By M. Isi Eromosele
The global financial system has three components: private
sector institutions, the nations that have supervisory jurisdiction over the
private institutions, and the international institutions through which the
national authorities coordinate and cooperate.
The Global Financial Architecture (GFA) is the collective
governance arrangements at the global level for safeguarding the effective
functioning (or the stability) of the global financial system.
The GFA is governed first and foremost by the countries that
have agreed to be part of it, for example, through their IMF membership, their
participation in other institutions and agreements, and their adherence to
various codes, standards, and understandings.
Accordingly, accountability for the successes and failures
of the GFA rests squarely with its member countries, in particular those that
strongly influence it. These same countries are accountable to their own
constituencies for the performance of the GFA and any implications its performance may have on national, regional,
continental, and global economic and financial outcomes.
The global financial and economic crisis of 2008 to present
revealed that the pre-crisis GFA was flawed both in its implementation and in
its structure. With the benefit of hindsight, there were warning signs and
policy mistakes and misjudgments.
But as structured and implemented, the Global Financial
Architecture was not effective in encouraging or persuading remedial actions at
the national, regional, continental, or global level until a full-scale global
systemic crisis was a reality to be dealt with.
The GFA was revealed to be structurally flawed. Its
coordination mechanisms failed to resolve cross-border problems without the
resort to national ring-fencing, unprecedented volumes of liquidity provided by
Central Banks to markets and volumes of credit guarantees and recapitalizations
provided by national treasuries to individual financial institutions not
previously witnessed on a global scale.
In light of the need for unprecedented massive interventions,
one important and perhaps overriding lesson for global governance emerging from
the crisis is that the international community lacks a body of international
law, or at least official agreements and conventions, and importantly ex ante,
burden-sharing mechanisms (or balance sheets) for resolving the weaknesses or
insolvencies of large, complex, interconnected financial conglomerates.
Systemic Issues Revealed By The Global Financial Crisis
The global crisis revealed fundamental weaknesses in the pre-crisis
global financial architecture for preventing, managing, and resolving crises in
the GFS. All lines of defense against a systemic crisis were breached during
the crisis.
Pre-crisis Framework for Safeguarding Global Financial
Stability
The pre-crisis framework for safeguarding financial
stability and encouraging economic and financial efficiency can be seen as
lines of defense against systemic problems that could threaten stability.
It was put in place over time by both private and public stakeholders
in the major financial centers. This architecture evolved over time as events
occurred. It was the result of neither a grand design nor an underlying genetic
code that predisposed the evolution of the system to emerge in the way it has.
It is more akin to an evolving patchwork quilt of consensus
decisions by stakeholders in the major financial centers to deal with problems
as they emerged and as an organic collection of private and public
international agreements and conventions.
There were four important sources of global systemic
financial risk: (1) global financial institutions, primarily large,
international banks/groups but also including global investment banks and
insurance/reinsurance companies; (2) global financial markets, foreign exchange, bond, and over-the-counter derivatives
markets; (3) unregulated financial-market activities of institutional investors
such as the capital markets activities of insurance and reinsurance companies
and of mutual, pension and hedge funds; and (4) economic and
financial-stability policy mistakes.
What Is Known From The Crisis
Although the global financial crisis has been characterized
by some as caused by the US sub-prime mortgage crisis, the continuing crises in
the Euro area, and in Europe more generally, suggest that the earlier and
ongoing US problems should be seen as symptomatic of an economic and financial
environment that encouraged imprudent risk taking, excessive leverage, a
worldwide credit boom, and the accumulation of an unsustainable amount of
private and public debt.
The pre-crisis policy framework and architecture described
earlier failed to prevent and resolve in a cost-effective manner the kind of
financial imbalances that ultimately created systemic risks and events that
threatened to create a worldwide depression.
This framework, created over time primarily by U.S.
and European policy architects, relied heavily on achieving and maintaining a
balance between market discipline and official oversight, with the objective of
providing checks and balances to prevent systemic threats to financial and economic instability.
The balance was wrong. Neither market discipline nor
official oversight by national authorities and international institutions such
as the IMF and FSF performed its function as intended.
Regarding the balance, it was tilted too heavily toward ex
ante market discipline, which proved to be elusive until it was too late, at
which point the ex post exercise of market disciplining behavior created panic
and market dysfunction.
It also relied too little on official oversight, which
failed to foresee the buildup of systemically significant imbalances and
weaknesses; it also failed to deal as effectively as it might (in a least cost
manner) with the crisis once it was upon the world.
In summary, the pre-crisis lines of defense against threats
to systemic stability proved to be inadequate and were breached most visibly in
the European Union and the United States :
- Private risk management and market discipline failed and markets dysfunctioned, the result of a combination of imperfect information, poor incentive structures, insufficient capital and inadequate governance/control by top management.
- Official supervision failed to promote safety and soundness of systemically important financial institutions (SIFIs).
- Macroeconomic policies contributed to conditions conducive to financial crisis.
- National and global market surveillance failed to identify the buildup of institutional, market, and system-wide financial imbalances with sufficient clarity and rigor.
- Pre-crisis Central Bank and finance ministry tools for addressing liquidity/solvency issues proved to be inadequate and were out of tune with the fast-paced nature and global reach of 21st century finance.
Principal Areas where Reforms Are Necessary
Six broad and closely related and overlapping areas can be identified
that are particularly relevant for considering reforms of the global financial
architecture as it impacts the stability of the global financial system.
Regulatory Requirements for Capital, Liquidity, and
Leverage and the Potential Benefits/Costs of Systemic-Risk Taxes
The global crisis revealed that regulatory requirements for
ensuring the safety and soundness of individual financial institutions (or
micro-prudential bank regulations) were inadequate.
There are many facets of these requirements that contributed
to the buildup of imbalances and risks including Basel II methodologies were
flawed in determining capital requirements, liquidity risks were misunderstood
as was private risk management and regulations, leverage limits were either
inadequate or unbinding, or in Europe completely absent.
Perimeters or Boundaries of Financial Regulation, Supervision,
and Infrastructures
The “perimeter” or “boundary” of financial regulations, supervision,
and infrastructures proved to be too narrow or ill-defined to prevent systemic
problems from arising and worsening.
For example, US authorities in charge of managing crises and
resolving bank failures had no legal authority or standing in resolving the
problems of Bear Stearns and Lehman Brothers.
Regulation and Surveillance of Global Money and Financial
Markets
Effective and enduring reform efforts in this area will
require changes in many dimensions: legal, process, architecture, and cross-border
cooperation. Reform proposals across the Atlantic differ,
and fierce competition between the major financial centers is active, but there
is also much common ground.
Systemically Important Financial Institutions or the “Too
Big to Fail (TBTF)” Problem
It is now more widely understood that some financial institutions
pose risks to the stability of the entire global financial system because of
their size, complexity, and
interconnectedness.
The pre-crisis architecture for safeguarding global
financial stability can be judged to have failed to assess, monitor and manage the wider
implications of financial imbalances and weaknesses that emerged within
individual financial institutions.
Crisis Management, Rescue and Resolution
Systemic Risk Board are necessary and worthwhile efforts
aimed at improving the ability to assess the potential for systemic risk in the
absence of market pressures and adequate supervision and regulation.
Early detection of financial imbalances is necessary to
avoid systemic problems through the implementation of risk-mitigating measures
that could reduce the potential for financial imbalances becoming systemic and
threatening financial stability.
Effective Management of Volatile Capital Flows
The epicenter of the global crisis was the US
financial system and economy and the principal locus of secondary eruptions was
Western Europe . But the crisis became global, encompassing
Central and Eastern Europe , Latin America ,
Asia , and Africa before running
its course.
A major transmission mechanism was the global financial
system and associated capital flows, which dried up, first, for Iceland
and Eastern Europe and ultimately for many of the major
emerging-market economies.
A second transmission mechanism was the recession in the
advanced countries that led to a collapse in global trade that was
unprecedented in the post-World War II era.
Macro-prudential Orientation
An important failure of the pre-crisis framework for
safeguarding global financial stability was that it was focused too heavily on
micro-prudential regulation and supervision and not enough on assessing, monitoring,
and resolving problems at the system-wide level.
The macro-prudential orientation of supervision and
regulation should have two major focal points: (1) the impact of the
aggregation of financial risks on the system as a whole, including externalities
and cross-correlations of risks (that is, a focus on systemic risk); and (2) the
impacts on the financial system as a whole of macroeconomic policies - monetary,
fiscal, and financial.
Recommendations
The structural financial weaknesses revealed by the global
crisis require further reforms of the global financial architecture if future
crises are to be managed and resolved more
cost effectively, both in terms of preserving the efficiency
gains of global modern finance and in terms of taxpayer monies.
First and foremost, reforms are required at national levels.
However, to maximize the probability that these reforms contribute to greater
stability of the global financial system and are implemented consistently, the
financial-stability roles of the relevant international institutions, the IMF and
FSB in particular should be enhanced individually and collectively.
More specifically, the IMF and the FSB must cooperate and
collaborate as closely as possible on the reform and operation of the global financial
system in order to achieve their mandated objectives that overlap in many areas.
M. Isi Eromosele is
the President | Chief Executive Officer | Executive Creative Director of Oseme
Group - Oseme Creative | Oseme Consulting | Oseme Finance
Copyright Control ©
2012 Oseme Group
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