerging market economies are fertile ground for the development of real estate and other financial bubbles. Despite these economies’ significant growth potential, their corporate and government sectors do not generate the financial instruments to provide residents with adequate stores of value. Capital often flows out of these economies seeking these stores of value in the developed world. Bubbles are beneficial because they provide domestic stores of value and thereby reduce capital outflows while increasing investment. But they come at a cost, as they expose the country to bubble-crashes and capital flow reversals. We show that domestic financial underdevelopment not only facilitates the emergence of bubbles, but also leads agents to undervalue the aggregate risk embodied in financial bubbles. In this context, even rational bubbles can be welfare reducing. We study a set of aggregate risk management policies to alleviate the bubble-risk. We show that liquidity requirements, sterilization of capital inflows and structural policies aimed at developing public debt markets ‘collateralized’ by future revenues, all have a high payoff in this environment.     

Capital requirements and mortgage pricing: Evidence from Basel II

As a result of the Basel II reforms, capital requirements on UK mortgages fell substantially in coincidence with the financial crisis. We exploit a novel, loan-level dataset on within-lender variation in risk-weighted capital requirements and a triple-difference identification strategy to estimate the pass through of capital requirements to mortgage rates. We find that a 1pp lower risk-weighted capital requirement leads to a reduction in rates by 10–16bp on average, with stronger effects for less-capitalized lenders. The competitive advantage induced by multi-tier regulation also affects the composition of banks mortgage portfolios, with larger lenders specializing in lower risk loans. Finally, our results support the use of countercyclical capital requirements to sustain lending in a crisis.     

Capital requirements and claims recovery: A new perspective on solvency regulation

Protection of creditors is a key objective of financial regulation. Where the protection needs are high, that is, in banking and insurance, regulatory solvency requirements are an instrument to prevent that creditors incur losses on their claims. The current regulatory requirements based on value at risk (V@R) and average value at risk (AV@R) limit the probability of default of financial institutions, but they fail to control the size of recovery on creditors' claims in the case of default. We resolve this failure by developing a novel risk measure, recovery V@R. Our conceptual approach is flexible and allows the construction of general recovery risk measures for various risk management purposes. We provide detailed case studies and applications. We show that recovery risk measures can be used for performance-based management of business divisions of firms and discuss how to calibrate recovery risk measures to historical regulatory standards. Finally, we analyze how recovery risk measures react to the joint distributions of assets and liabilities on firms' balance sheets and compare the corresponding capital requirements with the current regulatory benchmarks based on V@R and AV@R.     

Bank Capital and Liquidity Creation: Granger-Causality Evidence

We examine the relation between capital and liquidity creation. This issue is interesting because of the potential impact on liquidity creation from tighter capital requirements such as those in Basel III. We perform Granger-causality tests in a dynamic GMM panel estimator framework on an exhaustive data set of Czech banks, which mainly includes small banks from 2000 to 2010. We observe a strong expansion in liquidity creation until the financial crisis that was mainly driven by large banks. We show that capital negatively Granger-causes liquidity creation in this industry, where majority of banks are small. But we also observe that liquidity creation Granger-causes a reduction in capital. These findings support the view that Basel III can reduce liquidity creation, but also that greater liquidity creation can reduce banks’ solvency. Thus, we show that this reverse causality generates a trade-off between the benefits of financial stability induced by stronger capital requirements and the benefits of increased liquidity creation.     

Dynamic Financial System: Complexity,Fragility and Regulatory Principles

A financial system improves the allocation of real resources and enhances the performance of the production economy, but these benefits are offset in part by the risk of financial distress and the associated deadweight loss resulting from bankruptcy costs. We argue that “tiers” of financial claims increase complexity and fragility of the financial network. In equilibrium, the financial system grows relative to the real economy as the allocation of funds and risks becomes more sophisticated and as more financial claims are tiered. Growth is limited by the risk of a tiered, complex financial network and by the need to set aside additional capital as the financial sector grows. We discuss several sources of fragility in the financial system. We propose that regulators should limit the breaks in the system and do more to improve the resiliency of the network and less on individual issues that are only symptoms of fundamental problems of a network. We advocate a market based system of regulation in which market participants regulate each other, to a degree. In order for this to be feasible, the financial network must be organized according to three principles: trading transparency, competitive markets and competitive regulators, and incentive alignment of participants. Insofar as these regulatory approaches are successful in limiting network fragility, capital requirements can be reduced. Regulators should keep in mind this tradeoff between capital and regulation. With regard to regulatory policy, regulators should let the three principles be their guide in adapting to the evolving financial system rather than implementing narrowly conceived regulations that are quickly outmoded.     

A cost-benefit analysis of capital requirements adjusted for model risk

Capital adequacy is the key microprudential and macroprudential tool of banking regulation. Financial models of capital adequacy are subject to errors, which may prevent from estimating a sufficient capital base to absorb bank losses during economic downturns. In this paper, we propose a general method to account for model risk in capital requirements calculus related to market risk. We then evaluate and compare our capital requirements values with those obtained under Basel 2.5 and the new Basel 4 regulation. Capital requirements adjusted for model risk perform well in containing losses generates in normal and stressed times. In addition, they are as conservative as Basel 4 capital requirements, but they exhibit less fluctuations over time.     

Can a Coherent Risk Measure Be Too Subadditive?

We consider the problem of determining appropriate solvency capital requirements for an insurance company or a financial institution. We demonstrate that the subadditivity condition that is often imposed on solvency capital principles can lead to the undesirable situation where the shortfall risk increases by a merger. We propose to complement the subadditivity condition by a regulator's condition. We find that for an explicitly specified confidence level, the Value‐at‐Risk satisfies the regulator's condition and is the “most efficient” capital requirement in the sense that it minimizes some reasonable cost function. Within the class of concave distortion risk measures, of which the elements, in contrast to the Value‐at‐Risk, exhibit the subadditivity property, we find that, again for an explicitly specified confidence level, the Tail‐Value‐at‐Risk is the optimal capital requirement satisfying the regulator's condition.     

Bank Capital Requirements, Capital Structure and Regulation

This paper studies the impact of capital requirements, deposit insurance and franchise value on a bank’s capital structure. We find that properly regulated banks voluntarily choose to maintain capital in excess of the minimum required. Central to this decision is both firm franchise value and the ability of regulators to place banks in receivership stripping equity holders of firm value. These features of our model help explain both the capital structure of the large mortgage Government Sponsored Enterprises and the recent increase in risk taking through leverage by financial institutions. The insights gained from the model are useful in guiding the discussion of financial regulatory reforms.     

An analysis and critique of the BIS proposal on capital adequacy and ratings

This paper examines two specific aspects of stage 1 of the Bank for International Settlement’s (BIS’s) proposed reforms to the 8% risk-based capital ratio. We argue that relying on “traditional” agency ratings could produce cyclically lagging rather leading capital requirements, resulting in an enhanced rather than reduced degree of instability in the banking and financial system. Despite this possible shortcoming, we believe that sensible risk based weighting of capital requirements is a step in the right direction. The current risk based bucketing proposal, which is tied to external agency ratings, or possibly to internal bank ratings, however, lacks a sufficient degree of granularity. In particular, lumping A and BBB (investment grade corporate borrowers) together with BB and B (below investment grade borrowers) severely misprices risk within that bucket and calls, at a minimum, for that bucket to be split into two. We examine the default loss experience on corporate bonds for the period 1981–1999 and propose a revised weighting system which more closely resembles the actual loss experience on credit assets.     

Systemic risk contribution of banks and non-bank financial institutions across frequencies: The Australian experience

The Australian financial sector (AFS) is highly concentrated and interconnected. Besides, Australian banks' lending portfolios are dominated by residential mortgage loans, and 70% of insurance companies' revenues arise from non-policyholder sources. The AFS also performed relatively well during the global financial crisis (GFC). Given these distinctive features, in this paper, we examine the systemic risk contribution of Australian banks, insurance companies, and other financial services providers. We use a flexible copula-based delta conditional value-at-risk (ΔCoVaR) method across different frequencies. Further, we study the systemic risk determinants in a panel setting. We find that the major Australian banks are systemically more important than all other financial institutions. Systemic risk is typically higher after the GFC than in the pre-crisis period, despite the introduction of more stringent capital requirements. In addition, the short-term ΔCoVaR is significantly higher than the medium- and long-term ΔCoVaRs. Finally, institution-specific characteristics and market-wide variables explain the cross-sectional and time-series variation in systemic risk, and their explanatory power varies across frequencies.     

Regulatory Capital of Financial Institutions: A Comparative Analysis

This study analyzes regulatory capital requirements of banks, thrifts and securities firms. Regulatory capital has traditionally guarded against credit risk and has been set on an asset‐by‐asset basis. Regulators now recognize the need to guard against a wider range of risks and to measure risk in a portfolio context rather than on an asset‐by‐asset basis. However, the measurement of portfolio risk in the presence of a wide variety of financial instruments and the complexity of financial institutions requires a level of sophistication that regulators are unlikely to possess. Consequently, it is important to reassess the purpose of regulatory captial. Regulatory capital now guards against the failure of the entire financial institution, while regulatory responsibility extends only to the insurance fund that guarantees bank deposits or brokerage accounts. Narrowing the regulatory focus to protect only insured accounts would reduce the need to consider all the activities of a financial instituion as is now necessary in order to establish regulatory capital.     

宏观审慎管理框架下农村合作金融机构发展问题研究

近年来,经过新一轮深化改革,农村合作金融机构已经发展成为县域网点最多、涉农信贷投放最多、联系广大农民群众最紧密、农村普惠制金融服务和均等化建设贡献的农村金融纽带,但其在资本实力、风险、内控制度建设、公司治理等方面存在明显不足。为此,在目前加强宏观审慎管理的宏观政策背景下,我们在对农村合作金融机构改革和发展作出稳健性评估的基础上,针对当前农村合作金融机构发展中面临的问题与挑战,提出了促进稳健发展和尽快适应宏观审慎管理要求的政策建议。     

Partial Hedging for Equity-Linked Products Using Risk-Minimizing Strategies

In this article, we consider the pricing and hedging of equity-indexed annuities (EIAs) using local risk-minimizing strategies as well as evaluating the capital requirement for these products. Since these products involve mortality as well as financial risks, we integrate mortality risk and propose partial hedging strategies that protect the insurer based on risk measures. The framework we present makes use of sequential local risk-minimizing strategies to take into account all intermediate requirements. To demonstrate the flexibility of this framework we present numerical examples featuring point-to-point EIAs with a two-state regime-switching equity model.     

Financial stability and Basel II

The Basel II Advanced Internal Ratings (AIRB) approach is compared to capital requirements set using an equilibrium structural credit risk model. Analysis shows the AIRB approach undercapitalizes credit risk relative to regulatory targets and allows wide variation in capital requirements for a given exposure owing to ambiguity in the definitions of loss given default and exposure at default. In contrast, the Foundation Internal Ratings Based (FIRB) approach may over-capitalize credit risk relative to supervisory objectives. It is unclear how Basel II will buttress financial sector stability as it specifies the weakest regulatory capital standard for large complex AIRB banks.