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The global financial crisis has made us re-evaluate many aspects of financial regulation. Frank, blunt and constructive discussions between industry and government are an important part of designing a new system that works for all.

The different needs of different countries

The global financial crisis and the recession that followed it have signaled the beginning of a new global era. The global economy has been thrown into turmoil, and each economy faces a unique set of challenges. As early as January 2011 the update to the IMF’s World Economic Outlook, noted that while economic conditions were improving across the globe, the return to growth was then, and continues to be, uneven, taking the form of a two-speed recovery.

There is subdued economic growth and high unemployment in advanced economies such as the United States, United Kingdom, France and Japan, in contrast to buoyant economic growth in emerging economies such as China, India and Brazil, which face the risks of overheating and rising inflation.

Many developed economies are unable to achieve meaningful growth; several are struggling to reign in their national budgets and contain sovereign debt; and many are still seeking to constrain private financial sector activity. In many countries, financial sector’s activity grew too fast relative to the underlying real economy.

In contrast, one of the greatest challenges facing economies in Africa for example, is how to increase financial intermediation in order to finance infrastructure backlogs. A 2008 report by the African Infrastructure Country Diagnostic (AICD), which is a World Bank project, concluded that for the foreseeable future Africa would only be marginally above the level of investment required to maintain and operate its existing infrastructure. The African Development Bank estimates that a shortage of roads, housing, water, sanitation and particularly electricity, already reduces sub-Saharan Africa’s output by some 40 per cent.

Given the nature of a majority of these infrastructure investments, they will rely heavily on public funding. Government expenditure is however; limited by how much tax revenue can be collected without hurting economic growth, and by how much debt can be borrowed. Across the globe, governments’ revenue collection and ability to borrow are constrained by weak economic conditions, and given the size of the infrastructure deficit in many developing countries these sources would likely prove inadequate in any event. There is thus limited capacity for governments to pay for everything that is needed.

This creates significant opportunities for the private sector, particularly the financial sector, to play a crucial part in the realization of these infrastructure projects. The financial sector is indispensable to the development of these countries because government cannot meet all infrastructure needs. Governments cannot meet all infrastructure funding needs; therefore there is a role for the financial sector to play in channeling private funds appropriately. In contrast to the developed world, Africa and other developing regions are in dire need of increased, not decreased, financial intermediation. Furthermore, not only do developed and developing countries have differing views on the stability/growth trade-off, they have different policy objectives altogether.

The challenge then for developing countries is to put in place regulations that can achieve an appropriate level of stability, without compromising the financial sector’s ability to meet their unique needs. In contrast the priority for many developed economies is largely to restore stability to their financial systems.

While none truly escaped the recession that followed the 2008 financial meltdown, many developing countries did not experience a financial crisis. In Africa the main transmission mechanism for the crisis was the collapse of export revenues following the decline of world demand for mineral and fossil resources. The conditions that led to the crisis in the developed countries were not as prevalent in many developing countries. It is hard to see how subjecting the financial systems of the developing countries to arduous constraints that are intended to rectify problems that exist in the developed world could be of any significant benefit.

We should be wary of imposing unnecessary additional regulations on countries that came through the crisis relatively unscathed. In particular we should be aware that regulations that are sensible in the developed country context may not be applicable in the developing world. For example: even though debt markets in developing markets have expanded in size and breadth in recent years, their depth is substantially below that of advanced economies. As a result liquidity in those markets is more vulnerable to economic and financial sector developments, including those arising from internationally agreed regulatory reforms. Many of the multilateral initiatives and reforms are already being scrutinized and heavily criticized for their failure to adequately incorporate the emerging market perspective.

Emerging markets and developing economies

International efforts at financial sector reform have rightly been aimed primarily at the developed world – which is, after all, where the global financial crisis originated. However, against this background, it is necessary to ask whether these reforms have adequately taken into account the perspectives of emerging markets and developing economies.

At their most basic, banks and financial markets manage risk, channeling funds from those with excess capital to those with investment opportunities. As a result there will always be a trade-off between stability on the one hand and growth on the other. The most stable financial system would be one that doesn’t do anything at all and therefore doesn’t incur any risk, but it certainly wouldn’t be of any benefit to the economy. Where exactly a country wishes to position itself on the continuum between the sometimes conflicting objectives of absolute stability, and maximum growth will be dependent on the particular challenges that country faces.

It would be hard to justify rules that effectively dictate to countries struggling under the burden of extreme poverty, that because a handful of developed countries got the balance of risk wrong, that everyone should now prioritize stability above all else.

Some have therefore argued for a “two-track” approach, in order to accommodate emerging markets’ perspectives on financial regulation. They have argued that emerging markets should be subject to an entirely different set of rules and standards of financial regulation, separate to those for advanced economies. This is however, not a good idea. Out of all sectors, the financial sector is the most globally integrated, and the smallest difference in regulation amongst countries often creates regulatory arbitrage, leading to problematic behaviour in the system and threatening what should be a level playing field. It would therefore be equally foolhardy to establish a set of rules that would allow a country to forgo any and all stability concerns in the name of growth.

Basel III

In response to the crisis the Basel Committee on Banking Supervision (BCBS) introduced two sets of reforms, known as Basel 2.5 and III respectively, to the international capital framework for banks.

It is heartening to see that the Basel Committee is listening to many of the concerns of emerging and developing economies. Indeed, the Basel Committee on Banking Supervision has proposed several options to mitigate the problems arising from insufficient supplies of high quality liquid assets, (such as allowing banks access to a contractual committed liquidity facility provided by the relevant central bank for a fee), and that both of the liquidity standards are currently subject to an observation period that includes a review clause.

However, it is always necessary to be aware of the possibility that standards that are appropriate for advanced economies, may yield very different results in emerging economies, and it is not always as clear that these concerns are being adequately addressed or even that they are being voiced.

Trade finance which is fundamental to many of these economies is a sector that is heavily impacted by the enhancements to the risk coverage under Basel III. Trade finance continues to play an important role in emerging markets, many of which rely heavily on international trade. The Internal ratings-Based framework in Basel II and the leverage ratio in Basel III have been argued to impose excessively restrictive requirements on an otherwise low risk, short-tenor, self-liquidating activity. While the Basel Committee on Banking Supervision has already reviewed and made adjustments its capital rules as they relate to trade finance, many in the developing economies are concerned that the 100% credit conversion factor that is applied to off-balance sheet items, including trade finance exposures, for Basel III leverage ratio purposes, will increase the cost and reduce the demand for trade finance.

Conclusion

The difficulty that the world faces is this: The challenges and priorities that developed and developing countries face are not the same, the environments in which banks in developed and developing economies operate are not the same, and even pre-crisis the risks that built up in many advanced economies were simply not prevalent in many developing economies, and the role that financial institutions need to fulfil in different countries is not the same. Yet it is necessary to construct a set of rules for the financial sector that is applicable to, and appropriate for, everybody.

The focus has up until now justifiably been on the financial sectors of developed economies. But there is no doubt in my mind that multilateral institutions such as the Basel Committee, G20, FSB and other global bodies, as well as private sector organizations, will need to increasingly be aware of, and focus on solving, the issues that are specific to emerging and developing economies.

ByNhlanhla Nene
Deputy Minister of Finance, Republic of South Africa.