Excess capital a slippery measure
One aspect of the management of bank capital in Australia that's little noted is the careful avoidance of banks and their regulators of giving outsiders - depositors or investors, say - information about how much capital banks are supposed to hold.For all the routine disclosure of actual levels of capital held and reference to industry-wide minimum capital ratios - such as the soon to be superseded eight per cent ratio - no bank discloses the actual minimum capital target imposed on them by APRA.This is no accident, since APRA does not allow banks to do so.Exceptions to this rule are few. National Australia Bank had to work to a public, minimum capital ratio of 10 per cent following the foreign exchange trading losses in early 2004 that generated plenty of change in the boardroom, at least.The Rock Building Society mentioned in its latest financial statement that it was working to a minimum capital ratio of 12 per cent, though even small ADIs, many of them mutuals, are rarely explicit about this target.But as for the APRA capital targets that NAB and other banks are working to at present, these are ratios known to insiders but carefully screened from everyone else.This newsletter has asked banks now and then over the years and never found out; with the excuse always that APRA will not allow disclosure of this information.This is no instance of regulatory ephemera.Reports from sell-side analysts are already in circulation of the estimated "surplus capital" of banks under the Basel III proposals for capital announced by the Group of Governors and Heads of Supervision on Sunday.The notion that banks might hold surplus capital, and that their boards might be myopic enough to hand some of it back, is one of the fascinations of a select group of investment analysts. Questions along these lines continue to crop up at investor briefings, however unlikely this may be given the repercussions of the global financial crisis of 2008.Yet were there any surplus capital, the question is, surplus to what?One answer is the "target ranges" for capital ratios that banks often talk about, and which for core capital have increased markedly over the last few years (and so much so that banks can say they now meet the Basel III minimum standards).These target ranges take into account the minimum requirements APRA has set for the bank, but they still do not make clear what the local version is of the buffers that are prominent in the current debate and the additional buffer that is each bank board's own work.Taking into account the prospect that the big four banks might fit the definition of systemically important (reported in the prior article) any debates over excess capital in Australia are likely to be off the mark.