【漫步华尔街•第866期】耶伦：危机后美国银行业盈利能力显著改善
文/Janet L. Yellen；编译/袁佳
美国联邦储备理事会(美联储)的一个基本目标是确保美联储是根据不同的金融机构的风险进行监管和监督。正如2007年8月，具有系统重要性的金融机构的倒闭会破坏稳定金融体系和实体经济。最大、最复杂的公司必须比其他公司严格遵守审慎的标准。美联储在建立监管和监督程序中已取得了实质性的进展。我们实施关键标准，旨在限制大型金融机构对金融稳定带来潜在的风险。对于中小银行，我们已经采取措施确保他们不会承受过度的监管负担。展望未来，我们必须继续监控新出现的风险，从危机中得到的一个重要教训是金融稳定的威胁随着时间而变化。
一.加强对大型金融机构的监管
美联储在后危机时代对大型银行的监管要求比对中小型银行严格许多，这与《多德-弗兰克法案》相一致。我们努力减轻大型金融机构对金融稳定所带来的风险。首先，我们旨在使大型金融机构更具弹性以减少他们的失败的可能性。其次，使大型金融机构更好地分解对其他金融体系和经济造成的损失。
（一）弹性
美联储已经为国内外银行机构建立了一套广泛的审慎标准以增大银行机构的弹性。联合联邦存款保险公司(FDIC)和美国货币监理署，我们要求大型银行比2007年8月前有更高的资本要求。采用流动性覆盖比率(LCR)使其具备更大缓冲保护，信用额度防范信贷风险的过度集中，净稳定融资比率要求银行保持最低水平的稳定资金水平。我们创建了大型机构监管协调委员会(LISCC)加强对大型金融机构的监管。引入对大型银行机构的资本压力测试是一个标志性创新。金融危机证明，对于良性的环境中的足够的资本缓冲可能会远远低于压力时期的充足水平。因此，美联储对总资产在500亿美元及以上的银行机构进行监管压力测试，以确定他们是否能在经济和市场动荡时期有合适的资本总量和资本规划框架。大型银行机构应保持足够的资本缓冲，在承受重大压力时更具弹性。危机的出现强化了监管机构和监管者需要不断地重新审视他们的工具有效性的意识并根据需要进行相应调整。因此，我们在去年推出了一个综合资本分析和评估审查计划(CCAR)，目的是在全面的基础上重新评估压力测试效果。
综合CCAR评估是为了整合CCAR和资本监管框架。更具体地说，现在的资本监管规则包括公司特有的、具有全球系统重要性的银行(G-SIB)的基于风险的资本附加费、统一的资本保护缓冲。2008年以来，八家最大的银行所有者权益已经翻倍，达到8000亿美元。在过去五年，大型银行增加了高达1万亿美元的高质量资产。银行对于短期资金的依赖程度较以往有所降低，我们也在考虑对用于CCAR压力测试的假设进行某些修改。很大一部分原因是由于资本监管规则中资本保护缓冲的出现，当资本充足率低于缓冲要求时会限制了金融机构的资本配置的能力。
（二）可分解性
在危机期间，对于系统重要性的金融机构破产导致系统性危机的担忧会使政府采取非常规的行为。这种恐惧是有据可依的：雷曼兄弟的破产大大加重了危机。《多德-弗兰克法案》的165(d)要求大型银行订立生前遗嘱，帮助这些企业以有序的方式进行破产清算。《多德-弗兰克法案》的第二章中有序清算机构的功能可以减少公司决议的系统性影响。当有序清算基金蒙受损失时，这些损失将由主要金融机构的评估覆盖，不会转嫁给纳税人。
美联储最近提出了重要的新规定以增加有序解决G-SIBs的前景。去年10月，美联储提出要求美国八大G-SIBs满足总吸收损失的能力和长期债务的需求。今年5月，美联储提出第二个规则将加强G-SIBs合格的金融合约，包括衍生品和回购协议(回购)的限制防止快速、大规模解除这些合同。美联储与联邦存款保险公司也试图通过遗嘱增加G-SIB可分解性。
二.对中型及地区银行机构的监管
在监督资产超过500亿美元的大型金融机构不包括LISCC程序的过程中，美联储会密切关注以确保金融机构管理有方，保持适当的资本化，准备抵御潜在的不利的商业环境。对于拥有总资产在100亿美元和500亿美元之间的区域银行组织监督和监管要有针对性。区域银行业组织必须符合资本规则，但不受监管压力测试或CCAR，区域银行组织执行自己的压力测试。很多银行机构将其资产和活动集中在银行子公司，我们与其他美国银行机构密切协调监督活动，关注母公司及其服务于子公司的能力。
三.对社区银行的监管
社区银行在很多地区发挥至关重要的作用。经验告诉我们一个规则并不适合所有的机构。有效地促进金融机构安全与稳健经营，并遵守适用消费者保护法，规则需要有针对性，根据不同类型的社区银行等机构而进行监管和监督。
美联储监督800多个社区银行和4000多家控股小型存款机构的公司。我们遵循风险集中的原则，旨在检查高风险的业务，确保银行保持适当的规模和复杂性的风险管理能力。美联储和其他银行监管机构目前在完成经济增长的过程中减少文书工作和监管法案(EGRPRA)审查。此外，银行机构最近发布了一个关于社区银行的新提议。提议将消除某些数据项和减少许多其他数据项的报告频率。
四.当前的形势
为了应对监管和监督压力，美国的GSIBs机构的金融状况自危机以来显著加强。具有全球性系统重要性的最大8家银行所拥有的普通股权资本金额已增加了近8000亿美元，即普通股资本已增长一倍以上。此外，这些公司通常已经具有更稳定的资金头寸。在过去5年，最大的银行机构增持优质流动性资产超过1万亿美元，大大减少对于经营资金的依赖。减少运营风险是危机后的监管和监督的核心目标。
我们发现大型地区性银行资本充足。大型银行和地区银行机构的盈利能力有了显著的提高；社区银行“健康得多了”，美国的银行业超过95%实现盈利；危机期间流失的资本“大体得到了补偿”；贷款增速加快，现在问题贷款水平相当于金融危机初期的水平。
总之，在后危机时代我们的监管和监督方法应当具有前瞻性和针对性，美联储对最大型银行的要求更严格，对小型、风险小的银行相对宽容，会根据实际情况降低对它们的某些监管要求。预计短期内会进一步调整我国的监管和监督框架。
但是我们的工作还未完成，我们必须密切监控我们所作的监管变革的影响，并警惕威胁到金融稳定的新风险的出现。随时准备调整我们的监管方法，以确保金融体系依然强劲而稳定，保护和支持实体经济。（完）
附英文原文：
One of the Federal Reserve’s fundamental goals is to make sure that our regulatory and supervisory program is tailored to the risk that different financial institutions pose to the system as a whole. As we saw in 2007–08， the failure of systemically important financial institutions can destabilize the financial system and undermine the real economy. The largest， most complicated firms must therefore be subject to prudential standards that are more stringent than the standards that apply to other firms. Small and medium-sized banking organizations--whose failure would generally pose much less risk to the system--should be subject to standards that are materially less stringent.
The Federal Reserve has made substantial progress in building a regulatory and supervisory program that is consistent with these principles. We have implemented key standards designed to limit the financial stability risks posed by the largest， most complex banking firms. We continue to work on some remaining standards and to assess the adequacy of this package of measures. With respect to small and medium-sized banks， we must build on the steps we have already taken to ensure that they do not face undue regulatory burdens. Looking forward， we must continue to monitor for the emergence of new risks， since another key lesson from the crisis is that financial stability threats change over time.
Strengthening the Regulation and Supervision of the Largest Financial Institutions
The Federal Reserve’s post-crisis efforts to strengthen its regulation and supervision of large banks have focused on promoting the safety and soundness of these firms and on limiting the adverse effects that their distress or failure could have on the financial system and the broader economy. This orientation is consistent with section 165 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act)， which directs the Board to impose enhanced prudential standards on large banking organizations “in order to prevent or mitigate risks to financial stability.” Our efforts to mitigate financial stability risks posed by large financial institutions generally fall into one of two categories. First， we aim to make large financial institutions more resilient in order to reduce the likelihood of their failure or distress. And second， we aim to make large financial institutions more resolvable to limit the damage that their failure would have on the rest of the financial system and on the broader economy.
Resiliency
To increase the resiliency of the largest banking organizations， the Federal Reserve has established a broad set of enhanced prudential standards for large domestic and foreign banking organizations. Together with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency， we have implemented capital rules that require large banking organizations to hold substantially larger amounts of high-quality capital than they were required to hold before the 2007–08 crisis， and we have adopted a liquidity coverage ratio (LCR) that requires these organizations to hold a buffer of high-quality， liquid assets sufficient to meet liquidity outflows during a 30-day period of severe funding stress. We have also proposed single-counterparty credit limits that are designed to guard against the build-up of excessive concentrations of credit risk and， along with the other federal banking agencies， proposed a Net Stable Funding Ratio that would require banks to maintain a minimum level of stable funding relative to the liquidity of their assets over a one-year horizon.
In addition to strengthening the regulation of the largest， most complex financial institutions， we have also transformed our supervision of firms that pose elevated risk to U.S.financial stability through the creation of the Large Institution Supervision Coordinating Committee (LISCC).1 The LISCC is distinguished by several characteristics. First， the LISCC has implemented a centralized， multidisciplinary approach to supervision by bringing together experts from around the Federal Reserve System in the areas of supervision， research， legal counsel， financial markets， and payments systems. Second， major areas of focus for the supervision of firms in the LISCC portfolio are capital and liquidity resiliency under normal and potentially adverse conditions in the future， as well as recovery and resolution preparedness. And third， the LISCC complements traditional， firm-specific supervisory work with annual “horizontal” programs that examine these firms at the same time and on the same set of issues in order to promote better monitoring of trends and consistency of assessments across all of the LISCC firms.
With regard to capital adequacy， the introduction of capital stress testing for large banking organizations has been one of our signature innovations since the financial crisis. As events during the financial crisis demonstrated， capital buffers that seem adequate in a benign environment may turn out to be far less than adequate during periods of stress. For this reason， consistent with the stress-testing mandate in the Dodd-Frank Act， the Federal Reserve conducts supervisory stress tests each year on banking organizations with $50 billion or more in total assets to determine whether they have sufficient capital to continue operations through periods of economic stress and market turbulence， and whether their capital planning frameworks are adequate to their risk profiles. The expectation embodied in our stress testing program that large banking organizations should maintain sufficient capital buffers to withstand a period of significant stress promotes the resilience of those firms and of the financial system more generally.
While our stress testing program has been successful since it was first introduced in 2009， the crisis reinforced the need for regulators and supervisors to continually revisit the effectiveness of their tools and adjust as needed over time. We therefore launched a review of the Comprehensive Capital Analysis and Review (CCAR) program last year with the aim of reassessing our stress testing practices on a comprehensive basis. As part of this process， we met with a wide range of stakeholders， including academics， analysts， bankers， public interest groups， and others. We are now considering making several changes to our stress testing methodology and process. The leading idea that has emerged from our comprehensive CCAR review is to integrate CCAR with our regulatory capital framework. More specifically， the regulatory capital rules now include a firm-specific， risk-based capital surcharge for each global systemically important bank (G-SIB) and a uniform capital conservation buffer requirement above the regulatory capital minimum for all firms. Under the approach we are considering， the existing capital conservation buffer would be replaced with a risk-sensitive， firm-specific buffer that is sized based on stress test results. Each firm’s buffer requirement would be set equal to the decline in its common equity tier 1 capital ratio in the supervisory stress test. The buffer requirement would be floored at 2.5 percent of risk-weighted assets， the current level of the capital conservation buffer， to avoid any reduction in the stringency of the regulatory capital rules. We call this idea the “stress capital buffer，” and it would effectively move the stress test to the center of our regulatory capital framework.
For the eight U.S. G-SIBs， the move to the stress loss buffer--which would be similar in effect to including the G-SIB capital surcharge in the CCAR post-stress minimum--would result in a significant aggregate increase in capital requirements. Thus， in addition to simplifying the capital framework by integrating CCAR with our regulatory capital rules， the stress loss buffer would advance our macroprudential goal of making G-SIBs more resilient. In contrast， the move to the stress loss buffer approach generally would not entail a toughening of our requirements for the 25 large banking firms that are subject to CCAR but are not G-SIBs. Nor would the move have any impact on community banks or other firms with less than $50 billion in assets.
We are also considering making certain changes to the stress test assumptions used in CCAR. For example， under the current CCAR program， a firm’s capital adequacy is assessed by assuming that the firm continues to make its baseline capital distributions over the stress test’s two-year planning horizon. We are considering changing this conservative assumption， in significant part because of the advent of the capital conservation buffer in the regulatory capital rules， which limits the ability of a firm to make capital distributions when its capital ratios are lower than the buffer requirement. Instead， we are proposing that firms simply add one year of planned dividends to their stress capital buffer requirement in recognition of the fact that firms generally are more reluctant to reduce dividends than share buybacks. On this and other changes to CCAR that we are considering， we will of course seek public input before moving to adopt them.
Resolvability
During the crisis， fears about the systemic consequences that would result from the bankruptcies of systemically important firms motivated extraordinary government actions. The fears proved well-founded: The bankruptcy of Lehman Brothers significantly exacerbated the crisis. To reduce the potential that resolution of a large financial firm in bankruptcy will be disorderly， section 165(d) of the Dodd-Frank Act requires large banking organizations to produce living wills that help these firms prepare to be resolved in an orderly way under the Bankruptcy Code. Although the Bankruptcy Code provides the default legal framework for resolving a failed bank holding company， the Dodd-Frank Act also creates a backup resolution authority that can be used if the resolution of a failed financial company under the Bankruptcy Code would have serious adverse effects on U.S. financial stability. The orderly liquidation authority in Title II of the Dodd-Frank Act has several features that could reduce the systemic impact of a firm’s resolution， including an orderly liquidation fund and provisions to prevent the chaotic unwinding of a firm’s derivatives， securities financing transactions， and other qualified financial contracts. In the unlikely event that the orderly liquidation fund does incur losses， these losses would be covered by assessments on major financial firms and would not be passed on to taxpayers.
The Federal Reserve has recently proposed important new rules to increase the prospects for the orderly resolution of a G-SIB. Last October， the Board proposed to require the eight U.S. G-SIBs to meet total loss-absorbing capacity (TLAC) and long-term debt requirements. The proposal would require these systemically important firms to maintain outstanding a large quantity of long-term debt that could be used to absorb losses and recapitalize the firm in resolution. Because， by definition， the actual equity of a bank will have been substantially depleted--if not totally eliminated--by the time it fails， a separate long-term debt requirement is essential to ensure that the resolution authority has the raw material from which to manufacture new equity in resolution to recapitalize and stabilize the failed firm. For this reason， the proposed long-term debt requirement would more assuredly enhance the prospects for successful resolution--and thereby contribute to solving the too-big-to-fail problem--than would a TLAC requirement on its own. The proposal would also restrict the operations of G-SIB holding companies， so that those legal entities could go through resolution without setting off short-term wholesale funding runs or otherwise jeopardizing financial stability.
In May this year， the Board issued another proposal to make G-SIBs more resolvable. This second proposed rule would impose restrictions on G-SIBs’ qualified financial contracts-- including derivatives and repurchase agreements (repos)--to guard against the rapid， mass unwinding of those contracts during the resolution of a G-SIB. The proposed restrictions are a key step toward G-SIB resolvability because rapidly unwinding these contracts could destabilize the financial system by causing asset fire sales and toppling other firms.
Acting in conjunction with the FDIC， the Board has also sought to increase G-SIB resolvability through the living wills process. In April this year， the Board and the FDIC announced the results of their review of the eight U.S. G-SIBs’ 2015 resolution plans. During this review， the agencies evaluated the plans based on the firms’ capital， liquidity， governance mechanisms， operational capabilities， legal entity rationalization， derivatives and trading activities， and responsiveness to prior agency feedback. The agencies found that five of the GSIBs’ plans fell short of the resolvability standard set by the Dodd-Frank Act and required those firms to fix deficiencies in their plans by October of this year or potentially face more stringent prudential requirements. If the agencies jointly determine that a firm has failed to adequately remedy the noted deficiencies， the agencies may jointly determine that the company or its subsidiaries will be subject to more stringent capital， leverage， or liquidity requirements or to restrictions on the growth， activities， or operations of the firm. The agencies also identified less-severe shortcomings in the plans of all eight U.S. G-SIBs， which are expected to be addressed in the next round of resolution plan submissions， due in July 2017.
The resolution planning process requires firms to demonstrate that they have adequately assessed the challenges that their structure and business activities would pose during resolution and that they have taken action to address those issues. Firms must also confront the resolution consequences of their day-to-day management decisions on a continual basis， particularly those related to structure， business activities， capital and liquidity allocation， and governance. Firms are also expected to create a meaningful set of options for selling operations and business lines to generate resources and to allow for restructuring under stress， including through the sale or winddown of discrete businesses that could further minimize the direct impact of the firm’s distress or failure on the broader financial system. The deficiencies and shortcomings issued in the most recent plan review focus on steps necessary to ensure these objectives are met at each G-SIB on an ongoing basis.
In addition to providing the firms with our feedback on their resolution plans， the agencies took several steps in April to improve the transparency of the resolution planning exercise. These steps included publicly releasing the firm feedback letters， a paper outlining the resolution plan assessment framework and firm determinations， and a document detailing the expectations of the agencies regarding the firms’ 2017 resolution plan submissions. The expectations articulated for the 2017 plan contents build on detailed guidance previously provided to the G-SIBs in 2014 and 2015.
While the five firms that received joint deficiencies are required to fix those deficiencies by October 2016， all of the firms that received agency feedback in April are required to submit a full resolution plan by July 1， 2017. In these plans， firms will be required to address all identified shortcomings， follow all guidance provided by the agencies， and meet all statutory and regulatory requirements for their resolution plans. In meeting these expectations， the actions that firms need to take should be substantially complete by July 2017， as previously communicated by the agencies.
文章来源：美联储官网2016年9月28日（本文仅代表作者观点）
本篇编辑：袁佳
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