Does Basel III make sense?

In the past couple of decades the sung mantra for deregulation has been overwhelmingly dominant yet today light touch regulation is shown to increase volatility in growth. With a new era of regulation taking place, perhaps the single most globally important measure is BASEL.  Although BASEL II was never fully fulfilled in the US, BASEL III is now in line to be implemented it’s important to understand the risk management mechanics of this series of regulatory implementations. BASEL aims to recommend to banks how to be solvent by creating a system that evaluates risk based on leverage and the rating of assets. The innovations of  BASEL III is that it introduces a buffer conservation which restricts shareholder compensation if the equity level is too low and a counter cyclical buffer which is an attempt at creating a more dynamic capital requirement which increases if the credit to GDP ratio rises. This is a great step in making BASEL more dynamic but as long as arbitrary static figures exist within it it’s likely to not be efficient.

It’s a romanticised notion that this is actually a policy which would reduce risk by limiting the amount of exposure allowed. However this can also be seen as a transfer of liquidity risk. From a retail banks point of view, the liquidity risk is passed to the citizen as he can now borrow less. The static figures of capital requirements also assume an excessive amount of knowledge as to how many good investments are really available, relying excessively on a top down approach measuring style of how much banks should lend. Additionally limiting leverage based on risk weight actually reduces diversification because it encourages investment in low risk assets as the number of low risk assets has not increased, this reduction in diversification could increase risk in the long run. This system also allows for an excessive amount of leverage if too many low risk assets are used. In the worst case scenario fruitful investment will not be undertaken and in the best case scenario predatory lending will decrease, having imperfect knowledge means at least one of these will occur.

However having risk weights also encourages banks to want to pass on the risks to other bearers who might not be optimal holders. For example holding mortgage-backed securities today on a balance sheet is a very expensive endeavour which encourages the passing of this risk. BASEL could have been the culprit behind the reckless behavior that caused the financial crisis since it indirectly encouraged securitization because of its ability to skip over capital requirements. This goes contrary to an optimal framework because to reduce risk on securitized assets the optimal practice is to keep them with bearers who have the most information about them, and the longer the chain of risk selling, the more fragmented and scarce on information on the product becomes. A more thought out policy would take measures to ensure that the holders of the risk were not too far from the entity whose risk they are holding. A more bottom up approach such as giving regulators guidelines on systemic risk is a much more potent way of controlling it. To boost regulatory performance, there should be incentives such as bonuses based on low systemic risk measurements to ensure there are parties actively pursuing the interest of taxpayers.

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