BIS国际清算银行-Reflections-on-regulatory-responses-to-the-Covid-19-pandemic_9页_327kb

报告摘要

FSI Briefs Summary: Reflections on Regulatory Responses to the Covid-19 Pandemic

Core Content

This FSI Brief discusses the regulatory and supervisory responses to the economic impact of the Covid-19 pandemic, focusing on the balance between supporting economic activity and preserving the stability and transparency of the financial system. The authors, Claudio Borio and Fernando Restoy, highlight the need for a principled approach to policy adjustments, ensuring that they do not undermine long-term financial credibility or lead to excessive risk-taking.

Main Viewpoints

Supporting Economic Activity: Regulatory measures should aim to support economic activity, especially during crises, while maintaining the soundness of the financial system.
Flexibility and Transparency: Flexibility in regulatory requirements and accounting standards is essential, but it must be accompanied by transparency to avoid undermining credibility.
Avoiding Moral Hazard: Policies that ease standards during downturns must not create an expectation of future relaxation, which could lead to excessive risk-taking.
Procyclicality Concerns: The financial system has historically been procyclical, meaning it tends to tighten credit during downturns and loosen it during upturns. Regulatory adjustments should aim to mitigate this.

Key Information

1. Regulatory Measures Implemented

Jurisdiction	Government Guarantees	Capital Requirements	Asset Classification	Expected Loss Provisioning	Dividends and Other Payouts
Australia	Yes	Encouragement to use buffers	New guidance	-	Expectation to limit
Canada	Yes	Lower Domestic Stability Buffer, Encouragement to use buffers	New guidance	New guidance, Transitional arrangements	Expectation to halt increases
EU/SSM	Yes (*)	Release CCyB, Encouragement to use buffers	New guidance	New guidance	Expectation to halt
Japan	Yes	Encouragement to use buffers	Adjust risk weights of certain loans	-	-
United Kingdom	Yes	Release CCyB, Encouragement to use buffers	New guidance	New guidance	Expectation to halt
United States	Yes	Encouragement to use buffers, Adjust supplementary leverage ratio	New guidance, Definition of restructured debt	Optional suspension, Extension of transitional arrangements	Expectation of prudent decisions, Smoothing of automatic restrictions

Note: (*) indicates that conditions vary across member countries.

2. Principles for Assessing Adjustments

Principle 1: Adjustments should be effective in supporting economic activity, especially during the crisis and beyond.
Principle 2: Adjustments must preserve the health of the banking system, ensuring it remains sufficiently capitalised, liquid, and profitable.
Principle 3: Adjustments should not undermine the long-term credibility of financial policies. They should be seen as temporary and transparent.

3. Prudential Regulation and Supervision

The Basel III countercyclical capital buffer is the most appropriate tool for supporting lending during downturns. It is designed to accumulate capital in good times and draw it down in bad times.
The conservation buffer also plays a role in maintaining banks' intermediation function during crises.
Pillar 2 add-ons can be used as buffers to absorb losses in adverse scenarios, provided they are not used to compensate for deficiencies in Pillar 1 minima.
Government guarantees and payment holidays have been implemented to support lending, but they must be carefully designed to avoid moral hazard.

4. Accounting Standards for Expected Losses

Accounting standards aim to provide an accurate representation of firms' financial conditions, while prudential regulation focuses on promoting financial soundness.
The expected loss provisioning approach in IFRS and US GAAP is a forward-looking method that requires banks to provision for losses before they occur.
This approach can amplify procyclicality in the case of unexpected shocks like the pandemic, as provisions cannot be made in advance.
Transitional arrangements and pragmatic guidance have been used to mitigate the unintended effects of the new standards.

5. Conclusion

Regulatory responses to the pandemic must be bold and effective but should not compromise the stability and transparency of the financial system. The guidance option, combined with adjusted transitional arrangements, is seen as a balanced approach that supports economic activity without undermining long-term credibility.

References

Basel Committee on Banking Supervision (2020): "Measures to reflect the impact of Covid-19"
Borio, C (2019): "New loan provisioning standards and procyclicality"
Borio, C, C Furfine and P Lowe (2001): "Procyclicality of the financial system and financial stability"
Borio, C and K Tsatsaronis (2004): "Accounting and prudential regulation"
Carstens, A (2020): "Bold steps to pump coronavirus rescue funds down the last mile"
European Systemic Risk Board (2019): "The cyclical behaviour of the ECL model in IFRS 9"
Financial Stability Forum (2009): "Report of the Financial Stability Forum on addressing procyclicality in the Financial System"
Office of the Superintendent of Financial Institutions (2020): "OSFI actions to address operational issues stemming from COVID-19"
Restoy, F (2010): "Accounting, convergence, governance and regulation"
Restoy, F and J Roldán (2008): "Dynamic provisioning and accounting"
Restoy, F and R Zamil (2017): "Prudential policy considerations under expected loss provisioning"