Subordinated debt and prompt corrective regulatory action

Several recent studies have recommended greater reliance on subordinated debt as a tool to discipline bank risk taking. Some of these proposals recommend using subordinated debt yield spreads as additional triggers for supervisory discipline under prompt corrective action (PCA); action that is currently prompted by capital adequacy measures. This paper provides a theoretical model describing how use of a second market-measure of bank risk, in addition to the supervisors own internalized information, could improve bank discipline. We then empirically evaluate the implications of the model. The evidence suggests that subordinated debt spreads dominate the current capital measures used to trigger PCA and consideration should be given to using spreads to complement supervisory discipline. The evidence also suggests that spreads over corporate bonds may be preferred to using spreads over U.S. Treasuries. *The authors wish to thank Mark Flannery, Xavier Freixas, Ben Gup, Alan Hess, George Kaufman, Joe Haubrich, William Perraudin and Mark Vaughan for constructive comments and suggestions on earlier drafts. The authors also acknowledge the support of Nancy Andrews, Mark Murawski and George Simler in developing the database used in the study, and Andy Meyer, Alton Gilbert, and Mark Vaughan for graciously providing detailed information about their 'early warning model. The opinions expressed, however, are those of the authors and not necessarily those of the people mentioned above, the Federal Reserve Bank of Chicago, Federal Reserve Bank of Atlanta or the Federal Reserve System.