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Working Paper
Forward-looking and Incentive-compatible Operational Risk Capital Framework
This paper proposes an alternative framework to set banks? operational risk capital, which allows for forward-looking assessments and limits gaming opportunities by relying on an incentive-compatible mechanism. This approach would improve upon the vulnerability to gaming of the AMA and the lack of risk-sensitivity of BCBS?s new standardized approach for operational risk.
Discussion Paper
Is Operational Risk Regulation Forward-looking and Sensitive to Current Risks?
This article evaluates whether US large bank operational risk capital requirements are forward-looking, sensitive to banks' current exposures, and allow for risk mitigation, and discusses modifications that could bring regulation closer to these goals while also highlighting the potential pitfalls of doing so.
Working Paper
The Information Value of Past Losses in Operational Risk
Operational risk is a substantial source of risk for US banks. Improving the performance of operational risk models allows banks’ management to make more informed risk decisions by better matching economic capital and risk appetite, and allows regulators to enhance their understanding of banks’ operational risk. We show that past operational losses are informative of future losses, even after controlling for a wide range of financial characteristics. We propose that the information provided by past losses results from them capturing hard to quantify factors such as the quality of ...
Working Paper
Cost of Banking for LMI and Minority Communities
We test whether minimum account balances to avoid fees, maintenance fee amounts, and nonsufficient funds charges are systematically different in LMI and majority-minority communities relative to other communities and find that they are generally higher. The minimum account balance to avoid fees on a noninterest checking account is about $45 higher on average in LMI Census tracts than in higher income tracts, and more than $70 higher on average in majority-minority tracts than in majority-white tracts. We investigate potential sources of these differences such as bank business models, ...
Discussion Paper
How to Design Rules for Ex-Post Evaluation
Ex-ante cost-benefit analyses and other impact assessments are now a standard part of the rulemaking process. Yet some important effects of regulation are difficult—or impossible—to assess before a rule takes effect. In such cases, ex-post (or retrospective) evaluation, conducted after a rule is in effect, offers an opportunity to measure real-world outcomes that could not reliably be predicted in advance.