Be careful what you wish for. Bankers have for the past five years wanted less regulatory interference. But in a badly damaged financial system this was wishful thinking. Regulators and politicians just couldn’t take the chance of a major bank failure leading to systemic melt down. The liquidity and capital rules just reflected this zero failure regime. But now it’s going to change. Why? In hindsight regulation has been too punitive it’s stopped banks from lending. This is the legacy we currently live with. But political pressure is being brought to bear in order to get the real economy moving. It’s also recognised that failure can be constructive provided the taxpayer doesn’t foot the bill. Provided the authorities think the probability of systemic failure is negligible banks will be allowed to fail. When and where the first failure will occur is anyone’s guess but you have to think it will involve a small player first. The G-SIFIs turn will come later when regulators are confident that their structure can be effectively taken to pieces without endangering the rest of us. In part this is a return to banking as it used to be. But there will be safeguards. Board accountability will be re-enforced. Reporting will be comprehensive and accurate. Resolution will work. The subtle shift from zero bank failure to zero systemic failure has important implications for those of us who work in or around financial markets:
Risk levels will be allowed to increase but not to the levels of 2004-7. If you don’t like this then banking probably isn’t for you;
Failure to have a credible resolution plan will lead to dismemberment;
Board challenge will replace tick box regulation;
Unsecured credit exposures to banks are highly undesirable;
As is operational reliance on any one party;
Failed regulatory reporting will incur big fines;
System providers will gain from the infrastructure spend. The debate on the EU and banker’s bonuses is all part and parcel of this shifting process. Embracing free market thinking that would let badly run firms fail without taxpayer bailouts would surely provide bankers with the best argument for paying bonuses. It’s a pity but we aren’t there yet but I sense that’s where we are going. The problem for bankers is that the implied credit guarantee is major part of the revenue stream. Until then EU legislators will press their case.
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