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A Review of the Regulatory Impact Analysis of Risk-Based Capital and Related Liquidity Rules

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  • Thomas L. Hogan

    (American Institute for Economic Research, Great Barrington, MA 01230, USA
    For helpful comments and suggestions, the author thanks Stephen Miller, three anonymous reviewers, and session participants at the AIER Sound Money Project annual meeting. The author thanks David Schatz and Justin Wang for editing assistance.)

Abstract

This paper reviews the cost-benefit analysis, or “regulatory impact analysis” (RIA), in US bank regulators’ risk-based capital (RBC) rule proposals. We review the principles of cost-benefit analysis and its application by US bank regulators. We provide a brief background on RBC rules and review the literature on their costs and benefits. We then evaluate 27 proposed RBC rules and related rules on bank liquidity. We find that nine of the 27 rules include RIAs. Five of the RIAs claim the proposed rule will create net benefits, but none provide quantitative evidence that the benefits exceed the costs. In two proposals, the evidence cited indicates the rules’ net benefits may actually be negative.

Suggested Citation

  • Thomas L. Hogan, 2021. "A Review of the Regulatory Impact Analysis of Risk-Based Capital and Related Liquidity Rules," JRFM, MDPI, vol. 14(1), pages 1-29, January.
    • Handle: RePEc:gam:jjrfmx:v:14:y:2021:i:1:p:24-:d:475770
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    References listed on IDEAS

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    1. Hogan, Thomas L., 2015. "Capital and risk in commercial banking: A comparison of capital and risk-based capital ratios," The Quarterly Review of Economics and Finance, Elsevier, vol. 57(C), pages 32-45.
    2. Richard J. Herring, 2018. "The Evolving Complexity of Capital Regulation," Journal of Financial Services Research, Springer;Western Finance Association, vol. 53(2), pages 183-205, June.
    3. Van den Heuvel, Skander J., 2008. "The welfare cost of bank capital requirements," Journal of Monetary Economics, Elsevier, vol. 55(2), pages 298-320, March.
    4. Duca, John V. & Ling, David C., 2020. "The other (commercial) real estate boom and bust: The effects of risk premia and regulatory capital arbitrage," Journal of Banking & Finance, Elsevier, vol. 112(C).
    5. Ferri, Giovanni & Pesic, Valerio, 2017. "Bank regulatory arbitrage via risk weighted assets dispersion," Journal of Financial Stability, Elsevier, vol. 33(C), pages 331-345.
    6. Merrill, Craig B. & Nadauld, Taylor D. & Stulz, Rene M. & Sherlund, Shane, 2012. "Did Capital Requirements and Fair Value Accounting Spark Fire Sales in Distressed Mortgage-Backed Securities?," Working Papers 13-01, University of Pennsylvania, Wharton School, Weiss Center.
    7. Adrian, Tobias & Boyarchenko, Nina, 2018. "Liquidity policies and systemic risk," Journal of Financial Intermediation, Elsevier, vol. 35(PB), pages 45-60.
    8. John H. Cochrane, 2014. "Challenges for Cost-Benefit Analysis of Financial Regulation," The Journal of Legal Studies, University of Chicago Press, vol. 43(S2), pages 63-105.
    9. Andrew G. Haldane, 2015. "Multi-Polar Regulation," International Journal of Central Banking, International Journal of Central Banking, vol. 11(3), pages 385-401, June.
    10. Thomas L. Hogan & Scott Burns, 2019. "Has Dodd–Frank affected bank expenses?," Journal of Regulatory Economics, Springer, vol. 55(2), pages 214-236, April.
    11. Prasad Krishnamurthy, 2014. "Rules, Standards, and Complexity in Capital Regulation," The Journal of Legal Studies, University of Chicago Press, vol. 43(S2), pages 273-296.
    12. Avery, Robert B. & Berger, Allen N., 1991. "Risk-based capital and deposit insurance reform," Journal of Banking & Finance, Elsevier, vol. 15(4-5), pages 847-874, September.
    13. Thomas L. Hogan & Neil R. Meredith, 2016. "Risk and risk-based capital of U.S. bank holding companies," Journal of Regulatory Economics, Springer, vol. 49(1), pages 86-112, February.
    14. Patrick Slovik, 2012. "Systemically Important Banks and Capital Regulation Challenges," OECD Economics Department Working Papers 916, OECD Publishing.
    15. Herring, Richard J., 2016. "Less Really Can Be More: Why Simplicity and Comparability Should be Regulatory Objectives," Working Papers 16-08, University of Pennsylvania, Wharton School, Weiss Center.
    16. Stephen Matteo Miller, 2018. "The recourse rule, regulatory arbitrage, and the financial crisis," Journal of Regulatory Economics, Springer, vol. 54(2), pages 195-217, October.
    17. Thomas L. Hogan & Neil R. Meredith & Xuhao (Harry) Pan, 2015. "Risk-based capital regulation revisited: evidence from the early 2000s," Journal of Financial Regulation and Compliance, Emerald Group Publishing, vol. 23(2), pages 115-134, May.
    18. Thomas L. Hogan & G. P. Manish, 2016. "Banking Regulation and Knowledge Problems," Advances in Austrian Economics, in: Steven Horwitz (ed.), Studies in Austrian Macroeconomics, volume 20, pages 213-234, Emerald Publishing Ltd.
    19. William R. Cline, 2016. "Benefits and Costs of Higher Capital Requirements for Banks," Working Paper Series WP16-6, Peterson Institute for International Economics.
    20. Herring, Richard J., 2018. "The Evolving Complexity of Capital Regulation," Working Papers 18-01, University of Pennsylvania, Wharton School, Weiss Center.
    21. Selgin, George & Lastrapes, William D. & White, Lawrence H., 2012. "Has the Fed been a failure?," Journal of Macroeconomics, Elsevier, vol. 34(3), pages 569-596.
    22. Jones, David, 2000. "Emerging problems with the Basel Capital Accord: Regulatory capital arbitrage and related issues," Journal of Banking & Finance, Elsevier, vol. 24(1-2), pages 35-58, January.
    23. Matthias Efing, 2020. "Reaching for Yield in the ABS Market: Evidence from German Bank Investments [Causes of the financial crisis]," Review of Finance, European Finance Association, vol. 24(4), pages 929-959.
    24. James R. Barth & Stephen Matteo Miller, 2018. "On the Rising Complexity of Bank Regulatory Capital Requirements: From Global Guidelines to their United States (US) Implementation," JRFM, MDPI, vol. 11(4), pages 1-33, November.
    25. Richard J. Herring, 2016. "Less Really Can be More: Why Simplicity & Comparability Should be Regulatory Objectives," Atlantic Economic Journal, Springer;International Atlantic Economic Society, vol. 44(1), pages 33-50, March.
    26. VanHoose, David, 2007. "Theories of bank behavior under capital regulation," Journal of Banking & Finance, Elsevier, vol. 31(12), pages 3680-3697, December.
    27. Thomas L. Hogan & Neil R. Meredith & Xuhao (Harry) Pan, 2018. "Evaluating risk‐based capital regulation," Review of Financial Economics, John Wiley & Sons, vol. 36(2), pages 83-96, April.
    28. Jeffrey N. Gordon, 2014. "The Empty Call for Benefit-Cost Analysis in Financial Regulation," The Journal of Legal Studies, University of Chicago Press, vol. 43(S2), pages 351-378.
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    Cited by:

    1. Peter Zweifel, 2021. "Solvency Regulation—An Assessment of Basel III for Banks and of Planned Solvency III for Insurers," JRFM, MDPI, vol. 14(6), pages 1-22, June.

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