John J. Mingo

Policy implications of the Federal Reserve study of credit risk models at major US banking institutions

Abstract The current regulatory capital standard for banks – the Basle Accord – is a lose/lose proposition. Regulators cannot conclude that a bank with a nominally high regulatory capital ratio has a correspondingly low probability of insolvency. On the other hand, because the Accord often levies a capital charge out of proportion to the true economic risk of a position, banks must engage in “regulatory capital arbitrage” (or exit their low risk business lines). Since such arbitrage is costly, the capital regulations keep banks from maximizing the value of the financial firm. Regulators need to answer three questions: (1) What are the goals of prudential regulation and supervision? (2) How should bank “soundness” be defined and quantified? (3) At what level should a minimum “soundness” standard be set in order to meet the (perhaps conflicting) goals of prudential regulation and supervision? Possible answers to these questions are attempted, then the paper analyzes the two leading proposals for rationalizing the Accord – a “modified-Basle” (or ratings-based) approach and a “full-models” approach.

Credit risk modeling and internal capital allocation processes: implications for a models-based regulatory bank capital standard

Abstract This paper surveys the current state-of-the-art in credit risk modeling at large U.S. banks. Within this context, the paper examines the near-term feasibility of an internal models approach to setting formal regulatory capital requirements for banks, as a replacement for the 1988 Basle Accord. Such an overhaul of the international capital standards would require, in our view, specific attention to several deficiencies in current modeling practices, including questions relating to model specification, parameter estimation, and model validation procedures. The paper also discusses possible uses of internal risk models for setting regulatory capital requirements against selected credit instruments and/or improving examination guidance dealing with the capital adequacy of large, complex banking organizations.

Bank capital requirements for securitized loan pools

Abstract This paper analyzes the riskiness of credit enhancements offered on securitized pools of commercial and industrial loans. It develops a technique for allocating capital to such credit enhancements, based on setting the expected value of the credit losses in excess of allocated capital equal to the expected value of losses beyond required capital on the original loan pool. The resulting capital allocations are compared with those derived from a more general, bank-wide capital decision-rule, as well as newly published agency proposals regarding capital for credit enhancements.

The microeconomics of deposit rate ceilings : Inferences for NOW accounts and interest on checking accounts

Abstract This paper examines the specific set of market and product conditions which could support the theoretical argument, widely held among commercial bankers, that deposit rate ceilings, especially the prohibition of interest on checking accounts, are beneficial to bank earnings. The analysis points to the conclusion that ceilings are beneficial to bankers only if (a) bank deposits are homogeneous goods, (b) deposit markets are non-collusive oligopsonies, and (c) the regulated ceiling rate is not set too far below the ceiling that would exist in an unregulated monopsony. Empirical studies done elsewhere seem to indicate that none of these three necessary conditions are normally met in the marketplace. The NOW account, which is really an interest-bearing checking account, also extends demand deposit powers to non-bank thrift institutions. Under our analysis, the NOW account adds to the number of competitors offering checking-type deposits, driving up the cost of funds, other things equal, to the oligopsonist banker — perhaps by enough to offset the cost-reducing effect of repeal of the interest prohibition.