Measures aimed at mitigating pro cyclical effects of the Capital Requirements Framework: counter cyclical capital buffer proposals

Ojo, Marianne (2010): Measures aimed at mitigating pro cyclical effects of the Capital Requirements Framework: counter cyclical capital buffer proposals. Published in: Bank for International Settlements (BIS) Publications No. September 12 2010

Abstract

As well as highlighting the importance of introducing counter cyclical capital buffers, this paper draws attention to the need for greater focus on “more forward looking provisions”, as well as provisions which are aimed at addressing losses and unforeseen problems attributed to “maturity transformation of short-term deposits into long term loans.” Whilst the need for forward looking provisioning has been echoed by some authorities on the literature, the paper also adds weight to the argument through its attempt to link such an argument to the ever increasing prominence assumed by liquidity risks – since liquidity also contributes to pro cyclicality.

“The complex response of financial institutions to deteriorating market conditions - which to a large extent, is attributed to liquidity shortfalls which reflected on and off balance sheet maturity mismatches and excessive levels of leverage, has resulted in an increasingly important role for liquidity provided by central banks in the funding of bank balance sheets.” Owing to such increased importance of liquidity risks, this paper also attempts to highlight why the Basel Committee’s Counter Cyclical Buffer Proposal – a response to the recent financial crisis (which to a significant extent, focuses on banking sector capital requirements), should also take greater account of more forward looking provisions. In so doing, it draws attention to the importance of coupling forward looking provisions (as well as other measures) with counter cyclical charges and why this provides a better alternative to the mere introduction of counter cyclical capital charges.

• Item Type: MPRA Paper
• Language: English
• Keywords: counter cyclical buffers; liquidity risks; pro cyclicality; capital; loan loss provisions; financial crises; bank; regulation
• Subjects: D - Microeconomics > D5 - General Equilibrium and Disequilibrium > D53 - Financial Markets; E - Macroeconomics and Monetary Economics > E0 - General > E02 - Institutions and the Macroeconomy; K - Law and Economics > K2 - Regulation and Business Law; E - Macroeconomics and Monetary Economics > E3 - Prices, Business Fluctuations, and Cycles > E32 - Business Fluctuations ; Cycles; G - Financial Economics > G0 - General > G01 - Financial Crises

References

Accompanying Document to the Proposal for a Directive of the European Parliament and of the Council amending Capital Requirements Directive on trading book, securitisation issues and remuneration policies. < http://ec.europa.eu/internal_market/bank/docs/regcapital/com2009/impact_assesment_en.pdf >

Basel Committee on Banking Supervision, “An Assessment of the Long Term Economic Impact of Stronger Capital and Liquidity Requirements” Bank for International Settlements Publications August 2010 http://www.bis.org/publ/bcbs173.pdf?noframes=1

Basel Committee on Banking Supervision, „ Consultative Document: Counter cyclical Capital Buffer Proposal“ July 2010 http://www.bis.org/publ/bcbs172.pdf?noframes=1

Basel Committee on Banking Supervision, “Principles for Sound Liquidity Risk Management and Supervision” September 2008 http://www.bis.org/publ/bcbs144.htm

Borio C, “Implementing a Macro Prudential Framework : Blending Boldness and Realism” Bank for International Settlements Publications http://www.bis.org/repofficepubl/hkimr201007.12c.pdf?noframes=1

Brunnermeier M, Crockett A, Goodhart C, Persaud A and Shin H, “The Fundamental Principles of Financial Regulation”, ICMB-CEPR Geneva Reports on the World Economy, 11, 2009.

Chan Lau J, „Regulatory Capital Charges for Too-Connected-to-Fail Institutions: A Practical Proposal” http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1566443

Cifuentes R, Ferrucci G and Shin HS, “Liquidity Risk and Contagion” (2005) Journal of the European Economic Association Volume 3 at pages 556-566 http://www.bri.org/bcbs/events/rtf04shin.pdf

Committee of European Banking Supervisors, “Position Paper on a Counter Cyclical Capital Buffer” July 2009 <http://www.c-ebs.org/getdoc/715bc0f9-7af9-47d9-98a8-778a4d20a880/CEBS-position-paper-on-a-countercyclical-capital-b.aspx>

DLA Piper, The Turner Review :Key Elements of the Turner Review, DLA Piper Publications <http://www.dlapiper.com>

European Central Bank, “Is Basel II Pro Cyclical? A Selected Review of the Literature” Financial Stability Review, European Central Bank Publications December 2009

European Central Bank, “The Concept of Systemic Risk” Financial Stability Review December 2009 http://www.ecb.int/pub/fsr/shared/pdf/ivbfinancialstabilityreview200912en.pdf?a3fef6891f874a3bd40cd00aef38c64f

Financial Stability Forum, “Report of the Financial Stability Forum on “Addressing Pro cyclicality in the Financial System: Measuring and Funding Liquidity Risk” April 2009 http://www.financialstabilityboard.org/publications/r_0904a.pdf

Goodhart, Hofmann and Segoviano , “Bank Regulation and Macroeconomic Fluctuations” (2004) Oxford Review of Economic Policy, vol. 20,no. 4.

Hannoun H, „Towards a Global Financial Stability Framework“ Bank for International Settlements Publications February 2010 < http://www.bis.org/speeches/sp100303.pdf

Jimenez and Saurina , “Credit Cycles, Credit Risk, and Prudential Regulation” (2006) International Journal of Central Banking, vol.2, no.2.

Kashyap A, Stein J and Rajan R, “Rethinking Capital Regulation”, Jackson Hole Conference Paper, 2008.

Laeven L and Majnoni G, “ Loan Loss Provisioning and Economic Slowdown: Too Much Too Late?” (2003) Journal of Financial Intermediation Journal of Financial Intermediation (12) 178–197

Ojo M, „Social Rights and Economic Objectives: The Importance of Competition at Supra National Level „ http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1651610

Repullo R, Saurina J, and Trucharte C, “How to Mitigate the Pro cyclical Effects of Capital Adequacy Rules” <http://www.eurointelligence.com/article.581+M5ff0e4ba595.0.html>