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Implementing Quantitative Balancing (QB) within the EU financial regulatory framework presents several potential challenges. These challenges span regulatory, economic, and social dimensions, as well as technical and transitional issues. Below is a detailed analysis of these challenges:
1. Regulatory and Implementation Challenges
1.1 Alignment with Existing EU Regulations
The EU has a robust regulatory framework for banking and finance, including Basel III standards, Regulation (EU) No 575/2013 (Capital Requirements Regulation), and the Single Supervisory Mechanism (SSM). Implementing QB would require amendments to these regulations to accommodate the reclassification of deposits as seigniorage liabilities to the State Treasury
. This could lead to legal and procedural complexities, especially given the need for harmonization across member states.
1.2 International Coordination
The EU operates within a global financial system, and implementing QB in one jurisdiction (e.g., Austria or Italy) without corresponding reforms elsewhere could create regulatory arbitrage opportunities. Banks might shift operations to jurisdictions with less sound rules, undermining the effectiveness of QB
. There should be an adequate information campaign for bankers so that they understand how the new classification helps them within the CET-1 requirements.
1.3 Transitional Arrangements
Transitioning from the current system to QB would require careful management to avoid disruptions in the banking sector. For example, banks might face pressures during the initial phase when deposits are reclassified as seigniorage liabilities to the State Treasury. A phased implementation plan, supported by clear guidelines and temporary support mechanisms, would be essential
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2. Economic and Social Considerations
2.1 Distribution of Seigniorage Benefits
Under QB, seigniorage revenues—currently unaccounted for in private banks—would be directed to the public sector. While this could enhance government revenue and fund public services, it does not reduce profitability for banks. This arrangement can happen by recognizing bank money as a legal tender.
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2.2 Impact on Financial Stability
While QB aims to enhance financial stability by segregating deposits and improving transparency, there is a risk that the transition period could introduce instability. There should be an adequate information campaign for depositors so that they are clear about the benefits of segregation of accounts in the event of a bank liquidation.
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2.3 Public Perception and Trust
The success of QB depends on public trust in the new system. Depositors must understand that their funds are secure under the State Treasury’s guarantee. Miscommunication or lack of awareness could lead to skepticism, undermining the intended benefits of QB
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3. Maintaining the Nash Equilibrium
3.1 Coordination Among Stakeholders
QB relies on a stable Nash Equilibrium among banks, the State (Treasury), and depositors. Achieving this equilibrium requires clear communication, mutual trust, and robust enforcement mechanisms. Any deviation by one party—such as banks underreporting liabilities or the State overcharging seigniorage—could destabilize the system
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3.2 Regulatory Enforcement
Ensuring compliance with QB principles would require enhanced regulatory oversight. Regulators would need to monitor banks’ activities closely, particularly their reporting of M2 liabilities and adherence to seigniorage payment obligations. This could strain existing supervisory capacities, requiring resources and AI expertise.
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3.3 Addressing External Shocks
The financial system is vulnerable to external shocks, such as economic downturns or geopolitical crises. QB must include mechanisms to address these shocks without disrupting the equilibrium. For example, during periods of economic stress, the State might need to adjust seigniorage rates to ease money creation by banks
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4. Balancing Transparency with Prudential Regulation
4.1 Preventing Excessive Money Creation
While QB enhances transparency, it does not eliminate the risk of excessive money creation. Without robust prudential regulation, banks might still engage in risky lending practices, leading to inflationary pressures or asset bubbles. Clear guidelines for seigniorage rates and rigorous monitoring of bank activities are crucial to maintaining financial stability
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4.2 Harmonizing Accounting Standards
QB aligns with international accounting frameworks like IFRS-IAS 7.6, US-GAAP ASC 942-230-20 and SWISS GAAP FER 4, by recognizing deposit creation as legal money creation (cash). However, achieving full harmonization across jurisdictions would require overcoming differences in legal and regulatory interpretations. For example, some countries might resist treating deposits as liabilities to the State Treasury due to historical or institutional factors
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5. Technical and Operational Challenges
5.1 IT and Infrastructure Upgrades
Implementing QB would necessitate some upgrades to banks’ IT systems and infrastructure. For instance, banks would need to develop systems for recording seigniorage payments, managing segregated accounts, and ensuring real-time reporting to regulators. These upgrades could be time-consuming
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5.2 Training and Capacity Building
Bank employees, regulators, and other stakeholders would require training to understand and implement QB principles effectively. This includes understanding the new balance sheet dynamics, cash flow reporting requirements, and the role of seigniorage in monetary policy
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6. Case-Specific Challenges in the EU Context
6.1 Sovereign Debt Dynamics
In the context of the European Sovereign Debt Crisis (2010-2012), banks in countries like Greece, Ireland, and Spain were heavily exposed to sovereign debt. Under QB, the explicit recognition of seigniorage liabilities could reduce these exposures, potentially eliminating market concerns about sovereign risk. However, QB’s transparency could also enable earlier identification of vulnerabilities, allowing for timely interventions
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6.2 Fiscal Framework Adjustments
The EU fiscal framework, which includes rules on deficit and debt levels, would need to account for the influx of seigniorage revenues. This could simplify fiscal planning and require less adjustments to national budgets. Additionally, the redistribution of seigniorage benefits could push other member states to adopt QB as well.
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Final remarks
While QB offers a transformative approach to enhancing transparency, depositor protection, and financial stability, its implementation within the EU regulatory framework poses some challenges. Addressing these challenges requires careful planning, international cooperation, and robust regulatory enforcement. Policymakers must balance the need for transparency with prudential regulation, ensure smooth transitions, and foster trust among all stakeholders. Future research and pilot programs could help identify practical solutions and refine the QB framework for broader adoption
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References
- [PDF] Implementing Basel III in the EU: remaining challenges and timing .
- [PDF] The Challenges of the EU Banking Union - will it succeed in dealing .
- [PDF] Financial stability challenges in EU candidate and potential .
- Financial Stability Review, November 2024 - European Central Bank .
- [PDF] EU IMPLEMENTATION OF THE FINAL BASEL III FRAMEWORK .
- Saba, M. (2024). Rettifica contabile dei bilanci delle banche e riflessi sul bilancio dello Stato
- Bezemer, D. J. (2016). Towards an ‘accounting view’ on money, banking and the macroeconomy .
- Bossone, B. (2021). Bank Seigniorage in a Monetary Production Economy .
- [PDF] Technical Note on Open Banking .
- [PDF] Open finance policy considerations | OECD .
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