13/11/2014: Irish Banks: In a Bad League of Their Own

Standard & Poor's report published yesterday (link here) offers a dark view on the French banks, arguing that their capitalisation, based on S&P own metric, puts them into a "weaker position against their European and international peers than according to regulatory ratios".

The S&P looked at the rank order of national banking systems, "resulting from the capital measure that Standard & Poor's Ratings Services uses in its ratings analysis, the risk-adjusted capital (RAC) ratio… According to the latest available comparative data on Dec. 31, 2013, the five French banks (the four mentioned above plus Groupe Crédit Mutuel) had an average RAC ratio of 7.0% versus 7.7% for our top 100 rated banks. …The gap between our in-house measure and the regulatory one (the fully loaded ratio) mostly stems from the banks' internal models for credit risk that we view as less stringent on some asset classes than for some peers. It also results from our stricter treatment than under Basel III of French banks' large insurance subsidiaries."

So in basic terms, S&P used higher quality test of capital buffers. And here are the results for the select sample of European banking systems:

One thing is clear from the above: Ireland's banking system is faring the worst - by a mile - in the sample. In fact, by S&P measure, it is in the league of its own.

13/10/2013: On Taxes, Debt & Equity

EU Commission published some interesting research into Tax Reforms across the EU. The paper is available here: http://ec.europa.eu/economy_finance/publications/european_economy/2013/pdf/ee5_en.pdf

One interesting topic covered relates to the substitution away from equity in favour of debt funding in corporate capital investment. A chart to start with:

Now, per above, the disincentives to equity investment and incentives in favour of debt seem to be the lowest (in euro area) in Cyprus and Ireland. Note that these countries are associated with aggressive brass-plating (Luxembourg) are distinct from countries with aggressive tax arbitrage activities (Cyprus and Ireland). And thus, behold the skew in the EU Commission analysis: MNCs investing into these countries do not use debt on-shoring (US MNCs do not borrow in these countries), but use registry of equity there (for example, in Irish case - due to FDI-booked investments, or equity investment by IFSC companies, ditto for old Cypriot banking system vis Russian corporates).

The EU admits almost as much:
"There is also evidence that the tax advantage of debt fuels international profit-shifting activities as
rules on interest deductibility differ between countries and there are mismatches in decisions on which instruments are considered debt financing. Several studies analyse the debt financing of multinationals with either parent companies or subsidiaries in the United States, Germany, Canada and the EU. The results of these studies suggest that firms use intra-group loans to adapt their financial structure and minimise their overall tax burden. By shifting debt to an affiliate located in a high-tax country, corporate groups are able to deduct interest payments against a higher statutory tax rate while the interest received by the lending affiliate is taxed at a lower rate. Taking data from 32 European countries between 1994 and 2003, Huizinga et al. (2008) find that a 10 % increase in the tax rate increases leverage by 1.8 %. The authors also show evidence of debt-shifting as, for multinationals with two equal-size establishments in two countries, a 10 % increase in the tax rate in one country leads to an increase in leverage of the company located in that country by 2.4 % and a decrease in leverage in the affiliated foreign company by 0.6 %."

However, overall the tax rates also play the role in this debt-shifting: "Two recent meta-studies by Feld et al. (2013) and de Mooij (2011a) review the existing empirical studies and find that ... a one percentage point higher CIT rate is associated with a 0.27 percentage point higher debt-asset ratio."

Two more major points raised in the paper:

1. Welfare costs: "The tax bias towards debt financing also creates welfare costs. Weichenrieder and Klautke (2008) estimate this cost at between 0.08 % and 0.23 % of GDP, while Gordon (2010) estimates it at about 0.25 % of GDP. As pointed by de Mooij (2011b), these estimates ...fails to take into account the heterogeneity of responses and hence the additional welfare costs due to misallocations. Existing studies also fail to include the larger welfare costs of the negative externalities of using debt, such as systemic risk, the probability of default and the social costs of business cycle fluctuations. Finally, they do not take into account the distortions created by debtshifting activities and misallocation due to international tax arbitrage and administrative and compliance costs (de Mooij, 2011b). Consequently, the welfare impact of the debt bias can be assumed to be higher than what has been found in the literature so far."
2. Banking Systems and Debt Shifting: "Keen and de Mooij (2012) ...show that taxes influence the capital structure of banks and that, despite capital requirement constraints, the size of the effects of corporate taxation on the financial structure of banks is close to those for non-financial firms." In other words: capital rules do not induce any significant changes in banks behaviour when it comes to funding of banking activities: debt incentives still drive leverage up. Furthermore, "Hemmelgarn and Teichmann (2013) have found that bank leverage, dividend payouts and earnings management (in terms of loan loss reserves) react to changes in the domestic statutory CIT (corporate income tax) rate. ...In the three years after a tax increase by 10 percentage points, the results predict an increase in leverage of 0.98 percentage points or a relative increase by about 1.1 % (in relation to the equity ratio it would mean a notable relative decrease, of 8.9 % of equity)." Core conclusion: "These results suggest that a reduction in the preferential treatment of debt would result in a significant decrease in bank leverage. In addition, the results also show that regulatory capital requirements in the banking sector alone do not seem to be a prime determinant of financial structure. ... the effect of taxation conflicts with the aim of current regulatory reform to increase capital in the context of Basel III."

14/7/2013: Banking Reforms : recent links

Some recent articles on Banks Reforms in the global and EU context:

"A viable alternative to Basel III prudential rules" by Stefano Micossi (9 June 2013) argues that Basel III "…proposed reforms will fail to correct flaws in the old system. The new rules are even more complicated, opaque and open to manipulation. What is needed is a radical shift to prudential rule based on a straight capital ratio."
Link: http://www.voxeu.org/article/viable-alternative-basel-iii-prudential-rules


And in a typically Bruegelesque fashion, "Basel III: Europe’s interest is to comply" by Nicolas Véron (5 March 2013) argues that since "the EU was once a champion of global financial regulatory convergence", then "the EU should drop its lacklustre inertia and pursue Basel III because, in the end, it’s in its interests to comply. EU policymakers ought to aim at enabling the adoption of a Capital Requirements Regulation that would be fully compliant with Basel III."
Link: http://www.voxeu.org/article/basel-iii-europe-s-interest-comply

His colleague, Daniel Gros is of a view that diversification is a good thing, but diversification not i regulatory space. In his "EZ banking union with a sovereign virus" (14 June 2013) he argues that: "The doom-loop between banks and the national governments played a dominant role in the Eurozone crisis for Ireland and Cyprus. A Eurozone banking union is usually viewed as the solution. This column argues that the doom-loop cannot be undone as long as banks hold oversized amounts of their government’s debt. A simple solution would be to apply the general rule that banks are prohibited from holding more than a quarter of their capital in government bonds of any single sovereign." Here's the problem, however, in both Cyprus and Ireland sovereign bonds holdings of own governments were not a problem. In Cyprus the problem was holding of Greek Government bonds, and in Ireland, the contagion mechanism was from inter-bank lending and banks' own bonds issuance to the sovereign via a blanket 2008 Guarantee.
Link: http://www.voxeu.org/article/ez-banking-union-sovereign-virus


"Implementation of Basel III in the US will bring back the regulatory arbitrage problems under Basel I" by Takeo Hoshi (23 December 2012) says that "rejigging financial regulation is in vogue. But, in the world of international finance, how well do different regulatory systems join up?" In the US context, the author "argues that the US Dodd Frank Act and Basel III are, in part, incompatible and that harmonising them may lead to unintended consequences. The US ought to tread carefully here but should also try hard to maintain the spirit of better financial regulation."
Link: http://www.voxeu.org/article/implementation-basel-iii-us-will-bring-back-regulatory-arbitrage-problems-under-basel-i


There's a huge amount of opinion published on Voxeu.org on bank regulation: http://www.voxeu.org/debates/banking-reform-do-we-know-what-has-be-done


ZeroHedge classic: http://www.zerohedge.com/node/475643 "The Secret Sauce Of Iceland's Success Story: Debt Liquidation?" argues that "That Iceland is so far the only success story in the continent of Europe, which continues sliding into an ever deeper depressionary black hole, as a result of the complete destruction of its financial sector and its subsequent rise from the ashes, is by known to most. …As it turns out, perhaps the biggest jolt to Icelandic economic growth is what we said was the correct prescription for resolving not only the US but global growth malaise that struck in 2008: debt liquidation."


Irish Times covers the outright bizarre and sublimely ironic day-dreaming that is going on in Ireland's highest policy circles. The latests instalment is transformation of the IFSC into a sort of "We've screwed up so comprehensively, we can sell this as competence" story: http://www.irishtimes.com/business/sectors/financial-services/ifsc-faces-radical-rethink-as-effects-of-crash-become-clear-1.1460832?page=2

Pearls of wisdom: "Ryan’s paper makes eight proposals, including “relaunching the IFSC brand” along product lines – global asset finance, a global servicing platform and a global listing platform." All of which have been already in place for years to various success. "The document recommends the creation of a JobsHub to allow firms seeking staff to “find people quickly and cost effectively”." Other things: setting up IFSC as a centre for 'bad banks' on foot of 'experience already present in NAMA'. This is the logic of converting Dublin Bay into a global toxic refuse dump for the UK and European waste disposal, because we 'already have considerable expertise' at the Poolbeg waste facilities. And last, but not least: converting IFSC into "global centre of excellence for property"… Even the Irish Times could not have escaped the obvious irony present in this idea.


Last, but not least, Bloomberg report on Michel Barnier balmy ideas on 'Bank-Crisis' plans for the EU: http://www.bloomberg.com/news/2013-07-09/eu-steels-for-battle-over-bank-resolution-plans-led-by-germany.html from July 9. "The European Union’s executive arm proposed procedures for handling failing banks with a 55 billion-euro ($70 billion) backstop, setting up a showdown with Germany over control of taxpayers’ cash." Good summery of current play on this.

8/6/2013: Shortages of Safe Assets & Banks Recaps - troubled waters of Basel III

Here's an interesting view on European banks: http://www.voxeu.org/article/urgent-need-recapitalise-europe-s-banks . The core point is here:

Chart: Market-to-book value of European banks:

Quote: " On average, the market-to-book value of European banks now is about 0.50 (see Figure 1). This indicates that accountants’ estimates of bank capital are far too rosy, and that banks have substantial hidden losses on their books."

But there's more. "Until now, Europe’s banking sector has been kept afloat by implicit state guarantees of virtually all liabilities. …in 2012 these guarantees provided banks in Europe with an annual average funding advantage amounting to 0.3% of total assets. …An annual funding advantage of 0.3% of assets can be capitalised to be equivalent to 2% of total assets, on the assumption of a discount rate of 15% commensurate with banks’ uncertain earnings prospects. Given total banking assets of €33 trillion in the Eurozone, we are talking about an implicit guarantee of about €650 billion."

In short, through the crisis, European banking system was pumped with implicit supports to the tune of EUR2.6 trillion.

More than that. EBA is delaying stress tests into 2014, so we won't even in theory be able to know what is going on in the banks. Except, one has to doubt that the theory is a good instrument for the reality, as EBA has managed to bungle all stress tests it carried out to-date. In other words, EBA is acting de facto to increase implied supports as it delays and evades recognition of losses.


Look at the following paper: http://www.cpb.nl/en/publication/private-value-too-big-fail-guarantees (alternative link via ssrn: http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2271326) which concluded that: "over the period 1-1-2008 until 15-6-2012" for only 151 European banks, "the size of the funding advantage' granted by various state supports "is large and fluctuates substantially over time. For most countries it rises from 0.1% of GDP in the first half of 2008 to more than 1% of GDP mid 2011. Our results are comparable to findings in previous studies. We find that larger banks enjoy on average higher rating uplifts, but the effect of size does not increase anymore for banks with total assets above 1,000 billion Euro compared to banks with assets between 250 and 1,000 billion Euro. In addition, a higher sovereign rating of a bank‟s home country leads on average to a higher rating uplift for that bank."

In other words, remove the protectionist supports and the system will crumble.

Note, the paper also cites the case of Ireland. "When we take a closer look at the funding advantages of banks from Spain, Italy, and Portugal in Figure 7, we see that the advantages enjoyed by banks are relatively small in these countries. This can be explained by the smaller rating uplifts that the banks from these countries enjoy. The fact that rating uplifts are relatively small in these countries is likely to be related to lower sovereign creditworthiness. The banking sector in, for example, Spain is not necessarily smaller when compared to GDP than the banking sector in France and Germany. So this is unlikely to explain the results we find. In Ireland, funding advantages are relatively large compared to the other three countries. The funding advantage enjoyed by Irish banks is somewhat higher than the advantage enjoyed by French and German banks."

Figure 7: funding advantage per country (Spain, Ireland*, Italy, and Portugal) (*note that the figure for Ireland is drawn on a different scale)

Now, when you just thought that the resolution path (as suggested by the article linked above) is well-known: assess, expose, recap, things are getting slightly out of hand. BIS has warned that simply pumping more capital into banks might be a wrong thing to do. Here's the BIS paper: http://www.bis.org/publ/cgfs49.pdf.

In the nutshell, BIS is saying that core tools for dealing with banks insolvency so far are… possibly… making these banks less safe, not more. The problem is that under Basel III, safety of bank capital is determined by safety of underlying assets held as capital (so far - fine). These 'safe' assets are… err… Government bonds and Government-guaranteed commercial paper (e.g. MBS). The idea is that 1) these assets are more secure, thus provide better cushion in the case of distress, and 2) these assets can be sold (are liquid) easily to cover any losses.

Problem is: there is a shortage of 'safe' assets as defined by Basel. The shortages are riven by 1) higher demand for these assets, 2) smaller number of 'safe' (highly-rated) sovereigns, 3) reduced issuance by highly-rated sovereigns ('austerity') and 4) central banks and non-banking financial institutions (e.g pensions funds) hoovering up these assets. BIS is not worried about the shortages of safe assets, but here are some links on this:

• from the Economist: http://www.economist.com/blogs/freeexchange/2013/02/safe-asset-shortage
• and from BIS own researchers: http://www.bis.org/events/conf120621/gourinchas_paper.pdf
• from Bruegel: http://www.bruegel.org/nc/blog/detail/article/1023-blogs-review-the-safe-asset-shortage/
• from FT Alphaville: http://ftalphaville.ft.com/tag/shortage-of-safe-assets/ with a chart:

In turn, shortages of safe assets, even if nascent, can drive ups emend for riskier assets and thus increase riskier assets allocations by the financial intermediaries (think insurance and pensions funds on drugs).

Here's a very interesting discussion of what can happen next from @simonefoxman: http://qz.com/88585/new-fears-of-financial-interconnectedness-highlight-the-delusion-of-bank-capital/?oref=dbamerica

"And therein lies the risk. The assets don’t change hands permanently: It’s just one institution lending junk bonds to another and borrowing higher-quality ones in return. So a default on one side could translate into problems for the other. In such cases, the “high-quality capital” is only as reliable as the low-quality capital it was exchanged for. Moreover, if assets on either end of such a deal are mispriced, it could have knock-on effects across the financial system.

As a result, warns the BIS, the financial system is becoming more interconnected—and thus more susceptible to system-wide problems of the kind we saw in the financial crisis a few years ago."

Once again, Basel III might be off the target by a mile when it comes to improving quality of risk buffers in the banks… Just as with liquidity buffers: http://trueeconomics.blogspot.ie/2013/05/352013-basel-25-can-lead-to-increased.html

3/5/2013: Basel 2.5 can lead to increased liquidity & contagion risks

Banca d'Italia research paper No. 159, "Basel 2.5: potential benefits and unintended consequences" (April 2013) by Giovanni Pepe looks at the Basel III framework from the risk-weighting perspective. Under previous Basel rules, since 1996, "…the Basel risk-weighting regime has been based on the distinction between the trading and the
banking book. For a long time credit items have been weighted less strictly if held in the trading book, on the assumption that they are easy to hedge or sell."

Alas, the assumption of lower liquidity risks associated with assets held on trading book proved to be rather faulty. "The Great Financial Crisis made evident that banks declared a trading intent on positions that proved difficult or impossible to sell quickly. The Basel 2.5 package was developed in 2009 to better align trading and banking books’ capital treatments." Yet, the question remains as to whether the Basel 2.5 response is adequate to properly realign risk pricing for liquidity risk, relating to assets held on trading book.

"Working on a number of hypothetical portfolios [the study shows] that the new rules fell short of reaching their target and instead merely reversed the incentives. A model bank can now achieve a material capital saving by allocating its credit securities to the banking book [as opposed to the trading book], irrespective of its real intention or capability of holding them until maturity. The advantage of doing so is particularly pronounced when the incremental investment increases the concentration profile of the trading book, as usually happens for exposures towards banks’ home government. Moreover, in these cases trading book requirements are exposed to powerful cliff-edge
effects triggered by rating changes."

In the nutshell, Basel 2.5 fails to get the poor quality assets risks properly priced and instead created incentives for the banks to shift such assets to the different section of the balance sheet. The impact of this is to superficially inflate values of sovereign debt (by reducing risk-weighted capital requirements on these assets). Added effect of this is that Basel 2.5 inadvertently increases the risk of sovereign-bank-sovereign contagion cycle.

The paper is available at: http://www.bancaditalia.it/pubblicazioni/econo/quest_ecofin_2/qef159/QEF_159.pdf

19/1/2013: Euro area banks need EUR400bn in capital: OECD

An interesting article via Euromoney (January 14, 2013) on European banks facing EUR400bn in capital shortfall estimated by the OECD.

A quote:

"A chief gripe is the extent to which European banks have refused to acknowledge their losses and write down bad loans, echoing the comedy of errors that has blighted Japan in recent decades.

... the European Banking Authority’s (EBA) financial stress test in June 2011 – which determined the capital-raising target for the regional banking system for 2012 – was based on an excessively benign treatment of the coverage ratio.

The median coverage ratio of the 90 European banks examined in the test was just 38% to meet the 9% core tier 1 capital ratio target. By contrast, the coverage ratio -  which indicates the amount of reserves banks have set aside relative to a pool of non-performing loans - for US banks equated to 67% in the first quarter of 2011, according to the Federal Deposit Insurance Corporation. ...

In a November report, before the Draghi ‘put’, Deluard noted: “In its mild form, European banks’ refusal to recognize losses could lead to a Japanese ‘lost decade’: banks evergreen their loans [ie, rolling over loans to borrowers who are unable to pay], regulators agree to play the ‘extend and pretend’ game, and the credit creation mechanism is permanently clogged."

And this week "the OECD, headed by Angel Gurria, added to the chorus of criticism – in contrast to the EBA’s upbeat assessments – by stating that the ratio of core tier 1 capital to unweighted assets of eurozone banks falls well short of 5% “in many cases”. On this benchmark, European banks face a €400 billion capital shortfall, or 4.5% of the eurozone’s GDP."

The OECD’s concern echoes that of the IMF, the Bank of England and the Basel Committee: "banks have inflated their asset values, despite the EBA’s self-congratulatory claim in July 2012 that banks in the region had reached a minimum 9% of the best quality core tier 1 capital to risk-weighted assets, in excess of the current international requirements."

And as OECD points out, the problem is much more than just 'peripheral' banks - the problem is Germany and France.

Here are two slides from my recent presentation on banking sector (I was planning to present more on this at the Irish Economy conference on February 1, but the session on banking got canceled, so will be posting the full slide deck here in few days time - stay tuned).

Economics 6/11/10: Regulation in Financial Services Sector

This an unedited version of my column in the current issue of Business & Finance magazine.

The New Regulatory Normal: banking and financial services future

The latest poll of public opinion on the issues of domestic and cross-border competition, released in late October, has found that citizens across the EU identified energy (44%), the pharmaceutical products (25%) and telecommunication (21%) as the main sectors where they perceive lack of competition to remain a major problem. Irony has it, banking and financial services (18% concerned) came out closer to the bottom of the list in terms of perceived competition deficit.

Even though more than a quarter of Greek (31%), Irish (28%) and British (27%) residents said that, based on their own experiences, a lack of competition was causing problems for consumers in the financial services sector, these proportions are still below those for other sectors. For example 30% of Irish respondents are concerned with lack of competition in transport sector, and 41% in pharmaceutical sector.

This is despite the fact that across the EU, and indeed the entire developed world, banks are being supported directly (via taxpayers’ financed measures) and indirectly (via the Central Banks supply of liquidity) to the extent well in excess of the combined subsidies delivered to all of the aforementioned sectors of concern. Writedowns of banks assets remain a top priority for policymakers and the adverse newsflow from the sector is abating extremely slowly (chart below).

Total asset write downs by category, October 2009–April 2010
$ billions, Revisions to estimates
Source: IMF GFSR database, 2010

In addition, banks and financial services companies are facing a tsunami of regulatory reforms, which dominate the newsflow and will likely result in more restricted competition and lending in the sector in years ahead.

Banks and financial services companies across the EU play by far much more dominant role in financing economic activity of firms and households than they do elsewhere in the world, as was highlighted in the latest Global Financial Stability Report from the IMF. In contrast with consumers, business leaders worldwide perceive the financial services to be the current hot spot for adverse pressures on the economy. Banks and financial services providers are expected to be more significantly impacted by the uncertainty induced by the policymakers responses to the crisis. For example, Global CEO Study, 2010 conducted by the Institute for Business Value, IBM shows that a large number of CEOs worldwide expect the Banking and Financial Services sector to be subject to greater structural change and volatility over time than the public sector, despite the fact that public sector itself is experiencing unprecedented debt and deficit pressures.

So the latest public opinion polls seem to be at odds with the reality of the potential crisis-and reforms-induced distortions to competition in the banking sector.

This is an unfortunate oversight, for today, more than ever before financial services need a serious debate about the role for and the future direction of regulatory and supervisory regimes in the sector.

Regulatory structures in the traditional banking and financial services sector have failed to keep up with the increasing complexity, demand for services and interdependence of products and service providers. At the heart of the current crisis, by all accounts, were the imbedded conflicts of interest and outdated regulatory regimes.

For example, the overreliance on prescriptive regulation, an approach that is now being promoted as the panacea to the future crises, is itself partially to be blamed for the meltdown in the rated instruments. Per IBM research paper “The yin yang of financial reform: Embracing maxims to enable financial stability and healthy financial innovation”, when regulations mandated that institutions use of the credit rating agencies to assess risks inherent in MBSs and CDOs, “internal credit research essentially died. Had institutions done their own credit analyses, perhaps the ultimate outcome would have been different or, at the very least, less severe.”

This points to a major potential pitfall in the ongoing process of increasing regulatory systems reliance on prescriptive rules as a protection against future crises.

Since the Lehman collapse, governments in the US and Europe have been addressing the imbalances in their national financial systems by passing both structural and operational reforms. These focus on size, scope, societal costs and “too big to fail” institutions (i.e., cross-firm reforms). Operational reforms, typically implemented by regulators or multilateral international organizations, focus on capital, liquidity, incentives and taxation (i.e., what firms need to do within their own organizations).

As our research at the IBM’s Global Centre for Economic Development (GCED) highlights, on a nutshell, the direction of reforms adopted by the US and EU legislators to-date can be described by a stylized formula measuring the returns on equity (ROE) in the banking sector. So far, new regulatory regimes being introduced imply that in the future banking sector will see “Lower R + Higher E = Lower ROE”. This is a structural threat to the viability of the sector, and many new regulations coming on-line globally are the main culprit.

From the international Basel III framework to the Dodd-Frank Act in the US, increased quality and quantity of capital reserves on the financial services companies is likely to drive down global credit supply both in the short term (as banks engage in rebuilding their balancesheets) and in the long run (as financial services providers compete for a severely reduced capital pool).Per Josef Ackermann, the Deutsche Bank CEO, “There can be no doubt that [Basel III] will produce a drag on economic recovery.”

This statement relates to the core headlines coming out of Basel III and to the auxiliary parts of the framework. Specifically, higher capital reserves under Basel III, increasing common equity capital to 4.5% of risk-weighted assets by 2015 and to 7% by 2019, are expected to cost global economy some 3.1% of overall worldwide income over 2011-2015, implying a loss of almost 10 million jobs worldwide.

Ratio of capital to risk weighted assets held on balance sheet
% of Assets
Source: World Bank Financial Stability Indicators

In addition to the cost of rising capital reserves, Basel reforms include the idea of imposing a tax on the systemically important (aka larger) institutions, known as SIFIs. In addition to amounting to a tax on consumers (especially in the markets where a small number of larger banks controls the market for services, such as the Euro zone), such a charge will not address the issues of product (rather than institutions) specific risks.

Finally, Basel III introduction of the new liquidity and funding rules offers another example of a potentially market-restricting intervention that can end up costing the sector dearly, while producing little real benefit in alleviating systemic risks. The idea behind these measures is to ensure that financial institutions hold sufficient liquid reserves buffers to withstand a bank run, as well as to reduce the banks over-reliance (especially in Europe) on short-term wholesale funding. At the very best, these measures will lead to a significant cut in the banks’ ability to generate credit in the future.

At the same time, it is highly doubtful that any level and quality of reserves can ever guarantee a sufficient insurance against significant asset busts or even large liquidity events. Past history, as for example, analysed by a recent research paper from the University of Pennsylvania, clearly shows that regulatory tightening following previous episodes of major financial markets corrections had inevitably failed to prevent or even to significantly alleviate future financial busts. Instead, every episode of deep markets corrections was followed by severe tightening of financial regulation, prompting lenders to increase their reliance on more complex financial products. The levels of reserves never once were found sufficient to cover the sector.

More specific potential adverse effects of Basel III and Dodd-Frank Wall Street Reform and Consumer Protection Act changes relate to all three core sides of financial services business models: the trading side, the capital side and the funding side. On the trading side, increased capital reserves will likely constrain trading exposures, and cover for securitization and counterparties. The positive here will be a shift from narrowly traded derivatives to exchange-traded and centrally cleared derivatives. The net effect, however, will be smaller new products base in the sector and tighter margins, leading to a pressure on the returns.

Another study, titled “Global financial services: a New Regulatory Normal” prepared by the GCED identified a series of other potential risks in the latest regulatory reforms processes worldwide. In addition to the main headlines on capital side of the reforms outlined earlier, ongoing regulatory changes imply introduction of pro-cyclical capital bases, tighter restriction of capital allowances to paid up capital and retained earnings, elimination of hybrid products from capital base, as well as deferred taxes and intangibles. Restriction of minority equity and leverage ratios alongside with aforementioned capital rules changes will also likely lead to higher cost of banks capital and origination bases, implying restricted lending and associated jobs and income losses in the real economy. Lastly, stressed liability-linked liquidity provisions and efforts to reduce maturity mismatch via reduced reliance on short-term funding will further depress lending.

All of this suggests that going forward, banking sector in Europe and the US will face significant difficulties in generating new lending. In line with this, financial services growth is likely to shift away from traditional banking and brokerage, and toward less regulated and liquidity-rich sovereign wealth players and alternative lenders and investors.

This, in turn, will have profound effects on economic development, as the aforementioned GCED research highlights. In addition to tighter credit markets for companies and households, new rules are likely to lead to significant increases in costs and access barriers to capital for long term assets, such as infrastructure and plant investment. This development can also amplify, not reduce, the links between the exchequers and the banks. As banks will play an increasingly important role as the holders of public debt and as the source of tax revenue, current liquidity traps will be deepened. Liquidity supply and velocity of money will be reduced and M2 and broader money supply metrics will continue to lag liquidity injections from the central banks.

The resulting risk of closer political and economic integration between the financial services providers and the states can create simultaneously a new layer of inefficiency in financing of economic growth. It can also amplify shared risks, setting up the next crisis, this time around – with potential for a full contagion from the financial services to the sovereigns.

In the light of these regulatory changes and the convergence of regulatory regimes, banking and other financial services institutions face the need to provide sufficient internal buffers against the rising regulatory risk. These buffers require service providers to:

1. Rethink their business models to simplify operations and enhance ability to deal with systems and models complexity
2. Rebuild their balance sheet and focus on the new capital and leverage requirements
3. Actively pursue opportunities for mergers and divestitures
4. Improve their understanding of clients’ behaviors and preferences
5. Reconnect with their clients by investing in client analytics to gain insights
6. Provide clients with more and more complex and better responding services and data
   

In short, addressing business challenges presented by the ongoing processes of regulatory reforms worldwide, the banking and financial services sector will have to get much smarter in structuring future strategies for growth and operational processes.