Ojo, Marianne (2015): The unintended consequences and challenges of the Basel III Leverage Ratio: supplementary leverage ratios. Published in: Designing Optimal Models of Financial Regulation in a Changing Financial Environment No. ISBN: 978-163484-829-9 (February 2016)
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Abstract
The U.S standard leverage ratio, which is not as stringent as the U.S Supplementary Leverage Ratio, did not include Off Balance Sheet exposures - unlike the Basel leverage ratio. Hence the 3% Supplementary Leverage Ratio was established as part of measures to facilitate the inclusion of Off Balance Sheet exposures in July 2013 - even though many still consider the scope of such inclusion as not being extensive enough - since Secured Financing Transaction Exposures are still excluded.
Furthermore, the Enhanced Supplementary Leverage Ratio increased the 3% leverage ratio to 5% (a 2% buffer) for globally systemic important banks (GSIBs) bank holding companies and 6 % for their banking subsidiaries. In respect of securities financing transaction exposures, however, U.S banks are considered to enjoy competitive advantage, since the exclusion of such exposures still persist - even though it is also argued that recent liquidity coverage and net stable funding ratio provisions should serve to address these exposures - this also being in line with the complementary functions of liquidity standards and leverage ratios within the risk-based capital adequacy framework.
As well as contributing to the extant literature on supplementary leverage ratios, this paper will seek to illustrate why calibration between the risk capital adequacy framework, liquidity standards, and Basel leverage ratio is even more important than merely a focus on the relationship between the risk capital adequacy framework and the Basel leverage ratio.
Meanwhile as regards Europe, there are also concerns relating to sovereign credit risks and the “inadequate pricing” of such risks which results in under capitalisation of banks, as well as potential consequences relating to serious distortions in financial stability whose effects could have repercussions extending beyond the Euro zone and globally. This paper considers two headings which have generated controversial discussions - particularly in respect of Basel III leverage ratio implementation, namely, under capitalisation of banks and the issue of calibration. It aims to illustrate why these constitute areas which are still in need of redress - even though tremendous efforts have been made to align the Basel III Leverage Ratio with the Supplementary Leverage Ratios. The paper will also demonstrate that whilst there are concerns related to the issue of calibration, certain jurisdictions such as the UK, have also introduced supplementary leverage ratios - as well as considered alternatives to the Basel leverage ratio.
Item Type: | MPRA Paper |
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Original Title: | The unintended consequences and challenges of the Basel III Leverage Ratio: supplementary leverage ratios |
Language: | English |
Keywords: | supplementary leverage ratios; short term funding; financial stability; OBS exposures; Standardised Approach to Counterparty Credit Risk (SA-CCR); credit conversion factors (CCF) |
Subjects: | E - Macroeconomics and Monetary Economics > E6 - Macroeconomic Policy, Macroeconomic Aspects of Public Finance, and General Outlook G - Financial Economics > G1 - General Financial Markets > G14 - Information and Market Efficiency ; Event Studies ; Insider Trading G - Financial Economics > G2 - Financial Institutions and Services G - Financial Economics > G2 - Financial Institutions and Services > G28 - Government Policy and Regulation K - Law and Economics > K2 - Regulation and Business Law |
Item ID: | 69288 |
Depositing User: | Dr Marianne Ojo |
Date Deposited: | 08 Feb 2016 15:14 |
Last Modified: | 27 Sep 2019 11:07 |
References: | Acharya, V V “The Dodd-Frank Act and Basel III Intentions, Unintended Consequences, Transition Risks, and Lessons For India ” 2014 Bank of England, “ Financial Policy Committee’s Review of the Leverage Ratio October 2014 Basel Committee on Banking Supervision, Discussion Paper 'The Regulatory Framework: Balancing Risk Sensitivity, Simplicity and Comparability“ July 2013 Bank for International Settlements Publications Basel Committee on Banking Supervision, 'Capital Requirements and Bank Behaviour: The Impact of the Basel Accord' Basel Committee on Banking Supervision Working Papers April 1999 Basel Committee on Banking Supervision, 'Consultative Paper on a New Capital Adequacy Framework' 3rd June 1999 http://www.bis.org/press/p990603.htm Federal Reserve, 'Regulatory Capital Rules: Regulatory Capital, Enhanced Supplementary Leverage Ratio Standards for Certain Bank Holding Companies and their Subsidiary Insured Depository Institutions' Financial Stability Board, Update of Group of Global Systemically Important Banks (G-SIBs) (Nov. 1, 2012) http://www.financialstabilityboard.org/publications/r_121031ac.pdf Ojo, M Basel II and the Capital Requirements Directive: Responding to the 2008/09 Financial Crisis (September 2009) Ojo, M Basel III and Responding to the Recent Financial Crisis(September 2010 Ojo, M Preparing for Basel IV (Whilst Commending Basel III Part II) (January 2011) Paper presented at the 2011 INFINITI Conference on International Finance, 13 - 14 June 2011, Trinity College Dublin (the 9th INFINITI Conference on International Finance) 13th & 14th June 2011“Institutions, Actors and International Finance”. PricewaterhouseCoopers, “First Take: Supplementary Leverage Ratios” September 10 2014 http://www.pwc.com/us/en/financial-services/regulatory-services/publications/first-take-supplementary-leverage-ratio-basel-iii.jhtml PricewaterhouseCoopers, “Regulatory Brief: Basel Leverage Ratios: No Cover For US Banks” January 2014 particularly http://www.pwc.com/en_US/us/financial-services/regulatory-services/publications/assets/fs-reg-brief-dodd-frank-basel-leverage-ratio.pdf Shearman & Sterling LLP, “Enhanced Leverage Ratios for UK Financial Institutions” December 2014 Tarullo D , “ Opening Statement by Governor Daniel K. Tarullo before Federal Reserve Board” http://www.federalreserve.gov/newsevents/press/bcreg/tarullo-statement-20141209.htm Valladares MR“What Awaits Banks After the Leverage Ratio?” http://dealbook.nytimes.com/2014/04/09/what-awaits-banks-after-the-leverage-ratio Wolf M, The Shifts and the Shocks: What We’ve Learned - and Have Still to Learn” see particularly prologue 2014 Penguin Press New York |
URI: | https://mpra.ub.uni-muenchen.de/id/eprint/69288 |
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The unintended consequences and challenges of the Basel III Leverage Ratio: supplementary leverage ratios. (deposited 16 Jan 2015 00:11)
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- The unintended consequences and challenges of the Basel III Leverage Ratio: supplementary leverage ratios. (deposited 08 Feb 2016 15:09)