Key points from the report include:
- Bank deposits and payment systems are the lifeblood of our economies. Society relies on bank credit for economic and social order and governments will always step in to protect it.
- The expectation of bail-out means that banks receive a funding subsidy via government guarantees.
- There is no reason to subsidise trading activities, in fact this increases systemic risk.
- In the last 25 years, our largest banks have evolved into “flow monsters” with balance sheets dominated by subsidised trading assets and inter-connected via the derivatives markets.
- In today’s environment, it is difficult for highly inter-connected banks to undergo “creditor bail-in” without spreading danger throughout the financial system, which undermines the credibility of the bail-in mechanisms proposed.
- The proposed Resolution Fund and the European Stability Mechanism are too small to withstand a systemic banking crisis on their own.
- The activities that make banks too-big, too-complex and too-connected-to-fail also make them too-big, too-complex and too-connected-to-resolve in the normal way.
- When resolution mechanisms are not credible, investors charge a lower risk premium, encouraging the very activities that make resolution difficult.
- Without structural reforms and credible loss-absorbency mechanisms on banks’ liabilities, Banking Union risks becoming a paper tiger: a mechanism that appears to help but which delays meaningful bank reform and lacks teeth when the next systemic crisis strikes.
Policy recommendations in the report include:
- A strong legislative proposal in the current European Commission mandate to separate commercial banking from investment banking and trading activities, including market making, as recommended by the High-level Expert Group led by Erkki Liikanen.
- Significantly higher loss-absorbing capacity for banks, including equity requirements through the adoption of strict leverage caps by 2015.
- Stronger powers for supervisors to intervene to ensure that recovery and resolution plans are realistic.
