Why bank liquidity needs to be regulated? This version: June 2012 Sonia Ondo Ndong* and Peixin Zhang† Abstract: Our paper focuses on banking regulation, especially on the necessity of liquidity regulation as complement to traditional capital-based banking regulation. During the 2007/2008 financial crisis, some studies on troubled banks prove that the principal problem of these banks in trouble was illiquidity rather than insolvency. In fact, most of troubled banks were dropped down by the lack of stable funding sources which are less sensitive to market fluctuations instead of the credit risk raised by their toxic assets. In this paper, by implementing the traditional econometric analysis coupled with the neural-network method on a panel data of European banks during 2000 and 2008, we argue that liquidity regulation should be conceived as a both quantitative and qualitative requirement that is complementary to capital-based regulation rather than a simple separate regulatory ratio to restrict banks’ maturity transformation. Keywords: banking strategies; liquidity regulation JEL: G21, G28, G32 * University of Paris West Nanterre La Défense, EconomiX, address: Bureau G 301, 200 Avenue de la République, Nanterre 92001, France, tel: 01 40 97 59 07, e-mail: soniabarbara81@yahoo.fr † University of Paris West Nanterre La Défense, EconomiX, address: Bureau G 301, 200 Avenue de la République, Nanterre 92001, France, tel: 01 40 97 59 07, e-mail: alexandre_zhang@hotmail.com 1 1. Introduction The lesson of the global financial crisis beginning in the summer of 2007 shows that the actual banking regulation on the basis of the Basel II agreement is not sufficient to handle the problem in the banking sector due to banks’ excessive risk-taking through diverse financial innovations. Many studies have pointed to the main flaw of the present regulatory regime: a high dependence on the capital-based regulation, especially risk-based capital regulation, which has been criticized by some authors before the 2007/2008 financial crisis (Calem and Rob, 1999; Blum, 1999; Rime, 2001; Heid, 2007). Financial regulators and academics start to realize that regulatory reforms in the financial system are necessary (e.g. see FSA, 2009; De Larosière Group, 2009; Goodhart, 2008; Dewatripont, Rochet and Tirole, 2010). Some authors have proposed several paths for future regulatory reforms from the macro-prudential point of view. For instance, Adrian and Brunnermeier (2008) put forward a CoVar measurement for systemically important institutions; Kashyap, Rajan, and Stein (2008) suggest a counter-cyclical remedy for regulatory capital requirements; Krimminger (2008) concentrates on the resolution of cross-border banks and the cooperation between regulators; Allen and Carletti (2008) propose an additional balance sheet based on mark-tofunding evaluation for banks in order to reduce bank's liquidity risk. All these proposals are aimed at capturing the systemic risk in order to achieve the financial stability objective of regulators. As recognized by many authors (e.g. Bunnermeier et al., 2009), this financial systemic crisis is a liquidity crisis rather than a credit risk, and one of its main reasons is banks’ liquidity vulnerability due to their strong maturity mismatch. This phenomenon justifies the argument of Diamond and Rajan (2001; 2005) about the relationship between liquidity shortages and banking crises. Therefore, some studies have focused on the improvement of liquidity regulation in banking industry. For instance, Farhi, Golosov and Tsyvinski (2009) propose a simple implementation of the optimum that imposes a constraint on the portfolio share that financial intermediaries invest in short-term assets. Perotti and Suarez (2011) suggest that if the return to the lending activities undertaken by the banks using this funding is heterogeneously distributed across banks (or, similarly, over time), a Pigovian tax on short-term funding will dominate a net 2 stable funding ratio or a liquidity coverage ratio. Farhi and Tirole (2009) characterize the optimal regulation, which takes the form of a minimum liquidity requirement coupled with monitoring of the quality of liquid assets. Brunnermeier and Oehmke (2012) develop a model which shows that excessive maturity mismatch may arise even in the absence of an anticipated ex-post intervention by the central bank in order to promote to limit maturity in the financial institution. In the present paper, we also focus on regulatory reforms in the banking system. Especially, we are interested in liquidity regulation, more precisely in the justification and the modality for implementing liquidity regulation in the banking system. We use panel data analysis to find which type of risky banking strategies can significantly cause bank losses and thus destabilizing the bank. Therefore, the most important concern for future regulatory reforms is to reduce the risk-level of these significant banking strategies by imposing more appropriate regulation on banks. An outstanding result of our paper, concluded from empirical evidence on a panel data set of 25 banks from 14 European countries during the period between 2000 and 2008, is that the interaction between risky (funding) liquidity strategy and risky leverage (capitalization) strategy has a more detrimental effect on bank results. Furthermore, by making an analysis on bank sponsored Special-Purpose Entities (SPEs) domiciled in UK, we obtain a supplementary result that is the insignificant relationship between the creation of SPEs and the decline in parent banks’ funding structure. This result contradicts the argument of financial regulators and supervisors about the responsibility of SPEs for banks’ liquidity difficulties in the crisis (Loutskina, 2011). However, as our crude analysis is based on a period without regulatory requirement on prudential information disclosure, lack of detailed information about bank sponsored SPEs determine that our result is biased. Nevertheless, our analysis is not meaningless. In fact, our result affirms that the lack of sufficient detailed information has always been a main reason for the regulatory negligence on shadow banking system. Therefore, we suggest both the necessity of a qualitative aspect in liquidity regulation and the need for transparency in the banking system. As regards the methodological aspect of this paper, we use nonlinear neural-network approach with other usual estimators to perform our panel data analysis to enhance the robustness of our estimation. 3 The rest of the paper proceeds as follows. Section 2 describes the data and the variables used. Section 3 presents the empirical model and the results of the econometric analysis. Section 4 investigates the SPEs contribution to banks’ funding liquidity deterioration. Section 5 concludes and discusses policy implications. 2. Data and Variables We collect annual banking balance sheet and income-statement data from Bankscope database to construct our sample. We use the data for the period between 2000 and 2008, a whole cycle between two crises.1 At the start, information of our sample is gathered on commercial banks (commercial and cooperative)2 of 14 European countries of which the banking sector is more developed in comparison with other countries in the European Union.3 Then according to two criteria, we trim our sample by ruling out some unqualified banks. As we are constructing a panel data sample, continuous financial reporting is the first relevant criterion to construct our sample. Besides, some banks retained in the first step did not communicate information on certain variables used in our econometric analysis. Therefore, we also have to eliminate these banks. Then the final dataset for testing includes 25 banks over 9 years (225 observations). In addition, the data for our control variables is collected from IMF and ECB database. The data sample is described in Table 1. Variables description is presented in Table 2. 2.1. Dependent variable In this paper, we use the variation of banks' credit supply as a proxy for bank results. This relationship is especially justified in the case where commercial banks encounter losses. When 1 The IT bubble burst in the U.S. in 2000, following by a euphoric phase in which the Fed’s low-interest rate policy in favor of economy recovery. However, this behavior was one of the main reasons to explain the formation of the real estate bubble. When the Fed changed its opinion by raising interest rates from 2005 (the BCE implemented the same policy from 2006, an enormous amount of risk was stocked in the financial system. Finally, in the summer of 2007, the property bubble burst and another financial crisis broke out. 2 We exclude investment banks for the reason that the dependant variable used in our econometric analysis is the variation of credit supply which is considered as proxy for banking results of commercial banks rather than investment banks (see Section 2.2 for details). 3 We included Switzerland in our sample. Countries in our sample are countries are as follows: Belgium, Denmark, Finland, France, Germany, Luxembourg, Netherlands, Norway, Portugal, Republic of Ireland, Spain, Sweden, Switzerland, and United Kingdom. Since there are a large number of small Italian cooperative banks in Bankscope database, we excluded them from our sample in order to minimize the selection bias. 4 banks make losses and need to meet regulatory requirements, they have two ways to absorb losses: decreasing the volume of assets (contracting the supply of credit) or increasing the equity capital (issuing new equity shares). From the point of view of regulators, the second is more favorable to financial stability. However, the existing shareholders in reality prefer the first one. The rationale for this is raising equity will dilute existing shareholders’ control power in the bank. Moreover, risk-based capital regulation reinforces this behavior (Berger and Udell, 1994; Peek and Rosengren, 1995). In this paper, we use banking strategy variables to measure their impact on bank results. More precisely, we focus on following categories of banking strategies: capitalization strategy, liquidity strategy, portfolio strategy, and management strategy. To complete our empirical model, we also introduce some control variables. 2.2. Explanatory Variables 2.2.1. Capitalization strategy Here, we examine two types of capitalization strategies, leverage and regulatory capitalization. Leverage. Because debt is relatively costless to capital equity, the bank has a great incentive to use the former to finance their activities. Moreover, there is an increase in competition among banks and in expected return by shareholders. This leads banks to implement a risky leverage strategy by is using more costless funds (debt) rather than equity capital to finance its activities.4 However, the negative effect of a risky leverage strategy should not be neglected. A series of authors (Brunnermeier et al., 2009; Shin, 2009) have shown that a bank experiencing a highleverage strategy is riskier during crisis. In particular, highly leveraged institutions have to liquidate their assets at lower price or contract the supply of credit in order to reduce losses in the downward spiral. According to them, leverage ratio reflects banks’ risk level, and the risk level of banks’ leverage has an impact on bank results. Therefore, we use here banks' simple leverage ratio (equity-to-asset ratio) as the first proxy for capitalization strategy. 4 According to Modigliani-Miller (1958) theorem, a higher leverage ratio (debt-to-equity) can increase firms' return on equity. Therefore, risky leverage strategies of the bank allow maximizing shareholders' profit. 5 Regulatory capitalization. In last decades where competition in the banking industry was more and more fierce, banks were forced to build a reputation of being riskless and profitable in order to attract more customers.5 Since the capital requirement is qualified by regulators as a signal for revealing banks' level of risk, banks can reassure investors about the bank's stability by holding a high level of regulatory capital. It is usually an important instrument to conceal their real level of risk for large banks that have more risky activities. Therefore, we are willing to examine whether this type of banking strategy has an impact on bank results. 2.2.2. Liquidity strategy We are interested in two types of bank liquidity. The first one is liability-side liquidity that is measured in our empirical analysis by banks’ unstable funding ratio (short-term funding ratio) and the second one is asset-side liability that is measured here by asset-side liquidity ratio. Unstable funding ratio. The rationale for using this ratio is short-term funding is more costless than long-term liabilities to finance their activities, although they are potentially detrimental to banks’ stability. Nevertheless, if short-term funding is more prevailing in the bank's funding structure, the bank has to confront the increasing cost of renewal in time of crisis.6 Besides, the bank depending on short-term funding is more likely to be in the situation where creditors demand higher repayment when the bank wants to renew these funds. Indeed this situation may be aggravated by a systemic crisis in which the bank has already had a liquidity shortage. In this case, the penalty rate (or high risk premium) demanded by financiers will increase the bank's financing cost. Consequently, the bank has to choose between encountering losses (earns less) and contracting the supply of credit, as showed by Prisman, Slovin, and Sushka (1986). Asset-side liquidity ratio. This ratio measure how the bank handles maturity mismatches between its assets and liabilities. Even though maturity transformation is the main activity of the bank, a bank with large maturity mismatch will experience the fire sale of its assets, especially in the crisis, as showed by Brunnermeier (2009). Therefore, a risky (smaller) asset-side liquidity 5 Keeley (1990) argue that banks having more market power hold more capital than required level. Berger et al. (2008) show that large banks (Bank Holding Companies in U.S.) actively manage their capital ratios. 6 Morris and Shin (2004) show that traders who rely on short-term funding will encounter large losses by liquidating their assets at lower price, and that their “fire sale” behavior contribute to the formation of liquidity black holes. 6 ratio (holding less liquid asset relative to liquid liabilities) may have impact on bank results. 2.2.3. Portfolio Strategy Portfolio structure. Here we are interested in the composition of banks’ assets portfolio, namely banking book activities and trading book activities. As banking book activities are more regulated than trading book activities, the risk level of the former is usually lower.7 Therefore, holding more banking book assets can reduce banks’ risk exposure, especially the exposure to market risks. In contrast, since banks' trading book activities are highly related to financial markets, banks are more sensitive to market fluctuations. Particularly in time of crisis, banks that hold important trading book assets are prone to assuming losses. Thus we use banking book assets to total assets ratio as the first proxy for portfolio strategy. Size. Boyd and Runkle (1993) argue that there is a relation between bank size and the return on assets and leverage and thus large banks are more profitable but riskier by being highly leveraged. De Nicoló (2000) reports a positive and significant relationship between bank size and failure probabilities for the United States, Japan, and several European countries. Then it is interesting to examine whether the bank size has direct or indirect effect on the bank results. We use here the size of sampled banks relative to total balance sheets of MFIs in their domestic country to measure the impact of size on bank results. Off-balance sheet activities. Today off-balance sheet activities play an important role in the banking industry. It has became a new way for banks to maximize their profit by charging commission for financial services (e.g. credit lines), since the profit margin of banks' traditional activities decreased due to competition. In addition, banks create and sponsor SIVs to transfer their credit risk, and then to reduce their capital requirement. It is in line with banks' profitmaximization objective. Nevertheless, we all know that this “originate to distribute” model of banks played an important role in the subprime crisis. During the crisis, a bank that has large exposure to off-balance-sheet activities has to reengage them into its own balance sheet by reintermediation process. By doing so, the bank finally bear risks and encounter losses (Basel 7 Even if banking book activities are highly regulated, risk may appear in this type of assets. However, Holmström and Tirole (2000) show that the banking book is usually jeopardized by the trading book at first, even though the trading book is often used to hedge the banking book. 7 Committee on Banking Supervision, April 2008). We use here the ratio of off-balance-sheet items to total assets. Interbank activities. The bank's interbank claim can be used to measure the interconnection of one bank with the others. Allen and Gale (2000) and Freixas, Parigi and Rochet (2000) establish that contagion through interbank claims can make banks more fragile and cause bank losses. We use the interbank ratio (bank loans to bank deposits) to test this type of portfolio strategy. 2.2.4. Management Strategy As we know, managerial efficiency has an important effect on bank results. The role of an efficient management strategy by bank managers is not only to reduce managerial cost to income ratio, but also to release signals favorable to the bank in the market.8 In this section, we are interested in three types of management strategies: managerial quality, loan loss provision and ROE policy. Managerial quality. Overhead expenses are related to personal expenses and non-interest expenses in banking operations. Moreover, overheads are usually used to measure the bank’s managerial quality. For instance, Levine (2001) shows that large overhead expenses reflect a less efficient management of the bank. Therefore, we use overhead expenses to total assets ratio to measure the managerial quality of our sampled banks. Loan loss provision. Madura and McDaniel (1989) show that an increase in loan loss provision has the potential to convey to the market a negative strong signal that is the poor management of banks’ loan portfolio. Obviously, this bad news can weaken investors’ confidence so that the bank is more likely to face the financing problem. From viewpoint of regulators, the more loan loss provisions are held, the more the bank is risky. However, Madura and McDaniel (1989) also recognize the possible positive stock market reaction to loan loss provision announcement. In other words, an increase in loan loss provision may raise banks’ stock price and thus enhancing capitalization.9 Moreover, holding more loan loss provision can be considered as one of active 8 See for example Diamond (1991) for the importance of signaling to build reputation. 9 These phenomena are also highlighted by Musumeci and Sinkey (1990), and reexamined by Docking, Hirschey and Jones (1997). 8 risk management used by the bank to protect itself against credit risk. Therefore, which viewpoint prevails? More loan loss provisions make the bank assume more loss or not? In this empirical study, we use loan loss reserve ratio find out the answer. ROE policy. Return on equity measures the rate of return on shareholder’s equity and thus a bank’s (in general a firm) efficiency at generating profits from each unit of equity capital. This ratio is also a sort of operational/management strategy that reflects the relation between banks’ equity capital and risk-taking.10 The lesson of the actual financial crisis is that banks established a risky ROE policy (higher ROE) in favor of their shareholders, but their behavior generated a potential social cost (privatizing gains and socializing losses). Therefore, we test in this paper whether banks’ risky ROE policy is significantly detriment to their financial stability. 2.2.5. Interaction between liquidity and capitalization strategy By focusing on the mechanism of the subprime crisis, some authors (Brunnermeier et al., 2009; Calomiris, 2009; Hellwig, 2009) argue that highly leveraged institutions with large maturity mismatches are prone to carry out a fire sale in time of distress and thus aggravating the impact of the financial crisis. In other words, the joint implementation of risky capitalization strategy and risky liquidity strategy is dangerous both to individual banks and to the financial system. Therefore, in this paper we provide empirical evidence on European banks to test whether the interaction between two types of banking strategies has a significant effect on banks’ stability. The variable used in the econometric model is the unstable-funding to equity ratio, which is calculated by the division of unstable-funding ratio (UFS/TA) to simple leverage ratio (E/TA), by taking into account the effect of both two types of strategies. 2.2.6. Control variables As central bank policy had an important contribution to the formation of this cycle, we also introduce the real interest rate (RIR) of our sampled banks’ domestic country as a control variable.11 Besides, we take into account two other control variables, the importance of financial 10 Higher operating returns mean higher risk level. In a sense, a higher ROE signifies that the bank manager use less equity capital to take more risks in business operation. 11 See footnote 1. Real interest rate is calculated as the difference between nominal interest rate and inflation rate. 9 sector to national economy (FSI, measured as the ratio of aggregated balance sheet of all MFIs to GDP) and output gap. 3. Empirical model and results The econometric analysis proceeds in two steps. In the first step, we use first-difference estimator and neural-network estimator to estimate the pooled sample. By use of a between comparison, we try to find some generalities and to identify the significant effect of certain variables for sampled banks. In the second step, we use panel-data techniques to better capture the serially related and cross-sectionally related components of sampled banks. The econometric specification we used to test is as follows: 𝑉𝐴𝑅 = 𝛼 ∗ 𝐶𝑜𝑛𝑠𝑡𝑎𝑛𝑡 + 𝛽! 𝐿𝐸𝑉 + 𝛽! 𝑅𝐵𝐶𝑅 + 𝛽! 𝑈𝐹𝑆 + 𝛽! 𝐴𝑆𝐿𝑅 + 𝛽! 𝐵𝐵 + 𝛽! 𝑆𝐼𝑍𝐸 + 𝛽! 𝑂𝐵𝑆 + 𝛽! 𝐵𝐿𝐵𝐷 + 𝛽! 𝐿𝐿𝑅𝑅 + 𝛽!" 𝑀𝑄 + 𝛽!! 𝑅𝑂𝐸 + 𝛽!" 𝑈𝐹𝑆 + 𝛽!" 𝐺𝐴𝑃 + 𝛽!" 𝑅𝐼𝑅 𝐸 + 𝛽!" 𝐹𝑆𝐼 + 𝜀 3.1. Pooled sample analysis In this step, we also use the neural-network estimator in addition to the traditional linear firstdifference estimator to estimate the pooled sample. The rationale for using the neural-network approach is that banking strategies are usually interdependent in banks’ business operation. Especially in terms of riskiness, this interdependency can be interpreted as the amplification effect of one risky banking strategy on another strategy or both has the similar effect on each other. This peculiarity of banking strategies has been highlighted by many authors: for instance, the relation between ROE and leverage (Galai and Masulis, 1976; Saunders, Strock and Travlos, 1990), the relation between leverage and liquidity (Adrian and Shin, 2010; Brunnermeier et al, 2009), the relation between the bank size and ROE and leverage (Boyd and Runkle, 1993), the fact that banks' off-balance-sheet activities are usually supported by short-term funding strategies (Borio 2008). Obviously, this interdependency brings nonlinearity to the econometric modeling. Therefore, we are motivated to take into account the interdependency between banking strategies by using a nonlinear approach as a complement to the linear approach. 10 The nonlinear method we used here is the neural-network approach, a nonlinear method coming from the brain science of cognitive theory and neurophysiology, to this empirical study with the purpose of finding which strategies of the bank can cause banks' losses.12 Indeed, economists started to adopt neural network methods after a great technical improvement in these methods, namely the application of back-propagation to neural network learning (Rumelhart et al. 1986).13 Without loss of generality, we use in this step the traditional (one hidden layer with three neurons) Multi-layer-perceptron (MLP) neural network to conduct our estimation. 14 In addition, we introduce a linear ''perceptron'' (jump connections) in addition to the nonlinear structure in order to capture the linear relation. As a result, this structure allows us to capture both nonlinear relations and potential linear relations. The hybrid optimization coupling gradient-descent and genetic algorithm methods15 with the help of MATLAB programming allows us to perform the estimation. Table 4 and 5 show the result of pooled-sample estimation by use of linear first-difference estimator and nonlinear neural-network approach. 3.2. Panel data estimation In this step, we perform the estimation on our panel-data sample of 225 observations (25 banks during 9 years from 2000 to 2008). Table 5 also provides econometric results with two types of estimators we used in this panel data estimation, random-effect and fixed-effect estimator. 12 See McNelis (2005) for details in neural-network methodology. 13 This tool has been used for analyzing economic problems by a series of authors, especially in two fields, timeseries prediction and classification of economic agents. For application of neural network in time-series prediction, for instance, White (1988) is interested in the capital market and use neural network to test the efficient market hypothesis, and Bosarge (1993) argue that neural network allowing for nonlinearities can improve the quality of forecast, and also some articles invested in other areas, such as the one of Franses and Draisma (1997) and Swanson and White (1997) for macroeconomic variables, Church and Curram (1996) for consumers’ expenditure, or Kohzadi et al. (1995) for agricultural economics. 14 Several architectures of neural network have been applied to economic studies (McNelis, 2005). However, as summarized by Hamzaçebi, Akay and Kutay (2009), the most widely used type is the Multi-Layer-Perceptron (MLP) neural network, which belongs to feed forward networks. Besides, Hornik, Stinchcomb, and White (1989) argue that one hidden layer with two or three neurons yields good results in nonlinear function approximation at any accuracy level. 15 Quagliarella and Vicini (1998) who point out that hybridization coupling gradient-descent and genetic algorithm methods may lead to better solutions than those obtainable using the two methods individually 11 3.3. Results The first-step estimation by use of neural-network approach and first-difference estimator shows that the between comparison among sampled banks without taking into account time serial feature allows to identify the significance of following variables, UFS_E, LLRR, LEV, UFS, RBCR, MQ, ROE, SIZE and two control variables, FSI and GAP. In the second step panel-data techniques (random effect and fixed effect) validate MQ, UFS_E, SIZE, RBCR, LLRR, GAP.16 However, when we focus on the performance of two panel-data techniques we use in the second step, we find that the random effect estimator is more similar to the pooled OLS estimator than to the fixed effect estimator.17 Therefore, the result of fixed effect estimator that is less biased prevails. More precisely, the only three explanatory variables that have a significant impact on bank results are loan loss provision (management strategy), size and the interaction between liquidity and capitalization strategy. 3.3.1. Management strategy Loan loss provision and managerial quality are both negatively significant to bank results.18 It means that an increase in loan loss reserves and managerial expenses will cause losses to the bank. Therefore, a risky management strategy is detrimental to the bank’s stability. The impact of managerial quality on bank results is intuitive. High managerial expenses signify a less efficient management of the bank. As in a nonfinancial firm, a poor management is more likely to generate unexpected costs and to lower the firm’s performance. Likewise, when a bank’s managerial quality is low, it is prone to assuming more losses. Concerning loan loss provision, its impact is composed of two aspects. Firstly, a high loan loss 16 Because LEV, UFS, ROE, FSI are validated by neither of two panel-data estimators, we exclude them from significant variables. 17 Starting from the error-component model 𝑦!" = 𝛽! + 𝛽! 𝑥!" + 𝑣! + 𝜖!" , the random effect estimator is obtained by applying pooled OLS to the date after the following transformation, 𝑦!" − 𝜃𝑦! = 𝛽! 1 − 𝜃 + 𝛽! 𝑥!" − 𝜃𝑥! + { 1 − 𝜃 𝑣! + 𝜖!" − 𝜃𝜖! }. By calculating 𝜃 = 1 − 𝜎! ! /(𝑇𝜎! ! + 𝜎! ! ) , if 𝜃 is close to 0, the random effect estimator is similar to pooled OLS. On the contrary, the random effect estimator is similar to fixed effect estimator. In our random effect estimation, 𝜃 = 0.08. 18 We explain the effect of managerial quality in this section, because it is still validated by three estimators. 12 provision means that bank managers have realized some potential risks in the bank’s loan portfolio. Then they have to increase the loss provision to cover these risks. This behavior is the result of a decrease in loan portfolio quality that will cause losses to the bank in the future. Secondly, the increase in loan loss provision is also a signal to the market. When the bank manager announces a high loan loss provision, it is equivalent to telling its customers and market investors that the portfolio quality of the bank is lowering and it will be proved by loan losses in following periods. As soon as customers and investors receive this message, they are willing to protect themselves by reducing their exposure to this bank rather than to stick with the bank. As a result, the bank’s difficulties are self-fulfilling and aggravated by loss of confidence. 3.3.2. Size Amongst portfolio strategy variables, size is the only variable that is significant to bank results in our econometric study. This result indicates the negative effect of bank size on bank results and stability. In fact, this effect is obvious. The rationale for the fact that one bank decides to increase its size by holding more assets is the presence of economies of scale and market power. Therefore, increased bank size allows large banks to make more profits. However, these banks correspondingly have to assume more risks. Even if they can reduce risk with the help of portfolio diversification or risk transfer techniques, they are still exposed to systemic risk that is not diversifiable and could cause important losses to these large banks. 3.3.3. Interaction between liquidity and capitalization strategy The insignificance of liquidity strategy variables and the lack of robust significance of capitalization strategy show that the negative contribution of the increase in the risk level of a single strategy (liquidity or capitalization) to the bank’s stability is limited.19 Then, regulation on one single strategy is less efficient. That’s why many authors criticize the risk-based capital regulation (see for example, Blum, 1999; Rime, 2001; Ayuso, Pérez, and Saurina, 2004). Some authors emphasize the necessity of the introduction of risk-independent leverage restriction (e.g. Blum, 2008). Nevertheless, our result suggests that banking regulation that only relies on 19 We consider LEV and RBCR are less significant, because only two estimators validate them. Particularly, the unbiased model, the fixed effect estimator rejects their significance. 13 capitalization regulation is not sufficient to limit the impact of banks’ risk taking on their stability. The significance of the interaction between liquidity and capitalization strategy is the most important result we obtain in this empirical study. It shows that an increase in unstable-funding sources relative to equity capital will negatively affect bank results, namely bank losses. As this variable measures the interaction between liquidity and capitalization strategy of the bank, a high unstable-funding sources to equity ratio (UFS_E ratio) can be interpreted as follows. This ratio is obtained by dividing unstable-funding ratio (UFS ratio) by simple leverage ratio (equity-to-assets ratio). These two ratios are proxy for banks’ liquidity strategy and capitalization (leverage) strategy, respectively. Therefore, a high UFS_E ratio corresponds to the joint implementation of risky liquidity strategy (high UFS ratio) and risky capitalization strategy (low equity-to-assets ratio). As a result, the bank can be destabilized by the implementation of both risky liquidity strategy and risky capitalization strategy by banks. Why this interaction between two strategies explains bank results better than a separate strategy? The rationale is that banks always try to bypass the regulation by using risky strategies that are currently less regulated or unregulated. As we know, from the Basel I to Basel II the main spirit of banking regulation is capital adequacy requirements, whatever it is risk-based or not. According to regulators, if the bank takes more risks, it has to hold more equity capital that is costly to the bank. However, financial innovations help banks to easily decrease its regulatory charges. Indeed, through various ways, banks have transferred their risk to other banks, to other financial institutions, even to the whole financial system. Amongst these ways, the most popular one is the use of more short-term (unstable) funding sources instead of equity capital with the help of securitization or the creation of off-balance sheet entities. Then, the bank is able to use economizing on equity capital to invest in more risky activities. Consequently, the bank’s instability not only stems from the lack of equity capital, but also from the lack of stable-funding sources. 4. Further analysis on SPE The lesson of subprime crisis motivates regulators and academics to rethink the future regulatory reform in the banking system, regulatory tools as well as regulatory perimeter. Many authors 14 establish that the increase in the importance of banks’ off-balance sheet activities in recent years have a detrimental impact on the bank’s stability. Most of them point out that the main destabilizing factor of banks’ off-balance sheet activities is the close link between banks and the shadow banking system they sponsor (e.g. Adrian and Shin, 2009; Gorton et al., 2010). Especially in subprime crisis, Special Purpose Entities (SPEs) created by banks to securitize their risky assets and to get short-term funding sources instead of equity capital should be partly responsible for the liquidity problem of the bank and the decrease in stability of the whole financial system (e.g. Shin, 2009; Brunnermeier, 2009). Nevertheless, in our econometric estimation, off-balance sheet activities are not a significant variable to bank results. That is to say, the increase in off-balance sheet activities will not significantly raise the bank’s risk level, or cause losses to the bank. Intuitively, it seems inconsistent with the arguments we mentioned above. The reason is that the proxy for this variable we used in our study cannot include all off-balance sheet activities and especially their impact. As we introduced above, our proxy is off-balance sheet items reported in banks’ annual report. The main components of these items are contingent liabilities and loan commitments. Boot and Thakor (1991) establish that loan commitments may reduce banks’ portfolio risk. According to their argument, the insignificance of our proxy variable could be explained by the counterbalancing effect of loan commitments and other risky off-balance sheet activities on the bank’s stability. Besides, the proxy we used here neglects the effect of shadow banking system, especially SPEs created by banks. In fact, before 2008, banks are not forced to disclose information about their off-balance sheet entities.20 For this reason, in our econometric model, it is impossible to capture the important impact of bank-sponsored SPEs on the bank’s stability, so that the estimation of the effect of off-balance sheet variable is biased. 20 The Pillar III of Basel II about prudential information disclosure began to be reported by individual banks from 2008, and in this report one can find more details about banks’ off-balance sheet activities. European Central Bank also paid attention to the impact of banks’ SPEs (the term used by ECB is Financial Vehicle Corporations, FVC) on financial stability, so ECB has forced banks to report FVC statistics since 2010. 15 Even though we do not have enough information on SPEs created by our sampled banks, through our following crude analysis we still try to provide some inspiration for further researches on the negative contribution of bank-sponsored SPEs to the bank’s stability. This supplementary study on SPEs is based on the list provided by Bank of England, which quarterly reports general information on SPEs of which parent banks (23 banks) are installed in UK. The period we choose to analyze SPEs is from 2005 to 2008 as well as our econometric sample.21 By focusing on these SPEs’ parent banks, we try to analyze the impact of the creations and the type of securitization of these SPEs on banks’ funding structure, namely the interaction between risky capitalization and liquidity strategies (UFS/E). The dataset we used in this section to test this relationship is also a panel data that contains 92 observations. Table 6 shows that neither the number of SPE creation nor the type of securitization can significantly affect banks’ funding structure. This result establishes that the issuance of SPEs will not increase the riskiness of the joint implementation of liquidity and capitalization strategies. As we mentioned above, without enough detailed information on these SPEs we cannot conclude that SPEs created by banks do not have any negative impact on the bank’s stability. On the contrary, our result affirms that the lack of sufficient detailed information on shadow banking system constrains the measurement of banks’ liquidity risk. Therefore, we suggest both the necessity of a qualitative aspect in liquidity regulation and the need for transparency in the banking system. 5. Conclusion and policy implications One result of this paper that the risky leverage strategy and the risky liquidity strategy alone are not significant to the bank's losses justifies the idea of Ondo Ndong, Scialom, and Zhang (2010). They provide empirical evidence for the argument that focusing only on the solvency regulation, such as what regulators did for a long time, cannot reduce the bank's risk taking. By using the neural network approach and panel data techniques, we find as one of main results in this paper that the joint implementation of risky liquidity and leverage strategies has a negative effect can 21 23 banks domiciled in UK created 123 SPEs during 2005 and 2008. Indeed, because many banks in this sample did not report detailed financial information before 2005, data availability force us to concentrate on this short fouryear period. 16 cause more losses to the bank. As a consequence, the future regulation has to limit the joint use of these two types of risky strategies. Technically, capitalization regulation should not be considered as the only efficient regulatory approach to limit banks’ risk taking, and regulators have to pay attention to liquidity regulation that is proved in our study as an efficient complementary tool to capitalization regulation. In addition, the lesson from SPEs evidence shows that only the quantitative method is not sufficient to limit banks’ liquidity risk. The future liquidity regulation requires a qualitative aspect as well as the quantitative aspect that has already drawn regulators’ attention (e.g. BIS, 2010, Basel III agreements on Core Liquidity Ratio and Net Stable Funding Ratio). 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Proceeding of the IEEE International Conference on Neural Networks II, 451–458. 21 Appendix Table 1 Data sample description Period: from 2000 to 2008 Number of banks: 25 Number of observations: 225 Code Bank Country 1 Bank of Scotland Plc GB 2 ABN Amro Holding NV NL 3 Banco Santander SA ES 4 Lloyds TSB Bank Plc GB 5 Dexia Crédit Local SA FR 6 HSBC France FR 7 Dexia Bank Belgium - Dexia Bank BE 8 Crédit Industriel et Commercial - CIC FR 9 Banco Bilbao Vizcaya Argentaria SA ES 10 Allied Irish Banks plc IE 11 Landesbank Berlin Holding AG - LBB Holding AG DE 12 Nordea Bank Finland Plc FI 13 Northern Rock (Asset Management) Plc GB 14 Le Crédit Lyonnais (LCL) FR 15 Anglo Irish Bank Corporation Limited IE 16 Banco Espirito Santo SA PT 17 Irish Life & Permanent Plc IE 18 Bradford & Bingley Plc GB 19 Crédit du Nord FR 20 Caja Laboral Popular Coop. de Crédito ES 21 Banco Cooperativo Espanol ES 22 SkandiaBanken SE 23 Banco Itau Europa S.A. PT 24 Fionia Holding A/S DK 25 Bankaktieselskabet Alm. Brand Bank DK 22 Table 2 Variables description Variable Proxy Code Dependant: Bank results Credit supply variation VAR Capitalization strategy Leverage Regulatory-capitalization LEV RBCR Unstable funding ratio UFS Asset-side liquidity ratio Portfolio structure ASLR BB Size SIZE Off-balance sheet activities Interbank activities Asset quality Management quality ROE policy OBS BLBD LLRR MQ ROE Interaction between liquidity and capitalization strategy Unstable funding to equity ratio UFS_E Total short-term funding (customer deposits excluded) to equity Control variable Output gap Domestic interest rate Financial sector importance GAP DIR FSI (Actual GDP - Potential GDP) / Potential GDP Interest rate of domestic country Aggregated MFI balance sheet to GDP Liquidity strategy Portfolio strategy Management strategy Description Net loans variation from the last year to the present year Equity to total assets ratio Total regulatory capital to risk-adjusted assets ratio Total short-term funding (customer deposits excluded) to total funding sources Liquid assets to short-term funding sources Banking book assets to total assets ratio Total assets relative to total balance sheet of MFIs in domestic country Off-balance sheet items to total assets Bank loans to bank deposits Loan loss reserve ratio Overheads to total assets Returns on average equity Table 3 Descriptive statistics Variable Obs Mean Std. Dev. Min Max VAR 225 0.1348264 0.2012992 -0.7548397 1.184435 UFS 225 0.2682083 0.1814412 0.0025743 0.9368266 LEV 225 0.0490644 0.0286257 -0.0076543 0.1750997 RBCR 225 11.90089 2.984229 8.1 27.1 BB 225 0.8613856 0.1149114 0.3094596 0.9947096 OBS 225 0.2149386 1.182854 0 17.70003 LLRR 225 1.917156 1.857921 0 11.49 MQ 225 0.0154578 0.0096594 0.0017804 0.0683492 ROE 225 11.08236 18.19471 -178.93 45.54 BLBD 225 131.7282 144.5549 4.423764 923.1164 ASLR 225 41.3214 58.15818 1.268683 504.5263 SIZE 225 10.24307 18.26299 0.2479586 132.3618 UFSE 225 6.967914 8.99741 -59.59816 44.92315 GAP 225 2.255952 2.232136 -1.841209 9.003569 RIR 225 1.275949 1.456735 -1.526981 5.244417 FSI 225 3.519701 1.58301 0.9915413 9.420238 23 Table 4 Neural network results Dependent variable: Credit supply variation (VAR) Explanatory variables UFS LEV RBCR BB OBS LLRR MQ ROE BLBD ASLR SIZE UFS/E GAP RIR FSI DW HQIF RMSQ R-squared LWG TEST NN model 0,0073 (0.4274) 0.1319 (1) -0.2375*** (0) 0.0336 (0.9179) -0.0232 (0.6042) -0.1397*** (0) -0.2478*** (0) 0.077 (0.8947) 0.0611 (0.3116) -0.0009808 (0.8316) 0.0301 (0.5432) -0.2579*** (0) 0.1161 (1) -0.009 (0.88) -0.0616*** (0) 1.947 550.2979 0.5384 0.2344 0.20% The neural network model is bootstrapped 500 times to obtain the coefficient and the associated P-value (in parenthesis) of each explanatory variable. *** denotes the statistical significance at the 1%. LWF test is the specific test in neural network modeling in order to examine whether there exists a neglected nonlinearity. Our result, 0.003 for this test signifies that all nonlinearities are taken into account by our neural network. 24 Table 5 Pooled and panel data estimation Dependent variable: DVAR (Pooled model); VAR (Random effect and fixed effect) Explanatory variables Pooled model Random effect Fixed effect UFS -0.420896* 0.1472384 -0.2141103 (-1.67) (1.14) (-1.2) -5.674162** 1.101552 -0.5135375 (-3.01) (1.59) (-0.36) 0.0171186 -0.0225638*** -0.0112004 (1.4) (-3.41) (-1.3) 0.4774725 0.0911321 0.0975253 (1.61) (0.74) (0.51) 0.0048272 -0.0038071 0.0093081 (0.51) (-0.35) (0.81) -0.0393883** -0.0243568*** -0.0302584*** (-2.24) (-2.79) (-2.27) -9.927754*** -6.228728*** -4.868252 (-2.67) (-3.37) (-1.64) 0.0023443* 0.000967 0.00063 (1.85) (1.09) (0.58) -0.0000951 0.0001821 0.0002298 (-0.49) (1.28) (1.33) 0.0009762 -0.0001258 0.0003106 (1.53) (-0.36) (0.57) 0.008415*** 0.000102 0.005432*** (2.84) (0.14) (2.64) -0.0073298** -0.0070943*** -0.0057592** (-2.4) (-2.93) (-1.99) 0.0230974** 0.019799*** 0.0179653* (1.89) (2.76) (1.88) 0.0193723 -0.0012857 0.0011203 (1.41) (-0.14) (0.1) LEV RBCR BB OBS LLRR MQ ROE BLBD ASLR SIZE UFS_E GAP RIR 25 FSI -0.1082853*** -0.0148479 -0.0301881 (-2.66) (-1.3) (-1.59) 0.403229*** 0.3966918* (2.9) (1.68) CONSTANT R-squared 0.29 0.2 0.13 Number of observations 200 225 225 Pooled model estimation proceeds with the first-difference estimator. This table reports the estimated coefficients and associated T-statistics (in parenthesis, Z-statistics for random-effect model). *, **, ***, denote the statistical significance at the 10%, 5% and 1%, respectively. Table 6 Panel data estimation for SPEs Dependent variable: DUFS_E (Pooled model); UFS_E (Ramdom effect and fixed effect) Explanatory variables Pooled model Random effect Fixed effect NBI 0.0559794 (0.26) 0.0986963 (0.43) 0.0442004 (0.18) TYPE -0.1359412 (-0.16) -1.823181* (-1.8) -1.40757 (-1.29) 5.549475*** (7.53) 5.441633*** (9.61) CONSTANT R-squared 0.001 0.03 0.03 Number of observations 69 92 92 NBI denotes the number of SPE issuance, and TYPE denotes the type of securitization of SPEs. Pooled model estimation proceeds with the first-difference estimator. This table reports the estimated coefficients and associated Tstatistics (in parenthesis, Z-statistics for random-effect model). *, **, ***, denote the statistical significance at the 10%, 5% and 1%, respectively. 26
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