除非监管机构仔细踩踏，批评费用，他们可能会损害一个降低金融体系风险的精细调谐市场。本安全阀是回购协议的市场，或者重新回购，从2008年的低点急剧反弹。通过让银行使用广泛的抵押品允许彼此借用现金，这些抵押品避免任何单一公司狭隘的资产集中，仓库市场的财务震荡不太可能。但分析师和市场参与者担心即将推出的巴塞尔III流动性规则将留下借款人并贷款人危险地依赖监管机构祝福的薄型。“银行而不是监管机构，应该是流动性的法官，”乌玛·科学中心的访问研究员·理查德·科米托斯说，在U.K.的阅读大学。该中心成立于1991年，拥有国际资本市场协会的资金。在金融危机期间，回购市场在担心抵押品迅速但暂时削减交易量的担忧时遭到担忧。据欧洲回购委员会基于苏黎世的ICMA的ARM的ARM，欧洲呼购委员会的ARM的ARM，据欧洲追认委员会的一款位于苏黎世的ACMA的ARM，因此，与前6月相比，欧洲又押金的价值下降了29％。但截至去年12月，市场都通过篮板为34％，恢复了其预测大小，达到62万亿欧元。Now repo faces a new foe in Basel III’s liquidity coverage ratio, which national banking regulators will introduce by 2015. The LCR is one of the most hotly debated rules to emerge from the Basel Committee on Banking Supervision, the international body leading efforts to tighten bank capital and liquidity requirements. The liquidity ratio calls for banks to hold enough “high-quality liquid assets” to match any net cash outflows over a 30-day period. Earlier this year the Basel committee agreed to revisit the LCR, taking note of “specific concerns regarding the pool of high-quality liquid assets,” and to publish any modifications by the end of 2012. But bankers have become increasingly doubtful that the committee will make major changes. Although cash lenders can use assets held as repo collateral to help meet the ratio, the committee deems that equities don’t count as high-quality and liquid assets. The Basel committee and the Federal Reserve System, which will implement Basel III in the U.S., had no comment. The ICMA Center’s Comotto acknowledges the challenge of creating standardized liquidity rules. “My sympathy is with the regulators,” he says. “They face an impossible task.” Repo experts say the new rule will make counterparties more reluctant to lend cash for equities, pushing up the interest rates demanded for such deals, which are currently well below unsecured wholesale funding rates. “We may see cash lenders swapping equities for fixed income because equities cannot count toward their ratio,” says Staffan Ahlner, managing director of global collateral management at Bank of New York Mellon Corp. in London. Given the right safeguards, there’s no objective case for excluding prime equities on liquidity or quality grounds, says David Schraa, Washington-based regulatory counsel at the Institute of International Finance, a trade body for financial institutions. Prime equities — those included in major indexes — were quite liquid during the credit crisis, Schraa notes. The rules encourage banks to favor highly rated government bonds, despite the fact that the euro zone debt crisis has shattered assumptions about the creditworthiness of those securities. “The high-quality liquid definition is too narrow,” Schraa contends. “It will cause excessive concentration in sovereign bonds, which is of questionable wisdom.” Some skeptics go further by asking if regulators should be in the business of setting such standards. Because markets constantly change, “any attempt by the regulators to define a high-quality liquid asset will inevitably be wrong,” says Hugh Carney, senior counsel at the American Bankers Association in Washington. Repo participants have already reacted by shifting more funding into deals with a duration of more than 30 days, says the ICMA Center’s Comotto. This gives them a clearer picture of cash and asset holdings over the period covered by the LCR than would a plethora of shorter contracts. In the year through December 2011, contracts longer than 30 days rose from 25 percent to 36 percent of outstanding repo volume, the European Repo Council reports. But even if short-term deals dwindle, repo volumes will increase over time, predicts Greg Markouizos, head of Citigroup’s London finance desk. Markouizos cites financial institutions’ growing desire to seek safety through collateralized lending. Outside the repo world, what’s the upshot for bank treasuries? “The liquidity charge the treasury department allocates to business lines for holding on to assets that don’t count toward the ratio will inevitably go up,” says David Sunstrum, regulatory affairs specialist at the IIF.
美国律师协会的卡尼警告说，如果监管机构迫使银行持有一定比例的低收益资产，可能会带来意想不到的风险:“在追逐收益的过程中，你会被迫用投资组合中的剩余资产承担更大的风险。”通过抑制一种风险，巴塞尔协议III可能会创造另一种风险。••