资本监管的回望与思考

Retrospect and Reflection on Capital Regulation

资本监管制度要实现其＂吸收损失＂和＂资源配置＂的二元定位,应当更加全面地识别银行非预期损失发生的路径,提高损失吸收能力,探索银行分配资源的内生逻辑和运行机制,不断提升资本监管制度的针对性和有效性。所谓＂将本逐利＂,是对银行内部经营行为的美好期望。

Regulators should, in first place, avoid governing any regulatory standard as a dogma that mechanically relies on historical data, nor should they expect there to appear a single one-size-fits-all regulatory indicator. As a prudential standard to set constraints on banks' risk-taking which are, in turn, dominated by human exercising economic decisions, capital regulation should therefore be introduced as a set of standards that effectively orients risk behaviours of humans. It is in this sense that capital regulation is expected to embrace an integration of loss-absorption and resource-allocation. To achieve this, regulators should develop capacities to comprehensively identify drivers of unexpected losses incurred by banks. On this basis, capital regulation will facilitate to enhance loss-absorption and streamline firm-wide resource allocation which will eventually serve to assure to effectively realize its targets.