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	<title>Kasinomics &#187; basel II</title>
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		<title>Pro-Cyclicality &#8211; Discussion of the problem and possible solutions</title>
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		<pubDate>Tue, 06 May 2008 11:34:03 +0000</pubDate>
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				<category><![CDATA[Discussions]]></category>
		<category><![CDATA[basel II]]></category>
		<category><![CDATA[bis]]></category>
		<category><![CDATA[central banks]]></category>
		<category><![CDATA[Claudio Borio]]></category>
		<category><![CDATA[Craig Furfine]]></category>
		<category><![CDATA[credit rating agencies]]></category>
		<category><![CDATA[definition]]></category>
		<category><![CDATA[Dimitrios P Tsomocos]]></category>
		<category><![CDATA[Eva Catarineu-Rabell]]></category>
		<category><![CDATA[financial regulation]]></category>
		<category><![CDATA[financial stability]]></category>
		<category><![CDATA[fsa]]></category>
		<category><![CDATA[George G. Pennacchi]]></category>
		<category><![CDATA[ias]]></category>
		<category><![CDATA[iasb]]></category>
		<category><![CDATA[Jose Vinals]]></category>
		<category><![CDATA[monetary policy]]></category>
		<category><![CDATA[Nancy Masschelein]]></category>
		<category><![CDATA[Patricia Jackson]]></category>
		<category><![CDATA[Philip Lowe]]></category>
		<category><![CDATA[Philip Turner]]></category>
		<category><![CDATA[pro-cyclicality]]></category>
		<category><![CDATA[regulators]]></category>
		<category><![CDATA[subprime crisis]]></category>
		<category><![CDATA[William R White]]></category>

		<guid isPermaLink="false">http://www.kasinomics.com/?p=114</guid>
		<description><![CDATA[How to define pro-cyclicality Procyclicality is used in the context of discussing the effects of Basel II on the financial system. A simplified definition of pro-cyclicality is: International rules have encouraged banks to act more aggressively when the economic cycle &#8230; <a href="http://www.kasinomics.com/articles/pro-cyclicality-discussion-and-solutions/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<h4>How to define pro-cyclicality</h4>
<p>Procyclicality is used in the context of discussing the effects of Basel II on the financial system. A simplified definition of pro-cyclicality is:</p>
<blockquote><p>International rules have encouraged banks to act more aggressively when the economic cycle is in the middle of an upswing, when some argue that is precisely when they should be putting money away for a rainy day. The global economy has become more volatile as a result. <small>Source: <a href="http://www.thisismoney.co.uk/30-second-guides/article.html?in_article_id=440495">Thisismoney.co.uk</a></small></p></blockquote>
<p>Claudio Borio, Craig Furfine and Philip Lowe express the same statement in more sophisticated words:</p>
<blockquote><p>Financial developments have reinforced the momentum of underlying economic cycles, and in some cases have led to extreme swings in economic activity and a complete breakdown in the normal linkages between savers and investors.</p>
<p>These experiences have led to concerns that the financial system is excessively procyclical, unnecessarily amplifying swings in the real economy.</p>
<p>In turn, these concerns have prompted calls for changes in prudential regulation, accounting standards, risk measurement practices and the conduct of monetary policy in an attempt to enhance both financial system and macroeconomic stability.<small> Source: Claudio Borio, Craig Furfine and Philip Lowe in &#8220;<a href="http://www.bis.org/publ/bppdf/bispap01a.pdf">Pro-cyclicality of the financial system and financial stability: issues and policy options</a>&#8220;</small></p></blockquote>
<p>José Viñals, Director General International Affairs at the Banco de Espagna, reminds us that a certain procyclicality of the financial system is wanted, but excessive procyclicality can be a burden:</p>
<blockquote><p>In the financial sphere, a certain degree of procyclicality is a natural, sensible and desirable outcome as it reflects the extent to which the financial sector is influenced by developments in the real economy and viceversa. The issue is nevertheless to what extent there is an excessive degree of procyclicality. <strong>The financial system is excessively procyclical when it unnecessarily amplifies swings in the real economy and/or reduces the stability and soundness of the financial sector.</strong> <small>Source: José Viñals in &#8220;<a href="http://www.bde.es/prensa/intervenpub/archivo/vinals/relaci221104.pdf">Procyclicality of the financial system and regulation</a>&#8220;</small></p></blockquote>
<h4>Indicators of pro-cyclicality</h4>
<p>According to Claudio Borio, Craig Furfine and Philip Lowe periods of growth are often associated with:</p>
<ul>
<li>significant increases in the ratio of credit to GDP</li>
<li>large increases in equity and property prices</li>
<li>decreasing bond spreads between corporate and government securities</li>
<li>credit rating agencies failing to predict changes in the probability of crises</li>
<li>unaltered bank provisions</li>
<li>increasing bank profitability and increasing bank equity prices</li>
</ul>
<p><small>Source: Claudio Borio, Craig Furfine and Philip Lowe in &#8220;<a href="http://www.bis.org/publ/bppdf/bispap01a.pdf">Pro-cyclicality of the financial system and financial stability: issues and policy options</a>&#8220;</small></p>
<h4>Causes of Pro-Cyclicality in the financial system</h4>
<p>Nancy Masschelein, from the National Bank of Belgium, has listed various sources of pro-cyclicality. <small>Source: Nancy Masschelein in &#8220;<a href="http://www.nbb.be/doc/ts/publications/wp/wp120En.pdf">Monitoring pro-cyclicality under the capital requirements directive : preliminary concepts for developing a framework</a>&#8220;</small></p>
<ol>
<li><strong>Fluctuations in the quality of banks’ and borrowers’ balance sheets.</strong>An increase in bank profits during periods of growth supports the extension of credit, while decreasing bank profits due to defaulted loans reduce this extension of credit. At the same time, a recession causes declining profits, increases demand for new credit and increases the interest rates.Claudio Borio, Craig Furfine and Philip Lowe have labelled this the <em>Incentive Explanation</em>. <small>Source: Claudio Borio, Craig Furfine and Philip Lowe in &#8220;<a href="http://www.bis.org/publ/bppdf/bispap01a.pdf">Pro-cyclicality of the financial system and financial stability: issues and policy options</a>&#8220;</small></li>
<li><strong>Information asymmetries between borrowers and lenders.</strong>During periods of growth, the value of collateral rises and borrowers with riskier projects can find lending. Under recessions, due to the decreased value of collateral, even borrowers with very profitable projects will find it difficult to obtain funding. These cyclical effects are especially relevent for borrowers which are more prone to asymmetric information effects (such as SMEs).Claudio Borio, Craig Furfine and Philip Lowe call this explanation the <em>Financial-accelerator-explanation</em>. <small>Source: Claudio Borio, Craig Furfine and Philip Lowe in &#8220;<a href="http://www.bis.org/publ/bppdf/bispap01a.pdf">Pro-cyclicality of the financial system and financial stability: issues and policy options</a>&#8220;.</small></li>
<li><strong>Inappropriate responses by participants in the financial system and lack of institutional memory.</strong>Euphoric expectations which arise from an investment boom driven by the business cycle or a disaster myopia which shows in a reduced subjective probability of a major shock if the last shock has already a few years past, is another source of excessive lending by banks during periods of growth.Allen N. Berger and Gregory F. Udell raise the problem of a lack of institutional memory. <small>Source: Allen N. Berger and Gregory F. Udell in&#8221;<a href="http://www.federalreserve.gov/pubs/feds/2003/200302/200302pap.pdf">The Institutional Memory Hypothesis and the Procyclicality of Bank Lending Behavior</a>&#8220;</small><br />
<blockquote><p>Under the institutional memory hypothesis, as time passes since the last “learning experience” with problem loans – the last time that the bank suffered a loan “bust” – loan officer skills decline.</p>
<p>Part of this decline in lender ability is attributable to a proportional increase in inexperienced lenders who have never had such a “learning experience.”</p>
<p>Part of the decline in lender ability is also due to the atrophying skills of experienced loan officers as time passes since they last addressed significant loan problems.</p></blockquote>
</li>
<li><strong>New financial innovative instruments.</strong>The use of new financial instruments facilitated the spreading and the diversification of credit risks and increased the possibilities of hedging. In favourable circumstances, banks can easily transfer credit risk using innovative credit risk transfer (CRT) products, which could induce banks to increase lending as credit risk can be transferred.</li>
</ol>
<h4>Regulation and pro-cyclicality</h4>
<p>The most important dimension of pro-cyclicality that is being adressed in the remaind of this article is regulation. Minimum capital requirements imposed by regulators to reduce systemic risk from collapse of systemically important financial intermediaries may force banks to reduce lending in an recession, increasing the above pro-cyclical mechanisms of the financial system.</p>
<p><a href="http://www.business.uiuc.edu/gpennacc/">George G. Pennacchi</a> warned that Basel II increases the sensitivity of a bank&#8217;s capital requirement to the risk of its assets and creates incentives which make bank lending more procyclical.</p>
<blockquote><p>During recessions, loan losses reduce bank capital and, even if capital requirements are insensitive to risk, a capital-deficient bank must increase its capital ratio. In addition, recessions tend to raise the default risk of loans, and Basel II&#8217;s more refined risk-based standards would further pressure banks to strengthen their capital ratios. This response of capital ratios to default risks can reduce banks&#8217; incentives to lend during a recession and worsen economic activity. Thus, capital requirements as envisioned under Basel II increase macroeconomic instability.<small>Source: George G. Pennacchi, Journal of Financial Intermediation &#8220;<a href="http://www.sciencedirect.com/science?_ob=ArticleURL&amp;_udi=B6WJD-4F83PGF-3&amp;_user=1495569&amp;_rdoc=1&amp;_fmt=&amp;_orig=search&amp;_sort=d&amp;view=c&amp;_acct=C000053194&amp;_version=1&amp;_urlVersion=0&amp;_userid=1495569&amp;md5=873ec53914caccf07d84157f80477a1b">Risk-based capital standards, deposit insurance, and procyclicality</a>&#8220;</small></p></blockquote>
<p>Besides miminum capital requirements, there are other ways that regulation can increase pro-cyclicality. Philipp Turner has listed them and discussed their relevance. <small>Source: Philipp Turner in &#8220;<a href="http://www.newschool.edu/cepa/publications/workingpapers/archive/cepa0313.pdf">Procyclicality of Regulatory Ratios?</a>&#8220;</small></p>
<ol>
<li><strong>Timing of tightening of capital rules</strong>During and immediately after a financial crisis, policy-makers have large incentives to tighten bank regulation which further curtails bank lending. Turner says that this problem is not that revelant in practice, most countries allow a phase-in period for the tightening of prudential ratios or in dealing with generalised problems.</li>
<li><strong>Regulatory bias in favour of short-term lending</strong>Under Basel I, international interbank lending of up to one year maturity had a 20% risk-weight irrespective of country, but lending of more than one year to non-OECD countries carried a 100% risk weight which would make bank lending to emerging markets “too” short term. According to Turner, Data does not suggest that this effect is important, nevertheless Basel II adresses these ambivalent distinctions.</li>
<li><strong>Cyclicality of minimum capital ratios</strong>This will be discussed later in this article in relation to bank provision and IAS 39, but the general idea is that because of certain minimum capital rations banks will reduce lending to meet the required minimum capital rations, if they have not made sufficient provisions for losses.</li>
<li><strong>Cyclicality of capital ratios due to the use of external credit rating</strong>This will also be discussed later in relation to the impact of Basel II on risk management in banks, but the general idea is that an increased reliance on external credit rating in determining risk weights can lead to the necessity for increased capital ratios in times of recession.</li>
</ol>
<h4>Basel II, Credit Rating Agencies and Pro-Cyclicality</h4>
<p>According to José Viñals the philosophy of modern monetary politics and approaches to financial stability incorporated in Basel II is quite similar:</p>
<ul>
<li>both are forward-looking in nature and have a medium-term horizon</li>
<li>both have an anticipatory character that seeks prevention rather than cure</li>
<li>both attempt to incorporate market views through the role played by expectations and market discipline.</li>
</ul>
<p>He argues that Basel II reduces pro-cyclicality by improving banking supervision.</p>
<blockquote><p>By contributing to a better assessment and management of risks, Basel II should reduce the scope for surprises and thus for procyclicality.<small>Source: José Viñals in &#8220;<a href="http://www.bde.es/prensa/intervenpub/archivo/vinals/relaci221104.pdf">Procyclicality of the financial system and regulation</a>&#8220;</small></p></blockquote>
<p><img class="alignright size-medium wp-image-120" style="float: right;" title="baseliiprocyclicality" src="http://www.kasinomics.com/wp-content/uploads/2008/05/baseliiprocyclicality.gif" alt="" />The influence of Basel II on the real economy would work along the following mechanism</p>
<blockquote><p>Basel II would increase the risk-sensitiveness of minimum capital requirements which, in turn, would lead to higher cyclicality of the overall regulatory capital and to more procyclical capital. Consequently, this would be reflected onto more procyclical lending and onto a higher degree of procyclicality in the real economy.<small>Source: José Viñals in &#8220;<a href="http://www.bde.es/prensa/intervenpub/archivo/vinals/relaci221104.pdf">Procyclicality of the financial system and regulation</a>&#8220;</small></p></blockquote>
<p>The influence on Basel II on the real economy through capital requirements is the reliance on external credit assessment for calculating risk weights. Philip Turner states that under Basel I, risk weight for sovereign and corporate debt were based on OECD membership wich was not sufficiently responsive to risk. Basel II relies more on “credit assessment agencies”, so not only credit-rating agencies, but also export insurance agencies, credit registers, market data.</p>
<p>However, credit rating agencies are often more backward-looking rather than forward-looking, their assessments are strongly negatively correlated with the real effective exchange rates, even though depreciation in the wake of a crisis should not lead to a downgrade but to a recognition of medium-term strenght due to a more competitive exchange rate.<small>Source: Philipp Turner in &#8220;<a href="http://www.newschool.edu/cepa/publications/workingpapers/archive/cepa0313.pdf">Procyclicality of Regulatory Ratios?</a>&#8220;</small></p>
<p>Eva Catarineu-Rabell, Patricia Jackson and Dimitrios P Tsomocos more specifically identify the choice of rating system as an important element in pro-cyclicality:</p>
<blockquote><p>The proposed new Basel Accord, in contrast to the Current Accord, makes provision for time varying risk weights for individual loans. Although the Basel Committee will set fixed weights for loans with a given probability of borrower default, banks will choose the probability of default band into which a loan will be slotted.</p>
<p>It then becomes very important how the banks carry out this ‘slotting’. When banks assess a borrower’s probability of default the assessment can be based on current economic conditions (where the rating will be conditioned on the point in the cycle) or can take into account the effect on the borrower of a possible adverse change in the climate. [...] The new element under Basel II is the additional procyclicality which will come from the latter element. [...]</p>
<p>Strongly procyclical capital requirements could cause severe macro economic effects by creating credit crunches in recessions, thereby exacerbating the economic downturn. They could also encourage excessive lending in booms. An important policy issue is therefore whether banks would choose to adopt more stable ratings across the cycle, which would moderate the procyclical effects, or whether they would adopt ratings conditioned on the point in the cycle even though this could lead to an inability to meet demands for credit in a downturn.<small>Source: Eva Catarineu-Rabell, Patricia Jackson and Dimitrios P Tsomocos in &#8220;<a href="http://www.finance.ox.ac.uk/file_links/finecon_papers/2003fe06.pdf">Procyclicality and the new Basel Accord–banks’ choice of loan rating system</a>&#8220;</small></p></blockquote>
<h4>Procyclicality, bank provisions and IAS 39</h4>
<p>In addition to the minimum capital requirements, the role of bank provision is important. Turner argues that the ideal response to procyclicality is for banks to make adequate provisions for possible loan losses. Often however, he says, tax laws limits the tax deductibility of precautionary provisioning because loan loss provisions increase internal funding for the bank only to the extent that they reduce taxes. Furthermore, securities authorities like the SEC have argued that precautionary provisioning distorts financial reports and may mislead investors. The building up of provisions may conflict with the demand for well-document accounting.<small> Philipp Turner in &#8220;<a href="http://www.newschool.edu/cepa/publications/workingpapers/archive/cepa0313.pdf">Procyclicality of Regulatory Ratios?</a>&#8220;</small></p>
<p>More specificially, the introduction of International Accounting Standard 39 requiring fair-value accounting make bank provisions more pro-cyclical, as José Viñals <a href="http://www.bde.es/prensa/intervenpub/archivo/vinals/relaci221104.pdf">discusses</a>:</p>
<blockquote><p>IAS39 adds to procyclicality in the financial system through the introduction of fair-value accounting. [...] There is also a serious risk that, if the new rules are interpreted too rigidly, they could discourage, complicate and even prevent the implementation of some solutions to the procyclicality problem such as forward-looking provisioning.</p>
<p>Consequently, IAS39 might not only exacerbate procyclicality but also make it more difficult for regulatory policy to deal with procyclicality. In particular, Basel II is mainly about capital (to cover unexpected losses) and thus does not deal in depth with provisions (e.g. to cover expected losses, as in the case of forward-looking provisions). In turn, IAS39 contemplates only &#8216;incurred losses&#8217; as far as provisions are concerned. Hence, under a rigid interpretation, IAS39 would not be compatible with a system of forward-looking provisions.</p></blockquote>
<h4>Solutions for Pro-Cyclicality</h4>
<p>The problem of pro-cyclicality reflects a deeper problem of financial regulation. On the one hand, financial regulation for banks under Basel II was made more sensitive to the business cycle by relying on external credit assessment (in pillar 1 of Basel II) and fair-value-accounting (in pillar 3 of Basel II). The motivation behind these changes was to move away from the often arbitrary risk-weights assigned in Basel I. However, with more risk sensitivity of financial regulation, banks amplify the business cycles and contribute to systemic risk. In other word, the methods to avoid systemic risk are contributing to increase systemic risk.</p>
<p>There are a handful of proposals to change various aspects of Basel II. George G. Pennacchi, for example, suggests moving to a <a href="http://www.sciencedirect.com/science?_ob=ArticleURL&amp;_udi=B6WJD-4F83PGF-3&amp;_user=1495569&amp;_rdoc=1&amp;_fmt=&amp;_orig=search&amp;_sort=d&amp;view=c&amp;_acct=C000053194&amp;_version=1&amp;_urlVersion=0&amp;_userid=1495569&amp;md5=873ec53914caccf07d84157f80477a1b">risk-based deposit insurance</a> system which encourages less procyclicality of bank loans then risk-based capital ratios. In a <a href="http://www.fsa.gov.uk/pubs/international/crsg_procyclicality_pillar.pdf">policy brief</a> from the FSA, the authors discuss between adjusting &#8220;Pillar 1&#8243; or &#8220;Pillar 2&#8243; approach to counter procyclicality. &#8220;Pillar 1&#8243;-approach would be the modification of rating methodologies for capital requirements, &#8220;Pillar 2&#8243;-approach would mean relying increasingly on procyclicality stress tests to increase, if necessary, regulatory capital. The authors argue that the &#8220;Pillar 2&#8243;-approach is politically more feasible while the &#8220;Pillar 1&#8243;-approach would make more sense.</p>
<p>Several authors call for a more comprehensive approach to tackle the problem. In a <a href="http://www.bis.org/speeches/sp080326.htm">speech</a> given by <a href="http://www.bis.org/about/biowrw.htm">William R White</a>, Economic Adviser and Head of Monetary and Economic Department of the Bank for International Settlements, advocates a &#8220;new macrofinancial stability framework&#8221; which encourages regulators and central banks to resist the pro-cyclicality of the financial system.</p>
<p>Such a system would pay attention to the impact of systemic shocks, a close cooperation between central bankers and regulators in assessing the build-up of systemic risks, and a countercyclical use of policy instruments. Monetary policy and regulation would push in the same direction: credit tightening in times of growth and credit expansion in recession would go together with a biased regulatory policy of risk spreads (for expected losses), provisioning (for subsequent changes in expected losses), and capital (for unexpected losses) being increased in good times and decreased in bad times. He proposes to alter the capital required for credit risk with a formula based on estimates of system-wide increases in exposure. The formula could make use of the rate of growth of aggregate credit and asset prices from longer-term trends.</p>
<p>White advocates a international agreement for such a framework and improving risk management procedures under Basel II. The biggest impediment against moving towards such an international agreement, assuming consensus on the causes of the crisis and availability of the appropriate tools, is the act to will. Policy makers face the bureaucratic inertia and vigorous lobbying (against reacting) from the many people being made rich by the crisis. Central bankers face the problem that counter-cyclical regulation and tightened credit could strangulate an economy more than necessary. Regulators face the problem of not having long cultural tradition of concern for macroprudential issues and not seeing the big-picture of macro-financial stability. White suggests to include an automatic response to the procyclical tendencies of the financial system. (See also Whites paper &#8220;<a href="http://www.bis.org/publ/work193.pdf">Procyclicality in the financial system: do we need a new macrofinancial stabilisation framework?</a>&#8221; and the similar <a href="http://www.bis.org/publ/bppdf/bispap01a.pdf">suggestions</a> by Claudio Borio, Craig Furfine and Philip Lowe).</p>
<h4>Conclusion</h4>
<p>Business cycles are a necessary characteristic of an open economy. The fact that the financial systems moves along with the business cycle is a necessesary consequence of the fact that the actions of the financial system reflect the underlying changes in the real economy.</p>
<p>Regulators, central banks and policy-makers have a natural tendency to dampen the business cycle: through the use of fiscal, monetary and regulatory policy. To some extent it is however not possible to get rid of both things at the same time: financial instability and pro-cyclicality.</p>
<p>Financial stability rests on using the information about the state of risk provided by the market, but at the same time pro-cyclicality is increased by relying to heavily on the market for providing information about risk. Pro-cyclicality and financial stability are two sides of the same coin.</p>

	Topics of this post: <a href="http://www.kasinomics.com/topics/basel-ii/" title="basel II" rel="tag">basel II</a>, <a href="http://www.kasinomics.com/topics/bis/" title="bis" rel="tag">bis</a>, <a href="http://www.kasinomics.com/topics/central-banks/" title="central banks" rel="tag">central banks</a>, <a href="http://www.kasinomics.com/topics/claudio-borio/" title="Claudio Borio" rel="tag">Claudio Borio</a>, <a href="http://www.kasinomics.com/topics/craig-furfine/" title="Craig Furfine" rel="tag">Craig Furfine</a>, <a href="http://www.kasinomics.com/topics/credit-rating-agencies/" title="credit rating agencies" rel="tag">credit rating agencies</a>, <a href="http://www.kasinomics.com/topics/definition/" title="definition" rel="tag">definition</a>, <a href="http://www.kasinomics.com/topics/dimitrios-p-tsomocos/" title="Dimitrios P Tsomocos" rel="tag">Dimitrios P Tsomocos</a>, <a href="http://www.kasinomics.com/themes/discussions/" title="Discussions" rel="tag">Discussions</a>, <a href="http://www.kasinomics.com/topics/eva-catarineu-rabell/" title="Eva Catarineu-Rabell" rel="tag">Eva Catarineu-Rabell</a>, <a href="http://www.kasinomics.com/topics/financial-regulation/" title="financial regulation" rel="tag">financial regulation</a>, <a href="http://www.kasinomics.com/topics/financial-stability/" title="financial stability" rel="tag">financial stability</a>, <a href="http://www.kasinomics.com/topics/fsa/" title="fsa" rel="tag">fsa</a>, <a href="http://www.kasinomics.com/topics/george-g-pennacchi/" title="George G. Pennacchi" rel="tag">George G. Pennacchi</a>, <a href="http://www.kasinomics.com/topics/ias/" title="ias" rel="tag">ias</a>, <a href="http://www.kasinomics.com/topics/iasb/" title="iasb" rel="tag">iasb</a>, <a href="http://www.kasinomics.com/topics/jose-vinals/" title="Jose Vinals" rel="tag">Jose Vinals</a>, <a href="http://www.kasinomics.com/topics/monetary-policy/" title="monetary policy" rel="tag">monetary policy</a>, <a href="http://www.kasinomics.com/topics/nancy-masschelein/" title="Nancy Masschelein" rel="tag">Nancy Masschelein</a>, <a href="http://www.kasinomics.com/topics/patricia-jackson/" title="Patricia Jackson" rel="tag">Patricia Jackson</a>, <a href="http://www.kasinomics.com/topics/philip-lowe/" title="Philip Lowe" rel="tag">Philip Lowe</a>, <a href="http://www.kasinomics.com/topics/philip-turner/" title="Philip Turner" rel="tag">Philip Turner</a>, <a href="http://www.kasinomics.com/topics/pro-cyclicality/" title="pro-cyclicality" rel="tag">pro-cyclicality</a>, <a href="http://www.kasinomics.com/topics/regulators/" title="regulators" rel="tag">regulators</a>, <a href="http://www.kasinomics.com/topics/subprime-crisis/" title="subprime crisis" rel="tag">subprime crisis</a>, <a href="http://www.kasinomics.com/topics/william-r-white/" title="William R White" rel="tag">William R White</a><br />
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		<title>Project: Mapping the Financial Governance</title>
		<link>http://www.kasinomics.com/articles/mapping-financial-governance-project/</link>
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		<pubDate>Sun, 20 Apr 2008 18:26:38 +0000</pubDate>
		<dc:creator>kasi</dc:creator>
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		<category><![CDATA[g7]]></category>
		<category><![CDATA[imf]]></category>
		<category><![CDATA[iosco]]></category>
		<category><![CDATA[oecd]]></category>
		<category><![CDATA[regulation]]></category>
		<category><![CDATA[world bank]]></category>

		<guid isPermaLink="false">http://www.kasinomics.com/?p=95</guid>
		<description><![CDATA[When academics, analysts and scholars analyze the causes and remedies for the current credit crisis, most of them analyze macro-economic trends such as exchange rate movements, or micro-economic changes such as Basel II. How the global financial architecture evolved and &#8230; <a href="http://www.kasinomics.com/articles/mapping-financial-governance-project/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p>When academics, analysts and scholars analyze the causes and remedies for the current credit crisis, most of them analyze macro-economic trends such as exchange rate movements, or micro-economic changes such as Basel II.</p>
<p>How the global financial architecture evolved and how that influences the probability of crisis is very rarely discussed. In the analysis, the network structures of the global financial architecture is often forgotten.</p>
<p>The financial architecture is the system of public and private bodies which try to influence the regulation and standards required for financial markets to function. These are the the main types of actors in the financial architecture:</p>
<ul>
<li>Governments
<ol>
<li>National governments, in particular finace ministers</li>
<li>Informal meetings of government officials, such as the <a href="http://www.kasinomics.com/articles/g7">G7</a></li>
<li>Supra-national government organisations, such as the EC</li>
<li>International organisations representing the interests of governments, such as the <a href="http://www.kasinomics.com/articles/imf">IFM</a>, <a href="http://www.kasinomics.com/articles/world-bank">World Bank</a>, <a href="http://www.kasinomics.com/articles/oecd">OECD</a>.</li>
</ol>
</li>
<li>Central banks
<ol>
<li>National Central Banks</li>
<li>Informal Meeting of Central Bank Governors, such as the <a href="http://www.kasinomics.com/articles/g10">G10</a></li>
<li>Supra-National Central Banks, like the <a href="http://www.kasinomics.com/articles/ecb">ECB</a></li>
<li>International Organisations of Central Banks, such as the <a href="http://www.kasinomics.com/articles/bis/">BIS</a></li>
</ol>
</li>
<li>Regulators
<ol>
<li>National Regulators responsible for
<ul>
<li>Banks and other financial intermediaries</li>
<li>Securities Firms and other type of trade of financial derivatives</li>
<li>Insurers</li>
</ul>
</li>
<li>Supra-National Meetings of Regulators
<ol>
<li> with specific regulatory tasks, such as <a href="http://www.kasinomics.com/articles/cebs">CEBS</a>, <a href="http://www.kasinomics.com/articles/cesr">CESR</a> or <a href="http://www.kasinomics.com/articles/ceiops">CEIOPS</a></li>
<li>with over-arching regulatory tasks</li>
</ol>
</li>
<li>International Meetings of Regulators
<ol>
<li> with specific regulatory tasks, such as <a href="http://www.kasinomics.com/articles/bcbs">BCBS</a> or <a href="http://www.kasinomics.com/articles/iosco">IOSCO</a></li>
<li>with over-arching regulatory tasks</li>
</ol>
</li>
</ol>
</li>
<li>Private Bodies
<ol>
<li>National Lobbying Group of Financial Institutions</li>
<li>Surpa-National Lobbying Group of Financial Institutions</li>
<li>International Lobbying Group of Financial Institutions</li>
</ol>
</li>
<li>Academic Consultancies and Think Tanks</li>
<li>NGOs</li>
</ul>
<p>The heuristics still has some weakness, but it helps to get a first picture of the financial architecture.</p>
<p>It is difficult to get a meaningful categorization of the private bodies because scope and membership of these private bodies are overlapping. Some of these organizations have identical aims but conflicting interests because they represent financial actors from different regional constituencies without however saying this in their statutes.</p>
<p>The categorization concerning NGOs and Academic Institutions lacks details because they are not the main actors in standard-setting, which is the second part of the financial architecture. So in addition to the actors, a list of standards would be needed which then can be attributed to particular organisations.</p>
<p>There are quite a few hybrid bodies and it is difficult to put them into the system above, such as the FSF. Also the disction between public and private organisations are not as sharps, because many public bodies have advisory councils consisting of representatives from banks or other large financial institutions.</p>
<p>The distinction between regulation, standards and lobbying is also quite blurred. In financial markets, self-regulation and technical standards agreed upon without government intervention play an important role. Regulation sometimes reflects either the attempts of the industry to self-regulate (for instance in Codes of Conduct) or serves the interests of certain part of the industry to keep their competitors out of certain market segments.</p>
<p>The Mapping-Project undertaken here aims to get a better understanding on how standards are produced, how the financial actors communicate and co-operate and how the financial architecture is being build.</p>
<p>Key Questions to be asked will be:</p>
<ul>
<li>Decision-Making Process</li>
<li>Established by law or statute</li>
</ul>

	Topics of this post: <a href="http://www.kasinomics.com/topics/basel-ii/" title="basel II" rel="tag">basel II</a>, <a href="http://www.kasinomics.com/topics/bcbs/" title="bcbs" rel="tag">bcbs</a>, <a href="http://www.kasinomics.com/topics/bis/" title="bis" rel="tag">bis</a>, <a href="http://www.kasinomics.com/topics/cebs/" title="cebs" rel="tag">cebs</a>, <a href="http://www.kasinomics.com/topics/ceiops/" title="ceiops" rel="tag">ceiops</a>, <a href="http://www.kasinomics.com/topics/central-banks/" title="central banks" rel="tag">central banks</a>, <a href="http://www.kasinomics.com/topics/cesr/" title="cesr" rel="tag">cesr</a>, <a href="http://www.kasinomics.com/topics/code-of-conduct/" title="code of conduct" rel="tag">code of conduct</a>, <a href="http://www.kasinomics.com/topics/finance-ministers/" title="finance ministers" rel="tag">finance ministers</a>, <a href="http://www.kasinomics.com/topics/financial-architecture/" title="financial architecture" rel="tag">financial architecture</a>, <a href="http://www.kasinomics.com/topics/financial-institutions/" title="financial institutions" rel="tag">financial institutions</a>, <a href="http://www.kasinomics.com/topics/financial-markets/" title="financial markets" rel="tag">financial markets</a>, <a href="http://www.kasinomics.com/topics/financial-regulation/" title="financial regulation" rel="tag">financial regulation</a>, <a href="http://www.kasinomics.com/topics/g10/" title="g10" rel="tag">g10</a>, <a href="http://www.kasinomics.com/topics/g7/" title="g7" rel="tag">g7</a>, <a href="http://www.kasinomics.com/topics/imf/" title="imf" rel="tag">imf</a>, <a href="http://www.kasinomics.com/topics/iosco/" title="iosco" rel="tag">iosco</a>, <a href="http://www.kasinomics.com/themes/memo/" title="Memo" rel="tag">Memo</a>, <a href="http://www.kasinomics.com/topics/oecd/" title="oecd" rel="tag">oecd</a>, <a href="http://www.kasinomics.com/topics/regulation/" title="regulation" rel="tag">regulation</a>, <a href="http://www.kasinomics.com/topics/world-bank/" title="world bank" rel="tag">world bank</a><br />
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		<title>Overview of 2008 FSF Report on Financial Stability</title>
		<link>http://www.kasinomics.com/articles/2008-fsf-report-overview/</link>
		<comments>http://www.kasinomics.com/articles/2008-fsf-report-overview/#comments</comments>
		<pubDate>Sun, 13 Apr 2008 12:16:05 +0000</pubDate>
		<dc:creator>kasi</dc:creator>
				<category><![CDATA[Reports]]></category>
		<category><![CDATA[basel II]]></category>
		<category><![CDATA[bcbs]]></category>
		<category><![CDATA[credit rating agencies]]></category>
		<category><![CDATA[european union]]></category>
		<category><![CDATA[financial institutions]]></category>
		<category><![CDATA[financial stability]]></category>
		<category><![CDATA[financial stability forum]]></category>
		<category><![CDATA[fsf]]></category>
		<category><![CDATA[g7]]></category>
		<category><![CDATA[iaasb]]></category>
		<category><![CDATA[iais]]></category>
		<category><![CDATA[imf]]></category>
		<category><![CDATA[iosco]]></category>
		<category><![CDATA[monoline insurers]]></category>
		<category><![CDATA[otc-derivatives]]></category>
		<category><![CDATA[pillar 2]]></category>
		<category><![CDATA[pillar 3]]></category>
		<category><![CDATA[securities]]></category>
		<category><![CDATA[subprime crisis]]></category>

		<guid isPermaLink="false">http://www.kasinomics.com/?p=65</guid>
		<description><![CDATA[The G7 Finance Ministers met yesterday at the IMF Spring Meeting and approved a report prepared by the Financial Stability Forum, the main forum bringing together Central Banks, Regulators and Finance Ministers. Before discussing the report in detail, it is &#8230; <a href="http://www.kasinomics.com/articles/2008-fsf-report-overview/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p>The <a href="http://www.kasinomics.com/articles/g7">G7</a> Finance Ministers met yesterday at the <a href="http://www.kasinomics.com/articles/imf">IMF</a> <a href="http://www.imf.org/external/spring/2008/index.htm">Spring Meeting</a> and approved a <a href="http://www.fsforum.org/publications/FSF_Report_to_G7_11_April.pdf">report</a> prepared by the <a href="http://www.kasinomics.com/articles/fsf/">Financial Stability Forum</a>, the main forum bringing together Central Banks, Regulators and Finance Ministers. Before <a href="http://www.kasinomics.com/articles/2008-fsf-report-discussion">discussing</a> the report in detail, it is essential to get an overview of what the FSF is recommending.<span id="more-65"></span></p>
<p>The G7 finance ministers asked the FSF at their October 2007 meeting (<a href="http://www.g8.utoronto.ca/finance/fm071019.htm">statement</a>) to analyze the underlying causes of the turbulence, which the FSF did in the first chapter of the report.</p>
<p>The G7 also asked the FSF to offer proposals for liquidity and risk management; accounting and valuation of financial derivatives, role of credit rating agencies in structured finance; supervision of banks and the treatment of off-balance sheet vehicles.</p>
<p>At their <a href="http://www.g8.utoronto.ca/finance/fm080209.htm">February 2008 meeting</a>, they redefined the agenda of the FSF. They urged financial institutions (especially the banks) to disclose their losses. They called for a better liquidity risk management inside Basel-II and to address the problem of off-balance-sheet-vehicles. The G7 Finance Ministers said they were not hostile to a reform of the Basel II capital adequacy framework. They wanted to change the incentives of the originate-to-distribute-modell and address the conflict of interests in the credit rating agencies. They also called for a review of national and international supervisory mechanisms.</p>
<h4>Prudential Oversight</h4>
<h5>Basel II  and Minimum Capital Requirements</h5>
<p>The report of the FSF calls for a timely implementation of the Basel-II-framework, despite its deficiencies. In 2006 in a <a href="http://www.bis.org/fsi/fsipapers06.htm">response</a> to a questionnaire by the FSI, 95 countries indicated plans to implement Basel II in their jurisdiction (for members of the European Union, Basel II is mandatory). National supervisors are called for evaluating the impact of Basel II and adjust minimum capital levels accordingly.</p>
<p>The BCBS is called to reform Basel II by increasing capital requirements for complex structured credit products such as Colleratlized Debt Obligations of asset-backed securities (ABSs). Together with <a href="http://www.kasinomics.com/articles/iosco">IOSCO</a>, the BCBS will propose regulation for a better representation of these structured credit products in the trading books of banks and securities firms. The BCBS also wants to strengthen the capital treatment for banks’ liquidity facilities to off-balance sheet asset-backed commercial papers (ABCPs).</p>
<p>On the national level, supervisors are called for to continue to develop the risk assessment framework inside Basel II and the compliance of the banks. One main debate in the financial world is whether the risk-based mininum capital requirements in Basel II encourages procyclicality and supervisors are called to address that.</p>
<p>The role of monoline insurers and financial guarantors is going to be assessed by the IAIS and regulation to be introduced to reflect their relation to structured credit products.</p>
<h5>Liquidity risk and liquidity management</h5>
<p>Regulators are urged to be more strict in enforcing adequate liquidity risk management. Supervisors and central banks are called to examine an internationally consistent liquidity approach for cross-border banks. Pillar 2 (supervision) is strengthened to avoid that banks build up excessive exposures to liquidity risk.</p>
<p>The BCBS together with national supervisors is going to reassess the use of internal risk-models to ensure comparability between financial institutions.  One priority is the guidance relating firm-wide risks, including concentration risks. Again, this includes liquidity risk associated with off-balance-sheet-vehicles, securitisation business and exposure to leveraged counterparties (such as Hedge Funds).  Institutional investors are urged to be more cautious when investing in structured products.</p>
<p>Regulators are also called to review compensation models to avoid giving incentives for inappropriately risky conduct of financial business and more focus on long-term, firm-wide profitability.</p>
<h5>Over-the-Counter Derivatives</h5>
<p>The FSF calls for Market participants to improve the standards for credit derivative trade documentation in accordance with the not yet implemented cash settlement protocol. Standards for the accuracy and time lineless of trade data submissions for OTC derivatives should be improved. The financial industry as a whole is urged to develop reliable operational infrastructure supporting OTC derivatives.</p>
<h4>Transparency and Valuation</h4>
<h5>Accounting, Disclosure and Auditing</h5>
<p>Financial institutions should disclose their risks aand supervisors should enforce risk disclosure requirements under Pillar 3 of Basel II (with the help of the BCBS). Financial institutions are encouraged to disclose their losses in their upcoming mid-year 2008 reports.</p>
<p>The IASB is asked to propose an international disclosure standard for off-balance sheet vehicles and strengthen the standards to achieve better disclosures about valuations, methodologies and the uncertainty associated with valuations. The IASB is also called to improve its guidance on valuing financial instruments when markets have dried up (an advisory panel will be set up for that). The BCBS is called to enhance the supervisory assessment of banks’ valuation processes and help supervisors reinforce sound practices.</p>
<p>The auditing of complex or illiquid financial products needs to be improved. Therefore the <a href="http://www.kasinomics.com/articles/iaasb">International Auditing and Assurance Standards Board (IAASB)</a> and major national audit standard setters are required to rexamine the standards in that area.</p>
<h5>Transparency in securitisation processes and markets</h5>
<p>Securities market regulators and the securities need access to more information on securitised products and their underlying assets. Originators, arrangers, distributors, managers and Credit Rating Agency need to be more transparent at each stage of the securitisation chain by standardising information about assets underlying structured credit products. Securities market regulators will set up a comprehensive system for post-trade transparency of the prices and volumes traded in secondary markets for credit instruments.</p>
<h4>Changes in the role and uses of credit ratings</h4>
<h5>Rating process</h5>
<p>Credit Rating Agencies (CRAs) should improve the quality of the rating process and manage conflicts of interest in rating structured products. IOSCO will revise its Code of Conduct Fundamentals for Credit Rating Agencies and CRAs will revise the implementation of this code.</p>
<p>CRAs are called to differentiate ratings on structured finance from those on bonds, and expand the initial and ongoing information provided on the risk characteristics of structured products. They should expand the information on the risk characteristics of structured products.</p>
<p>CRAs should enhance their review of the quality of the data input and of the due diligence performed on underlying assets by originators, arrangers and issuers involved in structured products.</p>
<h5>Uses of ratings by investors and regulators</h5>
<p>The over-reliance on ratings by investors needs to be decreased. Ratings should not replace appropriate risk analysis and management on the part of investors.</p>
<p>Authorities will also review the use of ratings in the regulatory and supervisory framework. by checking the roles assigned to ratings in regulations and supervisory rules and their consistency with theobjectives of having investors make independent judgment of risks and perform their own due diligence.</p>
<h4>Strengthening the authorities’ responsiveness to risks</h4>
<h5>Translating risk analysis into action</h5>
<p>The FSF criticizes that Supervisors, regulators and central banks need to have adequate resources and expertise to oversee the risks associated with financial innovation and to ensure that firms they supervise have the capacity to understand and manage the risks. They should communicate to firms’ boards and senior management at an early stage their concerns about risk exposures and the quality of risk management and the need for firms to take responsive action.</p>
<p>The FSF will increase its own risk analysis and recommendations, both directly and through the actions of its members through a mechanism for regular interaction at senior level with private sector participants, including investors and CRAs, for prompting mitigating actions to identified risks and weaknesses.</p>
<p>The use of international colleges of supervisors will be expanded so that for each of the largest global financial institutions a college of supervisors exist.<br />
To increase the speed of supervisory responsiveness to developments that have a common effect across a number of institutions, supervisory exchange of information and coordination in the development of best practice benchmarks needs be improved at both national and international levels.</p>
<p>To facilitate central bank mitigation of market liquidity strains, large banks will be required to share their liquidity contingency plans with relevant central banks.</p>
<p>International regulatory, supervisory and central bank committees will strengthen their prioritisation of issues and, for difficult to resolve issues, establish mechanisms for escalating them to a senior decision-making level. As part of this effort, they will establish timetables for required action and action plans for addressing delayed or difficult issues.</p>
<p>National supervisors will, as part of their regular supervision, take additional steps to check the implementation of guidance issued by international committees.</p>
<p>The FSF will encourage joint strategic reviews by standard-setting committees to better ensure policy development is coordinated and focused on priorities.</p>
<p>The FSF and IMF will intensify their cooperation on financial stability, with each complementing the other’s role. As part of this, the IMF will report the findings from its monitoring of financial stability risks to FSF meetings, and in turn will seek to incorporate relevant FSF’s conclusions into its own bilateral and multilateral surveillance work.</p>
<h4>Robust arrangements for dealing with stress in the financial system</h4>
<h5>Central bank operations</h5>
<p>Central bank operational frameworks should be sufficiently flexible in terms of potential frequency and maturity of operations, available instruments, and the range of counterparties and collateral, to deal with extraordinary situations. To meet an increased but uncertain demand for reserves, monetary policy operational frameworks should be capable of quickly and flexibly injecting substantial quantities of reserves without running the risk of driving overnight rates substantially below policy targets for significant periods of time.</p>
<p>Policy frameworks should include the capability to conduct frequent operations against a wide range of collateral, over a wide range of maturities and with a wide range of counterparties, which should prove especially useful in dealing with extraordinary situations.</p>
<p>To deal with stressed situations, central banks should consider establishing mechanisms designed for meeting frictional funding needs that are less subject to stigma.</p>
<p>Central banks should have the capacity to use a variety of instruments when illiquidity of institutions or markets threatens financial stability or the efficacy of monetary policy.</p>
<p>To deal with problems of liquidity in foreign currency, central banks should consider establishing standing swap lines among themselves. In addition, central banks should consider allowing in their own liquidity operations the use of collateral across borders and currencies.</p>
<h5>Arrangements for dealing with weak banks</h5>
<p>Authorities will clarify and strengthen national and cross-border arrangements for dealing with weak banks. Domestica authorities will review the division of responsibilities of different national authorities for dealing with weak and failing banks.</p>
<p>National authorities should agree a set of international principles for deposit insurance systems. National deposit insurance arrangements should be reviewed against these agreed international principles, and authorities should strengthen arrangements where needed.</p>
<p>For the largest cross-border financial firms, the most directly involved supervisors and central banks should establish a small group to address specific cross-border crisis management planning issues. Authorities should share international experiences and lessons about crisis management. These experiences should be used as the basis to extract some good practices of crisis management that are of wide international relevance.</p>

	Topics of this post: <a href="http://www.kasinomics.com/topics/basel-ii/" title="basel II" rel="tag">basel II</a>, <a href="http://www.kasinomics.com/topics/bcbs/" title="bcbs" rel="tag">bcbs</a>, <a href="http://www.kasinomics.com/topics/credit-rating-agencies/" title="credit rating agencies" rel="tag">credit rating agencies</a>, <a href="http://www.kasinomics.com/topics/european-union/" title="european union" rel="tag">european union</a>, <a href="http://www.kasinomics.com/topics/financial-institutions/" title="financial institutions" rel="tag">financial institutions</a>, <a href="http://www.kasinomics.com/topics/financial-stability/" title="financial stability" rel="tag">financial stability</a>, <a href="http://www.kasinomics.com/topics/financial-stability-forum/" title="financial stability forum" rel="tag">financial stability forum</a>, <a href="http://www.kasinomics.com/topics/fsf/" title="fsf" rel="tag">fsf</a>, <a href="http://www.kasinomics.com/topics/g7/" title="g7" rel="tag">g7</a>, <a href="http://www.kasinomics.com/topics/iaasb/" title="iaasb" rel="tag">iaasb</a>, <a href="http://www.kasinomics.com/topics/iais/" title="iais" rel="tag">iais</a>, <a href="http://www.kasinomics.com/topics/imf/" title="imf" rel="tag">imf</a>, <a href="http://www.kasinomics.com/topics/iosco/" title="iosco" rel="tag">iosco</a>, <a href="http://www.kasinomics.com/topics/monoline-insurers/" title="monoline insurers" rel="tag">monoline insurers</a>, <a href="http://www.kasinomics.com/topics/otc-derivatives/" title="otc-derivatives" rel="tag">otc-derivatives</a>, <a href="http://www.kasinomics.com/topics/pillar-2/" title="pillar 2" rel="tag">pillar 2</a>, <a href="http://www.kasinomics.com/topics/pillar-3/" title="pillar 3" rel="tag">pillar 3</a>, <a href="http://www.kasinomics.com/themes/reports/" title="Reports" rel="tag">Reports</a>, <a href="http://www.kasinomics.com/topics/securities/" title="securities" rel="tag">securities</a>, <a href="http://www.kasinomics.com/topics/subprime-crisis/" title="subprime crisis" rel="tag">subprime crisis</a><br />
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