Abstract

The Basel III Accord was the centerpiece of the international regulatory response to the global financial crisis, setting new capital requirements for internationally active banks. This paper explains the divergent preferences on Basel III of national regulators in three countries that approximate what are frequently presented as distinct varieties of capitalism in Europe – Germany, the United Kingdom and France. It is argued that national regulators faced a ‘trilemma’ in setting capital requirements, having to prioritize among banking sector stability, the competitiveness of national banks and short to medium term economic growth. Different varieties of national financial system – specifically, banking system and different kinds of ‘banking champions’ – explain the different prioritization of objectives in the ‘trilemma’ and hence for the divergent preferences of national regulators on Basel III capital requirements.

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