From APRA chairman Wayne Byres’ keynote address to the AFR Banking & Wealth Summit 2017, Sydney:
Haven’t we done enough already?
The third question is: haven’t we done enough already?
The banking system certainly has higher capital adequacy ratios than it used to. But overall leverage has not materially declined. The proportion of equity that is funding banking system assets has improved only modestly, from a touch under 6 per cent a decade ago to just on 6½ per cent at the end of 2016.
The difference between improved risk-based measures of capital adequacy, and the more limited improvement in non-risk based measures of leverage (Chart 6), is driven to a significant degree by changes in asset composition. In particular, it reflects the increasing concentration of the banking system in mortgage lending (which benefits from lower risk weights – Chart 7).
It implies the system has de-risked more than deleveraged. But that assessment is itself premised on a critical assumption: that a high and increasing concentration in mortgages is generating a lower risk banking system. In the current environment, it is certainly an assumption that deserves a bit more scrutiny. While it might be a reasonable proposition most of the time, we need to be wary of the fallacy of composition when concentrations grow.
….The case for the Australian banking system to be seen as unquestionably strong remains as valid today as it did when the FSI recommended it in 2014. And, as much as we would like international policy deliberations to be complete, we do not think it right to defer a decision on this issue any longer…..
Bank leverage has barely improved despite substantial increases in capital ratios as banks have increasingly concentrated their exposure in residential mortgages which have lower risk-weighting. Chart 7 above shows how the average risk-weighting of bank assets has declined over the last decade.
Neel Kashkari, president of the Minneapolis Fed, believes that banks need to hold far higher capital in order to avoid future bailouts. His proposal:
….force banks to finance themselves with capital totaling 23.5% of their risk-weighted assets, or 15% of their balance-sheets without adjusting for risk (the “leverage ratio”). This, says Mr Kashkari, would be enough to guard the financial system against a shock striking many reasonably-sized banks at once. Any bank deemed too big to fail would need a still bigger buffer, eventually reaching an eye-watering 38% of risk-weighted assets….
It’s widely accepted that Australia’s big four banks are too-big-to-fail. If that is the case, applying Kashkari’s measure would require them to increase bank capital by 200%.
Even without the too-big-to fail buffer, the major banks would require a 100% increase in bank capital to meet the 23.5% capital requirement for risk-weighted assets. And a 150% increase to match the 15% minimum without risk weighting.
The question needs to be asked: is APRA doing enough to protect Australians from a financial crisis? To me the answer is a clear NO.
Hat tip to Macrobusiness.