Are we there yet ? Part II of a Series on Liquidity Risk

liquidity risk Basel IIIThank you for coming back to hear my round up of arguments on the regulations and standards posed on banks since the financial crisis. In Part I we reviewed BCBS 188, the Basel III regulation on Liquidity Risk.  I have further expanded on my arguments here, as to what implications this will have on financial institutions in the future.


The NSFR (Net Stable Funding Ratio): here the Basel proposals when combined with “bail-in” measures appear contradictory that will result in banks having to issue huge amounts of longer dated debt at much higher costs to a smaller investor market. Undoubtedly banks will need to significantly increase debt issuance to meet the NSFR requirements, and at a much higher cost.  The principal of lengthening the bank’s debt maturity profile is sensible, but whether this can be achieved given the challenges is not well understood.  Issuing debt seems straightforward enough, but will there be the demand, as bond holders will need to sign up to the bail in conditions.


Some investors will be restricted by internal policies for buying bank’s long term debt due to the bail-in clauses. At the same time rating agencies, in recognition of these proposals may reduce the ratings of those banks that have implicit government support thus further limiting overall demand for bank issued debt. Another constraint is the fear that bail-in clauses, when triggered, will see the debt written down and converted into equity which will not be regarded as an event of default on a CDS, thus limiting hedging options. 


No doubt alternative arguments can be proffered, but as mentioned at the outset, uncertainty on the exact regulatory details that lie ahead are the main worry.  If there are substantial changes to the regulatory framework, will banks find themselves pouring millions more into their compliance projects? Though this is not clear, as far as liquidity standards go, the Basel Committee will be in conference again in 2013, so to speak, to discuss whether there is merit in revising the proposals for the LCR or not.  There’ll be plenty to talk about and the industry is keenly hoping that all the lobbying will serve some purpose and their concerns will be addressed.  If I had to punt, I would not be overly optimistic on any movement on the LCR proposals but more so, on the NSFR. 


What is clear, based on the recent Committee meeting, is that despite some slippage, adherence to the Basel III timetable for implementation is of paramount importance and great efforts will made to keep the accord on track. We’re not there yet, but let’s wait and see what 2013 holds out for us.


I would love to hear from you about your plans and strategies to tackle the new liquidity standards.


Ziauddin Ishaq is the Global Solutions Lead for Liquidity Risk at Oracle. 


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