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报告摘要

FSI Briefs No 6: Banks' Dividends in Covid-19 Times

Core Content

This FSI Brief examines the regulatory and supervisory approaches to capital distribution (dividends, share buybacks, and bonuses) by banks during the Covid-19 pandemic. It highlights the tension between maintaining lending capacity and preserving bank solvency, and discusses how Basel III capital buffer requirements and distribution constraints interact with these objectives. The Brief also reviews how different jurisdictions have implemented these measures, emphasizing the divergence in scope, severity, and duration.

Main Views

Preserving Lending Activity and Solvency: Regulatory actions should focus on ensuring banks can continue lending without compromising their solvency. This requires a balance between flexibility in capital requirements and capital conservation.
Basel III Distribution Constraints: Under Basel III, when capital buffers are depleted, banks face automatic constraints on capital distributions. The Maximum Distribution Amount (MDA) is calculated based on earnings and is subject to reduction as buffers are used.
Capital Conservation Buffer (CCoB): A permanent buffer of 2.5% of RWA is required under Basel III. It is used to limit distributions when capital ratios fall below the total capital requirement, including buffers.
System-Wide and Individual Buffers: Basel III also provides for a countercyclical buffer (CCyB) and a buffer for global or domestic systemically important banks (G-SIBs or D-SIBs). These buffers vary in their application and requirements.
Supervisory Flexibility: Authorities have taken various supervisory actions to support capital conservation, such as suspending or restricting dividends, buybacks, and bonuses. These actions are often non-discriminatory and aim to avoid stigmatizing banks with low capital positions.

Key Information

Basel III Capital Buffer Requirements

Total Minimum Capital Requirement: 8% of RWA, composed of Pillar 1 (4.5% CET1) and Pillar 2 (additional capital).
Capital Conservation Buffer (CCoB): 2.5% of RWA, must be met with CET1 not already used for Pillar 1 or 2.
Countercyclical Capital Buffer (CCyB): Fluctuates between 0% and 2.5% of RWA, based on systemic risk assessment.
G-SIB and D-SIB Buffers: Vary based on systemic importance, with G-SIBs ranging from 1% to 3.5% of RWA.

Distribution Constraints

MDA Calculation: Based on a bank's earnings, with a reduction of 20 percentage points per buffer depletion.
Automatic vs. Supervisory Action: Distribution constraints apply automatically when buffers are used, but supervisory actions may be required for certain cases.
Exclusions from MDA: Dividends declared in line with MDA and non-discretionary payments that cannot be canceled without default.

Jurisdictional Implementation

United States: Introduced two methods for MDA calculation to make distribution constraints more gradual.
European Union: Imposed restrictions on CET1, AT1, and bonuses, with a focus on preventing buffer depletion.
China: Did not impose additional restrictions on dividends or buybacks.
India and Russia: Suspended dividends until September 2020.
United Kingdom: Cancelled outstanding 2019 dividends and suspended 2020 distributions.
Japan, Singapore, South Africa, and Switzerland: Implemented restrictions on dividends and bonuses, but not on buybacks.
Brazil: Suspended dividends and limited buybacks to 5% of stock.

Supervisory Actions

Scope: Some jurisdictions restrict all types of distributions, while others apply different rules to dividends and buybacks.
Severity: Some authorities suspend all distributions, while others issue recommendations to limit increases.
Duration: Restrictions are either fixed (e.g., until mid-2020) or open-ended, depending on the jurisdiction.
Retroactive Measures: The UK is unique in canceling outstanding 2019 dividends.

Conclusion

The Brief concludes that while many authorities have taken measures to restrict capital distributions in response to the pandemic, these measures are not uniform across jurisdictions. The need for capital conservation is widely recognized, but the application varies significantly. The overall objective is to support banks in maintaining lending activity and avoiding excessive deleveraging, while ensuring financial stability.