Basel
ii and Financial Conglomerates
Welcome to the May 2010 edition of the
Basel ii Compliance Professionals Association (BCPA)
newsletter
Dear
Members,
There
is a major problem with the
differentiated nature of financial regulation in the
international banking, insurance, and securities
sectors.
There are important
gaps
arising from the scope of financial regulation as it relates to
different financial activities, with a particular
focus on certain unregulated or lightly regulated
entities or activities.
Some conglomerates are very large
and global in their operations, and are undoubtedly of
systemic importance. Their failure would clearly pose
considerable challenges.
These groups should be subjected
to an acceptable level of global consolidated
supervision. Are they?
Today
we will study a very interesting paper:
Basel Committee on Banking
Supervision, The Joint Forum: Review of the
Differentiated Nature and Scope of Financial
Regulation,
Key
Issues and Recommendations (January 2010)
Review of the Differentiated Nature and Scope of
Financial Regulation
Executive Summary
I. Introduction
This report analyses key issues arising from the
differentiated nature of financial
regulation in the international banking, insurance, and
securities sectors.
It also addresses gaps
arising from the scope of financial regulation as it relates to
different financial activities, with a
particular focus on certain unregulated or lightly regulated
entities or activities.
The Joint Forum prepared
this report at the
request of the G-20
to help identify potential areas where systemic risks may not be
fully captured in the current regulatory framework and to make
recommendations on needed improvements to strengthen regulation
of the financial system.
The Joint Forum presents its
findings in five key issue areas:
•
Key regulatory differences across
the banking, insurance, and securities sectors;
•
Supervision and regulation of financial groups;
•
Mortgage origination;
• Hedge funds;
• Credit risk
transfer products (focusing on credit default swaps and
financial guarantee insurance).
The Joint Forum
focused on these areas because they help shed light on some of
the major sources of systemic risk that emerged from the current
financial crisis.
Unless action is taken, these issues
may continue to pose systemic risk to the
financial system and the global economy.
The Joint
Forum analysed problems that sometimes extend beyond or cut
across the scope of existing regulation of the banking,
insurance, and securities sectors.
The Joint Forum’s
goal was to analyse the key issue areas, identify gaps, and
produce recommendations to address these gaps and bolster
regulatory frameworks over the long term.
The
recommendations are supplemented with policy options when
consensus could not be reached.
This report
is
part of a global effort to reform and
strengthen financial regulation by the G-20 Leaders and
co-ordinated by the Financial Stability Board (FSB).
The Joint Forum’s parent committees - the Basel Committee on
Banking Supervision (BCBS), the International Organization of
Securities Commissions (IOSCO), and the International
Association of Insurance Supervisors (IAIS) - have initiated and
conducted several other projects aimed at strengthening
financial regulation and notably at redefining its scope.
Given the Joint Forum’s cross-sectoral perspective, this
report has taken into account all of the analyses and
recommendations from these initiatives, as well as other
authoritative research.
Additionally, the Joint Forum
notes that global policy initiatives aimed at reducing the
impact of future crises are resulting in increased prudential
requirements on regulated entities.
Paradoxically, these
concerted efforts could result in an undesired effect, that is,
providing incentives to operate outside the traditional
boundaries of supervision and regulation for the three sectors.
II. Mandate
At their 15 November 2008 meeting, the
G-20 Leaders called for a review of the differentiated nature
and scope of regulation in the banking, securities, and
insurance sectors.
This report responds to the
following declaration:
“The appropriate bodies
should review the differentiated nature of
regulation in the banking, securities, and insurance
sectors and provide a report outlining the issue and making
recommendations on needed improvements.
A review of the
scope of financial regulation, with a special emphasis on
institutions, instruments, and markets that are currently
unregulated, along with ensuring that all systemically-important
institutions are appropriately regulated, should also be
undertaken.”
In its 25 March 2009 report on Enhancing
Sound Regulation and Strengthening Transparency, the G-20 stated
the following:
“The Joint Forum, a Working Group of the
BCBS, IOSCO and the IAIS, is undertaking a project that
addresses the differentiated nature and scope of financial
regulation.
The main objective of this project is to
identify areas where systemic risks may not be fully captured in
the current regulatory framework.
Special emphasis will
be placed on institutions, instruments, and markets that are
currently unregulated or lightly regulated.
As
appropriate, the Joint Forum will leverage off current work from
other international bodies in its assessment.”
III. Focus and guiding principles of this study
In light of the breadth and short time frame of this
mandate, the Joint Forum took a focused approach for identifying
and analysing key issue areas and gaps.
Drawing
primarily on previous Joint Forum analyses,
the Joint Forum
first analysed the differentiated nature of financial regulation
by comparing key differences in existing international
regulation across the banking, insurance, and securities
sectors.
The Joint Forum also focused on areas that
correspond to immediate and well known gaps in supervision and
regulation, have a strong cross-sectoral dimension, have been
addressed by Joint Forum analyses of similar issue areas, and
would benefit from a mix of different regulatory perspectives.
While the areas the Joint Forum focused on obviously do
not represent all of the existing gaps and differences in
financial supervision and regulation, the either contributed to
the crisis in varying degrees or pose
significant systemic risk.
A. Focus of this study
This report focuses on
five key issue
areas for the following reasons.
1. Key regulatory differences across the
banking, insurance, and securities sectors
International financial regulation is sector specific as
evidenced by the independent development of core principles or
standards in each financial sector.
A sector-specific
approach to supervision comes with the potential for increasing
regulatory gaps, which causes supervisory challenges and
presents opportunities for regulatory arbitrage.
Differences
exist in the nature of financial regulation among the banking,
insurance, and securities sectors.
These differences are
warranted in some cases due to specific attributes of each
financial sector, but, in others, these differences may
contribute to gaps in the regulation of the financial system as
a whole.
One way to understand the differences and
identify the gaps is to compare the core principles for
financial supervision across each sector.
The core
principles reflect characteristics of the respective sector and
the nature of the supervised financial institutions.
They represent the key components and features of the
supervisory and regulatory framework of each financial sector.
These principles, issued independently by the BCBS,
IAIS, and IOSCO, correspond to the minimum requirements for
sound supervision.
This analysis provides insights into
the differentiated nature of regulation across sectors from an
international perspective2 but not into the unregulated sector.
2. Supervision and regulation of financial groups
Financial groups, through networks of legal entities and
structures, offer a wide range of financial services and are
often active across multiple jurisdictions and with multiple
interdependencies.
The financial crisis has shown the significant roles these
financial groups play in the stability of global and local
economies.
Because of their
economic reach and the mix of regulated and unregulated entities
(such as special purpose entities and unregulated holding
companies), financial groups blur the boundaries among the
sectors and present challenges for the application of
sector-specific financial regulation and also for their review
and assessment by supervisors.
3. Mortgage origination
The focus of the role of mortgage products in the financial
crisis has been on the securitisation of mortgage loans or the
sale of securitisations.
This has been addressed in
several international fora, including the Joint Forum and its
parent committees.
Receiving far less attention,
however, is the fundamental building block of sound
securitisation: the quality of underwriting of the component
mortgages.
The
G-20 noted that the
credit quality of loans granted with the intention of
transferring them to other entities through the securitization
process was not adequately assessed.
Therefore,
this report focuses on standards for the origination of mortgage
loans that contribute to sound securitisations and global market
stability.
4. Hedge funds
Hedge funds, especially the largest of them,
could have a systemic impact on financial
stability.
Failure in particular of
a large,
highly leveraged hedge fund might not only impact its investors,
but also financial institutions and markets.
Yet
hedge funds are perceived as largely unregulated because they,
like individual investors, typically do not have legal or
regulatory investment restrictions, although their operators are
regulated in many countries.
While the
possible
contribution of hedge funds to the financial crisis is still a
subject of debate, the Joint Forum agreed that the lack of a
consistent prudential regime for monitoring and assessing hedge
funds is a critical gap in the regulatory framework.
5. Credit risk transfer products
Credit default swaps and financial
guarantee insurance products transfer risks within but also
outside the regulated sectors.
There is broad
agreement that these products should be subject to sound
counterparty credit risk management and that more transparency
is needed.
This report focuses on areas not already
specifically addressed by other fora and on areas where
additional input on previous recommendations would be
beneficial.
This report also consolidates and emphasises
recommendations that have been made in other fora.
B. Guiding principles of this study
The broad mandate led to analysis of a diverse and large
range of issues.
Consequently, some recommendations and
policy options are aimed at supervisors while others target more
generally policymakers.
In developing these
recommendations and policy options, the Joint Forum applied
certain guiding principles that reflect general views about the
nature of financial regulation and, to a great extent, echo
general recommendations made by the G-20.
Articulating
these principles helps ensure that these recommendations are
designed for the long term.
•
Similar activities, products, and markets should be subject to
similar minimum supervision and regulation.
• Consistency
in regulation across sectors is necessary; however, legitimate
differences can exist across the three sectors.
•
Supervision and regulation should consider the risks posed,
particularly any systemic risk, which may arise not only in
large financial institutions but also through interactions and
interconnectedness among institutions of all sizes.
•
Consistent implementation of international standards is critical
to avoid competitive issues and regulatory arbitrage.
Because of the dynamic, changing nature of the global
financial system, the scope of financial regulation must be
continuously monitored and reviewed.
IV. Key issues and gaps
The following
summarises the
findings and observations in the five areas reviewed.
A. Key regulatory differences across the
banking, insurance, and securities sectors
To undertake the review of the differentiated nature of
existing regulation in the banking, securities, and insurance
sectors, the Joint Forum focused on updating a review of the
respective core principles of supervision in the banking,
insurance, and securities sectors conducted in 2001.
The
core principles reflect the main characteristics of the
respective sector and the nature of the financial institutions
supervised under each framework.
The purpose of such
comparsion was to
identify common
principles and understanding differences when they arise.
Despite different formats, content and language used, the
core principles review revealed substantial commonalities across
sectors.
Indeed, differences among each sector’s core
principles have been decreasing slightly over time, reflecting
the converging nature of the business in the three sectors.
Furthermore, some of the existing differences among the core
principles are warranted as they reflect - at least in part -
intrinsic characteristics of the banking, insurance, and
securities
sectors.
Examples of
these intrinsic differences include the following ones:
• There are many unique aspects in
securities regulation reflecting the broader scope of securities
supervisors.
The IOSCO core principles therefore encompass not only
the regulation and supervision of securities firms, but also
that of markets, exchanges, collective investment schemes, and
disclosure by issuers.
This broader scope of the IOSCO
core principles reflects unique and intrinsic aspects of
securities regulation and supervision. Core principles in the
banking and insurance sectors describe only the framework needed
to supervise financial institutions, not markets.
• Differences in the nature of the businesses being conducted by
firms within each sector also explain and justify some
fundamental differences in the nature of their regulation.
An example of this differentiated nature of businesses
of firms across sectors is the key role assigned to technical
provisions by insurance regulation, but not by banking and
securities regulation.
Insurance companies offer protection against uncertain future
events.
As a consequence, much regulatory and
supervisory effort in the insurance sector is directed towards
the valuation of technical provisions as they are estimations of
the cost of future liabilities.
However, as already noted
by the Joint Forum in 20018, key differences remain among the
regulatory frameworks of the banking, securities, and insurance
sectors that have no objective justification.
Furthermore,
the relevance of some of
these differences has been emphasised by the financial crisis,
as noted by the G-20 in its report on Enhancing Sound Regulation
and Strengthening Transparency.
As a general and
overarching matter, the Joint Forum believes that there is room
for greater consistency among each sector’s core principles, as
well as the standards and rules applied to similar activities
conducted in different sectors.
Such improvements would
reduce opportunities for regulatory arbitrage and contribute to
greater efficiency and stability in the global financial system.
Also, the financial crisis evidenced the lack of a
coordinated approach to assess the implications of systemic
risks and of the necessary policy options to address them.
The core principles for each sector should appropriately
reflect the extent to which systemic risk and financial
stability play a role in the development of supervisory policies
and approaches.
More specifically, despite exposures to
common risk factors and growing interactions and risk transfer
across the three sectors, there are areas treated differently
for the purposes of prudential regulation of financial firms
under each sector’s supervisory system:
•
This is notably the case with regard to the supervision and
regulation of financial groups.
The emphasis placed on supervision on a group-wide basis
varies dramatically and the principle is applied in very
different ways in the three sectors.
While the Basel
framework has always placed much focus on consolidated
supervision, the IAIS only started requiring group-wide
supervision (in addition to supervision of individual entities)
in 2003.
IOSCO’s core principles do not require
securities firms to be supervised on a group-wide basis.
•
Differences exist regarding a global uniform capital framework
within each sector.
A uniform framework exists only in the banking sector,
whereas different frameworks still coexist within securities and
the insurance sectors at the international level.
•
Prudential regulations across sectors also remain largely
different from both a conceptual and a technical point of view.
Although these largely reflect significant differences in
underlying business activities, some of these differences create
supervisory challenges as well as opportunities for regulatory
arbitrage.
•
The extent to which regulation of the different sectors deal
with business conduct and consumer or investor protection also
vary.
The Joint Forum believes that addressing these
inconsistencies in supervisory frameworks across the banking,
securities, and insurance sectors is necessary in order to
ensure a sounder financial system in the future.
In
addition to considering the legal or regulatory framework for
evaluating differences in prudential regulation across sectors,
it is also important to consider how supervisors implement these
regulations.
Differences at the implementation level are
important as they may impede fair and effective supervision and
assessment of the financial sector in general.
Although
how supervisors implement regulations was beyond the scope of
this work, the Joint Forum wishes to emphasise that partial or
inconsistent implementation of even nearidentical prudential
regulation can result in significant differences in practice.
B. Supervision and regulation of financial groups
Financial groups play a significant economic role but can
threaten financial stability at local and global levels.
Governments, supervisors, and central banks have
struggled to evaluate the risks of
financial groups and have incurred significant costs in
mitigating the potential impact of financial groups on financial
stability.
Financial groups
offer
services in banking, securities, insurance, or a combination of
these services.
This mix blurs the traditional
supervisory and regulatory boundaries among the sectors.
Moreover, these groups rely on a network of legal entities
and structures (some of them unregulated) to derive synergies
and cost savings and to take advantage of differences in
taxation, supervision, and regulation.
This report
focuses on differences in the treatment of:
•
Unregulated entities when calculating group capital adequacy.
The differences in how a financial group is defined, in
how entities are included for calculations, and in the methods
for calculating group capital adequacy create problems for
supervisors in assessing the risks of a financial group, the
capital adequacy of the group, and implications for regulated
entities within the group.
These differences create gaps
when unregulated entities are used to lower capital requirements
of individual regulated entities, to reduce group capital
adequacy requirements, and to blur the distinction among
sectors.
This can encourage the creation of group
structures that are complex, opaque, and interdependent.
•
Intra-group transactions and exposures (ITEs), including those
involving unregulated entities.
ITEs allow a financial group to coordinate its
businesses across its legal structure.
ITEs can create
contagion and unintended risks across the group and/or
individual legal entities within the group, as shown by the
failure of Lehman Brothers.
The differences in
approaches to supervision and regulation of ITEs can make it
difficult for supervisors to assess the risks to the
sustainability of the business models of the group and its legal
entities.
•
Unregulated entities, particularly unregulated parent companies
of regulated entities.
Differences can create loopholes for financial groups to
establish unregulated parent holding companies that end up
controlling regulated entities from a completely separate
jurisdiction.
The unregulated parent holding company’s
jurisdiction may not have related regulated entities or not have
legal authority to exercise power or oversight over unregulated
entities.
This
hinders
supervision.
The unregulated parent holding
company is under no obligation to provide information to
unrelated third parties, such as foreign supervisors, and is not
required to produce the information in a meaningful way.
Existing protocols for obtaining and sharing critical
information do not address unregulated entities that are higher
in the organisational hierarchy of ownership.
These
differences help create situations in which regulatory
requirements and oversight do not fully capture all the
activities of financial groups or the impact and cost that these
activities may impose on the financial system.
Thus,
there is a need to consider regulatory reforms to address, where
appropriate, these differences.
Meanwhile, supervisors
need to monitor the risks that these differences can create and
ensure that they are managed by regulated entities.
C. Mortgage origination
Until 2007, this decade was characterised by relatively
strong economic growth, low interest rates in many
jurisdictions, an abundance of liquidity, and increased lending
to consumers.
In a number of countries, housing and
mortgage markets expanded dramatically, and there was rapid
expansion in the variety and number of mortgage products and in
related securitisation.
Lack of
discipline by market participants in several jurisdictions was
notable during this boom period.
When housing
price bubbles were suspected, it was not clear at what point a
systemwide response would be needed, especially given the
positive macroeconomic effect of increasing home values and
homeownership.
This evaluation was further complicated
by rising home values masking a number of poor underwriting
practices, particularly those designed to lower initial monthly
payments.
In several countries that experienced a surge
in mortgage lending and housing growth, most notably the United
States and the United Kingdom, lenders developed new, riskier
products that made use of relaxed product terms, liberal
underwriting, and increased lending to highrisk populations.
These developments eventually resulted in significant losses
for consumers and financial institutions alike.
However,
many other countries with sophisticated mortgage markets have
not experienced a significant degree of distress and some
countries did not experience such growth, for example, Germany
and Canada.
This report focuses on two fundamental areas
of concern:
•
Poor mortgage underwriting practices.
Problems arising from poorly underwritten residential mortgages
in certain countries contributed significantly to the global
financial crisis; indeed, the securitisation and other
structured financing of these mortgage loans
-
which
were purchased by a number of international financial firms
- spread the problems of their poor underwriting to the
banking, securities, and insurance sectors globally.
In
contrast, prudent practices and sound and comprehensive policies
may have prevented market participants in those countries that
have not experienced a significant degree of distress from
engaging in the less disciplined underwriting behaviour that was
endemic in other, more troubled mortgage markets.
•
Mortgage originators subject to differing supervision,
regulation, and enforcement regimes for similar
activities/products.
Like most aspects of the mortgage industry, the
prevalence, role, and supervision of nonbank credit
intermediaries varies greatly across the various mortgage
markets.
Mortgage originators range from the smallest
individual mortgage brokers to large international lenders.
They include lenders that provide warehousing lines to fund
loans on an interim basis, those that structure securitisations
and market securities, and central banks and
government-sponsored enterprises that essentially make markets
in mortgage loans.
In some cases, the government closely
controls the mortgage market through explicit guarantees for the
full balance of the loan, while in others involvement is
limited.
The number of participants, the variety of roles they
play, and the differences among countries are substantial,
particularly given the patchwork approach to the regulatory
framework in many countries.
Such differences created
regulatory gaps that helped erode prudent mortgage underwriting
practices.
D. Hedge funds
Debates continue over whether and to what extent hedge funds
may have contributed to - or mitigated - the expansion of the
financial crisis.
Some argue that hedge funds increased
stress on liquidity in the financial markets in fall 2008, while
others argue that hedge funds generally reduce the likelihood
and prevalence of asset bubbles given the strategies hedge funds
use.
There is, however, general consensus that hedge
funds, given their role in the economy,
may have a systemic impact.
The analysis for this
report focuses on four areas of concern.
•
Internal organisation, risk management, and measurement.
Failures in risk management by hedge fund managers can
cause problems for markets and are a matter of cross-border and
cross-sectoral concern.
Yet there is no common or
cross-border understanding of or requirements for how funds are
organised or how fund risks are managed and measured.
•
Reporting requirements and international supervisory
cooperation.
The risks posed by hedge funds cannot be easily measured
by supervisors or investors because funds are not required to
fully disclose their activities.
The limited disclosure
rules that funds do face vary by jurisdiction and information
collected is not shared by supervisors for hedge funds operating
across borders.
•
Minimum initial and ongoing capital requirements for
systemically relevant fund operators.
Adequate financial reserves are needed to help fund
operators withstand the operational risks they incur, ensure
their orderly dissolution, and minimize potential harm to the
financial system.
Not all supervisors require such fund
operators to meet even minimum capital requirements.
•
Procyclicality and leverage-related risks posed by the pool of
assets.
The use of leverage allows funds to magnify potential
returns but also the exposures, and, consequently, the risks for
not only fund investors, but also the financial system itself.
Supervisors do not constrain the use of leverage by
funds.
E. Credit risk transfer products
One of the factors contributing to the crisis was the
inadequate management of risks associated with various types of
products designed to transfer credit risk.
This
resulted
in
severe losses for some institutions.
These products transfer risks within and outside
the regulated sectors.
This report focuses on two credit
risk transfer products that were evidenced to contribute to
major gaps in market practices or effective regulation: credit
default swaps and financial guarantee insurance.
Credit default swaps (CDS) and financial
guarantee (FG) insurance are products that provide protection
against identified credit exposures.
Because the
provider of that protection may have to make payments based on
the performance of the underlying credit, these products create
new sources of credit exposure.
Buyers of credit
protection, therefore, need to maintain and enforce sound
counterparty credit risk management practices with respect to
credit protection providers.
While CDS and FG insurance
products have quite different legal structures, they perform
similar economic functions.
The analysis identified the
following issues as common to both the CDS and FG insurance
markets. Each contributed to the recent
crisis or poses crosssectoral systemic risk.
•
Inadequate risk governance:
Sellers of credit protection did not, and often could not (given
their existing risk management infrastructure) adequately
measure the potential losses on their credit risk transfer
activities.
This was generally true in the CDS market
and to a lesser extent in the regulated FG insurance market
(where there is at least some financial reporting required by
statute).
Buyers of protection did not properly assess
sellers’ ability to perform under the contracts, and they
permitted imprudent concentrations of credit exposures to
uncollateralised counterparties.
•
Inadequate risk management practices:
Poor management of large counterparty credit risk exposures with
CDS and FG insurance transactions contributed to financial
instability and eroded market confidence.
CDS dealers
ramped up their portfolios beyond the capacity of their
operational infrastructures.
•
Insufficient use of collateral:
The absence of collateral posting requirements for highly rated
protection sellers (eg AAA-rated monoline firms) allowed those
firms to amass portfolios of over-the-counter derivatives, and
FG insurance contracts - and thus create for their
counterparties excessive credit exposures - far larger and with
more risk than would have been the case had they been subject to
normal market standards that required collateral posting.
•
Lack of transparency:
The lack of transparency in the CDS and to a lesser extent in
the FG insurance markets made it difficult for supervisors and
other market participants to understand the extent to which
credit risk was concentrated at individual firms and across the
financial system.
Market participants could not gauge
the level of credit risk assumed by both buyers and sellers of
credit protection.
•
Vulnerable market infrastructure:
The concentration of credit risk transfer products in a small
number of market participants created a situation in which the
failure of one systemically important firm raised the
probability of the failure of others.
Separately, this
report addresses key issues and gaps specific to CDS products.
They are
largely unregulated
although their use is subject to supervision and regulation when
protection buyers and sellers are regulated institutions.
To the extent that unregulated entities, such as special
purpose entities, are major participants in CDS markets, this
may be perceived as a gap in existing supervision and
regulation.
For example, even if regulated firms are
subject to capital requirements for risks arising from their CDS
exposures, systemically important unregulated firms are not
subject to comparable requirements, and this may pose a systemic
risk.
There also are concerns about potential weaknesses
in the market infrastructure for CDS products because they are
typically traded over-the-counter.
Operational risks can
be exacerbated by weaknesses in market infrastructure.
Finally, there are key issues and gaps specific to FG insurance
products.
The number of FG insurers worldwide is small,
but they operate across international boundaries and the
regulation of these insurers varies considerably across
jurisdictions.
In recent years, FG insurers increased
their risk appetites and expanded into asset-backed securities,
including collateralised debt obligations, as well as subprime
mortgage-backed securities.
Insurers also established
minimally capitalised special purpose entities, which sold CDS
products that were not legally permitted within the main FG
insurance business.
Accounting practices, capital and
liquidity, the role of credit rating agencies, use of special
purpose entities, and knock-on effects pose cross-sectoral
and/or systemic impact as the economic validity of the business
model and design of these products remains in question.
To read more:
www.financial-conglomerates-directive.com/Conglomerate_1.htm
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