2015年-ECB欧洲央行_The_impact_of_the_CRR_and_CRD_IV_on_bank_financing_-_Eurosystem_response_to_the_DG_FISMA_consultation_paper_39页_570kb

Summary of the Impact of the CRR and CRD IV on Bank Financing

Core Content

The Capital Requirements Regulation (CRR) and Capital Requirements Directive IV (CRD IV) represent a significant regulatory reform aimed at enhancing the resilience of the EU banking sector. The ECB acknowledges the importance of these regulations in restoring market confidence, ensuring financial stability, and providing a level playing field across the EU. The reforms were a necessary correction to the weak capital standards that existed pre-crisis and are aligned with international best practices.

The CRR/CRD IV package introduces higher capital requirements, which are seen as a prudent and proportionate approach. These requirements are often below the estimates of socially optimal capital levels, but they have been implemented to ensure banks are better prepared for financial shocks. The ECB emphasizes that the long-term benefits of these regulations, such as reduced bank defaults and financial crises, outweigh the short-term costs, particularly in the transition phase.

Main Views

• Regulatory Objectives: The primary goal of CRR/CRD IV is to strengthen the financial system's resilience, support sustainable economic growth, and reduce the risk of moral hazard.
• Capital Requirements: The minimum capital ratios are set at a level that is lower than some academic estimates but higher than pre-crisis standards. These requirements are not the only factor influencing capital management, as banks also consider market expectations and credit rating agency (CRA) standards.
• Impact on Lending: The empirical analysis suggests that the increase in capital requirements has had a moderate negative impact on loan supply in the short term, but the long-term effects are expected to be net positive. The impact is more pronounced for undercapitalised banks and those with higher non-performing loan (NPL) ratios.
• Supply-Side Constraints: The transition to higher capital requirements involves costs such as increased capital generation and market absorption, which should be phased in to avoid excessive short-term disruption.
• Macroprudential Buffers: These buffers are intended to complement regulatory capital requirements by addressing systemic risks. They have been introduced in some EU countries, but their impact on current lending is limited as capital levels already exceed these requirements.

Key Information

Capital and Lending Dynamics

• Short-term Impact: Increased capital requirements led to a tightening of credit conditions, with some studies indicating a reduction in lending volumes ranging from -1.40% to -8.40% depending on the time horizon.
• Long-term Impact: In the steady state, the effect on lending rates is relatively small, ranging from +0.03pp to +0.15pp. The long-term impact on lending volumes is expected to be low as banks adjust to new capital standards and regain access to capital markets.
• Distributional Effects: The impact of higher capital requirements may be distributional, with higher effects on SME lending compared to less risky borrowers such as mortgage holders.

Securitisation and Capital Treatment

• Post-Crisis Review: Securitisation was heavily scrutinized due to its role in the financial crisis. While some securitisation structures performed poorly, others such as covered bonds and ABS were resilient.
• Capital Charges: The revised Basel III framework introduced more risk-sensitive capital charges and reduced reliance on external ratings. However, it still fails to fully account for the qualitative features of securitisation.
• STS Securitisations: The ECB supports the EBA’s proposal to allow simple, transparent, and standardised (STS) securitisations to be subject to lower capital requirements, reflecting their reduced risk profile.

Regulatory and Supervisory Influence

• Supervisory Actions: The ECB’s Comprehensive Assessment (CA) and other stress tests played a significant role in improving banks' capital positions, with €200 billion of capital strengthening undertaken.
• Government Interventions: Government support and market pressures also influenced banks’ capital levels, especially during the crisis.
• Funding Costs: Undercapitalised banks face higher funding costs, which may lead to tighter credit conditions and customer switching to better-capitalised institutions.

Future Considerations

• Regulatory Calibration: The ECB recommends that the Commission continuously review the calibration of post-crisis regulations to ensure net benefits to society.
• Phasing In: A phased-in approach is necessary to allow banks to adjust to new capital requirements without causing undue short-term disruption.
• Macroprudential Integration: The ECB highlights the importance of integrating macroprudential buffers into the regulatory framework to address systemic risks and interconnectedness.

Conclusion

The ECB remains strongly supportive of the CRR/CRD IV regulations, viewing them as a critical step in enhancing the resilience of the EU banking sector. While there are short-term costs associated with the transition, the long-term benefits in terms of financial stability and reduced systemic risk are expected to outweigh these costs. The ECB encourages the Commission to continue reviewing and refining the regulatory framework to ensure it remains effective and aligned with evolving economic conditions.