The Canadian prudential regulator (OFSI) has made an interesting contribution to the capital buffer space via its introduction of a Domestic Stability Buffer (DSB).
Key features of the Domestic Stability Buffer:
- Applies only to Domestic Systemically Important Banks (D-SIB) and intended to cover a range of systemic vulnerabilities not captured by the Pillar 1 requirement
- Vulnerabilities currently included in the buffer include (i) Canadian consumer indebtedness; (ii) asset imbalances in the Canadian market and (iii) Canadian institutional indebtedness
- Replaces a previously undisclosed Pillar 2 loading associated with this class of risks (individual banks may still be required to hold a Pillar 2 buffer for idiosyncratic risks)
- Initially set at 1.5% of Total RWA and will be in the range of 0 to 2.5%
- Reviewed semi annually (June and December); with the option to change more frequently in exceptional circumstances
- Increases phased in while decreases take effect immediately
Implications for capital planning:
- DSB supplements the Pillar 1 buffers (Capital Conservation Buffer, D-SIB surcharge and the Countercyclical Buffer)
- Consequently, the DSB will not result in banks being subject to the automatic constraints on capital distributions that are applied by the Pillar 1 buffers
- Banks will be required to disclose that the buffer has been breached and the OFSI will require a remediation plan to restore the buffer
What is interesting:
- The OFSI argues that translating the existing Pillar 2 requirement into an explicit buffer offers greater transparency which in turn “… will support banks’ ability to use this capital buffer in times of stress by increasing the market’s understanding of the purpose of the buffer and how it should be used”
- I buy the OFSI rationale for why an explicit buffer with a clear narrative is a more usable capital tool than an undisclosed Pillar 2 requirement with the same underlying rationale
- The OFSI retains a separate Countercyclical Buffer but this Domestic Stability Buffer seems similar but not identical in its over-riding purpose (to me at least) to the approach that the Bank of England (BoE) has adopted for managing the Countercyclical Buffer.
- A distinguishing feature of both the BoE and OFSI approaches is linking the buffer to a simple, coherent narrative that makes the buffer more usable by virtue of creating clear expectations of the conditions under which the buffer can be used.
Bottom line is that I see useful features in both the BoE and OFSI approach to dealing with the inherent cyclicality of banking. I don’t see either of the proposals doing much to mitigate the cyclicality of banking but I do see them offering more potential for managing the consequences of that cyclicality. Both approaches seem to me to offer material improvements over the Countercyclical Buffer as originally conceived by the BCBS.
It will be interesting to see if APRA chooses to adapt elements of this counter cyclical approach to bank capital requirements.
If I am missing something, please let me know …
From the Outside