July 8, 2004 FINANCIAL REGULATION AND BANK SAFETY NETS: AN INTERNATIONAL COMPARISON Edward J. Kane Boston College In every risky enterprise, safety is a paramount concern. Miners wear hard hats and equip themselves with safety lamps. Cruise ships stock life vests and lifeboats and routinely drill personnel and passengers in their location and proper use. Society’s concern for the safety of a particular enterprise increases with the degree of adversity that attaches to bad outcomes and with the extent to which the bad outcomes damage parties who cannot directly influence the tradeoffs between profitability and safety that enterprise managers might feel free to make. Managers of financial institutions may be likened to a team of high-wire artists. They deliberately throw themselves into risky positions and, when things turn out badly, a messy multiparty disaster can ensue. What a government calls its financial safety net consists of measures it takes to restrict the risky positions institutions assume in the first place and to limit the damage customers, employees, and stockholders suffer when and if disaster ensues. This paper begins by analyzing the safety-net metaphor and using its entailments to clarify why the optimal design of financial safety nets varies with country circumstances. Section II of the paper introduces the idea that individual countries have a distinctive contracting environment and regulatory culture. The contracting environment encompasses the degree to which political and legal institutions and operative concepts of personal honor influence the accuracy of information flows and shape methods of private contract enforcement. The regulatory culture simultaneously authorizes and restricts the exercise of government power. Section III provides data on cross-country differences in safety-net design. It also identifies the benefits of specific design features. Section IV emphasizes the importance of incorporating accountability and disaster planning into safety-net design. It warns officials against introducing explicit deposit insurance This paper updates and refocuses material first treated in Kane (2000). The author is grateful to the Fundacion de Las Cajas de Ahorros Confederados in Madrid for financial support and to Richard Aspinwall for helpful comments on an earlier draft. Page 1 of 49 July 8, 2004 without first making sure that their country’s contracting environment and regulatory culture can control the subsidy to risk-taking that it might generate. I. Exploring the Safety-Net Metaphor A net is a cross-hatched mesh whose strands are composed of material strong enough to serve the net’s particular purpose. Although a mosquito net may be made of flimsy material, safety nets have to be strong enough to withstand the force of muscular bodies falling with great force. Circus Safety Nets. In a circus, a safety net serves two purposes. Its immediate function is to protect acrobats from splattering themselves against the ground when they make a mistake and to protect a paying audience from the trauma of witnessing such a disaster. Its deeper purpose is to encourage acrobats to practice and perfect stunts that are challenging enough to thrill an audience. Stunts must be perfected, because audiences will not pay to watch acrobats fall repeatedly into a net. Carrying out a relatively simple trick is more entertaining than botching a difficult one. From an economic point of view, safety nets are erected not to inspire wild risk-taking, but to embolden performers enough to free their minds to analyze and undertake risks in prudent and skillful ways. Safety-net design has many dimensions. Moreover, the costs and benefits of particular features unfold unevenly and over many periods. At the margin, increases in the present discounted value of the entertainment engendered by enhanced risk-taking must be traded off against the incremental costs of generating additional safety. Costs may be divided into: immediate costs of acquisition; future monitoring and maintenance expense; risks of technological obsolescence; and the residual risk of incurring catastrophes the net cannot cover. Benefits consist of cash flows that the circus earns from the performance of entertaining stunts. Wide-reaching and sturdy meshes are safer, but their acquisition cost is higher and the greater visibility of the protection they supply lessens the sense of risk sharing on which audience enjoyment depends. Sturdy filament materials exist whose thinness can Page 2 of 49 July 8, 2004 make the net less visible, but these materials are more costly to acquire and maintain. Finally, because no net can stop every possible disaster, conscientious operators must make plans to access emergency medical treatment promptly and to withstand whatever criticism subsequently emerges in the press. Comparison with Financial Safety Nets The economic principles that govern the design of a circus net apply equally well to the design of a country’s safety net. To design and operate a safety net optimally, authorities must consider costs and benefits over many periods and many of the tradeoffs they must make are subtle ones. Metaphorically, these tradeoffs share four entailments with a circus net. First, like acrobats, financial institutions that enjoy safety-net protection may be tempted to engage in activities so risky that critical mistakes can still cripple them or even end their existence. This phenomenon is called moral hazard. To explain moralhazard incentives, it helps to draw a correspondence between stakeholders in a bank and stakeholders in a circus. In a banking enterprise, borrowers and depositors correspond to individuals who manufacture the trapezes and tightwire platforms on which stunts are performed. To assess how fully their claims will be serviced, customers need to be able to monitor how well the bank is doing. Unless reliable public information about bank and borrower performance is in easy supply, customers and regulators have to devise procedures with which to extract reliable data. Other things equal, the weaker a country’s information environment, the more an unguaranteed customer’s stake is at risk. Of course, government efforts to protect bank customers by monitoring, controlling, and bailing out banks generate costs that must be financed, usually by assessments levied both explicitly and implicitly on banks and taxpayers. This financing pattern means taxpayers are not simply the equivalent of audience members. The government may call upon taxpayers to pay for any deficits the regulated “circus” might suffer. Financial safety nets protect borrowers, depositors, and taxpayers only from being directly harmed by financial-institution missteps. Indirectly, they harm them by encouraging individual institutions to shift some of the risks generated by their lending and funding activities onto the safety net. Page 3 of 49 July 8, 2004 Second, thrust into the role of circus managers, regulators have to balance conflicting concerns. They must guard against excessive risk-taking, while also controlling over time the other costs and benefits the safety net produces. Safety nets for banks comprise a series of policy arrangements that help stakeholders to avoid or weather loss-causing financial shocks (Diamond and Dybvig, 1983: Talley and Mas, 1990; Kane, 1995; Goldstein and Turner, 1996;Brock, 1999). These multidimensional policy schemes seek to align the costs and benefits generated by: 1. limiting aggressive risk-taking by banks; 2. protecting bank customers from being blindsided by bank insolvencies; 3. preventing and controlling damage from bank runs; 4. detecting and resolving insolvent banks; and 5. allocating across society the losses officials uncover when an insolvent bank is closed. Third, decisions about the design of a country’s financial safety net are not necessarily made selflessly. Decisions are influenced by incentives that result from political and bureaucratic arrangements that convey to regulatory officials and bank stakeholders a collection of mutually reinforcing rights and duties. To fashion a net of the right size and strength, decisions bearing on the cost and effectiveness of net components should be observable enough to be disciplined by healthy market and budgetary pressures. Unless officials feel fully accountable for policy-induced flaws in risk-taking incentives, the net’s overall effectiveness is bound to be shortchanged. For strategies of risk control to be maximally successful, employment contracts must assign top regulators the duty of measuring and managing the social costs (and especially the risk-taking incentives) generated by decisions about net design and incent all regulatory personnel to perform these duties well. Just as differences in the size and shape of a circus tent call for adjustments in the dimensions of the mesh and in the strength and location of its supporting piers, every regulator’s rights and duties must be anchored in the characteristics of the legal and private-information environment of the sponsoring financial system and national government. Finally, the effectiveness of a safety net is never perfect, nor is it constant over time. Authorities must understand that, on occasion, even the best-designed safety net Page 4 of 49 July 8, 2004 may fracture or prove too small. This means authorities must develop and regularly review strategic plans for managing financial crises and train their staff in the use of evolving crisis-management protocols. Paradoxically, unless a strong safety net is backed up by solid disaster planning, its very strength may foster a series of infrequent, but devastating crises. This is because, on balance, the more effective a nation’s safety net becomes, the less likely it is that regulatory personnel will have prior hands-on experience in coping with crisis pressures. Considering how and where the circus metaphor breaks down underscores an additional lesson. The major difference is that—unlike the splattering of an unlucky, incompetent, or overly well-connected acrobat—breakdowns in financial safety nets are not immediately visible to the naked eye. This lack of transparency intensifies the conflict between the tasks of maximizing a net’s effectiveness and minimizing its costs. To protect the reputation of their agency or top officers during their particular terms in office, self-interested regulators may be tempted to conceal and sugarcoat information about emerging or accelerating difficulties. As short-timers, they may callously fail to challenge misleading bank condition reports or even encourage disinformation to be entered on balance sheets and income statements. Precisely because top regulators do not want their professional reputation besmirched by blame for financial-institution failures, their authority over reporting protocols can be abused. Having the ability to reduce transparency supports an incentive to delay insolvency resolution in tough times or tough cases, so as to allow banks whose insolvency cannot yet be publicly recognized an opportunity to gamble for resurrection at taxpayer and competitor expense. Knowing that regulators can block the flow of adverse information and that they dislike public criticism tempts managers and owners of insolvent institutions to exploit regulators’ incentive conflicts. Unscrupulous bankers routinely praise officials for neglecting their duty of truth-telling. To justify their willingness to cover up bank weakness, regulators claim they have the right to conceal or mischaracterize evidence of widespread losses whenever they believe that forthright statements might generate a financial panic. But public fears could be calmed without postponing cost-effective action designed to preserve banking solvency. An explanation for ignoring banking losses is that in some cases top officials may be trying to achieve a reputationally clean Page 5 of 49 July 8, 2004 getaway. Depending on the quality of a nation’s information and bureaucratic environments, high officials may hope to escape blame for incurring insolvencyresolution costs on their watch by doctoring and suppressing evidence long enough to pass the bill for safety-net losses onto the next generation of regulatory officials. Recognizing the availability of this escape hatch undermines the urgency of promptly understanding newly emerging forms of risk-taking and engaging in extensive crisis planning. In turns, underinvesting in these activities disposes regulators to treat future financial breakdowns as if they were unique events that they can plan to handle in an ad hoc manner. II. Regulatory Culture and the Contracting Environment Modern finance theory emphasizes that bank depositors must worry about controlling incentives for opportunistic behavior by their bank’s managers, owners, and borrowers (Jensen and Meckling, 1976; Diamond, 1984; La Porta, Lopez-de-Silanes, Shleifer, and Vishny, 1998). Managerial opportunism has three intertwined roots: 1. difficulties a depositor faces in obtaining reliable information about unfavorable developments and observing adverse actions by bank managers, including recklessness, negligence, incompetence, fraud, and self-dealing (monitoring costs); 2. difficulties an individual depositor faces in adequately analyzing and responding to whatever information its monitoring activity turns up (policing costs); 3. difficulties depositors face in coordinating collective action (coordination costs). In most information and contracting environments, by stepping into depositors’ shoes, government regulators can reduce these costs. For this reason, all real-world economies establish a framework of centralized bank monitoring and deterrent response. Centralizing these functions aims at increasing depositor confidence while solving three coordination problems: avoiding redundant monitoring expense; standardizing contracting protocols; and timing and calibrating disciplinary action. In principle, a centralized monitor-enforcer makes it unprofitable for Page 6 of 49 July 8, 2004 banks to misrepresent their economic condition to depositors and to pursue profit-making opportunities that might exploit depositors’ informational disadvantage. Dimensions of Regulatory Culture Financial regulation and supervision are cooperative endeavors. Anyone can propose rules, but to command compliance requires legitimacy: a mutual understanding that the rules are conceived and enforced to increase social welfare. To win and sustain a legitimate right to wield coercive force, regulators must accept and respect appropriate checks on their authority. An “appropriate” check is one that is consistent with the country’s political culture and its citizens’ understanding of the country’s past regulatory experience. A culture is defined as customs, ideas, and attitudes that members share and transmit from generation by systems of subtle and unsubtle rewards and punishments. Carnell (1993) and Kane (2003) assign regulatory culture the role of defining, authenticating, and promoting the financial common good. One country’s regulatory culture may differ from another in any of six dimensions: 1. in the character of the statutory grant of authority and the reporting responsibilities a regulatory enterprise receives; 2. in the specific rules the enterprise formulates and how it develops and promulgates them; 3. in the methods the enterprise uses to monitor for violations; 4. in the penalties it can and does impose on clients when it finds material violations; 5. in the nature and extent of due-process restrictions (including specific burdens of proof) that protect regulated institutions from unfair administrative procedures; 6. in the extent of insured institutions’ rights to appeal regulatory decisions to a higher authority. To be viable, the taboos and traditions incorporated in a regulatory culture must embody community standards of fair play and proper use of government power. Transparency and Deterrency Regulators’ tools of damage control are rulemaking and enforcement. To understand the economic role these tools play, it is helpful to imagine a world in which depositors’ monitoring and policing costs would be uniformly zero. In this world, each Page 7 of 49 July 8, 2004 deposit contract would be self-enforcing. Coordination costs would be irrelevant. Establishing a team of centralized monitors and enforcers to thwart risk-shifting and misconduct by bank insiders would offer no incremental benefit either to banks or to their depositors. In such a world, changes in a bank’s condition and risk exposure would be transparent to depositors and depositors would possess sufficient expertise and sanctions to deter bank insiders from trying to take advantage of them. Maximal transparency (MT) describes a framework of disclosure that would perfectly and costlessly inform depositors about changes in bank performance and risk-taking activities. To provide a pair of parallel rhyming words, we use maximal deterrency (MD) to describe a situation in which depositors would immediately and perfectly understand the implications of information flows and would be able to protect themselves completely and costlessly from whatever threat to their wealth this information might reveal. The more closely an economy comes to offering creditors maximal transparency and maximal deterrency, the less ex ante value that banks and safety-net managers can create for depositors. In an MTMD economy, cash in advance and credit could substitute perfectly for each other in every payment context. Similarly, direct and indirect finance would provide equally economical ways of mobilizing savings, of choosing which real investment projects savers ought to support, and of deciding how to price project risk. As envisaged in the Capital Asset Pricing Model, corporate and government securities could be offered in denominations small enough to allow virtually every individual saver to invest directly in a diversified portfolio of stocks, bonds, and derivative securities. The MTMD thought experiment clarifies that safety nets owe their existence to difficulties of contract enforcement: blockages in information flows; differences in monitoring costs; variation in financial transaction costs; delays in appreciating and processing relevant information; and the costliness and inadequacy of the deterrent remedies that individual depositors have available to them. It also clarifies that a safety net is implicitly a five-party contract. The net imposes mutual rights and duties on: bankers, borrowers, depositors, safety-net managers, and suppliers of safety-net capital (principally healthy banks and taxpayers). The touchstone by which to judge the performance of safety-net managers is the fairness with which they treat each of their Page 8 of 49 July 8, 2004 counterparties and the efficiency with which they manage the diverse social costs of coping with divergences from MT and MD conditions. It is not enough for safety-net managers to aim at blocking corrupt and unwise flows of institutional credit and avoiding depositor runs. They must seek also to minimize the social damage caused by temporary bank illiquidity and by lasting bank insolvencies. In administering lender-of-last-resort facilities, safety-net managers are expected to perform the financial triage function of shielding solvent, but illiquid institutions from having to sell assets into momentarily disorderly markets. In practice, a safety-net manager must assemble a staff that can wield six categories of regulatory instruments fairly and efficiently: 1. record-keeping and disclosure requirements; 2. activity limitations; 3. capital, loss-reserving, and other position limits; 4. takeover rights and other enforcement powers; 5. lines of credit; and 6. performance guarantees. The first four categories delimit the net managers’ authority to regulate the bank. Along with banks’ rights to challenge and appeal adverse actions, the last two categories provide credible ways for regulators to bond themselves to exercise their supervisory authority in the joint interests of banks and their various creditors. To complete the web of social contract enforcement, the suppliers of regulatory risk capital—banks and taxpayers— must be able to observe and discipline the economic value of their stake in the rulemaking and enforcement activities that regulators undertake. Ideally, taxpayers must impose reporting requirements and establish deterrent rights sufficient to persuade net managers to deploy their examination, supervisory, and lending powers at reasonable economic cost to society as a whole. These costs must be defined comprehensively and include both the costs of operating the net and the costs of managing its occasional breakdown. Taxpayer-regulator contracting is important because the practical politics of financial regulation and the exercise of appeal rights by regulated institutions would otherwise tend to make regulatory personnel overly responsive to bank and depositor concerns. Page 9 of 49 July 8, 2004 Theoretically, a nation’s safety net is a multiparty web of contractual duties and obligations. Its most palpable features are deposit guarantees and lender-of-last-resort credit facilities. The ideal safety net is one that efficiently mitigates the particular monitoring, policing, and coordination difficulties that present themselves to banks, depositors, and taxpayers in the informational, ethical, legal, and economic environment of a particular country at a particular time. This means that the optimal design and operation of a country’s safety net must adapt promptly to changes in the market, legal, bureaucratic, and ethical/cultural problems the net is intended to alleviate. For regulation and supervision to establish incentives for banks and regulators that are compatible with the interests of all other parties, net design must be environmentspecific. One issue is how transparent information systems and supervisory technology for monitoring bank capital and risk exposures are, either to outside experts or to the financial press. A second issue is the extent to which regulator incentives lead to patterns of discipline that reinforce or displace market procedures. Evidence of Variation in Informational Transparency Depositors want to be sure that deposit interest rates fairly compensate them for the risk exposures that bank loans and investments pass through to them. The “information” needed to benchmark this compensation consists of valid facts and projections that would help a well-trained financial analyst to calculate the market value of bank net worth as the difference between the present discounted values of bank assets and liabilities. When a nation’s financial markets inaccurately identify and price risks, they misdirect savings and investment. Such misdirection undermines a nation’s economic growth and well-being. It is helpful to think of bank disclosures as ore and information as a mineral that depositors and regulators can, with effort and only imperfectly, extract from this ore. Extraction is imperfect for two reasons: because banks have a legitimate interest in reserving proprietary information for their own use and because they may want to conceal potentially damaging information from other parties. Bank regulators are supposed to identify and promptly correct material misinformation. The less effectively the ethical norm of “fair dealing” constrains the business dealings of corporate and government officials in a given country, the more Page 10 of 49 July 8, 2004 thoroughly safety-net managers ought to doublecheck data provided by banks and bank borrowers. However, as a practical matter, strong incentives may push regulators in the reverse direction. The less effectively ethical norms and investigative journalism constrain government officials, the more likely it becomes that safety-net managers may be enlisted to use their instruments to help banks and at least some bank customers to exploit taxpayers. In financially sophisticated environments, the reliability of disclosures about bank values is tested and disciplined --albeit imperfectly-- by an array of outside parties. Rules governing bank disclosures come both from statutory and administrative law. Statutes are shaped in legislatures. Regulations governing how to value and itemize sources and uses of funds are established by administrative agencies and self-regulatory organizations. Enforcement by rulemaking entities is subject to due-process and constitutional review by a nation’s judiciary system. Dishonest corporate and government reporting is additionally deterred by the knowledge that information flows will also be reviewed informally by private “watchdog institutions:” professional accountants, credit bureaus, credit-rating agencies, an independent financial press, investment advisors, and even academic researchers. However, even in high-income countries, the information-verification mission of these watchdogs often conflicts with their other economic interests. Elsewhere, interinstitutional competition is usually weak, reporting standards relatively uninformative, and validity checks on bank and borrower disclosures allow many informational impurities to survive the data-testing process. Recapping the discussion, the quality of regulation varies across countries with informational transparency (T). In turn, T varies with accounting integrity (AI), ethical norms (EN), press freedom (PF), and the quality and credibility of compensating restraints regulators place on financial transactors (R). In symbols: T = T (AI, EN, PF; R). (1) Several research institutions rate in different ways the quality of the governance and information environments for depositors and taxpayers in different countries. Table 1 reproduces 1990-1998 measures of the relative informativeness of a country’s accounting standards, the degree of corruption observed in government or business Page 11 of 49 July 8, 2004 transactions, and the extent of press freedom. The table shows that the quality of relevant information varies greatly across countries. The table also indicates that what we may call accounting and ethical “integrity” correlate positively with press freedom and each other and also with the level of a country’s per capita income. Across the 41 countries for which the spottier accounting index exists, accounting integrity and 1990-1995 average real per capita GDP show a correlation of .59, while the correlation coefficient for accounting integrity with ethical integrity and press freedom in this subset of countries is .63 and .40, respectively. The first principal component of the three information variables explains 73.4 percent of their joint variance. For the 66 countries for which the corruption index has been constructed, the first principal component of the press-freedom and corruption indexes explains 80.1 percent of these variable’s joint variance and the correlation of ethical integrity with per capita GDP is .80. The index of press freedom (which was available for 73 countries) shows an r=.67 with per capita GDP. These correlations suggest not that the level of development determines the level of informational transparency or vice versa, but that both variables are simultaneously determined by omitted variables. These omitted variables may be interpreted as a culture’s shared beliefs about what is tolerable and intolerable deal-making behavior. Using this perspective frames the level of economic and financial development as an imperfect control for evolving social and cultural attitudes that strengthen the enforceability of financial contracts. For a safety net to operate fairly and efficiently in environments where informational and ethical integrity are low, the policy-making process of selecting design features must be open enough to establish accountability between regulators and taxpayers. Political Accountability increases with the freedom accorded a nation’s press and with the political and economic freedoms it grants its citizens to challenge government policies. However, the correlation of measures of ethical integrity with the Freedom House Index of press freedom and Heritage Foundation indexes of economic freedoms suggests that accountability is often weak in the particular countries where it most needs to be strong. Evidence of Variation in Depositors’ Deterrent Capacity Page 12 of 49 July 8, 2004 Given a country’s level of informational transparency, an individual depositor’s ability to protect itself from looming bank or borrower defaults is limited by the deterrent rights and enforcement powers conveyed to contracting parties by its country’s legal system. A depositor may be regarded as holding a contingent claim on the stock of its bank. Similarly, a portfolio of stock options written on the bank’s corporate borrowers is imbedded in the value of the bank’s loans. Both sets of stock options come into the money when banks and their borrowers choose to default. All defects in counterparty rights, in their enforceability, or in judicial and bureaucratic efficiency leave financial markets less complete and banks and bank depositors more vulnerable to default. Deterrency (D) depends on a country’s systems for policing corporate and public governance (G): D = D(G, T). (2) Weaknesses in D disadvantage three groups with stakes in the safety net: banks as lenders; depositors as bank creditors; and all suppliers of safety-net capital. In lowdeterrency environments, a rational saver will be reluctant to trust its funds to unrelated parties, unless the borrower bonds its repayment capacity in a credible way. Table 2 ranks 195 countries according to the 2002 level of a World Bank index of their ability to control corruption. Data for 1996, 1998, and 2000 are included to show that most countries’ average rating remains in the same quartile over time. As we observed with the indexes of informational integrity arrayed in Table 1, five other measures of deterrent protections that are posted on the World Bank website are highly correlated with one another and with this index. As with transparency, the level of deterrency increases on average as per capita income rises. Both types of collinearity reinforce our contention that unmeasured socio-cultural norms and freedoms explain differences in transparency and deterrency. This encourages us to investigate how differences in the quality of a country’s corruption control and level of development affect safety-net design. A climate of corruption makes it simultaneously harder for depositors to monitor insolvent banks and harder for taxpayers and solvent banks to monitor regulators. Used as a proxy for informational transparency, the index of corruption control can help us to explore how increases in informational reliability affect the dimensions of the safety net. Page 13 of 49 July 8, 2004 However, viewed as a proxy for deterrency and public accountability, enhancements in corruption control have contradictory effects. This because, in lessening banking fragility, effective corruption control simultaneously reduces the costs and the benefits of safety-net protection. Evidence of Cross-Country Variation in Accountability No existing dataset specifically documents cross-country differences in top officials’ accountability for safety-net performance. However, measures of central-bank independence have been compiled for 56 countries by Cukierman, Webb, and Neyapti (1992) and inverse indexes of press and economic freedoms are compiled by Freedom House and the Heritage Foundation, respectively. Each of these indexes proxies to some degree the accountability taxpayers impose on economic policymakers in general. The freer is a country’s press, the more readily taxpayers can observe and respond to government policymaking decisions. Similarly, the less coercive are a country’s economic policies, the easier it is to engage in circumventive behavior that both limits and underscores the potential damage that inefficient or unfair policies might otherwise generate. Finally, for central-bank officials, legal independence reduces political subservience. Cukierman et al. (1992, pp. 380-381) measure the extent to which centralbank officials have the authority and autonomy to pursue the goal of price stability even when this goal conflicts with other government objectives. By extension, the more politically independent is a country’s central bank, the more readily taxpayers can hold its top officials responsible for the macroeconomic effects of the supervisory policies the bank adopts. Like most other variables, central-bank independence and press and economic freedoms correlate significantly with per capita GDP, with correlation coefficients running as high as .70. Increases in central-bank independence and decreases in economic repression make it easier for suppliers of safety-net capital to hold safety-net managers accountable for the costs of the policies they follow. Role of Foreign-Bank Entry For 72 countries for which banking-market indexes existed in 1999, the three-firm banking concentration ratio correlates positively with economic repression (r ≈ .30 for five of the Heritage Foundation’s indexes). This correlation between banking-market Page 14 of 49 July 8, 2004 concentration and economic repression suggests that a country’s banking markets are more contestable when customers may transact more freely. In weak contracting environments, transparency, deterrency, and accountability are enhanced by the entry of foreign banks. In countries where actual competitors are few and entry protections have previously proved effective, incumbent banks would be apt to charge interest rates on loans that lie above their marginal funding costs and to pay interest rates on bank deposits that lie below their marginal value to the bank. Given an opportunity to extract monopoly rents from their customers, the net interest margin between loan and deposit interest rates would be high. In today’s world, however, high margins engender entry from abroad. Outside entry not only squeezes the benefits that entry restrictions can deliver to local banks, it drives the value of these benefits below the costs of cultivating the political influence necessary to support them. To persuade government officials to resist entry requires bankers to devise a politically workable way of sharing government-generated rents with friendly politicians and regulators. Deducting the side payments a bank makes to support entry protections produces what we may call its net regulatory rent. In principle, the capitalized value of the projected future net regulatory rents an incumbent bank can earn is an intangible asset that influences a bank’s earnings, stock price, market capitalization, and credit rating. However, once the profitability of local banks becomes dependent on the favors of government officials, schemes for compensating friendly officials impose tax-like influence-peddling costs that --as banking market structures meld globally—are eventually bound to exceed the benefits that entry restrictions can still produce. New products and communications channels expand opportunities for customers and outside institutions to circumvent transaction controls. Monopoly rents create incentives for customers and foreign banks to innovate around government restrictions. Technological change has continually undermined the effectiveness of entry barriers countries have previously used. In a world of rapid technological change, officials can at best temporarily slow the rate of outside entry. Thanks to the communications and information revolutions, globalization is wiping out the capitalized net value of regulation-induced bank rents in high-barrier countries. Page 15 of 49 July 8, 2004 Over time, entry tends to benefit host-country customers by providing access to better-regulated banks and by pushing loan and deposit interest rates in their favor. This path dependence makes it impossible to sign a priori the effect that current banking concentration has on safety-net design. The more energetically authorities have tried to limit banking competition to sustain bank profits in the past, the more rapidly they must expect foreign and domestic nonbank competitors to take high-margin business away from local banks in the future. Hence, high concentration simultaneously signals local banks’ prior investment in political clout and their future vulnerability to global competition. III. Cross-Country Differences in Safety-Net Design Features In the absence of MT and MD, depositors must watch for harm from two directions: 1. from past losses that bank insiders have managed (possibly with regulatory connivance) to conceal from public view; 2. from hidden exposures to future losses from illiquidity, bad luck, incompetence, negligence, fraud, corruption, or zombieness. For the safety net to efficiently and fairly protect depositors from these dangers, the net’s managers must incorporate design features into the mesh that counter the particular weaknesses in transparency and deterrency that characterize financial transactions in their country. For best results, the reasoning leading to particular design decisions should be made transparent to taxpayers, so that outside analysts can challenge and deter decisions that threaten to harm the public interest. Sources of Implicit Coverage The most important difference is whether the guarantees provided to depositors are made partially explicit or left completely implicit. Guarantees are explicit when they are embodied in enforceable obligations that depositors may collect from the insurer’s assets as a matter of law. Explicit systems are usually funded from ex ante premiums or ex post assessments imposed on eligible institutions. Although implicit deposit insurance is by nature unfunded, it is important and exists always and everywhere that banks are formally chartered by a specific government. Guarantees are implicit when their Page 16 of 49 July 8, 2004 enforceability depends on public confidence in the strength of recognized political incentives for a country’s leaders to bail out or rescue stakeholders in banks that become economically insolvent. Even in an explicit system, a degree of implicit insurance comes from the discretion authorities have to treat troubled institutions mercifully. An incipient banking crisis creates political incentives for incumbent officials in any government with an explicit system to extend regulatory forbearances, subsidized loans, and unfunded de facto coverages that exceed the formal limits specified in the nation’s laws and regulations. Also, in many countries, one or more banks are state-owned. For such banks, implicit deposit insurance is widely perceived to be absolute. Politically enforced implicit coverage is particularly strong among depositors of state-owned banks. To investigate the effect of this presumption, we use the La Porta, Lopez-de-Silanes, and Shleifer (1999) cross-country index of the relative importance of state-owned banks (GB, for Government Banking presence). GB measures the percentage of aggregate assets in a country’s ten largest banks that were controlled in 1995 by state-owned institutions. The index runs from precisely zero in about eight countries to precisely 100 percent in three others. The index is particularly high in socialist and ex-socialist countries. The median percentage is about 40 percent in Middle Eastern, Asian, and Latin American countries, and is notably lower for the so-called industrialized countries of Europe. The GB variable is significantly and negatively correlated with GDP, all of the information measures, economic freedom, and various corporate-governance variables. These correlations support the hypothesis that government banking presence tends to be larger in environments where informational integrity, deterrent rights, and accountability are weak. Implicit insurance also exists in explicit schemes, because formal limits on government support can easily be ignored. Officials have the option to extend coverages beyond statutory limits whenever that serves their bureaucratic or political interests. Unfortunately, extracontractual coverages are often provided when market-mimicking regulatory discipline would better promote taxpayer interests. Spread of Explicit Schemes Page 17 of 49 July 8, 2004 Figure 1 shows that during the last four decades, explicit deposit insurance has spread rapidly. Especially in Europe, socio-cultural expectations and cross-country agreements have added deposit insurance to the mix of baseline governmental responsibilities. Deposit-insurance guarantees sometimes protect even against the risk of currency devaluation by covering accounts denominated in foreign currencies. Table 3 documents that, during the last 25 years, countries in different regions adopted explicit deposit insurance in different degrees and in different ways. Figure 2 indicates that explicit insurance was part of the “best practices” policy standards that were promulgated in IMF policy reports during the last half of the 1990s (Lindgren, Garcia, and Saal, 1996 and Garcia, 1999). It is now widely understood that these standards are not in fact “best practices” in environments where transparency, deterrency, and accountability are weak (Demirgüç-Kunt and Kane, 2002). In poor informational and contracting environments, it is especially dangerous to undermine depositors’ ethical responsibility to look out for themselves. The lack of controls and the ambiguous and unfunded nature of purely implicit deposit insurance leads depositors to demand a risk premium that is broadly commensurate with the risktaking capacity of their bank. By providing bureaucratic and political mechanisms for patching weak banks, explicit guarantees make depositors less eager to gather information about an institution’s financial condition and less likely to react promptly to bad news about this condition. The more completely and reliably government or private insurers attempt to “bulletproof” depositors against loss, the less incentive individual depositors have to police the risks their banks can or do take. More than half the nations of the world still limit themselves to implicit guarantees. Hovakimian, Kane, and Laeven (2003) show econometrically that, when explicit guarantees are adopted, unfavorable country characteristics adversely influence deposit-insurance design. For explicit deposit insurance to improve social welfare, the regulatory culture must be strong enough to impel authorities to generate as much supervisory discipline as the private discipline that deposit insurance displaces. Anesthetization of depositor concerns can permit minor bank insolvencies to fester and grow into hopeless insolvencies unless the regulatory culture focuses on addressing supervisory problems promptly. Page 18 of 49 July 8, 2004 Together, Tables 2 and 3 show that success in controlling corruption helps to predict the introduction of explicit deposit insurance. However, corruption control is neither a necessary nor a sufficient condition for including explicit guarantees in the safety net. One-third of the countries in each of the lowest three quartiles of Table 2 offer explicit guarantees, while one-third of the 40 countries with the least-corrupt environments do not. However, the recent surge in adoption by lower-ranking countries has been distorted by pressure from multinational organizations. For example, Eastern European countries have been eager to meet criteria for membership in the European Union and these criteria include explicit deposit insurance. Also, throughout the 1990s, IMF personnel encouraged countries in Latin America and Asia that experienced banking crises to craft explicit deposit insurance systems as a way to back away from unlimited guarantees installed in the heat of crisis. Special Dangers of Introducing Explicit Deposit Insurance in Difficult Circumstances In downturns, deposit insurance can block the exit of insolvent banks. Instead of assuring the prompt exit of crippled or unprofitable firms, political pressure may urge regulators to narrow the industry’s “exit drainpipe.” This is most likely to occur when politicians are eager to preserve these institutions’ contribution to politically inspired credit-allocation programs. Allowing unprofitable deposit institutions to issue guaranteed deposits can artificially prolong their life at levels of net worth that would otherwise be too low to sustain their existence. These deeply insolvent firms may be likened to “zombies” in that they are kept alive by the black magic of government guarantees. Zombie competitors are dangerous to society because they can bid down industry profit margins to levels so low that even healthy and well-managed banks can no longer turn a profit. In the United States, exit pressure that built up in the mid-1960s was not released until well into the 1980s, when an explosion of belated deposit-institution exits occurred. By then, most of the departing firms were zombie institutions whose insolvency could and should have been resolved long ago. Some of the others were marginal institutions that might have survived had safety-net managers not allowed industry profit margins and risk-taking incentives to become so badly distorted. Page 19 of 49 July 8, 2004 When deposit insurance retards the exit of poorly performing deposit institutions, not only is new entry discouraged, but healthy competitors and taxpayers (as suppliers of safety-net capital) are forced to back up high-risk gambles by crippled firms. Bailing out zombie institutions distorts the stock of real capital by encouraging loans to high-risk enterprises and assigns taxpayers an unbalanced option on industry profits. Taxpayers are required to pay off future losses, but receive little opportunity to participate in gains. The most that taxpayers can receive from a recovered institution is relief from the need to continue to fund bailout arrangements. Explicit deposit insurance is especially dangerous when it is introduced in crisis circumstances. Typically, adopting explicit insurance as an emergency measure serves to enhance the danger of deeper future crises. In crisis circumstances, insurance authorities seldom receive sufficient monitoring and policing authority to compensate for the depositor discipline their deterrent activity is bound to displace. Moreover, even in cases where the insurer’s deterrent powers are sufficient in principle, safety-net managers are not made adequately accountable for using these powers in the interests of society as a whole. When these critical design features are compromised, explicit deposit insurance encourages a nation’s banks to direct a considerable amount of credit to imprudent longshot investment projects that waste a nation’s scarce savings and reduce the present discounted value of its aggregate stock of real capital. The problem is governmental myopia. The immediate benefits of a bankingsystem rescue come at a time when the long-run control of supervisory and bank risktaking incentives has little urgency. Once a country’s banking system experiences large losses, bank stakeholders lobby for a massive infusion of state resources. Introducing explicit deposit insurance provides a convenient way for these stakeholders to mask the size of the subsidies they extract. Government guarantees can rescue a deeply troubled banking system without immediately requiring economic policymakers either to recognize the size of bank losses or to impose new taxes. Because explicit insurance reduces depositor concern for transparency and deterrency, opportunities for engaging in unsound and corrupt banking practices tend to expand unless and until subsequent reforms strengthen government banking supervision appropriately. Page 20 of 49 July 8, 2004 Confirming these concerns, Demirgüç-Kunt and Detragiache (1998 and 2002) find that, when they control statistically for the impact of exogenous crisis-generating forces, the likelihood of undergoing a banking crisis is higher in countries that have adopted an explicit deposit-insurance system than in countries in which guarantees of bank deposits are entirely implicit in character. A companion paper (1999a) by these same authors shows that open banking crises are likely to follow the lifting of binding interest-rate ceilings on deposits and that the likelihood of a crisis is higher in countries where “the rule of law is weak, corruption is widespread, the bureaucracy is inefficient, and contract enforcement mechanisms are ineffective.” In these environments, capitalimpaired institutions are not identified and disciplined quickly enough to avoid massive losses to insuring agencies and their taxpayer-owners. The combination of virtually complete coverage and resolution delay encourages depositors to allow weak institutions to increase risky positions until the aggregate losses become too large for the insurance system to credibly support. Desirable and Undesirable Safety-Net Features In principle, several deposit-insurance design features can constrain banks’ ability to exploit weaknesses in transparency, deterrency, and accountability. Market discipline can be generated by increasing the number of private parties that are responsible for absorbing a “first-loss share” of the losses bank insolvencies entail. In practice, private loss bearers are either very large depositors, bonding companies, or subordinated debtholders. The value to society of incorporating this design feature turns on the credibility of two expectations: (1) that government officials will force private parties to live up to their contractual responsibilities and (2) that loss-sharing private parties will not stand by if governmental forbearance exposes them to increasing risks. Several ways exist to expand first-loss exposure. One is to make private parties underwrite and manage some of the loss exposures inherent in the deposit-insurance system. For example, clearing members of stock and commodities exchanges operate a private safety net in which they promise to absorb losses traders suffer due to failures in settlement. In Table 3, when the column labeled “Management” shows a “2,” the deposit insurance system is jointly managed by private and governmental entities; when it shows a “3,” responsibility for insurance is formally private. Tables 3 and 4 show that, of the 11 Page 21 of 49 July 8, 2004 countries whose stock exchanges Siow and Aitken (2003) rate highest in efficiency and integrity, seven incorporate privatization features in their banking safety net. A second way to enlist private parties in constraining bank risk shifting is to use exclusions and coverage limits to render insurance coverage incomplete. Most countries formally specify an upper limit to the size of deposit balance they protect. Relatively few countries cover interbank deposits, but it is fairly common to insure accounts denominated in foreign currency. A contractual device for controlling moral hazard similar to exclusions and coverage limits that private insurance companies use is coinsurance (Calomiris, 1998; Kane, 1995). Coinsurance requires that the insured party bear a specified share of the value that is destroyed when a loss-causing event occurs. Although risk-control benefits of coverage limits and coinsurance require assured enforcement, they can be realized without turning small depositors into loss-bearers. A deposit insurer can exempt small accounts and structure larger depositors’ coinsurance responsibility as a combination of percentage and fixed deductions from each reimbursement claim. What matters is to impart to designated private stakeholders the incentives and information they need to control bank risk-taking. Table 3 shows that only about 15 countries currently ask depositors to coinsure safety-net losses. IV. Matching Deposit-Insurance Design Features with Individual-Country Characteristics Contracting theory emphasizes that counterparties face strong incentives to minimize the costs of agency. Black, Miller, and Posner (1978) conceive of a country’s deposit insurers as “stepping into the shoes of individual depositors.” This conception clarifies that, absent outside pressure from international institutions, conscientious officials in individual countries would design their portion of the safety net to cope with the particular deficiencies in transparency and deterrency that depositors face in their country’s financial and economic environment. However, officials’ conscientiousness varies with cross-country differences in transparency, deterrency, and accountability. Hovakinian, Kane, and Laeven show that, in weak institutional environments, authorities are unlikely to adopt a mix of loss-sharing rules, risk-sensitive premiums, and coverage limits strong enough to control moral hazard. This implies that European Union, IMF, and World Bank personnel should Page 22 of 49 July 8, 2004 recommend changes in the structure of a country’s safety net only after carefully analyzing how each change would affect transparency, deterrency, and accountability. Accountability for Implicit Coverages as a Design Feature Taxpayers’ investment in the safety net consists of the contingent tax liability they accept in explicitly and implicitly backing up the net’s guarantees. In the absence of taxpayer back-up, private and government deposit-insurance managers would have to expend additional resources to convince contractual counterparties that the enterprise can be relied upon to fulfill its contractual commitments (Merton and Perold, 1993). The capitalized value of the annual saving in enterprise expense may be defined as “risk capital” that taxpayers contribute to the deposit-insurance system. Unless taxpayercontributed risk capital generates a fair return in the form of safety-net benefits to society, deposit-insurance schemes unwisely subsidize bank risk-taking. In managing safety-net capital, regulators are pulled in contradictory directions. On the one hand, they are expected to minimize the risk of a banking disaster. For this reason, regulators who show mercy to a troubled bank garner public praise for themselves and their agency. On the other hand, regulators are also expected to minimize the cost of bailing out troubled banks and to subject all banks to market-mimicking discipline. However, regulators who strongly and transparently discipline a weak bank risk being blamed for aggravating the bank’s problems. Suppressing evidence of banking weakness and relaxing capital requirements is a rational way to resolve this tension, especially if safety-net officials expect to hold office briefly and can derive bureaucratic and reputational benefits from currying industry support. This incentive conflict is not easily resolved. Unless regulatory decisions take place in a MTMD environment for taxpayers, safety-net managers cannot be made fully accountable in a timely manner for managing taxpayers’ economic stake in the safety net. Though helpful, efforts to privatize the loss exposure can never be complete, because even a privately managed and funded deposit-insurance scheme enjoys implicit catastrophic taxpayer back-up. The taxpayer remains a silent partner whose investment in the net is both unfunded and unlikely to be formally acknowledged by net managers. To the extent that the informational environment allows, it is important to make specific officials responsible for tracking the aggregate losses to which the safety net Page 23 of 49 July 8, 2004 exposes taxpayers and for pricing and managing this exposure appropriately. However, the difficulty of implementing this principle in environments where information is unreliable and corruption is rampant implies that introducing explicit guarantees may end up substituting corrupt government supervision for value-preserving private discipline. To guard against this unhappy result, political independence for safety-net officials is not enough. In low-accountability environments, safety-net designers must incorporate features that can generate strong private discipline on safety-net managers and bankers alike. A good starting point is for authorities to take steps to make risk more visible to outsiders at the individual-bank level. In particular, a positive obligation might be placed on every insured bank’s top officers to personally certify the material accuracy of marked-to-market estimates of bank net worth and to report promptly all substantial changes in risk exposures and net worth to regulators. Where mark-to-market estimates are hard to verify, insured banks should be asked to hold proportionately higher levels of accounting capital and their officers should be subject to particularly severe penalties for failing to disclose material adverse information. As better information on bank capital and loss exposure becomes available, government regulators can be assigned two further specific tasks: (1) to calculate in a reproducible manner an accounting estimate of the opportunity-cost value of depositinsurance risk exposures in insured banks, and (2) to tailor insurance premiums and regulatory intervention to control the risk each bank passes on to the insurer. Accountability for these activities could be established by having regulators’ calculations closely audited by a multinational private accounting firm and by offering top regulators in each country deferred compensation that they would forfeit if statistical analysis of available data and subsequent events could prove that the agency’s risk calculations were fudged. It is also possible to lessen incentive conflicts by directly curtailing the benefits that stockholders of insolvent institutions can extract by go-for-broke risk-taking. In practice, the profitability of endgame plays can be blunted by extending stockholder liability for liquidation losses beyond the level of the capital actually paid-in at the corporate level. Several now-industrialized countries (including the U.K., the U.S. and Page 24 of 49 July 8, 2004 Canada) imposed extended liability on bank shares when their contacting environments were more rudimentary. Extended liability has the advantage of increasing transparency, deterrency, and accountability at the same time. It increases transparency by transforming movements in the stock price of publicly traded banks into a clearer signal of institutional strength or weakness. Extended liability means that the insurer’s right to liquidate an insolvent bank carries with it a right to collect additional funds from the personal assets of every stockholder. As compared to limited-liability shareholding, deterrency is enhanced by stockholders’ duty to pony up additional funds if (but only if) managers and regulators allow the bank to become so insolvent that it passes into liquidation. Stock markets would imbed the value of this contingency into the price of each bank’s shares. The value of the contingency would be negligible for banks that were performing well and adequately supporting their risk with paid-in capital. However, the insurer’s right would become increasingly valuable whenever a bank began to take poorly supported risks or to slide into serious trouble. By increasing the sensitivity of bank stock prices to changes in bank earning power and earnings volatility, extended liability would encourage information-revealing stockholder runs on troubled banks in advance of their falling into complete economic insolvency. This kind of stock sell-off would increase regulatory deterrency by helping safetynet managers to identify institutions that deserve increased supervisory attention long before the enterprise-contributed capital of these institutions could be exhausted. Moreover, in contracting environments where the chance that stockholders might overreact to bad news is strong, the deterrent effect of extended liability would be particularly forceful. Extended liability would increase regulatory accountability because adverse stock price movements would generate public pressure on regulators to investigate and take remedial action. Extended liability would also raise the news value to outside stockholders, taxpayers, and the financial press of staying abreast of regulatory actions and their effects. To make sure that extended-liability assessments can be collected promptly from failed-bank stockholders, it would be reasonable for authorities to require each Page 25 of 49 July 8, 2004 stockholder to bond its extended-liability obligation by depositing earning assets in a collateral account at the central bank.1 Stockholders could be free to move individual assets into and out of the collateral account over time as long as the aggregate market value of the collateral account remains sufficient and the value of all posted assets can be continuously verified. Just as in an ordinary margin account, if the total value of the pool falls below a specified threshold value, it must be promptly replenished. If it is not, the custodian must be empowered to force a stock sale. For any economy that ranks low in informational and ethical integrity, extended liability provides an elegant economic solution to the problem of deposit-insurance riskshifting. It would improve the private and public contracting environments by insinuating an observable and market-driven wedge between the economic interests of ethical and unethical bankers and regulators. Of course, this is precisely why it is politically difficult to build an effective constituency for it. One must expect bank stockholders to resist efforts to narrow their risk-shifting capacity. One must also expect corrupt regulators to defend limited liability and the kickbacks that risk subsidies generate. Still, for conscientious officials, extended liability represents a workable alternative to more intrusive government supervision of bank activity and is a strategy that would work little harm on banks that expect to stay healthy. Desirability of Rehearsing Crisis Management Procedures When a safety net fails in a circus, managers face a multidimensional disaster: at least one dead or badly broken acrobat, a shocked and grieving staff, a panicked crowd of traumatized spectators, and a mess that needs to be contained and cleaned up before it can escalate into a catastrophe. Unless staffmembers have been drilled in containing and cleaning up a crisis, they are unlikely to prioritize and coordinate their activities in the best interests of the circus or the audience. When a country’s financial safety net breaks down or threatens to break down, similar problems of priority and coordination arise. Although the first line of crisis management is an unstinting program of inspection, testing, and prompt repair, it must be recognized that troubled banks have strong incentives to circumvent the prevention 1 Where appropriate, this account might be required to include some kind of currency hedge and could be held in safekeeping at the insured institution. Page 26 of 49 July 8, 2004 system. Whenever prevention fails to contain circumvention, a number of banks go splat. The second line of crisis management is resolving the insolvency of damaged banks. Insolvency resolution determines who loses what amounts when the net worth of many banks is wiped out at the same time. For authorities to allocate losses efficiently, they must establish defensible policy priorities in advance and commit themselves to pursuing these priorities in the event. The first priorities are rescue and triage. Dead and injured institutions must be sorted out immediately and cared for appropriately. The second priority is crowd control. Evidence that triage is being handled efficiently should help to curtail panicky audience exits, but specific staffmembers must take up the task of helping depositors who want to extract their funds to do so in an informed and orderly manner. The third priority is to clean up the mess so that the show may resume without an undue delay. Rescue and Triage. In the midst of an emergency, triage decisions cannot wait for formal ratification by less-informed higher-ups. Although staff judgments must be reviewed and criticized later, during an emergency the autonomy of examination teams must be respected and supported at all levels of the bureaucracy. The difficulty of switching from a hierarchical structure of bureaucratic decision-making to a decentralized structure of immediate response helps to explain why government officials must not presume that they can work out efficient schemes of disaster management on the fly. In any medical disaster, making decisions about the urgency of treating different patients is called triage. Triage begins with evaluating each casualty’s particular needs. This assessment seeks to determine which parties are and are not beyond help. Its second objective is to set priorities for treating those that can benefit from specific assistance. Available medical resources must be allocated to the particular tasks that promise to do the most good. This means rushing into surgery those whose wounds and injuries either are at a life-or-death stage or are apt to worsen greatly with delay. Nonsurgical (i.e., less scarce) personnel take on the roles of comforting moribund patients and helping noncritical patients wait for treatment. In a systemic banking crisis, the casualties are the stockholders, employees, depositors, and nondeposit creditors of a nation’s banks. Authorities cannot be expected to find and treat individual casualties efficiently unless they have formulated an Page 27 of 49 July 8, 2004 integrated disaster plan and drilled personnel in its execution. Regulatory staff must be prepared to react to the first signs of crisis without having to wait for specific directions from above. Bank examiners must have access to the data and expertise needed to size the depth of emerging insolvencies promptly. Supervisory personnel must be divided into teams that are trained to determine—for every individual institution that suffers an insolvency-revealing run— the degree of help that the institution’s different stakeholders would require to make them whole. Without this information, higher officials cannot evaluate the reasonableness of forcing taxpayers to supply that help. It is easy to see that it makes no sense in the midst of an emergency to divert limited surgical resources to sewing up the wounds or resetting the broken bones of a moribund individual. Similarly, officials must be trained to recognize that in dealing with hopelessly insolvent institutions it makes no sense to open the public purse to preserve the positions of stockholders and subordinated creditors or to keep paying top managers lofty salaries. Until the size of individual insolvencies can be sorted out, depositor access to funds must be suspended. Insured depositors should be granted access to their funds as soon as it is administratively possible and uninsured depositors should be accorded a fair degree of immediate fractional access to their funds. How fully the positions of other uninsured creditors should be marked down (or “haircut”) depends on the depth of—and margin for error in—the loss assessments that the examination team is able to assemble. Procedures for setting the transactable fraction of different deposit accounts should be founded in conservative valuation techniques whose application is rehearsed in advance. Examiners should be trained to estimate the minimum percentage of uninsured deposits that could be recovered in an orderly liquidation of the bank’s tangible portfolio. The rest of each depositor’s balance is unfrozen in stages when and as the depth and intangible elements of each bank’s insolvency can be sized more precisely. The most straightforward way to preserve the liquidity of bank depositors is to assure insured and uninsured customers of each insolvent bank that arrangements are being made to grant them direct or indirect access to central-bank funds based on the recoverable value of their net claims on the bank and its insurer. Preparing examiners to Page 28 of 49 July 8, 2004 calculate promptly the value at which bank assets could be liquidated in an orderly manner is the key step in restoring the liquidity of deposit accounts. Once examiners have made these quick-and-dirty calculations, depositors can be granted at least fractional access to the funds in their accounts. At the same time, the government should establish a formal claim on the equity of each insolvent bank either by completely extinguishing the rights of former shareholders or by taking a warrant position large enough to compensate taxpayers for the administrative and risk-bearing costs of overseeing the bank’s recapitalization. In either case, the aim would be to sell the government’s equity claim to private parties as soon as reliable information on asset values can be developed. Crowd Control. Banking panics are triggered by adverse information that destroys customer confidence in the repayment capacity of a group of banks. The trigger may be information either about broad economic events, about specific banks, or about assets banks are known to hold. A panic is defined by two conditions. First, in a panic, depositor runs are so widespread that affected banks cannot raise funds quickly by selling liquid assets to other parties at fair prices. Second, institutions not experiencing runs are reluctant to lend enough funds to affected banks to allow them to maintain the convertibility of their deposits into cash. For authorities, an obvious concern is to halt the spread of illiquidity and financial dislocation. Using the words “panic” and “depositor runs” to describe the onset of this problem builds a subliminal case for authorities to throw themselves into rescue mode without stopping to consider longer-run priorities. The urgency of stopping the spread of confusion must not over-ride the simultaneous need to identify zombie institutions and begin the process of winding up their affairs. Issuing blanket government loans and guarantees to all troubled banks shifts the burden of absorbing the losses imbedded in zombie portfolios to taxpayers and relieves managers, stockholders, and creditors from bearing due responsibility for loss-making decisions they had effectively ratified. Injections of liquidity should be offered only in exchange for good assets and control over zombie institutions must be put into new hands. This principle allows authorities to maintain aggregate liquidity by open-market operations, but requires them Page 29 of 49 July 8, 2004 to take the measure of a bank’s wounds before expanding its individual access to emergency loans. It should be understood that insolvency-assessment timeouts will occur and that, during these timeouts, would-be transactors can be expected to use standard and innovative forms of credit to prevent transactions from grinding to a halt. Checks and credit-card slips will still circulate. However, instead of being cleared promptly, they will stand as evidence of personal indebtedness. When the timeout ends, if the issuing bank cannot cover them, these debts may be discharged from other sources. The spread of confusion can and should be countered by an intelligent mix of structural and macro policies. Macro control may be effected by avoiding monetary contraction and by offering government loans and guarantees to certifiably healthy banks. Structural policy measures should enlist nongovernmental parties in the tasks of identifying viable institutions and of focusing liquidity assistance on them. Policymakers should make sure that, in judging which banks and assets deserve to be shielded from the spreading harm, authorities do not blunt the analytic capacities of nongovernmental entities, customers, local clearinghouses, and foreign banks. Cleanup. Banking crises are the deep downside of a process of lending to parties whose ability to repay cannot be accurately assessed in advance. A panic occurs when profound weaknesses in customer repayment capacities surface so suddenly that large losses need to be assigned not just to bank stockholders, but also to bank creditors and their guarantors. To clean up the red ink that has been spilled, declines in bank asset values must pass through the liability side of bank balance sheets. In designing an interim treatment plan, the long-run cost of interfering with the transfer of a bank’s losses to its creditors must be weighed against the benefits of bringing the panic to a quicker end. It is unreasonable to suppose that keeping stockholders in deeply insolvent banks from paying for managerial mistakes is a desirable public policy. Inefficiently managing a bank’s resources destroys its ownership capital. This loss of capital should unleash market forces that transfer the valuable parts of any insolvent bank’s franchise into better-capitalized and potentially more-skillful hands. Closing an insolvent bank or assigning its business to a new owner is not a barbarously cruel thing to do. Unless creditors and investors expect inefficient managers and undercapitalized firms to be Page 30 of 49 July 8, 2004 promptly and appropriately disciplined, the incentives that govern the evaluation and selection of risky investment projects will break down. On average, the more fairly an insolvent banking system’s losses can be allocated, the more likely it is that socially desirable patterns of bank lending will be restored. The more efficiently and more fairly the process of loss resolution is conducted, the smaller the long-run cost in economic resources and social demoralization a country must pay to make its banking system whole again. V. Summary The risks banks take originate in the real economy. To allow banks to intermediate a nation’s flow of savings and investment, depositors must be confident in banks’ ability to monitor the quality of borrowers. Accumulating stockholder equity is a way for individual banks to bond the quality of their monitoring activity, but it is not the only way. In particular, because governments have an interest both in assuring the efficiency with which savings are invested and in limiting the damage that bad banking may engender, governments erect a financial safety net. Safety-net design must address differences in transparency, deterrency, and accountability that exist across countries. The weaker is a country’s informational, ethical, and corporate-governance environment, the greater the danger than a wholly governmental system of explicit deposit guarantees will undermine bank safety and stability. Barth, Caprio, and Nolle (2004) provide a snapshot of how banking and regulatory environments differ across countries. The analysis presented here stresses that the design features incorporated into a country’s net ought to evolve over time with changes in private and government regulators’ capacity for valuing banking institutions, for monitoring and disciplining risk-taking, for resolving insolvencies promptly, and for being held accountable for how well they perform these tasks. Safety-net managers should neither subsidize nor tax bank risk-taking. No reputable body of economic thought argues that taxing or subsidizing risk-taking is an optimal way to run a developing nation’s economy. Even if a case for such a policy Page 31 of 49 July 8, 2004 could be made, it would be inefficient to channel taxes and subsidies through a government-run safety net whose managers are not required either to plan for disaster or to account publicly for taxpayers’ stake in its operations. REFERENCES Barth, James R., Gerard Caprio, and Daniel E. Nolle, 2004. “Comparative International Characteristics of Banking,” Washington: Comptroller of the Currency, Economic and Policy Analysis Working Paper 2004-1 (January). Black, Fischer, Merton Miller, and Richard Posner, 1978. “An Approach to the Regulation of Bank Holding Companies,” Journal of Business, 5 (July), pp. 379412. Brock, Philip L., 1999. “Financial Safety Nets: Lessons from Chile.” Seattle: University of Washington, (March). Calomiris, Charles W., 1999. “Building an Incentive-Compatible Safety Net,” Journal of Banking and Finance, 23(October), pp. 1499-1519. _____, 1997. The Postmodern Safety Net: Lessons from Developed and Developing Economies. Washington: American Enterprise Institute. Carnell, Richard, 1993. “The Culture of Ad Hoc Discretion,” in George Kaufman and Robert Litan (ed.), Assessing Bank Reform: FDICIA One Year Later, Washington: Brookings Institution, pp. 113-121. Cukierman, Alex, Stephen Webb, and Bilin Neyapti, 1992. “Measuring the Independence of Central Banks and its Effect on Policy Outcomes,” World Bank Economic Review, 6 (No. 3), pp. 353-398. Demirgüç-Kunt, Asl, and Enrica Detragiache, 1998. “The Determinants of Banking Crises: Evidence from Developing and Developed Countries,” IMF Staff Papers, 45 (no. 1), pp. 81-109. _____, 1999a. “Financial Liberalization and Financial Fragility,” Proceedings of the Annual World Bank Conference on Development Economics, Washington: The World Bank, pp. 303-31. Page 32 of 49 July 8, 2004 _____, 2002. “Does Deposit Insurance Increase Banking System Stability?: An Empirical Investigation,” Journal of Monetary Economics, 49, pp. 1373-1406. Demirgüç-Kunt, Asle, and Edward J. Kane, 2002. Journal of Economic Perspectives, 16 (No. 2), pp. 175-195. Demirgüç-Kunt, Asl, and Tolga Tobac, 2000. “Deposit Insurance Around the World: A Data Base,” World Bank manuscript. Diamond, Douglas, 1984. “Financial Intermediation and Delegated Monitoring,” Review of Economic Studies, 51(July), pp. 343-414. Diamond, Douglas, and Philip Dybvig, 1983. “Bank Runs, Deposit Insurance, and Liquidity,” Journal of Political Economy, 91(June), pp. 401-19. Garcia, Gillian G.H., 1999. “Deposit Insurance: A Survey of Actual and Best Practices,” Washington: International Monetary Fund, Working Paper No. 99/54. Goldstein, Morris, and Philip Turner, 1996. Banking Crises in Emerging Economies: Origins and Policy Options. Basle: Bank for International Settlements. Hovakimian, Armen, Edward Kane, and Luc Laeven, 2003. “How Country and SafetyNet Characteristics Affect Bank’s Risk-Shifting,” Journal of Financial Services Research, 23 (No. 2) pp. 177-204. Jensen, Michael C., and William Meckling, 1976. “Theory of the Firm: Managerial Behavior, Agency Costs, and Ownership Structure,” Journal of Financial Economics, 3(June), pp. 305-360. Kane, Edward J., 2000. “Designing Financial Safety Nets to Fit Country Circumstances.” (unpublished). _____, 1995. “Three Paradigms for the Role of Capitalization Requirements in Insured Financial Institutions,” Journal of Banking and Finance, 19 (June ), pp. 431-459. __________, 2003. “What Kind of Multinational Deposit-Insurance Arrangements Might best Enhance World Welfare?,” Pacific-Basin Finance Journal, 11 (No. 4), pp. 413-428. La Porta, Rafael, Florencio Lopez-de-Silanes, and Andrei Shleifer, 1999. “Government Ownership of Commercial Banks,” Harvard University manuscript (November). Page 33 of 49 July 8, 2004 La Porta, Rafael; Florencio Lopez-de-Silanes, Andrei Shleifer, and Robert W. Vishny, 1998. “Law and Finance,” Journal of Political Economy, 106 (December), pp. 1113-1155. Lindgren, Carl-Johan, Gillian Garcia, and Matthew I. Saal, 1996. Bank Soundness and Macroeconomic Policy. Washington: International Monetary Fund. Merton, Robert C., and André F. Perold, 1993. “Theory of Risk Capital in Financial Firms,” Journal of Applied Corporate Finance, 6(Fall), pp. 16-32. Miller, Geoffrey P., 1997. “Deposit Insurance for Economies in Transition,” in Yearbook of International Financial and Economic Law, Amsterdam: Kluwer Law International, pp. 103-138. Siow, Audris S. and Aitken, Michael J., "Ranking World Equity Markets on the Basis of Market Efficiency and Integrity," The HP Handbook of World Stock, Derivative & Commodity Exchanges 2003, Herbie Skeete, ed., pp. xlix-lv, Mondo Visione Ltd., 2003 http://ssrn.com/abstract=490462 Talley, Samuel H., and Ignacio Mas, 1990. Deposit Insurance in Developing Countries, Policy, Research, and External Affairs Working Paper Series No. 548, Washington: The World Bank. Page 34 of 49 July 8, 2004 Figure 1: Cross-Country Trend in the Adoption of Explicit Deposit Insurance 83 85 79 77 78 80 74 75 70 63 65 56 57 55 50 50 46 43 45 40 40 35 30 30 34 36 27 25 20 15 10 5 32 1 3 4 6 7 9 10 14 15 12 13 19 20 17 18 22 0 19 34 19 61 19 62 19 63 19 66 19 67 19 69 19 71 19 74 19 75 19 77 19 79 19 80 19 82 19 83 19 84 19 85 19 86 19 87 19 88 19 89 19 92 19 93 19 94 19 95 19 96 19 97 19 98 19 99 20 00 20 01 20 02 20 03 Number of Explicit DI Systems 60 Years Number of DI Systems Page 35 of 49 July 8, 2004 FIGURE 2 BEST PRACTICES FOR SAFETY-NET DESIGN, AS ENVISIONED BY IMF RESEARCHERS IN THE MID-1990s All Countries Should Establish Explicit Deposit Insurance The Insurance System Should Incorporate at Least the Following Design Features: Prudential regulation Limitations on coverage Mandatory membership Political “independence” for regulatory officials. Page 36 of 49 July 8, 2004 Page 37 of 49 July 8, 2004 Table 2: Control of Corruption in 195 Countries Between 1996 and 2002, Listed in Order of Percentile Rank in 2002 Country 2002 2000 1998 1996 FINLAND SINGAPORE NEW ZEALAND DENMARK SWEDEN ICELAND SWITZERLAND NETHERLANDS CANADA LUXEMBOURG NORWAY UNITED KINGDOM AUSTRALIA AUSTRIA GERMANY UNITED STATES IRELAND BELGIUM CHILE HONG KONG SPAIN FRANCE BAHAMAS PORTUGAL ANDORRA BARBADOS BERMUDA CAYMAN ISLANDS LIECHTENSTEIN JAPAN PUERTO RICO UNITED ARAB EMIRATES ISRAEL KUWAIT OMAN BAHRAIN QATAR BHUTAN SLOVENIA CYPRUS COSTA RICA ANTIGUA AND BARBUDA FRENCH GUIANA MARTINIQUE TAIWAN 100 99.5 99 98.5 97.9 97.4 96.9 96.4 95.9 95.4 94.8 94.3 93.8 93.3 92.8 92.3 91.8 91.2 90.7 90.2 89.7 89.2 88.7 88.1 85.6 85.6 85.6 85.6 85.6 85.1 84.5 84 83.5 83 82.5 82 81.4 80.9 80.4 79.9 79.4 77.8 77.8 77.8 77.3 100 99.5 97.3 97.8 98.9 98.4 95.7 96.7 96.2 94 94.6 95.1 93.5 92.9 91.8 92.4 90.8 87 90.2 89.1 91.3 89.7 81.5 88.6 N/A N/A N/A N/A N/A 87.5 88 76.1 85.9 82.1 78.3 70.7 77.2 86.4 84.2 84.8 83.2 N/A N/A N/A 77.7 98.9 97.3 97.8 99.5 98.4 95.1 100 96.2 96.7 92.9 95.6 94.5 93.4 91.8 94 91.3 92.3 86.3 85.8 90.2 89.6 90.7 78.7 89.1 N/A N/A N/A N/A N/A 86.9 88.5 81.4 88 85.2 83.6 73.8 82 75.4 82.5 87.4 80.3 N/A N/A N/A 84.2 99.3 97.3 98.7 100 98 91.3 95.3 96 96.7 92 94.7 94 93.3 89.3 90.7 90 92.7 83.3 86 88 81.3 86.7 66 85.3 N/A N/A N/A N/A N/A 84.7 84 64 87.3 78.7 63.3 62 57.3 N/A 82.7 88.7 80.7 N/A N/A N/A 80 Page 38 of 49 July 8, 2004 MALTA ITALY URUGUAY BOTSWANA GRENADA ESTONIA HUNGARY GREECE SAUDI ARABIA MAURITIUS DOMINICA SEYCHELLES ST. KITTS AND NEVIS ST. LUCIA ST. VINCENT AND THE GRENADINES POLAND CZECH REPUBLIC MALAYSIA SOUTH AFRICA TUNISIA KOREA, SOUTH CAPE VERDE BRUNEI SLOVAK REPUBLIC LITHUANIA CROATIA MAURITANIA NAMIBIA SURINAME MADAGASCAR FIJI LATVIA ERITREA MALDIVES JORDAN MARSHALL ISLANDS MOROCCO BURKINA FASO TRINIDAD AND TOBAGO BRAZIL SAMOA MACAO CUBA SRI LANKA MONGOLIA THAILAND SENEGAL BULGARIA MEXICO PERU 76.8 76.3 75.8 75.3 74.7 74.2 73.7 73.2 72.7 72.2 71.1 71.1 69.6 69.6 69.6 69.1 68.6 68 67.5 67 66.5 66 65.5 64.9 64.4 63.9 63.4 62.9 62.4 61.9 61.3 60.8 60.3 59.8 59.3 58.8 58.2 57.7 57.2 56.7 56.2 55.7 55.2 54.6 54.1 53.6 53.1 52.6 52.1 51.5 Page 39 of 49 68.5 82.6 78.8 83.7 63 79.3 79.9 81 60.9 75 48.9 63 63 75.5 63 73.4 72.3 67.9 73.9 76.6 72.8 63 55.4 69.6 70.1 60.3 26.6 85.3 68.5 21.2 74.5 59.2 58.2 33.2 62 63 71.2 25 71.7 59.8 63 N/A 45.7 58.7 41.8 46.2 42.9 54.9 44 56.5 78.7 84.7 74.9 78.1 63.4 76.5 79.8 83.1 72.7 71 48.6 48.6 63.4 63.4 63.4 77 73.2 80.9 74.3 68.3 69.9 48.6 66.7 62.8 67.8 46.4 48.6 72.1 66.7 15.3 70.5 61.7 75.4 34.4 71.6 34.4 62.3 38.8 69.4 68.9 48.6 N/A 53.6 57.4 54.6 61.2 41.5 39.9 41 58.5 66 74.7 74 71.3 N/A 60.7 78 70.7 42 75.3 N/A N/A N/A N/A N/A 72.7 77.3 76 79.3 58 76.7 N/A 66 73.3 53.3 34.7 N/A 82 44 66 N/A 31.3 N/A N/A 56.7 N/A 64.7 44 65.3 55.3 N/A N/A 59.3 50 66 42.7 38.7 29.3 39.3 56 July 8, 2004 PANAMA BELIZE SAO TOME AND PRINCIPE INDIA SWAZILAND LESOTHO EGYPT SYRIA NEPAL MALI LEBANON ROMANIA ETHIOPIA IRAN TURKEY DOMINICAN REPUBLIC GHANA CHINA KIRIBATI MICRONESIA TONGA VANUATU NICARAGUA JAMAICA COLOMBIA GUYANA PHILIPPINES TIMOR, EAST EL SALVADOR GABON GUINEA RWANDA BOSNIA-HERZEGOVINA BENIN GUINEA-BISSAU VIETNAM TOGO YEMEN ALGERIA GUATEMALA ARMENIA PAKISTAN MACEDONIA COMOROS DJIBOUTI ARGENTINA HONDURAS BELARUS YUGOSLAVIA SIERRA LEONE 51 50 50 49.5 49 48.5 47.9 47.4 46.9 46.4 45.9 45.4 44.8 44.3 43.8 43.3 42.8 42.3 40.2 40.2 40.2 40.2 39.7 39.2 38.7 38.1 37.6 37.1 36.6 36.1 35.6 35.1 34.5 34 33.5 33 32.5 32 31.4 30.9 30.4 29.9 29.4 28.4 28.4 27.8 27.3 26.8 26.3 25.8 Page 40 of 49 45.1 62.5 63 52.7 48.9 63 54.3 23.9 40.2 35.9 36.4 38 57.1 32.6 47.8 47.3 40.8 46.7 33.2 48.9 48.9 48.9 17.4 53.3 39.7 43.5 37.5 N/A 53.8 25.5 41.3 61.4 37 48.9 42.4 23.4 28.8 26.1 29.9 29.3 22.8 27.2 38.6 33.2 12.5 44.6 28.3 57.6 9.8 22.3 54.1 48.6 15.8 60.1 59 66.1 56.3 31.7 30.1 31.1 47 44.3 56.8 27.9 65.6 37.7 43.2 57.9 34.4 48.6 48.6 48.6 25.7 55.7 30.6 55.2 45.9 N/A 47.5 11.5 14.8 34.4 45.4 19.7 32.2 28.4 42.6 32.8 25.1 23.5 23 20.2 48.1 15.8 15.8 59.6 21.9 29.5 8.2 22.4 33.3 N/A N/A 43.3 N/A N/A 62.7 28.7 48 44 52 51.3 12.7 23.3 61.3 40.7 36 58.7 N/A N/A N/A N/A 52.7 40.7 37.3 44 38 N/A 25.3 4.7 66 N/A N/A N/A 12.7 30.7 12.7 49.3 40 18 30 15.3 10.7 N/A N/A 54 17.3 20 20.7 0.7 July 8, 2004 BOLIVIA LIBYA GAMBIA KYRGYZ REPUBLIC ALBANIA COTE D'IVOIRE SOLOMON ISLANDS MOLDOVA RUSSIA PAPUA NEW GUINEA CAMBODIA MALAWI UGANDA VENEZUELA CONGO UKRAINE ZAMBIA LIBERIA WEST BANK/GAZA TANZANIA MOZAMBIQUE ECUADOR BURUNDI CENTRAL AFRICAN REPUBLIC CHAD GEORGIA UZBEKISTAN KENYA KAZAKHSTAN TAJIKISTAN AZERBAIJAN SUDAN CAMEROON NIGER BANGLADESH ANGOLA INDONESIA ZIMBABWE KOREA, NORTH SOMALIA TURKMENISTAN PARAGUAY LAOS NIGERIA AFGHANISTAN MYANMAR CONGO, DEM. REP. IRAQ HAITI EQUATORIAL GUINEA 25.3 24.7 24.2 23.7 23.2 22.7 22.2 21.6 21.1 20.6 20.1 19.6 19.1 18.6 18 17.5 17 16.5 16 15.5 14.9 14.4 12.9 12.9 12.9 12.4 11.9 11.3 10.8 10.3 9.8 9.3 8.8 8.2 7.7 7.2 6.7 6.2 5.7 5.2 4.6 4.1 3.6 3.1 2.6 2.1 1.5 1 0.5 0 27.7 15.2 56 20.1 32.1 31.5 48.9 19.6 10.3 8.2 35.3 48.4 18.5 31 16.3 14.1 20.7 3.8 80.4 12 39.1 13.6 2.7 12.5 33.2 24.5 21.7 9.2 19 4.9 6.5 6 7.6 16.8 30.4 2.2 8.7 15.8 14.7 0.5 5.4 10.9 17.9 7.1 1.1 3.3 1.6 4.3 11.4 0 42.1 10.9 40.4 26.2 9.8 44.8 34.4 38.3 26.8 24 2.7 39.3 29 21.3 7.1 12 33.3 0.5 77.6 8.7 18.6 19.1 15.8 34.4 14.2 27.3 7.7 10.4 13.1 3.8 5.5 20.8 4.4 12.6 43.7 4.9 6.6 60.7 33.9 0.5 3.3 9.3 24.6 6 N/A 2.2 0 1.6 13.7 15.8 Source: World Bank’s Governance Databank, accessible at http://www.worldbank.org/wbi/governance/capacitybuild Page 41 of 49 22 21.3 66 24.7 60 72 N/A 50.7 27.3 48.7 18.7 12 32 28 24 26.7 16 0.7 N/A 9.3 32.7 26 N/A N/A N/A 8 11.3 8.7 22.7 2.7 16.7 7.3 6.7 44 36.7 10 35.3 54.7 44 0.7 3.3 34 18.7 5.3 N/A 6 0 4 12.7 N/A July 8, 2004 Table 3: Cross-Country Variation in Deposit-Insurance Design Features DEPOSIT INSURANCE SYSTEMS Date Enacted/ Revised Membership Administration Funding Premium or Assessment Base Annual Premium Coverage Limit Foreign Currency Interbank Deposits Source of Funding compulsory=1 joint=2 funded=1 yes=1 yes=1 voluntary=0 private=3 unfunded= 0 no=0 no=0 0 = Banks Only 1= Banks & Gov. 2= Government Only $5,336 0 1 1 $3,557 0 1 1 $3,557 0 1 1 $3,557 0 1 1 $3,557 0 1 1 $5,336 $1,750 0 1 1 1 1 1 official=1 % of base in ecu (euros) or U.S. dollars Africa Cameroon Central African Rep. Chad Congo Equatorial Guinea 1999 1999 1999 1999 1999 0 0 0 0 0 2 2 2 2 2 1 deposits and nonperforming loans 1 deposits and nonperforming loans 1 deposits and nonperforming loans 1 deposits and nonperforming loans 1 deposits and nonperforming loans 0.15% of deposits + 0.5% of npls 0.15% of deposits + 0.5% of npls 0.15% of deposits + 0.5% of npls 0.15% of deposits + 0.5% of npls 0.15% of deposits + 0.5% of npls 0.15% of deposits + 0.5% of npls 0.15 Gabon Kenya 1999 1985 0 1 2 1 1 1 deposits and nonperforming loans deposits Nigeria 1988 1 1 1 deposits 0.9375 $588 / $2435 0 1 1 Tanzania 1994 1 3 1 deposits 0.1 $376 0 0 1 Page 42 of 49 July 8, 2004 Uganda 1994 1 1 1 deposits 0.2 $2,310 0 0 1 Date Enacted/ Revised Membership Administration Funding Premium or Assessment Base Annual Premium Coverage Limit Foreign Currency Interbank Deposits Source of Funding Asia Bangladesh India 1984 1961 1 1 1 1 1 1 deposits deposits 0.005 0.005 0 1 0 0 1 1 South Korea 1996 1 1 1 deposits 0 0 1 Marshall Islands 1975 0 1 1 deposits $100,000 1 1 0 Micronesia 1963 0 1 1 deposits 0.05 risk-based 0.00 to 0.27 risk-based 0.00 to 0.28 $2,123 $2,355 $14,600 but in full until the year 2000 $100,000 1 1 0 Philippines Sri Lanka 1963 1987 1 0 1 1 1 1 0.2 0.15 $2,375 $1,470 1 0 1 0 1 1 Taiwan Vietnam 1985 2000 0 1 1 deposits deposits insured deposits 0.015 $38,500 0 0 1 n.a. n.a. 1 n.a. 2000 n.a. n.a. 0 1 1 1 deposits n.a. 0.5% until July 2001, then changed to 0.3% 2764 n.a. n.a. 1 DEPOSIT INSURANCE SYSTEMS Transitional Socialist Economies Albania Belarus BosniaHerzegovina 2002 1998 Page 43 of 49 July 8, 2004 Date Enacted/ Revised Membership Administration Funding Bulgaria 1995 1 2 1 Croatia 1997 1 2 Czech Rep. 1994 1 Estonia 1998 Hungary Premium or Assessment Base Annual Premium risk based to 0.5 1 insured deposits insured deposits 1 1 insured deposits 0.8 commercial banks: 0.5, savings banks 0.1 1 2 1 1 2 1 0.5 (max) risk based to 0.3 Kazakstan 1993 1999/ 2003 deposits until 2002 insured deposits 1 1 1 Latvia 1998 1 1 1 Lithuania 1996 1 1 1 n.a. insured deposits insured deposits Macedonia 1996 0 2 1 insured deposits 1.5 1.5, riskbased 1% to 5% not more than 0.4 risk-based 0.3 to 0.6 0.1 to 0.3 for banks DEPOSIT INSURANCE SYSTEMS Poland 1995 1 1 1 Romania Russia Serbia and Montenegro Slovak Republic Slovenia 1996 2003 1 2 1 deposits, also risk-adjusted assets insured deposits 1 2 1 insured deposits 1% 0.3 Coverage Limit Foreign Currency Interbank Deposits Source of Funding $1,784 1 0 1 $15,300 1 0 1 0 0 1 1 0 1 1 0 1 1 n.a. 1 1 0 1 1 0 1 1 0 1 1 0 1 $3,600 1 0 1 $7,900 1 0 1 coinsurance to 11756 coinsurance 90% of 1383, but ecu in 2010 ecu 44165 or $4565 2599 $830 intil year 2000 $6250 then coinsurance coinsurance 75% to $183 ecu 1000, then 90% coinsurance for the next ecu 4000 2001 1996 2003 Page 44 of 49 July 8, 2004 DEPOSIT INSURANCE SYSTEMS Date Enacted/ Revised Membership Administration Funding Premium or Assessment Base Annual Premium Coverage Limit Foreign Currency Interbank Deposits Source of Funding $250 1 0 1 1998 1 1 1 total deposits 0.5 plus special charges 1993 2000 2000 1 2 0 deposits ex post $5,640 1 0 0 1967 n.a. 1 n.a. 2 n.a. 1 n.a. credit accounts n.a. 0.05 n.a. 0 n.a. 1 n.a. 1 Oman 1995 1 1 1 0 1 1983 1 1 1 0.02 risk-based 1.0 to 1.2 1 Turkey deposits insured savings deposits n.a. $3,300 coinsurance 75% to $52,630 in full 1 0 1 risk-based, 0.36 to 0.72 30,000 1 0 0 120 of 1% 40,816 0 0 0 $17,000 demand deposits in full and 90% coinsurance to UF 120 of $3,600 for savings deposits 1 0 0 1 0 2 Ukraine Middle East Bahrain Cyprus Jordan Kuwait Lebanon Latin America and the Carribean Argentina 1971, 1979, 1995 Bahamas Bolivia 1 3 1 1,999 1999 1 1 1 insured deposits insured deposits Brazil 1995 1 3 1 insured deposits 0.3 Chile 1986 1 1 0 not applicable none Page 45 of 49 July 8, 2004 DEPOSIT INSURANCE SYSTEMS Date Enacted/ Revised Membership Administration Funding Premium or Assessment Base Annual Premium Colombia Dominican Republic 1985 1 1 1 insured deposits 0.3 1962 0 2 1 deposits 0.1875 Ecuador 1999 1 1 1 El Salvador 1999 1 1 1 0.65 risk-based, 0.1 to 0.3 Jamaica 1998 1 1 1 deposits insured deposits insured deposits Mexico Paraguay 1986 2003 1 1 0.1 Foreign Currency Interbank Deposits Source of Funding 0 1 0 1 0 1 1 1 n.a. C 30,000 1 0 1 $5,512 in full except subordinated debt until 2005 1 0 1 1 1 1 Coverage Limit in full until 2001, then coinsurance to $5,500 coinsurance to $13000 in full to year 2001 1 all obligations 0.3 (max) plus 0.7 as needed insured deposits risk-based from 0.65 to 1.45 $21,160 1 0 1 0.2 $7,957 1 1 1 2 $7,309 0 0 1 1 0 1 0.02 + 0.04 $24,075 but coinsurance for businesses ecu 1500, 20000 in year 2000 1 0 1 0.33 max $40,770 0 1 1 Peru Trinidad & Tobago 1992 1 2 1 1986 1 1 1 Venezuela 1985 1 1 1 deposits insured deposits Industrialized Countries Austria 1979 1 3 0 Belgium 1974 1 2 1 Canada 1967 1 1 1 insured deposits insured liabilities insured deposits Page 46 of 49 pro rata, expost July 8, 2004 Date Enacted/ Revised Membership Administration Funding Denmark 1988 1 2 1 Finland 1969 1 3 1 France 1980 1 3 0 DEPOSIT INSURANCE SYSTEMS Germany Gibraltar 1966 1998 1 1 3 2 1 0 insured deposits 1993 1 2 1 Iceland 1985 1 1 1 Ireland 1989 1 1 1 Italy 1991 1987 1 1 1 2 insured deposits insured deposits n.a. insured deposits in commercial banks DIS, risk-assets in other DIS Greece Isle of Man Premium or Assessment Base 0 0 deposits insured deposits EU and EEA, i.e insured deposits Annual Premium Coverage Limit Foreign Currency Interbank Deposits Source of Funding ecu 20000 1 0 1 $29,435 1 0 1 1 0 0 1 0 0 admin .expenses and expost 65387 private: 30% of capital; official coinsurance 90% to ecu 20000 lesser of 90% coinsurance of ecu 20000 decreasing by size: 0.0025 to 1.25 20,000 ECU 1 0 0 1 0 0 1 0 0 0.2 (max) risk based: 0.05 to 0.3 on demand but limited official is 0.03 but can be doubled 0 0.2 ecu 20000 coinsurance 90% to ecu 15000 deposits the greater of 25,000 £ & 0.0125% of deposit base subject to max annual contribution of 250,000 £ the lower of $24,941 or 75% of amount deposited 1 0 0 protected funds adjusted for size and risk risk adjusted expost 0.4 to 0.8 $125,000 1 0 1 Page 47 of 49 0.15 1 July 8, 2004 DEPOSIT INSURANCE SYSTEMS Date Enacted/ Revised Membership Administration Funding Premium or Assessment Base Annual Premium 0.0048 + 0.036 1 2 1 Liechtenstein 1971 1992/2 003 insured deposits 1 1 1 n.a. n.a. Luxembourg Malta Netherlands 1989 2003 1979 1 3 0 insured deposits ex post 1 1 0 Norway 1961 1 3 1 case by case risk-weighted assets and total deposits expost 0.005 assets 0.01 deposits risk-based 0.08 to 0.12 + more in emergencies Japan Portugal 1992 1 1 1 insured deposits Spain 1977 1 2 1 insured deposits Sweden 1996 1 1 1 Switzerland 1984 0 3 0 insured deposits balance sheet items United Kingdom 1982 1 3 0 insured deposits United States 1934 1 1 1 domestic deposits max. of 0.2 risk-based, 0.5 first, 0.1 later on demand on demand risk-based, 0.00 to 0.27 Foreign Currency Interbank Deposits Source of Funding 0 0 1 n.a. coinsurance 90% to ecu 15000 thru 1999, then to ecu 20000 n.a. n.a. 0 1 0 0 ecu 20000 1 0 1 $260,800 ecu 15000, coinsurance to ecu 45000 ecu 15000 through 1999, then ecu 20000 1 0 1 1 0 1 1 0 1 1 0 1 $19,700 larger of 90% coinsurance to $33,333 or ecu 22,222 0 0 0 1 0 0 $100,000 1 1 1 Coverage Limit $71000, but in full in recent crisis ecu 28663 $31412 Source: Demirgüç-Kunt and Sobaci (2001), as updated by Luc Laeven of the World Bank through February 6, 2004. Note: Blank spaces and n.a. indicates a detail of the deposit-insurance scheme that either has not yet been determined or has not yet been verified by World Bank personnel. See Demirgüç-Kunt and Sobaci (2001) for qualifications and additional explanation. Page 48 of 49 July 8, 2004 Table 4: 25 Highest-Ranking Stock Exchanges on Market Integrity and Market Efficiency Market Deustche Boerse-Xetra (electronic) Integrity Efficiency 4 3 10 1 Stockholmborson 5 7 Toronto Stock Exchange 7 5 Helsinki Stock Exchange 3 11 11 4 Deustche Boerse-Frankfurt 1 14 Copenhagen Stock Exchange 8 12 Euronext Paris 19 2 London Stock Exchange 14 8 6 16 Tokyo Stock Exchange 17 6 Cyprus Stock Exchange 2 23 Hong Kong Stock Exchange 16 10 Australian Stock Exchange 15 13 Singapore Stock Exchange 13 17 9 22 Taiwan Stock Exchange 22 9 NASDAQ Stock Market 20 15 Philippines Stock Exchange 12 25 Oslo Bors 18 20 Istanbul Stock Exchange 21 19 Kuala Lumpur Stock Exchange 23 18 American Stock Exchange 25 21 Jakarta Stock Exchange 24 24 Correlation 0.226 New York Stock Exchange Borsa Italia New Zealand Stock Exchange Cairo & Alexandria Exchanges Source: Siow and Aitken (2003), p.20. Page 49 of 49
© Copyright 2026 Paperzz