7. Conclusion
In response to the current financial crisis, the FSF (2009) issued a report recommending that regulators and policy
makers reconsider the role of loan loss provisioning in the pro-cyclicality of the financial system. Specifically they stated
that
Earlier recognition of loan losses could have dampened cyclical moves in the current crisis, and that earlier identification of
and provisioning for credit losses are consistent both with financial statement users’ needs for transparency regarding
changes in credit trends and with prudential objectives of safety and soundness.
We exploit cross-sectional variation in implementation of the incurred loss framework to investigate the effect of delay
in recognizing expected loan losses on banks’ lending behaviors. Our study sheds some light on whether delays in
expected loss recognition contribute to the pro-cyclicality of regulatory capital requirements. We find that during the
period after implementation of Basel risk based capital regulations and FDICIA, banks with greater delays in expected loss
recognition reduce their lending during recessions more than banks with smaller delays. We also find that banks with
greater delays are more subject to capital crunches during recessions compared to smaller delay banks. Our study indicates
that the lending of banks with smaller delays in expected loss recognition is less pro-cyclical. This holds across partitions
of well managed and poorly managed banks.
We also find that banks with smaller delays increase their pre-provision equity more during non-recessionary periods
and decrease their pre-provision equity less during recessions than banks with greater delays. This provides smaller delay
banks with the ability to reduce their lending less during recessions without increasing their regulatory capital adequacy
concerns.
In supplemental tests, we find no evidence of pro-cyclicality related to the capital ratio in the period prior to capital
regulation. Taken together, these results suggest that capital regulation combined with greater delays in recognizing
expected losses leads to the capital crunch on lending during recessions.
Finally, we find that large banks are more vulnerable to capital constraints compared to small banks. This finding is in
contrast to the results of studies conducted prior to the implementation of FDICIA. These findings suggest that the prompt
corrective action and the internal control provisions of FDICIA may have had the unintended consequence of making bank
lending more pro-cyclical.