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Basel Ii Implementation in the Midst of Turbulence

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Basel Ii Implementation in the Midst of Turbulence BASEL II IMPLEMENTATION IN THE MIDST OF TURBULENCE BASEL II IMPLEMENTATION IN THE MIDST OF TURBULENCE CHAIRMAN: FREDERIK C. MUSCH FORMER SECRETARY-GENERAL, BCBS CHAIRMAN, GLOBAL FINANCIAL SERVICES REGULATORY PRACTICE PRICEWATERHOUSECOOPERS RAPPORTEUR: RYM AYADI SENIOR RESEARCH FELLOW, CEPS WITH CONTRIBUTIONS FROM: MARIA NIETO, BANK OF SPAIN MATHIAS SCHMIT, SOLVAY BUSINESS SCHOOL CEPS TASK FORCE REPORT JUNE 2008 The Centre for European Policy Studies (CEPS) is an independent policy research institute in Brussels. Its mission is to produce sound policy research leading to constructive solutions to the challenges facing Europe. The views expressed are entirely those of the author. This report is based on discussions in the CEPS Task Force on the Implementation of the New Basel Capital Accord and the Remaining Challenges and was complemented by substantial internal research. The members of the Task Force participated in extensive discussions in the course of several meetings in 2005-06, and submitted comments on earlier drafts of the report. Its contents convey the general tone and direction of the discussions, but its recommendations do not necessarily reflect a common position reached by all members of the Task Force. Nor do they represent the views of the institutions to which the members, the rapporteur and her fellow contributors belong. A list of participants and invited guests and speakers appears in the final appendix at the end of this report. The rapporteur of the Task Force is Dr Rym Ayadi, Senior Research Fellow and Head of the Financial Institutions and Prudential Policy research unit at CEPS. She wishes to thank Maria Nieto and Mathias Schmit for their valuable written contributions to the Task Force Report, Frederik C. Musch for chairing the meetings, Karel Lannoo for his recommendations to improve the final draft and all the members of the Task Force for their helpful remarks and suggestions. ISBN 978-92-9079-628-2 © Copyright 2008, Centre for European Policy Studies. All rights reserved. No part of this publication may be reproduced, stored in a retrieval system or transmitted in any form or by any means – electronic, mechanical, photocopying, recording or otherwise – without the prior permission of the Centre for European Policy Studies. Centre for European Policy Studies Place du Congrès 1, B-1000 Brussels Tel: (32.2) 229.39.11 Fax: (32.2) 219.41.51 E-mail: [email protected] Contents Preface.......................................................................................................................i Executive Summary & Policy Recommendations..............................................1 Introduction.............................................................................................................7 1. What is behind the new Basel capital framework?......................................10 1.1 Capital requirements an essential regulatory tool...........................10 1.2 Basel I: A first step towards capital regulation….............................16 1.3 An integrated view of Basel II’s three pillar approach....................20 1.4 Conclusions ...........................................................................................47 2. What are the likely impacts of risk-sensitive capital requirements?.........49 2.1 An overall decrease of capital requirements in benign market conditions ..............................................................................................49 2.2 How reliable are the QIS5 results?.....................................................56 2.3 Conclusions ...........................................................................................58 3. What are the building blocks of implementating Basel II in Europe? ......62 3.1 A form of Basel II adapted to the European context .......................63 3.2 A strengthened role for the European Parliament...........................67 3.3 A multicephalic implementation process..........................................69 3.4 Supervisory consistency and convergence .......................................81 3.5 Conclusions ...........................................................................................92 4. Will Basel II be implemented consistently across the globe? .....................94 4.1 A challenging role for the AIG ...........................................................95 4.2 Uncertainty delaying timely implementation in the US….............99 4.3 Conclusions .........................................................................................107 Postscript .............................................................................................................109 Glossary ...............................................................................................................112 References............................................................................................................114 Appendix 1. Impact of the recent market turbulence on selected banks....121 Appendix 2. Basel II: Overview of strengths and remaining concerns ......124 Appendix 3. Fundamental differences betweenBasel II and the CRD........126 Appendix 4. The Lamfalussy approach ..........................................................131 Appendix 5. Task Force Members & Invited Guests and Speakers ............132 List of Figures Figure 1. A comprehensive overview of the new Basel framework..............23 Figure 2. IRB risk weights across asset classes .................................................28 Figure 3. Cash securitisation ...............................................................................29 Figure 4. Synthetic securitisation........................................................................29 Figure 5. An integrated view of Basel II’s 3 pillars ..........................................45 Figure 6. Layers of the decision-making process for transposing the CRD in Europe ...............................................................................69 Figure 7. Links between the ICAAP and SREP ................................................47 Figure 8. The main players involved in the finalisation of the NPR ...........100 List of Tables Table 1. Regulatory capital in selected countries in 2005................................17 Table 2. History of the Basel II process..............................................................21 Table 3. Changes in the MRC relative to the current Accord (in %). ............51 Table 4. MRC contribution under the most likely IRB approach relative to the current Accord, by portfolio (in %)...........................53 Table 5. The legislative texts of the CRD (June 2006) ......................................70 Table 6. Volume of queries to the CRD Transposition Group (up to April 2008) .................................................................................71 Table 7. Standards and guidelines produced by CEBS ...................................73 Table 8. Areas of discretion for national authorities........................................77 Table 9. Transitory measures ..............................................................................78 Table 10. Countries intending to adopt Basel II that are not members of the BCBS............................................................................................98 Table 11. Basel II Accord and US implementation timelines........................103 List of Boxes Box 1.What is capital in a regulatory context?..................................................12 Box 2. What is economic capital?........................................................................19 Box 3. The capital ratio under Basel II ...............................................................23 Box 4. US definition of default in relation to the Basel II Accord ..................59 PREFACE his Task Force report on the implementation of Basel II is the second report prepared by the Centre for European Policy Studies (CEPS) in T parallel with the Basel II process. As with the previous Task Force, the meetings generated lively debates on many issues by well-informed presenters and participants from the financial industry, academia, central banks and regulators, from both Europe and the US. It is again thanks to Dr Rym Ayadi, Senior Research Fellow and Head of the Financial Institutions and Prudential Policy Unit at CEPS who acted as rapporteur, and to enthusiastic contributions from Maria Nieto, Advisor at the Bank of Spain, and Mathias Schmit, Professor at the Solvay Business School, that this new report – combining the many, sometimes conflicting views – is here before us. The report was close to finalisation when the first effects of the subprime turmoil began to be felt in the summer of 2007. At that stage, Task Force members agreed that many issues were close to resolution. However, they felt that further work by both supervisors and bankers was needed to address some key questions, namely: • How can further evolution towards fully integrated risk-management practices be encouraged? • How can more consistency and clarity be provided on supervisory expectations and practices under pillar 2? • How can it be ensured that disclosures, while aligned with International Financial Reporting Standards, also provide significant and essential information to both counterparties and the public? • How can timely implementation be facilitated in order to enhance the level playing field? | i ii | PREFACE As we all know, the subprime crisis spread quickly to Europe from the US. At first, many considered
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