By Thomas F. Huertas (auth.)
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Additional resources for Safe to Fail: How Resolution Will Revolutionise Banking
The higher the ratio (or the more the bank finances itself with equity), the lower the risk of the bank (all other things being equal). It’s when one starts to look at what’s in the ratio that things get more complex. What counts as capital for the purposes of the leverage ratio? Total capital, Tier 1 capital, common equity Tier 1 capital before/after deductions of goodwill, deferred tax assets and other items in the so-called sin bucket? There are proponents and rationales for each of these definitions, but both supervisors and market participants appear to have converged on total Tier 1 capital as the standard to be used in calculating the numerator in the leverage ratio.
In aggregate, the composite provided by the collection of risk limits should mesh with the top-down statement of risk appetite. According to the Financial Stability Board, the bank’s board of directors should assure that the bank has a sound RAF – yet further evidence of the increasing responsibility for good governance that supervisors are demanding that boards assume. Management should be responsible for the development of the RAF. The CEO (with the support of the CFO and CRO) should set the tone from the top, so that the RAF and RAS influence the risks the bank decides to take or not take and how the bank manages the risks it does take.
37 These steps have prompted a response from the United States. 38 Consequently, the United States took the view that it would have to look after the US operations of foreign banking organisations (FBOs). If that was to be the case, the US authorities reasoned that the US operations of FBOs should meet within the United States the same standards with respect to capital, liquidity, governance and data management as US banking organisations. To facilitate this outcome (and assure that it would be the primary supervisor of FBOs in the United States) the Federal Reserve has mandated that FBOs form an intermediate holding company to hold all of the FBOs’ US subsidiaries.
Safe to Fail: How Resolution Will Revolutionise Banking by Thomas F. Huertas (auth.)