US Basel III Final Rule on banks’ capital requirements: A different-size-fits-all approach
DOI:
https://doi.org/10.13133/2037-3643/11541Keywords:
US Basel III Final Rule, CRR/CRDIV, capital requirements, leverage ratio, one-size-fits-all, community banks, systemic banksAbstract
The US Basel III Final Rule was issued by the Banking Agencies (Fed, OCC and FDIC) in July 2013. The Rule implements the international Basel III framework defined by the Basel Committee on Banking Supervision and represents a major overhaul of the US banks’ capital requirements, since the adoption of Basel I in 1992. The Rule incorporates provisions contained in the Dodd-Frank Act (2010). The purpose of this note is to highlight some key specific features of the US standard. In particular, it is argued that the US Rule introduces, de facto, a modular approach according to size and complexity and places great emphasis on leverage requirements for systemic banks, to avoid a mere backstop character of the non-risk-based capital ratios. These two features stand in contrast with the EU transposition of Basel III (CRR/CADIV).
JEL codes: G21, G28
References
ADMATI A. and HELLWIG M. (2013), The Bankers’ New Clothes: What’s Wrong with Banking and What to Do About It, Princeton: Princeton University Press.
BASEL COMMITTEE ON BANKING SUPERVISION (BCBS) (2013), “Revised Basel III Leverage Ratio Framework and Disclosure Requirements”, Consultative Document, Basel: Bank for International Settlements.
BASEL COMMITTEE ON BANKING SUPERVISION (BCBS) (2013). “The Regulatory Framework: Balancing Risk Sensitivity, Simplicity and Comparability”, Discussion Paper, Basel: Bank for International Settlements.
BLUNDELL-WIGNALL A. and ATKINSON P. (2011), “Global SIFIs, Derivatives and Financial Stability”, OECD Journal: Financial Market Trends, vol. 2011 n. 1, pp. 167-200.
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM, FEDERAL DEPOSIT INSURANCE CORPORATION and OFFICE OF THE COMPTROLLER OF THE CURRENCY (2013), New Capital Rule Community Bank Guide, July, Washington (DC).
CHOULET C. (2013), “Basel 3 in the United States: A Work in Progress?”, ECO Conjoncture, BNP Paribas, Paris, March.
COUNCIL OF THE EUROPEAN UNION (2013), “Council agrees position on bank resolution”, Press release, n. 11228/13 PRESSE 270, 27 June, Brussels.
DEPARTMENT OF THE US TREASURY and FEDERAL RESERVE SYSTEM (2013), Regulatory Capital Rules: Regulatory Capital, Implementation of Basel III, Capital Adequacy, Transition Provisions, Prompt Corrective Action, Standardized Approach for Risk-weighted Assets, Market Discipline and Disclosure Requirements, Advanced Approaches Risk-Based Capital Rule, and Market Risk Capital Rule. Final Rule, July 9, Washington (DC).
EUROPEAN COMMISSION (2013), “Capital Requirements – CRD IV/CRR – Frequently Asked Questions”, MEMO/13/690, July 16, Brussels.
EUROPEAN COMMISSION (2013), A Recovery on the Horizon? Final Report. Annual Report on European SMEs 2012/2013, October, Brussels.
EUROPEAN COMMISSION, ECORYS (2012), EU SMEs in 2012 at the crossroad, September, Rotterdam.
FEDERAL DEPOSITS INSURANCE CORPORATION (FDIC) (2012), FDIC Community Banking Study, December, Washington (DC).
EUROPEAN PARLIAMENT and EUROPEAN COUNCIL (2013), DIRECTIVE 2013/36/EU of 26 June 2013 on Access to the Activity of Credit Institutions and the Prudential Supervision of Credit Institutions and Investment Firms, Amending Directive 2002/87/EC and Repealing Directives 2006/48/EC and 2006/49/EC Text with EEA Relevance (CRDIV), Brussels.
EUROPEAN PARLIAMENT and EUROPEAN COUNCIL (2013), Council Regulation (EU) n. 1024/2013 of 15 October 2013 Conferring Specific Tasks on the European Central Bank Concerning Policies Relating to the Prudential Supervision of Credit Institutions, Brussels.
EUROPEAN PARLIAMENT and EUROPEAN COUNCIL (2013), Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL Establishing a Framework for the Recovery and Resolution of Credit Institutions and Investment Firms and Amending Council Directives 77/91/EEC and 82/891/EC, Directives 2001/24/EC, 2002/47/EC, 2004/25/EC, 2005/56/EC, 2007/36/EC and 2011/35/EC and Regulation (EU) No 1093/2010, Brussels.
EUROPEAN PARLIAMENT and EUROPEAN COUNCIL (2013), REGULATION (EU) N. 575/2013 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 26 June 2013 on Prudential Requirements for Credit Institutions and Investment Firms and Amending Regulation (EU) N. 648/2012 Text with EEA relevance (CRR), Brussels.
FEDERAL RESERVE SYSTEM (2013), “Agencies Issue Final Rules Implementing the Volcker Rule”, Joint Press Release, Board of Governors of the Federal Reserve System, Commodity Futures Trading Commission, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, Securities and Exchange Commission, December 10, Washington (DC).
FEDERAL RESERVE SYSTEM (2013), “Basel III Final Rule and Notice of Proposed Rulemaking”, Press Release, 9 July, Washington (DC).
GETTER D.E. (2012), U.S. Implementation of the Basel Capital Regulatory Framework, Congressional Research Service, 14 November, Washington (DC).
GOODHART C.A. (2011), “Global Macroeconomic and Financial Supervision: Where Next?”, NBER Working Paper, n. 17682, December.
GRUENBERG M.J. (2013), “FDIC Board Approves Basel III Interim Final Rule and Supplementary Leverage Ratio Notice of Proposed Rulemaking”, Press release, 9 July, Washington (DC).
HALDANE A.G. and MADOUROS V. (2012), “The Dog and the Frisbee”, paper delivered at the Federal Reserve Bank of Kansas City’s 36th economic policy symposium The Changing Policy Landscape, 31 August, Jackson Hole (WY).
HOENIG T. (2012), “Back to Basics: A Better Alternative to Basel Capital Rules”, speech delivered at the American Banker Regulatory Symposium, 14 September, Washington (DC).
HOENIG T. (2013), Statement from FDIC Vice Chairman Hoenig on the use of International Financial Reporting Standards in computing the leverage ratio for systemically important financial institutions, 23 July, Federal Deposits Insurance Corporation, Washington (DC).
LAMANDINI M. (2013) “Il nuovo meccanismo di vigilanza unica europea: i poteri micro e macroprudenziali affidati alla BCE”, presented at the ABI conference Basilea 3, CRDIV e Unione Bancaria. Evoluzione o rivoluzione?, 5 December, Rome.
LIN Y.J. and SUN X. (2011), “Delegated Monitoring and Bank Size Distribution”, mimeo, available at the URL old.ccer.edu.cn/download/7811-1.pdf.
MASERA R. (2012), “Bank Capital Standards: a Critical Review”, LSE Financial Markets Group Paper Series, n. 215, December.
MASERA R. and MAZZONI G. (2011), “Towards a New Architecture for Financial Regulation. Reform of the Risk Capital Standard (RCS) and Systemically Important Financial Institutions (SIFIs)”, in Paganetto L. (ed.), Recovery after the Crisis: Perspective and Policies, Saarbrücken: VDM Verlag Dr. Müller, pp. 82-120.
MASERA R. and MAZZONI G. (2013), “Cost of Equity, Enterprise Value and Capital Regulation of Banking Firms”, SSRN Working Paper, available at the URL http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2189295.
MONTANARO E. (2013), “Regole di Basilea e modelli di vigilanza: quale convergenza?”, Moneta e Credito, vol. 66 n. 264, pp. 415-442.
PRESTI G. (ed.) (2012), Analisi giuridica dell’economia, vol. 2, Il rating. Mito, realtà, narrazioni, Bologna: Il Mulino.
SCHICH S. and LINDH S. (2012), “Implicit Guarantees for Bank Debt: Where Do We Stand?”, OECD Journal: Financial Market Trends, n. 1., pp. 1-22.
TARULLO D.K. (2013), Evaluating Progress in Regulatory Reforms to Promote Financial Stability, Board of Governors of the Federal Reserve System, 3 May, Washington (DC).
TARULLO D.K. (2013), Opening statement, Board of Governors of the Federal Reserve System, 24 October, Washington (DC).
TONVERONACHI M. (2013), “L’Unione Bancaria Europea. Di nuovo un disegno istituzionale incompleto”, Moneta e Credito, vol. 66 n. 264, pp. 397-413.
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