The paper identifies dangers from firms that are too-big or too-interconnected-to-fail, or too-big-to-rescue. Remedies might include a capital/liquidity surcharge, increased trading book capital and living wills.
The FSA today issued a discussion paper (DP) focusing on policy measures to address the problem of systemically important ‘too-big-to-fail’ banks. The paper also examines the trade-offs involved in increasing capital and liquidity requirements, and stresses the need to assess the cumulative impact of multiple reforms. The paper identifies the dangers posed by firms that are seen as too-big or too-interconnected-to-fail, or too-big-to-rescue. It describes the full range of policy options - including the creation of ‘narrow banks’ – in order to provide the basis for an informed debate, but also outlines the position which the FSA is currently proposing in international fora, namely that:
· there is a strong case for applying some form of capital (and perhaps liquidity) surcharge internationally for systemically important banks; surcharges could be proportional to continuous and increasing measures of systemic importance, avoiding the dangers created by specific thresholds of systemic importance;
· a capital surcharge could be combined with an approach to global banking groups which places greater emphasis on the standalone sustainability of national subsidiaries, with overt understanding that home country authorities will not be responsible for the rescue of entire groups. The more groups are organised on this basis, the less the required surcharge at group level might need to be;
· action should be taken to reduce inter-connectedness in wholesale trading markets, with much over-the-counter (OTC) derivative trading moved to central counterparties (CCPs), and with effective collateral and margin call arrangements for bilateral trades which reduce the dangers of strongly pro-cyclical margin call effects;
· reform to trading book capital should significantly increase capital requirements and differentiate more strongly between basic market-making functions which support customer service and riskier trading activities, with a bias for conservatism in relation to the latter;
· systemically important banks should be required to produce recovery and resolution plans (‘living wills’) setting out how operations would be resolved in an orderly fashion. If supervisory examination of these plans reveals serious obstacles to resolution, then steps will need to be taken to reduce or remove them – this could require restructuring certain parts of the group. Restructuring could include clear separation between retail deposit-taking business and businesses involved in proprietary trading activities, with the latter able to fail even if the former were supported in crisis conditions.
The DP also stresses the need to assess the possible cumulative impact of multiple reforms to capital and liquidity regimes now being considered by international standard-setting bodies. It describes the case for significant increases in capital and liquidity requirements to reduce financial instability risks, while recognising the potential implications for lending volumes and the cost of credit intermediation. It considers methodologies which can help inform judgements on the trade-offs involved.
© FSA - Financial Services Authority
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FSA report too-big to fail banks.pdf
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