Letter to the editor: a response to Cosandey and Wolf’s Avoiding pro-cyclicality
From Thomas Garside, managing director, finance and risk management, and Christian Pedersen, senior manager, Oliver, Wyman & Company, London
Much has been written on the proposed changes to the Basel Accord (Basel II), and we have been surprised that the vast majority of both academic and practitioner literature focuses on the prescriptive regulatory approaches and formulas to calculate minimum capital requirements under Pillar I. In our opinion, it is actually the introduction of Pillars II and III that will have a greater impact – Pillars II and III will fundamentally change the role of regulators and financial
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