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Underlying principles
The remaining challenges for financial reform fall into three broad groups:
Consistent implementation of what has been agreed
Basel III enhances the regulatory framework introduced by Basel II at the level of individual institutions, and sets up a macro-prudential overlay to limit systemic risk. But agreeing on Basel III is only a first step; the next phase, implementation, is just as critical.
1. Better and more capital and liquidity
Basel III raises the level and quality of capital in the system. Basel III also addresses systemic risk in both of its dimensions, mitigating procyclicality over time, and reducing interconnection and contagion risk across firms and markets. The second central element of Basel III, complementing capital, is liquidity. The new liquidity standard includes a liquidity coverage ratio (LCR) and a net stable funding ratio (NSFR).
2. Monitoring implementation
Full, consistent and timely implementation by national jurisdictions is now at the top of the Basel Committee's agenda. It has started to conduct peer and thematic reviews to help ensure timely and consistent implementation of all elements of the Basel framework.
Completing the regulatory reform agenda
1. Strengthening resolution
The goal of strengthening resolution frameworks is significantly to reduce the possibility that authorities will find themselves forced to bail out institutions in order to prevent costly market disruption. By reducing the impact of failure, we also lessen the expectation of an official bailout, and thereby reduce moral hazard.
2. OTC derivatives markets
3. Shadow banking
A third critical element of the reform agenda is to monitor and, where appropriate, to address the risks posed by the shadow banking system. Shadow banking can perform valuable functions, such as supplying alternative funding for the real economy, and providing banks and investors with the means to manage credit, liquidity and maturity risks. However, as the financial crisis has shown, systemic risk and regulatory arbitrage can build up in the shadow banking system. Therefore, it is important to monitor the evolution of shadow banking and to address the risks it poses.
Proactive oversight of the financial system
Mr Caruana pointed out that writing rules is not enough. Institutions and processes are needed to ensure that the goals of the new regulatory framework are achieved consistently and effectively.
On the one hand, countries are putting in place macro-prudential oversight frameworks that will support and complement reforms at the micro-prudential level. On the other hand, efforts to implement the new rules need to be supported by enhanced supervision of individual banks, including their asset composition and risk management practices. Supervisors must also be alert to the ongoing evolution of the financial system, in order to address the consequences of financial innovation and regulatory arbitrage.