Financial market pressure as an impediment to the usability of regulatory capital buffers
Yet, banks may be unwilling to use their capital buffers, constraining the effectiveness of the measures.
- Yet, banks may be unwilling to use their capital buffers, constraining the effectiveness of the measures.
- Indeed, banks did not fully reflect the capital relief measures in the target CET1 ratio they announce to investors.
- So far, these policies have alleviated the need to reduce capital targets, while still being able to accommodate loan demand.
1 Introduction
- All of these measures were aimed at avoiding a procyclical decline in bank lending to the private sector, which could further weaken macroeconomic dynamics.
- The effectiveness of these measures critically hinges on banks willingness to adapt their internal capital planning to the temporary regulatory changes.
- Such behaviour would indicate that the released buffers are (at least partly) usable to absorb losses without triggering deleveraging pressure.
- Market discipline in general is essential for financial stability and helps to avoid excessive leverage in the banking sector.
- Against this background, this article provides empirical evidence that market pressure is an impediment to the usability of regulatory capital buffers.
- The second part explores the impact of capital ratios on banks access to funding markets.
2 Did banks lower their target capital ratios as a consequence of regulatory capital buffer releases?
- Banks typically choose to maintain a management capital buffer on top of the regulatory capital buffers and guidance.
- In extreme cases, banks may even need to shrink core portfolios to address the breach of capital buffers and requirements.
- The sum of required capital (including buffers and P2G) and the target management buffer constitutes a banks capital target.
- Many banks explicitly define their target in terms of a buffer on top of the CET1 capital threshold that triggers automatic restrictions on distributions the maximum distributable amount (MDA) trigger.
- Chart1 Capital requirements appear to be key drivers of target CET1 ratios Banks target CET1 ratios and CET1 requirements before the COVID-19 crisis (percentages)
- Three types of reactions were observed among the 35banks which disclosed their new internal target for the regulatory CET1 ratio between April and September 2020 (see also Chart2, left panel).
- Chart2 Mixed reaction of euro area banks to the temporary capital relief measures and lowered macroprudential buffers Change in banks target capital ratios and distance to target after the COVID-19 outbreak (left panel: number of banks; right panel: difference between actual and target CET1 ratios, percentage points)
- All of these banks target a level of capital, as opposed to a distance to the MDA trigger.
- Third, a few banks maintained their regulatory capital ratio targets, despite ample capital in excess of the internal target.
- For this set of banks, the target ratios already stood significantly above the requirements.
- In addition, several banks entered the crisis with capital ratios below or close to their targets.
- These banks CET1 ratios may therefore remain below target even after a reduction in capital requirements, mitigating the effectiveness of the reductions.
- [7] This approach implicitly assumes that banks adapt their management buffer to the economic environment in order to manage the risk of unintended regulatory breaches.
- Table1 Capital targets rise with capital requirements and adverse macrofinancial conditions Elasticity of bank target CET1 ratio to regulatory and macrofinancial determinants
- The estimates suggest that macroprudential buffer releases should result in a significant decline in banks target ratios, but the immediate impact remains uncertain.
- Changes in combined buffer requirements and other regulatory requirements are found to have a positive, strongly significant and economically large impact on banks CET1 ratios (see Table1), confirming that reductions of capital requirements result in declining target ratios for banks a necessary condition for an expansionary effect of macroprudential policies.
- In adverse financial and economic conditions, banks seem to target higher regulatory capital ratios, which may counteract the impact of buffer releases.
- The regression analysis above finds that the macro-financial environment significantly affects banks target capital ratios.
3 Does financial market pressure play a role?
- Chart3 shows estimates of the impact of a 1percentage point decline in solvency ratios on banks funding costs based on existing empirical analyses.
- [8] It presents the effects on banks overall funding costs (first panel) and on senior unsecured bond market funding costs in the primary and secondary markets.
- Wholesale bond market costs exhibit a higher sensitivity than overall funding costs, which is not surprising given the importance of insured (and thus risk-insensitive) deposits in a banks overall liability structure.
- Consequently, financial market pressure on banks will vary with, among other factors,[9] their funding structure.
- Anecdotal evidence confirms that, all other things being equal, eroding management buffers would indicate a higher probability of default and increase the risk of rating downgrades.
- [10] Lower ratings are not only associated with less favourable wholesale funding conditions but can also result in lost market access.
- The market reaction immediately after the outbreak of COVID-19 is a case in point.
- A surge in risk aversion and a flight to safety resulted in a temporary closure of the unsecured wholesale bond market.
- Overall, the currently expected declines in regulatory capital ratios are unlikely to result in a large wave of rating downgrades associated with a major worsening of banks access to external funding markets.
- Model simulations show that a 2percentage point decline in management capital buffers, which would be similar to aggregate CET1 capital depletion in the central scenario of the ECBs vulnerability analysis[12], would result in only a small increase in the probability of rating downgrades.
- The largest effect would be for AAA to AA-rated banks, with an increase in the probability of being downgraded to A of between 1.5 and 2.5percentage points (see Chart5, right panel).
- A further reason for banks reluctance to use their capital buffers could be related to the increased likelihood of MDA trigger breaches.
- Banks facing restrictions on distributions would be unable to pay dividends, which would hit their stock market valuations, and may need to restrict coupon payments on AT1 securities and cut some components of management remuneration.
- Rebuilding capital buffers organically would therefore be challenging and could only be achieved very gradually, over a relatively long period.
- Such considerations may strengthen a latent unwillingness to use buffers to support the flow of bank credit in the current uncertain environment.
- In the past such market-based risk metrics have been a strong predictor of bank distress[13] and are used by financial analysts for their investment recommendations and by rating agencies to cross-check their own rating models, ultimately affecting market funding costs.
- Chart6 shows a notable increase in market-implied bank probabilities of default (PDs) during the COVID-19 pandemic, driven by the very low levels of the market-based leverage ratio (ratio of the market value of equity to total assets).
- Box 1 Estimating the impact of management capital buffers on bank credit ratings Prepared by Jan Hannes Lang This box estimates the impact of a banks management capital buffer on its credit rating.
- As shown in ChartA (left panel), higher-rated banks tend to have higher management capital buffers than lower-rated banks.
- The estimated model coefficients reveal that lower management buffers increase the probability of a bank receiving a lower credit rating.
- A higher banking sector credit-to-GDP ratio and a higher level of real GDP per capita both decrease the probability of a low credit rating.
- All estimated coefficients, with the exception of the unemployment rate are statistically significant at least at the 10% level.
4 Conclusion
- This in itself would create space for banks to expand their balance sheets, support lending and absorb future losses.
- However, at present, banks seem unwilling to adjust fully, if at all, to the recent buffer releases.
- Adverse and uncertain periods are characterised by low risk appetite and flight to safety among investors in bank debt and equity.
- Lower-rated banks in particular may be concerned about their ability to access wholesale funding markets if they let their buffers shrink.
- So far, these policies have alleviated the need to reduce capital targets, while still being able to accommodate loan demand.