Abstract
By requiring forward-looking provisions based on economic forecasts, CECL changed how minimum capital requirements constrain lending, yet minimum capital requirements have not been adjusted in response. This paper studies optimal capital regulation under ILM and CECL and shows that the two regimes call for qualitatively different designs. With time-varying requirements, both regimes can support an efficient allocation, but CECL requires a lower ratio that adjusts over the economic cycle. The sharpest differences arise with constant requirements, where the provisioning model determines not only the optimal level of the requirement but also the types of outcomes that are achievable. Which regime is preferable depends on the consequences of bank failure: when failure risk must be eliminated, ILM dominates; when some failure risk can be tolerated, CECL can dominate through its self-disciplining mechanism, enabling an outcome that has no analogue under ILM. CECL's advantage, however, is not automatic -- it depends on forecasts being informative enough to affect lending while credit risk uncertainty remains. The transition to CECL therefore requires careful recalibration of capital ratios and close attention to the properties of economic forecasts used in provisioning.Dissertation
Awards:
J. Michael Harrison Doctoral Prize for Impactful Contribution to Theory
FASB Emerging Scholar Finalist
Community Banking Research Conference Emerging Scholar Award, sponsored by the Federal Reserve, the Conference of State Bank Supervisors, and the Federal Deposit Insurance Corp
Presentations: Credit Scoring and Credit Control Conference (University of Edinburgh), American Accounting Association Annual Meeting (Poster presentation), Trans-Atlantic Doctoral Conference (LBS), Chicago Booth Workshop
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Presentations: Advances in Field Experiments Conference, 2023 North American ESA Meeting, Chicago Booth Behavioral Economics Lab
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