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The Countercyclical Capital Buffer of Basel III: A Critical Assessment

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We provide a critical assessment of the countercyclical capital buffer in the new regulatory framework known as Basel III, which is based on the deviation of the credit-to-GDP ratio with respect to its trend. We argue that a mechanical application of the buffer would tend to reduce capital requirements when GDP growth is high and increase them when GDP growth is low, so it may end up exacerbating the inherent pro-cyclicality of risk-sensitive bank capital regulation. We also note that Basel III does not address pro-cyclicality in any other way. We propose a fully rule-based smoothing of minimum capital requirements based on GDP growth.
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... When economic conditions deteriorate, banks can draw down this buffer to absorb losses and maintain lending. This mechanism helps to smooth the credit cycle, preventing the build-up of systemic risk during booms and supporting lending during busts, thus contributing to financial stability (Repullo & Saurina, 2011). According to Repullo & Saurina (2011), the implementation of countercyclical capital buffers has been shown to reduce the procyclicality of the financial system and enhance its resilience to economic shocks. ...
... This mechanism helps to smooth the credit cycle, preventing the build-up of systemic risk during booms and supporting lending during busts, thus contributing to financial stability (Repullo & Saurina, 2011). According to Repullo & Saurina (2011), the implementation of countercyclical capital buffers has been shown to reduce the procyclicality of the financial system and enhance its resilience to economic shocks. ...
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... For example, Hamilton (2018) argues that the HP filter produces spurious dynamics that are not based on the underlying data and the data obtained in the middle and at the end of the sample are different. Repullo and Saurina (2011) claim that decision making on the countercyclical capital buffer based on a mechanical application of the Basel gap would lead to reduce capital requirements in bad times and vice versa. Other papers indicate that in certain countries the Basel gap underestimated risks during a period of excessive credit growth and reported negative credit gap (Castro et al., 2016;Lang and Welz, 2017;Lang et al., 2019, Baba et al., 2020. ...
... Alan Greenspan, 2001. 33 Addressing the evolution of risk over time in the financial sector and its pro-cyclical behaviour has become a crucial concern for academics and policy-makers (see Repullo and Saurina (2011) and Repullo, Saurina, and Trucharte (2010)). The Bank for Inter-national Settlements, in its 2009 annual report, defines procyclicality as "the fact that, over time, the dynamics of 32 In a similar approach, Huang, Zhou, and Zhu (2012) propose a new indicator, Distress Insurance Premium (DIP), for measuring systemic risk. ...
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... Repullo & Saurina, 2011). The stock nature of credit and the flow nature of the GDP mean that the impact of economic slowdown becomes apparent slower and more gradually in the amount of credit. ...
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