The chart (left) lists 21 international organizations. Some of them are grouped together to reduce the overlap. The organizations are clustered along four categories:

• informal government-institutions (blue): G5, G7, G8, G22, G33, G20, G24
• formal government-institutions (yellow): OECD, FATF, Paris-Club, World Bank, IMF
• central-bank-institutions (red): G10, CPSS, CGFS, BIS
• regulator institutions (green): FSF, BCBS, Joint Forum, IOSCO, IAIS

All institutions operate on the international level.

The power-ranking (below) lists the countries according to their membership in crucial institutions. The power-rank is calculated by assigning equal value to all organisations and then distributing the value across the members of an organisation. A country is more “powerful” if it is a member of a more exclusive group of nations.

The countries can be grouped into six categories:

• W1: The Group of Seven (G7): This premier league of Developed Western Economies can be subdivided into two groups:
  • The Group of Five (G5): France, Germany, Japan, United Kingdom, United States
  • The Two Add-Ons: Canada, Italy
• W2: Second league of Developed Western Economies: Netherlands, Switzerland, Belgium, Sweden, Australia, and Spain.
• W3: Third league of Developed Western Economies: Luxemburg, Denmark, Poland, Finland , Ireland, Norway, New Zealand, and Austria
• E1: The Emerging Ten: The premier league of emerging economies can subdivided into three groups:
  • BRICS+05: Russia, Mexico, Brazil, China, India, South-Africa
  • The Two Key Capital Markets: Singapore, Hong Kong
  • The Two Emerging Aspirants: Argentina, South Korea
• E2: Second league of Emerging Economies: Turkey and Indonesia
• E3: Third league of Emerging Economies: Malaysia, Thailand, Saudi-Arabia, Greece, Egypt, Chile, Philippines, Morocco, Venezuela and Côte d’Ivoire.

Main findings

• The dominance of the G5 and the G7 in the international institutions can be clearly found in the institutional membership.
• Russia is quite unlike the G7, is not a full member in the financial institutions, and without G8 membership its rank would be significantly lower.
• China and Hong Kong together rank higher than all members of the W2, the second league of Western developed countries. In other words, China and Hong Kong together have more influence in international institutions than for instance the Netherlands, Switzerland or Belgium.
• Mexico, Brazil, China, India, South Africa, South Korea and Argentina are all good candidates for G8 enlargement when considering institutional membership. South Korea and Argentina are however impeded by the relative dominance of Mexico, Brazil, and China in international institutions. South Africa and India are less influential than South Korea and Argentina in terms of institutional membership.
• The main difference between the first (W1) and second (W2) league of developed economies is membership in the FSF and in the G20.
• The main difference between the second (W2) and third (W3) league of developed economies is participation in BIS-hosted institutions.
• The main difference between W3 and E3 is that E3 was a member of the G33 whereas W3 participates in the OECD.
• There is considerable overlap of membership in the BIS-hosted institutions and in the OECD-FATF-Paris-Club-Cluster.
• The BIS-hosted cluster of institutions, unlike the BIS itself, does not grant extensive membership to the emerging economies, with the exception of Hong Kong and Singapore.

W1: G5 and G7

The dominance of the G5 countries (US, UK, G, F, J) can be seen in both the chart and the ranking. The G5 are members in all institutions (with the exception of the G24) and often play a dominant role in the various institutions.

The two remaining members of the G7, Canada and Italy, play a similar important role in most of these institutions. Yet in contrast to the G5, they do not have exclusive positions in the IMF/World Bank Board of Governors/Directors.

Canada and Italy participate in only two out of three of the working groups in the Joint Forum, whereas the G5 participates in all three working groups. (The Joint Forum is a forum for discussing financial conglomerates, bringing together regulators with the three main international regulatory bodies, BCBS, IOSCO, and IAIS in three working groups, Banking, Insurance and Securities.)

E1: BRICs and O5

Russia is a member of the G8, but clearly does not fall into the same category as the G7 in terms of institutional membership. For historic but also for economic reason is it not member of the G10, which is a forum of central banks and finance ministers of major financial markets.

Russia does not contribute to the various Committees hosted by the BIS, such as the CPSS, CGFS, the BCBS or the Joint Forum. Russia was invited to join the OECD, actively participates in the FATF and the Paris Club. The fact that Russia does not belong to G7 is confirmed by the continued tradition of the G7 Finance Ministers still meeting without Russia, except in the meeting ahead of the G8-Summit.

Russia is often grouped with other emerging economies, such as China, Brazil, and India (the so-called BRIC countries) or the so-called O5 (Outreach Five: Brazil, Mexico, India, China, South Africa). In the power-index, these six countries can all be found in the upper-half of the index, but occupy very different ranks (Russia: 13th, Mexico: 14th, Brazil: 16th, China: 19th, India: 21st, South-Africa: 23rd).

The common characteristic of these six countries is their membership in all forums attempting to bring together emerging economies and the developed economies, such as the G22, the G33 or the G20. This confirms the “bridge position” that these six countries maintain to the developing world. Brazil, India and Mexico are also member of the G24, a group of developing countries discussing financial matters, China is only an observer of that group.

A common characteristic of these six countries that they lack participation in the BIS-hosted bodies, especially they are not members of the CPSS or the CGFS. Brazil, China, India, and Mexico have been consulted by the CGFS occasionally. All six countries are member of the BIS, but only Mexico and China have seats on the Board of Directors, which gives them slightly more impact on the BIS activities.

Mexico is the only country which is a full member of the OECD, although Brazil, China, India, Russia and South Africa have been invited to join. With the exception of India, all countries are member of the FATF, a task force for fighting money laundering and financing of drugs.

They are all members of IOSCO and IAIS, but only Brazil and South Africa have gained seats on the Executive Council.

W2 vs. E1: G8 Enlargement

When looking at these six countries, two questions should arise: are they really suitable candidates for G8 enlargement? And are there other more suitable candidates?

Russia occupies a high position in the ranking but mostly because of its membership in the G8. Without the G8 membership, it would fall from the 13th to the 20th rank.

Mexico (14th) and Brazil (16th) clearly earned their position in the global financial architecture, and thus among the emerging economies of E1 are the first candidates to be considered for G8 enlargement.

Nevertheless, they are surpassed by the develped countries occupying the upper-third of the ranking (W2). These are developed, medium-sized Western Economies such as Netherlands (8th), Switzerland (9th), Belgium (10th), Sweden (11th), Australia (12th), and Spain (15th). In the past, these countries complained that the G7 weakens their institutional power by not engaging with them more. Nevertheless, their strength is clearly reflected in other forums, such as the BIS-hosted bodies. However, the reason why the W2 have not been invited to the W1 is clearly that they would not bring much diversity to the table of the G7, but make decision-making more difficult, thus it is unlikely that they would ever be candidates for G8 enlargement.

China (19th), India (21st) and South Africa (23rd), however, are surpassed by other emerging economies, such as Singapore (17th), Hong Kong (18th), Argentina (20th), and South Korea (22nd), which are also part of the E2.

The high-ranking of Singapore and Hong Kong reflect their status as important financial markets in the Asian region, which is why they are also members of the Financial Stability Forum.

China is not a direct member of the FSF, but indirectly through Hong Kong. If Hong Kong and China are counted as one entity, instead of two separate entities, than “ChinaHongKong” would occupy the 9th position in the ranking, far ahead of the Netherlands and all other countries that follow.

Why are Argentina and South Korea often ignored in G8-enlargement debates, while India and South Africa are mentioned? In terms of membership in international institutions, all four have similar characteristics like the above mentioned BRICS/O5. They are members of the G20 (and the G22+G33). Argentina is also member in the G24, Korea has been consulted in the CGFS. Argentina has not been invited to the OECD, but Korea is a full member. Argentina is a member in the FATF, Korea is not. Argentina is a member of the Executive Council of IOSCO, Korea is a normal member in IOSCO. But in terms of institutional membership they can clearly match India and South Africa.

India and South Africa are most likely to be chosen for G8 enlargement for geopolitical balance. India represents a large fraction of Earth population, whereas South Africa is the most developed country in Africa (other countries in Africa, like Egypt (38th), Morocco (41st) and Côte d’Ivoire (43rd), occupying position at the lower end of the ranking). Argentina is overshadowed by Mexico and Brazil, whereas South Korea is overshadowed by China, Hong Kong and Singapore in South-East Asia.

W1 vs. W2: FSF- and G20 participation

What distinguishes the group of “old developed economies” (W2) from the G7 (W1)? The Netherlands (8th), Switzerland (9th), Belgium (10th), Sweden (11th), Australia (12th), and Spain (15th) occupy ranks on the top-third of the scale. Only Australia is a member of the G20 and the G22, but all are member of the G33.

Except for Spain and Australia, all are members of the G10, the CPSS, the CGFS (Spain and Australia have been consulted by the CGFS). Belgium, Spain and Sweden are not members of the FSF, Australia, Netherlands and Switzerland send one delegate to the FSF (contrasted with three delegates sent by G7).

All countries of the W2 are full members of the Paris Club, the OECD, the FATF, the IMF and World Bank, but do not dominate these organisations.

Australia is not a member of the BCBS, all other five W2 countries are. Sweden is not a member of the Joint Forum, all others are, with Australia having the most impact as being member of two working groups. Australia and Spain occupy executive positions IOSCO (Spain because IOSCO’s headquarters are in Madrid), all six are members of IOSCO and IAIS.

Thus the main difference between W1 and W2 is the FSF- and G20-participation. The ranking suggests that these countries were deliberately given a weaker-status or excluded from membership by the G7, because again they would add little diversity to the table but make decision-making more difficult. The W2 have impact through the BIS-hosted institutions

W2 vs. W3: BIS-Participation

The second league of developed countries must be contrasted with eight other developed countries (W3) which occupy the lower half of the ranking of the 43 countries, such as Luxemburg (24th), Denmark (26th), Poland (27th), Finland (29th), Ireland (30th), Norway (31st), New Zealand (32nd), and Austria (33rd).

These countries are mostly not members of the G22, G33 or G20 (except for Poland, who was a member of the G33 and the G22, but was not chosen for the G20).

They are members of the BIS (with the exception of Luxemburg), but do not have seats on the Board of Directors. None of them however are systemically important to be members of the FSF or the BCBS (with the exception of Luxemburg, who is a member of the BCBS even though it is not a member of the BIS). Only Denmark participates in the Joint Forum, the other ones do not.

They are members of the Paris Club (with the exception of Luxemburg and Poland), all are members of the OECD, FATF, IMF and World Bank. Only New Zealand and Poland have an Executive Position in IOSCO, but all are members of IOSCO and IAIS.

E2 vs. W3: G20 and OECD participation

Turkey (25th) and Indonesia (28th) can be found in similar position as the above mentioned W3. However, both Turkey and Indonesia have become members of the G20, in contrast to the W3. They are not members of the OECD or the FATF, but Indonesia has been offered enhanced engagement in the OECD (for the ranking, enhanced engagement and invited membership is given the same weight).

Neither Turkey nor Indonesia are member of the FSF or the BCBS, thus the main difference to the group above is their membership in the G20 or in the OECD. It would be fruitful to study whether G20 or OECD membership adds more power capability in terms of institutional membership.

E3: Occasional participants in international financial institutions

The last group to be discussed is a group of developing countries occupying the lower ranks: Malaysia (34th), Thailand (35th), Saudi-Arabia (36th), Greece (37th), Egypt (38th), Chile (39th), Philippines (40th), Morocco (41st), Venezuela (42nd) and Côte d’Ivoire (43rd).

Malaysia and Thailand were members of the G22 and G33, but not members of the G20. Egypt, Philippines and Venezuela were members of the G24, but not in the G22 or G20 (although Egypt was member of the G33).

None of the eight are important members of BIS-hosted organisations, although Chile, Greece, Malaysia, the Philippines, Saudi-Arabia and Thailand are members of the BIS.
Greece is a full member of the OECD and the FATF, Chile has been invited, the other countries in E3 are not members.
All of them are members of IOSCO and IAIS, with the exception of Saudi-Arabia, Venezuela (only member of IOSCO) and Côte d’Ivoire.

Why include countries like the E3 in the ranking at all? With the exception of Côte d’Ivoire, all countries of E3 are important economies in their region, but this is not reflected in the institutional membership.

• Saudi-Arabia is not a member of BIS or BIS-hosted bodies, it is not a member of IOSCO and IAIS, not a member of the OECD, the FATF or the Paris Club, but a member of the G33.
• Venezuela has been included in this ranking because it is a member of the G24.
• Côte d’Ivoire has been included in this ranking because it was a member of the G33.

There are probably other countries in their respective regions which would earn a higher ranking if included.

Relationship between memberships in various institutions

In the sample of 43 countries, there are some clear relationships between memberships in the various institutions. The most obvious is that all members of the G5 are members of the G7, all members of the G7 are members of the G8, all members of the G8 are members of the G22, G33 and G20 (this is the dominance of the G5/G7 describe earlier).

G24 members are not members of the G8 and vice versa, but 5 members of the G24 are also in the G22, G33, and G20. G24 members are not members of the G10, the CPSS, the CGFS and, with the exception of Mexico, they are not members of the OECD.

When turning to the regulator-institutions and central bank institutions, it is obvious that all G7 members are G10 members, all G10 members are members of BIS, CPSS, CGFS, BCBS, OECD, and FATF.

In fact, not only is the G10 members of the BIS-hosted institutions, the G10 has not added many other countries to these institutions. The CGFS consists of the G10 plus Luxemburg (not a BIS member), the CPSS of the G10 plus Hong Kong and Singapore, the BCBS of the G10 plus Spain.

There is also considerable overlap between the G10 and other instutions hosted by the BIS. Out of the eleven G10 members, only Belgium and Sweden do not participate in the FSF, but the FSF includes Hong Kong, Singapore and Australia.

The Joint Forum includes the G10 with the exception of Sweden, and includes Australia and Denmark.
Seventeen countries are the most relevant players in the BIS-hosted organisations: the G7 (Rank 1-7), Netherlands (8th), Switzerland (9th), Belgium (10th), Sweden (11th), Australia (12th), Singapore (17th), Hong Kong (18th), Luxemburg (24th) and Denmark (26th). None of the emerging economies, despite being members of the BIS, participate in these BIS-hosted institutions.

The vast majority of BIS-members in the sample are also members of IOSCO and IAIS.

Memberships also overlap with regard to the governmental organisations in Paris: the Paris Club, the OECD and the FATF. All members of the Paris-Club with the exception of Russia are members of the OECD. Russia has been invited to the OECD, however. All members of the OECD, with the exception of South Korea actively participate in the FATF. And all members of the FATF, like all other states in our sample are members of the IMF and the World Bank.

Further research

The index has tried to focus on groups relevant to the Financial Architecture, but clearly other institutions could be included. In the area of trade, for instance the G77, the WTO, the Trade-G33, the Trade-G20, the Quad-Group would be relevant. In the area of security policy, the Security Council as well as the P5 (five permanent members in the Security Council), as well as the OSCE could be relevant. In the field of energy, group membership in the OPEC or the IEA needs to be included. Also regional institutions, such as APEC, ASEAN, EU or AU can be incorporated.

Since the index is only a first attempt to get a grip on how group membership affects power, further research would also incorporate different weights for the organisations, maybe differentiated along categories of attendance – head of states, ministers, deputies, working group etc. and policy field.

The April 11 statement was “not very different” from the importance of the 1985 Plaza Accord.

The Plaza Accord reached by the G7 in 1985 refers to a joint intervention in the Currency Markets against the stark appreciation of the US-Dollar in the 1980s. If the comparison is right, then Finance Ministers and Central Bank Governors have agreed to intervene into the currency markets to stabilize the value of the dollar.

Log nominal value of US dollar against other major currencies. NBER defined recession dates shaded gray. Source: Federal Reserve Board via FRED II via Econonbrowser.

Menzie Chinn at Econbrowser discusses the article and is skeptic about the capability of G7 finance ministers to intervene in foreign exchange markets:

• Policymakers, especially finance ministers, have limited means to affect exchange rates directly. [...]
• The evidence that sterilized intervention works is actually more mixed than is commonly allowed. [...]
• When effects of intervention have been identified, they typically (although not always) seem to be of a short term nature. [...]

Prof. Chinn goes on to quote from Owen Humpage’s “Government Intervention in the Foreign Exchange Market” (2003):

Sterilized intervention affords monetary policy makers a means of occasionally pushing an exchange rate in a desired direction. The alternative level then serves as a new starting point for a random walk process compatible with existing fundamentals.

Prof. Chinn then argues that while monetary policy makers cannot change the underlying market fundamentals, their signal to intervene in currency markets can be credible if also the fiscal policies are adjusted.

He predicts that the exchange rate intervention is not immiment, but will occur sooner or later:

If the Fed perceives that the dollar has dropped far enough to keep the U.S. economy out of a deep recession, and the ECB perceives the euro has risen enough to adversely impact euro area economic activity at a time of a pronounced slowdown (see here), then “the stars will be aligned” for a change in the path of (monetary) fundamentals, and hence the value of the dollar.

It is strange that both the Bloomington article and the Econbrowser-blog-post focus so much on exchange rates because Christine Lagard does make some interesting comments in the interview given to Bloomberg Television.

She points out to a special calendar: a 100-day-action-plan (with one of the instruments being a call for disclosure of the losses by banks) and a 300-day-action plan. The measures suggested in the FSF-Report are however not as clearly structured in a 100- and 300-days-action-plan.

Interestingly as well, she sees the changes of International Accounting Standards to be the most crucial one:

Bloomington: Is there a specific change, a specific part of that plan that will make the most immediate difference?

Lagarde: I think the demand that we are putting on the International Accounting Supervisory Board [probably the IASB] is going to be the most critical one. Because what we are saying is actually that the accounting principles that apply at the moment – the marked-to-market is fine, we are not questioning that at all – but we’re simply saying that in the absence of market [liquidity] then clearly additional tools need to be used, indices and various other mechanisms that we want the IASB to actually recommend. And that is important because it will help banks in particular, financial institutions in general, to actually to put a value on something which could not be valued so far.

To make another prediction: the micro-economic changes agreed upon by the G7 Finance Ministers will have a much bigger impact on this crisis as the exchange interventions that the interested public mind seems to crave for.

In the paper, he focuses mostly on the participation of developing countries in the International Government Organisation, but he also gives some interesting definitions on some key words which often appear in global governance discussions.

Global economic governance and types of actors

Global economic governance is the set of norms and institutions along which rules are generated to manage the global economy.

He focuses on four types of actors in Global Economic Governance

• intergovernmental organizations (IGOs)
• states
• non-governmental organizations (NGOs)
• businesses.

Secession, Veto and Opt-Out

The secession right is the right for a state to quit the organization and hence free itself from any obligations and rights.

The opt out right is the right not to implement decisions of an IGO while remaining member of it.

The veto right is the formal right for individual states to veto an organization’s decisions.

Confederations and federations

Weak confederations are IGOs in which member-states have an opt out right but no veto rights. States may not be forced to follow a global rule but they may not prevent others from adopting it for themselves.

Strong confederations have a veto-right but no opt-out right. States may prevent a rule from being adopted, but once adopted, they must all follow it. Strong confederations have therefore the advantage of discipline but the disadvantage of inflexibility, and are best suited for relatively small groups of states with a common sense of purpose.

Federations are IGOs in which states have neither opt out nor veto rights, and hence are forced to follow rules that they do not approve whenever they find themselves in minority.

Statutes, culture, reality

Jabocs also makes the interesting distinction between statutes, cultures and reality. His remarks on the influence of the G7 and other international organisation in the field of standard setting are very interesting:

Global economic policy involves numerous “codes and standards” emanating from the Bretton Woods institutions, the G7, the OECD, the BIS, the FSF, and some UN agencies, as well as from international professional associations (i.e., global business).

Many of these organizations, particularly in the financial area, are selective clubs of Northern states that function with a strong culture of consensus. The global regulations they develop are all subject to opt out rights, and indeed they are often not even enshrined in treaties.

But there is a strong peer pressure among Northern states to actually comply with them, supported by pressure from global business but also from domestic business since, as mentioned earlier, economic isolation from global norms can hurt domestic enterprises.

These organizations can therefore arguably be described as strong confederations.

States that are not members of these exclusive clubs are also expected to embrace the regulations they generate, but they benefit from a real opt out capacity. Many of them exercise that capacity, but others adopt codes and standards to comply with IMF conditionality or because of pressures from credit rating agencies or other private financial actors.

To assess the impact of the report on the global financial architecture and the responses to the credit crisis in the financial markets, it is worthwhile recalling the original demands of the G7.

In essence, the FSF was asked to look at the underlying causes of the credit crisis (which it did) and make proposals for tackling the problem. Quite clearly the FSF concentrated mostly on the micro-economic implications of Financial Regulation and not so much on more macro-economic developments, such as global interest rates, exchange rate movements or the role of new actors like Sovereign Wealth Funds as (de-)stabilizing force in the Financial Markets.

The general message of the report cam be summarized as follows: Blame the banks, blame the credit rating agencies, blame national supervisors! There is very little blame directed at the political level, the central banks or the international bodies coordinating supervision.

This however was expected, given that G7 wanted the conduct of business by the banks (especially the business of off-balance-sheets-vehicles which speculate heavily in structured products) and the credit rating agencies (which are involved in analysing and rating structured products, but also in giving advice on how to set-up structured products) to be at the heart of the global regulatory response.

The FSF reponse shows a tricky balance when it comes to the global framework for Banking Regulation. On the one hand, the FSF wants to increase the scope of Basel II and encourage more countries to adopt the framework, on the other hand Basel II has some deficiencies which have worsened this crisis, that a reform Basel II will undergo a scrutinous review.

The report addresses the fields where Basel-II will undergo a review:

• Increased minimum capital requirements for capital requirements for complex structured credit products (such as Colleratlized Debt Obligations of asset-backed securities) when they are in the balance sheets of financial institutions, especially taking into account liquidity risk when the secondary market for these products evaporates.
• Increased minimum capital requirements for the so-called off-balance-sheets vehicles.
• Less reliance on the ratings of credit-rating agencies when assessing the liquidity risks of securities and less reliance on the ratings of monoline-insurers in Basel II.

The main task of reforming Basel-II will reside in the BCBS, but it seems that other organisations such as IOSCO and IAIS will provide guidance. Furthermore, the FSF will provide guidance for the national regulators to improve their supervision and enforcement of the Basel-II-rules and ensuring that the financial institutions have adequate risks management models.

The enforcement of the national supervisors is also crucial when disclosing losses, which the FSF has enphasized in quite drastic words. The FSF has put out the mid-year reports as a condition for the banks to disclose their losses for two reasons:

• firstly, it wants to overcome the prisoner-dilemma of banks which are faced with the problem that a joint disclosure of losses in the long-term leads to increased trust in the interbank-lending-markets, but in the short-run represents a punishment by the markets when share prices drop.
• secondly, disclosing the losses will be a precondition for a bail-out through lower interest rates by the central banks which the financial institutions could use to recapitalize themselves.

Interestingly, also the IAASB is called upon for to improve the auditing standards, despite the fact that at least in the public mind, incorrect auditing was not the big problem of the credit crisis. The IASB is also called upon to update International Accounting Standards, especially for structured products. Finally, markets are urged to implement better settlement standards for OTC-derivates. All three events point to the problem that underlying causes of the credit crisis is really market information.

The heavy attack on the Credit Rating Agencies follows the market information perspective, but seems to be politically motivated. The internal code of conduct of Credit Rating Agencies does minimize conflict of interests and the IOSCO-2004-Code for CRAs (which is called for an update by 2009) is too vague and general as to really provide some substantial guidance.

Most likely there will be regulation calling for internal firewalls between the departments dealing with the consultancy for structured products, and the analysts rating structured products. As the FSF indicates, there will also be regulation that the CRAs have to introduce differentiated rating schemes for structured products.

Yet it is not clear that all of these measures will help to tackle the fundamental problem of the global financial market, which is an often incoherent and overlapping financial architecture regulating financial markets.

For large financial conglomerates, the regulatory landscape is very complex. The FSF proposes to introduce “Colleges of Supervisors” from the main jurisdictions. This is an interesting idea, especially because such “Colleges of Supervisors” are also going to be introduced for Cross-Border Financial Institutions.

It is also to be welcomned that the international bodies are encouraged to develop more closer cooperation, especially the IMF and the FSF are moving closer again. Whether this is motivated by the idea of strengthening the role of the IMF or linking macro-ecnomic and micro-economic aspects of Financial Stability, can only be speculated.

In any case, there is no central, singular, international, supervisory authority and given the complexity of the problem, it is unlikely that such an authority will emerge any time soon. But until then, the reform of the financial architecture will be patchwork – and the FSF Report is a good example of this principle.

The G7 finance ministers asked the FSF at their October 2007 meeting (statement) to analyze the underlying causes of the turbulence, which the FSF did in the first chapter of the report.

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.

At their February 2008 meeting, 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.

Prudential Oversight

Basel II and Minimum Capital Requirements

The report of the FSF calls for a timely implementation of the Basel-II-framework, despite its deficiencies. In 2006 in a response 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.

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 IOSCO, 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).

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.

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.

Liquidity risk and liquidity management

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.

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.

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.

Over-the-Counter Derivatives

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.

Transparency and Valuation

Accounting, Disclosure and Auditing

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.

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.

The auditing of complex or illiquid financial products needs to be improved. Therefore the International Auditing and Assurance Standards Board (IAASB) and major national audit standard setters are required to rexamine the standards in that area.

Transparency in securitisation processes and markets

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.

Changes in the role and uses of credit ratings

Rating process

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.

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.

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.

Uses of ratings by investors and regulators

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.

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.

Strengthening the authorities’ responsiveness to risks

Translating risk analysis into action

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.

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.

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.
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.

To facilitate central bank mitigation of market liquidity strains, large banks will be required to share their liquidity contingency plans with relevant central banks.

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.

National supervisors will, as part of their regular supervision, take additional steps to check the implementation of guidance issued by international committees.

The FSF will encourage joint strategic reviews by standard-setting committees to better ensure policy development is coordinated and focused on priorities.

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.

Robust arrangements for dealing with stress in the financial system

Central bank operations

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.

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.

To deal with stressed situations, central banks should consider establishing mechanisms designed for meeting frictional funding needs that are less subject to stigma.

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.

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.

Arrangements for dealing with weak banks

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.

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.

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.

In summary, Banks take the blame for the credit crisis by saying that lending standards declined, securities were not sufficiently underwritten, structured products not fully understood, liquidity risks (when markets dry out) not anticipated and because of poor management reputational risk (which result in the stock prices of bank going down) not foreseen for the banks.

The IIF suggests a code of conduct for the major financial institution. The motivation is twofold: such a code of conduct should send a signal to the regulators that the financial industry does not need new regulation. It is questionable though, whether regulators continue to rely on voluntary standards, such as the IOSCO Code of Conduct (2004) for Credit Rating Agencies or the Hedge Fund Code of Conducts (2007).

The second motivation is toward the markets: a code of conduct can be a signal to the markets that certain risks are being addressed. However, markets are more difficult to fool than regulators: if a code of conduct is simply a piece of paper which does not reflect the practices of financial institutions, then markets won’t take the bait.

One weakness of the proposal by the IIF is already included in the proposal: because of the diversity, there will be no single standard for the whole industry. The report says:

Because there are substantial differences in business models, mix of business, exposures,
regulatory oversight and culture, there is unlikely to be a single solution to any issue that would be optimal for all firms and all circumstances. Thus, “best practice” as used here is not a legal obligation but a high standard for firms to apply in developing solutions appropriate to their own situations.

The IIF report calls for improved standards in areas: risk-management governance; technical risk-management issues; and stress testing. They admit that questions have been raised about…

…the ability of certain Boards properly to oversee senior managements and to understand and monitor the business itself.

The report wants to establish a “risk culture” and “three lines of defense” (business management, risk management, audit and control functions). The problem however is not so much that the existing regulation did not already establish these mechanism. The problem is that often the management encouraged the taking of excessive risks claiming that their competitors did the same. This “herding” led to the problem of prudent banks such as the German Landesbanken or the IKB speculating heavily with products they did not fully understand.

In essence, it is doubtful if voluntary standards will satisfy the regulators, but the debate between regulators and industry surely has taken an interesting turn.

(Will be continued)

• Institution: International Association of Deposit Insurers
• Abbreviation: IADI
• Type: Public
• Founded: 2000
• Members Total: 50 (Member Directory)
• Membership in:
• Membership of:
• Description:
  The International Association of Deposit Insurers (IADI) is a separate legal entity domiciled at the Bank for International Settlements in Basel, Switzerland. IADI was created following the work of the study and working groups on deposit insurance (1999 – 2001) by the Financial Stability Forum to consider the usefulness of setting out guidance and then to develop approaches to help policymakers design and improve the effectiveness of deposit insurance systems.

  The objectives of the Association are to contribute to the stability of financial systems by promoting international cooperation in the field of deposit insurance and to encourage wide international contact among deposit insurers and other interested parties. In particular, the Association aims to:

  • enhance the understanding of common interests and issues related to deposit insurance;
  • set out guidance to enhance the effectiveness of deposit insurance systems, with such guidance taking into account different circumstances, settings and structures;
  • facilitate the sharing and exchange of expertise on deposit insurance issues through training, development and educational programmes;
  • provide advice on the establishment or enhancement of effective deposit insurance systems.
• Working Group:
• Outreach: Regional Committees for Africa, Asia, Eurasia, the Caribbean and Latin America
• Reporting to: FSF
• Website:www.iadi.org
• Highest Organ: General Meeting of Members
• Chair: Jean Pierre Sabourin, President and Chief Executive Officer of the Canada Deposit Insurance Corporation
• Seat: Basel
• Function:
• Standards: Core Principles for Effective Deposit Supervision