Releasing the liquidity standard in times of stress could communicate authorities’ views on banks’ forward-looking liquidity resilience and  Page 11  appropriate usage of liquidity buffers, supporting financial stability and market confidence. But while the principle may be similar, in practice there may be bespoke challenges to releasing liquidity standards via the LCR. As I discussed earlier, it is an incomplete, static metric, which can mean different things for banks’ liquidity in different scenarios. But it is the existing regulatory standard. So in considering how to release liquidity standards, we would need to be mindful of the challenges posed by the nature of the LCR metric, and that in some stresses releasing the LCR may not be the right policy. These challenges motivate broader consideration of whether and how we might improve the LCR metric itself to make it less cyclical and volatile. For example, we could explore a less cyclical approach to calibrating the potential liquidity outflows from margin calls stemming from an increase in market volatility during a time of stress. There may also be other options for improving usability that worth exploring, but there are unlikely to be any silver bullets – we will need to be mindful of the potential issues and inherent trade-offs that different options entail.
Chiarotti, Mathur, and Rajan (forthcoming), ‘Assessing Basel III: Impact of automatic distribution restrictions on regulatory capital and bank lending’, Bank of England Staff Working Paper. The authors apply a difference-in-difference approach to aggregate bank balance sheet data and granular loan-level data on syndicated lending to corporates. The latter allows the authors to control for important unobservable features in the aggregate data such as changes in credit demand and in borrowers’ risk. 12. To ensure that banks which have different concerns about MDAs nevertheless have similar probabilities of triggering the restrictions, the analysis considers also the banks’ capital surpluses to regulatory buffers. 13. During the Covid-19 pandemic, several jurisdictions including ECB/SSM Fed and BoE recommended banks to restrict or suspend dividends and share buybacks, but not AT1 coupons (see Svoronos and Vrbaski (2020) (2021)  and BCBC  ). 14. During the pandemic AT1 coupons were excluded from the scope of the blanket distributions restrictions that many jurisdictions imposed, so unlike for dividends banks’ ability to pay AT1 coupons was still linked to automatic distribution restrictions thresholds. 15. A somewhat extreme version of broad-based capital conservation – reflecting the unusual and extreme level of economic and market uncertainty at the time - was implemented during Covid-19 when PRA recommended the major UK deposit takers to cancel dividend payments, share buybacks and cash bonuses. 16.