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3 years after the implementation of Basel 2, the integration of risk-models in business operations is not optimal yet. The heart of the structural problems of Basel 2 is that no indication is present of how to provide for a sound capital assessment; no effective monitoring and reporting-structure of risks exists; and the passive behavior of the Internal Control-department
In the mean while, the Basel Committee has announced that Basel 3 shall have to be implemented before 1 January 2020. The largest impact of Basel 3 for banks is a renewed sense of urgency for liquidity requirements by retaining more real capital and a smaller leverage; the implementation of a liquidity coverage ratio; and a counter-cyclical capital buffer. However, Basel 3...
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