2012年-CEPS欧洲政策研究中心_The_Commissions_CRD_IV_requires_a_deeper_reading_2页_116kb

CRD IV Summary: A Call for Thorough Review and Reform

Core Content

The Capital Requirements Directive IV (CRD IV) is a major regulatory reform that implements Basel III in EU law. It is the most substantial post-crisse measure and addresses the critical issue of low bank capital levels in the EU financial system, which contributed to the crisis. The document emphasizes the need for the European Parliament (EP) and EU Council to conduct a more rigorous and comprehensive review of CRD IV to ensure it is both effective and aligned with the broader goals of financial stability and resilience.

Main Points and Key Issues

CRD IV is a complex regulatory framework, consisting of a Regulation with 488 articles and 4 annexes, and a Directive with 154 articles and 1 annex, totaling approximately 220,154 words. This complexity poses challenges for legislative bodies, particularly the EP, which should ensure that the directive is properly scrutinized and not rushed into law.

1. Risk-Weighting for Sovereign Exposures

• The current zero risk weighting for EU government debt remains unchanged in the EP's initial review.
• This approach is criticized for unduly penalizing banks that lend to the real economy, as opposed to sovereigns.
• The document calls for a reevaluation of sovereign risk-weighting to better reflect the actual risk involved.

2. Leverage Ratio

• The leverage ratio should play a more central role in capital adequacy assessments than currently proposed.
• The current reliance on the risk-weighted core tier 1 ratio is seen as misleading, as demonstrated by the failure of Dexia, a bank with a high core tier 1 ratio but low tangible equity.

3. External Credit Ratings-Based Approach

• The role of credit ratings agencies in determining risk weights remains unchanged.
• Despite the European Commission's efforts to reduce reliance on these agencies, they continue to have a significant regulatory influence.

4. Real Estate Risk-Weighting

• Real estate exposures are still given more favorable risk-weighting than other types of exposures.
• This is in contradiction with the principle of maximum harmonization and may encourage excessive risk-taking.
• The document suggests that real estate risk-weighting should be based on actual costs rather than arbitrary assumptions.

5. Maximum Harmonisation Approach

• The EP and EU Council are urged to adopt a stronger stance on the maximum harmonisation approach.
• This approach aims to standardize capital requirements across the EU, but it is difficult to justify in the context of capital regulation.
• The document argues that allowing banks to compete based on higher capital levels would enhance financial stability.

Conclusion

The author highlights the need for the EP and EU Council to take a firm and responsible approach in reviewing CRD IV, rather than yielding to external pressures or political compromises. The current draft is seen as a missed opportunity to significantly strengthen the EU's banking regulations, particularly in areas such as risk-weighting, leverage ratio, and real estate exposure. The EP's initial review is criticized for being too lenient, especially in comparison to its 2005 handling of CRD I, which led to the inclusion of trading book provisions without adequate discussion. The author concludes that CRD IV should be thoroughly examined to ensure it addresses the core issues of the EU financial system and prevents future crises.