Category: Uncategorized

Self regulation in DeFi

This article in Wired offers a useful summary of how some motivated individuals are attempting to use the transparency of the system to control bad actors.

It is short and worth reading in conjunction with this paper titled “Statement on DeFi Risks, Regulations, and Opportunities Commissioner Caroline A. Crenshaw that sets out a US regulator’s perspective on the question of how DeFi should be regulated. This extract from the paper covers the main thrust of her argument in favours of formal regulation

While DeFi has produced impressive alternative methods of composing, recording, and processing transactions, it has not rewritten all of economics or human nature. Certain truths apply with as much force in DeFi as they do in traditional finance:

– Unless required, there will be projects that do not invest in compliance or adequate internal controls;

– when the potential financial rewards are great enough, some individuals will victimize others, and the likelihood of this occurring tends to increase as the likelihood of getting caught and severity of potential sanctions decrease; and

– absent mandatory disclosure requirements,[10] information asymmetries will likely advantage rich investors and insiders at the expense of the smallest investors and those with the least access to information.

Accordingly, DeFi participants’ current “buyer beware” approach is not an adequate foundation on which to build reimagined financial markets. Without a common set of conduct expectations, and a functional system to enforce those principles, markets tend toward corruption, marked by fraud, self-dealing, cartel-like activity, and information asymmetries. Over time that reduces investor confidence and investor participation.

Conversely, well-regulated markets tend to flourish

“Statement of DeFi Risks, Regulations and Opportunities” by Commissioner Caroline A Crenshaw, The International Journal of Blockchain Law, Vol. 1, Nov. 2021.

Tony – From the Outside

JP Koning’s “over consumptionist” theory of Bitcoin and decentralisation

Interesting post by JP Koning exploring the current debate about the value of Bitcoin and its energy demand.

There are two extreme theories about cryptocurrency energy consumption, both of them bitterly opposed to each other. The first I’ll call the big waste theory. Cryptocurrencies such as Bitcoin and Ethereum serve no useful purpose. Yet they are sucking up huge amounts of useful electricity. Let’s ban them.

The second theory is the vital cog theory. Cryptocurrencies are a useful bit of global financial infrastructure. And so the huge amounts of energy that they are consuming is beneficial. Let’s not impede them.

“The overconsumption theory of bitcoin (and decentralization in general)”, JP Koning, May 2021

Koning offers an alternative “overconsumptionist theory” – worth reading

Tony – From the Outside

Australian bank capital adequacy – building out the Unquestionably Strong framework

In this post, I lay out some problems that I have encountered in attempting to reconcile what it will mean for a D-SIB ADI to be “Unquestionably Strong” under the proposed new framework that APRA outlined in its December 2020 Discussion Paper (“A more flexible and resilient capital framework for ADIs”). Spoiler alert – I think the capital buffers adding up to a 10.5% CET1 prudential requirement may need to be recalibrated once all of the proposed changes to risk weights are tied down. I also include some questions regarding the impact of the RBNZ’s requirement for substantially higher capital requirements for NZ domiciled banks.

The backstory

The idea that Australian Authorised Deposit Taking Institutions (“ADIs” but more commonly referred to as “banks”) needed to be “Unquestionably Strong” originated in a recommendation of the Australian Financial System Inquiry (2014) based on the rationale that Australian ADIs should both be and, equally importantly, be perceived to be more resilient than the international peers with which they compete for funding in the international capital markets.In July 2017, APRA translated the FSI recommendation into practical guidance in an announcementsupported by a longer information paper.

For most people, this all condensed into a very simple message, the systemically important Australian ADIs needed to maintain a Common Equity Tier 1 (CET1) ratio of at least 10.5%. The smaller ADIs have their own Unquestionably Strong benchmark but most of the public scrutiny seems to have focussed on the larger systemically important ADIs.

In the background, an equally important discussion has been playing out regarding the extent to which the Unquestionably Strong framework should take account of the “comparability” and “transparency” of that measure of strength and the ways in which “flexibility” and “resilience” could be added to the mix. This discussion kicked off in earnest with a March 2018 APRA discussion paper (which I covered here) and has come to a conclusion with the December 2020 release of the APRA Discussion Paper explored in the post above.

December 2020 – “Unquestionably Strong” meets “A more flexible and resilient capital framework for ADIs”

I have written a couple of posts on APRA’s December 2020 Discussion Paper but have thus far focussed on the details of the proposed changes to risk weights and capital buffers (here, here and here). This was partly because there was a lot to digest in these proposals but also because I simply found the discussion of how the proposed new framework reconciled to the Unquestionably Strong benchmark to be a bit confusing.

What follows is my current understanding of what the DP says and where we are headed.

On one level, the answer is quite simple – Exhibit A from the Discussion Paper (page 17) …

APRA DP “A more flexible and resilient capital framework for ADIs” page 17
  • For systemically important ADI (D-SIB ADIs), the Unquestionably Strong 10.5% CET1 benchmark will be enshrined in a series of expanded capital buffers that will come into force on 1 January 2023 and add up to 10.5%.
  • However, we also know that APRA has at the same time outlined a range of enhancements to risk weights that are expected to have the effect of reducing aggregate Risk Weighted Assets and thereby result in higher capital adequacy ratios.
  • APRA has also emphasised that the net impact of the changes is intended to be capital neutral; i.e. any D-SIB ADI that meets the Unquestionably Strong benchmark now (i.e. that had a CET1 ratio of at least 10.5% under the current framework) will be Unquestionably Strong under the new framework
  • However this implies that the expected increase in reported CET1 under the new framework will not represent surplus capital so it looks like Unquestionably Strong will require a CET1 ratio higher than 10.5% once the new framework comes into place.

The only way I can reconcile this is to assume that APRA will be revisiting the calibration of the proposed increased capital buffers once it gets a better handle on how much capital ratios will increase in response to the changes it makes to bring Australian capital ratios closer to those calculated by international peers under the Basel minimum requirements. If this was spelled out in the Discussion Paper I missed it.

What about the impact of RBNZ requiring more capital to be held in New Zealand?

Running alongside the big picture issues summarised above (Unquestionably Strong, Transparency, Comparability, Flexibility, Resilience”, APRA has also been looking at how it should respond to the issues posed by the RBNZ policy applying substantial increases to the capital requirements for banks operating in NZ. I wrote two post on this issue (see here and here) that make the following points

  • To understand what is going on here you need to understand the difference between “Level 1” and Level 2” Capital Adequacy (part of the price of entry to this discussion is understanding more APRA jargon)
  • The increased share of the group capital resources required to be maintained in NZ will not have any impact on the Level 2 capital adequacy ratios that are the ones most commonly cited when discussing Australian ADI capital strength
  • In theory, maintaining the status quo share of group capital resources maintained in Australia would require some increase in the Level 2 CET1 ratio (i.e. the one that is used to express the Unquestionably Strong benchmark)
  • In practice, the extent to which the Level 2 benchmark is impacted depends on the maternity of the NZ business so it may be that there is nothing to see here
  • It is hard to tell however partly because there is not a lot of disclosure on the details of the Level 1 capital adequacy ratios (at least not a lot that I could find) and partly because the Level 1 capital measure is (to my mind) not an especially reliable (or indeed intuitive) measure of the capital strength
Summing up
  • There is I think a general consensus that the Australian D-SIB ADIs all currently exceed the requirements of what it means to be Unquestionably Strong under the current capital adequacy framework
  • This implies that they have surplus capital that may potentially be returned to shareholders
  • APRA has laid out what I believe to be pretty sensible and useful enhancements to that framework (the expanded and explicitly more flexible capital buffers in particular)
  • These changes have however (for me at least) made it less clear what it will mean for an ADI to be Unquestionably Strong post 1 January 2023 when the proposed changes to Risk Weighted Assets come into effect

Any and all contributions to reducing my ignorance and confusion will be gratefully accepted – let me know what I am missing

Tony – From the Outside

Tether offers a bit more detail on the composition of its reserves

… but Jemima Kelly at FT Alphaville remains a sceptic. I think the FT headline is a bit harsh (“Tether says its reserves are  backed by cash to the tune of . . .  2.9%”). Real banks don’t hold a lot of “cash” either but the securities they hold in their liquid asset portfolios will tend to be a lot better quality than the securities that Tether disclosed.

The role of real banks in the financial system may well be shrinking but the lesson I take from this FT opinion piece is that understanding the difference between these financial innovations and real banks remains a useful insight as we navigate the evolving new financial system.

Let me know what I am missing …

Tony – From the Outside

Explaining the value of Dogecoin

I don’t profess to be able to explain the value of Dogecoin but Matt Levine offers an interesting perspective curtesy of a research report published by Galaxy Digital Research. Apart from the left field explanation of what underpins Dogecoin’s value, the relatively short report (22 pages) offers a useful recap of the story of how this variation of digital money came to be.

Here is a short extract from the report

“When we set out to write this report, we expected to find what we’ve always known: Dogecoin is a joke, but it’s also a joke… not credible, resilient, or adopted. But as we reviewed the data, we found that, despite its deficiencies, Dogecoin has remarkably strong fundamentals and powerful forces supporting its rise: a genuine origin story, longevity, and a growing community of users who appear determined to meme a Shiba Inu-themed global currency into existence. We don’t expect Dogecoin to become the world’s most valuable cryptocurrency any time soon, but DOGE should not be ignored.”

“Dogecoin: The Most Honest Sh*tcoin” by Alex Thorn, Head of Firmwide Research and Karim Helmy, Research Associate, Galaxy Digital Research, 4 May 2021

Matt’s column has a link to the report itself which is worth a read if you are interested in Dogecoin in particular or the broader topic of digital money.

Tony – From the Outside

The Conversation: “Hostage to fortune: why Westpac could struggle to find the right buyer for its NZ subsidiary”

Another useful contribution to the question of how the Australian banks deal with changes in the capital requirements impacting their NZ subsidiaries.

Their conclusion is that Westpac will struggle to find a buyer at an acceptable price

The Conversation: “Hostage to fortune: why Westpac could struggle to find the right buyer for its NZ subsidiary”

Capital adequacy is not always intuitive

I did a short post yesterday scratching the surface of the issues associated with Westpac’s announcement that it is reviewing its options in New Zealand. In this post I will offer a little more background and comment focussed on the impact of Australian capital adequacy requirements.

The backstory thus far is that:

These combined changes obviously impact the economics of an Australian ADI owning a NZ regulated banks but to have any hope of understanding what is going on I believe we first need to define two pieces of Australian ADI capital jargon, Level 1 and Level 2

Level 1 is the ADI itself on a stand alone basis (note that is a simplification but close enough to the truth for the purposes of this post).

Level 2 is defined in APRA’s consultation paper as “The consolidation of the ADI and all its subsidiaries other than non-consolidated subsidiaries; or if the ADI is a subsidiary of a non-operating holding company (NOHC), the consolidation of the immediate parent NOHC and all the immediate parent NOHC’s subsidiaries (including any ADIs and their subsidiaries) other than non-consolidated subsidiaries.”

For completeness I should probably also define “ADI” which is an Authorised Deposit Taking Institution (more colloquially referred to as a bank).

You can be forgiven for not being familiar with the Level 1 – Level 2 distinction but the capital ratios typically quoted in any discussion of Australian ADI capital strength are the Level 2 measures. The Unquestionably Strong benchmark that dominates the discussion is a Level 2 measure. 

Part of the problem with the RBNZ initiative is that the increase in capital required to be held in the NZ part of the Group has no impact on the Level 2 capital ratio that is used to define the “Unquestionably Strong” benchmark the Australian ADI are expected to meet. The RBNZ is of course within its rights to set what ever capital requirement it deems appropriate but APRA then has to ensure that the increase in NZ based capital does not come at the expense of Australian stakeholders.

The Level 2 capital measure tells us nothing about this question. In theory this is where the Level 1 capital adequacy measure comes into play but I have always found the Level 1 measure a bit counter-intuitive.

  • My intuitive expectation is that the Level 1 measure for an Australian ADI should include the capital actually available in Australia and the risk exposures that capital has to underwrite.
  • What actually happens is that the dollar value of the Level 1 capital can be virtually the same as the Level 2 measure even though capital has been deployed in an offshore banking subsidiary (retained earnings in the subsidiary do not count but that can be addressed by paying a divided to the parent and then investing an equivalent amount of capital back in the subsidiary).
  • Level 1 risk weighted assets of the parent only incorporate an allowance for the risk weighted value of the equity invested in the banking subsidiary
  • This adjustment to the Level 1 risk weighted assets will of course be substantially less than the risk weighted assets the subsidiary is supporting with that equity that are excluded from the Level 1 parent capital ratio.
  • As a result, it is mathematically possible for the Level 1 CET1 ratio of the parent entity to be higher than the Level 2 Group ratio even though capital has been deployed outside the parent entity – that seems counter intuitive to me.

The changes that APRA has proposed to introduce will force the Australian banks to hold more capital to offset the impact of the CET1 deduction created when the investment in the banking subsidiary exceeds the (10%) threshold. As I understand it, this deduction only applies to the Level 1 measure so Level 2 capital will, all other things being equal, be higher as a result of responding to the combined impact of the RBNZ and APRA requirements. At face value that looks like stronger capital, which it is for the Group on average (i.e. Level 2), but the Australian parts of the banking Group do not benefit from the increase and it is important to understand that when evaluating the extent to which the Australian part of the banking group continues to be Unquestionably Strong.

APRA’s proposed change addresses the immediate issue created by the RBNZ requirement but I must confess that I still find the Level 1 capital adequacy measure a touch confusing. Level 1 capital ratios calculated on the basis I have set out above do not appear (to me at least) to offer an intuitively logical view of the relative capital strength of the various parts of the banking group.

As always, it is entirely possible that I am missing something here but understanding the technical issues outlined above is I think useful when making sense of the issues that Westpac (and other Australian ADIs) will be considering as they weigh their options in New Zealand. Relying on your intuition expectations of how the two requirements interact may be an unreliable guide if you are not familiar with the technical detail.

Tony – From the Outside

Westpac considers its options in NZ

Westpac today (24 March 2021) announced that it is “… assessing the appropriate structure for its New Zealand business and whether a demerger would be in the best interests of shareholders. Westpac is in the very early stage of this assessment and no decisions have been made.”

There are obviously a lot of moving parts here but one important consideration is the interaction between the substantial increase in capital requirements mandated by the RBNZ and APRA’s proposed change in the way that these investments must be funded by the Australian parent.

The rest of this post offers a short summary of how these investments are currently treated under the Australian capital adequacy standard (APS 111) and APRA’s proposed changes.

As a rule, APRA’s general capital treatment of equity exposures requires that they be fully deducted from CET1 Capital in order to avoid double counting of capital. The existing rules (APS 111) however provides a long-standing variation to this general rule when measuring Level 1 capital adequacy. This variation allows an ADI at Level 1 to risk weight (after first deducting any intangibles component) its equity investments in banking and insurance subsidiaries. The risk weight is 300 percent if the subsidiary is listed or 400 per cent if it is unlisted.

APRA recognises that this improves the L1 ratios by around 100bp versus what would be the case if a full CET1 deduction were applied but was comfortable with that outcome based on exposure levels that preceded the RBNZ change in policy.

The RBNZ’s move towards higher CET1 requirements however undermines this status quo and potentially sees a greater share of the overall pool of equity in the group migrate from Australia to NZ. APRA recognises of course that the RBNZ can do whatever it deems best for NZ depositors but APRA equally has to ensure that the NZ benefits do not come at the expense of Australian depositors (and other creditors).

To address this issue, APRA has proposed to amend APS 111 to limit the extent to which an ADI may use debt to fund investments in banking and insurance subsidiaries.

  • ADIs, at Level 1, will be required to deduct these equity investments from CET1 Capital, but only to the extent the investment in the subsidiary is in excess of 10 per cent of CET1 Capital.
  • An ADI may risk weight the investment, after deduction of any intangibles component, at 250 per cent to the extent the investment is below this 10 per cent threshold.
  • The amount of the exposure that is risk weighted would be included as part of the related party limits detailed in the recently finalised APS 222.

As APRA is more concerned about large concentrated exposures, it proposed to limit the amount of the exposure to an individual subsidiary that can be leveraged to 10 per cent of an ADI’s CET1 Capital. This means capital requirements are increasing for large concentrated exposures, as amounts over the 10 per cent threshold would be required to be met dollar-for-dollar by the ADI parent company.

You can find my original post here which offers more background and may be useful if you are not familiar with the technicalities of Level 1 and Level 2 capital adequacy. At the time the change was proposed, APRA indicated that it would release more detail during 2020 with the aim of implementing the change on 1 January 2021. Covid 19 obviously derailed that original timeline but I assume APRA will provide an update sometime soon.

Tony – From the Outside