The sustainability of pension schemes

The sustainability of pension schemes, by Srichander Ramaswamy
BIS Working Papers No 368
http://www.bis.org/publ/work368.htm


Abstract

Poor financial market returns and low long-term real interest rates in recent years have created challenges for the sponsors of defined benefit pension schemes. At the same time, lower payroll tax revenues in a period of high unemployment, and rising fiscal deficits in many advanced economies as economic activity has fallen, are also testing the sustainability of pay-as-you-go public pension schemes. Amendments to pension accounting rules that require corporations to regularly report the valuation differences between their defined benefit pension assets and plan liabilities on their balance sheet have made investors more aware of the pension risk exposure for the sponsors of such schemes. This paper sheds light on what effects these developments are having on the design of occupational pension schemes, and also provides some estimates for the post-employment benefits that could be delivered by these schemes under different sets of assumptions. The paper concludes by providing some policy perspectives.


8  Summary and policy issues (edited)

A weak macroeconomic environment and unusually low real interest rates in many countries have put the funding challenges faced by occupational and public pension schemes in the spotlight. This paper took a simple actuarial model to quantify how the cost of funding DB pension schemes increase as the real rate of return in asset markets falls. If real returns on pension assets are assumed to be lower by 0.5% compared to their historical averages, service costs of DB schemes would be 15% higher than in the past for the same benefit payments. Converting final salary pension schemes to career average schemes (and not altering the percentages applied) would lower pensions by 20–25% assuming that real wages grow at the rate of 1–1.5% per annum.

Declining mortality rates will put further upward pressure on the contribution rates needed to fund these schemes. When the expected increases in longevity are priced into the actuarial model for computing the service cost, this cost is likely to be 10% higher than estimates presented in the paper. Increasing longevity as well as demographic changes that point to a rise in the old-age dependency ratio poses challenges to the sustainability of PAYG schemes. The projected increase in old-age dependency ratio suggests that in many countries the contributions to PAYG schemes have to increase by 20% from current levels in 2020 to pay pensions. But as PAYG schemes that service current pensions from employee contributions and taxes do not report the contractual pension liabilities, estimating the funding shortfalls these schemes might face going forward is a challenge.

In contrast to PAYG schemes and some funded public pension schemes, occupational DB schemes have to comply with accounting standards to report the market value of their pension liabilities and the assets that back them so that potential funding shortfalls faced by these schemes can be quantified. Unusually low real interest rates and poor financial market returns in the past decade have had an adverse impact on the coverage ratio of these schemes through the valuation effects on liabilities and lower returns on pension assets. Estimates of the coverage ratio of occupational DB schemes based on these returns would point to a funding deficit of 10 to 20 per cent against their pension liabilities. The size of any deficit that eventually materialises over the long lives of these schemes, however, would depend on future returns – which are unknown.

For occupational DB schemes that face large funding shortfalls, employer contributions will have to rise to improve the coverage ratio of these schemes. At the same time, increasing longevity and falling real yields against the backdrop of a weak macroeconomic environment are raising the service costs of DB schemes and adding to the upward pressures on required contribution rates. Recent amendments to pension accounting standards, which require companies to provide more disclosures in their financial statements on the risks the DB scheme poses to the entity and to report the net gains or losses from their DB pension plans on their balance sheet, are likely to accelerate the shift out of occupational DB plans into DC plans. This is because DC plans limit the contractual liabilities of employers to the contribution rates to be paid for the current service period of the employee.

A progressive shift from DB to DC schemes can have material implications for post-employment benefits because it exposes employees to the investment risks on the pension assets. In addition to this risk, beneficiaries of DC plans will also be exposed to the principal risk factors that determine annuity payments, namely level of real interest rates and the projections of mortality rates into the future when the actual annuity payments will be made. Using a simple model to estimate the retirement income from DC schemes, the numerical results presented in Table 2 showed that when contributions to DC schemes are 18% of salaries over a 30-year period and the returns net of administrative expenses on plan assets are 2% higher than the rate at which wages grow, post-employment benefits from a DC scheme would roughly be 43% of the final salary. The excess return assumption of 2% is based on the following input variables in the model to compute retirement income for DC plans: real yield on long-term bonds is 2%; equity risk premium over the returns on long-term government bonds is 3%; plan assets have an equal share of bonds and equities; administrative expenses are 0.5% of plan assets; and the annual real wage growth rate is 1.25%.

The quantitative analysis presented in this paper provides some insights on the possible trade-offs that may be available for public policy on the design of sustainable pension schemes. For example, the internal rate of return on the notional assets of PAYG schemes will be approximately equal to the rate of real GDP growth of the local economy, which is expected to be 2% or lower in advanced economies. The actuarial model showed that service cost of a pension scheme will be high when the rate of return on the pension assets is low. A funded public pension scheme, on the other hand, will be able to raise the level of return on pension fund assets by investing them in higher growth markets. Estimates using the actuarial model suggest that a 50 basis points increase in real returns lowers the service cost of the pension scheme by 15%. Funded pension schemes therefore offer the prospect of lowering service costs and to be able to better align the pension benefits offered by these schemes to the contribution rates received.

Public policy may also be needed to develop efficient markets for pricing annuity risk as occupational DC plans become the preferred post-employment benefit scheme offered by employers. Efficient markets for pricing annuities will in turn depend on how the market for managing and hedging longevity risk develops. As more employers progressively shift towards DC schemes for providing post-employment benefits, regulatory policies might be needed to restrict the range of permissible investment options available for plan assets to avoid unintended risks being taken by the plan beneficiaries, and to set mandatory minimum contribution rates for participating in DC schemes. Finally, considering that plan beneficiaries in DC schemes are exposed to interest rate risk at the time of converting plan assets into an annuity, the pros and cons of providing insurance policies that guarantee a minimum real yield at which these assets can be converted into an annuity will have to be examined.

BCBS: Application of own credit risk adjustments to derivatives - consultative document

Application of own credit risk adjustments to derivatives - Basel Committee consultative document
December 21, 2011
http://www.bis.org/press/p111221.htm

The Basel Committee today issued a consultative document on the application of own credit risk adjustments to derivatives.

The Basel III rules seek to ensure that a deterioration in a bank's own creditworthiness does not at the same time lead to an increase in its common equity as a result of a reduction in the value of the bank's liabilities. Paragraph 75 of the Basel III rules requires a bank to "[d]erecognise in the calculation of Common Equity Tier 1, all unrealised gains and losses that have resulted from changes in the fair value of liabilities that are due to changes in the bank's own credit risk".

The application of paragraph 75 to fair valued derivatives is not straightforward since their valuations depend on a range of factors other than the bank's own creditworthiness. The consultative paper proposes that debit valuation adjustments (DVAs) for over-the-counter derivatives and securities financing transactions should be fully deducted in the calculation of Common Equity Tier 1. It briefly reviews other options for applying the underlying concept of paragraph 75 to these products and the reasons these alternatives were not supported by the Basel Committee.

The Basel Committee welcomes comments on all aspects of this consultative document by Friday 17 February 2012. Comments should be sent to baselcommittee@bis.org. Alternatively, comments may be submitted to the following address: Basel Committee on Banking Supervision, Bank for International Settlements, Centralbahnplatz 2, 4002 Basel, Switzerland. All comments may be published on the BIS website unless a commenter specifically requests confidential treatment.


Summary (http://www.bis.org/publ/bcbs214.htm, edited):

A deterioration in a bank's own creditworthiness can lead to an increase in the bank's common equity as a result of a reduction in the value of its liabilities. The Basel III rules seek to prevent this. Paragraph 75 of the Basel III rules requires a bank to "[d]erecognise in the calculation of Common Equity Tier 1, all unrealised gains and losses that have resulted from changes in the fair value of liabilities that are due to changes in the bank's own credit risk". The application of paragraph 75 to fair valued derivatives is not straightforward since their valuations depend on a range of factors other than the bank's own creditworthiness. The consultative paper proposes that debit valuation adjustments (DVAs) for over-the-counter derivatives and securities financing transactions should be fully deducted in the calculation of Common Equity Tier 1. It briefly reviews other options for applying the underlying concept of paragraph 75 to these products and the reasons these alternatives were not supported by the Basel Committee.

PDF: http://www.bis.org/publ/bcbs214.pdf

2011: A Year of Important Pharmacological Advances for Patients

2011: A Year of Important Pharmacological Advances for Patients
December 21, 2011
http://www.innovation.org/index.cfm/NewsCenter/Newsletters?NID=193

New advances in biopharmaceuticals came as welcome good news for U.S. patients. In recent years, despite increasing investments in R&D, fewer medicines have recieved approval, reminding us just how difficult drug discovery is. But in 2011 there were more new medicines approved than in recent years and these approvals represented important advances in many areas.

The Food and Drug Administration reported in November that in fiscal year 2011 (10/1/10–9/30/11) there were 35 new medicines approved,[i] among the highest in the last decade. According to the FDA report, "few years have seen as many important advances for patients." The final tally of medicines approved in calendar year 2011 waits to be seen but it is clear that 2011 has been a great year for advancing the fight on many disease fronts. Below is information on some of the treatments highlighted in the FDA report.

Cancer: With improvements in early detection and a steady stream of new and enhanced treatments cancer can be more effectively managed and even beaten. Two new personalized medicines for lung cancer and melanoma now provide effective options for patients with tumors expressing certain genetic markers.[ii] The personalized melanoma treatment and another new melanoma medicine became the first new approvals for the disease in 13 years. Read about continued efforts to improve cancer treatment and the 887 medicines currently in development.

Rare Diseases: An estimated 25-30 million Americans suffer from rare or "orphan" diseases, which are often among the most devastating to patients and complex for researchers.[iii] However, advances in science have allowed us to hone in on the causes of many rare diseases and translate those findings into new treatments. Between January 1st and December 7th 2011, eleven new medicines to treat rare diseases were made available to patients for diseases such as the genetic defect congenital Factor XIII deficiency, several cancers, and scorpion poisoning.[iv] A record 460 new medicines are in clinical trials or awaiting FDA review.[v] Read more about the ongoing commitment to improve treatment for rare diseases.

Lupus: Lupus is a serious and potentially fatal autoimmune disease that attacks healthy organs and tissues of the body. For the approximately 300,000 to 1.5 million lupus sufferers in the U.S. the last approved drug came in 1955. This year a newly approved medicine ended that drought with a new approach to treating lupus. Read more about medicines in development for autoimmune diseases.

Hepatitis C: Hepatitis C is a chronic viral disease that affects the liver and can lead liver cancer and liver failure. It affects approximately 3 million people in the United States. Two new medicines approved this year are the first in a new class and offer a greater chance of cure for some patients compared with existing therapies. For more information on medicines in development for infectious diseases, click here.

This is only a partial list of the many advances approved in 2011, for a more complete listing visit www.FDA.org.

Looking ahead to 2012, biomedical research continues to draw us in new directions and helps us to better understand the cause and progression of disease. Coupled with innovative approaches at the bench and in the clinic, we can better prevent, detect, and treat disease to save and improve lives.


References
[i]US Food and Drug Administration, FY2011 Innovative Drug Approvals, (November 2011) http://www.fda.gov/AboutFDA/ReportsManualsForms/Reports/ucm276385.htm

[ii]US Food and Drug Administration, FY2011 Innovative Drug Approvals, (November 2011) http://www.fda.gov/AboutFDA/ReportsManualsForms/Reports/ucm276385.htm

[iii]PhRMA, Orphan Drugs in Development for Rare Diseases (February 2011) http://www.phrma.org/sites/default/files/878/rarediseases2011.pdf

[iv]US Food and Drug Administration, CDER New Drug Review: 2011 Update (December 2011) http://www.fda.gov/downloads/AboutFDA/CentersOffices/OfficeofMedicalProductsandTobacco/CDER/UCM282984.pdf

[v]PhRMA, Orphan Drugs in Development for Rare Diseases (February 2011) http://www.phrma.org/sites/default/files/878/rarediseases2011.pdf

BCBS: revised "Core principles for effective banking supervision" - consultative paper

Consultative paper on revised "Core principles for effective banking supervision" issued by the Basel Committee
December 20, 2011
http://www.bis.org/press/p111220.htm

The Basel Committee on Banking Supervision today issued for public comment its revised "Core principles for effective banking supervision" [http://www.bis.org/publ/bcbs213.htm].

The consultative paper updates the Committee's 2006 "Core principles for effective banking supervision" [http://www.bis.org/publ/bcbs129.htm] and the associated "Core principles methodology" [http://www.bis.org/publ/bcbs130.htm], and merges the two documents into one. The Core Principles have also been re-ordered, highlighting the difference between what supervisors do themselves and what they expect banks to do: Principles 1 to 13 address supervisory powers, responsibilities and functions, focusing on effective risk-based supervision, and the need for early intervention and timely supervisory actions. Principles 14 to 29 cover supervisory expectations of banks, emphasising the importance of good corporate governance and risk management, as well as compliance with supervisory standards.

Among other things, the revision of the Core Principles builds on the lessons of the last financial crisis. The Core Principles have been enhanced to strengthen supervisory practices and risk management. In addition, the revised Core Principles respond to several key trends and developments that emerged during the last few years of market turmoil: the need for greater intensity and resources to deal effectively with systemically important banks; the importance of applying a system-wide, macro perspective to the microprudential supervision of banks to assist in identifying, analysing and taking pre-emptive action to address systemic risk; and the increasing focus on effective crisis management, recovery and resolution measures in reducing both the probability and impact of a bank failure.

Ms Sabine Lautenschläger, Co-chair of the Core Principles Group and Vice-President of the Deutsche Bundesbank, noted that "the revised Core Principles contribute to the broader ongoing effort by the Basel Committee to raise the bar for banking supervision in the post-crisis era". She added that "the Committee has achieved a lot in terms of rule-making over the past five years and this work will be instrumental in firmly entrenching many of the supervisory lessons and regulatory developments since the Core Principles were last revised".

The latest revision ensures the continued relevance of the Core Principles in providing a benchmark for supervisory practices that will withstand the test of time and changing environments. The total number of Core Principles has increased from 25 to 29; 36 new essential and additional criteria have been introduced and another 33 additional criteria have been upgraded to essential criteria that represent minimum baseline requirements for all countries.

The Core Principles are the de facto framework of minimum standards for sound supervisory practices and are universally applicable. The Committee believes that implementation of the revised Core Principles by all countries will be a significant step towards improving financial stability domestically and internationally, and provide a good basis for further development of effective supervisory systems.

"With the advent of various policy measures for addressing both bank-specific and broader systemic risks, the key challenge in this revision of the Core Principles has been to uphold their relevance for different jurisdictions and banking systems," stated Ms Teo Swee Lian, Co-chair of the Core Principles Group and Deputy Managing Director of the Monetary Authority of Singapore. "As highlighted in the paper, a proportionate approach achieves this through advocating risk-based supervision and supervisory expectations that are commensurate with a bank's risk profile and systemic importance."

The revised Core Principles represented the collective efforts between the Basel Committee and other banking supervisors from around the world, as well as the International Monetary Fund and the World Bank.

For information purposes, a document comparing the 2006 assessment methodology with the revised version has also been posted. This document is provided to facilitate a direct comparison between the two versions of assessment criteria.

The Basel Committee welcomes comments on the revised Core Principles. Comments should be submitted by Tuesday 20 March 2012 by email to: baselcommittee@bis.org. Alternatively, comments may be sent by post to the Secretariat of the Basel Committee on Banking Supervision, Bank for International Settlements, CH-4002 Basel, Switzerland. All comments may be published on the Bank for International Settlements's website unless a commenter specifically requests confidential treatment.


PDF: http://www.bis.org/publ/bcbs213.pdf (84 pages)

BCBS: Proposed regulatory capital disclosure requirements

Proposed regulatory capital disclosure requirements issued by the Basel Committee

December 19, 2011

http://www.bis.org/press/p111219a.htm

The Basel Committee on Banking Supervision today published for consultation a set of requirements for banks to disclose the composition of their regulatory capital. These aim to improve the transparency and comparability of banks' capital bases, including on a cross border basis.

During the financial crisis, market participants and supervisors attempted to undertake detailed assessments of the capital positions of banks and make cross jurisdictional comparisons. These efforts were often hampered by insufficiently detailed disclosure and a lack of consistency in reporting between banks and across jurisdictions. A lack of clarity on the quality of capital may have contributed to uncertainty during the financial crisis.

In addition to improving the quality and level of required capital, Basel III established certain high level disclosure requirements to improve transparency of regulatory capital and enhance market discipline. The Basel Committee noted that it would issue more detailed Pillar 3 disclosure requirements in 2011. Today's publication sets out these detailed requirements for consultation.

The Basel Committee welcomes comments on the proposed consultative document. Comments should be submitted by Friday 17 February 2012 by email to: baselcommittee@bis.org. Alternatively, comments may be sent by post to the Secretariat of the Basel Committee on Banking Supervision, Bank for International Settlements, CH-4002 Basel, Switzerland. All comments may be published on the Bank for International Settlements's website unless a commenter specifically requests confidential treatment.

Joint Forum: Consultative paper on "Principles for the supervision of financial conglomerates"

Consultative paper on "Principles for the supervision of financial conglomerates" released by the Joint Forum
December 19, 2011

The Joint Forum released today a consultative paper on Principles for the Supervision of Financial Conglomerates.

The proposed principles, which revise the Joint Forum's 1999 principles, provide national authorities, standard setters and supervisors with a set of internationally agreed principles that support consistent and effective supervision of financial conglomerates and in particular those financial conglomerates that are active across borders.

Mr Tony D'Aloisio, Chairman of the Joint Forum, stated that "these principles should, over time, help strengthen the global financial system through more effective and consistent oversight and supervision of financial conglomerates notably including risks arising from unregulated financial activities and entities".

The financial crisis that began in 2007 exposed situations in which regulatory requirements and oversight did not fully capture all the activities of financial conglomerates or fully consider the impact and cost that these activities may pose to the financial system. The principles issued today address complexities and gaps resulting from cross-sectoral activities with a scope of application based on a revised and broader definition of a financial conglomerate.

The proposed principles are organised into five sections and expand on and supplement the 1999 Principles in a number of ways:


Supervisory powers and authority

The principles are directed to both policy makers and supervisors highlighting the need for a clear legal framework that provides supervisors with the necessary powers, authority and resources to perform, with independence and in coordination with other supervisors, comprehensive group-wide supervision.


Supervisory responsibility

The principles reaffirm the importance of supervisory cooperation, coordination and information exchange. They clarify the importance of identifying a group-level supervisor whose responsibility is to focus on group-level supervision and the facilitation of coordination between relevant supervisors. New principles have been included which relate to the role and responsibilities of supervisors in implementing minimum prudential standards, monitoring and supervising activities of financial conglomerates and taking corrective action as appropriate.


Corporate governance

The principles reaffirm the importance of fit and proper principles and also provide, through a series of new principles, guidance for supervisors intended to ensure the existence of a robust corporate governance framework for financial conglomerates. These new principles relate to the structure of the financial conglomerate, the responsibilities of the board and senior management, the treatment of conflicts of interest and remuneration policy.


Capital adequacy and liquidity

The principles highlight the role of supervisors in assessing capital adequacy on a group basis, taking into account unregulated entities and activities and the risks they pose to regulated entities. They include new principles on group-wide capital management. The principles also provide guidance on internal capital planning processes that rely on sound board and management decisions, incorporate stressed scenario outcomes, and are subject to adequate internal controls. A new principle on liquidity assessment and management is also introduced - providing guidance for supervisors intended to ensure that financial conglomerates properly measure and manage liquidity risk.


Risk management

The principles set out the need for a financial conglomerate to have a comprehensive risk management framework to manage and report group-wide risk concentrations and intra-group transactions and exposures. Greater emphasis is placed on the financial conglomerate's ability to measure, manage and report all material risks to which it is exposed, including those stemming from unregulated entities and activities. The principles focus on group-wide risk management culture and appropriate tolerance levels; addressing risks associated with new business areas and outsourcing; group-wide stress-tests and scenario analyses for the prudent aggregation of risks; bringing off-balance sheet activities within the scope of group-wide supervision.


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The consultative report is available on the websites of the Bank for International Settlements (www.bis.org), IOSCO (www.iosco.org) and the IAIS (www.iaisweb.org). Comments on this consultative report should be submitted by Friday 16 March 2012 either by email to baselcommittee@bis.org or by post to the Secretariat of the Joint Forum (BCBS Secretariat), Bank for International Settlements, CH-4002 Basel, Switzerland. All comments may be published on the websites of the Bank for International Settlements, IOSCO (www.iosco.org) and the IAIS (www.iaisweb.org) unless a commenter specifically requests confidential treatment.

Link to this press release: http://www.bis.org/press/p111219b.htm
Link to the PDF: http://www.bis.org/publ/joint27.pdf

Bank Competition and Financial Stability: A General Equilibrium Exposition

Bank Competition and Financial Stability: A General Equilibrium Exposition. By Gianni De Nicolo' & Marcella Lucchetta
IMF Working Paper No. 11/295
Dec 16, 2011

Summary: We study versions of a general equilibrium banking model with moral hazard under either constant or increasing returns to scale of the intermediation technology used by banks to screen and/or monitor borrowers. If the intermediation technology exhibits increasing returns to scale, or it is relatively efficient, then perfect competition is optimal and supports the lowest feasible level of bank risk. Conversely, if the intermediation technology exhibits constant returns to scale, or is relatively inefficient, then imperfect competition and intermediate levels of bank risks are optimal. These results are empirically relevant and carry significant implications for financial policy.

Excerpts:

The theoretical literature offers contrasting results on the relationship between bank competition and financial stability. Yet these results arise from models with three important limitations: they are partial equilibrium set-ups; there is no special role for banks as institutions endowed with some comparative advantage in screening and/or monitoring borrowers; and bank risk is not determined jointly by the borrower and the bank. This paper contributes to overcome these limitations. A more general assessment of the relationship between bank competition, financial stability and welfare is not only important per se, but it is also essential to evaluate whether “granting” banks the ability of earning rents may reduce their risk-taking incentives.

We study the relationship between bank competition, financial stability and welfare in versions of a general equilibrium banking model with moral hazard, where the choice of “systematic” risk by either banks or firms is unobservable. In our set-up, risk-neutral agents specialize in production at the start date, choosing to become entrepreneurs, bankers, or depositors, and at a later date they make their financing and investment decisions. In this risk-neutral world, the welfare criterion is total surplus, defined as total output net of effort costs. We consider two versions of the model. In the first version, called “basic”, the bank is a coalition of entrepreneurs that are financed by depositors. In the second version, called “extended”, the “firm” is a coalition of entrepreneurs that is financed by the “bank”, which is a coalition of bankers financed by depositors. The firm, the bank and depositors can be also viewed as representing the business sector, the banking sector and the household sector.

In both versions, we consider two specifications of the bank’s screening and/or monitoring technology, called the “intermediation technology”. In the first specification, the intermediation technology exhibits constant returns to scale: the effort cost of screening and/or monitoring is proportional to the size of investment. In the second specification, this technology exhibits increasing returns to scale: the effort cost of screening and/or monitoring is independent of investment size. This second specification captures in a simple form the essential role of banks in economizing on monitoring and screening costs identified by a well-known literature briefly reviewed below.

In the basic model the bank chooses (systematic) risk, this choice is unobservable to outsiders, and there is competition in the deposit market only, indexed by the opportunity costs of depositors to invest in the bank. The results of this model differ strikingly depending on whether the intermediation technology exhibits constant or increasing returns to scale.  Under constant returns to scale, as competition in the deposit market increases, bank risk increases, bank capital declines, and welfare is maximized for some intermediate degree of competition. Thus, perfect deposit market competition is sub-optimal, as it entails excessive bank risk-taking and sub-optimally low levels of bank capitalization. However, allocating large shares of surplus (or rents) to banks is not optimal either, as it results in sub-optimally low levels of bank-risk taking and excessive bank capitalization.

When the intermediation technology exhibits increasing returns to scale, however, results are totally reversed: as competition increases, bank risk declines, capitalization increases, perfect deposit market competition is optimal, and the lowest feasible level of bank risk is best. This reversal is simply explained as follows. As competition increases, a ceteris paribus increase in the cost of funding induces the bank to take on more risk. But at the same time the increase in the supply of funds to the bank reduces the costs of the intermediation technology owing to increasing returns to scale: this offsets the negative impact of higher funding costs on bank’s expected profits, inducing the bank to take on less risk. This result is remarkable for two reasons: it is obtained under a standard assumption about the bank’s intermediation technology, and without modeling loan market competition. Thus, introducing loan market competition, as in Boyd and De Nicolo’ (2005), is not necessary—albeit it may be sufficient—to yield a positive relationship between bank competition and financial stability.

The extended model depicts the more realistic case in which there is competition in both lending and deposit markets, bank risk is jointly determined by borrowers and banks, and setting up the intermediation technology entails set-up costs. Here, bank competition is indexed by the opportunity costs of depositors to invest in the bank, and the opportunity costs of the firm to be financed by the bank. In this model, the relationship between bank competition, financial stability, and welfare becomes complex in a substantial economic sense, since double-sided competition determines how total surplus, whose size is endogenous, is shared by three sets of agents, rather than two, as in the basic model. When the degree of competition in lending and deposit markets differs, we illustrate several results suggestive of a rich comparative statics, which in some cases overturn simple conjectures on the relationship between bank risk, firm risk and capital.

Focusing on changes of competition in both loan and deposit markets, we obtain the following main results. If the bank intermediation technology is relatively inefficient, as defined as one that entails high monitoring and screening costs but relatively low set-up costs, then a level of competition lower than perfect competition is optimal, corresponding to an “intermediate” optimal levels of bank risk. However, if the bank intermediation technology is relatively efficient, defined as one that entails low monitoring and screening costs but relatively large set-up costs, then perfect competition is optimal, and the optimal level of bank risk turns out to be the lowest attainable. Notably, these results are independent of whether the intermediation technology exhibits constant or increasing returns to scale in screening and/or monitoring effort.

We discuss below the empirical relevance of some of our results. Furthermore, we believe these results throw a new light on the important policy question regarding the desirability of supporting bank profits, or banks’ “charter value”, with some “rents” in order to guarantee financial stability: what seems to matter are not necessarily rents per se, but what are their sources and how banks might exploit them.

Conclusions:

We studied versions of a general equilibrium banking model with moral hazard in which the bank’s intermediation technology exhibits either constant or increasing returns to scale. In the basic version of the model under constant returns of the intermediation technology we showed that as deposit market competition increases, bank risk increases, capitalization declines, and “intermediate” degreed of deposit market competition and bank risk are best..The result that the lowest attainable level of bank risk is not optimal echoes Allen and Gale’s (2004b) result that a positive degree of financial ”instability” can be a necessary condition for optimality. Yet, the efficiency of the intermediation technology matters. If this technology exhibits increasing returns to scale, then the implications of this model for bank risk, capitalization and welfare are totally reversed: as competition increases, bank risk declines, capitalization increases, perfect deposit market competition and the lowest attainable level of bank risk are optimal.

Subsequently, we studied the more realistic version of the model where there is competition in both lending and deposit markets and bank risk is determined jointly by the bank and the firm. The key results of the extended model pertain to the role of the efficiency of the intermediation technology in relationship to the level of competition in both lending and deposit markets. We showed that independently of whether the intermediation technology exhibits constant or increasing returns, perfect competition and the lowest attainable level of bank risk are optimal if the bank intermediation technology is relatively efficient. When such technology is relatively inefficient, however, perfect competition is suboptimal, and intermediates levels of competition and bank risk are best.

The theoretical results or our study are empirically relevant. Several studies present evidence consistent with a positive relationship between bank competition and financial stability.  Jayaratne and Strahan (1998) find that branch deregulation resulted in a sharp decrease in loan losses. Restrictions on banks’ entry and activity have been found to be negatively associated with some measures of bank stability by Barth, Caprio and Levine (2004), Beck (2006a and 2006b), and Schaeck et al. (2009). Furthermore, Cetorelli and Gambera (2001) and Cetorelli and Strahan (2006) find that banks with market power erect an important financial barrier to entry to the detriment of the entrepreneurial sector of the economy, leading to long-term declines in a country’s growth prospect. Lastly, Corbae and D’Erasmo (2011) present a detailed quantitative study of the U.S. banking industry based on a dynamic calibrated version of Boyd and De Nicolo’ (2005) model, finding evidence of a positive association between competition and financial stability. It is apparent that these results are consistent with the predictions of the basic model with increasing returns, and those of the extended model in which banks use relatively efficient intermediation technologies.

Under a policy viewpoint, we believe that our results provide an important insight with regard to the question of whether supporting bank profits with some rents—or, in a dynamic context, supporting banks’ charter values—is a desirable public policy option. A substantial portion of the literature and the policy debate maintains that preserving bank profitability through rents enhancing bank profitability—or banks’ charter values—may be desirable, as it induces banks to take on less risk. As we have shown, however, this argument ignores how these rents are generated, or how they may be eventually used once granted.

Our results suggest that supporting bank profitability (or charter values) with rents that are independent of bank’s actions aimed at improving efficiency may be unwarranted. If rents accrue independently of banks’ efforts to adopt more efficient intermediation technologies and, more generally, to provide better intermediation services, then rents are suboptimal and do not guarantee banking system stability. In this light, competitive pressures may be an effective incentive for banks to adopt more efficient intermediation technologies. In a competitive environment, rents would need to be earned by investing in technologies that provide banks a comparative advantage in providing intermediation services, rather than been derived from some market power enjoyed “freely”.

Source: http://www.imf.org/external/pubs/cat/longres.aspx?sk=25439.0

BCBS: The internal audit function in banks - consultative document

The internal audit function in banks - consultative document
The Basel Committee on Banking Supervision, December 2, 2011

The Basel Committee on Banking Supervision is issuing this revised supervisory guidance for assessing the effectiveness of the internal audit function in banks, which forms part of the Committee's ongoing efforts to address bank supervisory issues and enhance supervision through guidance that encourages sound practices within banks. The document replaces the 2001 document Internal audit in banks and the supervisor's relationship with auditors. It takes into account developments in supervisory practices and in banking organisations and incorporates lessons drawn from the recent financial crisis.

The document builds on the Committee's Principles for Enhancing Corporate Governance [http://www.bis.org/publ/bcbs176.htm] which require banks to have an internal audit function with sufficient authority, stature, independence, resources and access to the board of directors. Independent, competent and qualified internal auditors are vital to sound corporate governance.

As a strong internal control framework including an independent, effective internal audit function is part of sound corporate governance. Banking supervisors must be satisfied as to the effectiveness of a bank's internal audit function, that effective policies and practices are followed and that management takes appropriate corrective action in response to internal control weaknesses identified by internal auditors. An effective internal audit function provides vital assurance to a bank's board of directors and senior management (and bank supervisors) as to the quality of the bank's internal control system. In doing so, the function helps reduce the risk of loss and reputational damage to the bank.

The document is based on 20 principles, organised in three sections: A) Supervisory expectations relevant to the internal audit function, B) The relationship of the supervisory authority with the internal audit function, and C) Supervisory assessment of the internal audit function. This approach seeks to promote a strong internal audit function within banking organisations and addresses supervisory expectations for the internal audit function and the supervisory assessment of that function. It also encourages bank internal auditors to comply with and to contribute to the development of national and international professional standards, such as those issued by The Institute of Internal Auditors, and it promotes due consideration of prudential issues in the development of internal audit standards and practices. An annex to the consultative document details responsiblities of a bank's audit committee.

The Basel Committee welcomes comments on the proposed consultative document. Comments should be submitted by Friday 2 March 2012 by email to: baselcommittee@bis.org. Alternatively, comments may be sent by post to the Secretariat of the Basel Committee on Banking Supervision, Bank for International Settlements, CH-4002 Basel, Switzerland. All comments may be published on the Bank for International Settlements's website unless a commenter specifically requests confidential treatment.

You can download the PDF from here: http://www.bis.org/publ/bcbs210.htm


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Press release: Banks' internal audit function - consultative paper issued by the Basel Committee
December 2, 2011
http://www.bis.org/press/p111202.htm

The Basel Committee on Banking Supervision issued today a consultative paper on The internal audit function in banks.

The objective of the proposed guidance, which revises the Committee's 2001 document Internal Audit in Banks and the Supervisor's Relationship with Auditors, is to help supervisors assess the effectiveness of a bank's internal audit function. The guidance reflects developments in supervisory and banking practices and incorporates lessons drawn from the financial crisis.

The proposed guidance is built around a set of principles that seek to promote a strong internal audit function within banks. The principles cover supervisory expectations related to the internal audit function as well as the supervisory assessment of that function. The principles also review the relationship between a supervisory authority and a bank's internal audit function.

The Basel Committee welcomes comments on the proposed consultative documents. Comments should be submitted by Friday, 2 March 2012 by email to: baselcommittee@bis.org. Alternatively, comments may be sent by post to the Secretariat of the Basel Committee on Banking Supervision, Bank for International Settlements, CH-4002 Basel, Switzerland. All comments may be published on the Bank for International Settlements's website unless a commenter specifically requests confidential treatment.

The Committee is now in the process of developing supervisory guidance on external audit. This guidance will build on existing Basel Committee guidance on this topic, including The relationship between bank supervisors and external auditors (2002) and External audit quality and banking supervision (2008). The Committee expects to publish a consultative version of its external audit guidance in 2012.