Abstract

As per the 15th progress report on adoption of the BASEL regulatory framework, published in October 2018 by Basel Committee on Banking Supervision, 26 member jurisdictions now have final rules in force for CCCB. In India, the final rules on CCCB came into force from 5th Feb, 2014; however, the buffer has not been activated by RBI till now as in its assessment, the Credit to GDP gap and other indicators currently do not warrant activation of the countercyclical capital buffer (CCCB). The Basel III regulatory framework for more resilient banks and banking systems, released in December 2010, had introduced the CCCB aimed at strengthening banks defense against the build-up of systemic vulnerabilities. The CCCB is a pre-emptive measure that requires banks to build-up capital gradually as imbalances in the credit market develop. The primary objective of CCCB is to avoid any banking industry stress resulting from wide fluctuations in the credit cycle using the credit-to-GDP gap. In doing so, it raises the cost of capital for banks resulting in moderation of credit demand as well as dissuasion of banks from participating in binge credit growth during the buildup phase itself. The authors have calculated the credit-to-GDP gap (which has been accepted as the main Indicator) for India using the available data and conclude that the buffer guide has historically worked as a reliable EWI in the Indian context. The authors have also concluded that while CCCB is an instrument to protect banks from the bust phase of the financial cycle, it is not an instrument to manage the financial cycle, even if it may potentially have a smoothing impact. An important implication of implementing CCCB using the credit-to-GDP gap as the main indicator for banks and EMEs is that it may hinder beneficial financial deepening, if it is used to actively manage the financial cycle. The authors recommend including the attribution of the Credit-to-GDP GAP w.r.t., the changes attributable to GDP growth, as well as attributable to changes in credit growth in the decision making process to activate CCCB.

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