Professional Documents
Culture Documents
Deposit insurance or deposit protection is a measure implemented in many countries to protect bank
depositors, in full or in part, from losses caused by a bank's inability to pay its debts when due. Deposit
insurance systems are one component of a financial system safety net that promotes financial stability.
History
• 1924 : First central government sponsored deposit insurance in Czechoslovakia
• 1934: Federal Deposit Insurance in the US
• 2004: 83 countries out of 181 have explicit deposit insurance. The rest have implicit
insurance.
Purpose
• Reduce probability of bank failure, for instance caused by a bank run. (bank run= when
many clients withdraw their money)
o Specifically, reduce bank run on a single bank that can be ill-founded.
o In addition, reduce banks runs involving more banks based on informational spill-
overs that can also be ill-founded.
• Reduce cost of bank failure in the form of
o Losses to depositors, especially small depositors
o Reductions in funding of economic activity
o Losses to government in case of bailouts of distressed banks
Banking crisis is more costly than failure of other firm of comparable size. Are banks also more
fragile?
• Banks have a high proportion of demandable and other short-term debt. This makes
banks susceptible to bank runs.
• Average maturity of assets tends to be larger than average maturity of liabilities. Loans,
for instance, have a higher maturity than demandable, zero-maturity deposits. Hence,
there is a maturity mismatch.
• This makes bank susceptible (rentan) to ‘fire sales’, i.e. they may have to sell long-
maturity assets quickly at reduced prices.
• Banks have small proportion of cash relative to assets. This may also force banks to sell
illiquid assets on short notice.
• Banks have high leverage. Hence, there is little capital to be depleted before a bank is
bankrupt
Current structure of US deposit insurance
• Both ex ante and ex post deposit insurance premiums.
o Ex ante premium is regular insurance premium
o Ex post premiums: banks that survive have to pay for banks that went under.
o Hence, the US Federal Deposit Insurance Corporation (FDIC) is effectively backed
by the capital of the entire banking industry. If banking system runs out of
capital, then the U.S. Treasury will have to pay.
• Insurance premium is risk-based, i.e. premium depends on riskiness of bank assets.
Risk-based deposit insurance is insurance with premiums that reflect how prudently banks act
when investing their customers' deposits.
• Should premium be risk-based?
o This reduces incentives for banks to take risk. Bank become reluctant to take
risks
• However, risk-based premiums would not be necessary if banks that are losing capital
are closed or sold in time before deposit insurance funds need to be paid out.
o Thus, as important bank risk is regulatory risk, meaning that regulators do not
intervene promptly if a bank is heading towards bankruptcy.
o In the US, regulators have to close or otherwise deal with banks that have
equity-to-assets ratios below 0.02 within 9 months. This is the requirement of
‘prompt and corrective action’.
Market discipline
• Market discipline exists if the cost of bank funding reflects the riskiness of a bank’s asset
portfolio. If so, it potentially constrains bank risk taking.
• To illustrate, we first consider a two-period model of how market discipline affects the
asset risk choice of banks.
• A subsequent question will be whether deposit insurance reduces market discipline.
•
• Here, 𝑎 is assets, 𝑙 is liabilities, and 𝑒 is equity. 𝑣 is the value of assets 𝑎 in the second
period. 𝑣 is a random variable on the interval [ 0, ∞ >.
• Payouts to equity and liability holders in the second period are also random:
• 𝑃𝑒 = 𝑣 – 𝑙 if 𝑣 − 𝑙 ≥ 0, 𝑃𝑙 = 𝑙 if 𝑣 − 𝑙 ≥ 0
• 𝑃𝑒 = 0 if 𝑣 − 𝑙 < 0, 𝑃𝑙 = 𝑣 if 𝑣 − 𝑙 < 0
• In the first period, the bank has to select a distributions of 𝑣: 𝑔(𝑣) 𝑜𝑟 𝑓(𝑣)
• They have the same expected value: 𝐸𝑔 (𝑣) = 𝐸𝑓 (𝑣) > 𝑙
• But distribution 𝑓 is relatively risky as it has fatter tails:
•
• Return to liability holders under 2 strategies:
• To compensate liability holders in case distribution 𝑓 (more risky) is chosen, they will
demand a higher interest rate. Hence, they exercise market discipline.
• This eliminates the incentive for the bank to choose distribution 𝑓.
Empirical evidence on market discipline
• Flannery and Sorescu (1996) find that debenture yields (hasil obligasi) reflect a bank’s
default risk as represented by financial ratios based on accounting data.
• Effective market discipline entails that investors monitor banks affecting bank liability
and equity prices, and that these prices affect firm behaviour. Firm behaviour can be
affected in two ways:
o directly, through actions of the firm
o indirectly, through actions of the supervisor
Does deposit insurance reduce market discipline? Basically the answer is YES
• Deposit insurance makes deposit interest rate in theory less dependent on bank risk.
Hence, it potentially undermines market discipline
• Empirical study of the effect of deposit insurance on extent of market discipline by
Demirguc-Kunt and Huizinga (2004).
• Deposit insurance reduces market discipline if it reduces the sensitivity of bank interest
expenses to indicators of bank risk.
•
• We expect:
𝜃 < 0 : higher value of 𝑅𝑖,𝑡−1 means lower risk, reducing interest expenses
𝛿 < 0 : deposit insurance leads to lower interest expenses
𝜑 > 0 : deposit insurance reduces sensitivity of interest expenses to bank risk, implying
less market discipline
• The estimating equation implies:
• From regression 1:
o 𝜃 = −0.597
o 𝛿 = −0.015
o 𝜑 = 0.609
• Hence,
• Thus, there is a reduced sensitivity of interest expenses to the equity variable in case
there is explicit deposit insurance as evidence of lower market discipline.
• From Regression 1
o 𝜃 = 1.787
o 𝛿 = 0.114
o 𝜑 = −1.502
• Hence:
• Thus, there is a reduced sensitivity of the deposit growth rate to the equity variable in
case there is explicit deposit insurance as evidence of lower market discipline
o
o The authors estimate a multivariate logit model.
o β > 0 implies that explicit deposit insurance makes a crisis more likely
• Example:
• Thus, explicit deposit insurance increases the probability of a banking crisis. Liat dari
beta nya kalo lebih dari 0 berarti increase
Deposit insurance may not reduce financial stability much if there is good bank supervision.
• With good bank supervision, bank is not allowed to pursue risky strategies despite the
presence of deposit insurance.
• Let 𝑄 be quality of supervision, or more generally the quality of legal and other public
institutions in a country.
• Econometric Model:
Lecture 4: Large Banks: Are They Too Big to Fail or Too Big to Save?
The value of TBTF subsidy to financial institutions
• Claimants to TBTF financial institutions receive transfers from tax payers when
governments are forced into bailouts.
o These claimants can include depositors and bank bondholders.
• Subsidies implicit in bailouts lower funding costs to TBTF institutions
• Implications:
o TBTF institutions have incentive to take on more risk: moral hazard, (krn mereka
lowkey tau kalo ada apa2 bakal di bail-out government, jadi mereka malah
berani buat take more risk unwisely)
o Incentive to be become large and complex, e.g. through M&As
o Distortion of competition with other firms that do not enjoy TBTF subsidy. This
enables TBTF banks to can gain market share and additional profits at the
expense of smaller firms that are not TBTF.
Deposit insurance and wealth effects: The value of being “Too Big To Fail”
• In September 1984, the Comptroller of the Currency testified before Congress that some
banks are simply ‘too big to fail’ and that for those banks total liability insurance would
be provided. This policy would apply to the 11 largest banks, while names were not
given. [Comptroller of the Currency is the head of a U.S bank regulatory agency.]
• Empirical question: Does this provide wealth effects for bank shareholders that are
positive for the top 11 banks, and negative for other smaller banks?
Why positive wealth effects (they feel richer even though they have the same amount of
income beforw) for TBTF banks?
• Total liability insurance renders bank liabilities riskless. This reduces banks’ cost of
funds. Normally, only $ 100,000 is fully insured by deposit insurance.
• Banks can take on more risk, as their liabilities have become riskless
• Wealth effects could be negative for smaller banks that are not TBTF
• Wealth effects are investigated for sample of 64 banks with stock market listing,
including 11 largest banks.
• Example:
• Most of the largest 11 banks experienced a positive stock return on September 20,
1984. Continental Illinois was already bankrupt at the time, which explains its zero stock
return.
• Positive stock returns of banks on September 20, 1984 could reflect that the overall
stock market went up that day.
• To control for the movement of the overall stock market, we next consider excess stock
returns for banks. i.e. stock returns for banks that are adjusted for the movement of the
overall market.
o where 𝑅𝑚,𝑡 is the return for the overall stock market at time t, and where 𝛼 ̂ 𝑗
and 𝛽𝑗 ̂ are estimated for each bank for days -55 to -6 relative to September 20,
1984
• Excess return for bank 𝑗 at time 𝑡:
• Example:
•
• Excess returns are positive on day 0 for Wall Street Journal (WSJ) sample of 10 banks (11
banks excluding Continental Illinois that had gone bankrupt and already had been bailed
out).
o The Liabilities variable measures a bank’s total liabilities relative the GDP of its
country of location.
•
o Note that 13 of these 20 countries are European
•
o Thus, for 85.8% of bank observations the ratio of total bank liabilities to GDP is
less than 0.05, while for 0.9% this ratio exceeds 1.
•
o This figure shows that the average bank-level ratio of total bank liabilities to GDP
fell sharply in the financial crisis year 2008
• Dependent variables in empirical analysis to determine whether banks are TBTF or TBTS:
o Market value of the bank relative to book value:
To swap the risk of default, the lender buys a CDS from another investor who agrees to reimburse the lender in the
case the borrower defaults. Most CDS contracts are maintained via an ongoing premium payment similar to the
regular premiums due on an insurance policy.
• We relate MV/BV and the CDS spread to measures of bank size to test for TBTF or TBTS:
o Estimating equations:
o If CDS spread declines, this means lower liability insurance premium, and hence
a safer bank.
• Sample:
o Note: The sample includes banks around the world during 1991-2008
o In regression 1, MV/BV is negatively and significantly related to Assets and to
Liabilities (which is bank liabilities relative to GDP): This is evidence consistent
with TBTS.
o In regression 3, MV/BV is negatively and significantly related to Other liabilities
(which is the sum of other banks’ liabilities relative to GDP): This is evidence
consistent with TBTS.
o In regression 8, the CDS spread is positively and significantly related to Other
liabilities (which is the sum of other banks’ liabilities relative to GDP): This is
evidence consistent with TBTS.
o Thus, the evidence points in the direction banks being TBTS
• Evidence of a negative relationship between MV/BV and bank size suggests that banks
have grown too large.
In particular, bank growth has not been in the interest of bank shareholders.
• Why did banks grow to be so large?
o Executive compensation increases with size
o Prestige and power of bank executive rise with size
• This suggests that the problem is one of corporate governance: how to make sure that
manager does what is in the interest of shareholders.
•
• Hence, Global Systemically Important Banks (G-SIBs) are large (by total assets),
international (by % of foreign assets), and complex (by total subsidiaries and number of
countries).
• Of the 28 G-SIBs, 16 are in Europe, 8 in the US, 3 in Japan and 1 in China
Bank
Underwriting
Insurance
b. Parent bank with non-bank operating subsidiaries
Parent
bank
i.
c. Holding company with bank and non-bank affiliates
Holding
company
under insurance
bank
writing
Corporate complexity and the safety and soundness of the financial system
Potential sources of conflict among national supervisors of banks that affect financial
stability:
• International exchange of relevant information: Information may be withheld by one
regulator
• When to intervene: Principal supervisor may wish to postpone intervention if costs of
intervention are primarily domestic. In the US, intervention is required if the ratio of
equity to assets is less than 0.02 by doctrine of ‘prompt and corrective action’.
• Which country’s law and bankruptcy proceedings to use?
• There are possibly different views internationally on whether a bank is systemically
important, and hence needs to be bailed out.
• Who pays for bailout? There is a potential problem of burden sharing
Recapitalization of bank in international context Recapitalization, inject money to increase liquidity of the bank
• Recapitalization carries the benefit of keeping the payments system afloat and the cost
of public bailout moneys.
• In domestic context, the benefits and cost of recapitalization are for a single country.
Then recapitalization decisions will be efficient, i.e. there will be recapitalization if
benefits exceed costs, and only then.
• In international context, benefits of recapitalization are collective, but contributing to
the bailout remains a national cost. Then recapitalization decisions may be inefficient,
because of a coordination problem.
• Contributing to recapitalization is a public good. There may be underprovision of this
public good in an international context.
• Model based on Freixas (2003) in paper on ‘Crisis Management in Europe’
• Domestic setting:
o 𝛩: benefit of recapitalization, i.e. keeping distressed bank afloat
o 𝐶: bailout cost
• Decision:
o Recapitalize if 𝜃 − 𝐶 > 0 (positive)
o Let bank fail if 𝜃 − 𝐶 < 0 (negative)
o Decision is efficient
o Let us assume
1. 𝜃 − 𝐶 > 0
This means that recapitalization is collectively efficient
2. 𝜃𝑗 − 𝐶 < 0 for all 𝑗
No country can benefit from recapitalizing the bank individually.
o Will bank be recapitalized? For this we need two condition to be satisfied:
i. 𝑃 = 𝐶 [sufficient contributions]
ii. 𝜃𝑗 ≥ 𝑃𝑗 [each country benefits from recapitalization]
o Can recapitalization be a non-cooperative equilibrium?
§ Consider that countries apply the following payment rule:
=
Hence, each country gets a share # of the collective gains 𝜃 − 𝐶 from
recapitalization. This means that condition ii) is satisfied, each countries
benefits from recapitalization
§ Are aggregate payments sufficient?
Yes, aggregate payments are sufficient. Hence, condition i) is satisfied,
§Thus, payments according to the given payment rule can be
noncooperative equilibrium outcome. It is rational for country 𝑗 to apply
this rule if all other countries are doing this.
§ Recapitalization occurs even though countries do not explicitly
cooperate. They just believe (correctly) that other countries make
payments according to the given rule.
o Can absence of recapitalization also be an equilibrium?
§ In particular, can 𝑃𝑗 = 0 for all 𝑗 be noncooperative equilibrium?
§ 𝑃> = 0 is optimal policy for country 𝑗 given 𝑃?> = 0 for other countries than
country 𝑗. –
§ This reflects that country 𝑗 will not recapitalize the bank by itself given
that no other country contributes.
§ Hence, there are multiple equilibria, as both recapitalization and no
recapitalization can be equilibria.
The mean value of the liability concentration variable is 0.966. Thus, most banks have
liabilities in only 1 or very few countries
• Estimating equation to examine the impact of the foreign liabilities share (FLS) on
interest expenses:
o We expect to find:
§ 𝛽1 > 0 , as more international banks (measured by a higher FLS) may
need to pay higher interest rates as the prospect of a bailout is less
certain.
§ 𝛽2 < 0 , as more profitable banks are less likely to require a bailout.
Hence, the relation between interest expenses and the degree of bank
internationalization is expected to be weaker for more profitable banks.
• Alternatively, we can replace FLS by CON in the estimating equation to get:
o Note that
o We expect to find:
§ 𝛽1 < 0 , as more international banks (measured by a lower CON) may
need to pay higher interest rates as the prospect of a bailout is less
certain
§ 𝛽2 > 0 , as more profitable banks are less likely to require a bailout.
Hence, the relation between interest expenses and the degree of bank
internationalization is expected to be weaker for more profitable banks.
•
o In regression 2 including FLS, we find 𝛽1 = 0.042 > 0 and 𝛽2 -1.740 < 0 (ini yg
lagged). This provides evidence that banks with a high foreign liabilities share
have higher interest expenses, especially if they have lower profitability.
o In regression 4 including Concentration (CON), we find 𝛽1 = −0.021 < 0 and 𝛽2 =
0.882 > 0 (lagged). This provides evidence that banks with a high foreign
liabilities concentration have lower interest expenses, especially if they have
lower profitability.
o Overall, the evidence suggests that more international banks face higher
interest expenses, consistent with reduced chances of generous bailouts for
these banks.
• World GDP growth rate is index of global economic health. This can substitute for the
profits rate as an index of bank-level financial health.
o Estimating equation:
o We expect to find:
§ 𝛽1 > 0 , as more international banks (measured by a higher FLS) may
need to pay higher interest rates as the prospect of a bailout is less
certain.
§ 𝛽2 < 0 , as more profitable banks are less likely to require a bailout. Banks
tend to be more profitable at times of high world GDP growth. Hence, the
relation between interest expenses and the degree of bank
internationalization is expected to be weaker at times of high world GDP
growth.
• Example
This figure shows that international banks faced only slightly higher interest expenses
than domestic banks in years such as 2000 and 2006-2007 of high world GDP growth.
The year 2000 preceded the bursting of the internet stock market bubble in 2001, and
the years 2006-2007 preceded the financial crisis of 2008-2009
• Interaction of the foreign liabilities share with world GDP growth
The interaction of the foreign liabilities share with world GDP growth receives a negative
coefficient of -0.944. This implies that interest expenses rise less with the foreign
liabilities share at times of higher world GDP growth.
• A country is more likely to be able to bail out a bank if it has plentiful public resources.
o This is more likely to be the case if the country experiences a fiscal balance
surplus.
o To consider this, we construct the Fiscal balance variable which is given by the
ratio of the fiscal balance to GDP.
• To consider the role of the Fiscal balance variable, we split the sample into two
subsamples with:
i. Fiscal balance > 0 (there is a fiscal surplus)
ii. Fiscal balance < 0 (there is a fiscal deficit).
• We expect the relation between a bank’s interest expenses and its degree of
internationalization to be weaker if the fiscal balance is positive, as then a country may
have sufficient resources to bail out all banks, including international banks.
• Example: Sample split for interest expense regressions by fiscal balance
o In case there is a fiscal deficit, we see that a bank’s interest expenses are
positively related to the foreign liabilities share (in regression 3) 0.032, and
negatively to Concentration (in regression 4) -0.026.
o This shows that bank internationalization has a more positive impact on
interest expenses in countries experiencing a fiscal deficit.
Conclusion
• International banks have relatively high interest expenses.
• Depositors exercise market discipline on especially international banks.
• This suggests that the financial safety discriminates against international banks, which
are then at a competitive disadvantage.
• Possible solution: Bailout decisions can be taken at an international level. This is the
case in the euro area after the establishment of the Single Resolution Mechanism.
(SRM)
Lecture 6: Financial Sector Taxation
In 2010, the IMF published a report entitled: ‘A Fair and Substantial Contribution by the
Financial Sector’ Objectives:
• To ensure domestic financial institutions bear the burden (menanggung beban) of any
extraordinary government interventions fairly and efficiently. Efficiently means without
endangering real economy. Fairly means that beneficiaries of prior bailouts should pay
the most. It means that banks are asked to pay higher bailout by higher taxation.
• To address banks’ excessive risks today (for instance, through overleveraging) to reduce
the probability and costliness of crises.
Public support provided and measures to recover it in recent crisis: money from taxation can be
used for
• Capital injections
• Lending to banks by treasuries, the ministry provide loans
• Asset purchases and protection schemes.
o For instance, the government can sell put for certain bank assets to banks with a
particular exercise price
• Guarantees of bank liabilities,
• Provision of liquidity and other support by central banks, central banks lend money to
commercial banks
• Expanded deposit insurance (coverage increased from € 20,000 to €100,000 in the EU
after the crisis), $250,000 (US)
Cost of Direct support consist of capital injections, purchase of assets, and lending by the
treasury
Taxation and regulation to address adverse (negative) externalities from the financial sector in
case of bank failure
• In a simple textbook world, tax and regulations could be equivalent. Consider the
problem of capital adequacy:
Bank Levies
• Purposes: cover net fiscal cost of direct public support (bailouts), and help reduce
excessive risk taking (generate new revenue).
• Revenue (if it paid to government) could go into special fund. In that case, the bank levy
could lead to moral hazard, if fund is seen to make future bailouts more likely., bcs they
are guaranteed bank tend to start taking more risk unwisely
• Base of levy would be balance sheet measure. It could be broad measure of liabilities of
a bank, giving rise to a relatively low rate.
• To be excluded from the tax (bank levy) base:
o Equity, to encourage capital
o Insured deposits, to avoid double taxation
o Intracompany debt to bcs we want the bank levy to be neutral to company
structure. Equivalently, just liabilities of consolidated firm could be taxed.
• Alternatively, tax base could be risky component of funding such as
o Wholesale funding (short-term funding from capital market), risky funding for
banks
o Foreign funding
Disadvantage: narrow base requires high rate, which can lead to distortions
• Rate of the levy
o Could depend on risk of the institution
o How high should the rate be?
The ratio of liabilities to GDP can be taken to be (equal to 2 times) 2. With a rate of
0.1%, revenues will be 0.2% of GDP per year. After 10 years, revenue will be 2% of
GDP, and after 20 years 4% of GDP. This corresponds to the cost of a crisis, which
tends to be in the 2-4% of GDP range.
In 2011, the European Commission proposed a directive for a common system of financial
transactions tax.
• With EU-wide tax rate of 0.1% on bond and equity transactions and a rate of 0.01% on
derivative transactions
• Estimated revenue per year is € 57 billion,
• Proposal was for revenue to be divided between EU and member states
• Proposal was not accepted by member states
• 2013 new proposal, not all eu countries participate only 11 countries
International Taxation
• Tax rate variables:
o 𝑡𝑖 is the corporate tax in subsidiary country i
o 𝑡𝑝 is the corporate tax in parent country i
o 𝑤𝑖 is the non-resident withholding tax in subsidiary country i on income
repatriated to country p
o Let 𝜏𝑖𝑝 𝜏)$ be additional international tax.
𝜏)$ = [total tax on income flowing from country i to country p] – 𝑡)
• Calculation of additional international tax depends on the pertinent convention of
double tax relief.
• Examples of double tax relief conventions:
•
•
The national share of foreign ownership is the share of the assets of foreign-owned
banks in total assets of banks located in a country.
Mean values of tax related variables for banks by country of residence
• Host country corporate tax is corporate income tax rate in the bank’s country of
residence. Dividend double tax is the double tax rate on repatriated dividend income
Estimate of 𝛽 is 0.035 F
Banks as Information Processing Intermediaries, to make risky loans they have to make
judgement from their customer information
• Banks absorb risk to transform liquidity and credit risk characteristics of assets
(qualitative asset transformation)
• Banks invest in illiquid loans (loans for a house for like 30 years) and finance them with
liquid demandable deposits
• Banks invest in risky loans (loans after recession) but finance them with riskless deposits
(there’s deposit insurance to reduce the risk)
Relationship Banking
• Substantial contractual flexibility based on the generation of hard and soft proprietary
information during a banking relationship
• Write discretionary contracts ex ante (before the law created) that leave room for ex
post adjustments
• Timely intervention: when the bank loan has sufficiently high priority, the bank could
threaten to call back the loan
Implication of Integration
• Greater competition is inducing banks to follow their customers to the capital market.
Providing Risk mitigation products like liquidity guarantee, underwriting, for their own
risk management too,
• Banks themselves are using the financial market increasingly for their own risk
management example CDS credit default swap, securitization
• More difficult to isolate banking risks from financial market risks, become active on
capital market
• Bail out of uninsured investors, thereby increasing moral hazard
Securitization,
• Prior to 2007-2009 crisis banks securitized an increasingly wide range of assets, such as
mortgage loans, take (grant) hundreds of mortgage loans and sell them to financial
markets
• Changing role of banks from “originate and hold” to “originate, repackage and sell”
Traditional Securitization
• Pooling of credit risky assets, such as residential mortgage loans
• Subsequent sale to special purpose vehicle
• SPV issues securities
*Special Purpose Vehicles Work. The SPV itself acts as an affiliate of a parent corporation,
which sells assets off of its own balance sheet to the SPV. The SPV becomes an indirect
source of financing for the original corporation by attracting independent equity investors to
help purchase debt obligations.
• Securities are sold to investors where the principal and interest depend on the cash
flows produced by the pool of underlying financial assets (MBS)
f
Evolution of Non-Financial Capital/Asset Ratios (1978-2002)
Reduction in Bank Capital/Asset Ratios
• Moral hazard in the banking system due to existence of explicit and implicit guarantees
(too big to fail), too costly to let big banks fail, may create losses to other banks, millions
accounts will lose their access to their money or debt, government need to rescue the
bank, it will create expectation to the investor, like will be rescued by government, new
equity capital will be injected, for the bondholder higher equity capital buffer enable
bank to guarantee losses
• Perverse incentives for taking more risk and reducing bank capital
• Bond holders have no incentive for proper risk monitoring and disciplining of the bank
• Short-term bonus schemes
Market Discipline
Market discipline is the onus (tanggung jawab) on banks, financial institutions, sovereigns, and
other major players in the financial industry to conduct business while considering the risks to
their stakeholders. Market discipline is a market-based promotion of the transparency and
disclosure of the risks associated with a business or entity. It works in concert with regulatory
systems to increase the safety and soundness of the market.
https://www.investopedia.com/terms/m/market-discipline.asp
• Flannery: market discipline entails two components, namely monitoring and influencing
• First, if investors accurately monitor their bank’s condition, security prices and the
bank’s liability choices will reflect that market information
• Second, investors’ reactions to a bank’s credit developments must influence how the
firm behaves
• if bank taking too much risk and bank equity capital ratio does not increase the investors
will require higher risk premium on their debt means higher discount rate and higher
market price
Through the support of disclosures and clear financial reporting systems, market discipline
increases the information available to the public and encourages the release of timely data on a
company's assets, liabilities, income, net profit or loss, cash flows, and other financial
information. In addition, qualitative information surrounding a company’s goals, management,
and any legal pressures also becomes more readily available. This data helps reduce
uncertainty, increase accountability, and promote the function of the market as an exchange
between lenders and borrowers.
An example of market discipline is public support for raising capital requirements. Banks and
other depository institutions must have liquidity for a certain level of assets. While regulatory
agencies like the Bank for International Settlements, the Federal Deposit Insurance Corporation
(FDIC) or the Federal Reserve Board set standards for capital requirements, market discipline
pushes banks to uphold and even expand them. In turn, this can increase the public’s confidence
in their banks.
Basel 1 (1988)
• Capital requirements for assets divided into credit risk buckets
• Also capital requirements for off-balance sheet (OBS) exposures
• OBS exposures are converted into on-balance sheet credit equivalents
• Guarantees for securities issued by special purpose vehicles (SPV) investing in subprime
mortgage loans
Basel 2 (2004)
• Basel 2 addresses regulatory capital arbitrage problem of Basel 1
• Increased risk differentiation by allowing banks to design internal ratings based systems
• Potentially perverse incentives for underestimating, deliberately or undeliberately,
credit risk profile and capital need
• Lack of market discipline as a counterbalance
Basel 3 (2010)
Basel III introduced new requirements with respect to regulatory capital with which large banks
can endure cyclical changes on their balance sheets. During periods of credit expansion, banks
must set aside additional capital. During times of credit contraction, capital requirements can be
relaxed.
The new guidelines also introduced the bucketing method, in which banks are grouped according
to their size, complexity, and importance to the overall economy. Systematically important banks
are subject to higher capital requirements.
Contingen Capital
• Mandatorily convertible bonds referred to as CoCos (Credit Suisse) or bonds with
mandatory loss clause (Rabo)
• Could make the increase of bank capital easier: not only shares but also debt capital
• Markets for contingent capital need to be developed with adequate risk-return trade off
• Promising signals from Asia and the Middle East
Compensation Schemes
• Change incentive schemes of management by defining longer-term targets
• Introduce claw back clauses
• Maximize bonus part of compensation package
• Banks have a special role in society which requires a social responsibility of bankers in
order to regain confidence
Lecture 9: Basel 3
Financial Crisis 2007-2009
• Financial crisis has many causes (such as monetary policy providing cheap liquidity, lack
of well-regulated markets for securitized mortgages)
• Financial crisis clearly demonstrates fragility of bank balance sheets and inadequacy of
bank capital levels
• Very soon after the first problems emerged in August 2007 banks stopped lending to
each other
• Unprecedented injections of liquidity, capital support and guarantees, exposing
taxpayers to large losses
Critique of Basel 2
• Complexity and regulatory burden
• Supervisory burden given information disadvantage
• Gaming, manipulation and risk arbitrage
• Insufficient attention to market discipline
• Reduction of regulatory capital contrary to initial aim
• Procyclicality
• Focus on individual banking institution (microprudential)
• No focus on stability of the whole banking system or systemic risk (macroprudential)
• Excessive on-and off-balance sheet leverage
• Lack of high-quality capital for absorbing losses
• No focus on bank liquidity
Bank Capital
• Financial crisis demonstrated that
o not all bank capital was available for absorbing losses
o inconsistency in the definition of capital across jurisdictions and lack of
disclosure
• Focus on Tier 1 capital (“going-concern capital”) within total capital requirement; Tier 2
capital (“gone-concern capital”) counts only for max. 2%
• Moreover, predominant form of Tier 1 capital must be common shares and retained
earnings
Tier 1 Capital
Tier 1 capital is a bank's core capital and includes disclosed reserves—that appears on the
bank's financial statements—and equity capital. This money is the funds a bank uses to function
on a regular basis and forms the basis of a financial institution's strength. These funds come
into play when a bank must absorb losses without ceasing business operations. Tier 1 capital is
the primary funding source of the bank.
https://www.investopedia.com/ask/answers/043015/what-difference-between-tier-1-capital-
and-tier-2-capital.asp
• Common equity Tier 1 capital consists of common shares and retained earnings plus
items such as stocks surplus (share premium)
• Additional Tier 1 capital is
o subordinated to depositors, general creditors and subordinated debt
o perpetual or may be callable at the initiative of the issuer only after a minimum
of five years under the condition that it is replaced by capital of the same or
better quality, or the bank demonstrates that the capital position is above the
minimum
• Additional Tier 1 capital includes contingent capital instruments classified as liabilities
for accounting purposes but having principal loss absorption through
o conversion to common shares at an objective pre-specified trigger point, or
o a write-down mechanism which allocates losses to the instrument at a pre-
specified trigger point
Contingent Capital
• Mandatorily convertible bonds referred to as CoCos (Credit Suisse) or bonds with
mandatory loss clause (Rabo)
• Could make the increase of bank capital easier, but the Basel Committee only allows
limited application as part of Tier 1 capital
• Markets for contingent capital need to be developed with adequate risk-return trade off
but signals from Asia and the Middle East are promising
Tier 2 Capital
Tier 2 capital includes undisclosed funds that do not appear on a bank's financial statements,
revaluation reserves, hybrid capital instruments, subordinated term debt—also known as junior
debt securities—and general loan-loss, or uncollected, reserves. Revalued reserves is an
accounting method that recalculates the current value of a holding that is higher than what it
was originally recorded as such as with real estate. Hybrid capital instruments are securities
such as convertible bonds that have both equity and debt qualities.
Tier 2 capital is supplementary capital because it is less reliable than tier 1 capital. It is more
difficult to accurately measure due to its composition of assets that are difficult to liquidate.
Often banks will split these funds into upper and lower level pools depending on the
characteristics of the individual asset.
• Tier 2 capital is
o subordinated to depositors and general creditors (e.g., subordinated debt)
o may be callable at the initiative of the issuer only after a minimum of five years
under the condition that it is replaced by capital of the same or better quality, or
the bank demonstrates that the capital position is above the minimum
Conservation Buffer
• The capital conservation buffer was introduced to ensure that banks have an additional
layer of usable capital that can be drawn down when losses are incurred. The buffer was
implemented in full as of 2019 and is set at 2.5% of total risk-weighted assets
• During the financial crisis many banks continued to make large distributions in the form
of dividends, share buy backs and generous compensation payments
• In case the common equity Tier 1 ratio falls below 7% the bank is required to conserve
an increasing part of its earnings in the subsequent financial year (up to 100%)
Countercyclical Buffer
Basel III introduced new requirements with respect to regulatory capital with which large banks
can endure cyclical changes on their balance sheets. During periods of credit expansion, banks
must set aside additional capital. During times of credit contraction, capital requirements can be
relaxed.
Leverage Ratio
A leverage ratio is any one of several financial measurements that look at how much capital
comes in the form of debt (loans) or assesses the ability of a company to meet its financial
obligations. The leverage ratio category is important because companies rely on a mixture of
equity and debt to finance their operations, and knowing the amount of debt held by a company
is useful in evaluating whether it can pay off its debts as they come due.
A leverage ratio is any one of several financial measurements that assesses the ability of a
company to meet its financial obligations.
• Many banks built up excessive leverage while still showing strong risk-based capital
ratios
• During the crisis banks were forced by financial markets to reduce leverage, thereby
amplifying downward pressure on asset prices and exacerbating losses, declines in bank
capital and contraction in credit availability
• Introduce a “simple, transparent, non-risk based leverage ratio that is calibrated to act
as a supplementary measure to the risk-based capital requirements
• Basel 3 introduces minimum Tier 1 leverage ratio of 3% of non-risk based assets plus the
on-balance sheet credit equivalent of off-balance sheet activities
• Parallel run period from January 2013 until January 2017 tracking the behaviour over
the economic cycle and relative to the risk-based requirement
• Leverage ratio used to be seen as a crude risk measure when designing Basel 2
Risk Coverage
• Strengthen the risk coverage of the Basel 2 framework
• Raise capital requirements for the trading book and complex securitization and off-
balance sheet exposures (such as SIVs)
• Increase capital requirements for counterparty risk exposures arising from banks’
derivatives, repo and securities financing activities, thereby also providing incentives to
move OTC derivative contracts to central counterparties
Systemic Risk
• Strong interconnectedness among systemically important banks (SIBs) can transmit
shocks across the financial system
• Negative externalities of institutions that are perceived as not being allowed to fail due
to their size, interconnectedness, complexity, lack of substitutability or global scope
(potentially huge moral hazard)
Liquidity vs Solvency
• “During the early ‘liquidity phase’ of the financial crisis, many banks – despite adequate
capital levels – still experienced difficulties because they did not manage their liquidity
in a prudent manner” (Basel Committee, 2010)
• Already in Fall 2007, one year before the fall of Lehman Brothers, the interbank market
had dried up
• Financial institution regulation used to be focused on the safety net, including
o Lender of last resort to support liquidity when markets cannot distinguish
between solvent and insolvent financial institutions
o Deposit insurance to prevent bank runs
o Capital adequacy with primary focus on solvency of individual banks
Basel III
• Increase microprudential capital requirements, notably common equity Tier 1 of 7%
• Introduce macroprudential capital requirements, both for a cross-sectional and
temporal dimension of systemic risk
• Cross-sectional: 29 global SIBs face additional capital charge of 1%-2.5%
• Temporal: countercyclical capital requirements of 0%-2.5% in order to contain
procyclicality of financial system
o Weakest link or worst-off individual bank is the only concern because all banks
are considered systemically important (risk aversion)
o Indifference curves are inversely L-shaped
• Social Risk Functions: Utilitarian
o Only considers average loss returns of banks in the system without regard to
how losses are distributed
o Indifference curves are linear
• Social Risk Functions: Minimin
o The best of the worst cases is the only concern because the survival of a single
bank is deemed sufficient for the survival of the entire system
o Indifference curves are L-shaped
• Social Risk Functions: mixture of Utilitarian and Minimax
•
Data Description
• 25 major banks – eurozone
o Source: Hartman, Straetmans, de Vries (2005)
o Selection criteria
(1) sizes measured by assets and deposits
(2) involvement in interbank lending
• Daily stock prices
o April 2, 1992 – February 27, 2004
o 3106 observations
Empirical Analysis
• Daily loss level
o Set xVaR = 0.03, 0.06, 0.09, 0.12
§ Pr{Xt > 0.03} = probability of a loss return of 3% or more in a single day
• Given loss levels reflecting approximately 5, 1, 0.2, 0.05 percentiles
o For example, 3% loss may occur once per 20 days
o 12% loss (systemically important event) ⇒ once per 8 years
•
Concluding Observations
• Supervisory social risk functions, used as input for selection and aggregation of bank loss
returns, result in very different estimated probabilities of systemically important events
(pf )
• Supervisors should specify their preferred SRF
• In case supervisors think that estimated probabilities pf are too high, they should take
remedial actions such as increasing bank capital requirements
• The question whether a supervisor thinks that estimated pf are too high crucially
depends on a more detailed and quantitative specification of its preferred SRF and
would need future research
• The contribution of our paper is to highlight the importance of the fact that different
SRFs can lead to very different estimates of the likelihood of systemically important
events
• Basel III still has predominantly a microprudential focus, trying to prevent individual
bank failures (consistent with the Minimax SRF)
• This would justify a substantial increase of bank capital requirements but, most likely,
beyond the increase currently proposed under Basel III
• It is interesting to note that Switzerland has decided to require its SIBs to hold a capital
ratio of 19% which is significantly above the ratio set by Basel III
Lecture 11: Banking Crisis
Banking Crisis
• Caprio and Honohan note that the banking crisis that broke out in August 2007 is only
the latest episode in a long series around the world
• Banks have played a central or important supporting role although some financial crises
have had their focus elsewhere (government debt, exchange rate and stock market
crises)
Over-optimism
• Dynamic instability in widely held expectations about macroeconomic and business
prospects has played a major role in many systemic banking crises
• Over-optimism about economic growth, often manifested in a real estate price boom,
results in a rapid credit expansion
• Disaster myopia prevails (underestimating the probability of disaster)
• Chuck Prince: as long as the music is playing, you’ve got to get up and dance. You may
expect crisis but just keep stay in the game (take risk)
Japan (1990s)
• Bursting of real asset price bubble in early 1990s
• Banks’ non-performing loans and capital positions were addressed only after a long time
period
• Lack of sense of urgency and strong public resentment about the use of taxpayers’
money
• Compare with the current European situation
Lecture 12: The Eurozone Crisis and the Roadmap towards European Banking Union
Moral Hazard in The Euro Zone (19 countries that shares the same currencies)
• Moral hazard in the euro zone due to perception of guarantees and bail outs. Due to the
existence of implicit and explicit guarantees.
• Bond holders perceive the riskiness of a German bond as about equal to a Greek bond
There's a perception that if one bank in a certain country fails, the euro zone will
definitely help, because if not, they can just leave the euro zone and create new
currencies. If someone leaves the euro zone, they will leave perception to other
countries, like why did they leave the euro zone?
• Ministers of Finance had an incentive to create an image of risk equality and diminish
Germany’s anchor role
• Convergence of interest rates already before the euro was launched in 1999
Euro Zone: First Phase
*The Maastricht Treaty, known formally as the Treaty on European Union, is
the international agreement responsible for the creation of the European Union (EU)
signed in 1991 and which became effective in 1993.Creation of new currency EURO
• Maastricht Treaty and Black Monday (Dutch EU Presidency second half of 1991)
• Violation of the Growth and Stability Pact. German and France violated the rules
• High budget deficits and debt levels (the famous rule – budget deficit shouldn’t be
higher than 3% and government debt ratio shouldn’t be higher than 60%)
• Lack of enforcement of structural reforms on labour and product markets. Ur country
have to be flexible the labor market, and typically. Import are higher than export back
then (trade deficit)
• Weak starting position when financial crisis emerged as from 2007. There’s a credit
boom, been assuming a lot of debt.
• Started with Greece early 2010 government debt ratio was much higher than ….,
Portugal weak states, Ireland the government bail-out a lot of their banks. This countries
get rescue fund from the ESM
European Central Bank (ECB), ultimate creator of liquidity, they can print money
• July 26, 2012: Draghi states “whatever it takes to preserve the euro”. Market completely
feel reassured and market explode (stock, bonds, etc)
• September 6, 2012: Draghi’s “audacious gamble” with “outright monetary transactions”
• Unlimited buying scheme of existing bonds of problem countries IF they meet ESM
conditionality. To create liquidity
• Strict and effective conditionality in terms of budget cuts and economic reforms. If a
country is having a trouble, interest rates go up, it cannot refinances itself against the
very high interest rate, will lead to bankruptcy. It need to comply with a package of
condition
• OMT (Outright Monetary Transaction) has not been used but seems successful given the
low interest rates on government bonds in Italy, Spain and Portuga. Buying government
bonds in troubled country
• Bank Recovery and Resolution Directive (BRRD), including a bail-in debt mechanism (as
from 2016) and a requirement to draw up living wills
• BRRD establishes harmonized procedures for restructuring problem banks
• SRM supplements BRRD and establishes the Single Resolution Board, ensuring a
coherent and uniform approach to the operation of the resolution rules across Europe
as from 2015. If remedial action from ECB does not solve the problem, the case will be
transferred to the Single Resolution Board
• Build-up of a Single Resolution Fund