Контрциклический буфер капитала банков: есть ли основания для применения в России?

Abstract

Recently, the concept of countercyclical regulation in the financial sector has become key for the implementation of macroprudential policies in many countries, while a countercyclical buffer capital of banks is becoming a primary tool of regulation. The purpose of this research is to study the appropriateness and specifics of the countercyclical capital buffer application in Russia’s banking sector based on the analysis of credit aggregates’ dynamics for 2004-2016 and for the mid-term. Drawing on the filtration method, the study shows that the most effective indicator of excessive lending in the Russian economy is credit-to-GDP, the gap dynamics of which testifies a possible activation of capital buffer in 2007 and 2013. At the same time, the size of the buffer appeared to be insignificant, with a short activation period, which suggests the replacement of the buffer with alternative regulative tools. The minimum capital adequacy, taking into account the buffer, is not critical for the banking sector. However, some of the largest banks appeared to be vulnerable to increased capital requirements. The results of this study are of great value both for the implementation of macroprudential policy, and for strategic management of banks capital adequacy.