Early studies on the effect of holding company affiliation on bank performance yield some curious results (see [9], [11], [12]). Specifically, these studies did not find that holding company affiliation results in changes in capital-asset ratios or bank profitability.

The current regulatory capital standard for banks – the Basle Accord – is a lose/lose proposition. Regulators cannot conclude that a bank with a nominally high regulatory capital ratio has a correspondingly low probability of insolvency. On the other hand, because the Accord often levies a capital charge out of proportion to the true economic risk of a position, banks must engage in “regulatory capital arbitrage” (or exit their low risk business lines). Since such arbitrage is costly, the capital regulations keep banks from maximizing the value of the financial firm. Regulators need to answer three questions: (1) What are the goals of prudential regulation and supervision? (2) How should bank “soundness” be defined and quantified? (3) At what level should a minimum “soundness” standard be set in order to meet the (perhaps conflicting) goals of prudential regulation and supervision? Possible answers to these questions are attempted, then the paper analyzes the two leading proposals for rationalizing the Accord – a “modified-Basle” (or ratings-based) approach and a “full-models” approach.

This paper analyzes the riskiness of credit enhancements offered on securitized pools of commercial and industrial loans. It develops a technique for allocating capital to such credit enhancements, based on setting the expected value of the credit losses in excess of allocated capital equal to the expected value of losses beyond required capital on the original loan pool. The resulting capital allocations are compared with those derived from a more general, bank-wide capital decision-rule, as well as newly published agency proposals regarding capital for credit enhancements.