Our job is to make sure that both moves are properly managed and capitalised in the firms we regulate. This is much easier said than done for another type of corporate lending, largely carried out by investment banks. This type of lending is secured against equity holdings of the borrower, often in a related entity – so-called “margin loans”. The first observation about this is that it will often create wrong-way risk because the value of the collateral may well be linked to the credit-worthiness of the borrower, which can cause problems in times of stress even though collateral haircuts tend to be 30-50%. Largely due to this, we estimate that banks in London lost more than € in a single deal in 2017. But the broader observation is that this type of lending is not well captured by today’s capital framework for banks – in part because it tends to sprawl awkwardly across credit, market and operational risk requirements. I don’t ask you simply to accept this statement at face value – our analysis (presented in anonymised form in Chart 8) of the capital held against one such recent exposure by a range of banks illustrates it well: even allowing for differentiation in terms across firms, this level of variation simply cannot be right.
Before delving into the details, I’d like to give you a preview of my main points:   First, I would like to discuss capital and the financial crisis, and will suggest that many U.S. financial institutions did not have the quality or quantity of capital needed to withstand the shocks we recently experienced. The focus in Basel III on improving the quantity and quality of capital at financial institutions – particularly systemically important financial institutions – is critically important.   Second, I will suggest that we should be particularly focused on narrow definitions of capital, which are what investors focused on during the financial crisis.   Third, I will suggest that stress tests are an important supervisory tool that should be used for prudential and macroprudential3 supervision as well as for management’s own capital planning efforts. The rapid recapitalization of many financial institutions in the United States greatly benefitted from the attention during supervisory exercises (including stress tests) on the quantity and quality of capital. I will also discuss the evaluation of discretionary capital distributions (such as increasing dividends, and stock buybacks). Capital and the financial crisis I think it is instructive to look at the capital ratios of two of the very large banking organizations that encountered problems and were acquired during the financial crisis. Wachovia was one of the four largest banking organizations in the United States, with total assets in 2008 exceeding $ billion.