22 March 2024

IMF's Adrian/Dobler: More Work is Needed to Make Big Banks Resolvable

Last year's turmoil showed that further progress is required in a number of areas to ensure banks aren’t too big to fail. What we’ve learned: Intrusive supervision and early intervention are critical.

Almost a year ago, Credit Suisse, a globally systemic bank with $540 billion in assets and the second-largest Swiss lender, founded in 1856, failed and was sold to UBS. In the United States, Silicon Valley Bank, Signature Bank and First Republic Bank failed at around the same time amid Federal Reserve interest rate hikes to contain inflation. With a combined $440 billion of assets, these were the second, third, and fourth biggest bank resolutions since the Federal Deposit Insurance Corporation was created during the Great Depression.

This banking turmoil represented the most significant test since the global financial crisis of ending too-big-to-fail—whereby a systemic bank can be resolved while preserving financial stability and protecting taxpayers.

So, what’s the verdict? In short, while significant progress has been made, further work is required.

On the one hand, as we note in a recent report, the actions of authorities last year successfully avoided deeper financial turmoil, and the financial soundness indicators for most institutions signal continued resilience. In addition, unlike many of the failures during the global financial crisis, this time significant losses were shared with the shareholders and some creditors of the failed banks.

However, taxpayers were once again on the hook as extensive public support was used to protect more than just the insured depositors of failed banks. Amid a massive creditor run, the Credit Suisse acquisition was backed by a government guarantee and liquidity nearly equal to a quarter of Swiss economic output. While the public support was ultimately recovered, it entailed very significant contingent fiscal risk, and created a larger, more systemic bank. Use of standing resolution powers to transfer ownership of Credit Suisse, after bailing in shareholders and creditors, rather than relying on emergency legislation to effect a merger would have seen Credit Suisse shareholders fully wiped out and potentially less public support extended. We expect to learn more in the coming days when a Swiss report on the too-big-to-fail regime is issued.

In the United States, in addition to easing collateral requirements for liquidity support, the authorities cited systemic concerns to invoke an exception allowing protection of all deposits in two of the failed banks. This significantly increased costs for the deposit insurer which will need to be recouped from the industry over time. Even very large and sophisticated depositors were protected—not just the insured.

What we’ve learned

Intrusive supervision and early intervention are critical. Credit Suisse depositors lost confidence after prolonged governance and risk management failures. In the US, the failed banks pursued risky business strategies with inadequate risk management. Supervisors in both cases should have acted faster and been more assertive and conclusive. Our recent review of supervisory approaches found that the ability and will to act remain critical—and can suffer from unclear mandates or inadequate legal powers, resources, and independence as well as powerful financial sector lobbies. Policymakers need to better empower banking supervisors to act early and with authority if needed.

Even smaller banks can be systemic. Supervisory and resolution authorities should ensure sufficient recovery and resolution planning for the sector. This should include banks that may not be systemic in all circumstances but could be in some. This was a key recommendation of our latest Financial Sector Assessment Program for the US....

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