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引用次数: 182
摘要
本文讨论了2007/2009年金融危机后银行资本监管的改革。尽管巴塞尔银行监管委员会(Basel Committee on Banking Supervision)似乎只是在这里或那里做一些微小的改变,但这份报告呼吁进行彻底改革,从风险校准转向大幅提高资本金要求。这一论点基于以下观察:当前的风险校准资本要求体系,特别是基于模型的方法,在允许银行在危机前资本不足方面发挥了关键作用,对去杠杆乘数和银行间市场的运作产生了强大的系统性影响。该论点还基于这样一种观察,即当前的制度没有理论基础,其目标不明确,其影响没有得到充分考虑,无论是对个别银行还是对整个制度。反对大幅提高资本金要求的理由,要么与经济逻辑背道而驰,要么本身就是道德风险和监管必要性的证据。
Capital Regulation after the Crisis: Business as Usual?
The paper discusses the reform of capital regulation of banks in the wake of the financial crisis of 2007/2009. Whereas the Basel Committee on Banking Supervision seems to go for marginal changes here and there, the paper calls for a thorough overhaul, moving away from risk calibration and raising capital requirements very substantially. The argument is based on the observation that the current system of risk-calibrated capital requirements, in particular under the model-based approach, played a key role in allowing banks to be undercapitalized prior to the crisis, with strong systemic effects for deleveraging multipliers and for the functioning of interbank markets. The argument is also based on the observation that the current system has no theoretical foundation, its objectives are ill-specified, and its effects have not been thought through, either for the individual bank or for the system as a whole. Objections to substantial increases in capital requirements rest on arguments that run counter to economic logic or are themselves evidence of moral hazard and a need for regulation.