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The Information Content of Bank Examinations

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Author Info
Allen Berger
Sally Davies

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Abstract

The role of information acquisition for bank regulators is important for the recognition and possible control of bank risk. This role is also consistent with the modern theory of banking under which banks hold a substantial amount of private information about their loan customers, and by implication, private information about their own conditions.

The authors suggest that the main purpose of bank examinations is information acquisition. In order to maintain the safety and soundness of the banking system, regulators conduct regular on-site reviews of operations and determine a composite rating for the institution, known as its CAMEL rating. The authors test whether bank exams do in fact result in significant information acquisition. Their tests involve observation of how capital markets react around the times of examinations and whether these reactions are related to changes in examination ratings. They use event study methodology and track the cumulative abnormal returns on an institution's stock price before and after the examination relative to the predictions of a two-factor market model. Data are for institutions whose stocks were actively traded on major exchanges from 1985-1989 - a relatively stable regulatory regime.

The question of whether bank examinations succeed in discovering substantial private information about loan quality and bank risk is crucial to answering policy questions regarding financial system reform. The modern theory of banking often rests on the assumption that are delegated monitors because of scale economies in information acquisition about borrowers. An extension of this theory might suggest that there are economies of scale in "monitoring the monitors". These economies of scale do not necessarily imply that government agencies should be the monitors. However, under the current federal safety net and deposit insurance regime, the federal government bears greater losses than do their creditors in the event of bank failure.

One important consideration in choosing how much of the risk-bearing and associated monitoring responsibility should rest with government versus private sector agents depends upon the quality of the information available to the two groups. The authors' data suggest that regulatory examinations do generate valuable private information, although conceivable private sector firms could gain essentially the same or better information under a reformed regime.

While CAMEL ratings and exam data are confidential, the authors suggest there are several ways information gathered in the process can be incorporated into capital market prices. One is that market prices react because insiders trade on information, although this would be illegal. Alternatively, the market may respond to information revealed in public documents released after an examination. The authors test for this possibility.

The authors posit that there are at least three types of information effects that may be transmitted to the market from an examination - auditing, regulatory discipline, private information. They attempt to separate the effects of the three types by differentiating between examinations in which the CAMEL rating remained unchanged, improved, and worsened.

The empirical results suggest that the net auditing effect is close to zero, and perhaps negative. They also find a relatively small regulatory disciple effect. The authors state that the data suggest that the private information effects of CAMEL downgrades in revealing unfavorable information about bank condition are substantial. Thus is consistent with some of the earlier studies of the combined effect and inconsistent with others. It also provides support for the concept of bank uniqueness - that banks hold private information about loan customers. The authors also find evidence that suggests that quarterly financial statements or the Call Report may be the conduits through which some of the examination information is revealed to the market.

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Publisher Info
Paper provided by Wharton School Center for Financial Institutions, University of Pennsylvania in its series Center for Financial Institutions Working Papers with number 94-24.

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Date of creation: Jul 1994
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Handle: RePEc:wop:pennin:94-24

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References listed on IDEAS
Please report citation or reference errors to , or , if you are the registered author of the cited work, log in to your RePEc Author Service profile, click on "citations" and make appropriate adjustments.:
  1. Brown, Stephen J. & Warner, Jerold B., 1985. "Using daily stock returns : The case of event studies," Journal of Financial Economics, Elsevier, vol. 14(1), pages 3-31, March. [Downloadable!] (restricted)
  2. Cole, Rebel A., 1998. "The importance of relationships to the availability of credit," Journal of Banking & Finance, Elsevier, vol. 22(6-8), pages 959-977, August. [Downloadable!] (restricted)
  3. Peek, Joe & Rosengren, Eric, 1995. "Bank regulation and the credit crunch," Journal of Banking & Finance, Elsevier, vol. 19(3-4), pages 679-692, June. [Downloadable!] (restricted)
    Other versions:
  4. James, Christopher, 1987. "Some evidence on the uniqueness of bank loans," Journal of Financial Economics, Elsevier, vol. 19(2), pages 217-235, December. [Downloadable!] (restricted)
  5. Sally M. Davies, 1991. "Accounting for prediction variance in event studies," Finance and Economics Discussion Series 173, Board of Governors of the Federal Reserve System (U.S.).
  6. Boyd, John H. & Prescott, Edward C., 1986. "Financial intermediary-coalitions," Journal of Economic Theory, Elsevier, vol. 38(2), pages 211-232, April. [Downloadable!] (restricted)
    Other versions:
  7. Hand, John R M & Holthausen, Robert W & Leftwich, Richard W, 1992. " The Effect of Bond Rating Agency Announcements on Bond and Stock Prices," Journal of Finance, American Finance Association, vol. 47(2), pages 733-52, June. [Downloadable!] (restricted)
  8. Allen N. Berger & Sally M. Davies & Mark J. Flannery, 1998. "Comparing market and supervisory assessments of bank performance: who knows what when?," Finance and Economics Discussion Series 1998-32, Board of Governors of the Federal Reserve System (U.S.). [Downloadable!]
    Other versions:
  9. Jones, David S. & King, Kathleen Kuester, 1995. "The implementation of prompt corrective action: An assessment," Journal of Banking & Finance, Elsevier, vol. 19(3-4), pages 491-510, June. [Downloadable!] (restricted)
  10. Holthausen, Robert W. & Leftwich, Richard W., 1986. "The effect of bond rating changes on common stock prices," Journal of Financial Economics, Elsevier, vol. 17(1), pages 57-89, September. [Downloadable!] (restricted)
  11. Graham, David R & Humphrey, David Burras, 1978. "Bank Examination Data as Predictors of Bank Net Loan Losses," Journal of Money, Credit and Banking, Blackwell Publishing, vol. 10(4), pages 491-504, November. [Downloadable!] (restricted)
  12. Berger, Allen N & Udell, Gregory F, 1995. "Relationship Lending and Lines of Credit in Small Firm Finance," Journal of Business, University of Chicago Press, vol. 68(3), pages 351-81, July. [Downloadable!] (restricted)
  13. Lummer, Scott L. & McConnell, John J., 1989. "Further evidence on the bank lending process and the capital-market response to bank loan agreements," Journal of Financial Economics, Elsevier, vol. 25(1), pages 99-122, November. [Downloadable!] (restricted)
  14. Berger, Allen N. & King, Kathleen Kuester & O'Brien, James M., 1991. "The limitations of market value accounting and a more realistic alternative," Journal of Banking & Finance, Elsevier, vol. 15(4-5), pages 753-783, September. [Downloadable!] (restricted)
  15. Gary Whalen & James B. Thomson, 1988. "Using financial data to identify changes in bank condition," Economic Review, Federal Reserve Bank of Cleveland, issue Q II, pages 17-26. [Downloadable!]
  16. Benston, George J & Marlin, John Tepper, 1974. "Bank Examiners' Evaluation of Credit: An Analysis of the Usefulness of Substandard Loan Data," Journal of Money, Credit and Banking, Blackwell Publishing, vol. 6(1), pages 23-44, February. [Downloadable!] (restricted)
  17. Katerina Simons & Stephen Cross, 1991. "Do capital markets predict problems in large commercial banks?," New England Economic Review, Federal Reserve Bank of Boston, issue May, pages 51-56.
  18. Billett, Matthew T & Flannery, Mark J & Garfinkel, Jon A, 1995. " The Effect of Lender Identity on a Borrowing Firm's Equity Return," Journal of Finance, American Finance Association, vol. 50(2), pages 699-718, June. [Downloadable!] (restricted)
Full references

Cited by:
(explanations, Please report citation or reference errors to , or , if you are the registered author of the cited work, log in to your RePEc Author Service profile, click on "citations" and make appropriate adjustments.)

  1. Mark Flannery, 2001. "The Faces of “Market Disciplineâ€," Journal of Financial Services Research, Springer, vol. 20(2), pages 107-119, October. [Downloadable!] (restricted)
  2. Delis, Manthos D & Staikouras, Panagiotis, 2009. "On-site audits, sanctions, and bank risk-taking: An empirical overture towards a novel regulatory and supervisory philosophy," MPRA Paper 16836, University Library of Munich, Germany. [Downloadable!]
  3. Allen N. Berger & Margaret K. Kyle & Joseph M. Scalise, 2000. "Did U.S. Bank Supervisors Get Tougher During the Credit Crunch? Did They Get Easier During the Banking Boom? Did It Matter to Bank Lending?," NBER Working Papers 7689, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
    Other versions:
  4. Elyas Elyasiani & Iqbal Mansur, 2005. "The Association Between Market and Exchange Rate Risks and Accounting Variables: A GARCH Model of the Japanese Banking Institutions," Review of Quantitative Finance and Accounting, Springer, vol. 25(2), pages 183-206, September. [Downloadable!] (restricted)
  5. John S. Jordan, 1999. "Pricing bank stocks: the contribution of bank examinations," New England Economic Review, Federal Reserve Bank of Boston, issue May, pages 39-53. [Downloadable!]
  6. R. Alton Gilbert & Andrew P. Meyer & Mark D. Vaughan, 2002. "Can feedback from the jumbo-CD market improve off-site surveillance of community banks?," Supervisory Policy Analysis Working Papers 2002-08, Federal Reserve Bank of St. Louis. [Downloadable!]
  7. Joe Peek & Eric S. Rosengren & Geoffrey M. B. Tootell, 1999. "Using bank supervisory data to improve macroeconomic forecasts," New England Economic Review, Federal Reserve Bank of Boston, issue Sep, pages 21-32. [Downloadable!]
  8. Allen N. Berger & Margaret K. Kyle & Joseph M. Scalise, 2001. "Did U.S. Bank Supervisors Get Tougher during the Credit Crunch? Did They Get Easier during the Banking Boom? Did It Matter to Bank Lending?," NBER Chapters, in: Prudential Supervision: What Works and What Doesn't, pages 301-356 National Bureau of Economic Research, Inc. [Downloadable!]
  9. Linda Allen & Julapa Jagtiani & James Moser, 2001. "Further Evidence on the Information Content of Bank Examination Ratings: A Study of BHC-to-FHC Conversion Applications," Journal of Financial Services Research, Springer, vol. 20(2), pages 213-232, October. [Downloadable!] (restricted)
  10. Allen N. Berger & Sally M. Davies & Mark J. Flannery, 1998. "Comparing market and supervisory assessments of bank performance: who knows what when?," Finance and Economics Discussion Series 1998-32, Board of Governors of the Federal Reserve System (U.S.). [Downloadable!]
    Other versions:
  11. anonymous, 2000. "Improving public disclosure in banking," Staff Studies 173, Board of Governors of the Federal Reserve System (U.S.). [Downloadable!]
  12. Douglas D. Evanoff & Larry D. Wall, 2000. "Subordinated debt and bank capital reform," Working Paper 2000-24, Federal Reserve Bank of Atlanta. [Downloadable!]
    Other versions:
  13. Edward Simpson Prescott, 2008. "Should bank supervisors disclose information about their banks?," Economic Quarterly, Federal Reserve Bank of Richmond, issue Win, pages 1-16. [Downloadable!]
  14. David C. Wheelock & Paul W. Wilson, 1999. "The contribution of on-site examination ratings to an emprircal model of bank failures," Working Papers 1999-023, Federal Reserve Bank of St. Louis. [Downloadable!]
  15. Joe Peek & Eric S. Rosengren & Geoffrey M. B. Tootell, 1998. "Does the Federal Reserve have an informational advantage? you can bank on it," Working Papers 98-2, Federal Reserve Bank of Boston. [Downloadable!]
  16. Frederick T. Furlong & Robard Williams, 2006. "Financial market signals and banking supervision: are current practices consistent with research findings?," Economic Review, Federal Reserve Bank of San Francisco, pages 17-29. [Downloadable!]
  17. R. Alton Gilbert & Andrew P. Meyer & Mark D. Vaughan, 2003. "Can feedback from the jumbo-CD market improve bank surveillance?," Working Papers 2003-041, Federal Reserve Bank of St. Louis. [Downloadable!]
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