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1 The impact of the 1988 Basel Accord on banks’ capital ratios and credit risk-taking: an international study 1 Patrick Van Roy (*) European Center for Advanced Research in Economics and Statistics (ECARES), Université Libre de Bruxelles Av. F.D. Roosevelt 50, CP 114 1050 Brussels, Belgium This draft: December 2003 Abstract The purpose of this paper is to see whether and how G-10 banks have complied with the 1988 Basel Capital Accord. The interest of this study lies in the fact that the standardized approach of the New Basel Accord is similar to the 1988 agreement. However, very little is known about the reaction of non-US banks to the imposition of fixed minimum capital requirements. Building on previous studies, this paper uses a simultaneous equations model to analyze adjustments in capital and portfolio risk at banks from G-10 countries over the period 1988-95. The results suggest that banks close to the Basel standards have generally increased their capital adequacy ratios without any offsetting increases in portfolio risk. In addition, a negative correlation is found between changes in capital and risk ratios suggesting that, everything else being equal, the capital build-up of the early 1990s was associated with a decrease in the credit risk-taking of G-10 banks. Keywords: Capital requirements; Credit risk; Bank regulation JEL classification: G21; G28 1 I would like to thank participants at the 10 th ENTER Jamboree (Tilburg University, The Netherlands), the 8 th Belgian Financial Research Forum (Limburgs Universitair Centrum, Belgium), the 4 th Conference of the International Economics and Finance Society – UK Chapter (City University, UK) as well as many colleagues from ECARES for helpful comments and suggestions on earlier drafts. The assistance of Bureau Van Dijk in providing the data used in this study is also gratefully acknowledged. (*) Research Fellow, Fonds National de la Recherche Scientifique. Tel: + 322 650 34 69; Fax: + 322 650 33 69; E-mail address: [email protected].

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Page 1: The impact of the 1988 Basel Accord on banks’ capital ratios and … · the context of the Basel Accord. Section 3 presents the data used in this study, while section 4 outlines

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The impact of the 1988 Basel Accord on banks’ capital ratios

and credit risk-taking: an international study 1

Patrick Van Roy (∗)

European Center for Advanced Research in Economics and Statistics (ECARES),

Université Libre de Bruxelles

Av. F.D. Roosevelt 50, CP 114 1050 Brussels, Belgium

This draft: December 2003

Abstract

The purpose of this paper is to see whether and how G-10 banks have complied with the 1988 Basel Capital Accord. The interest of this study lies in the fact that the standardized approach of the New Basel Accord is similar to the 1988 agreement. However, very little is known about the reaction of non-US banks to the imposition of fixed minimum capital requirements. Building on previous studies, this paper uses a simultaneous equations model to analyze adjustments in capital and portfolio risk at banks from G-10 countries over the period 1988-95. The results suggest that banks close to the Basel standards have generally increased their capital adequacy ratios without any offsetting increases in portfolio risk. In addition, a negative correlation is found between changes in capital and risk ratios suggesting that, everything else being equal, the capital build-up of the early 1990s was associated with a decrease in the credit risk-taking of G-10 banks. Keywords: Capital requirements; Credit risk; Bank regulation JEL classification: G21; G28

1 I would like to thank participants at the 10th ENTER Jamboree (Tilburg University, The Netherlands), the 8th Belgian Financial Research Forum (Limburgs Universitair Centrum, Belgium), the 4th Conference of the International Economics and Finance Society – UK Chapter (City University, UK) as well as many colleagues from ECARES for helpful comments and suggestions on earlier drafts. The assistance of Bureau Van Dijk in providing the data used in this study is also gratefully acknowledged. (∗) Research Fellow, Fonds National de la Recherche Scientifique. Tel: + 322 650 34 69; Fax: + 322 650 33 69; E-mail address: [email protected].

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1. Introduction

One of the major developments undergone by the banking industry over recent years has been

the worldwide implementation of the so-called Basel Accord that sets minimum capital

standards for internationally active banks. The Basel guidelines were originally adopted by

the central banking authorities from 12 countries (all G-10 countries plus Luxembourg and

Switzerland) in July 1988. Their implementation started in 1989 and was completed 4 years

later, in 1993. The purpose of the Accord was twofold. First, it aimed at creating a level

playing field among banks by raising capital ratios, which were generally perceived as too

low in many countries. Second, and linked to this, it aimed at promoting financial stability by

adopting a relatively simple approach to credit risk with the potential to distort incentives for

bank risk-taking.

Fifteen years after the adoption of the Basel Accord and whilst new regulatory guidelines are

being designed, it is fair to say that empirical research has failed to answer the following

questions: was the 1988 agreement effective in raising capital ratios among banking

institutions falling below the minimum requirements? How did banks respond to the capital

adequacy rules, i.e. did they increase their level of capital, forgo risky projects or sell off

assets? Did the new guidelines induce banks to modify the credit risk of their portfolio and if

so, to which risk categories did they reallocate their assets? Analysis of how G-10 banks have

responded to the 1988 risk-based standards is of course crucial if one wants to gain insight

into the likely implications of the New Basel Capital Accord.

The lack of answers to the questions raised above is largely due to the limited amount of data

on capital levels and risky assets of G-10 banks. Indeed, these data are mainly confidential or

hard to obtain on a standardized cross-country basis. Most studies focus on the US, while

evidence has remained scarce for other countries that were part of the Accord.

Therefore, an important contribution of this paper is to shed further light on the impact of the

1988 Basel Accord using data from 7 different countries: Canada, France, Italy, Japan,

Sweden, the UK and the US. More precisely, I extend the simultaneous equations model

developed by Shrieves and Dahl (1992) to a multi-country setting in order to analyze the

relationship between changes in capital ratios and credit risk at the G-10 level. The model

also allows for cross-country comparisons of undercapitalized banks’ behavior towards

capital and risk.

The results show that changes in the capital and credit risk ratios of G-10 banks were

negatively related over the 1988-95 period. In addition, the findings indicate that banks close

to the Basel minimum requirements increased their capital ratios (except in France and Italy),

whereas there is only weak evidence for a rise in their credit risk-taking. All in all, this

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suggests that the beginning of the 1990s was a period of increased stability for the G-10

banking industry.

The remainder of the paper is organized as follows. Section 2 reviews the theoretical and

empirical literature dealing with the effects of capital requirements on banks’ portfolio risk, in

the context of the Basel Accord. Section 3 presents the data used in this study, while section 4

outlines the empirical methodology. Results are discussed in section 5 and some conclusions

are drawn in section 6.

2. Bank capital regulation and its impact on banks’ risk-taking in theory and in

practice

2.1. Theoretical review

The main justification for regulating bank capital is the need to avoid the risk-shifting

incentive generated by improperly priced deposit insurance. Indeed, although it may promote

financial stability in the short-run, risk-insensitive deposit insurance tends to reduce banks’

incentives to maintain adequate capital and may thus endanger stability in the long-run. The

ability of capital standards to successfully eliminate this “moral hazard” problem, thereby

reinforcing the effect of a higher capital ratio on default risk, has been at the heart of a

theoretical debate for more than 20 years.

A first strand of the literature focuses on utility-maximizing banks using the portfolio

approach of Pyle (1971) and Hart and Jaffee (1974). In this framework, Koehn and

Santomero (1980) show that the introduction of higher leverage ratios will lead banks to shift

their portfolio to riskier assets and that the reshuffling effect will be larger for institutions

which initially held relatively more risky assets per unit of capital. This effect occurs because

flat requirements restrict the banks’ risk-return frontier, which leads them to compensate the

loss in utility from the upper limit on leverage with the choice of a riskier portfolio. One way

to eliminate the risk-shifting incentive is to require banks to meet risk-related capital ratios, as

suggested by Kim and Santomero (1988).

These conclusions have been questioned on several grounds. Using an option model, Furlong

and Keeley (1989) and Keeley and Furlong (1990) find that higher capital requirements

reduce the incentives for a value-maximizing bank to increase asset risk. They contend that

the utility-maximization framework, which reaches opposite conclusions, is inappropriate

because it does not adequately describe the bank’s investment opportunity set by neglecting

the option value of deposit insurance and the possibility of bank failure. Within the same

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modeling framework, Gennotte and Pyle (1991) relax the assumption that banks invest in zero

net present value assets and find that there are now plausible situations in which an increase

in capital requirements results in an increase of asset risk.

The portfolio approach is used again by Rochet (1992) who shows that when the limited

liability of banks is taken into account, insufficiently capitalized banks may exhibit risk-

loving behavior even if regulation makes use of a risk-related capital ratio. As a consequence,

it may be necessary to impose an additional requirement, in the form of a minimum capital

level.

More recently, Blum (1999) also finds that capital regulation may increase banks’ riskiness

but in a dynamic framework. Using a two-period model, he shows that an intertemporal effect

has to be considered in addition to the standard negative effect of capital regulation on credit

risk. If banks find it too costly to raise additional equity to meet new capital requirements

tomorrow or are unable to do so, they will increase risk today. This second effect will

reinforce the well-known risk-shifting incentive due to the reduction in profits.

In short, economic theory is unclear on whether imposing harsher capital requirements leads

banks to increase or decrease the risk structure of their asset portfolio. Answering this issue is

important as the probability of default of a bank depends positively on its leverage and on its

portfolio risk. If capital requirements increase asset risk, their net effect on the probability of

bankruptcy, hence on financial distress, will be ambiguous.

The next subsection attempts to clarify the debate about the risk effects of capital regulation

by briefly restating the key rules of the 1988 Basel Accord and observing how banks can

comply with them.

2.2. Capital requirements in practice: The 1988 Basel Accord

The 1988 Basel standards are almost entirely focussed on credit risk,2 the risk of loss due to

borrower or counterparty default. An amendment to incorporate market risk has been issued

in 1996, while the Basel Committee on Banking Supervision has submitted a proposal for a

New Basel Accord in 1999. This proposal is based on three mutually reinforcing pillars

(minimum capital requirements – supervisory review – market discipline) that allow banks

and supervisors to evaluate additional types of risks, like operational risk and interest rate

risk, thereby avoiding treating portfolio risk in isolation. Implementation of the New Accord

(though probably not by all adopting countries) is expected by year-end 2006.

2 The terms “credit risk” and “portfolio risk” are used interchangeably throughout the paper.

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The key to the 1988 Basel Accord is the obligation for internationally active banks to

continually meet two capital adequacy ratios, the so-called tier 1 and total capital ratios. Both

ratios have the same denominator, which is a risk-weighted sum of banks’ on-balance and off-

balance sheet activities. A simplified formula of the risk-weighted assets (RWA) of a bank is

given by:3

RWA=0*(bucket 1) + 0.2*(bucket 2) + 0.5*(bucket 3) + 1.0*(bucket 4) [1]

where bucket 1 consists of assets with zero default risk (e.g. cash, government bonds /

securities), bucket 2 of assets with a low rate of default (e.g. loans to OECD banks), bucket 3

of medium-risk assets (essentially residential mortgage loans) and the remaining assets (in

particular loans to non-banks) fall into bucket 4. The denominator of both capital adequacy

ratios thus represents the accounting value of banks’ assets adjusted for their individual risk.

The tier 1 ratio and the total capital ratio differ by their numerator. The numerator of the

former ratio consists only of tier 1 capital while the numerator of the latter ratio includes both

tier 1 and tier 2 capital. Tier 1 capital, also called “core capital”, consists mainly of

stockholder equity capital and disclosed reserves whereas tier 2 capital or “supplementary

capital” includes elements like undisclosed reserves and subordinated term debt instruments

(provided that their original fixed term to maturity does exceed five years). The difference

between tier 1 and tier 2 capital thus reflects the degree to which capital is explicit or

permanent. Total capital is the sum of tier 1 and tier 2 capital.

The 1988 capital adequacy guidelines require banks to have a tier 1 ratio of at least 4% and a

total capital ratio of at least 8% with the contribution of tier 2 capital to total capital not

exceeding 50%, i.e., the following inequalities must hold:

Tier 1 ratio = Tier 1 capital / RWA ≥ 0.04 [2]

Total capital ratio = Total capital / RWA = (Tier 1 capital + Tier 2 capital) / RWA ≥ 0.08 [3]

Tier 1 capital ≥ Tier 2 capital [4]

The regulation also limits general loan-loss reserves and subordinated debt that can be eligible

for inclusion in tier 2 capital (see Appendix 1). The implementation of the Basel guidelines in

G-10 countries occurred in two steps. Interim standards of 7.25% for the total capital ratio and

3 Strictly speaking, formula [1] is only valid for on-balance sheet assets. Off-balance sheet items are also assigned to four risk buckets but they involve additional weights reflecting the nature of the operation. See Dewatripont and Tirole (1994, pp. 52-53) for the precise regulatory definition of RWA.

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3.25% for the tier 1 ratio had to be met by the end of 1990, whereas full compliance with the

definitive standards was expected by year-end 1992.

Banks that wish to raise their capital adequacy ratio (either to obey the minimum

requirements or for other non-regulatory reasons) can use three types of balance-sheet

adjustments. They can increase their capital level (depending on the regulatory ratio

concerned, this can be done in several ways), decrease their risk-weighted assets as a

proportion of total assets and / or decrease their total assets. This is summarized in equation

[5], which decomposes the growth rate of the capital adequacy ratio into three terms: the

growth rate of capital, the growth rate of the credit risk ratio and the growth rate of assets - a

proof is given in Appendix 2:

t t t t

t t t t

CAR K RISK A= - -

CAR K RISK A∆ ∆ ∆ ∆

[5]

where CAR = K / RWA = capital adequacy ratio (tier 1 ratio or total capital ratio)

K = capital (tier 1 capital or total capital)

RISK = RWA / A = credit risk ratio

A = total assets

t denotes time

From equation [5], it can be seen that a (mandatory) increase in the capital adequacy ratio

does not prevent banks from raising the credit risk of their portfolio provided that the growth

rate of the credit risk ratio is lower than the growth rate of capital.4 Thus, the Basel Accord,

which aimed at imposing a higher capital buffer against insolvency, may well have

encouraged banks to take on more credit risk, thereby having an ambiguous effect on their

probability of failure.

In the remainder of the paper, I focus on the relationship between changes in capital and risk

ratios.5 Furthermore, I analyze the behavior of banks which are close to the minimum capital

requirements, as they can be reasonably expected to have had a stronger and faster response

to the Basel Accord than better capitalized institutions.

4 Holding total assets constant. 5 Other strands of the empirical literature have looked at the effect of capital requirements on capital levels “K” and on total assets “A”. For a review of both types of studies, see Basel Committee on Banking Supervision (1999).

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2.3. Review of the related empirical literature

The main papers that investigated the impact of the Basel capital requirements on banks’

credit risk-taking are listed in Table 1. With the exception of Ediz et al. (1998), all use the

simultaneous equations approach that is described in section 4. This modeling framework

allows to compare the behavior of undercapitalized and adequately capitalized banks with

respect to changes in capital and risk ratios and to see whether these changes are related.

(insert Table 1 here)

The studies surveyed in Table 1 generally support the idea that undercapitalized banks (i.e.,

those failing to achieve the Basel requirements) increased their capital adequacy ratios in the

first half of the 1990s. A similar phenomenon, although to a lesser extent, is observed for

adequately capitalized institutions. The latter result is consistent with an idea that will be used

when modeling regulatory pressure, namely that banks tend to be well above the minimum

requirements for precautionary and / or reputational reasons. Furthermore, there is little

consensus among the papers reviewed on whether banks – adequately capitalized or not –

engaged in riskier activities. Finally, changes in capital ratios and credit risk appear to be

mostly unrelated.

Results of US studies are difficult to interpret as the implementation of the second stage of the

Basel Accord, between end-1990 and end-1992, coincide with the passage of the Federal

Deposit Insurance Corporation Improvement Act (FDICIA) in December 1991. Section 131

of FDICIA, Prompt Corrective Action (PCA), goes one step further than the Basel Accord by

defining three regulatory ratios (the Basel capital standards plus a leverage requirement) and

five categories into which banks are classified according to their compliance with the three

ratios. Thus, it is hard to ascribe the findings of the two papers by Aggarwal and Jacques

(1997, 2001) to the Basel Accord as opposed to FDICIA, as US banks’ behavior is likely to

have been affected by both regulations over the period that they consider. However, this is not

a too big problem to the extent that one is interested in the effects of capital regulation in a

broad sense. The study by Jacques and Nigro (1997) deals exclusively with the consequences

of the Basel Accord, as it concentrates on the years 1990-91, i.e. the period before FDICIA

was passed. However, the very small number of undercapitalized institutions in Jacques and

Nigro’s sample - less than 2% of the total number of banks - may reduce the reliability of

some of their estimates.

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Two papers present some non-US evidence regarding the relationship between capital ratios

and credit risk. Ediz et al. (1998) base their study on confidential UK data whereas Rime

(2001) uses Swiss data. Like other studies listed in Table 1, the first of these two papers uses

a partial adjustment framework but, unlike them, treats changes in capital and risk-taking as

two separate decisions. Unfortunately, Ediz et al.’s model leads to the puzzling result that

banks adjust their capital levels each year by more than the difference between the current

level and the target they have in mind, which means that banks overshoot the target (and by a

higher amount each year). The study by Rime (2001) is interesting because it provides the

first application of the simultaneous-equations model reviewed in section 4 to non-US banks.

However, Rime adopts the PCA regulatory classification to measure regulatory pressure on

Swiss banks, which might be inappropriate given that the additional requirements set by PCA

have not been adopted formally by any other country besides the US.6

Finally, a paper by Sheldon (1996) – not listed in Table 1 – looks at the risk effects of capital

adequacy on eleven G-10 countries using an option-pricing framework. Sheldon’s main result

is that the Basel Accord did not have a risk-increasing impact on banks’ portfolio but is a bit

difficult to interpret, as he is does not control for regulatory and non-regulatory influences.

Moreover, his sample is not always representative of the banking industry of each G-10

country, as some countries are only represented by very small banks.

Therefore, the main contribution of this study is to extend the empirical literature on the

effects of the Basel Accord using a simultaneous-equations model for seven different

countries along with a representative data set, the construction of which is detailed in the next

section.

3. Data sources and description

3.1. Sources

Data were obtained from Bankscope, a database of bank account figures which is a joint

product of Fitch Ratings and Bureau Van Dijk, a major rating agency and a publisher of

financial databases on CD-ROM, respectively. Consistent with most studies on the impact of

6 Rime also uses a regulatory pressure variable relatively similar to mine, which does not alter his results.

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the Basel requirements, I chose to restrict the sample to commercial banks over the 1988-95

period.7

3.2. Methodology

All the variables used in this study were available on Bankscope, except the credit risk ratio

of banks. Therefore, capital adequacy ratios (CAR), capital levels (K) and total assets (A)

were extracted from the database in order to compute the credit risk ratio (RISK) using the

following formulas:

K K= = RWA

KCARRWA

[6]

RWA= RISK

A [7]

Equation [6] can be computed in two different ways, either using tier 1 data (i.e., K = tier 1

capital and CAR = tier 1 ratio) or using total capital data (i.e., K = total capital and CAR =

total capital ratio). Obviously, both methods yield the same value for risk-weighted assets. In

order to check for consistency of the results, I computed the credit risk ratio using both

methods except for Japanese banks, which generally do not report their total capital.

3.3. Sample Statistics

Using the data from Bankscope, I constructed an unbalanced panel containing 586

commercial banks from seven G-10 countries with assets of more than $ 100 million during

the period 1988-95. Banks that did not report their total capital ratio, their tier 1 ratio or their

credit risk ratio for at least 2 consecutive years were omitted from the data set. Also, banks

with a capital ratio above 50% or a credit risk ratio above 200% were treated as outliers and

excluded from the sample.

(insert Table 2 here)

7 Data on capital adequacy are not available for years prior to 1988, preventing any comparison with the pre-Basel period. The choice of 1995 is somewhat arbitrary but quite standard given that most studies on the impact of the Basel Accord focus on the first half of the 1990s. In the case of the US, Flannery and Rangan (2002) have shown that none of the 100 largest banking firms appears to have been constrained by regulatory capital requirements since 1995.

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The second column of Table 2 shows the distribution of banks by country. Unfortunately,

Bankscope does not contain data on the capital levels of Belgian, Dutch, Luxembourg,

German and Swiss commercial banks over the period of interest, which prevents the

computation of their risk-weighted assets using equation [6]. This explains why the analysis is

limited to the remaining seven G-10 countries. Unsurprisingly, Japanese and US banking

institutions constitute the vast majority of the sample.

The remainder of Table 2 indicates that the sample is in fact quite representative of each

national banking sector. With the exception of the UK, the data set includes at least 7 of the

10 biggest commercial banks (in terms of assets) of each country. Moreover, the sum of

sample banks’ assets almost always exceeds half of the total national banking assets.

(insert Table 3 here)

Table 3 lists the average total capital ratio, tier 1 ratio and credit risk ratio of each country

between 1988 and 1995. The comparability of the figures displayed in the table is not

guaranteed since the number of observations is increasing over time.8 Nevertheless, some

tentative remarks can be made.

First, the tier 1 ratio and the total capital ratio of all countries are far above their minimum

required levels of 4% and 8%, respectively. Moreover, both series are upward trending across

the years 1988-93, with no significant increase afterwards. Two groups of countries coexist in

the sample: those with relatively low capital adequacy ratios throughout the whole period

(Canada, France and Japan) and those that exhibit higher figures for both regulatory ratios

(Italy, Sweden, the UK and the US).

Second, with respect to credit risk, some countries (Canada, the UK and possibly the US)

appear to have experienced a decrease in their banking portfolio risk whereas others (France,

Italy, Japan and Sweden) have seen their credit risk ratio remaining relatively constant. Once

again, the sample can be divided into two groups of countries: those with an average credit

risk ratio varying between 50% and 60% (France, Italy, Sweden and perhaps the UK) and

those with a credit risk ratio equal or higher than 70% (Canada, Japan and the US). At first

glance, it might be tempting to attribute the higher credit risk ratio of these 3 countries to their

pre-1988 capital adequacy rules. Indeed, until the Basel guidelines were adopted, simple

gearing ratios were in force in Canada, Japan and the US (Pecchioli, 1987), which may

account for their historically higher level of credit risk. But then, the 1988 Accord should

have led to a decrease in the credit risk ratio of these countries as risk-based standards take

8 G-10 banks started to implement the Basel standards only gradually, which explains the low number of observations at the end of the 1980s. The slightly lower number of banks in 1994 and 1995 is due to a few mergers, which were not motivated by the level of capitalization of merging banks.

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into account the composition of a bank’s portfolio when assessing capital charges. However,

Table 3 (Panel C) provides mixed support for this hypothesis: Canadian banks did indeed

experience a decrease in their portfolio risk whereas the level of risk-taking of Japanese

institutions remained fairly constant. The increasing number of observations for the US

prevents any reliable comparison.

On the whole, Table 3 suggests that the seven G-10 countries have raised their capital

adequacy ratios during the 1988-93 period whereas no specific trend could be found in the

credit risk series. Table 4 presents further descriptive statistics on the relationship between

capital and risk, by decomposing the average annual growth rate of the total capital ratio and

of the tier 1 ratio into three terms, as in equation [5].

(insert Table 4 here)

As can be seen from Table 4, the growth rate of both ratios over the sample years is roughly

similar and is mainly driven by a rise in capital levels, which offsets the rise in total assets.

The growth rate of the credit risk ratio is close to zero for all countries except Canada,

Sweden and the UK. However, Tables 3 and 4 do not tell us whether ∆CAR and ∆RISK are

related, nor whether the increase in capital adequacy ratios that took place between 1988 and

1993 was due to the introduction of capital adequacy rules. Indeed, it could be the case that

banks that were not part of the Basel Accord also decreased their leverage.

(insert Figure 1 and Figure 2 here)

Figure 1 shows that a rise in the equity to asset ratio9 was not only experienced by G-10 banks

at the beginning of the 1990s, but also by non G-10 banks and even by banks from countries

where capital adequacy rules were not put in place before 1993.10 In a similar way, Figure 2

indicates that the reliance of these three groups of banks on subordinated debt11 – a key

component of tier 2 capital – was roughly similar throughout the period surveyed.

9 The equity to asset ratio is a very rough approximation of the tier 1 ratio, as its numerator does not include disclosed reserves and its denominator does not assign different weights to the different asset categories. 10 The use of this third group of banks is motivated by the fact that a large number of non G-10 countries did adopt Basel-like rules between 1988 and 1993. I consider that a country has not implemented the Basel Accord before 1993 if its banks did not report a capital adequacy ratio before that year. 11 Expressed as a percentage of total assets. Note that Figure 2 does not distinguish between subordinated debt with a term to maturity of less or more than five years. Only the latter category is allowed to count as tier 2 capital, along with other elements (cf. section 2.2).

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Thus, determining whether the Basel agreement caused changes in capital and risk ratios of

G-10 banks and whether these changes were related requires a more complex econometric

analysis than just looking at descriptive statistics. The following section sets up a model that

aims at assessing the empirical determinants of observed changes in capital and risk ratios

with a particular emphasis on the role played by capital adequacy rules.

4. The model

In order to acknowledge that capital and risk decisions are determined together, I extend the

simultaneous equation model developed by Shrieves and Dahl (1992) to a multi-country

setting. In this model, observed changes in banks’ capital and credit risk ratios consist of two

components, a discretionary adjustment and a change caused by factors exogenous to the

bank:

d

i,t i,t i,tCAR = CAR +E∆ ∆ [8]

di,t i,t i,tRISK = RISK +S∆ ∆ [9]

where ∆CARi,t and ∆RISKi,t are the observed changes in capital and risk ratios, respectively,

for bank i in period t. The d di,t i,tCAR and RISK∆ ∆ variables represent discretionary

adjustments in capital and risk, and Ei,t and Si,t are exogenously-determined factors.

Following Shrieves and Dahl, I model the discretionary changes in capital and risk using a

partial adjustment framework such that:

d *

i,t i,t i,t-1CAR = (CAR -CAR )α∆ [10]

d *i,t i,t i,t-1RISK = (RISK -RISK )β∆ [11]

where * *i,t i,tCAR and RISK are the target capital and risk ratios, respectively. Thus, the

discretionary changes in capital and risk for bank i are proportional to the difference between

the target ratio and the (observed) ratio in period t-1.

Substituting equations [10] and [11] into equations [8] and [9], the changes in capital and risk

can now be written as:

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*i,t i,t i,t-1 i,tCAR = (CAR -CAR ) +Eα∆ [12]

*i,t i,t i,t-1 i,tRISK = (RISK -RISK ) +Sβ∆ [13]

This means that observed changes in capital and risk in period t are a function of the target

capital and risk ratios, the lagged capital and risk ratios, and any random shocks. Due to the

low number of observations for most of the sample countries, I decided to pool cross-country

data to estimate this system of equations.

Although the target capital and risk ratios of a bank are not observable, they are assumed to

depend on some set of observable variables describing the bank’s financial condition and the

state of the economy in each country. The variables that I use to approximate the target capital

ratio (CAR*) are the size of the bank (SIZE), a measure of its liquidity (LOANS), a

profitability indicator (ROA), changes in the risk ratio (∆RISK), country dummies, the degree

of regulatory pressure (REG) interacted with country dummies, and year dummies (YEAR).

The variables used to proxy the target credit risk ratio (RISK*) are the size of the bank

(SIZE), a measure of its liquidity (LOANS), a measure of asset quality (LLOSS), changes in

the capital ratio (∆CAR), country dummies, the degree of regulatory pressure (REG)

interacted with country dummies, and year dummies (YEAR).

The explanatory variables can thus be divided into bank-specific and country-specific factors

plus year dummies.

4.1. Bank-specific variables

All the variables presented here have been used in the studies listed Table 1 with the

exception of the LOANS variable.

SIZE is measured as the natural log of total assets. It is included as a control variable because

large banks have an easier access to equity capital markets and are thus expected to have

lower capital ratios than smaller banks. In addition, large banks carry out a wider range of

activities, which should increase their ability to diversify their portfolio hence to decrease

their credit risk. The variable LOANS, defined as the percentage of total assets tied up in

loans, is included in the system of equations as a measure of the riskiness of the bank. As

higher LOANS values correspond to lower investment in non earning assets, they should lead

to higher portfolio risk and a greater need for capital. Therefore, the impact of LOANS on

capital ratios will be positive if capital levels increase by more than what is necessary to

compensate the increase in the credit risk ratio (cf. equation [5]). Consistent with previous

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studies, the return on assets, ROA, is included in equation [12] as profitable banks may prefer

to increase capital through retained earnings rather than through equity issues in the presence

of asymmetric information in capital markets. Loan loss provisions as a percentage of total

assets, LLOSS, are included in equation [13] as they represent funds that banks set aside to

cover bad loans. Loan loss provisions are deducted from outstanding loans and should

therefore lead to a decrease in risk-weighted assets. As a consequence, they are expected to

have a negative impact on the credit risk ratio.

Finally, the analysis in section 2 indicates that banks’ capital and risk choices are

interdependent, which suggests the inclusion of ∆CAR in equation [13] and of ∆RISK in

equation [12]. The sign of the relationship between these two variables is not clear a priori. A

positive sign would mean that G-10 banks increased their capital buffer and their credit risk

simultaneously, a result consistent with the unintended effects of more stringent capital

requirements suggested by the literature reviewed in section 2.1. This would also imply that

banks rely on an increase in capital levels and / or a decrease in total assets to increase their

capital adequacy ratios. On the other hand, a negative relationship between changes in capital

and risk ratios would indicate that higher capital ratios did not give banks greater incentives to

increase credit risk, leading to an unambiguous decrease in the probability of bankruptcy at

the G-10 level.

4.2. Country-specific variables

Country fixed-effects are included in the model in order to account for factors that are not

reflected by the set of bank-specific variables, such as national differences in capital

preferences and risk-aversion. The country dummies are also assumed to capture the extent to

which national variants of the Basel Accord had an impact on capital and risk. Some countries

that were part of the 1988 agreement have indeed supplemented the original guidelines with

additional requirements such as higher capital thresholds or new regulatory ratios over the

period studied.12

Of greater interest here is the regulatory pressure variable (REG), which is interacted with a

second set of country dummies. This variable is meant to capture the impact of the Basel

Accord across the G-10 as it describes the behavior of the banks that fell short of the

regulatory standards. More precisely, the regulatory pressure variable used in this study

12 As already mentioned, FDICIA was adopted in the US but there is also evidence that national regulators in other countries have set additional constraints on banks. See Ediz et al. (1998) for the UK and Rime (2001) for Switzerland.

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emphasizes two aspects. First, the level below which a bank should be regarded as

undercapitalized and hence influenced by capital adequacy rules. Second, the size of the gap

between a bank’s capital ratio and this level, hence the magnitude of regulatory pressure

experienced by the bank. With the exception of Jacques and Nigro (1997), the papers listed in

Table 1 focus on the first aspect and neglect the second one. That is, they create a simple

dummy variable, which is equal to one when capital adequacy ratios are below some

threshold level and zero otherwise. The threshold level is the minimum regulatory ratio (cf.

equations [2] and [3]) or the minimum plus some bank-specific quantity.

The need to take into account the second characteristic of supervisory pressure – i.e., a

measure of how far banks are from the threshold – suggests the use of the following

regulatory pressure variable:

REG=THR -CAR if CAR < THR0 otherwise���

[14]

where THR represents the threshold level.

Thus, supervisory pressure is positive whenever CAR < THR, but decreasing as CAR

approaches THR from below. Banks with a CAR above THR are considered to be unaffected

by capital adequacy regulation. Of course, a proper threshold value still needs to be chosen.

For this purpose, I use Table 5, which lists the number of banks’ observations experiencing

positive regulatory pressure for different values of THR (from now on, I use the term

“undercapitalized” to describe these observations).

(insert Table 5 here)

As shown in Panels A and B, the percentage of banks’ observations that can be regarded as

undercapitalized is very low when the threshold is first set to the interim standards and then to

the definitive standards (Panel A) or directly to the latter standards (Panel B). Although this

result seems to support the widespread idea that banks were not affected by the Basel

standards, it could be the case that lower requirements would have induced banks to hold less

capital and that banks actually constructed a buffer above the regulatory minimum for

precautionary and / or reputational reasons. Panels C to E illustrate this possibility by setting

the threshold value for the total capital ratio and for the tier 1 ratio to the regulatory minimum

augmented by one standard deviation of the bank’s own capital ratio (Panel C), to 9% and

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4.5% (Panel D) and finally to 10% and 5% (Panel E), respectively. Consequently, the

percentage of undercapitalized observations based on the total capital ratio increases to

roughly 18% in Panels C and D and to 34% in Panel E whereas the percentage of

observations that do not meet the different threshold values for the tier 1 ratio remains

systematically below 8%. Thus, a first finding that emerges from Table 5 is that G-10 banks

were more constrained by their total capital ratio than by their tier 1 ratio over the 1988-94

period. A second result is that, whatever the value taken by THR, the UK and the US always

have the lowest percentages of banks with CAR < THR. This is probably due to the fact that

most observations for both countries are from the years 1992-1995, when banks were strictly

obliged to obey the regulatory requirements.

Looking at the percentages of undercapitalized observations and their dispersion across

countries, it seems appropriate to consider two different threshold levels: the one set in Panel

B and the one shown in Panel C. The choice of the first threshold is motivated by the fact that

it corresponds to the binding regulatory minimum even though it generates an insufficient

number of undercapitalized observations for the purpose of estimation.13 The second

threshold solves this problem by producing sensible percentages of banks with CAR < THR

in each country. On the contrary, Panel A does not have enough undercapitalized observations

whereas Panels D and E classify too many Japanese banks and / or too few American banks in

the undercapitalized category.

To sum up, I measure regulatory pressure using equation [14], where THR alternatively takes

two values: the minimum requirement and the minimum requirement plus one bank-specific

standard deviation. Note that the use of the regulatory pressure variable to capture the impact

of the Basel Accord faces one important criticism, namely that the behavior of banks below

the threshold is likely to be influenced by other factors than capital requirements, including

market pressure coming from peer banks, private investors and even rating agencies. Thus, it

may be hard to disentangle the effects of the Basel Accord from increased market discipline

(Basel Committee on Banking Supervision, 1999). However, one could reasonably argue that

market pressure is ultimately driven by the prevailing capital adequacy rules, and hence, that

the REG variable is appropriate to capture the impact of the Basel standards on banks’

behavior.

13 I have looked at several ways to increase this number. For instance, by taking into account the additional requirements regarding tier 2 capital (cf. equation [4]) or the amount of general loan-loss reserves and subordinated debt eligible for inclusion in tier 2 capital (cf. Appendix 1). Unfortunately, none of the sample banks violates equation [4] whereas the composition of tier 2 capital is not disclosed in Bankscope.

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4.3. Year dummy variables (YEAR)

Dummy variables for each year of the reference period – except 1989 in order to avoid perfect

collinearity – are added to the specification to take account of macroeconomic shocks (e.g.

changes in the volume or in the structure of loans demand) that can affect banks’ capital and

credit risk ratios.

4.4. Specification

On the basis of the variables selected to explain target capital and risk ratios, the model

defined by equations [12] and [13] is written as follows:

i,t 0 i,t 1 i,t 2 i,t 3 i,t-1 4 i,t j j i,t-1j j

CAR =a SIZE +a LOANS +a ROA +a CAR +a RISK + b + c REG∆ ∆ � �

t i,tt

+ YEAR +ε� [15]

i,t 0 i,t 1 i,t 2 i,t 3 i,t-1 4 i,t j j i,t-1j j

RISK =f SIZE +f LOANS +f LLOSS +f RISK +f CAR + g + h REG∆ ∆ � �

t i,tt

+ YEAR +ν� [16]

where b, c, g and h are the country dummy variables and j is a country index

εi,t and νi,t are disturbance terms

The coefficients of particular interest in this system of equations are cj and hj, which

represent, for country j, the impact of regulatory pressure on observed changes in capital and

risk, respectively, and a4 and f4 that test the relationship between changes in capital and risk

ratios at the G-10 level.

5. Results

Since the right-hand side of both ∆CAR and ∆RISK includes an endogenous variable, the

estimation of the system formed by equations [15] and [16] is carried out by three stage least

squares (3SLS). Unlike ordinary least squares (OLS), estimation by 3SLS provides consistent

estimates of the parameters. In addition, 3SLS estimation is more efficient than two stage

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least squares (2SLS) as it exploits error correlation across equations.14 Tables 6 and 7 present

the results for the system based on the total capital ratio and on the tier 1 ratio, respectively.

The first two columns of each table show the results when THR is set to the minimum

regulatory requirement, while the remaining two columns present the results when THR is

defined as the minimum requirement plus one standard deviation of the bank’s own capital

ratio. A quick examination of both tables reveals that most of the explanatory variables are

statistically significant15 in at least one of the regressions.

The time dummies are all positive and significant in the ∆CAR equations of Table 6, which

indicates that target total capital ratios were higher over the period 1990-1995 than in 1989.

The magnitude of the year dummies implies that the biggest increase in total capital ratios

across the seven countries took place in 1992 (dummy 1992 - dummy 1991 ≅ +1.2%). This

result is logical since the definitive Basel standards had to be implemented by the end of

December 1992. On the contrary, the time dummies included in the ∆CAR equations of

Table 7 are mostly insignificant, which suggests that target tier 1 ratios were relatively

constant across years. These results echo Table 5, which showed that banks had more

difficulties in meeting the minimum requirement for the total capital ratio than the minimum

requirement for the tier 1 ratio. The time dummies included in the ∆RISK equations are only

negatively significant in Table 7, providing mixed support for the hypothesis that target risk

ratios were lower in the first half of the 1990s than in 1989.

Next, the country dummy variables, used alone, capture the extent to which target capital and

risk ratios differed across countries over 1989-95. The country dummies are essentially

significant in the ∆CAR equations, where their magnitude is roughly identical for each

country. This result suggests that most banks across the G-10 had the same target capital

ratios in mind and that the national variants of the Basel Accord did not bring major changes

to it. Indeed, Canada is probably the first country to have seriously departed from the 1988

agreement by requesting its banks to hold a minimum tier 1 ratio of 7% and a minimum total

capital ratio of 10% but only recently, in 1999. In the regressions where THR is set to the

minimum regulatory requirement, an F-test rejected the null hypothesis that the target capital

ratio of Swedish banks was of the same order of magnitude as that of other G-10 banks. The

higher magnitude of the dummy variable for Sweden is more than probably due to the

14 However, 3SLS may be sensitive to misspecification or measurement error. This suggests comparison with 2SLS estimates as a specification check. Estimation of equations [15] and [16] using 2SLS produces essentially the same results. 15 Throughout the paper, “significance” refers to a level of confidence of 95% and “marginal significance” to a level of confidence of 90%.

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aftermath of the banking crisis experienced by this country, with banks forced to recapitalize

heavily, leading them to overshoot the target induced by Basel.

Before analyzing the regulatory pressure brought about by the Basel Accord, I briefly discuss

the sign of some bank-specific variables (lower panel of Tables 6 and 7). The parameter

estimates on lagged capital and risk ratios are negative and significant in both tables, with

values between –0.214 and –0.152. This result indicates that banks were only slowly

adjusting their capital and risk ratios to desired levels in the first half of the 1990s. Bank size

(SIZE) has a negative impact on bank capital ratios and a positive impact on the credit risk

ratio. Possible interpretations are that large banks have easier access to capital markets and

can therefore operate with lower amounts of capital or that they feel less pressure to increase

their capital ratio because of a “too-big-to-fail” effect. A larger size also allows a greater

diversification to mitigate the credit risk exposure. As hypothesized, loans as a percentage of

total assets (LOANS) are a good proxy of the target risk profile of a bank as they always

increase the credit risk ratio significantly. Their impact on capital ratios is negative, which

suggests that capital levels rise by less than what is necessary to compensate the increase in

risk. The return on assets (ROA) was found to have a positive effect on banks’ capital ratios, a

result consistent with the hypothesis that banks with higher earnings can retain more capital.

Finally, loan loss provisions as a percentage of total assets (LLOSS) had no effect on target

risk ratios overall.

More importantly, Tables 6 and 7 provide some insights on the behavior of banks

experiencing regulatory pressure and on the overall relationship between ∆CAR and ∆RISK.

Hereunder, I focus on the results obtained by setting THR to the minimum regulatory

requirement plus one bank-specific standard deviation, i.e. on the last two columns of each

table. Regressions with THR equal to the regulatory minimum include too few

undercapitalized observations and may therefore display unreliable estimates or no estimates

at all for the regulatory pressure variables (see the first two columns of Table 7).

Impact of the Basel Accord on bank capital ratios

In Table 6, banks put under regulatory pressure because they were below the 8% requirement

plus one standard deviation increased their total capital ratio significantly in four countries:

Canada, Japan, Sweden and the US.16 It is well-known that one of the hidden goals of the

Basel Accord was to create a level playing field by eliminating the funding-cost advantage

16 Interpreting the magnitude of the regulatory pressure variable (REG) interacted with country dummies is not possible due to its definition (see equation [14]).

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enjoyed by Japanese banks which operated with significantly lower capital to asset ratio

compared to their competitors in other G-10 countries (Wagster, 1996). Results in Table 6

show that the Basel Accord was quite effective in raising the total capital ratio of

undercapitalized Japanese institutions, which tends to indicate that part of this competitive

advantage was reduced. In France and in the UK, some banks (e.g. Banque Paribas or Lloyds

Bank plc) did not raise their total capital ratio in the first years of the Basel implementation

process, which probably accounts for the fact that the regulatory pressure variable is found to

be insignificant for both countries.17 The fact that French banks were slow in meeting the

Basel requirements is not surprising given that they had previously only been subject to a

minimum total capital ratio of 5%. Surprisingly, I found that Italian banks within one standard

deviation of the regulatory minimum actually decreased their total capital ratio even though

only marginally significantly. Two things might explain this result. First, Italian banks

belonging to a banking group are allowed to have a capital ratio as low as 7% provided that

the 8% requirement is respected for the group as a whole. Second, some troubled banking

institutions not only fell below the regulatory threshold, but also saw their capital position

deteriorate dramatically over the period studied. For instance, the total capital ratio of Banco

di Napoli, the seventh biggest Italian bank in terms of assets, was down from 8.46% in 1992

to 1.74% in 1995. These banks were eventually recapitalized.

Examining the coefficients on the regulatory pressure variable in the capital equation of

Table 7 indicates that undercapitalized banks showed the same response to the Basel Accord

in their tier 1 ratio than in their total capital ratio, except in Canada and in Japan for which the

coefficients are non significant. The result for Japan is consistent with several papers18 which

show that undercapitalized Japanese banks tended to issue more subordinated debts (an

increase in tier 2 capital, hence in total capital), while leaving their tier 1 capital relatively

unchanged. Finally, it should be mentioned that the regulatory pressure variable has a positive

and significant impact on both capital adequacy ratios when it is not interacted with country

dummies.19

Impact of the Basel Accord on bank portfolio risk

Regarding the impact of the Basel standards on portfolio risk, the parameter estimates for the

regulatory pressure variable show little significance, except in Table 6 where they are positive

17 Regulatory pressure has a positive and (marginally) significant impact on UK banks when REG is replaced by a simple dummy variable, a result consistent with what Ediz et al. (1998) found using a much larger data set of UK banks. 18 See for instance Ito and Sasaki (1998). 19 This result is not reported in any table.

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and significant for Canada, Sweden and Japan, but only marginally in the latter case. Thus,

the findings weakly support the hypothesis that undercapitalized banks in these three

countries were increasing risk in response to the Basel agreement between 1988 and 1995.

Moreover, the regulatory pressure variable is found to be insignificant when not interacted

with country dummies,19 suggesting that capital requirements did not increase credit risk-

taking at the G-10 level. This result contradicts earlier findings by Koehn and Santomero

(1980) and others, who argue that more stringent bank capital regulation will cause a utility

maximizing bank to increase asset risk and may, as a result, increase the probability of bank

failure.

Overall relationship between changes in capital and risk ratios

Finally, a robust finding emerges from Tables 6 and 7, namely the negative relationship

between changes in capital and risk ratios over 1988-95. Conditioning on other variables, an

increase in the credit risk ratio of 1% decreases the total capital ratio by only 0.07% and the

tier 1 ratio by a mere 0.05%, suggesting that G-10 banks almost offset any increase in risk

with an increase in capital and / or a decrease in total assets. Looking at the “risk” equations,

a rise of 1% in both capital ratios is associated with a similar decrease in the credit risk ratio.

This means that, conditioning on other variables, higher capital ratios led to a decrease in

portfolio risk at the G-10 level during the 1988-95 period. The existence of a negative

relationship between changes in capital ratios and credit risk contrasts with the empirical

studies reviewed in section 2.3, which generally find that these changes are either somewhat

positively related or not related at all (see the last column of Table 1). This result also

strongly rejects various theories providing a rationale for a positive relationship between

changes in capital and risk, including the “bankruptcy cost avoidance” theory and the

“managerial risk aversion” theory (see Shrieves and Dahl, 1992).

6. Conclusion

This paper documents the behavior of banks from seven G-10 countries toward capital and

risk between 1988 and 1995 by using a modified version of the model developed by Shrieves

and Dahl (1992). Prior research, both at the theoretical and empirical levels, indicates that

banks may well respond to an increase in capital requirements by a corresponding increase in

the credit risk of their portfolio.

The evidence presented here shows that G-10 banks within one standard deviation of the

minimum regulatory capital requirement tended to increase their capital adequacy ratios,

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except in France and in Italy. This finding indicates that regulatory pressure, i.e., the degree to

which banks are urged to raise their capital ratios by the prudential authorities, was generally

effective in raising the capital buffer of banks across the G-10. Moreover, regulatory pressure

only marginally raised the credit risk of banks, a result suggesting that banks that had to raise

their capital ratios drastically did not in general engage in riskier activities. In addition, the

tendency toward higher capital ratios, which characterizes G-10 banks during the 1988-95

period, was shown to have gone hand in hand with a decrease in credit risk. All in all, the

evidence presented here indicates that the 1988 Basel Accord did not lead banks to engage in

riskier activities, while providing them with a higher capital buffer against insolvency. These

findings have important policy implications for regulators as they suggest that the use of risk

buckets to assess and limit credit risk-taking is likely to produce the desired effect. This

approach to portfolio risk is currently being refined under the “standardized approach” of the

New Basel Accord, which is likely to be adopted by many small banks that do not have the

resources to use one of the more advanced “internal ratings-based approaches”.20

Two caveats are in order, however. First, as pointed out by Jones (2000), banks may attempt

to arbitrage between their economic assessment of risk and regulatory requirements. This can

be done either by boosting capital ratios through “cosmetic arrangements” or by exploiting

shortcomings in the measure of risk through “regulatory capital arbitrage”, both methods

allowing banks to misreport their effective capital ratios and / or credit risk. Although the lack

of data prevents measuring the extent to which these techniques were used by banks (Basel

Committee on Banking Supervision, 1999), this points out that risk-weighted assets as

defined by the 1988 Basel standards may not fully reflect the actual risk of a bank’s portfolio.

Second, the paper analyzes portfolio risk in isolation from other types of risks, like market

risk or interest rate risk. It could be the case that banks chose not to modify their credit risk to

comply with the Basel guidelines, while increasing their interest or market exposure.

However, evidence on the existence of such a trade-off is scarce, even if it is due to a lack of

data.21 Moreover, the fact that credit risk is still the biggest risk faced by banks strengthens

confidence in the conclusion that G-10 banks did not become riskier in the first half of the

1990s.

20 Under the “standardized approach”, corporate exposures are now assigned to five risk buckets (0%, 20%, 50%, 100% and 150%) according to the nature of the claim and the assessment of external agencies, while retail exposures receive a 75% risk weight. The “internal ratings-based approaches” allow banks to determine their own risk weights through the combination of their quantitative inputs and formulas specified by the Basel Committee on Banking Supervision. 21 Typically, estimating interest-risk exposure requires data on the duration of banks’ assets. This information is almost impossible to obtain on a standardized cross-country basis. In the case of the US, Allen et al. (1996) provide some evidence that substitution of unpriced interest rate risk for priced credit risk did occur. However, they do not allow for other features of banks’ books, which makes their results difficult to interpret.

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Prompt Corrective Action on Bank Capital and Risk,” in Financial Services at the Crossroads: Capital Regulation in the 21st Century, Conference, 26-27 February 1998, Federal Reserve Bank of New York.

Aggarwal, R. and K. Jacques (2001): “The impact of FDICIA and Prompt Corrective Action

on bank capital and risk: estimates using a simultaneous equation model”, Journal of Banking and Finance, vol.25 (6), pp. 1139-1160.

Allen, L., J. Jagtiani and Y. Landskroner (1996): “Interest Rate Risk Subsidization in

International Capital Standards”, Journal of Economics and Business, vol.48 (3), pp. 251-267.

Basel Committee on Banking Supervision (1988): “International convergence of capital

measurement and capital standards”, Bank for International Settlements, Basel. Basel Committee on Banking Supervision (1999): “Capital requirements and bank behavior:

the impact of the Basel Accord”, working paper #1, Bank for International Settlements, Basel.

Blum, J. (1999): “Do capital adequacy requirements reduce risks in banking?”, Journal of

Banking and Finance, vol.23 (5), pp. 755-771. Dewatripont, M. and J. Tirole (1994): “The prudential regulation of banks”, MIT Press. Ediz, T., I. Michael and W. Perraudin (1998): “Capital Regulation and UK Banks’ behavior”,

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Evidence from the Capital Buildup of the 1990s”, working paper, Department of Finance, Insurance and Real Estate, Graduate School of Business, University of Florida.

Furlong, F.T. and M.C. Keeley (1989): “Capital regulation and bank risk-taking: a note”,

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Finance, vol.15 (4-5), pp. 805-824. Hart, O.D. and D.M. Jaffee (1974): “On the application of portfolio theory to depository

financial intermediaries”, Review of Economic Studies, vol.41 (1), pp. 129-147. Ito, T. and Y.T. Sasaki (1998): “Impact of the Basel Standard on Japanese Banks Behavior”,

working paper #6730, National Bureau of Economic Research, Cambridge, MA. Jacques, K. and P. Nigro (1997): “Risk-Based Capital, Portfolio Risk and Bank Capital: A

Simultaneous Equations Approach,” Journal of Economics and Business, vol.49 (6), pp. 533-547.

Jones, D. (2000): “Emerging problems with the Basel Capital Accord: Regulatory capital

arbitrage and related issues”, Journal of Banking and Finance, vol.24 (1-2), pp. 35-58.

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Keeley, M.C. and F.T. Furlong (1990): “A re-examination of the mean-variance analysis of bank capital regulation”, Journal of Banking and Finance, vol.14 (1), pp. 69-84.

Kim, D. and A.M. Santomero (1988): “Risk in banking capital regulation”, Journal of

Finance, vol.43 (5), pp. 1219-1223. Koehn, M. and A.M. Santomero (1980): “Regulation of bank capital and portfolio risk”,

Journal of Finance, vol.35 (5), pp. 1235-1244. Pecchioli, R. (1987): “Prudential Supervision in Banking”, OECD, Paris. Pyle, D.H. (1971): “On the theory of Financial Intermediation”, Journal of Finance,

vol.26 (3), pp. 737-747. Rime, B. (2001): “Capital Requirements and Bank Behavior: Empirical Evidence for

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Table 1: Previous studies on the impact of the 1988 Basel Accord on capitalization and credit risk-taking.

Author(s) (Year of

Publication) Sample and Period

Impact of regulatory pressure

on ∆CAR

Impact of regulatory pressure

on ∆RISK

Relationship between

∆CAR and ∆RISK

Jacques and Nigro (1997)

2,570 US commercial banks with assets > $100 million over 2 years (1990-91) – First step in the implementation process.

+ for A 0 / - for U

– for A 0 for U

mostly 0

Aggarwal and Jacques (1997)

2,849 US commercial banks with assets > $100 million over 3 years (1991-93) – Second step in the implementation process

+ for A in 93 + for U

+ in 91 / – in 92-93 for A and U

– in 91-92 / + in 93

Ediz et al. (1998)

94 UK banks over 25 quarters (4th quarter 1989 - 4th quarter 1995)

+ for U 0 for U not studied

Rime (2001) 154 Swiss banks over 7 years (1989-95)

0 for A + for U

0 for A and U

0 / +

Aggarwal and Jacques (2001)

1,685 US commercial banks with assets > $100 million over 6 years (1991-96)

+ for A and U in 91

+ in 91 / 0 in 92 / – in 93-96 for A and U

+ and – in 91-92 / + in 93-96

Note: +: significantly positive; –: significantly negative; 0: insignificant. A: adequately capitalized banks; U: undercapitalized banks. Table 2: Representativeness of the sample

Number of banks Number of banks from the national

top-10 *

Sample bank assets / Total national banking assets *

Canada 7 7 0.92 France 9 7 0.49 Italy 16 9 0.74 Japan 76 9 0.84 Sweden 10 8 0.97 United Kingdom 9 6 0.70 United States 459 10 0.91 * As of December 1995.

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Table 3 (Panel A): Total capital ratio (%) - number of observations in parenthesis 1988 1989 1990 1991 1992 1993 1994 1995

Canada 7.14 (6) 7.59 (7) 7.89 (7) 8.86 (7) 9.01 (7) 9.84 (7) 9.94 (7) 9.91 (7) France 6.00 (1) 7.03 (7) 7.34 (9) 7.72 (9) 8.26 (9) 8.80 (9) 9.65 (9) 9.41 (9) Italy 10.02 (1) 8.84 (3) 8.97 (6) 9.75 (8) 9.32 (11) 10.15 (14) 11.69 (16) 11.33 (16) Japan 9.24 (37) 8.61 (51) 8.93 (74) 8.49 (75) 9.23 (76) 9.60 (76) 9.24 (76) 9.58 (72) Sweden - 8.77 (1) 8.26 (4) 9.40 (7) 8.76 (8) 11.64 (9) 16.09 (10) 16.79 (10) United Kingdom 10.95 (2) 9.91 (6) 11.31 (7) 12.16 (7) 12.22 (9) 12.59 (9) 13.71 (9) 13.55 (9) United States - 9.30 (1) 8.90 (3) 10.08 (156) 12.30 (418) 13.10 (444) 12.63 (429) 13.01 (399) All countries 8.99 (47) 8.49 (76) 8.86 (110) 9.55 (269) 11.64 (538) 12.42 (568) 12.14 (556) 12.46 (522) Table 3 (Panel B): Tier 1 ratio (%) - number of observations in parenthesis 1988 1989 1990 1991 1992 1993 1994 1995 Canada 4.84 (6) 5.33 (7) 5.54 (7) 6.07 (7) 6.23 (7) 6.67 (7) 6.76 (7) 6.97 (7) France 3.20 (1) 4.34 (5) 4.41 (8) 4.58 (8) 5.11 (8) 5.41 (8) 5.95 (8) 5.89 (8) Italy 8.88 (1) 7.31 (3) 7.76 (4) 7.85 (8) 7.37 (10) 8.00 (14) 9.28 (16) 8.96 (14) Japan 4.91 (37) 5.30 (51) 5.61 (74) 5.66 (75) 5.89 (76) 6.07 (76) 6.21 (76) 6.12 (72) Sweden - 7.31 (1) 5.72 (4) 7.03 (7) 5.97 (7) 8.80 (8) 11.12 (9) 12.57 (10) United Kingdom 6.05 (2) 5.72 (6) 6.68 (7) 7.47 (7) 7.14 (8) 7.72 (9) 8.85 (9) 8.89 (9) United States - 5.50 (1) 6.47 (3) 8.37 (156) 10.56 (418) 11.34 (444) 10.79 (429) 11.13 (399) All countries 5.00 (47) 5.39 (74) 5.69 (107) 7.36 (268) 9.59 (534) 10.32 (566) 9.97 (554) 10.23 (519) Table 3 (Panel C): Credit risk ratio (%) - number of observations in parenthesis 1988 1989 1990 1991 1992 1993 1994 1995 Canada 97.65 (6) 93.28 (7) 89.40 (7) 83.59 (7) 79.78 (7) 74.58 (7) 71.64 (7) 68.37 (7) France 72.00 (1) 55.80 (5) 58.75 (8) 59.11 (9) 58.89 (9) 57.11 (9) 54.71 (7) 53.00 (7) Italy - 58.00 (1) 56.00 (2) 57.50 (6) 60.22 (9) 55.36 (14) 54.63 (16) 57.46 (13) Japan 66.76 (37) 68.47 (51) 67.76 (74) 68.28 (75) 69.75 (76) 68.78 (76) 68.33 (76) 67.97 (72) Sweden - 66.00 (1) 61.50 (4) 57.43 (7) 66.29 (7) 59.25 (8) 56.50 (10) 53.22 (9) United Kingdom 75.00 (1) 79.50 (4) 76.50 (6) 74.14 (7) 65.50 (8) 65.13 (8) 62.67 (9) 61.56 (9) United States - 92.00 (1) 86.00 (3) 78.94 (156) 69.93 (418) 69.28 (444) 70.90 (428) 72.91 (397) All countries 71.18 (45) 70.81 (70) 69.09 (104) 74.23 (267) 69.57 (534) 68.54 (566) 69.49 (553) 70.95 (514)

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Table 4: Decomposition of the average annual growth rate of CAR for the period 1988-95 (%)

Panel A: CAR = Total capital ratio; K = Total capital

t

t

CARCAR

∆ t

t

KK

∆ t

t

RISKRISK

∆ t

t

AA

∆ Number of

observations

Canada 4.56 8.67 -4.23 8.33 48 France 4.55 7.76 -1.57 4.77 46 Italy -1.68 1.92 0.75 2.85 45 Japan 1.55 5.02 0.32 3.15 49 Sweden 11.80 13.04 2.87 -1.64 36 United Kingdom 3.16 4.96 -4.04 5.85 43 United States 3.34 13.93 0.68 9.91 1,385 All countries 3.40 12.76 0.39 8.97 1,652 Panel B: CAR = Tier 1 ratio; K = Tier 1 capital

t

t

CARCAR

∆ t

t

KK

∆ t

t

RISKRISK

∆ t

t

AA

∆ Number of

observations

Canada 4.56 8.67 -4.23 8.33 48 France 5.47 8.50 -2.00 5.03 40 Italy -5.01 -1.40 0.75 2.85 45 Japan 2.24 9.32 0.26 6.82 461 Sweden 9.22 9.39 2.59 -2.43 33 United Kingdom 3.98 5.98 -3.91 5.90 42 United States 3.00 13.59 0.68 9.91 1,385 All countries 2.86 11.86 0.36 8.65 2,054

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Table 5: Impact of the choice of a particular threshold level on the percentage of observations for which CAR < THR (data are for the 1988-94 period).

CAR = Total capital ratio (*) CAR = Tier 1 ratio (**) Threshold level (THR) Country # of obs.

(total)

# of obs. for which

CAR < THR

% of obs. for which

CAR < THR

# of obs. (total)

# of obs. for which

CAR < THR

% of obs. for which

CAR < THR

Panel A Canada 48 10 20.83 48 0 0.00 For * : 7.25% France 53 18 33.96 46 5 10.87 until 1990, then Italy 59 8 13.56 56 1 1.79 8% Japan 465 18 3.87 465 4 0.86 For ** : 3.25% Sweden 39 2 5.13 36 0 0.00 until 1990, then UK 49 0 0.00 48 0 0.00 4% US 1,451 17 1.17 1,451 2 0.14

Total 2,164 73 3.37 2,150 12 0.56 Panel B Canada 48 14 29.17 48 1 2.08 For * : 8% France 53 19 35.85 46 6 13.04 For ** : 4% Italy 59 8 13.56 56 1 1.79

Japan 465 31 6.67 465 12 2.58 Sweden 39 2 5.13 36 0 0.00 UK 49 1 2.04 48 0 0.00 US 1,451 17 1.17 1,451 2 0.14 Total 2,164 92 4.25 2,150 28 1.30

Panel C Canada 48 30 62.50 48 8 16.67 For * : 8% + std France 53 38 71.70 46 18 39.13 For ** : 4% + std Italy 59 22 37.29 56 5 8.93 Japan 465 146 31.40 465 37 7.96

Sweden 39 22 56.41 36 10 27.78 UK 49 4 8.16 48 4 8.33 US 1,451 123 8.48 1,451 30 2.07 Total 2,164 385 17.79 2,150 112 5.21

Panel D Canada 48 29 60.42 48 3 6.25 For * : 9% France 53 41 77.36 46 15 32.61 For ** : 4.5% Italy 59 19 32.20 56 2 3.57

Japan 465 238 51.18 465 41 8.82 Sweden 39 12 30.77 36 0 0.00 UK 49 2 4.08 48 1 2.08 US 1,451 76 5.24 1,451 3 0.21 Total 2,164 417 19.27 2,150 65 3.02

Panel E Canada 48 44 91.67 48 11 22.92 For * : 10% France 53 48 90.57 46 22 47.83 For ** : 5% Italy 59 34 57.63 56 2 3.57

Japan 465 404 86.88 465 103 22.15 Sweden 39 18 46.15 36 4 11.11 UK 49 14 28.57 48 3 6.25 US 1,451 173 11.92 1,451 8 0.55 Total 2,164 735 33.96 2,150 153 7.12

Note: std = standard deviation of banks’ own capital ratios series.

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Table 6: Results for the system based on CAR = Total capital ratio

(THR = minimum) (THR = minimum + one std) ∆CAR ∆RISK ∆CAR ∆RISK

Year Dummies 1990 0.007 -0.003 0.007 -0.004 (2.45)** (-0.29) (2.51)** (-0.37)

1991 0.005 -0.012 0.005 -0.01 (1.73)* (-1.29) (1.92)* (-1.1)

1992 0.017 -0.015 0.016 -0.013 (5.81)*** (-1.53) (6.15)*** (-1.28)

1993 0.012 -0.016 0.014 -0.012 (4.51)*** (1.69)* (5.43)*** (-1.28)

1994 0.006 -0.01 0.008 -0.007 (2.22)** (-1.16) (3.01)*** (-0.75)

1995 0.013 -0.003 0.015 0.001 (4.56)*** (-0.3) (5.64)*** (-0.14)

Country Dummies Canada 0.05 -0.035 0.04 -0.045 (7.67)*** (2.08)** (6.22)*** (2.55)**

France 0.046 0.001 0.038 -0.005 (7.71)*** (-0.03) (6.48)*** (-0.31)

Italy 0.047 0.006 0.04 0.003 (8.05)*** (-0.36) (7.06)*** (-0.2)

Japan 0.05 -0.005 0.041 -0.01 (8.96)*** (-0.33) (7.71)*** (-0.69)

Sweden 0.067 -0.015 0.039 -0.048 (10.42)*** (-0.87) (5.94)*** (2.73)***

UK 0.052 -0.011 0.042 -0.015 (8.27)*** (-0.69) (7.09)*** (-0.94)

US 0.049 0.021 0.039 0.017 (9.36)*** (-1.64) (7.74)*** (-1.3)

Regulatory Pressure * REG * Canada 0.906 3.839 0.568 1.946 Country Dummies (1.71)* (2.27)** (2.34)** (2.35)**

REG * France -0.329 -0.083 -0.156 0.128 (-1.55) (-0.12) (-1.01) (-0.25)

REG * Italy -1.002 -5.544 -0.48 -1.316 (-0.72) (-1.25) (1.72)* (-1.4)

REG * Japan 0.862 0.467 0.669 1.052 (2.50)** (-0.41) (3.82)*** (1.70)*

REG * Sweden 2.621 15.162 1.819 3.005 (-1.28) (2.39)** (10.61)*** (4.19)***

REG * UK 1.085 -2.012 0.764 -0.322 (-0.41) (-0.24) (-1.28) (-0.16)

REG * US 0.792 0.342 0.732 0.095 (2.85)*** (-0.37) (11.41)*** (-0.32)

Control variables SIZE -0.002 0.003 -0.002 0.003 (6.78)*** (2.56)** (6.05)*** (2.71)***

LOANS -0.028 0.142 -0.027 0.141 (8.12)*** (10.96)*** (8.20)*** (10.77)***

ROA 0.255 0.319 (5.55)*** (7.23)***

CAR(-1) -0.2 -0.168 (11.98)*** (10.71)***

∆RISK -0.082 -0.069 (4.04)*** (3.51)***

LLOSS -0.01 -0.009 (-1.22) (-1.14)

RISK(-1) -0.157 -0.156 (12.89)*** (12.90)***

∆CAR -0.935 -0.949 (4.35)*** (3.91)***

R-squared 0.282 0.218 0.365 0.227 # Observations 2,017 2,017 2,017 2,017 t statistics in parentheses; * significant at 10%; ** significant at 5%; *** significant at 1%.

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Table 7: Results for the system based on CAR = Tier 1 ratio

(THR = minimum) (THR = minimum + one std) ∆CAR ∆RISK ∆CAR ∆RISK

Year Dummies 1990 -0.001 -0.015 -0.000 -0.012 (0.31) (1.52) (0.10) (1.27)

1991 0.000 -0.019 0.001 -0.018 (0.12) (2.13)** (0.23) (2.00)**

1992 0.005 -0.032 0.005 -0.030 (1.78)* (3.69)*** (2.01)** (3.37)***

1993 0.004 -0.029 0.005 -0.027 (1.45) (3.42)*** (1.77)* (3.09)***

1994 -0.002 -0.023 -0.002 -0.021 (0.79) (2.71)*** (0.62) (2.43)**

1995 0.004 -0.016 0.005 -0.013 (1.41) (1.85)* (1.78)* (1.53)

Country Dummies Canada 0.070 -0.013 0.063 -0.021 (10.79)*** (0.80) (10.12)*** (1.24)

France 0.061 0.015 0.055 0.010 (10.33)*** (0.92) (9.49)*** (0.59)

Italy 0.065 0.018 0.060 0.014 (11.01)*** (1.12) (10.50)*** (0.89)

Japan 0.067 0.012 0.061 0.006 (12.13)*** (0.78) (11.37)*** (0.39)

Sweden 0.080 0.003 0.062 -0.022 (12.64)*** (0.17) (9.93)*** (1.30)

UK 0.066 0.003 0.060 -0.000 (10.76)*** (0.19) (10.06)*** (0.00)

US 0.067 0.037 0.060 0.032 (12.65)*** (2.81)*** (11.72)*** (2.44)**

Regulatory Pressure * REG * Canada -1.609 28.784 0.294 2.854 Country Dummies (0.11) (0.58) (0.34) (0.98)

REG * France -0.431 -1.393 -0.144 -0.464 (0.56) (0.56) (0.42) (0.40)

REG * Italy - - -2.146 -2.660 - - (2.70)*** (0.98)

REG * Japan 0.750 0.025 0.468 0.751 (0.74) (0.01) (1.09) (0.52)

REG * Sweden - - 4.371 7.383 - - (11.93)*** (4.76)***

REG * UK - - 0.455 -4.765 - - (0.30) (0.95)

REG * US 0.346 6.096 0.911 0.400 (0.22) (1.19) (8.20)*** (0.93)

Control variables SIZE -0.003 0.003 -0.003 0.003 (9.32)*** (2.40)** (8.60)*** (2.76)***

LOANS -0.035 0.134 -0.034 0.137 (9.89)*** (10.09)*** (9.92)*** (10.50)***

ROA 0.238 0.279 (5.29)*** (6.32)***

CAR(-1) -0.214 -0.199 (12.25)*** (11.97)***

∆RISK -0.056 -0.045 (2.56)** (2.16)**

LLOSS -0.007 -0.007 (0.93) (0.81)

RISK(-1) -0.152 -0.155 (12.57)*** (12.98)***

∆CAR -1.042 -1.040 (5.09)*** (4.79)***

R-squared 0.261 0.237 0.332 0.252 # Observations 2,011 2,011 2,011 2,011 t statistics in parentheses; * significant at 10%; ** significant at 5%; *** significant at 1%.

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31

Figure 1: Median of the equity to asset ratio over 1988-95, by type of banks

4

5

6

7

8

9

10

11

1988 1989 1990 1991 1992 1993 1994 1995

Equ

ity /

Tot

al A

sset

s (%

)

G-10 banks Non G-10 banks Banks not reporting a CAR before 1993

Figure 2: Median of the subordinated debt to asset ratio over 1988-95, by type of banks

0

1

2

3

1988 1989 1990 1991 1992 1993 1994 1995

Subo

rdin

ated

Deb

t / T

otal

Ass

ets

(%)

G-10 banks Non G-10 banks Banks not reporting a CAR before 1993

Source: Bankscope, Update 77 (December 1996)

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32

Appendix 1: The 1988 Basel Accord: Transitional and implementing arrangements

End-1990 End-1992

1. Total capital ratio

7.25 % 8 %

2. Tier 1 ratio 3.25 % 4%

3. Limit on general provision (or general loan loss reserves) in Tier 2 capital (∗)

Maximum 1.5 % or, exceptionally, up to 2% of

Tier 2 capital

Maximum 1.5 % or, exceptionally and

temporarily, up to 2% of Tier 2 capital

4. Limit on term subordinated

debt in Tier 2 capital No limit (at discretion) Maximum 50% of Tier 1

capital

5. Deduction for goodwill Deducted from Tier 1 capital (at discretion)

Deducted from Tier 1 capital

(∗) In the event that no agreement was reached on the definition of unencumbered resources

eligible for inclusion in Tier 2 capital. Source: Basel Committee on Banking Supervision (1988).

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33

Appendix 2: Proof of equation [5]

t tt t

t t

K RWAAs CAR = and RISK =

RWA A

tt

t t

KWe have that CAR =

RISK .A Taking logs and differentiating with respect to time:

t t t tdlog(CAR ) dlog(K ) dlog(RISK ) dlog(A )= - +

dt dt dt dt� �� �

Using the notation

t t t

t t

dlog(X ) dX X1= × =

dt X dt X

We obtain easily that

• • • •

t t t t

t t t t

CAR K RISK A= - -

CAR K RISK A

Note that equation [5] uses discrete time changes rather than time derivatives and is therefore only an approximation of the correct formula for the growth rate of capital adequacy ratios.