Basilea 3 vista da New York e da Berna

Il CEO di Citigroup discute le conseguenze di Basilea 3:




mentre in questo articolo sul Wall Street Journal
Patrick Raaflaub, presidente dell'autorità svizzera di controllo dei mercati finanziari, illustra la regolamentazione adottata nel paese elvetico per evitare il rischio di fallimento di una grande banca (il TBTF, Too Big To Fail), con requisiti di capitale molto più stringenti di Basilea 3. Secondo Raaflaub nell'affrontare il problema

The approach must be two-fold: Regulators must make the failure of these institutions much less likely, but if the unthinkable still happens, they must make it possible to wind them up in an orderly fashion and continue their critical functions without the global markets seizing up.
Last week, an expert commission tasked by the Swiss government published its plan for how to mitigate the problem for my own country's systemically relevant banks. The commission comprised of members of Switzerland's large banks, industry, regulators, the central bank, and academia, and its conclusions were unanimous. The plan, which we could call Bern I in deference to the naming conventions of global standard setters, consists of capital and liquidity regimes going beyond the new Basel III standards. The plan also calls for a reduction of inter-bank risk concentrations, and organizational measures to ensure the continuation of systemically critical functions in a crisis. The commission returned a clear "no" on the questions of bank levies, external resolution funds, bonus taxes, prohibitions on business lines, or splitting up the banks.
The tougher capital and liquidity regimes are clearly calibrated. Switzerland's liquidity regime, which contains tougher assumptions than those currently being discussed by the Basel Committee, has been in place since June. New risk-concentration limits will be adopted along with the first stage of the Basel capital reforms on Jan. 1. While the plan would not work if parts of the package were to be picked apart, its cornerstone is the application of higher capital standards for systemically relevant banks.
So in what way does Bern I go further than Basel III? The large Swiss banks will be required to hold 10% of their risk-weighted assets in the form of common equity, compared to the Basel III target of 7%. On top of that they will need a further 9% of risk-weighted assets in other forms of capital, which must always be available to absorb losses, or in the worst case contribute to the resolution of the bank. This reserve pool of capital could be seen partially as a resolution fund for the wind-up of the bank, but would be held inside rather than outside the system. If combined with steps towards a credible international resolution regime, we would be approaching the holy grail for all regulators: making an orderly market exit possible even for the largest globally active banks.
Basel III goes a long way to reducing the fragility of the banking system as a whole by demanding better-quality capital, and by weighting trading risks much more strongly. But for institutions that can endanger the entire global financial system, better-quality capital alone will not suffice.

Secondo Raaflaub Basilea 3 è stata troppo gentile con le banche, un opinione che condivido, e conclude il suo articolo con tre suggerimenti su come migliorare la regolamentazione internazionale delle banche:


We have three suggestions: insist that the Basel Committee keeps its resolve to introduce a tough new global liquidity standard by 2015; demand that all supervisors of globally system-relevant banks have a credible resolution regime explicitly permitting the reciprocal recognition of decisions made in overseas regimes; and make 10% of risk-weighted assets the minimum acceptable level of common equity for the juggernauts on the global financial highway Those are concrete and responsible ways to make another pile-up less likely.