I find that I wrote this, a couple of years ago, in IT Governance – Guidelines for Directors: “Basel 2 seeks to achieve its goal of strengthening the international financial system through three pillars. Pillar 1 aims to align a bank’s minimum capital requirements more closely to its actual risk of economic loss, aiming to establish an explicit capital charge for a ‘bank’s exposures to the risk of losses caused by failures in systems, processes, or staff or that are caused by external events,’[1] Those banks whose approaches to measuring, managing and controlling their operational risk exposures are appropriate to the risk area will have lower capital requirements. While Pillar 2 allows for supervisory review of banks’ risk management processes, Pillar 3 explicitly sets out to enhance transparency in banks’ public reporting in order to ‘leverage the ability of market discipline to motivate prudent management’.”
So, what on earth was the point of Basel II?
It rather looks to me as though:
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Pillar 1 was a bust, or we wouldn’t have had Northern Rock, RBS, HBOS, Citi, etc;
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Pillar 2 – well, the supervisory reviews of banks’ risk management processes clearly haven’t been that hot, or someone might have spotted that lending someone 125% of the value of the already inflated value of their property on repayment terms that in some cases exceeded their monthly gross earnings wasn’t exactly a demonstration of effective risk management – or that the creation of opaque, deliberately over-complex CDOs and other instruments wasn’t an attempt at clarity (to say nothing of the cynical appointment to the regulatory authority’s board of someone responsible for firing one of the few risk managers who actually appears to have been doing their job in drawing attention to the bank’s failure to manage risk effectively) – and, as for
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Pillar 3 – well, I guess ‘Sir’ Fred Goodwin’s £650k annual pension (after early retirement!) is a good example of market discipline motivating prudent management, isn’t it? And I bet that no-one would even consider removing the knighthoods that this collection of pretend bankers were awarded, will they?
So, maybe BASEL II was really just an excuse for a lot of central bankers to get together for dinner on a regular basis?
[1] BIS Press Release, 26 June 2004
