Will bankers ever learn?

Basel-III capital norms, which bankers oppose, are beneficial for both banks and the economy

Jamie Dimon, the chief executive officer of JP Morgan Chase, is that rare banker who doesn’t hesitate to take on regulators and lawmakers. He was severe in his criticism of the Dodd-Frank Act that led to stricter regulation of banks in the US after the global financial crisis (GFC).

Now, Mr Dimon has trained his guns on the Basel-III “end game” rules for banks planned by American regulators. These are the final rules related to the implementation of the norms widely agreed upon after the GFC. The new rules will mean higher capital requirements for banks. While Mr Dimon may be gutsy in taking on regulators, it doesn’t mean he’s right.

US regulators are proposing several changes in the way capital requirements are determined under Basel-III. They want all banks with assets exceeding $100 billion to use standardised models, instead of internal models, for providing capital for credit risk and operational risk. For market risk, these banks will have to calculate risk-weighted assets using both standardised and model-based approaches and use the higher of the two. In addition, banks will have to reflect unrealised losses or gains on available-for-sale securities. These and other proposals will cause bank capital to increase, and that’s what we need.

Requiring the use of standardised models for risk assessment is a huge shift. In standardised models, risk is assessed based on the average risk experience. Under Basel-II rules, which were in place until Basel-III came into force, the focus was on capturing risks specific to a bank using internal risk-based (IRB) models. Banks that effectively managed risk would end up having a capital requirement lower than that required under standardised models, resulting in a higher return on equity.

Only banks that could demonstrate the robustness of their risk models would qualify for use of the IRB approach. The very fact that a bank had been approved for the use of the IRB approach signalled to the markets its superior prowess in managing risk.

Regulators are now having second thoughts on the use of IRB models. During GFC, it turned out that many of the banks that used IRB models just did not have the necessary capital to cope with losses. In drawing up the Basel-III norms, regulators judged that placing too much reliance on IRB models was unwise. They decided to supplement the earlier capital requirements with a simple leverage ratio, defined as Tier I capital to total assets, of 3 per cent. This translates into a debt-to-equity ratio of 33:1. If this seems an absurdly high level of leverage, remember that banks were even more leveraged earlier.

With the latest Basel-III proposals, American regulators are changing tack. They would rather not rely on banks’ internal models at all. They aim to do away with internal models for credit risk and operational risk and play safe with models for market risk. The Reserve Bank of India (RBI) has been moving towards estimating credit loss based on IRB models. It may now want to revisit the proposition. 

The underlying principle driving the new US proposals is simple enough: For banks, more equity capital is better than less. Mr Dimon opposes the move based on arguments we have been hearing from bankers for years now. Two American academics, Anat Admati and Martin Hellwig, have devoted a whole book to showing up the fallacies in these arguments (The Bankers’ New Clothes).

Mr Dimon says more equity capital will translate into higher lending rates for borrowers. This is based on the premise that equity is costlier than debt, especially when we take the tax shield for debt into account. In banking that is true only because bank debt is hugely under-priced.

Lenders to banks know that a large bank will not be allowed to fail (“too big to fail”) and are willing to lend at a lower rate than would be dictated by the level of debt. There is thus an implicit subsidy received by banks considered “too big to fail”. This is a cost that is borne by the taxpayer. It is only when we ignore this implicit subsidy in bank debt that it appears as cheap as it does today. To ignore this is to pave the way for more bank failures and bailouts by taxpayers.

Mr Dimon also contends that investors find bank stocks unappetising if capital requirements go up and return on equity falls. That is not true either. The share price of a bank is a multiple of the price/earnings ratio (P/E) and earnings per share (EPS). Higher equity requirements tend to cause the EPS to fall but they result in a higher (P/E) ratio as investors perceive banks with higher equity as safer, and re-rate bank stocks with higher equity capital.

Which of the two effects above will dominate? Bankers seem to think it is the (P/E) effect that will dominate and result in higher valuations. What else can explain the fact that the capital adequacy ratios at the best-performing banks have raced far ahead of the regulatory minimum?

In the US, capital adequacy at an International Monetary Fund sample of banks averages over 16 per cent, while the requirement stands at around 11 per cent for most banks and slightly higher at 16-17 per cent for very few large banks. The averages in the UK, Switzerland and Sweden are 22, 20, and 23 per cent, respectively. In India, private banks operate at a capital adequacy of 19 per cent, even though the regulatory requirement is just 12 per cent. If higher capital is going to cheese off investors, how do we explain the fact that banks with higher capital than average also command the highest valuations?

Bankers must be aware of this, so why do they set up a howl every time the regulatory requirement goes up? One explanation put forward is that bankers are paid bonuses based on return on equity. The solution, then, is for boards to change the metric for performance awards from return on equity to return on risk-adjusted capital. Allowing a high level of debt so as to show higher return on equity is certainly not the solution.

The regulatory trend is in the direction of increasing capital requirements for banks. That is good for both banks and the economy. The question is: Will bankers ever gracefully accept this reality?

ttrammohan28@gmail.com