افزایش نظم و انضباط بازار در بانکداری: نقش بدهی های فرعی در اصلاح مقررات مالی

The increasing complexity of large financial firms has led to consideration of alternative regulatory structures. This has intensified recently because of the worldwide turmoil in financial markets. One important consideration has been to increase reliance on market discipline—most notably, increased reliance on subordinated debt (sub-debt) in the bank capital structure to discipline banks’ risk taking. This proposal, however, has been subject to criticism related to the quality of the signal generated in current sub-debt markets. We argue that previous studies evaluating the potential usefulness of sub-debt proposals have evaluated sub-debt spreads in a very different environment from that characterized by a fully implemented sub-debt program, where the market will become deeper, issuance will be more frequent, debt will be viewed as a more viable means to raise capital, bond dealers will be less reluctant to publicly disclose more details on debt transactions, and generally, the market will be more closely followed. As a test to see how the quality of the signal may change, we evaluate the risk-spread relationship—accounting for the enhanced liquidity and market transparency surrounding new debt issues. Our empirical results indicate a superior risk-spread relationship surrounding the period of new debt issuance due

“When pursuing regulatory objectives through the application of market discipline, regulators must consider the nature of the incentives faced by different types of stakeholders… equity holders may “gamble for resurrection” by encouraging rather than discouraging excessive risk-taking… holders of uninsured debt don’t benefit if the bank's stock price rises when undue risk-taking pays off. Consequently, they focus on what bank managers are doing to avoid default… The incentive to monitor risk-taking is particularly keen for holders of subordinated debt, as they are last in line in the event of failure. Because debt holders are sensitive to changes in the probability of financial distress, risk-taking by a bank raises its cost of funding in credit markets, and that connection creates an incentive for banks to control risks. Moreover, the price of a bank's debt provides useful information about the bank's riskiness. With that information, the bank's counterparties and supervisors can take steps of their own to ensure that the bank is operating safely…” [Bernanke, 2007].

There have recently been a number of banking reform proposals to increase the role of subordinated debt in the bank capital requirement in order to increase market discipline on large and complex banking organizations (LCBOs). There has also been a growing consensus that bank risk could be more effectively regulated if market information and market discipline were more fully incorporated into the bank supervisory process. Effective market discipline will enhance the quality of market signals, which can be used by bank supervisors for on-site as well as off-site monitoring efforts to identify problem institutions. This could help regulators allocate supervisory resources more efficiently.