K C Chakrabarty: Post-crisis - the New Normal
Keynote address by Dr K C Chakrabarty, Deputy Governor of the Reserve Bank of India, at
the Reserve Bank of India-Bank of France Seminar, Paris, 8 November 2011.
* * *
Assistance provided by Smt T Karunakaran, Shri T Gopinath and Shri A Gaiha in preparation of this address is
gratefully acknowledged.
1. The aftermath of the recent global financial crisis bears testimony to the fact that
impact of the turmoil is severe and the recovery therefrom is protracted, resulting in
significant losses in output and employment for an extended period of time. Even two-years
after the recent crisis, there are lingering apprehensions that global economy in general and
advanced economies in particular may suffer double-dip recession.
2. There is a perception that advanced countries performed better during the crisis
management but fared rather poorly in the post-crisis phase. In other words, developed
economies won the war in the crisis period, lost the peace in the post-crisis period. This
evolving post-crisis scenario has been described as New Normal.
3. Mr. Mohamad El-Erain, the Chief of Pacific Investment Management Company
(PIMCO) coined the phase New Normal during early 2009 fundamentally to signify a
downward shift in potential growth of advanced economies because of the impairment of
their financial sectors and capital destruction. The phrase captured the imagination of the
world and began to be used in varied contexts to broadly underscore regime shifts and hard
transformation, embodying the characteristics of De-leveraging, De-globalization and
Reregulation, the so-called DDR dynamics.
4. I would like to focus on the aspect of Re-Regulation.
I. Re-regulation: the New Normal
The banking regulation before the crisis, especially in advanced economies, was basically
minimalist in nature; segmented in scope, done in silos displaying undue faith in the market
discipline, devoid of any big-picture awareness on the part of the supervisors. The overall
framework came to be known as light-touch regulation focusing on individual banks and
institutions, disregarding the interconnectedness among these entities and the systemic risk
such interconnectedness could pose to the financial stability. The potential adverse
implications of fallacy of composition were completely ignored.
5. In other words, while the build-up of leverage and the under pricing of credit risk
were recognized in advance of the turmoil, their impact was under-appreciated. Further,
there was no globally coordinated approach to assess the implications of these systemic
risks and policy options to address them. There was also insufficient recognition of the
interconnectedness of risks within both regulated and unregulated markets. Reflecting these
lessons of the crisis, the financial regulatory reforms have been underway spearheaded at
the international level by the G20, aiming, inter alia, at increasing the resilience of the global
financial system. In the process, the international best practice trajectory itself has shifted
upwards with the introduction of Basel III and other initiatives. This is what can be called
reregulation, the New Normal.
6. The New Normal broadly embodies two strands: one relating to paradigm shift in
institutional arrangement for regulation and another pertaining to regulation itself.
Institutional arrangements
7. There is discernible trend of institutionalization of collegial arrangements involving
the central bank, other regulators and the government, with the broader responsibility of
identifying threats to financial stability. In the US, the Financial Stability Oversight Council
(FSOC) is headed by the Treasury Secretary and comprises the Fed Chairman and the
heads of all the regulatory agencies. New supervisory bodies involving council approach
have been created in the EU. The European Systemic Risk Board (ESRB) is chaired by the
President of the European Central Bank (ECB) and is a part of the European System of
Financial Supervision which also comprises the three newly created systemic authorities for
banking, insurance and occupational pensions and for securities markets.
8. The UK Financial Services Authority (FSA) has been split in two, as the UK
embraces what is called "twin-peaks" model of financial regulation, where separate entities
for prudential supervision, and the oversight of consumer protection and market conduct are
created. The prudential oversight wing moved inside the Bank of England. Further, an
independent Financial Policy Committee at the Bank, chaired by Governor, Bank of England
has been set up having the tools and the responsibility to look across the economy at the
macro issues that may threaten economic and financial stability and take effective action in
response. Of course this new arrangement may come into being only in 2013.
Regulatory initiatives
9. Globally, various initiatives to reform financial sector regulation, the New Normal,
have been spearheaded by G-20 with the Financial Stability Board (FSB) assuming the role
of the oversight agency. There is greater appreciation for adherence to Basel Core Principles
and openness to peer reviews.
10. These initiatives have been well documented and hence it would suffice here to
mention that the broad contours of the international initiatives on regulatory reforms envisage
strengthening the quality, consistency and transparency of regulatory capital and risk
coverage, introducing minimum liquidity standards and leverage ratio, countercyclical
measures in the form of capital buffers and forward looking provisioning, developing a
framework for systemically important entities including cross-border resolution arrangements,
extending the regulatory perimeter to unregulated pools of money, de-risking the OTC
derivatives trading through central counterparties and new framework for regulating
employee compensation within the financial sector. Further, there will be an overlay of
macro-prudential regulation by systemic regulator to review macro prudential risks.
II. Challenges of re-regulation
11. Implementation of the New Normal of re-regulation does pose various challenges.
The collective resolve to reform the regulation of financial sector reflecting the spirit of New
Normal needs to be maintained as various countries experience varied macro-economic and
financial conditions post the Pittsburgh Summit in September 2009. This unity of commitment
is becoming hard to come by. Further, harmonised implementation of regulatory policies
across jurisdictions to address regulatory arbitrage is rendered difficult when their underlying
business cycles lack synchronization.
12. Be that as it may, challenges that EMEs face in implementing the New Normal of
reregulation are entirely different, notwithstanding in-built flexibility for national differences in
adoption and implementation by way of a "comply or explain" provision.
Emerging market perspective1
13. The New Normal of Re-regulation broadly reflects the lessons of the recent crisis
and is therefore basically oriented towards ensuring financial stability in advanced
economies. Even so, EMEs have to implement it. However, its implementation does entail
various trade-offs, especially for the EMEs.
Capital standards
14. The Basel III standards for increased bank capital and liquidity will provide a strong
anchor for enhancing the resilience of each individual institution to adverse shocks. It forces
all lenders, particularly the largest to build up buffers of equity, cash and liquid assets to
protect themselves against unexpected losses or another market crisis. But, they carry cost
which may drive up costs for their customers and make many of banks' business lines
unprofitable. Banks and Supervisors need to guard against complacency that capital buffers
could be effective without strong governance risk management and internal controls.
15. As the EMEs have higher capital ratios, the balance sheet of the banks expand on
the back of growing credit to fund higher growth, and these banks in EMEs may have to
mobilize larger capital with cost implications. Higher capital requirements arising out of
resecuritisation and complex derivatives may have muted implications for EMEs because of
the fact that such exposures are either limited or not permitted. Supervisors need to be
vigilant that tighter regulation does not drive risk from the banking system into the shadows
and to less transparent and lightly supervised parts of the financial system.
Liquidity standards
16. EMEs have not experienced the levels of liquidity stress that advanced economies
had suffered. Therefore, implementing the liquidity standards requires EMEs to develop the
capability to collect and collate the relevant data accurately and granularly, with a view to
analysing and forecasting the liquidity stress scenarios with reasonable accuracy and
consistent with their own situation. They have however the advantage of drawing upon the
experience of the developed economies.
Leverage ratio
17. The current proposal under consideration of the Basel Committee on Banking
Supervision (BCBS) is to include all on and off balance sheet exposures. Here, an area of
concern for EMEs could be the treatment of off-balance sheet (OBS) exposure. Most of the
OBS exposures in EMEs have their footprints in the real economy, basically for hedging
purposes, as proprietary trading by banks is limited and/or complex financial products are not
introduced in these jurisdictions. Further, these contingent liabilities do not generally
materialise. On the contrary, in advanced economies, OBS exposures have their footprints
predominately in the financial sector, including for speculative purposes. Given this critical
differentiation, credit conversion factor (CCF) is crucial. Higher CCFs could have adverse
implications for flow of credit to real sector and capital formation in the EMEs.
Countercyclical capital buffer
18. Another dimension of the regulatory reform is to align regulation to the credit and
default cycles. The difficulty for the EMEs is that emerging markets do not have adequate
history of cycles and hence lack the nuanced understanding of them. Given this, there are
various operational issues regarding various time-varying regulatory approaches under
consideration, including how and when to build or draw-down capital buffers and how to
formulate expected loss-provisioning.
19. As per the BCBS guidance, credit to GDP ratio is the preferred buffer guide for
assessing banking sector conditions for buffers. However, there is a need to draw a
distinction: Assessment of credit aggregates may have different implications for EMEs, as
contrasted with those for advanced economies. Growth in bank credit in the EME could be
due to factors such as financial deepening from a low base, structural shifts in supply
elasticities, rising efficiency of credit markets and perhaps policy initiatives to improve flow of
credit to sectors like the agriculture and small scale units.
20. The impact of these factors on credit aggregates of the advanced economies is by
and large muted. Hence, care and caution needs to be exercised while studying credit
aggregates for capital buffers. Other related issues with regard to buffers include the optimal
size of the buffers and the methodology for its determination. Too large a buffer, while
promoting financial stability, may impound more capital than warranted and hence could
have adverse implications for cost and availability of capital for the real sector. If so, what
does it mean for better price discovery and improving allocative efficiency, given the fact that
high capital gearing is fundamentally against inter mediation?
The New Normal and financial inclusion
21. How does the New Normal of re-regulation impinge on EMEs' efforts at financial
inclusion? Does augmenting financial stability through, inter alia, addressing systemic risk,
extending scope of regulation, mitigating procyclicality and strengthening prudential oversight
comprise financial inclusion as the increased stability come at a price of hiking the cost of
banking business and thereby taking banking away from the poor?
22. This important perspective should not be lost sight of, particularly in EMEs. In EMEs
upscaling financial inclusion endeavor to bring the opportunities of cost effective banking to
the underprivileged and low income groups is essential for banks to play a critical role, going
forward, as it embodies the potential for augmenting growth prospects in terms of enhancing
bank savings and financial deepening.
Comply and explain
23. As enumerated above, the New Normal has in-built flexibility for national differences
in adoption and implementation by way of a "comply or explain" provision. In the event of
deviation from the standards of New Normal, EMEs have an additional challenge of effective
and timely communications with the markets to ensure that the deviation is not mistaken for
regulatory looseness.
The New Normal - a few thoughts
24. I see The New Normal at a fundamental level, as signifying a need for financial
systems and regulators to get back to basics .As I see it, the three intertwining strands of the
new Normal across the globe, are Stability, Financial Inclusion and Consumer protection.
25. The New Normal, at a fundamental level would underscore the following aspects:
Financial intermediation should stand the test of operational and allocative efficiency,
manifest in the form of lower intermediation cost. Scarce financial resources should be
allocated among the competing sectors efficiently with least possible cost, promoting
productivity. Strengthening and developing financial sector should be subservient to the
needs of the real sector and as such the growth of former has to be in alignment with that of
the latter. A financial system where the financial sector drives the real sector and growth in
the financial sector outstrips regulatory surveillance capacity and absence of supporting
institutions to support financial innovation are warning signals for regulators. Hence, it is
imperative to ensure harmonized development of real and financial sectors. There should be
greater focus on reaching out to the bottom of the Pyramid, as inclusive growth is a viable
business option for banks and leads to growth in GDP. This would also mean improving
levels of financial education with a bias towards simple rather than complex products,
particularly in the EMEs.
26. The financial crisis has put the unqualified faith in the efficient market hypothesis
under question. Financial markets are indeed important, but that should not be construed as
financial markets being right all the time. As markets are susceptible to irrational behavior
and driven by sentiment and herding, there is need for proactive regulation and constant
surveillance of markets.
27. Innovation drives growth. The backlash of the financial crisis should not result in
stagnation, or regulatory straitjackets which thwart and stifle innovation. Innovation is
necessary for efficient allocation of resources, operational efficiency and delivery of
economical, cost effective and consumer products and consequently improved productivity.
This does not mean that financial innovation should be unregulated as it has implications for
consumer protection and systemic risk.
28. Financial innovation should continue to play a catalytic role in intermediating savings
for providing adequate levels of funding to the real sector, thereby supporting economic
growth. However, financial intermediation should not acquire dynamics of its own as it can
potentially lead to economic rent seeking, rather than delivering valuable customer and
economic benefits. Hence, it is essential that optimal balance is maintained between financial
innovation and regulation. Collectively, the above four aspects of the New Normal should
contribute to the promotion of financial stability, financial inclusion and consumer protection.
III. Indian experience
29. India, like most other emerging market economies, was not seriously affected by the
recent financial turmoil in developed economies. Indian banking system, similar to other
Asian banks, remained profitable, well-capitalised and prudently regulated. Financial stability
in India has been achieved through perseverance of prudential policies which prevent
institutions from excessive risk taking, and financial markets from becoming extremely
volatile and turbulent.
30. In fact, various measures/proposals underpinning the New Normal of Re-Regulation
have already been brought into practice in India even before the crisis. These included
restrictions on leverage for banking and non banking institutions, stringent liquidity
requirements, counter cyclical prudential measures, not recognising in Tier I capital many
items that are now sought to be deducted internationally, recognising profits from sale of
securitised assets to SPVs over the life of the securities issued, not reckoning unrealised
gains in earnings or in Tier I capital.
31. In the above backdrop, the Indian response in the post-crisis period was primarily
guided by the immediate imperative of containing the financial contagion from abroad and
carrying forward the process of financial sector reforms in a calibrated manner distilling the
lessons from the crisis.
Measures for containing financial contagion
32. The RBI responded to the crisis by providing ample rupee liquidity and comfortable
forex liquidity to ensure that credit and financial markets functioned normally. To cushion the
adverse impact of the downturn, various sector-specific counter-cyclical regulatory measures
involving risk-weights and provisioning were introduced. It also gave regulatory guidance for
restructuring of viable loan accounts for ensuring continued flow of credit to productive
sectors of the economy with a view to arresting growth deceleration.
Financial sector reforms
33. The regulatory measures initiated for furthering financial sector reforms introduced
in the post-crisis period aimed at institutional and market development and strengthening
resilience of the financial system are as follows:
Institutional and market development measures
Securitization market
34. The RBI issued guidelines on securitisation of standard assets in February 2006.
These guidelines prohibit originators from booking profits upfront at the time of securitisation.
Two other features relate to deduction from capital of any credit enhancements provided in
the first of first loss, and disallowing the release of credit enhancement during the life of the
credit-enhanced transaction. Further, the revised draft guidelines on securitisation, primarily
on minimum holding period and minimum retention requirements, have been issued in
September 2011.
Credit Default Swap
35. Drawing from the recommendations of the Internal Group and distilling the lessons
of the recent global financial crisis, final guidelines were issued in May 2011 for the
introduction of plain vanilla OTC single-name CDS for corporate bonds.
Financial Stability Development Council (FSDC)
36. Financial Stability and Development Council (FSDC) has been constituted with a
view to strengthen and institutionalise the mechanism for maintaining financial stability. The
Council would monitor macro-prudential supervision of the economy, including the
functioning of large financial conglomerates, and address inter-regulatory coordination
issues.
Conglomerate structure
37. A Working Group has recommended a roadmap for the introduction of holding
company structure in the Indian financial sector together with the required regulatory,
supervisory and legislative framework with a view to introducing an alternate organizational
structure for the banks and identified financial conglomerates in India.
Measures for strengthening resilience of financial system
Basel II advanced approaches
38. The timetable for the phased adoption of advanced approaches for the computation
of regulatory capital under the Basel II framework in India has been put in public domain in
July 2009. Enhancements to Basel II guidelines - New Capital Adequacy Framework - were
issued in February 2010. These enhancements prescribed increased capital requirements for
specific risk and liquidity facility for securitisation exposures. It also intended banks to better
identify and appropriately capture risks in their internal assessments of capital adequacy and
manage risks and more granular disclosure requirements for credit risk mitigations and
securitised exposures.
39. The guidelines on "The Standardised Approach (TSA)" and "Alternative
Standardised Approach (ASA)" for operational risk were issued in March 2010. The
guidelines on Internal Models Approach (IMA) for VaR-based measurement of exposure to
market risk have been issued in April 2010. The guidelines on Advanced Measurement
Approach (AMA) for calculating operational risk capital charge for operational risk were
issued in April 2011. Draft guidelines for internal rating based (IRB) approach for credit risk
were put in public domain on August 11, 2011 for comments.
Provisioning buffer
40. With a view to augmenting provisioning buffer in a counter-cyclical manner when the
banks were making good profits, as a macro-prudential measure, a Provisioning Coverage
Ratio (PCR) of 70 percent of gross Non Performing Assets with reference the banks' position
as on September 30, 2010 was prescribed in April 2011.
Implementation of Basel III
41. As alluded to earlier, distilling the lessons of the crisis, an international endeavour is
underway to reform global financial regulation, of special mention is the guidelines known as
Basel III. Some of the Basel III guidelines relating to capital and liquidity have already been
issued. The Reserve Bank would adhere to internationally agreed phase-in period (beginning
January 1, 2013) for implementation of the Basel III framework.
Supervisory issues
42. The crisis has underpinned the need for more intense and effective supervision
particularly relating to systemically important financial institutions (SIFIs). Since they have
their presence in different segments of the financial system, the level of supervision and
resources applied by supervisors must be commensurate with the potential destabilization
risk that such firms pose to domestic financial systems, and global financial systems.
Supervisory co-operation across domestic and global financial systems becomes imperative
in a scenario which requires increased information sharing and concerted action in a crisis.
Further impact of policy changes spurred by Basel III would be critical in reducing the
probability and impact of a SIFI failure.
43. The lessons of the crisis have shown that certain institutions failed for risks
embedded in products even though they were assessed by supervisors as highly capitalized
and highly liquid. This underscores weaknesses in determining capital sufficiency, which has
both quantitative and a qualitative, aspects and involves a judgmental exercise. The capital
assessment should be driven by the supervisor's understanding of the legal, operating, and
corporate governance structure of the organization and its primary strategies, business lines,
risk management and internal control functions, which shape its unique and distinct risk
profile and hence capital requirements.
44. While financial systems cannot be totally risk free, Supervisors need to assess risk
in banks' business models and have a reasonably accurate assessment of the balance
between the risk taking capacity of a financial institution and the appropriate level of capital
available to absorb unexpected losses and intervene early when there is an imbalance.
Inadequate assessments and imbalances as also delays and unpreparedness for timely and
decisive interventions can make the financial system highly vulnerable leading to potential
loss of confidence.
45. On the other hand, excessive capital requirements could drive risk to less regulated
entities which may pose potentially new risks to the system. The crisis revealed, blind spots
in supervisor's assessment of bank risks, as under highly stressed and largely unforeseen
circumstances, they were found to be inadequately capitalized. The timely and accurate
supervisory assessment of capital levels is critical. Given the systemic impact of SIFI failures,
there is also the need for continuous and intense supervision of SIFIs. Supervisors need to
have a through the cycle mentality as times of economic serenity breeds complacence.
Supervisors need to stay hungry and not necessarily foolish.
46. Supervisors also need to have a result oriented approach, focussing on outcome of
stress tests and risk management processes within banks. They need to review whether they
are commensurate with their assessment of the bank's risk profile. The lessons from the
financial crisis showed that considerable supervisory attention was focussed on the
governance frameworks and processes in areas such as risk management, credit risk
approvals, board oversight, and capital adequacy assessments, without enough analysis to
confirm that the outputs of the processes, given the business model of the bank and its
products in terms of the risk profile and exposures were consistent with supervisory
expectations. The crisis underscored flaws in bank's risk management practices and
insufficient understanding by supervisors of the risks posed by increasing complexity of
products and systems in banks.
47. The use of stress tests tools and its outcomes in understanding areas of risk and
remedial action has emerged vital to the re-engineering processes in supervision. Data
integrity and aggregation are key to effective risk management for banks and critical for
ongoing supervision of SIFIs, as is consolidated supervision. There is also a need for wider
customer education, and stringent customer suitability and appropriateness policies in place
while selling structured products. This underscores the importance of a strong governance
framework and compliance culture in banks.
Stress testing also forms a critical part of the banks' Internal Capital Adequacy Assessment
Processes which are reviewed as part of the Reserve Bank's onsite supervision of banks.
Within the Reserve Bank, the stress testing process - both top down stress testing of the
entire banking system and bottoms up stress testing of individual banks - have been
upscaled.
48. The Reserve Bank conducts a series of stress tests periodically. Single factor
sensitivity tests assess the impact of a range of stress scenarios on the credit, interest rate,
foreign exchange rate, equity price and liquidity risks faced by banks and are conducted on
quarterly basis. To assess the resilience of the system to adverse macroeconomic scenarios,
stress testing analysis is carried out within a macro stress testing framework. Two major
groups of macro testing exercises are conducted: one based on a multivariate regression,
and the other based on a vector autoregressive (VAR) model. While the former allows
evaluating the impact of a particular macroeconomic variable on the banking system's NPA
and capital ratios, the latter reflects the impact of the overall economic stress situation on the
NPA ratio and bank capital through a feed-back effect. The macro stress tests are also
conducted on a quarterly basis.
49. In India, we have reviewed our supervisory processes for close and ongoing
supervision of 12 large banks which account for nearly 53% of the assets of the banking
system. The Supervisory Review of banks is being taken up this year, strengthened with
lessons learnt from the pilot run of the previous year. To further refine and bench mark
supervisory policies and processes with international best practices, a Steering Committee
has been set up to examine the entire gamut of supervisory policy, processes ,rating
methodology, etc.
50. Reserve Bank of India recognizes that the quality of supervision of SIFIs would be
extended to other banks/FIs on a risk based approach. There is closer co-ordination with
other Regulators and Supervisors through formal MoUs and ongoing dialogue through
informal/formal channels and Supervisory Colleges, underscoring our appreciation of the
need for close and co-ordinated supervision of large systemically important banks.
IV. Indian Scenario - regulatory framework in India / exchange control
environment
51. In the Indian context, large scale external sector reforms (exchange control and
other areas such as trade policy {customs/duties}) were initiated in the aftermath of the
balance of payments crisis faced by India in 1990-91. Till this time the Indian economy was
largely insulated from the world and was largely a closed economy in so far as cross border
transactions (specially capital account transactions were concerned).
52. Some of the lessons which emerged for policy makers (from the BoP crisis of
1990-91) were that i) there were long term benefits of opening the economy both on the
current and capital account, albeit in a phased / calibrated manner; ii) official capital flows in
the form of debt / aid were unsustainable in the long run and therefore required to be
replaced with private capital flows; and iii). public policy should actively differentiate and
provide for preferential treatment between capital flows which are pure equity flows and debt
flows (with FDI, portfolio flows and debt flows in descending order of preference).
53. The lessons learnt from the BoP crisis of 1990-91 were subsequently instrumental
in framing appropriate public policies for the external sector (by the Government and the
Central Bank). India became fully convertible on the current account in 1994 (barring a few
quantitative restrictions and a small negative list of transactions {keeping in view larger public
interests/good} ) and therefore all current account transactions are freely allowed as long as
they are for bonafide purposes and are routed through normal banking channels.
54. On the capital account front, India has been following a calibrated and gradual
approach towards full capital account convertibility. This approach is based on the emerging
macroeconomic and macro-prudential environment and broadly guided various
concomitants2/indicators such as i) Fiscal Consolidation, ii) Monetary Policy Objectives,
iii) Strengthening of the Banking System and, iv) External Sector Indicators (CAD, Adequacy
of Reserves).
55. The primary objectives of the extant exchange control regime in India3 are
facilitating external trade and payments and for promoting the orderly development and
maintenance of foreign exchange market in India. On the capital account front there has
been a conscious policy effort to give precedence to equity flows over debt flows as well as
FDI over portfolio flows.
56. Amongst the emerging market economies, India has a peculiar situation where we
have a persistent current account deficit which has to be funded from the capital account
surplus. While prima facie this should encourage us to move at a faster pace towards full
capital account convertibility, a detailed analysis shows that increased and uninhibited capital
inflows may (under certain circumstances) be more detrimental4 than beneficial to the
domestic economy as well as the overall BoP position. Thus the nature and amount of capital
inflows has an important effect on the overall BoP as well as foreign exchange reserves of
the country and exchange rate policies have to be suitably tweaked to harvest the beneficial
effects of increased capital inflows while at the same time avoid the ill effects of the same.
The entire emphasis in our forex management is to reduce reliance on short term flows and
not using Forex Rate mechanism as a tool to manage monetary policy.
57. In conclusion, to quote an African proverb, "Smooth seas don't make for good
sailors". The aftershocks of the crisis have made supervisors and regulators look inwards
and the insights on deficiencies in supervision and regulation is shaping many of the key
initiatives in redefining and enhancing effectiveness of regulation and supervision. The
Seminar, I am sure will help in further evolving and strengthening regulation and supervision
of the financial system even in the most turbulent times.
I wish the seminar all success.
References
1. El-Erian, Mohamed A. (2010): Navigating the New Normal in Industrial Countries,
Per Jacobsson Foundation Lecture, International Monetary Fund (IMF), October 10, 2010.
2. Financial Stability Board, November 2, 2010, "Intensity and Effectiveness of SIFI
Supervision".
3. "Bankers versus Basel"