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Introduction: What is the countercyclical capital buffer?
The countercyclical capital buffer (“CCyB”) is a requirement that aims to promote a sustainable provision of credit to the economy by making the banking system more resilient to cyclical risks and loss. The CCyB aims to counter cycles in the financial system. The CCyB increases the regulatory capital requirements in times of economic growth as an additional buffer that is in place to absorb losses whenever systemic risks are increasing.
In contrast when there is an economic downturn and the financial system is experiencing times of stress, the release of the CCyB aims to limit the potential that regulatory capital requirements act as an impediment to the supply of credit to the economy. The objective is that this buffer will assist credit institutions by maintaining the supply of credit to the economy and dampen the downswing of the financial cycle. On the other hand the CCyB can also help stifle excessive credit growth during the upswing of the financial cycle.
The Basel Committee on Banking Supervision (“BCBS”) recommended the CCyB as part of the many changes made to the global regulatory framework as a direct result of the financial crisis of the mid-to-late 2000s. The CCyB was enacted across the European Banking system since 2016 under the Capital Requirements Directive (“CRD”) IV. In 2019 it was amended in line with CRD V, which was transposed into Irish law in 2020 (Statutory Instrument No. 710/2020). It does not only apply to the traditional banking sector but also applied to MiFID investment firms that are subject to the Capital Requirements Regulation.
Setting the Countercyclical Capital Buffer?
As the Central Bank of Ireland (“CBI”) is the supervisory and regulatory authority in Ireland, it is responsible for setting the national rate of CCyB. The European Central Bank (“ECB”) has a leading supervisory role over significant banks in the EU as part of the Single Supervisory Mechanism (“SSM”). In the context of the SSM, the ECB assesses the CCyB decisions of national designated authorities - in the case of Ireland this is the CBI - and if necessary has the power to set a higher rate. The rate is reviewed every 3 months to make sure it is at the appropriate level given macroeconomic circumstances.
Raising the Countercyclical Capital Buffer
The CBI announced in August 2022 that the countercyclical capital buffer (“CCyB”) rate on Irish exposures would remain at 0 per cent until 15th June 2023 when it will then rise to 0.5 per cent. The move is seen as a step in a gradual build-up of the CCyB to 1.5 per cent.
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