While market prices can be useful tools for bank regulation, recent theoretical work
argues that reliance on prices can be counterproductive when secondary markets are
stressed and illiquid. Evidence from the financial crisis unearthed by Bhat et al.
(in press) provides empirical validation of these arguments. Though Bhat et al. do not
fully acknowledge it, their findings suggest that forcing banks to count liquidityinduced
unrealized losses in securities holdings against regulatory capital destroys
value and exposes bank creditors, including taxpayers, to more risk. Policy makers
contemplating greater regulatory reliance on market prices ignore these findings at
their peril.