Reducing Taxpayer Exposure to Loss from Innovations in Bank Risk Management
指出银行风险承担技术变革要求监管技术同步更新,当前基于历史成本的资本监管体系已过时,无法有效控制纳税人损失风险。
SEA CHANGES IN THE TECHNOLOGY of bank risk taking demand parallel sea changes in the technologies of regulatory monitoring and loss control. Federal regulators purport to control taxpayers' exposure to loss at federally insured banks by enforcing capital requirements linked to each bank's perceived risk. But regulatory systems for monitoring bank risk and bank capital have become outdated. These systems are rooted in information, communications, and managerial technologies of yesteryear. Regulators' current monitoring system focuses on approximately annual on-site bank examinations and comprehensive quarterly surveys and selective weekly reports of tangible book values. During at least the past twenty years, the net economic value of the average bank's intangible book of business has grown faster than the value of its net tangible positions. Moreover, for the most part, tangible book values are based on the costs incurred in acquiring a position rather than the current values needed to guide regulatory loss-control policies in the modem era. Acquisition costs take no account of a bank's investment successes and failures on an ongoing basis. Changes in information processing, contracting, and transaction-execution technologies create an environment of information flows and portfolio response that makes gaps in the time frame for observing bank capital increasingly inappropriate. An aggressive bank can concentrate risk in ways that threaten to move the market value of its capital far more substantially from day to day and week to week than ever before. Nevertheless, regulators are collecting information from insured banks with