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Countercyclical Capital Buffer in the Election Year

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To avoid speculation about the state of banks and the economy in the election year, there are no more capital adjustments.

Bank capital should be accumulated when cyclical systemic risk is judged to be increasing, creating buffers that increase the resilience of the banking sector during periods of stress when losses materialise. Since the decision on the formation of equity capital is not left to the banks themselves, but is controlled by the German Federal Financial Supervisory Authority (BaFin), the decisions of BaFin are of high political importance and symbolism.

The countercyclical capital buffer (CCyB) is set every quarter by BaFin which takes into account recommendations of the AFS Financial Stability Committee and the European Systemic Risk Committee (ESRB) when making its decision. The CCyB is part of a set of macroprudential instruments, designed to help counter pro-cyclicality in the financial system.

Unfortunately, these measures themselves have a pro-cyclical effect. The capital requirements and their changes are themselves signals for the market. Exaggerated reactions on the part of market participants are possible, both in the event of easing as well as increased capital requirements.

In response to the corona pandemic, BaFin lowered the CCyB from 0.25 percent to 0 percent in April 2020 and has kept it there ever since. The amount BaFin will set the countercyclical capital buffer after the corona pandemic will largely depend on how the cyclical vulnerabilities and risks in the banking sector develop, writes BaFin: “It is currently not foreseeable when the pandemic will be over.”

In contrast, it is possible to predict when the general election in Germany will take place. The Federal Ministry of Finance is responsible for BaFin. Although being member of only the third strongest party in the German Bundestag, the Federal Minister of Finance is entering the election campaign as a candidate for Chancellor and the top candidate of the Social Democratic Party.

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BaFin’s decision shall help maintain the supply of credit and dampen the downswing of the financial cycle. The CCyB can also help dampen excessive credit growth during the upswing of the financial cycle. BaFin’s decision may therefore not reflect economic realities, but rather the need to keep the issue of the fragility of the economy and the vulnerability of banks out of the election campaign. Normally a quarterly review of the decision would be undertaken.