The G20 meeting in Brisbane in November signaled an apparent watershed in the battle to end too-big-to-fail (TBTF) banking, through the introduction of total loss-absorbing capacity (TLAC) buffers for larger firms, while policymakers beefed up cross-border resolution regimes. Bank of England governor Mark Carney, head of the Financial Stability Board, announced the measures would “substantially complete the job” of “fixing the fault lines” that triggered the global crisis. But for all the sanguine pronouncements over the regulatory agenda, policymakers fear the Basel III framework does not go far enough in barricading national financial systems from capital storms. As a result, the battle against TBTF has exacerbated the crisis in the global banking model – also driven by market-driven pressures – even with coordination at the Basel level. Challenges include mandatory ringfencing rules for foreign banking organizations (FBOs) in the US, an EU-US spat over the leverage ratio and efforts to separate retail and investment banking.
The regulatory onslaught underscores how bankers have made three strategic mistakes:
they criticized the regulatory onslaught too early and too aggressively;
they misconstrued the punitive costs on cross-border flows as an unintended, rather than intended, policy outcome; and
they banked on regulatory forbearance to preserve short-run growth.