Dueling Capital Requirements in the U.S. Banking Sector
Abstract
U.S. bank capital regulation attempts to prevent bank failure via a risk-based capital (RBC) rule that requires banks to fund riskier assets with more equity. After the financial crisis, regulators added the supplementary leverage ratio (SLR), a risk-agnostic minimum equity requirement against all assets. This paper shows that adding the SLR to the RBC (the “Dual-rule policy”) has three effects. First, the higher equity requirement causes SLR-bound banks to shrink. Second, SLR-bound banks shift from producing low-risk services, like Treasury intermediation, to high-risk loans. Third, each bank is bound by the rule that penalizes its specialty assets most, so the portfolios of both RBC-bound banks and SLR-bound banks converge toward the banking sector’s average portfolio. I estimate that these three effects lower banks’ expected return by 12.2 bp per year, mostly through higher funding costs. If the higher funding costs are offset by commensurate financial stability benefits, the remaining cost of the Dual rules is a misallocation of production across banks and assets. I show that this misallocation, which costs 1.1 bp of expected return annually, is avoidable under a policy that guarantees a minimum equity ratio without charging banks different regulatory costs for providing the same service.
