Felix Salmon » Basel III http://blogs.reuters.com/felix-salmon A slice of lime in the soda Thu, 10 Nov 2016 19:11:15 +0000 en-US hourly 1 http://wordpress.org/?v=4.2.5 Chart of the day, bank-lending edition http://blogs.reuters.com/felix-salmon/2013/09/17/chart-of-the-day-bank-lending-edition/ http://blogs.reuters.com/felix-salmon/2013/09/17/chart-of-the-day-bank-lending-edition/#comments Tue, 17 Sep 2013 16:47:28 +0000 http://blogs.reuters.com/felix-salmon/?p=22502 Well done to Matt Levine for finding — and explaining very clearly — the BIS’s special feature, by Ben Cohen, on the way in which the world’s banks have adjusted to higher capital requirements. Basically, the BIS, which sets the Basel capital requirements for the world’s banks, wanted to know how banks reacted when those capital requirements were raised.

The first thing that happened is that the banks did, in fact, become significantly better capitalized — and that is especially true of what the BIS calls “large, internationally active banks”. Since those are the banks we’re mainly worried about, this is definitely good news. Those banks were well below the Basel III minimum at the beginning of 2010, but they reached it by mid-2011, and they comfortably exceeded it by mid-2012, well ahead of the Basel III schedule.

The banks achieved this feat in the most painless way possible: they simply retained their earnings, rather than paying them out in dividends. And those earnings weren’t easy to come by, either. The banks in general shed what Levine calls “income that lots of people find naughty, prop trading and so forth”, which reduced their overall profitability. The banks instead had to make money the old-fashioned way, by lending it out at a higher rate than their cost of funds. Net interest income, across all global banks, rose substantially from the pre-crisis period to the post-crisis period: it was 1.34% of assets in 2005-7, and 1.62% of assets in 2010-12.

Here’s where the slightly disappointing part of the story comes in, though: despite the fact that their loans were more profitable than ever, the banks didn’t actually lend more, overall. The BIS report has some rather confusing charts on this, so here’s a FRED chart I put together, showing total US bank credit, in constant 2008 dollars, over the past 15 years:

The story here is clear. Total credit was rising at a very steady real pace for the decade running up to the crisis — but then it stopped growing when the crisis hit, and it has never really recovered.

Levine, and the BIS, put a positive spin on this, saying that the banks “are not cutting back on lending”. Which is true — but they’re not exactly fueling the recovery, either. Indeed, this chart is worse than what we would have seen if the banks had just rolled over all their existing loans and made no new loans at all.

That said, I’m not sure that this chart is really bad news. If you stipulate that there was too much lending in the economy in 2008, and that we needed to enter a period of slow deleveraging, this is actually exactly what the doctor ordered.

One way of reading the BIS report is to think of a set of trade-offs between three constituencies: banks, borrowers, and regulators. When the regulators got tough and implemented Basel III, the main losers were the banks, which lost a lot of permanent profitability. But borrowers were also hit: they’re paying more for loans, and they’re not being given as many loans as they were in the past. The big winner, meanwhile, was society as a whole, which significantly reduced the amount of systemic risk in the banking system.

The BIS is not entirely unsympathetic to the banks. In fact, in a quite astonishing passage which Levine picks up on in a footnote, they suggest that maybe the banks could form an informal cartel, passively agreeing not to compete with each other on lending rates:

The bank could seek to reduce the share of its profit it pays out in dividends. Alternatively, it may try to boost profits themselves. The most direct way to do so would be by increasing the spread between the interest rates it charges for loans and those it pays on its funding. While competitive pressures may limit how much an individual bank can widen these spreads, lending spreads could rise across the system if all banks followed a similar strategy and alternative funding channels (such as capital markets) did not offer more attractive rates.

Remember that from a regulatory perspective, a highly profitable bank is a significantly better bet than one with narrower profit margins. Regulators want banks to make good money: it makes their own job a great deal easier. And if that comes from charging borrowers higher rates, so be it.

What’s more, banks actually have the ability to do this relatively easily. Borrowers who don’t have direct access to the capital markets — which is the overwhelming majority of us — are not, in reality, particularly price-sensitive when it comes to lending rates. Payday lenders learned this lesson years ago: borrowers value convenience much more than they do lower interest rates. And as a result, banks actually have quite a lot of leeway to raise lending rates if they want to, at least when it comes to individuals and small businesses.

And in reality, a large part of the stagnation in bank lending has to be a consequence of the fact that the economy as a whole is evincing little demand for credit. Individuals are more interested in paying down their debts than they are in borrowing more; businesses, too, have learned the hard way that debt has a tendency to bite, hard, at the worst possible moment. If higher lending spreads help to discourage borrowing, at the margin — and maybe conversely encourage businesses to take some kind of equity funding, instead — then possibly they will result in a more resilient economy overall.

For the time being, as well, higher bank spreads are no big deal, just because the banks have such an incredibly low cost of funds: the actual nominal interest rates being paid by borrowers are still extremely low. My own bank recently offered me, out of the blue, a free, unsecured credit line at 6.3%: that’s well above their cost of funds, but it’s still a very low interest rate, in the grand scheme of things, should I find myself in a position where I need to take advantage of it.

So I’m with Levine on this one: so far at least, Basel III seems to be working in an almost optimal manner. We’re used to a world where the only way you can achieve growth is through leverage — and we learned, with extreme pain, that leverage is a very dangerous thing. This recovery, by contrast, is not being driven by leverage. And that is surely a good thing.

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Why the Basel change was a bad idea http://blogs.reuters.com/felix-salmon/2013/01/09/why-the-basel-change-was-a-bad-idea/ http://blogs.reuters.com/felix-salmon/2013/01/09/why-the-basel-change-was-a-bad-idea/#comments Wed, 09 Jan 2013 06:57:48 +0000 http://blogs.reuters.com/felix-salmon/?p=20108 Monday’s Counterparties email went out under the headline “QEBasel“, which may or may not have been an effective way to communicate that the latest relaxation of Basel rules was emphatically done with monetary policy in mind, rather than regulatory prudence. Under the new rules, it might take banks longer to get to a truly safe place, but at least those banks will (we fervently hope) lend more in the meantime, giving a much-needed boost to global growth.

Interestingly, the press reacted very badly indeed to the announcement, which means that Andrew Ross Sorkin, in defending the new rules, is fighting a lonely battle.

He doesn’t do so very well, it must be said. He quotes one John Berlau saying that implementation of Basel as written “almost certainly would have thrown the U.S. and other economies into a recession”, and then says that “Mr. Berlau is right”. Well, Mr Berlau is not right: according to the Basel timetable, very little has to be done this year — and in fact nothing with a 2013 deadline has actually changed at all. The problem with Basel III was never that it would cause some kind of sudden stop in capital flows from banks to borrowers, the minute that it started getting implemented.

And Sorkin also undermines his one genuinely good point. “The chances of a leverage-induced crisis from Wall Street banks right now is quite low,” he writes — and he’s right about that. Indeed, the chances of any leveraged-induced crisis any time before 2019 are very slim indeed. (For one thing, there isn’t enough time, between now and then, to get out of our present slump, find ourselves in a boom, watch the boom get out of control, and then see the boom spectacularly implode.) But here’s the problem: Basel’s leverage requirements haven’t actually changed at all. It’s the liquidity requirements which have changed. And while I’m not worrying about banks’ leverage, I am worrying about their liquidity.

Here’s the difference: leverage requirements protect banks against a sudden drop in the value of their assets. Liquidity requirements, on the other hand, protect banks against bank runs. And bank runs are all about trust and confidence. Banks, especially in the US, might have reasonably strong balance sheets these days. But no one trusts them, or their accounting. (If you don’t believe me, just read Jesse Eisinger and Frank Partnoy in the Atlantic, then you will.) When you don’t have trust, you need liquidity to make up for it — which is why the liquidity requirement is exactly the wrong place for the Basel committee to be fiddling.

What’s more, the Basel committee didn’t just delay the implementation of the liquidity requirements: they changed the requirements themselves. Liquidity is not a completely well-defined term, but it basically means money, or something very very close to it. But the Basel committee has now given up on saying that you need cash, or government bonds, to count against your liquidity requirement. Now, you can even use mortgage-backed securities, if you have enough of them: the rule is that $100 of mortgage-backed securities provide the same amount of liquidity as $50 of cash.

This is a bit silly. If you owe me $50, I’ll accept $50 in cash. In a pinch, I’ll accept $50 in government debt. But I’m not going to accept mortgage-backed securities, any more than the merchants in Times Square accepted a gold bar in lieu of fiat money. The point about liquidity is that it’s money, and mortgage-backed securities aren’t money, they’re securities, which may or may not be easily converted into money at any given point in time. During a liquidity crisis, it’s entirely possible that such things could lose their bid entirely, and that they would therefore be useless in during a bank run.

Another problem here is that the change was not communicated well at all. It was put forward as a significant change in the international system of bank regulation — which is exactly what it is. And as such, it clearly makes bank regulation weaker, and the chances of a crisis some tiny bit greater. But the regulators didn’t change the rules because they thought that the rules were too stringent before; they changed the rules because they wanted banks to lend more, and thereby boost the economy. They just didn’t effectively say what they were doing, with the result that the financial press took the announcement at face value, rather than greeting it as another heterodox way of trying to use central-bank policy to generate economic growth.

The central bankers certainly should have been up-front about what they were doing, because it has important implications. For one thing, they’re playing straight into the hands of the banking lobby. Every time anybody proposes a new bank regulation, no matter how small, the ABA and the IIF and other banking-industry lobbyists will start screaming that the new regulation will depress lending, which in turn will hurt the economy; the clear implication is that even if a regulation makes perfect logical sense from a safety-and-soundness point of view, authorities still shouldn’t implement it if it will reduce the flow of credit from banks into the economy at large. That’s just not true: safety should always come first. But the Basel committee seems to have implicitly accepted that the argument does have validity.

More generally, the committee has clearly determined that if you’ve run out of ammunition in terms of interest rates and quantitative easing, then when you’re searching around for some other monetary-easing tool, regulations are a reasonable place to look. And I really don’t like that precedent. Monetary policy should be entirely separate from bank regulation, even if central banks should properly perform both roles. With the ink barely dry on the Basel III agreement, now is no time to start diluting it for the sake of some hypothetical temporary future marginal boost to growth.

After all, we have no particular reason to believe this stunt will even work. Banks have more than enough liquidity already, to meet the requirements, and they don’t seem to be very keen to lend it out. Sure, the new rules will allow them to lend out that cash, if they want to. But the market right now is rewarding the conservative banks, and punishing those who lend to Main Street. Changing the liquidity rules won’t change that. It will just make banks that much riskier over the long term.

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Counterparties: QEBasel http://blogs.reuters.com/felix-salmon/2013/01/07/counterparties-qebasel/ http://blogs.reuters.com/felix-salmon/2013/01/07/counterparties-qebasel/#comments Mon, 07 Jan 2013 23:20:36 +0000 http://blogs.reuters.com/felix-salmon/?p=20074 Welcome to the Counterparties email. The sign-up page is here, it’s just a matter of checking a box if you’re already registered on the Reuters website. Send suggestions, story tips and complaints to Counterparties.Reuters@gmail.com.

The central bankers in the Basel committee have suddenly decided to make Basel III a lot less restrictive and a lot less urgent.

The Basel III rules, intended to make the world’s big banks safer during crisis, were scheduled to take effect on January 1, 2015, but banks will now have an additional four years to fully meet Basel’s “Liquidity Coverage Ratio” [LCR]. Now, they will only have to to be 60% of the way there by 2015. Mervyn King, the outgoing head of the Bank of England, says that the “vast majority” of the 200 banks under Basel’s auspices are already in compliance with these less restrictive standards. (Felix has a comprehensive set of posts on multi-year battle over Basel here.)

Crucially, the new Basel broadens the list of what banks can hold as “high-quality liquid assets” as a buffer against the next crisis. Banks can now count certain high-rated corporate bonds, equities, and mortgage-backed securities toward their LCR.

The NYT’s Jack Ewing says this marks “the first time regulators have publicly backed away from the strict rules imposed by the Basel Committee in 2010.” Reuters, for its part, called the previous Basel liquidity standards “draconian”. One bank analyst said the new rules amounted to “a fairly massive softening”. Per Kurowski says the rules will help banks, but will help kill the real economy.

The new rules, Simon Nixon writes, will free up money for banks to use productively, and will mean they’ll need to hold fewer soveriegn bonds. This could mean bigger profits: Barclays may see its pre-tax profit rise by 4%. Mervyn King, the outgoing head of the Bank of England, told reporters: “Nobody set out to make [Basel] stronger or weaker, but to make it more realistic.”

Realistic or not, the central bankers on the Basel committee have shifted their focus. When Basel III arrived in 2010, it was a “quiet victory” — central bankers succeeded in passing tough new rules to make big banks safer. Now, those central bankers are no longer primarily worried about preventing banks from taking down the financial system. They’re back to their monetary policy role: As FT Alphaville suggested, they’re worrying about banks lending.  — Ryan McCarthy

On to today’s links:

BofA to pay more than $10 billion to Fannie Mae, unloads mortgage servicing rights – DealBook
10 banks pay $8.5 billion to end foreclosure reviews – Reuters

New Normal
America’s prison population is shrinking — you can thank California – Wonkblog
Median pay for less experienced MBA grads: just $54,000 – WSJ

Unsolved Mysteries
No one really knows how much government debt is too much – The Economist

Why the NYSE merger may hurt average investors – Stephen Gandel
There are 181,000 social media “gurus”, “ninjas” and “mavens” on Twitter – AdAge

The year in corporate bullshit, “guff, cliche, euphemism and verbal stupidity – Lucy Kellaway

Get ready to mint that coin – Paul Krugman
Rebranding the trillion-dollar coin – Steve Randy Waldman
The trillion-dollar coin is all fun and games until someone puts an eye out – Felix

Old Timey
Tom Wolfe is confused by Wall Street’s eunuchs – Newsbeast

Interesting Failures
Why infinite scroll failed at Etsy – Dan Nguyen

Crisis Retro
“Thank you, America” – AIG CEO Robert Benmosche

“Profoundly unhappy” adolescents earn 30% less as adults – WSJ

Crisis Retro
“Thank you, America” – AIG CEO Robert Benmosche

“Profoundly unhappy” adolescents earn 30% less as adults – WSJ

Follow us on Twitter and FacebookAnd, of course, there are many more links at Counterparties.

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Why we can’t simplify bank regulation http://blogs.reuters.com/felix-salmon/2012/09/14/why-we-cant-simplify-bank-regulation/ http://blogs.reuters.com/felix-salmon/2012/09/14/why-we-cant-simplify-bank-regulation/#comments Fri, 14 Sep 2012 17:04:38 +0000 https://blogs.reuters.com/felix-salmon/?p=17657 Is simplicity the new new thing?

Is simplicity the new new thing? The front page of the new issue of Global Risk Regulator — the trade mag for central bankers around the world — features an excellent article by David Keefe about Sheila Bair, Andrew Haldane, and calls for a “return to simplicity”. Bair tells Keefe that “we’re drowning in complexity”:

“The public is tired of rules they don’t understand,” she said, adding: “We should be simplifying the rules, we should be simplifying the institutions for which the rules are made, but it’s going in the opposite direction.” …

Bair said she was in “wholehearted agreement” with Haldane’s attack on the complexity of regulation.

“Regulation”, in this context, means one very specific thing: Basel III, the new code governing the world’s banks. No one is advocating that it be abolished: it’s clearly much more robust than its predecessor, Basel II.

But if Basel II was horribly complicated, Basel III is much more complex still — and, as I and others have been saying for the past couple of years, that’s a real problem. Ken Rogoff puts it well:

As finance has become more complicated, regulators have tried to keep up by adopting ever more complicated rules. It is an arms race that underfunded government agencies have no chance to win.

More recently, bankers themselves have started saying the same thing: yesterday, for instance, Sallie Krawcheck said that the complexity of financial institutions “makes you weep blood out of your eyes”.

So perhaps there’s a consensus emerging that regulation needs to be simplified, trusting heuristics more while spending less time and effort complying with thousands of pages of highly-detailed rules. What matters is not whether financial institutions dot every i and cross every t, so much as whether they are behaving in a safe and sensible manner. After all, one of the main reasons that we haven’t seen any high-profile criminal convictions of bankers for their roles in the financial crisis is just that their compliance officers were generally very good at staying within the letter of the law. Which didn’t really help the system as a whole one bit.

But there are lots of very good reasons why even if we are reaching a consensus on this, that doesn’t mean there’s much if any chance of some new simple system ever actually coming into place.

For one thing, the window of opportunity has closed. In the immediate wake of the financial crisis, regulators found agreement that they should get tough: that had never happened before, and it’s likely that it will never happen again. Even in the Basel III negotiation process, national regulators tended to push hardest for regulations which would be felt the most by banks in other countries, rather than their own. But at least everybody was in the vague vicinity of the same page. Without another major crisis, no one feels any real urgency to implement yet another round of major regulatory change, especially before Basel III has even been implemented. And without that sense of urgency, nothing is going to happen.

And more generally, there’s a ratchet system at play here. It’s easy to make a simple system complex; it’s pretty much impossible to make a complex system simple. All of us live in a world of contracts and lawyers — and the financial system much more than most. Financial regulation will become simpler the day that contracts become shorter and easier to understand, which is to say, never.

How has the financial-services sector managed to make an ever-greater proportion of total profits over time? By extracting rents from complexity. As a result, any attempt to radically simplify anything in the sector is going to run straight into unified and vehement opposition from pretty much every bank and financial-services company in the world. (Note that Sallie Krawcheck, like Sandy Weill, only started criticizing bank complexity after she left the industry.)

So while banks opposed Basel III, at least they got increased complexity out of it, which means that the barriers to entry in the industry were raised. Which is good for them, and bad for the rest of us. Why did Simple, for instance, take so long to launch? Because it’s very, very difficult to create anything simple in today’s banking system. Complexity is here to stay, whether the likes of Bair and Haldane and Krawcheck like it or not. And with complexity comes hidden risks. Which means we’ll never be as safe as any of these people would like.

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All bank regulators are captured http://blogs.reuters.com/felix-salmon/2011/11/02/all-bank-regulators-are-captured/ http://blogs.reuters.com/felix-salmon/2011/11/02/all-bank-regulators-are-captured/#comments Wed, 02 Nov 2011 17:03:30 +0000 http://blogs.reuters.com/felix-salmon/?p=10887 Sheila Bair aims her fire squarely at Europe's banks and their regulators today, contrasting the high degrees of leverage and low degrees of capital in Europe to the safer banks we have here in the US.

Sheila Bair aims her fire squarely at Europe’s banks and their regulators today, contrasting the high degrees of leverage and low degrees of capital in Europe to the safer banks we have here in the US.

The U.S., which has tighter rules governing how FDIC-insured banks determine the riskiness of assets, requires well-capitalized banks to hold capital equal to at least 5% of total assets, regardless of how risky they think the assets are. So for any asset, be it cash, U.S. Treasury securities, or supposedly safe mortgages, banks must hold at least 5% capital against it. European banks do not have this kind of “leverage ratio,” and Basel II has allowed them to treat sovereign debt as having zero risk. That is one of the main reasons they have loaded up on nearly $3 trillion of it…

European regulators should supplement this [9% common equity capital] requirement with the Basel III 3% leverage ratio — or even better, the U.S. 5% requirement, adjusting for accounting differences. The EBA should also use realistic loss estimates more in line with those of the IMF and private analysts. If banks have to accept dilution of their stock or temporary nationalization, so be it…

U.S. regulators made many mistakes, but because we maintained our leverage ratio and delayed Basel II implementation, FDIC-insured banks have remained much more stable than other financial institutions. Bank capital standards should not be an insider’s game. The public deserves better. Bank regulators should do their job, and it is their job, not the job of conflicted bank managers, to set minimum capital levels.

I’m sure that Bair feels that it’s her intrinsic toughness and common sense which resulted in US banks being held to tougher standards than their European counterparts. And she’s absolutely right that when it comes to capital and leverage, US regulators came out of the crisis looking better than European regulators. But not by much. US investment banks were allowed to increase their leverage and decrease their capital as much as they liked — which is one reason why Bear Stearns and Lehman Brothers collapsed so quickly. And other countries, like Canada and India, were much tougher even than the US.

The fact of the matter, however, is that all regulators are captured by banks. Or, to be a little more precise, all legislatures are captured by banks, and all regulators do what the government tells them to do.

In countries like Canada and India, there’s a very small number of strong, well-capitalized banks with a vested interest in maximizing barriers to entry. So they’re happy with very tough standards. In Europe, national banking systems are also concentrated, so in theory they could go the same way. But European banks are more likely to have cross-border and global ambitions, and in any case as a matter of contingent fact they’re not very well capitalized. So they get the regulation they want — which allows them to grow fast without having to raise lots of expensive new equity capital.

And then there’s the US, which is pretty much unique among major economies in having thousands of pretty vibrant small banks. Those small banks have a lot of political clout in Congress, and they hated Basel II, because they’re not nearly sophisticated enough to take advantage of it. So they essentially bullied Congress into keeping the old Basel I standards, for fear that otherwise they would be at a massive competitive disadvantage with respect to the big US banks like JP Morgan Chase. Congress obliged, and used the FDIC as its chosen mechanism for blocking the adoption of Basel II in the US.

Does that make the FDIC particularly virtuous? No: it makes the FDIC just as beholden to the banks as any European regulator. Look at the banks’ contributions to the FDIC insurance fund, for instance: they fell to zero, for no good reason, just because the banks didn’t like making those payments.

So Bair is hopelessly naive if she thinks that European regulators — or even American regulators — can really ever force banks collectively to do something they don’t want to do. The only reason the FDIC has any teeth at all in terms of capital requirements is that it’s in the small banks’ interest, and those small banks have a lot of political influence. There really aren’t any small banks in Europe, and European taxpayers are now on the hook for much bigger potential financial-sector losses as a result. That’s bad for Europe, and the world. But the US, and Bair, are in no particular position to deliver lectures on this subject.

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How much will a capital surcharge hurt? http://blogs.reuters.com/felix-salmon/2011/09/30/how-much-will-a-capital-surcharge-hurt/ http://blogs.reuters.com/felix-salmon/2011/09/30/how-much-will-a-capital-surcharge-hurt/#comments Fri, 30 Sep 2011 18:17:46 +0000 http://blogs.reuters.com/felix-salmon/?p=10273 The Clearing House has a new study complaining about the idea that the world's biggest banks -- the Too Big To Fail institutions -- should have higher levels of capital than other banks.

The Clearing House has a new study complaining about the idea that the world’s biggest banks — the Too Big To Fail institutions — should have higher levels of capital than other banks. (The study is meant to be here, but the website isn’t working very well, so I’ve mirrored it here.pdf.) The main conclusion is that “if the Basel Committee’s G-SIB capital surcharge is implemented in the U.S., these banks would have to either increase the borrowing costs to their customers by 60 basis points” — an outcome so self-evidently horrific that the study doesn’t even bother to explain how harmful it would be.

But of course a closer look at the study shows that borrowing costs wouldn’t actually need to rise at all. Here’s the key headline in the presentation:


NIM here, is Net Interest Margin, which is then used to compute borrowing costs. And “NIX ratio” is non-interest expenses, known to many as “bankers’ bonuses”.

The calculations here are not mathematically unconvincing. According to The Clearing House, the cost of bank equity will go down under the new regime — by about 70 basis points. That won’t make up for the hit to shareholders from being less leveraged.

So yes, it’s entirely possible that there is indeed a non-negligible cost to implementing this surcharge. That cost is going to have to be borne by three different groups: borrowers, bankers, and bank shareholders.

But if you look at the report, it’s predicated on the idea that shareholders don’t bear any of the cost at all all: we have to “maintain shareholder returns”, for some unknown reason. This is silly, for reasons convincingly explained by Martin Wolf — the returns that banks are offering to their shareholders are far too high. Back in the 50s and 60s, banks had a return on equity around 7%; now they require more than double that. There’s no reason why we shouldn’t go back to the old returns.

If banks’ return on equity fell from about 15% to about 7%, then there wouldn’t be any increase at all in borrowing costs, and bankers could even keep their bonuses. But more likely, some combination of the three will happen: lower return on equity, lower bonuses, and slightly higher borrowing costs, to the tune of maybe a couple of tenths of a percentage point.

This is all good. Bankers’ bonuses should be lower. And borrowing from a big bank should cost more: it helps to incentivize borrowers to move their business to smaller, less systemically-dangerous institutions.

Besides, the problem right now isn’t that banks are lending at exorbitant rates: it’s that banks aren’t lending at all. I think many small businesses, especially, would be perfectly happy to pay an extra 0.6% if that meant they could get a loan rather than not get a loan.

And it’s undoubtedly true that the more capital banks hold, the less of a risk they pose to the financial system as a whole.

Right now, there are two huge risks which could result in trillion-dollar writedowns at the world’s too-big-to-fail banks. The first is real estate: prices are still falling in the US and around the world, and at some point mortgages can and should have their principal written down. And the second, of course, is developed-world sovereigns, especially on the European periphery. If they default, then there will be a lot of writing down to go around.

Higher capital levels can’t protect us fully against either of those risks, let alone both of them. But they would help. And if banks build up their capital to a healthy point, then maybe we’ll be able to orchestrate a market-friendly set of global writedowns which doesn’t bring the entire financial system to its knees.

Maybe that’s what the big banks really fear, here: that if they’re asked to build up their capital, that only means they’re going to be asked to write down that capital later. I can see why they wouldn’t be happy about doing such a thing. But for the other 99%, the idea frankly looks rather attractive.

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Basel: the Sifi surcharge arrives http://blogs.reuters.com/felix-salmon/2011/06/27/basel-the-sifi-surcharge-arrives/ http://blogs.reuters.com/felix-salmon/2011/06/27/basel-the-sifi-surcharge-arrives/#comments Mon, 27 Jun 2011 11:31:34 +0000 http://blogs.reuters.com/felix-salmon/?p=8789 Basel has spoken, and the Sifi surcharge -- the amount of extra capital that will have to be held by systemically important financial institutions -- will range from 1% to 3.5%, with no bank in the first instance being subject to a surcharge of more than 2.5%.

Basel has spoken, and the Sifi surcharge — the amount of extra capital that will have to be held by systemically important financial institutions — will range from 1% to 3.5%, with no bank in the first instance being subject to a surcharge of more than 2.5%.

This is more or less in line with expectations, and in fact is maybe a little bit tougher than was expected by some of the pessimists. It’s not the size of the surcharge which is particularly impressive, but more its nature: it’s made up only of the highest-quality capital — no CoCos allowed. And the fact that it’s based on a sliding scale means that it has the important feature of both dissuading the biggest banks from getting bigger and indeed giving them an incentive, at the margin, to get smaller.

The surcharge doesn’t end too big to fail, of course. Bethany McLean is absolutely right that capital requirements aren’t some kind of panacea, and that in and of themselves they don’t prevent crises. But they’re still a crucial part — along with liquidity and leverage constraints, and a crackdown on off-balance-sheet vehicles — of making the global banking system more robust, less pro-cyclical, and less prone to catastrophic failure.

And while the Sifi surcharge won’t stop banks growing to the point at which they have to be bailed out in extremis, it might make such growth significantly less profitable than it was in the past.

One of the peculiarities of the global financial crisis was the behavior of Citigroup’s deposits — here was a huge and insolvent bank, most of whose depositors were not insured. (Citi has many more deposits outside the US than it has domestically.) I was very worried about this: if those depositors moved their money out of an insolvent bank and into something safer, the consequences for Citi could have been disastrous. But the bank run never happened, and in fact over the course of the crisis Citi’s deposit base went up. That’s known as the moral-hazard play: depositors the world over trusted the US government to bail out Citi, as in fact it did, and knew that as a result their money was safe, backstopped by an implicit US government guarantee. Which you certainly can’t say about money held in a foreign branch of a mid-sized community bank.

That’s just one of many advantages to being huge, and as a result it’s great that Basel is forcing the likes of Citi to hold more capital than their smaller counterparts. It might be a relatively small victory, but every win counts.

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How the UK wants to deal with its biggest banks http://blogs.reuters.com/felix-salmon/2011/06/14/how-the-uk-wants-to-deal-with-its-biggest-banks/ http://blogs.reuters.com/felix-salmon/2011/06/14/how-the-uk-wants-to-deal-with-its-biggest-banks/#comments Tue, 14 Jun 2011 21:59:56 +0000 http://blogs.reuters.com/felix-salmon/?p=8655 In the Republican presidential debate last night, there was unanimity on most issues, including the new orthodoxy on the right that bank regulation -- like any other regulation, for that matter -- is a Bad Thing, and a sign of the government overreaching. It's important to remember that this is not the way that right-wing parties behave elsewhere in the world.

In the Republican presidential debate last night, there was unanimity on most issues, including the new orthodoxy on the right that bank regulation — like any other regulation, for that matter — is a Bad Thing, and a sign of the government overreaching. It’s important to remember that this is not the way that right-wing parties behave elsewhere in the world. Consider for instance the UK, which seems to be cracking down on banks in a manner which would make even Barney Frank blush:

Britain’s biggest banks will be forced to put a firewall around their retail operations, the chancellor will announce on Wednesday at the Mansion House…

This was the central proposal made by the Independent Commission on Banking (ICB) in its April interim report…

By putting retail banking into a separate legal subsidiary, ring-fenced from the trading and investment banking activities of a big bank, the vital parts of our giant banks will be less exposed to danger in a crisis.

The idea is that the retail banking bits of Barclays, HSBC and Royal Bank of Scotland will have more capital to absorb possible losses…

The ICB’s interim report suggested a minimum capital ratio for retail banks of 10%, which Mr Osborne is understood to support, although he won’t quote any precise number for the new minimum capital ratio.

A source close to the chancellor said there was “nothing sinister” in Mr Osborne’s reluctance to quote a particular number for how much capital above the international floor should be held by British retail banks. “Ten per cent is certainly the right ballpark”, he said.

This is bold and welcome thinking. From a regulatory perspective, banks have good profits and bad profits. Bad profits are the ones coming from risky structured products and leveraged trading desks; good profits are the ones which come from the lending investment capital to individuals, small businesses, and large companies. State-insured deposits should be use to fund good businesses, not risky and speculative businesses — as should any access to central bank liquidity windows.

So if you’re not going to break the big banks up, then the next best thing is to force their riskier arms to operate outside the protective walls of their too-big-to-fail retail operations. And the retail operations should be as bankruptcy-remote as possible, with extremely stringent capital requirements on the order of 10% of total assets.

Now the 10% figure, although it sounds tough, might not be quite as harsh as it seems at first glance: I’m sure that it’s based on risk-weighted assets, for one thing, and so the details of the risk weighting will be very important. And I suspect that banks might be able to put all manner of capital into that 10% bucket, beyond tangible core equity: the UK is likely to allow them to use their beloved CoCos, for starters.

All the same, Britain’s politicians are thinking constructively about how to rein in the more dangerous tendencies of its biggest banks. The same can’t be said, sadly, of their U.S. counterparts. There are bank regulators at the Federal Reserve and elsewhere who are trying to put in place higher capital requirements for systemically important financial institutions — but those will be negotiated on the international stage, in Basel, and will phase in very slowly. The UK policy, by contrast, could simply be implemented unilaterally, and would make that country significantly less prone to systemically-dangerous bank crises. Just don’t think for a minute that it’s likely to be replicated here.

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Basel spatwatch, EU vs US edition http://blogs.reuters.com/felix-salmon/2011/06/02/basel-spatwatch-eu-vs-us-edition/ http://blogs.reuters.com/felix-salmon/2011/06/02/basel-spatwatch-eu-vs-us-edition/#comments Thu, 02 Jun 2011 14:15:06 +0000 http://blogs.reuters.com/felix-salmon/?p=8512 The FT has all the details, starting with Peter Spiegel's story yesterday that Michel Barnier, the European commissioner in charge of financial markets, had sent a strongly-worded letter to Tim Geithner.

It’s not an easy time to be a central banker. In both the eurozone and the US, unemployment is proving stubbornly immune to monetary policy. And on the regulatory side of things, the global nature of the banking system means that you need to get all major countries on the same page. Which is proving all but impossible, as the latest little spat between EU and US regulators proves.

The FT has all the details, starting with Peter Spiegel’s story yesterday that Michel Barnier, the European commissioner in charge of financial markets, had sent a strongly-worded letter to Tim Geithner, complaining that the US has historically been very slow on adopting Basel standards, and that its attempts to regulate bankers’ pay are toothless and ineffectual. All of this is true.

Today, the FT follows up with the US response, which concentrates on the fact that the US is ahead of Europe on matters such as central clearing and derivatives trading, and hinting that Europe is more likely to backslide on the Basel III timetable than America is. These, too, are reasonable points. Treasury also pushes back on the matter of banker pay, saying it has no real interest in prescribing how much people get paid, just how much risk they’re incentivized to take. That one makes less sense.

This ministerial-level Twitter fight doesn’t, ultimately, make anybody look good. One of the big successes of the Basel III process was that while there were serious disagreements along the way, the governments and central banks concerned were pretty good at keeping the discussions productive and confidential. But just as with Dodd-Frank, it seems, the real difficulty is going to be in implementation, and that’s where there’s a big risk of everything becoming very political.

In the short term, the biggest winners in any fight between regulatory authorities are always going to be the banks, who will happily arbitrage differing regional regulatory regimes and take advantage of their parents’ squabbles to stay out drinking all night. In the long term, however, even the banks would ultimately prefer a single global regulatory regime with clear ground rules and a level playing field — something which lets them concentrate on their main job, of banking, rather than expending enormous effort on lobbying and loopholes.

But with large fractures now emerging even within Europe, and with attention being focused on averting the meltdown of the entire euro project, the chances of a global regulatory consensus seem as far away as ever. Which means that although Basel III is a great idea in theory, the jury’s still out on whether it’s ever going to be consistently implemented in practice.

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Regulatory arbitrage of the day, Citigroup edition http://blogs.reuters.com/felix-salmon/2011/04/19/regulatory-arbitrage-of-the-day-citigroup-edition/ http://blogs.reuters.com/felix-salmon/2011/04/19/regulatory-arbitrage-of-the-day-citigroup-edition/#comments Tue, 19 Apr 2011 13:34:09 +0000 http://blogs.reuters.com/felix-salmon/?p=7987 Well done to Tracy Alloway for calling it as it is, in a post headlined "Citi’s Basel-dodging, capital-avoiding, accounting switch".

Well done to Tracy Alloway for calling it as it is, in a post headlined “Citi’s Basel-dodging, capital-avoiding, accounting switch”. At issue is a pool of $12.7 billion in assets, which is housed at Citi’s “bad bank”, Citi Holdings.

In 2008, Citi decided that these assets were not available for sale, and rather were going to be held to maturity. Presto — the bank no longer had to mark the assets to market, and could hold them on its books at par instead. And the difference between par value and market value went straight to Citi’s precious capital, helping it look stronger.

Now, in the wake of a massive bond rally. Citi has decided to switch the assets back. No longer are they held to maturity; instead, they’re available for sale. At a stroke, Citi has to recognize all the gains and losses in the portfolio immediately — that’s $1.7 billion in losses, and $946 million in gains. But the losses can be applied against profits elsewhere in the bank, to reduce the total tax burden. Which is nice, because we wouldn’t want too much money flowing from Citigroup to the taxpayers which bailed it out.

Of course, banks can’t just oscillate back and forth between classifying assets as being held-to-maturity or marked-to-market at whim, depending on how such a classification makes them look in their quarterly report. That defeats the whole point of classing assets as being held to maturity in the first place. If you say an asset is going to be held to maturity, it should be held to maturity, not held to the point at which it’s no longer held to maturity.

And so Citigroup had to explain to regulators what excellent reason it had for changing the classification. And you’re going to love the reason it came up with. The authors of the new Basel III capital adequacy rules, it turns out, managed to notice that assets being held at par and held to maturity are naturally riskier than assets which the bank can sell at any time and is marking to market on a daily basis. And so the capital requirements on held-to-maturity assets are higher than the capital requirements on assets which are marked to market.

So far so reasonable. But Citi’s brainwave was to cite the new Basel III requirements as the fundamental change which would give them an excuse to switch classifications now that the bond market is looking frothy again. Basically, Citi went along to its regulators, and said hey, the capital requirements on these held-to-maturity assets are rather onerous, would you mind if we reclassified them so that we don’t need to hold as much capital against them? And the regulators said by all means, go ahead!

Of course, the assets themselves haven’t changed at all — they’re the same assets, being held at the same bad bank. But now the bad bank has a lower capital requirement, since the assets have been reclassified.

All that remains is to wait until the bond market goes down again, and see what new reason the bright sparks at Citi will be able to come up with to explain that actually, they want to go back to classifying the assets as being held to maturity. It’s all very simple, really: when bond prices are low, assets are held to maturity, and can sit on your balance sheet at par. When bond prices are high, they’re available for sale, and your capital requirements go down. The bank wins either way, while the regulators look like schmucks. And if Citi’s doing this, you can be sure everybody else worked it out long ago.

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