Implications of Ring-Fencing for European Cross-Border Banks Eugenio Cerutti (with A. Ilyina, Y. Makarova and C. Schmieder) Vienna – October 3, 2011

Bankers without Borders? - Motivation Statement at the end of the European Bank Co- ordination Initiative’s Second Full Forum Meeting IMF Press Release No. 10/106 March 22, 2010 “The large bank groups with systemic presence in those [Eastern European] countries have committed to maintain their exposure and keep their subsidiaries well capitalized.” On the one hand, many cross-border banking groups acted as Lenders of Last Resort for their CESE subsidiaries during the crisis.

Bankers without Borders? - Motivation The Croatian National Bank Governor, Željko Rohatinski, Press conference held on 18 February 2009 “the CNB would not look favorably upon attempts [by foreign parent banks] to withdraw capital, deposits or pay out total accumulated profits, because that would destabilize the domestic banking system. In such a case, the CNB would be forced to undertake protective measures, regardless of thus connected risks.” On the other hand, host country regulators might ring fence foreign affiliates within their jurisdictions due to: Banking-stability considerations (e.g. the need to protect the domestic banking system from negative spillovers from the rest of the group) Macro-stability considerations (e.g. avoid capital outflows)

Bankers without Borders? - Motivation Ring Fencing Outcome: cross-border banking groups’ ability to re-allocate funds from subsidiaries with excess capital/liquidity to those in need of capital/liquidity is limited.  The Question we attempt to answer in the paper: What are the capital needs of banking groups under different ring-fencing assumptions?

A “stylized” cross-border banking group: with subsidiaries in countries A, B, C Parent Bank Sub ASub BSub C Losses (net of provisions) at each of the subs Sub A Sub B Sub C Regional credit shock Buffers Profits and Capital at each of the subs Sub A Sub B Sub C Outcome Recapitalization needs (if any) at each of the subs Sub A Sub B Sub C Bankers without Borders? – Stylized Example

Degree of ring-fencing Capital needs (post regional credit shock) under different ring-fencing assumptions No ring-fencing CN(1) = sum of recapitalization needs of all subsidiaries – sum of excess profits and capital of all subsidiaries – profits of the parent bank Partial ring-fencing CN (2) = sum of recapitalization needs of all subsidiaries – sum of excess profits of all subsidiaries – profits of the parent bank Complete ring- fencing CN (3) = sum of recapitalization needs of all subsidiaries – profits of the parent bank Stand-alone subsidiarization CN (4) = sum of recapitalization needs of all subsidiaries At the group level, the capital need (CN) is the total amount of capital required to restore the CARs of all of the group’s affiliates to their regulatory minimums. Bankers without Borders? – Stylized Example

25 Banking Groups/113 CESE subsidiaries Bankers without Borders? – Data Sample

Description and Calibration of the shock Time frame: (2 years): Description of the shock: 2009: Use of preliminary data (GFSR) 2010: Use regression models to determine (a) “baseline” (WEO forecast for GDP, CPI and interest rates); (b) “Adverse Shock” (same as baseline, except for GDP growth - half of the one in 2009) Method: Use of dynamic panel models to forecast i) NPLs and ii) Profit for 2010 Bankers without Borders? – Scenario Analysis

Capital Needs arising from a regional credit shock affecting the CESE subsidiaries (in percent of group’s regulatory capital): CN(1) – no ring-fencing ( both excess capital and profits can be re-allocated) CN(2) – partial ring-fencing ( only excess profits can be re-allocated) CN(3) – complete ring-fencing ( only transfers from parent bank are allowed) CN(4) – stand-alone subsidiarization (no intra-group transfers are allowed) Bankers without Borders? – Scenario Analysis

Capital Needs arising from a regional credit shock affecting the CESE subsidiaries (in percent of group’s regulatory capital): Bankers without Borders? – Scenario Analysis

The capital needs of cross-border banking groups to ensure adequate capitalization of all parts of the group (after a shock) are higher under complete/partial ring- fencing than under no ring-fencing. These differences are more significant for more geographically diversified banking groups. Hence, the standard stress tests of cross-border banking groups based on consolidated balance sheet data (which implicitly assume no restrictions on intra- group transfers) may lead to the wrong conclusions about the adequate level of the group’s capitalization. Bankers without Borders? – Conclusions

A credible and well-designed framework for the resolution of cross-border banking groups could help to avoid unilateral and likely more costly solutions. Setting minimum capital requirements for cross-border banking groups would have to take into account the potential presence of ring-fencing. The capital buffer needs for cross-border banking groups could be even larger in future crises if recent reforms, pursuing logical individual country perspectives (e.g. UK), trigger new higher levels of ring fencing during crisis. Bankers without Borders? – Policy Implications

Background Slides

The Dynamic Panel Regression: CESE NPLs VariableFixed EffectsArellano-BondArellano-Bover NPL (t-1)0.6113***0.6445***0.728*** GDP (t) *** *** *** Interest (t)0.1544***0.1758***0.1048** Inflation (t) Constant2.1217***1.9921***2.173*** # of Observations # of Groups18 R2R2 0.69NA Wald Chi 2 NA359425

Calibration of the shock: NPL assumptions 2008 Median 2009 Median 1/ 2010 Baseline Median 2/ 2010 Adverse Median 3/ Baltic countries CEE CIS/ SEE Footnotes: 1/ Most recent provisional data is available for each country (GFSR); 2/ Estimated based on a dynamic panel regression; 3/ Adverse scenario assumes a double-dip recession, i.e., 2010 GDP growth is equal to ½ of 2009 GDP growth

The Dynamic Panel Regression: CESE ROAs VariableFixed EffectsArellano-BondArellano-Bover ROA (t-1) ** GDP (t)0.0723***0.0840***0.0768*** Interest (t) *** *** *** NPLs (t) *** *** *** Constant1.7519***1.5055***1.7181*** # of Observations # of Groups18 R2R2 0.52NA Wald Chi 2 NA146232

Calibration of the shock: ROA assumptions 2008 Median 2009 Median / Baseline Median 2/ 2010 Adverse Median 3/ Baltic countries CEE CIS SEE Footnotes: 1/ Actual data from GFSR (and model output for Albania, Croatia, Romania and Slovenia) 2/ Estimated based on a dynamic panel regression using CESE NPLs, GDP growth, nominal interest rates and NPLs;