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‐ Examining the new Capital Stability Rules by the Basel Committee
– A Theoretical and Empirical Study of Capital Buffers
Peter Miu
DeGroote School of Business
McMaster University
Bogie Ozdemir*
BMO Financial Group
Michael Giesinger
BMO Financial Group
Feb 2010
*
Correspondence should be addressed to Bogie Ozdemir, BMO Financial Group, FCP, 100 King Street West, 23rd
Floor, Toronto, Ontario, M5X 1A1, Canada, Phone: 416.643.4567, email: bogieozdemir@yahoo.ca. Opinions
expressed in this paper are those of the authors and are not necessarily endorsed by the authors’ employers.
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– A Theoretical and Empirical Study of Capital Buffers
Abstract:
In the aftermath of the financial crisis, to reinforce the stability of the financial system, policy makers
and the Basel Committee have developed proposals to ensure that financial institutions maintain
sufficient capital buffers. The December proposal by the Basel Committee outlines fundamental
changes and is already being called “Basel III” by the practitioners. It includes a more restrictive
definition of Tier 1 Capital, use of leverage ratios, restrictions on discretionary distributions of earnings,
and a “bottom‐of‐the‐cycle” calibration for the Pillar I regulatory capital requirements. In this paper we
study these proposals first from a theoretical standpoint and then conduct a quantitative impact study.
Recent studies and observations support increasing the quality of capital. Leverage ratios appear
redundant and implementation of them would further complicate the risk optimization problem faced
by financial institutions (FIs). Constraining the discretionary distributions of earnings can keep agency
costs under control but needs be carefully thought through to make sure that value transfer simply
does not take another form and it does not overly interfere with the FI’s dividend policies. The “bottom‐
of‐the‐cycle” calibration does not look defendable. Among other problems, it could adversely affect the
FI’s profitability, decelerating the capital built up by reducing the income generation per unit of capital
base. Addressing the capital buffer problem within the Pillar II Internal Capital Adequacy Assessment
Process (ICAAP) framework supplemented by conditional and forward looking stress testing is clearly the
preferred approach.
Key words: Basel II, Basel III, Pillar I, Pillar II, Capital Buffers, Internal Capital Adequacy
Assessment Process (ICAAP), Capital Adequacy, Risk Appetite, Procyclicality, Risk Capital,
Available Capital, Conditional and Unconditional Value‐at‐Risk (VaR), Tier 1 Capital Adequacy
Ratio, Point‐in‐Time, Through‐the‐Cycle.
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– A Theoretical and Empirical Study of Capital Buffers
Overview:
The recent financial crisis showed the vulnerability of the international financial system.
Financial institutions, previously perceived as unshakable, failed and capital levels of those
which survived were significantly depleted. International policy makers and regulators have
been working on a solution to address the vulnerabilities identified. The December 2009 paper
by the Basel Committee on Banking Supervision titled “Strengthening the resilience of the
banking sector” (BCBS, 2009), is already being referred to as “Basel III” by the practitioners. It is
an attempt to raise the capital levels in hopes of ensuring sufficient levels are maintained
during downturns and stress periods. It plays all seemingly available cards to do so: the
definition of Available Capital (i.e. the supply of capital) is narrowed to raise the quality of
capital, the level of Risk Capital (i.e. the demand of capital) is increased via “bottom‐of‐the‐
cycle” calibration, so that throughout the cycle capital demand stays at its maximum, and
discretionary distributions of earnings are restricted to prevent capital reduction during stress
periods. It even has an extra safely net: if all of the above risk based measures fail, the industry
is instructed to rely on leverage ratios, a reliable non‐risk based measure. In this paper, we
examine each of the components of the proposal both theoretically and empirically. This
discussion can only be meaningfully carried out in a Pillar II framework. Therefore, in Section 1
we define Capital Adequacy in the Pillar II framework. In Section 2 we briefly describe the new
requirements. Section 3 provides a theoretical examination of the new requirements. Section
4 is an Empirical Impact Study. Section 5 is the conclusions.
Section 1 – Capital Adequacy in Pillar II framework – Definition of Capital Buffers
In the Pillar II framework, Financial Institutions (FIs) design an Internal Capital Adequacy
Assessment Process (ICAAP) to measure, monitor and manage the Capital Buffer between their
Risk Capital and Available Capital. This Capital Buffer acts like a “Shock Absorber” and it
ensures that an FI remains adequately capitalized considering its business strategy and its Risk
Appetite under an expected economic outlook and as well as under stress conditions. Risk
Capital is measured in terms of both Regulatory Capital (RC) and Economic Capital (EC) which is
an internally estimated, more advanced measure. Available Capital is most commonly
measured in terms of Tier 1 equity. Available Capital can be thought of as the supply of capital
where as Risk Capital is the demand for capital representing the amount of capital required
from the debt‐holders’ perspective with respect to the FI’s risk taking activities.
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Figure 1: The buffer between “Available Capital” (the supply) and “Risk Capital” (the demand)
It is expected that FIs maintain a positive Capital Buffer at all times (thus Available Capital is
larger than the Risk Capital) although the level of the Capital Buffer may change over the
business cycle – it decreases during downturns and expands during expansions. The larger the
Capital Buffer, the greater the chances that it remains positive (i.e. Risk Capital does not exceed
the Available Capital). On the other hand, a Capital Buffer as a safety cushion is excess (or
unused) equity on which the FI’s shareholders do not receive their required return on equity
(only the Risk Capital is invested in risk taking activities thus providing a return).
After the financial crisis, we see strong arguments to “build up” a capital buffer during
expansionary times, to ensure capital adequacy during recessions. Capital Buffer is the
difference between Available Capital and Risk Capital. While the former can be “built up” (via
retaining of earnings or issuing common share), the latter can be “contained” (for example by
limiting term risk) during expansionary times. Therefore, building up a capital buffer means
maintaining a high surplus capital (being the difference between Available Capital and Risk
Capital). However, maintaining an excessive capital surplus will hurt the FIs’ risk adjusted
profitability due to unutilized Risk Capital.
The FI’s Risk Appetite dictates the amount of Capital Buffer that it is targeting. Because there
are two measures of Risk Capital (EC and RC), there are also two measures of Capital Buffers:
(1) Tier 1 Ratio representing the Tier 1 (Available) Capital to RC relationship and (2) Available
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Capital to EC ratio. FIs, in their Risk Appetite statement for ICAAP, define the minimum
acceptable Tier 1 Ratio and Available Capital to EC ratio.
FIs also need to ensure that their Capital Buffers can withstand stress conditions. The Capital
Buffer between Available Capital (the supply) and Risk Capital (the demand) is squeezed from
both sides under stress. Risk Capital increases due to higher levels of risk (such as increased
probability of default and downgrade probabilities), whereas Available Capital decreases due to
reduced income and increased losses (translating into reduced or negative retained earnings).
Figure 2: Capital Buffer between “Available Capital” (the supply) and “Risk Capital” (the
demand) is squeezed from both sides under stress.
Available Capital
Available
Stress Available Capital Capital
Current
Risk Capital
Risk Capital
In their ICAAP, FIs test their Capital Buffers under stress conditions to ensure their Capital
Buffers remain positive. More specifically, in their Risk Appetite, FIs state the minimum amount
of Capital Buffer allowed under stress ‐ in terms of the Minimum Tier 1 Ratio under stress and
Available Capital to EC ratio under stress. In their ICAAP exercise, FIs examine a number of
topical and conditional stress scenarios, and quantify the impact on Risk Capital and Available
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Capital, and finally test if their Capital Buffer, that would shrink under stress, is still larger than
what is allowed in satisfying their Risk Appetite under stress.
Section 2 – Description of the New Requirements
2.1 The new definition of Tier 1
The Basel II accord originally narrowly defined Tier 1 capital to include only high quality capital
elements such as permanent shareholder equity and disclosed reserves. Both elements are
common in all banking systems, highly visible on financial statements, and have a significant
impact on an FI’s profitability. However, this proposed definition of Tier 1 capital was later
broadened to include some hybrid securities. The original Basel II framework also allowed for
the inclusion of other important and legitimate elements of a bank’s capital base dependent on
both the discretion of the regulators and the fulfillment of certain specific requirements
outlined in the document. As a result, Tier 1 could include but is not limited to:
• Common shareholders’ equity, defined as common shares, contributed surplus and
retained earnings
• Qualifying non‐cumulative perpetual preferred shares
• Qualifying innovative instruments
• Qualifying non‐controlling interests arising on consolidation from Tier 1 capital
instruments
• Accumulated net after‐tax foreign currency translation adjustment reported in Other
Comprehensive Income (OCI)
• Accumulated net after‐tax unrealized loss on available‐for‐sale (AFS) equity securities
reported in OCI
A new approach has been outlined by BCBS (2009) to strengthen the definition of Tier 1 to
ensure that all qualifying elements can be used to absorb losses while the FI remains a going
concern without worsening an FI’s condition in a crisis. The approach specifically suggests that
FIs should reduce their reliance on non‐common equity elements of capital which are
considered of lesser quality. That is, the proposal requires that Tier 1 must be predominantly
common shares and retained earnings adjusted to maintain consistency among different
regulatory jurisdictions. For non‐common equity elements, the requirements for inclusion in
Tier 1 have been strengthened to ensure a higher quality of capital sources. Specifically, they
must be loss absorbing under crisis, they must be “…subordinated, have fully discretionary non‐
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cumulative dividends or coupons and have neither a maturity date nor an incentive to redeem”
(see BCBS, 2009).
The new definition of Tier 1 capital also seeks to entirely exclude instruments with “innovative”
features which have previously been subject only to a maximum weighting restriction of total
Tier 1 capital. Such elements are typically both lower cost as well as lower quality and have, as a
result, eroded the quality of Tier 1 capital due to their increased use in the last decade.
Specifically, securities with “innovative” features such as “step‐ups”, indirect issues, or other
redeemable instruments will be excluded.
Finally, the proposal seeks to increase the transparency of Tier 1 capital by requiring a full
reconciliation of all capital elements back to the balance sheet in financial statements, separate
disclosure of all regulatory adjustments, a description of all limits and minima, a description of
the main features of capital instruments issued, and a disclosure of ratios involving components
of capital with a description of how these ratios are calculated.
2.2 Discretionary distributions of earnings
A key component of the proposal in BCBS (2009) which is now gaining considerable traction
among policy‐makers is a restriction on the discretionary distributions of earnings prior to,
during, and shortly after a crisis. The ultimate goal of such capital conservation measures is to
maintain the stability of capital levels and require that, in the event of stress, other
stakeholders do not receive compensation at the expense of creditors and, more specifically,
depositors and taxpayers.
At a high level, discretionary earnings distributions are any payments which, in crisis, can be
reduced or eliminated entirely if it is in the best interests of the FI to do so in order to ensure
that it remains a going concern. Specifically, discretionary earnings distributions include, but are
not limited to, dividends on both common and preferred shares, share buy‐backs, incentive or
bonus compensation, payments to pension plans, or charges associated with the optional
redemption of innovative securities as included in Tier 1 capital.
During the financial crisis which began in late 2007, it was noted by regulators that many FIs
which had depleted their capital buffers as a result of higher than expected losses did not
reduce their discretionary earnings distributions, in particular dividend payments and incentive
compensation payments. These actions were justified under the assumption that industry
analysts would have negatively viewed any reduction in discretionary earnings distribution as a
sign of weakness potentially resulting in reputational damage to the FI.
In order to prevent this in the future, the Basel Committee has proposed that a buffer range
should be established above the minimum capital requirements such that, if Tier 1 capital
should fall into the buffer range, FIs would be constrained in the total amount of discretionary
earnings distributions. As a result, any reduction in discretionary distributions could be qualified
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under the caveat that it does not demonstrate management’s opinion of future profitability but
rather can be viewed positively in that it reduces the short term drain on the bank’s capital
position.
One of the concerns of the industry in implementing such constraints is that the restrictions
should not be so severe that they cause the buffer to become the effective minimum capital
requirement. On the other hand, the restrictions must be sufficiently strong to force FIs to place
the rebuilding of the capital buffer as one of its highest priorities. In order to balance these two
conflicting requirements, the proposal suggests that the severity of the restrictions on
discretionary distributions should increase gradually as the buffer is depleted.
2.3 Leverage Ratios
Prior to the crisis, many banks built up excessive on‐ and off‐balance sheet leverage in market
conditions which were relatively stable. However, when the crisis occurred, these banks were
forced to deleverage which exaggerated the downward pressure on asset prices, encouraging
further deleveraging, thereby entering a downward spiral in asset values which increased losses
and reduced capital levels.
In the past, the industry has focused primarily on risk‐based capital ratios as a determination of
the appropriate level of capitalization. The high levels of leverage which occurred prior to the
financial crisis were not accurately accounted for in these ratios. BCBS (2009) seeks to develop
a leverage ratio which would “… constrain the build‐up of leverage in the banking sector,
helping avoid destabilising deleveraging processes which can damage the broader financial
system and the economy”; and reinforce the risk‐based requirements with a simple, non‐risk‐
based ”backstop” measure founded on gross exposure.
The Basel Committee has proposed the development of the leverage ratio as a secondary
measure to be used in conjunction with Basel II risk based capital ratios. The leverage ratio will
be calculated as the ratio of a high quality measure of capital, specifically Tier 1 capital and the
predominant form of Tier 1 capital, and on‐ and off‐balance sheet exposure including
derivatives, repos, securitization, etc. with certain adjustments to ensure international
consistency. For the exposure, the Basel Committee has proposed several outstanding
questions that must be discussed, including but not limited to, whether or not exposure should
be the gross amount or should include accounting and regulatory netting.
Currently, many global FIs already include a leverage ratio as part of their quarterly financial
reporting. This leverage ratio is typically calculated as total adjusted assets divided by Tier 1
capital where adjustments include the deduction of specific intangible assets to ensure
comparability between Tier 1 capital and total assets.
2.4 Bottom‐of‐the‐cycle calibration:
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Adjustments to Pillar I Risk Capital were first suggested to remedy the procyclicality of the
capital requirement. FIs use hybrid risk rating philosophies in assigning probabilities of default
(PDs) to their obligors, with varying degrees of Point‐in‐Time (PIT)‐ness. This PIT (i.e.
conditional) element1 makes the PDs procyclical which in turn makes the Pillar I Risk Capital
procyclical. Gordy and Howells (2006) discussed alternative approaches – either by adjusting
the inputs or output – to dampen this procyclicality.
After the financial crisis, the attention of the regulators turned to “building” Capital Buffers. It
was argued that the FIs need to build Capital Buffers during good economic times to ensure
capital adequacy during the downturns (i.e. building up Available Capital while containing Risk
Capital during good economic times). This followed the suggestions for “bottom‐of‐the‐cycle”
calibration for the Pillar I Risk Capital. Under this approach, the level of Risk Capital is set to its
maximum over a cycle so that no matter where we are in the cycle and what the PIT
(conditional) capital requirement is, a FIs’ Risk Capital stays at its maximum. This approach
seems to kill two birds with one stone. Procyclicality is eliminated and a Capital Buffer is
maintained for a rainy day.
Figure 3: Bottom‐of‐the‐cycle calibration sets the capital to its highest level over the cycle
Bottom‐of‐the‐cycle Capital
Risk Capital (t)
There are alternative possible approaches discussed in the Committee of European Banking
Supervisors (CEBS, 2009) and in BCBS (2009). Here we will briefly examine the two commonly‐
discussed ones to achieve a “bottom‐of‐the‐cycle” calibration: (1) a time‐varying confidence
level (as opposed to the constant 99.9% used in Pillar I) and (2) a portfolio level scaling factor:
CEBS proposes that the Confidence Level, CL(t), used in Pillar I’s risk weight function (RW) be
time‐varying which is determined to fulfill: 2,3
1
See Miu & Ozdemir (2009b) for a more specific definition of PIT‐ness
2
Confidence level is currently fixed at 99.9%.
3
RW is used to determine RC for credit risk as per Pillar I.
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RW CL=99.9%(PA‐PDMax) = RW CL(t)(PA‐PDt) where PA‐PDMax is the maximum portfolio average PD
over the full business cycle and PA‐PDt is the current portfolio average PD. As long as PA‐PDMax>
PA‐PDt, CL(t)>99.9%.
During expansionary times when PA‐PDt is low, CL(t) is increased so that RC or RW remains
unchanged. Because PA‐PDMax represents the worst PDs over a cycle, RW CL=99.9%(PA‐PDMax)
represents the maximum RC required over the cycle, thus the adjustment provides a bottom‐of‐
the‐cycle calibration.
In CEBS’s same discussion, as well as in BCBS (2009), a portfolio level scaling factor, SFp(t), is
applied as SFp(t)= PA‐PDDown‐turn /PA‐PDt. If PA‐PDDown‐turn = PA‐PDMax, we can immediately see
that this is the same adjustment discussed above, only being applied to the PDs via SFp(t) rather
than to the CL(t) in order to ensure that the capital level remains approximately at the level
required at the bottom‐of‐the‐cycle (or least at a downturn). More formally, the purpose is to
make sure that:
RW CL=99.9%(PA‐PDMax)≈ RW CL=99.9%( SFp(t) x PA‐PDt).
Section 3 – Theoretical Examination of the New Requirements
Below we discuss the adjustments suggested by BCBS (2009) as outlined in Section 2 from a
theoretical standpoint.
3.1 Tier 1 capital definition:
As discussed in Section 2.1, the new suggested definition of Tier 1 significantly narrows the type
of instruments which may be classified as Tier 1, with heavy reliance on Common Shares and
Retained Earnings. The previous addition of so called “hybrid” instruments, designed to allow
FIs to raise capital at a lower cost and on a tax‐effective basis, is now excluded from the
definition of Tier 1. This view seems to be supported by recent studies4 which suggest that the
Total Common Equity to RWA ratio is a significantly better “predictor” of distress than Tier 1 to
RWA and than (Tier I + Tier II) / RWA . This finding is further consistent with the observation
that some of these hybrid instruments were not able to absorb losses during the last financial
crisis.
4
Buehler, Samandari, and Mazingo, 2010. One caution about the results of this study: this is not a controlled
experiment.
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Hybrid instruments cover three broad groups: innovative instruments (i.e. instruments with
incentives to redeem such as step‐ups); non‐innovative instruments (i.e. instruments which do
not have incentives to redeem); and non‐cumulative perpetual preference shares (e.g. see
CEBS, 2008). These hybrid instruments are often issued by a special purpose vehicle which is
created for the primary reason of raising capital for the FI and are structured to get a
favourable equity treatment from ratings agencies while allowing issuers to make tax‐
deductible payments (the more debt‐like the structure, the better the tax treatment and the
worse the treatment from ratings agencies and vice versa). During the financial crisis, many of
these hybrid instruments were downgraded by ratings agencies and were no longer able to
absorb losses on a going concern basis.
The limits on the maximum amount of innovative instruments or other hybrid instruments as a
percentage of total Tier 1 capital depend on the specific regulatory regime. The original Basel
framework limited innovative hybrid instruments to 15% of Total Tier 1 capital. For hybrids
excluding non‐cumulative preference shares, the limit varies considerably between countries.
In Europe, the limit ranges between as little as 15% and as much as 50% of Total Tier 1 capital.
On the other hand, in Canada, non‐common Tier 1 capital (preferred shares, innovative / hybrid
instruments) could provide no more than 25% of Total Tier 1 capital (which was later increased
to 40% to allow more flexibility in the financial crisis). By removing preferred shares and
hybrids as elements of Tier 1 capital, the Basel proposal would ensure better comparability
between different regulatory regimes given that all allowable elements of Tier 1 capital will be
consistent under the Basel framework.
3.2 Discretionary distributions of earnings:
In the recent financial crisis, the banking system suffered a considerable reduction in common
equity through losses on the asset portfolios of financial institutions. However, throughout that
time, many banks have continued paying dividends, maintaining share buyback programs, and
disbursing earnings in the form of incentive compensation even when it was no longer in the
best interests of the organization. For those banks which continued their discretionary
distributions of earnings given the anticipated losses associated with the financial crisis, it can
be suggested that those distributions were paid to shareholders at the expense of both
creditors and deposit holders. This is in effect a violation of the basic priority of the seniority of
debt over equity. There is significant legal precedent which suggests that directors of financially
distressed firms have a fiduciary duty to creditors as well as to shareholders.
Similarly, because common equity is typically made up of the safe marketable assets,
particularly cash and government bond holdings, by paying out dividends in crisis, there is an
increase in the risk and illiquidity of the remaining assets. “Paying out dividends in the form of
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cash leaves behind riskier assets on a thinner equity cushion, which benefits the shareholders
once again, at the expense of the debt holders” (see Acharya et al., 2009).
A common refrain from industry participants is that banks are incentivized to maintain
discretionary distributions of earnings and not to raise fresh capital to avoid giving an adverse
signal about the health of the bank (see Tucker, 2008). However, the side‐effect of this
collective decision not to reduce discretionary payments was a considerable depletion in
common equity of all FIs at a time when Tier 1 capital ratios were approaching regulatory
minimums.
One study of ten large US financial institutions from 2000 to 2008 suggests that the annual
dividends paid as a percentage of total assets are estimated to have increased from 0.26% in
2007 to 0.34% in 2008 after the first full year of the financial crisis.5 Among the ten large US FIs
which were reviewed, two did not reduce their dividends during the crisis, three reduced or
eliminated their dividend in 2008 and the remaining five reduced or eliminated their dividends
in the first quarter of 2009. Although there was considerable evidence of instability in the
financial markets at the beginning of 2008 (after the collapse of Bear Sterns), there was no
reduction in dividends outside of those three institutions which had suffered crippling losses.
With respect to compensation, critics of existing compensation practices believe that senior
managers within FIs are generally over‐ and inefficiently ‐ paid. “According to this theory,
managers are able to extract significant rents because distant, diffuse, and disinterested
shareholders are unable or unwilling to discipline managers, and because the board is captured
and manipulated by the CEO” (see for example Henderson, 2007). In addition, existing
compensation schemes generally are structured to reward based on short‐term returns which
potentially ignore the long‐term implications and are often not risk‐adjusted.
The proposed changes by the Basel Committee outlined in BCBS (2009) do not attempt to
resolve this misalignment of objectives between creditors and senior management. On the
other hand, the proposal will reduce the discretion of senior managers when capital levels are
depleted beyond a target level. The proposed implementation of a capital buffer to limit
discretionary payments is designed to reduce the ability for FIs to maintain distributions of
earnings in crisis by relying on future predictions of recovery as a justification. Likewise, the
proposal is attempting to reduce the existing pressure to demonstrate strength in a crisis by
presumptively distributing earnings even with a fragile balance sheet. As a result, senior
5
The ten US financial institutions are JP Morgan, Wells Fargo, Lehman Brothers, Wachovia Corp. Citigroup,
Washington Mutual, Merrill Lynch, Morgan Stanley, Bank of America and Goldman Sachs.
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managers will be constrained in their decision making, with respect to distributions and not
operations, to focus on rebuilding the capital position of the FI.
An interesting counterpoint to the proposed capital buffer can be seen in the impact the
proposal may have on more conservative FIs. FIs which historically had consistent and high
dividends will be penalized under the new proposal although they did not significantly
contribute to the volatility during the crisis. For some investors, conservative FIs are seen as a
source of predictable dividend payments and are particularly useful for pension savings.
In effect, because certain FIs have established a strong tradition of maintaining consistent
dividend levels, those FIs will be forced to either raise the target minimum capital level
significantly above the buffer in order to ensure predictable dividend payments or have
investors potentially bear the risk of more volatile dividend payments. Unfortunately, both
options will likely reduce the valuation of those FIs in the long term. The former option, to
increase available capital levels well above the buffer to ensure predictable dividend payments,
will reduce the return to investors while the latter, not holding extra buffer to avoid being
constricted in terms of discretionary distributions, will discourage a core group of investors
including pension funds who rely on stable and predicable bank dividends as a source of
income. The side effect of both scenarios is a reduction in overall confidence in the banking
system and an increase in the cost of capital for more conservative FIs.
As a result of political pressure from the US and UK governments, many large banks have
already discussed reducing bonus compensation and increasing base salaries for senior
executives. Moreover, as part of the stimulus package signed into law by President Obama,
banks which were recipients of taxpayer capital through the Troubled Asset Relief Program
have already restructured the compensation of senior executives to ensure that they meet the
limits on bonus pay. The constraint applied under the Basel Committee proposal on
discretionary bonuses will likely encourage this shift causing a significant increase in base
salaries. It will be important to take into account changes in base salaries during a crisis and
capture this increase as a discretionary distribution to ensure that FIs do not side‐step the
restriction of discretionary distributions by shifting compensation from variable bonus
compensation to fixed salaries which is not subject to the same constraints.
Ultimately, there is considerable evidence from the recent financial crisis to suggest that even a
moderate reduction in discretionary distributions of earnings would have significantly improved
the stability of the industry. A Bank of England report (see Bank of England, 2009) suggests that
“if discretionary distributions had been 20% lower per year between 2000 and 2008, banks
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would have generated around £75B of additional capital – more than provided by the public
sector during the crisis.”
3.3 Leverage Ratios:
After the crisis, the confidence on more recent risk and capital management tools such as
Value‐at‐Risk (VaR) as a tail risk measure and Basel II as a whole has decreased. Therefore, at
first glance, the use of more fundamental and easily understood leverage ratios as an additional
tool appears to be a good way to hedge the reliance on complex risk‐based models to help
ensure financial market stability.
The introduction of more risk sensitive measurement as part of the Basel II framework
introduced new challenges associated with measurement and assessment of risk within large
complex financial institutions. Specifically, by relying on more sophisticated risk models,
regulators introduced new sources of model risk. The use of leverage ratios may help regulators
to assess an FIs capital adequacy without relying on complex modeling assumptions and an FIs’
internal parameter calibration procedures. In that respect, leverage ratios provide a secondary
backstop which can be used in conjunction with more complex risk‐based capital ratios (see
Estrella et al., 2000). Leverage ratios have the significant benefit of being nearly costless to
introduce due to their relative simplicity. In addition, the use of leverage ratios can prevent FIs
from being able to perform regulatory arbitrage by structuring products to obtain higher credit
ratings to qualify for more lenient capital requirements.
There are, however, a number of significant issues with leverage ratios that must be examined
carefully before they are considered a reliable measure of distress. First of all, some recent
studies showed that leverage ratios did not “predict” distress once risk based capital ratios are
taken into account (see Buehler et al., 2010). This is not a surprising outcome as leverage ratios
have the inherent limitation that they are not risk sensitive. If leverage ratios are viewed in
isolation, they can incent excessive risk taking such that the financial institution has a relatively
riskier balance sheet although they are complying with the ratio requirement. This issue may be
remedied by including leverage ratios as a secondary measure to be used in conjunction with
risk‐sensitive ratios such as the Tier 1 capital ratio. There are, however, issues with this
approach as well. Many financial institutions already present the leverage ratio as the ratio of
Tier 1 capital and adjusted assets. Differences in regulatory and accounting regimes can cause
significant discrepancies between the treatments of certain assets. Specifically, the use of IFRS
results in much higher total asset amounts and therefore lower leverage ratios compared to
similar exposures for US GAAP. Studies performed by the Federal Reserve Bank of Atlanta (see
Brewer et al., 2008) using the financial results of large global banks over the period of 1992 –
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2005, have demonstrated that the average leverage ratio can vary country to country between
as little as 3.01% for Germany up to 8.40% for the United States. Similarly, over the same
period, the average Tier 1 capital ratio was 6.27% for Germany and up to 10.04% for
Switzerland. The lack of standardized assumptions surrounding the calculation of total assets in
each regulatory and accounting regime can introduce a lack of comparability among countries.
Moreover, leverage ratios are determined in such a way which is inconsistent with other
industry practices. For example, within many global financial institutions, performance
measurement, deal acceptance and portfolio management are all assessed on a risk‐adjusted
basis. It may be challenging for FIs to create awareness of leverage ratios and ensure that new
deal acceptance requirements take into account the marginal impact on the FIs overall leverage
ratio.
Second order concerns include the lack of clarity for the interaction between leverage ratios
and liquidity ratios and the noise introduced because of some conservative adjustments. For
instance, the proposed assessment of exposure in the leverage ratio would be based on
accounting treatment. As there are many potential differences between the accounting
treatment of exposures in different accounting and regulatory regimes, a one size fits all
approach will introduce noise into the system. In addition, it is unclear as to whether or not the
proposed approach would take exposures as being the commitment amount or the drawn
amount. The assumption that unused commitment will be fully drawn is not supported by
empirical studies and, as this amount varies among different facility types and among different
countries, this one size fits all approach will introduce noise in the system.
3.4 Bottom‐of‐the‐ cycle calibration:
Among the suggested changes in BCBS (2009), the “bottom–of‐the‐cycle” calibration is the
most problematic from a theoretical standpoint as discussed below.
3.4.1 Embedded Historical Stress:
Under the “bottom‐of‐the‐cycle” calibration, at any point in the cycle, the capital level is equal
to the most recent bottom‐of‐the cycle capital level with a buffer equal to the difference
between the bottom‐of‐the‐cycle capital and current capital. We can interpret this Capital
Buffer during the benign parts of the cycle as being a “historical stress” buffer.
Figure 4: Under Bottom‐of‐the‐cycle calibration, Capital Buffer incorporates Historical Stress
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Bottom‐of‐the‐cycle Capital
Capital Buffer
Risk Capital (t)
However, this backward looking historical stress testing may not be relevant for both internal
and external factors. The macroeconomic conditions FIs are facing may be very different from
what they have faced in the past. Moreover, the portfolios currently held, and thus the risk
profile, may also have changed significantly over time. In that respect, bottom‐of‐the‐cycle
calibration has long memory. Consider a bank that was caught with a high risk portfolio during
the last crisis but has since corrected its risk appetite, risk management practices and its
management. This bank’s old mistakes will carry on in its capital buffer.
The calibration also depends on how exposures changed over time. Consider two otherwise
identical banks. Exposure size for Bank A changes over time based on EA(t) and for Bank B,
EB(t). Assume EA(t) = EB(t+Δ), where t is time and Δ is some fixed time period. When t =
bottom‐of‐the‐cycle, the bank with a larger exposure at the time would carry a larger capital
buffer with the implementation of the new rules. We can make the argument that the bank
whose exposure level was lower at the bottom‐of‐the‐cycle was able to reduce its exposure size
more effectively and thus deserves a lower capital buffer. However, some drivers of exposure
may be exogenous to the bank, in which case the differences in capital buffers between Bank A
and Bank B become less justifiable.
In assessing adequacy of the Capital Buffer, the use of more relevant conditional stress testing,
is clearly the preferred approach. As discussed in Section 1, this can be done in the ICAAP
exercise by examining a number of topical and conditional stress scenarios, and quantify the
impact on Risk Capital and Available Capital and by examining if an FI’s Capital Buffer, which
would be depleted under stress, is still larger than what is required in their Risk Appetite.
3.4.2 Confidence Level:
16
Under the “bottom‐of‐the‐cycle” calibration, the reference point is the RC calculated at 99.9%
CL and adjustments are made to bring RC to the same level at different phases of the cycle.
Therefore, the implicit assumption is that CL of 99.9% is accurate for the measurement of RC at
the bottom‐of‐the‐cycle for all FIs. In reality, CL is driven by the target debt rating of the FIs and
CL follows different cyclical patterns over the cycle for different target debt ratings.6 (see Miu
and Ozdemir, 2009b).
3.4.3 Increased disconnect between Internal and External Estimates of Capital. With RC being
more of a binding constraint for many FIs, RC may effectively replace more accurate EC.
Basel II brought Regulatory Capital (RC) closer to internally estimated Economic Capital (EC).
For example in Pillar I, the Risk Weight Function was developed to approximate Economic
Capital for credit risk under some simplifying assumptions.7 However, as a result of these
simplifying assumptions, RC is not as accurate as EC and the error is particularly large for
portfolios with large sectoral and geographical diversification and with exposures which are
heterogeneous in size. Because RC cannot correctly capture the diversifiable risk of a new loan
by the reference portfolio, it cannot correctly estimate marginal capital, therefore it is not
appropriate for the pricing of new loans.8 Moreover, correctly capturing and managing
concentration risk, which is particularly important in the aftermath of the financial crisis, is only
possible with the utilization of multifactor EC models. These shortcomings of RC are well
known. However, when total RC is larger than total EC, RC becomes the binding constraint for
the FIs. These FIs, concerned about generating sufficient return on RC, feel the need to
consider the return on RC as a measure for decision making at different levels, even including
pricing and deal acceptance where RC is arguably most inappropriate.
This must be seen as an unintended consequence of Basel II. RC was not meant to replace the
more accurate EC. This replacement would result in real economic risk, such as concentration
risk, going unnoticed, not correctly priced and managed, and accumulated over time which, in
return, would create significant systemic risk.
Under the “bottom‐of‐the‐cycle” calibration, RC will very likely materially exceed EC, especially
during upturns, which will amplify the problem of RC being the binding constraint and even
more so replacing EC, thus adversely altering the behavior of the banks.
6
The higher the target debt rating, the higher the CL.
7
Portfolios are assumed to be infinitely granular and there is a single source of systematic risk.
8
A multi‐factor EC model, on the other hand, can correctly capture diversifiable risk and thus an EC‐based pricing
methodology correctly prices the new loans based on their correlations with the reference portfolio.
17
3.4.4 Neutrality of risk rating philosophies:
Although all FIs, arguably, use some form of hybrid risk rating philosophies in their PD rating
systems, the degree of PIT‐ness varies among FIs. This makes the comparison of different RCs
at different phases in the credit cycle not possible.
Figure 5: Without correcting for the different degree of PITness in the assessment of Risk
Capital, Capital Buffers cannot be readily compared among FIs
Available Capital
Capital Buffer for More TTC Bank
Capital Buffer for More PIT Bank
Risk Capital
Below we demonstrate how two FIs with different levels of PITness would have different
(conditional) PDs at the same point in the cycle, despite having the same unconditional PDs.
Consider a risk rating system that consists of M different risk rating m = 1, 2, 3, …, M. Under
Merton’s model, the unconditional PD (or long‐run PD) of risk rating m is the unconditional
probability of the asset return of its obligors (pi,t) becoming lower than some constant default
point (DPm). That is,
[
Unconditional PD = Pr p i ,t < DPm . ] (1)
Under the infinitely granular single‐factor model of the economic model underlying the Basel II
Pillar I risk‐weighted asset function, it can be robustly estimated by evaluating the following
time‐series average of “transformed” default rates (see Miu and Ozdemir, 2008a, for details).
⎛ 1− R2 T ⎞
⎜ ⎛ ⎞⎟
Estimation of Unconditional PD = Φ ⎜⎜ T ⎜∑ Φ −1
(θ )
t ⎟⎟ (2)
⎝ t =1 ⎠⎟
⎝ ⎠
where θt is the default rates observed for a particular risk rating from time t = 1 to T; whereas
R2 is the pair‐wise asset return correlation. We can therefore estimate DPm by observing
historical default rates of each risk rating.
18
Let us examine the variation of RCs and capital buffers of two banks (Bank A and Bank B) over
the business cycle. Suppose the two banks are, in every aspect, identical except for the fact
that Bank B adopts a “perfect” PIT philosophy whereas that of Bank A is less PIT. For any risk
rating, they therefore share the same unconditional PD and thus DPm. The “assessment of PD”,
which dictates the amount of RC, will however be different between the two banks at any point
in time. Let us illustrate this difference in the time‐series behavior of RC by considering the
case of a single risk rating defined by the constant default point DPm. Suppose the obligors’
asset returns (pi,t) within this risk rating can be described by the following factor model (here
we follow the specification of Miu and Ozdemir, 2009a).
[ ]
pi ,t = R × f (X t1 , X t2 ,..., X tJ ) + et + 1 − R 2 × ε i ,t (3)
where εi,t is the idiosyncratic risk factor which is assumed to follow the standard normal
[ ]
distribution; whereas the systematic factor f (X t1 , X t2 ,..., X tJ ) + et is a function of J explanatory
t t
2
t
J
[
(e.g. macroeconomic) variables, X , X ,..., X . The systematic factor f (X t1 , X t2 ,..., X tJ ) + et is
1
]
made up of two components: (a) observable component f (X , X ,..., X ) ; and (b) 1
t t
2
t
J
unobservable component et. The unobservable component et is assumed to be normally
distributed. Equation (3) therefore describes the credit risks of the obligors in the portfolios of
both banks given that they are identical.
For illustrative purposes and without loss of generality, let us consider an economy in which
there is only a single explanatory variable X and f(X) = X. So, X is a pro‐business cycle variable.
When X is high (low), we are in the booming (downturn) state of the economy when a low
(high) default rate is expected to be realized.
Let us start with Bank B. Given the fact that Bank B’s philosophy is perfectly PIT, at any time t, it
will assess its PDt (in turn its RCt) based on the observed value of Xt at time t. Its PD assessment
can therefore be expressed as:
[
PDtBank B = Pr p i ,t < DPm X t ]
[
= Pr R × ( X t + et ) + 1 − R 2 × ε i ,t < DPm ]
⎡ DP − R ⋅ X ⎤
= Φ⎢ m t
⎥ (4)
⎢⎣ R 2 ⋅ σ e2 + (1 − R 2 ) ⎥⎦
where Φ (•) is the cumulative standard normal distribution function and σ e is the standard
deviation of et. As expected, from Equation (4), the PD assessment of Bank B (and thus its RC) is
negatively related to the observed value of Xt. Its capital buffer is therefore positively related
to Xt. That is, its capital buffer becomes larger during a booming state of the economy.
19
How will the PD assessment of Bank A different from that of Bank B illustrated above? Given
the fact that Bank A is less PIT, even though it might observe Xt, it will not take into
consideration the full effect of this observation in assessing its PD (and thus in RC).9 Suppose
Bank A only considers part of Xt, denoted as Yt, in making its PD assessment.
X t = Yt + Zt (5)
where Zt is the remaining part of Xt which is ignored in the PD assessment. The PD assessment
of Bank A can therefore be expressed as:
PDtBank A = Pr pi ,t < DPm Yt [ ]
[ ]
= Pr R × (Yt + Zt + et ) + 1 − R 2 × ε i ,t < DPm
⎡ DPm − R ⋅ Yt ⎤
= Φ⎢ ⎥ (6)
⎢⎣ R 2 ⋅ (σ Z2 + σ e2 ) + (1 − R 2 ) ⎥⎦
where σ Z is the standard deviation of Zt.10 Comparing Equations (4) and (6), given that the
variation of Yt only represents a portion of the variation of the business cycle variable Xt. the
variability of PDtBank A (or thus the RC of Bank A) will be less than that of PDtBank B (or thus the RC
of Bank B) over a business cycle. The relative values of the RCs of the two banks at the bottom
of a business cycle will be dictated by the relative values of the assessed PDs in Equations (4)
and (6). There are two off‐setting effects. First, Xt tends to be more negative than Yt at the
Bank B Bank A
bottom of the business cycle, thus resulting in PDstress > PDstress . That is, RC of Bank B is larger
than that of Bank A (or, in other words, the capital buffer of Bank B is smaller than that of Bank
A). On the other hand, the higher degree of uncertainty in the risk assessment conducted by
Bank A under a less than perfect PIT philosophy will lead to a higher PD assessment. It is
represented by the higher value of the denominator of Equation (6) in comparison with that of
Equation (4). In ignoring Zt, Bank A is essentially introducing an additional layer of uncertainty
around its PD assessment based upon Yt. The fact that the denominator of Equation (6) is
Bank A Bank B 11
larger than that of Equation (4) will result in PDstress > PDstress . That is, the RC of Bank A is
larger than that of Bank B (or, in other words, capital buffer of Bank A is smaller than that of
Bank B). The net effect of these two off‐setting factors will determine the relative values of RC
(and thus the capital buffers) of the two banks during a downturn.
9
In the extreme situation of a perfect TTC philosophy, we can interpret it as if the bank will simply ignore Xt.
10
In deriving Equation (6), we assume Zt is independent of εi,t and et.
11
Note that the numerators of Equations (4) and (6) are likely to be negative during the downturn.
20
CEBS (2009)’s approach is considered neutral with respect to the risk rating philosophy. For a
(more) PIT bank, during expansionary times, the portfolio average PD, PA‐PDt will be low(er),
thus CL(t) will be large(r) so that RW CI(t) would be independent of the risk rating philosophy.
This would only be true however if the maximum portfolio average PD over the cycle, PA‐PDMax
is also independent of the risk rating philosophy. The latter is not immediately obvious. The
time varying confidence interval discussed in the CEBS paper (2009) is non‐neutral with respect
to the risk rating philosophy. This neutrality can only be achieved by making the cyclical CL(t)
also a function of the specific realization of the FIs risk rating philosophy.
The same problem also exists for the portfolio level scaling factor discussed in CEBS’s same
discussion paper (2009). This approach is also considered neutral with respect to the risk rating
philosophy with the explanation that for a (more) PIT bank, during expansionary times, PA‐PDt
will be low(er), thus SFp (t) will be large(r) so that RW CL=99.9% would be independent of the risk
rating philosophy. This would only be true, however, if PA‐PDMax is also independent of the risk
rating philosophy, which is not immediately obvious.
In conclusion, neither tool of the bottom‐of‐the‐cycle calibration, the time varying confidence
interval nor the portfolio‐level scaling factor is necessarily neutral to the varying degrees of PIT‐
ness of risk rating philosophies adopted by different FIs, which makes an apples‐to‐apples
comparison among the FIs not possible.
As a matter of fact, such neutrality can be achieved by decomposing hybrid risk rating
philosophies into conditional and unconditional elements as discussed for example in Miu,
Ozdemir (2009b).
Figure 6: Capital adequacies of FIs adopting different risk philosophies are not directly
comparable
Bank A
Unconditional PD ‐ VaR
Conditional PD ‐ VaR
Comparison of
Comparison of
Direct Comparison
Not possible
Bank B
Section 4 – Empirical Impact Study
In considering the validity of the proposed capital buffer approach which incorporates the
“bottom‐of‐the‐cycle” calibration and the capital conservation buffer, a couple of studies were
performed in this section to examine the impact on realistic corporate and commercial
portfolios. Analysis of historical portfolios demonstrated that PD and exposure size are the two
most significant drivers of capital given a fixed type of portfolio (largely corporate exposures
with consistent levels of industry diversification).
In order to eliminate the noise caused by changes in portfolio size as a result of expansion of an
FI’s portfolio and capture the impact of changes in the business cycle, several assumptions were
made in both studies:
• PD migration through the business cycle was taken into account by shifting the PDs
based on historical changes in the portfolio average PD. That is, the PA‐PDt for each year
matched the historically measured portfolio average PD with the PDt of each obligor
shifting based on the ratio between PA‐PDt and PA‐PDbase
⎛ PA − PDt ⎞
PDt = PDbase ⎜⎜ ⎟⎟ (7)
⎝ PA − PDbase ⎠
• The studies covered the period from 1995 to 2009.
• The base portfolio was taken to be the fourth quarter of 2009.
4.1 Corporate Portfolio
The first study was performed using a portfolio containing largely corporate exposures with
some sovereign and bank exposures which had low PDs and high correlation. Risk Capital was
estimated using the Basel II Pillar I’s Internal Rating Based (IRB) formula for calculating risk‐
weighted assets of corporate, sovereign and bank exposures.
22
Figure 7: PD and Risk Capital Levels for a Sample Corporate Portfolio based on Historical Data
from 1995 ‐ 2009
1.8%
100% 1.6%
25% 48%
Capital (% of 2009 Capital)
1.4%
80%
1.2%
PDs
60% 1.0%
0.8%
40% 0.6%
0.4%
20%
0.2%
0% 0.0%
1995 1997 1999 2001 2003 2005 2007 2009
For the corporate, bank and sovereign portfolio, the largest difference between the highest
level and the lowest level of Risk Capital was a 48% decrease in capital from the base year. The
difference between the highest level of Risk Capital and the long‐run average Risk Capital level
was a 25% decrease in capital from the base year.
4.2 Commercial Portfolio
The second study was performed using a portfolio which consists of commercial and small‐ and
medium‐sized enterprise (SME) exposures. The Risk Capital was again estimated using the Basel
II IRB formula for calculating risk‐weighted assets of corporate, sovereign and bank exposures
with the firm‐size adjustment for small‐ and medium‐sized entities where relevant.
Figure 8: PD and Risk Capital Levels for a Sample Commercial and SME Portfolio based on
Historical Data from 1995 ‐ 2009
23
120% 3.00%
11%
Capital (% of 2009 Capital)
100% 2.50%
24%
80% 2.00%
PDs
60% 1.50%
40% 1.00%
20% 0.50%
0% 0.00%
1995 1997 1999 2001 2003 2005 2007 2009
For the commercial and SME portfolio, the largest difference between the highest and the
lowest level of Risk Capital was a 24% decrease in capital from the base year. The difference
between the highest level of Risk Capital and the long‐run average Risk Capital level was a 11%
decrease in capital from the base year.
In comparing the two portfolios, we can make note of several key differences. Although the
relative volatility of PDs for both portfolios was similar, the level of PDs for the corporate
portfolio was less than half the level for the commercial portfolio. The second significant
difference between the portfolio used in the first study and the portfolio used in the second
study was that the average asset correlation (i.e. R‐squared in IRB implementation) was lower
for the latter than the former due to the higher PDs and the firm‐size adjustment. As a result, it
was expected that changes in the business cycle would have a less significant impact on
changes in the Risk Capital level of the latter portfolio than the former. The results of the study
shown in Figures 7 and 8 confirmed this result.
4.3 Combined Portfolio
If we combined the commercial and corporate portfolio, we can see that the Risk Capital
volatility is slightly reduced and the largest difference between the highest and the lowest level
of Risk Capital was a 36% decrease in capital from the base year. The difference between the
highest level of Risk Capital and the long‐run average Risk Capital level was a 19% decrease in
capital from the base year.
24
Figure 9: Risk Capital Levels for a Sample “Combined” Portfolio based on Historical Data from
1995 ‐ 2009
120%
100%
36% 19%
Capital (% of 2009 Capital)
80%
60%
40%
20%
0%
1995 1997 1999 2001 2003 2005 2007 2009
4.4 Combined Portfolio with Available Capital
The third element of the empirical study was to incorporate Available Capital, specifically Tier 1
capital, and examine the impact of the Capital Conservation Buffer on capital adequacy.
In this study, Tier 1 capital is estimated based on historical values for Tier 1 capital and Net
Income. Dividends and other discretionary earnings distributions were allowed to fluctuate up
to a target maximum level during expansions subject to the restrictions of the Capital
Conservation Buffer outlined in BCBS (2009). As a result, Tier 1 capital (ACt) is calculated as the
previous year’s Tier 1 capital plus the Net Income after disbursements in the form of share
buyback or dividends to shareholders.
BCBS (2009) states that banks should hold capital above the regulatory minimum set as the
“bottom‐of‐the‐cycle” calibration. This buffer range called a “Capital Conservation Buffer” is
established above minimum capital requirements. If a bank’s capital falls within this buffer
25
range, capital distribution constraints will be imposed. During times of stress, the buffer can be
drawn down but should be rebuilt once the bank has the capacity to do so.
Banks should not use future predictions of recovery as justification for diverting earnings away
from rebuilding capital buffers towards distributions to shareholders, other capital providers
and employees.
BCBS (2009) outlines the general qualities of the Capital Conservation buffer and provides an
example of a potential buffer to be used, although the Basel Committee suggests that the
specific implementation of a buffer would require calibration in order to ensure that it has
reasonable effectiveness and does not overly penalize financial institutions. The constraints
placed on the bank in this study were based on the initial proposal by the Basel Committee and
are outlined in the table below.
Table 1: Example of Individual Bank Minimum Capital Conservation Standards as defined by
BCBS (2009)12
The difference between Tier 1 capital (i.e. Available Capital) and Risk Capital is the excess
capital. Within the table, the excess capital is broken up into three sections:
• Structural excess capital which results from the use of downturn or bottom‐of‐the‐cycle
calibration of Risk Capital.
• Capital Conservation Buffer which results from the implementation of the proposal by
the Basel Committee to create a Capital Conservation Range. Under stress, the Capital
Conservation Buffer can be drawn down upon, however banks in which Tier 1 capital is
less than the Capital Conservation Range maximum are constrained in terms of
decisions relating to discretionary earnings distributions. If the Capital Conservation
12
Numbers are illustrative and do not represent a proposed calibration level.
26
Buffer is zero (i.e. Tier 1 capital is less than bottom‐of‐the‐cycle Risk Capital), then the
bank is undercapitalized.
• Usable Excess Capital which results from Tier 1 capital being above the maximum of the
Capital Conservation Range. If Usable Excess Capital is greater than zero, then the bank
is unconstrained with respect to discretionary earnings distributions.
The following examples demonstrate the results of implementing a Capital Conservation buffer
as proposed by BCBS (2009). The first study is based on the assumption that the Capital
Conservation buffer would have a range of 15% of bottom‐of‐the‐cycle Risk Capital. The second
study is based on the assumption that the Capital Conservation buffer would have a range of
30% of bottom‐of‐the‐cycle Risk Capital. Note that in the results of both studies, the excess
capital is listed as a percentage of bottom‐of‐the‐cycle Risk Capital.
Figure 10: Capital Levels for Wholesale Portfolio with 15% Capital Conservation Buffer (Note: AC
– Available Capital; RC – Risk Capital)
120%
Capital Conservation
Buffer
100%
Bottom-of-the-cycle
80% Risk Capital Structural
Excess Capital
60%
40%
1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009
AC RC Downturn RC
In the case of the Capital Conservation buffer with a range of 15% of Risk Capital, the study
shows that the year with the maximum excess capital was in 2005. In that year, structural
excess capital was equal to 21% of Available Capital (or 28% of Risk Capital). At the same time,
the capital conservation buffer was entirely maintained and was equal to 11% of Available
27
Capital (or 15% of Risk Capital). Finally, the usable excess capital was equal to 15% of Available
Capital (or 21% of Risk Capital).
Figure 11: Capital Levels for Wholesale Portfolio with 30% Capital Conservation Buffer (Note: AC
– Available Capital; RC – Risk Capital)
160%
120%
Capital Conservation
Buffer
100%
Structural
Bottom-of-the-cycle Excess Capital
80%
Risk Capital
60%
40%
1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009
AC RC Downturn RC
Similarly, if the Capital Conservation buffer had a range of 30% of Risk Capital, the study shows
that structural excess capital was equal to 19% of Available Capital (or 28% of Risk Capital). At
the same time, the Capital Conservation buffer was entirely maintained and was equal to 20%
of Available Capital (or 30% of Risk Capital). Finally, the usable excess capital was equal to 14%
of Available Capital (or 20% of Risk Capital).
The above experiment shows that with a 15% Capital Conservation buffer, the total capital
surplus can reach up to 64% of Risk Capital with only 21% of it being usable and 43% being
unusable (i.e. 28% Structural Excess Capital; 15% Capital Conservation Range). Similarly, it
shows that with a 30% Capital Conservation buffer, the total capital surplus can reach up to
78% of Risk Capital with only 20% of it being usable and 58% being unusable (i.e. 28% Structural
Excess Capital; 30% Capital Conservation Range). These levels of capital buffers do look
excessive and as it is not income generating, it would significantly hurt the FI’s risk adjusted
profitability. It can decelerate the capital built up by reducing the income generation per unit
28
of capital base. Ironically, this outcome is the direct opposite of what is intended as an FI’s
ability to replenish its capital levels during upturns is impaired.
There is also a concern of adverse incentivizing. During the expansionary times, banks whose
Risk Capital level is calibrated to the bottom‐of‐the‐cycle (thus, they will need to hold high
capital levels despite the low portfolio average PDs which will hurt their risk adjusted
profitability due to the excess capital buffers) are incented to increase portfolio average PDs by
shifting their portfolio composition towards riskier loans. Although this would make use of the
excess capital buffer, it is not the desired behaviour from a systemic risk perspective.
Other unintended consequences can range from increased cost of capital and cost of borrowing
for the banks which will translate into higher borrowing costs for end users of credit, reduction
in available credit in the system, to reduced rates of return on equity for banks and, in the
extreme, to a reduction in investor appetite as suppliers of that equity.
Section 5 – Conclusions
In this paper, we discussed the new Capital Stability Rules proposed by the Basel Committee in
BCBS (2009), which is already referred to as “Basel III” by the practitioners due to its very
significant implications. Our theoretical analysis identified significant shortcomings most
notably for bottom‐of‐the‐cycle calibration. The impact analysis on a couple of stylized
portfolios showed that Capital Surplus can reach up to 64% of Risk Capital with only 21% of it
being usable and 43% being unusable during the top‐of‐the‐cycle if the Capital Conservation
Range was establish as 15% of Total Risk Capital. These levels of capital surplus would
significantly impair an FIs’ risk adjusted profitability and decelerate capital build‐up during the
economic expansions. Other unintended consequences can range from an increased cost of
capital and cost of borrowing for the FIs which will translate into higher borrowing costs for end
users of credit, reduction in available credit in the system, to reduced rates of return on equity
for banks and, at the extreme, to a reduction in investor appetite as suppliers of that equity. In
terms of the other components of the proposal, recent studies and observations from the
financial crisis support the case for increasing the quality of capital. Imposing leverage ratios
appears redundant and disconnected with current practices, and implementation of which is
very likely to further complicate the risk optimization problem faced by FIs. Constraining the
discretionary distributions of earnings appears well intentioned to keep agency costs under
control and to prevent value transfer from deposit holders to share holders. However, it needs
to be carefully thought through to make sure that value transfer does not simply take another
form. Another important drawback is the risk of interfering with an FIs’ dividend policies which
29
are formulated, in many cases, on very legitimate economic realities. The “bottom‐of‐the‐
cycle” calibration however does not look defendable. Addressing the capital buffer problem
within the Pillar II – an ICAAP framework supplemented by conditional and forward looking
stress testing is clearly the preferred approach. We would like to conclude by reminding that
no amount of capital is a substitute for (a lack of) sound risk and capital management. We need
to be cautious about over relying on capital buffers for the aversion of a crisis. The emphasis
should be on developing better risk and capital management processes, and maintaining higher
quality capital.
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