AREAS UNDER SCRUTINY BY FINANCIAL AUTHORITIES: SUMMARY

The reports recognize deviations from sound practices and the deficiencies of regulations. Recommendations and proposals are still to be refined and undergo feasibility assessments. Some are specific enough to sound readily feasible. Others have to be better refined and some have yet to be fully defined.

• Capital reinforcement and solvency.

• Dynamic and more forward-looking provisioning.

• Supervision of liquidity, mismatch risk and leverage.

• Governance and alignment of compensations towards longer-term goals.

• Simpler and more flexible accounting standards.

• Clearinghouse for credit derivatives and traceability of OTC derivatives.

• Obligation of financial firms to maintain a financial commitment in pools of securitization vehicles.

• Extension of supervision to un-regulated players, notably funds, to a degree left open at this stage.

• Extension of supervision to rating agencies, and fuller disclosure of differentiated rating methodologies.

• Focus on system-wide monitoring and oversight, beyond monitoring of individual entities.

• Focus on "Tier-1 FHCs" or "too big to fail and interconnected" financial firms.

• Recognition for the need of a new regime for compelling such firms to internalize costs and for handling eventual failure.

• Consumer and investor protection.

There are pending issues with respect to implementation and how far supervisors will go. In some cases, technical solutions and feasibility are question marks.

Some general remarks stems from such "lessons from the crisis." Perhaps, two points deserve to be mentioned as concluding remarks.

First, the business model of financial entities is not questioned and current reports fail to address, except indirectly through the Tier 1 firms, the sustainability issue of giant banks forming a global monopoly. There is a case for casting doubt on how to escape the asymmetrical treatment of internalized gains and externalized losses. More practically, there are doubts as well with respect to the manageability of such large banks.2

Second, there seems to be a consensus on some core corrective actions. This is not very surprising. With respect to practices, models and risk management tools, it is striking that all recommendations converge towards best practices and techniques and deficiencies of regulations of which many were known, but not fully recognized, before the systemic crisis.

The near future will let us know what will prevail in terms of enhancements of supervision and regulations, and, in the medium term, how the system as a whole will evolve.

 
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