Blog article
See all stories »

Is Basel III bad for finance?

The Basel III accord’s stated purpose is:

This consultative document presents the Basel Committee's proposals to strengthen global capital and liquidity regulations with the goal of promoting a more resilient banking sector. The objective of the Basel Committee's reform package is to improve the banking sector's ability to absorb shocks arising from financial and economic stress, whatever the source, thus reducing the risk of spillover from the financial sector to the real economy.
BCBS Consultative Proposal: "Strengthening the resilience of the banking sector"

The intent of the Basel accords must be to afford consumers, shareholders, the corporation, and the 'banking sector' at large, more generally protection from shocks, abuse, corruption or intended manipulation. In that respect, Basel broadly takes a position of “trust no one”, and builds into the system a comprehensive framework of understanding, monitoring and mitigating any risk of sufficient intensity that it could do harm to the sector or players.

Reflexive Feedback loops

The issue with this approach is, of course, that by creating a set of rules and by changing the system, this very approach generates a reflexive feedback loop that increases complexity of the processes between customers and the institution, and between the institution and third parties. The more complexity that is built into the system, the greater the likelihood of abuse as complex systems are harder to control or police.

While payments, interbank networks and such may appear inordinately complex, there are those that maintain that such networks produce predictable or measurable behavior in response to specific shocks or trends, but essentially this is through either the emergence of a dominant sentiment (i.e. the old "buy on rumor sell on facts" saying) or through exogenous events.

While some claim that sentiment analysis through tools like Twitter, might predict the way the network or market will move in the short-term, the problem with Basel III is that its very complexity might possibly have a deleterious effect on the market as a whole, but most certainly on the effectiveness of the institution. The primary concern for institutions will be that Basel III might actually reduce the ability of the organization to respond to shocks in the system, because it might be outside of the approved risk management process. Essentially working exactly the opposite to its intended purpose. However, the implementation of Basel III could actually have a more short-term effect on institutional competitiveness.

Lessons from the regulation of markets

ICBC was the world's largest IPO in history to-date. There was much discussion over this IPO, but it was telling that ICBC chose, not New York or London to launch their IPO, but Hong Kong. The long and the short of these discussions are essentially that the US market, in particular, is now too heavily regulated to stay competitive on a global stage as a capital market. The US continues to find some momentum around its reputation as the biggest and best market, but a number of proponents of change in the US cite the medium-term demise of the US capital markets as a real risk. For example, Professor Hal Scott, in his paper "Competitive Complacency in the decline of US Public Equity Capital Markets" (May 2007) challenges regulators and the market in this way:

While America’s public equity marketplace is still winning the war as the world’s most dominant marketplace, it is losing many of the key battles to foreign and private markets. America is losing its place of primacy, power and influence as the global leader in public equity capital markets competitiveness. Further, the evidence is equally compelling that New York is losing its place as the dominant center for global financial markets. There is a tremendous price America’s economy may pay for failing to compete sufficiently to stay ahead of its global rivals.

And further in respect to the US regulatory environment

“What we are witnessing is the latest chapter in the evolution of the euromarkets. In the past, US banks moved to London to escape onerous banking regulation and the eurobond market was created in part to avoid US taxes. Now exchanges are moving abroad in part to avoid the US capital market’s regulatory regime. Europe should not be threatened. It is the US that should be concerned. Once a market moves abroad it is difficult to get it back.” - Hal Scott and George Dallas

In a report commissioned by Mayor Michael Bloomberg in 2007, supported by the strategy research firm McKinsey, Bloomberg states the shifting competitive environment in the following way:

"Traditionally, London was our chief competitor in the financial services industry. But as technology has virtually eliminated barriers to the flow of capital, it now freely flows to the most efficient markets, in all corners of the globe. Today, in addition to London, we’re increasingly competing with cities like Dubai, Hong Kong, and Tokyo." - Michael Bloomberg, Sustaining New York’s and the US’ Global Financial Services Leadership, Jan 2007

So as competition heats up, the heavy regulatory environment of the US and UK markets has not actually helped those markets to be more competitive, in fact, exactly the opposite. The downside of taking a heavier approach to risk mitigation and management is the reduction of competitiveness. In this respect, while dotting the i's and crossing the t's Basel III doesn't contribute positively in any immediately recognizable form to the competitiveness of an institution. In the long-term, we might argue that Basel III is ultimately about insurance, and reducing future risk, which will make you more robust or less risky than your competitors who don't adhere to the standards. The same argument is made for regulation in markets like the US, but essentially the cost has to be weighed up because in the short-term revenue and competitiveness is taking a hit.

Is there a better way?

So given the cost of implementation, the loss of competitiveness, the fact that Basel III adds inordinately to the complexity of the institution from an organizational structure and process perspective, why don't we see more of the big banks complaining? Probably because purely the cost of implementing Basel III is prohibitive and it is likely to produce more consolidation of the sector as they snap up banks who can't afford to comply. There has to be a better way though...

The Basel accords team needs to encourage the reduction of complexity in the system, which in itself creates risk. Rather than enforce new reporting or analysis elements for existing processes, what I'd like to see is a real revolution in process redesign. Let's look at ways of taking the complexity out of the system, reducing risk by reducing handling, process and silos.


Comments: (2)

Olivier Berthier
Olivier Berthier - Moneythor - Singapore 17 December, 2010, 05:59Be the first to give this comment the thumbs up 0 likes

And then there is also the likely negative impact of Basel III on trade finance...

As it stands today, and as been reported like never before, from the G20 to national banking associations, Basel III advocates increased regulation and further constraints on trade finance instruments to meet its admirable objective of tackling excessive leveraging.  Lower-risk traditional instruments, such as Letters of Credit (despite their short-term nature) are included in this treatment because, among other things, of the rigidity of its one-year maturity floor on all lending facilities.

Trade finance would suffer under the proposed Basel III recommendations by bearing a flat 100% credit conversion factor because of the off-balance sheet treatment. There are ways to circumvent this with the Advanced Internal Ratings approach, but this arguably is only really possible for the larger banks as it requires extra effort and resources for retrieving the in-depth historic data needed for reporting. 

For most of the regional and local banks, such Basel III proposals would result in a poorer situation for the majority of banks than under Basel II – and indeed it will be significantly worse than Basel I’s 20% credit conversion factor for trade finance. We cannot and must not let Basel III be even worse for trade finance than its predecessors.

Now, if we trust the final line of a recent press release from the Bank of International Settlements indicating that "as requested by the G20 Leaders, the Committee will also evaluate the impact of the regulatory regime on trade finance in the context of low income countries", there might be hopes that we will end up with fair treatment in the final version of the revised rules so that the trade finance industry and therefore global trade will not suffer. Fingers crossed.


Nikhil Mittal
Nikhil Mittal - Wells Fargo - Charlotte 20 December, 2010, 08:07Be the first to give this comment the thumbs up 0 likes

Basel III will be attacking the books of acocunts of banks in multiple ways, some of the important ones are:

1. Increase of Capital Adequacy Ratio upto 7% from 2015 onwards thus constraining the usage of Tier 1 capital

2. Stringent counterparty credit risk limitations which will have profound impact on global trade finance

3. Putting in place a long term structural liquidity baseline and maintaining the minimum 30 day stress fund as a measure of global minimum liquidity

All these measures to counter any cyclicality of risks of any type, are effectively impacting the growth and recovery engines. While the banks subscribing to Basel III have to be large enough to sustain the costs of subscription, they're the only few handful which are assisting in global recovery by churning money among them.

Restraining the big banks will slow down the recovery, hence stretching the cyclicality rather than curing it.

Brett King

Brett King

CEO & Founder


Member since

14 Apr 2010


New York

Blog posts




More from Brett

This post is from a series of posts in the group:

Innovation in Financial Services

A discussion of trends in innovation management within financial institutions, and the key processes, technology and cultural shifts driving innovation.

See all