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。     

Remarks on Basel II

In this paper Le Pan focuses on some key issues related to Basel II, such as complexity, impact on capital and home‐host implementation, and offers ten thoughts on the post Basel II world.     

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.      

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.     

Basel II: Correlation Related Issues

Basel II aims to aggressively improve on Basel I, and is projected to capitalize on the technological advancements that have permeated the financial industry since Basel I. This paper examines the correlation issues that arise, and provides recommendations on implementation as we move forward. We provide the following results: (1) We demonstrate that fixing asset value correlations by regulators without a specification of business unit granularity and aggregation impacts franchise risk. (2) Loss distributions for credit risk are more sensitive to correlation assumptions that those for market risk; arbitrary, inaccurate correlation specifications can cause large errors in capital requirements. (3) Current regulations do not recognize that credit losses depend on four distinct correlations, not just one. (4) Recovery rates may be determined uniformly across banks. (5) Tail risk comes from LGD correlations and non-Gaussian risks. (6) The 1-year VaR horizon causes distortions especially when regimes and pro-cyclicality are involved. (7) We recommend a quantitative measure for implementing market discipline, the third pillar of the Basel II accord. Therefore, this paper highlights many issues that may be addressed using the tools banks already employ for internal risk management.     

Basel II: A Contracting Perspective

Financial safety nets are incomplete social contracts that assign responsibility to various economic sectors for preventing, detecting, and paying for potentially crippling losses at financial institutions. Basel II forces signatory countries to reopen safety-net bargaining across affected sectors. This paper uses the theories of incomplete contracts and sequential bargaining to interpret the Basel Accords as a framework for endlessly renegotiating minimal duties and standards of safety-net management across the community of nations. Modelling the stakes and stakeholders represented by different regulators helps us to understand that inconsistencies were bound to exist in prior understandings about the range of sectoral effects that the 2004 Basel II agreement might produce. The analysis seeks to explain why, in the U.S., attempting to resolve what turned out to be intolerable inconsistencies spawned an embarrassingly fractious debate and repeatedly pushed back Basel II’s scheduled implementation.     

Understanding Basel II Operational and Strategic Implications

In 2004/05 McKinsey and Company conducted a major international research project to understand the operational and strategic implications of Basel II for credit institutions and capital markets. In this paper, which is a condensed summary of the findings of this effort, Krall foresees a number of interacting developments influencing banks operational and strategic choices as well as the overall level of systemic risk in the global credit markets.     

Bank size and risk-taking under Basel II

We analyze the relationship between bank size and risk-taking under the Basel II Capital Accord. Using a model with imperfect competition and moral hazard, we show that the introduction of an internal ratings based (IRB) approach improves upon flat capital requirements if the approach is applied uniformly across banks and if the costs of implementation are not too high. However, the banks’ right to choose between the standardized and the IRB approaches under Basel II gives larger banks a competitive advantage and, due to fiercer competition, pushes smaller banks to take higher risks. This may even lead to higher aggregate risk-taking.     

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.     

An Assessment of Basel II Procyclicality in Mortgage Portfolios

In this paper we develop a probability of default (PD) model for mortgage loans, taking advantage of the Spanish Credit Register, a comprehensive database on loan characteristics and credit quality. From that model, we calculate different types of PDs: point in time, PIT, through the cycle, TTC, average across the cycle and acyclical. Then, we compare capital requirements coming from the different Basel II approaches. We show that minimum regulatory capital under Basel II can be very sensitive to the risk measurement methodology employed. Thus, the procyclicality of regulatory capital requirements under Basel II is an open question, depending on the way internal rating systems are implemented and their output is utilised. We focus on the mortgage portfolio since it is one of the most under researched areas regarding the impact of Basel II and because it is one of the most important of banks’ portfolios.     

新资本协议要求下我国银行会计信息市场的问题探析

巴塞尔委员会于2004年6月公布的新资本协议是国际银行业的新"游戏规则",它形成的现代金融监管体系的"三大支柱"对于银行业的发展具有划时代的意义,特别是它强调信息披露和市场纪律约束在资本监管及整个银行监管中的重要性,这对我国银行业的发展具有非常重要的借鉴意义.本文介绍了新资本协议的主要内容和我国的实施计划,重点剖析了我国银行会计信息市场存在的主要问题及原因.     

The three pillars of Basel II: optimizing the mix

The on-going reform of the Basel Accord relies on three “pillars”: a new capital adequacy requirement, supervisory review and market discipline. This article develops a simple continuous-time model of commercial banks' behavior where interaction between these three instruments can be analyzed. We study the conditions under which market discipline can reduce the minimum capital requirements needed to prevent moral hazard. We also discuss regulatory forbearance issues.     

香港实施新资本协议的最新进展和政策特点

按照通行的国际监管标准对银行业实施审慎监管是香港建设国际金融中心的重要举措.按照巴塞尔委员会确定的时间表,香港于2007年初在亚洲区率先开始实施新资本协议,新资本监管规则正式取代以1988年资本协议为基础的资本监管规则.     

次贷危机对新巴塞尔协议提出的挑战与启示

次贷危机的爆发使得人们对新巴塞尔协议运行的有效性产生质疑,对新巴塞尔协议的重新思考也应运而生.笔者从政策监管、银行经营模式以及风险管理实践等三方面深入研究次贷危机对新巴塞尔协议提出的挑战,揭示了新巴塞尔协议中存在的诸多不足.并且进一步从强化对高杠杆运作的监管、强化交易对手风险的评估,以及提高银行全面风险管理水平的具体措施上提出改进建议.对新巴塞尔协议的思考也将为我国提供宝贵的资料与经验,有利于进一步与国际接轨、规范我国的商业银行的经验管理.     

我国商业银行实施巴塞尔新资本协议的问题分析及建议

本文结合我国银行的资本管理实际及巴塞尔新资本协议的要求,对我国商业银行实施新资本协议存在的问题从数据基础、管理工具、文化等方面进行了详细分析,指出存在的各种差距,并结合这些分析及大多数商业银行的实际,提出了积极筹备的几项具体建议.     

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.     

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.