Risk-based Capital Requirements Research Articles

Supplementary Leverage Ratio and Repo Supply

While simpler than risk-based capital requirements, the leverage ratio may encourage bank risk-taking. This paper examines the activity of broker-dealers affiliated with bank holding companies (BHCs) and broker-dealers not affiliated with BHCs in the repurchase agreement (repo) market to test whether this may be occurring. Using data on the triparty repo market, the paper arrives at three findings. First, following the 2012 introduction of the supplementary leverage ratio (SLR), broker-dealer affiliates of BHCs decreased their repo borrowing but increased their use of repo backed by more price-volatile collateral. Second, the paper finds that regardless of whether a U.S. BHC-affiliated broker-dealer parent is above or below the SLR requirement, the announcement of the SLR rule has disincentivized those dealers affiliated with BHCs from borrowing in triparty repo. Finally, the paper finds an increase in the number of active nonbank-affiliated dealers in certain asset classes of triparty repo since the 2012 introduction of the supplementary leverage ratio. This illustrates how regulation can have competitive effects on the financial sector and may result in activities shifting among financial firms.

Regulation and pension fund risk-taking

We investigate the extent to which regulations governing investment, valuation and funding affect the riskiness of defined benefit pension funds' asset allocation. We compare the regulatory frameworks of public, corporate and industry pension funds in the United States, Canada and the Netherlands over 1992–2011. Derived from panel data analysis of a unique set of asset allocation details for close to 600 funds, our results highlight that regulatory factors are more economically significant than pension funds' characteristics in shaping asset allocation. In particular, risk-based capital requirements and mark-to-market valuation are both associated with a 7% lower risky asset exposure, especially equities, regardless of market conditions. By contrast, the exposure of a pension fund subject to a 100% funding requirement does not differ significantly from that of an unconstrained pension fund during normal times, but the constrained pension fund invests 4% less in risky assets during a financial crisis. In line with theoretical predictions, we find that risk-based capital requirements and minimum funding limits have different consequences for pension funds’ risk-taking.

Do Higher Capital Standards Always Reduce Bank Risk? The Impact of the Basel Leverage Ratio on the U.S. Triparty Repo Market

While simpler than risk-based capital requirements, the leverage ratio may encourage bank risk-taking. This paper examines the activity of broker-dealers affiliated with bank holding companies (BHCs) and broker-dealers not affiliated with BHCs in the repurchase agreement (repo) market to test whether this may be occurring. Using data on the triparty repo market, the paper arrives at three findings. First, following the 2012 introduction of the supplementary leverage ratio (SLR), broker-dealer affiliates of BHCs decreased their repo borrowing but increased their use of repo backed by more price-volatile collateral. Second, the paper finds that regardless of whether a U.S. BHC-affiliated broker-dealer parent is above or below the SLR requirement, the announcement of the SLR rule has disincentivized those dealers affiliated with BHCs from borrowing in triparty repo. Finally, the paper finds an increase in the number of active nonbank-affiliated dealers in certain asset classes of triparty repo since the 2012 introduction of the supplementary leverage ratio. This suggests risks may be shifting outside the banking sector.

An Assessment of the Market Risk Solvency Capital Requirement Simplifications for Insurance Undertakings

The Solvency II regulatory framework has been implemented as of January 1st, 2016 and among other things it introduced economic risk-based capital requirements across all EU Member States for the first time, applicable for insurance and reinsurance undertakings. Similar to Basel II whose scope is banks, the Solvency II directive provides a new regime based on three pillars for insurers and reinsurers: 1) pillar 1: harmonized valuation and risk based capital requirements, 2) pillar 2: harmonized governance and risk management requirements and 3) pillar 3: harmonized supervisory reporting and public disclosure. The Solvency Capital Requirement (SCR) should correspond to the Value-at-Risk of the basic own funds of an insurance or reinsurance undertaking subject to a confidence level of 99.5% over a one-year period. The Solvency II directive provides a range of methods to calculate the SCR. This allows insurance or reinsurance undertakings to choose a method that is proportionate to the nature, scale and complexity of the risk that is measured. In order to calculate the SCR, an insurance undertaking can use a fully internal model, the standard formula and a partial internal model, the standard formula with undertaking-specific parameters, the standard formula as it is or a simplification. When introducing a simplification, the SCR estimate could deviate from the calculation without the simplification. A simplification could lead in important/crucial information missing from the SCR calculation. In some occasions the SCR is overestimated and in some others it is underestimated. It is therefore of interest to find the range of this deviation, potential bounds—if any and the effect it can have on the required capital. In this paper we attempt to measure this deviation for simplifications pertaining to the interest rate risk for insurance companies.

Optimal equity protection of Solvency II regulated portfolios

The Solvency II regulatory framework creates incentives for using derivatives to mitigate risk. However, for investors willing to reduce capital charges by protecting their portfolio against losses, very few practical solutions exist. In the context of equity investments, we examine the relationship between the cost of acquiring protection (in the form of a put option) and the reduction of capital charges that it entails. We develop the idea that Solvency II regulations introduce an external utility that modifies the economic value of options. Using these findings, we show that there is a way to choose protection levels that maximizes reductions in capital charges for every dollar spent on the put options. We provide results for both risk-based and drawdown-based capital requirements and argue that risk-based capital requirements offer even greater incentives for using derivatives in the context of risk mitigation.

Risk-Based Capital Requirements for Banks and International Trade

The authors provide the first evidence that changes in risk-based capital requirements for banks affect the real economy through international trade. Using a natural experiment – mandatory Basel II adoption in its Standardized Approach by all banks in Turkey on July 1, 2012 – they investigate the impact of new risk-weights applied to commercial letters of credit (CLC) on that country’s exports to 174 countries. The authors estimate the resulting payment-term-cost elasticity of CLC-financed trade to be between -0.5 and -1 while the overall trade elasticity to be between -0.032 and -0.179. Calculations suggest that both CLC-related bank pricing and rationing channels are involved.

Capital regulations, supervision and the international harmonization of bank capital ratios

In recent decades, despite the Basel Committee’s effort to develop internationally uniform regulatory capital standards, the capital ratios of banks across countries continue to exhibit significant differences. This paper examines the fundamental question of whether, given a uniform regulatory capital standard, regulators should expect similar banks to exhibit similar risk-based capital ratios. More specifically, this study develops a one-period theoretical model to examine the level playing field argument in light of not only uniform regulatory capital standards but also differences in bank supervision. The results of the theoretical model suggest that even with an internationally uniform risk-based capital requirement, it is unreasonable to expect banks in different countries to hold similar capital ratios. This occurs, in part, because regulators have discretion in how they apply the risk-based capital standards. Furthermore, the results suggest that a necessary condition for banks to exhibit similar capital ratios is that uniform capital requirements must be accompanied by a uniform stringency and application of regulatory supervision.

Risk-Based Capital Requirements and Optimal Liquidation in a Stress Scenario*

We develop a simple yet realistic framework to analyze the impact of an exogenous shock on a bank’s balance-sheet and its optimal response when it is constrained to maintain its risk-based capital ratio above a regulatory threshold. We show that in a stress scenario, capital requirements may force the bank to shrink the size of its assets and we exhibit the bank’s optimal strategy as a function of regulatory risk-weights, asset market liquidity, and shock size. When financial markets are perfectly competitive, we show that the bank is always able to restore its capital ratio above the required one. However, for banks constrained to sell their loans at a discount and/or with a positive price impact when selling their marketable assets (large banks) we exhibit situations in which the deleveraging process generates a death spiral. We then show how to calibrate our model using annual reports of banks and study in detail the case of the French bank BNP Paribas. Finally, we suggest how our simple framework can be used to design a systemic capital surcharge.

Organizational structure, risk-based capital requirements, and the sales of downgraded bonds

Abstract Using bond downgrades as external shocks to life insurers’ asset risk, we document several findings of the impact of organizational structure and risk factors on investment risk taking. First, we find that mutual insurers and widely-held stock insurers are more likely to sell downgraded bonds than are closely-held stock insurers. Second, we find evidence that insurers are less likely to sell downgraded bonds that remain in the same rating class than bonds downgraded to a lower rating class. The result implies that insurers sell downgraded bonds mainly because of additional capital charge is imposed, not because of downgrade itself. In other words, risk factors in risk-based capital regulation do matter on life insurers’ investment risk taking. Finally, we find that life insurers might be reluctant to sell downgraded bonds at fire-sale prices during the 2008–2009 financial crisis.

Market risk-based capital requirements, trading activity, and bank risk

Abstract This study investigates if market risk-based capital requirements (MRR) implemented in 1998 mitigated bank risk associated with trading activities. Recognizing that only banks with sufficiently high trading activities are subject to the MRR (regulated), we implement a difference-in-difference (DID) approach to show that in the post-MRR period, unregulated banks experienced an increase in risk associated with trading activity, while their regulated counterparts enjoyed no appreciable change in trading-related risk. We interpret the resulting negative DID coefficient as the evidence of a risk-mitigating effect of the MRR. This effect disappears at already well-capitalized banks. We also show that upon the implementation of the MRR, unregulated banks exhibit a significantly larger increase in contribution of opaque trading activity to bid-ask spreads, compared to regulated banks, for which the association between trading activity and bid-ask spreads actually declines. Our results are consistent with the view that the MRR significantly reduced moral hazard and adverse selection problems associated with opaque trading activities.

Market Risk-Based Capital Requirements, Trading Activity, and Bank Risk

This study investigates if market risk-based capital requirements (MRR) implemented in 1998 mitigated bank risk associated with trading activities. Recognizing that only banks with sufficiently high trading activities are subject to the MRR (regulated), we implement a difference-in-difference (DID) approach to show that in the post-MRR period, unregulated banks experienced an increase in risk associated with trading activity, while their regulated counterparts enjoyed no appreciable change in trading-related risk. We interpret the resulting negative DID coefficient as evidence of a risk-mitigating effect of the MRR. We also show that upon the implementation of the MRR, unregulated banks exhibit a significantly larger increase in contribution of opaque trading activity to bid-ask spreads, compared to regulated banks, for which the association between trading activity and bid-ask spreads actually declines. Our results are consistent with the view that the MRR significantly reduced moral hazard and adverse selection problems associated with opaque trading activities.The views expressed in this paper are those of the authors alone and do not necessarily reflect the views of the Board of Governors of the Federal Reserve System, the Federal Reserve System, or their staff.

Capital Regulation and Bank Risk-Taking Behavior: Evidence from Pakistan

In response to the global financial crisis of 2007–2009, risk-based capital requirements have been reinforced in the new Basel III Accord to counter excessive bank risk-taking behavior. However, prior theoretical as well as empirical literature that studies the impact of risk-based capital requirements on bank risk-taking behavior is inconclusive. The primary purpose of this paper is to examine the impact of risk-based capital requirements on bank risk-taking behavior, using a panel dataset of 21 listed commercial banks of Pakistan over the period 2005–2012. Purely regulatory measures of bank capital, capital adequacy ratio, and bank assets portfolio risk, risk-weighted assets to total assets ratio, are used for the main analysis. Recently developed small N panel methods (bias corrected least squares dummy variable (LSDVC) method and system GMM method with instruments collapse option) are used to control for panel fixed effects, dynamic dependent variables, and endogenous independent variables. Overall, the results suggest that commercial banks have reduced assets portfolio risk in response to stringent risk-based capital requirements. Results also confirm that all banks having risk-based capital ratios either lower or higher than the regulatory required limits, have decreased portfolio risk in response to stringent risk-based capital requirements. The results are robust to alternative proxies of bank risk-taking, alternative estimation methods, and alternative samples.

Risk-Based Capital Requirements and Optimal Liquidation in a Stress Scenario

Risk-Based Capital Requirements and Optimal Liquidation in a Stress Scenario

Countercyclical capital regime revisited: Tests of robustness

Financial entities have been subject to risk-based capital requirements for many years. The experiences of the recent financial crisis led to heightened criticism that these rules are pro-cyclical, meaning they require insufficient capital during economic booms and excessive capital during busts. In response, recent revisions to such rules have included a countercyclical capital buffer, but it is problematic because implementation is discretionary with respect to both timing and amount on the part of regulators. An alternative rules-based countercyclical capital proposal put forth by Smith and Weiher (April, 2012. Countercyclical capital regime: a proposed design and empirical evaluation. Federal housing finance agency, working paper no. 12-2) that embodies a dynamically adjusting stress test for mortgage assets was intentionally structured to address these concerns.This paper tests the robustness of key elements of the Smith and Weiher (SW) countercyclical capital regime. Specifically, we examine each of the key design elements of the stress test, including construction of the trend line, the trough, and the time-path. We also expand on the empirical results presented by SW by showing how the resulting capital requirements might vary when their countercyclical stress test is applied using several different credit models.These tests of robustness support the conclusion that the SW countercyclical capital regime should produce capital requirements sufficient to ensure an entity would remain solvent during severe house price cycles. This conclusion is strongly supported by a test of concept of the countercyclical framework using Fannie Mae's historical book of business. If the countercyclical capital requirement had been in place during the run-up to the recent house price bubble, Fannie Mae would have been sufficiently capitalized to withstand losses it sustained in the subsequent housing crisis. This result is particularly noteworthy given that key components of the SW stress test were designed based upon pre-2002 data.

How do banks perform under Basel III? Tracing lending rates and loan quantity

In late 2010, the Basel Committee on Banking Supervision issued the Basel III document enumerating measures focused on improvements in the definition of regulatory capital, introduction of a leverage ratio as a backstop for risk-based capital requirement, capital buffers, enhancement of risk coverage through improvements in the methodology to measure counterparty credit risk and liquidity measurement standards. This study investigates the impact of the new capital requirements introduced under the Basel III framework on bank lending rates and loan growth. Higher capital requirements, by raising banks’ marginal cost of funding, lead to higher lending rates. The data presented in the paper suggest that assuming a 1.3 percentage point increase in the equity-to-asset ratio to meet the Basel III regulations, the country-by-country estimations imply a reduction in the volume of loans by an average 4.97 percent in the long run for the banks in countries that experienced a crisis and by 18.67 percent for the banks in countries that did not experience a crisis. The wide variance in the results reflects cross-country differences in the elasticity of loan demand with respect to loan interest rate and bank's net cost of raising equity.

Basel III D: Swiss Finish to Basel III

After the Basel Committee on Banking Supervision (BCBS) introduced the Basel III framework in 2010, individual countries confronted the question of how best to implement the framework given their unique circumstances. Switzerland, with a banking industry that is both heavily concentrated and very large relative to the size of its overall economy, faced a special challenge. It ultimately adopted what is sometimes referred to as the “Swiss Finish” to Basel III – enhanced requirements applicable to Switzerland’s “too-big-to-fail” banks Credit Suisse and UBS that go beyond the base requirements established by the BCBS. Yet the prominent role played by relatively new contingent convertible capital (CoCos) in the Swiss Finish, coupled with the fact that banks are allowed to use their own internal models in determining whether requirements are met may call into question the extent to which the Swiss Finish to Basel III represents a meaningful enhancement to the risk-based capital requirements of the Basel framework.

Risk-Based Capital Framework: Conventional vs. Takaful Operators

Malaysia introduced an RBC framework for its conventional insurance industry in 2009. In 2011, enhancements to the RBC framework were completed. In an effort to improve the overall Takaful regulatory framework, BNM issued new operational and valuation guidelines on 23 September 2010. BNM further issued the draft of risk-based capital (RBC) guidelines for Takaful operators in April 2011 and gathered the industry’s feedback (Dhesi, 2012). The proposed Takaful RBC framework appears to be similar to that imposed for a conventional business. Parallel to its counterpart, Takaful operators are obliged to have at least 130% of supervisory capital-adequacy ratio (CAR). The minimum CAR imposed is formulated so that Takaful operators have sufficient capital in the shareholders’ fund to meet any shortage in Takaful fund. Capital adequacy is a theoretical amount of capital that is required by each insurance company in order to meet payment obligations and support everyday operation without becoming insolvent. The same methodology and assumptions as outlined in the RBC requirements for conventional business have been used to determine each of these capital charges (Dhesi, 2012). However, Conventional insurer and Takaful operators are having different types of risk for their operations (Obaidullah, 1998). Takaful operators also adopt different types of operating models (mudharabah, wakalah and hybrid). The RBC-framework for conventional insurers provides detailed guidelines on the estimation of assets by considering the different types of risks related. Still, the RBC framework for Takaful operators insufficiently addresses the risk that relevant to Takaful operator’s activities. The main point that distinguishes Takaful operators and its counterparts is in terms of the sharing of risk with customers.

Does Regulation Matter? Riskiness and Procyclicality in Pension Asset Allocation

In this paper, we investigate the relative importance of drivers to pension funds’ asset allocation choices. We specifically test if the contrast between regulatory approaches of public and private Defined Benefits (DB) pension funds in the US, Canada and the Netherlands have an impact on the riskiness and procyclicality of their asset allocation. Derived from panel data analysis of a unique database comprising of more than 800 pension funds’ detailed asset allocations, our results underscore the economic importance of regulation in the funds’ asset allocation choices, relative to institutional and individual funds’ characteristics. In particular, quantitative risk-based capital requirements, and to a lesser extent valuation and funding requirements (i.e., the choice of the liability discount rate) or the presence of quantitative investment restrictions, induce pension funds to significantly decrease their asset allocation to risky assets, especially to equities. Allocation to alternatives, which are comparatively treated quite favorably by solvency standards, is higher in the presence of risk-based capital requirements. Contrary to popular conviction that regulatory mechanisms encourage procyclical asset allocation, we find that funds subject to risk-based capital requirements were likely to be less procyclical during the last crisis – an outcome possibly tempered by temporary regulatory slackening in response to the crisis.

Capital requirements or pricing constraints?

Purpose – This paper aims to investigate the interaction between capital requirements and pricing constraints as measures for insurance regulation. Design/methodology/approach – In a theoretical model framework, the author derives the insurer’s shareholder-value-maximizing response to capital regulation, price regulation and the unregulated strategy as a benchmark; all three strategies are presented in an analytical form. Findings – The paper demonstrates that risk-based capital requirements exhibit an efficiency advantage over price regulation and allow for lower premiums. Moreover, the analysis identifies situations in which price floors make insurance more expensive, but have no positive impact on the safety level. Practical implications – The comparison between capital regulation and price floors provides policymakers with a methodology to evaluate which regulatory tool is more appropriate. Also, the article discusses that maximum discount rates for European life insurers could be ineffective when the new regulatory framework Solvency II is in place. Originality/value – In all, the article obtains analytical and informative results with relevant implications for insurance regulation.

Optimal Investment Strategies for Insurance Companies when Capital Requirements are Imposed by a Standard Formula

The Solvency II standard formula employs an approximate value-at-risk approach to define risk-based capital requirements. This paper investigates how the standard formula’s stock risk calibration influences the equity position and investment strategy of a shareholder-value-maximising insurer with limited liability. The capital requirement for stock risks is determined by multiplying a regulation-defined stock risk parameter by the value of the insurer’s stock portfolio. Intuitively, a higher stock risk parameter should reduce risky investments as well as insolvency risk. However, we find that the default probability does not necessarily decrease when reducing the investment risk (by increasing the stock risk parameter). We also find that, depending on the precise interaction between assets and liabilities, some insurers will invest conservatively, whereas others will prefer a very risky investment strategy, and a slight change of the stock risk parameter may lead from a conservative to a high-risk asset allocation.