Experience has taught me that every decision-making body needs a sheltered area away from the public where things may be imperfectly stated and seemingly irrefutable truths may be called into question. If such a sheltered domain is abolished, this will, in my view, have a negative effect on negotiating practices and the quality of decisions. Optimisation of ex ante transparency is, by its very nature, more critical. A clear and open commitment to a monetary policy goal is of central importance. Thus the central bank must state explicitly what it means by price stability, and it must also communicate how it assesses the long-term development of the target figure. Both elements serve to enhance - or even facilitate - the predictability of its policy and to reduce uncertainties. Conversely, it must be accepted in monetary policy that the precise way to the goal is fraught with considerable uncertainties and that therefore too much ex ante transparency can easily become counterproductive. In the context of our concept this applies in particular to the interest rate path to be followed. If a target range for the money market rate is published at a particular point in time, this steering intention remains valid “for the time being”. It is quite understandable that market participants should wish to know more: how long the interest rate target is to remain valid, and what interest rate steps are likely to follow. What they would prefer above all else is information on the planned interest rate path for several quarters.
So summing up, as with the Concordat, a country’s prudential regime could be judged as complying with the Core Principles even though it does not ensure that the distribution of capital across a banking group leaves its individual entities adequately capitalised. Finally, the Capital Accord7 – now in its third incarnation – applies to banking groups on a consolidated basis (or at a sub-consolidated basis for different tiers of a group). The Accord gives jurisdictions an option to apply capital requirements on a solo-basis to individual legal entities as an alternative to applying the requirements to consolidated groups of legal entities8, but there is no requirement to exercise that option. Again, then, there is no hard rule that ensures a sensible distribution of capital across individual entities within a group. If you cannot fit all that together, you can be excused! Here’s an attempt to make sense of it. There appears to be a disconnect between the Concordat (consolidated supervision); the Core Principles (both consolidated and solo perspective recognised as important, but no mandated solo capital requirements); and the Capital Accord (consolidated and sub-consolidated, with solo subject to deductions allowed but not required). Or, put another way, each of the three BCBS documents does an important job but none of them addresses the distribution of capital across a group. That is a gap. Do not assume that this is a theoretical point. It is one reason there have been attempts by regulators to shore up the financial soundness of local subsidiaries during the crisis.