The Basel Committee on Banking Supervision is
proposing to introduce, in 2006, new risk‑based requirements for
internationally active (and other significant) banks. These will replace
the relatively risk‑invariant requirements in the current Accord.
This article examines the implications of this new risk‑based regime
for procyclicality of minimum capital requirements – in particular
whether the choice of particular loan rating system by the banks would
significantly increase the likelihood of sharp increases in capital
requirements in recessions, creating the potential for classic credit
crunches. The paper finds that rating schemes that are designed to be more
stable over the cycle, akin to those of the external rating agencies,
would not increase procyclicality, but ratings that are conditioned on the
current point in the cycle, akin in some respects to a Merton approach,
could substantially increase procyclicality. This makes the question of
which rating schemes banks will use very important. The paper uses a
general equilibrium model of the financial system to explore whether banks
would choose to use a countercyclical, procyclical or neutral rating
scheme. The results indicate that banks would not choose a stable rating
approach, which has important policy implications for the design of the
Accord. It makes it important that banks are given incentives to adopt
more stable rating schemes. This consideration has been reflected in the
Committee’s latest proposals, in October 2002.
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