Overall Summary and Policy Implications
This paper deals with the off-balance sheet exposures of banks, which as the recent crisishas shown have grown remarkably over the course of the last 30 years. It first explains thelinkages of the banking system to the shadow banking system. Then, due to the complexityof the issues at hand and in order to reach analytical depth, it focuses on the accounting andprudential treatment of a very important part of the shadow banking sector, the market forshort term asset backed commercial paper. It traces the impact national regulators in canhave on the kind of engagements their banks have in these markets by analysing the differ-ent national regulations in Germany, France, Spain and the Netherlands and the respectiveengagement of banks from these countries in that market. The overall analysis demonstratesthe large scope of action national regulators have in regulating the off-balance sheet en-gagements of their banks. National Regulators are much more than agents enforcing inter-national treaties, rather they are interpreters of international accords in the frame of na-tional law, which leaves much space for interpretation. This implies that national parliamen-tarians, which are interested in increasing the financial stability of their respective bankingsystem, could and should engage in a close supervision of the actions of their national bank-ing regulators in this field in order to avoid regulatory capture. For this purpose they can useinternational comparisons by international organizations such as the OECD, internationalauditing firms and the rating agencies. The paper closes by showing the most recent changesin the treatment of off-balance sheet engagements of banks on the international level inorder to sensitize the readers to potential issues of interpretation involved in their interpre-tation.