Researchers at the Federal Reserve Bank of New York and Others: Stricter Regulation May Lower Bank Resolution Costs but Could Tighten Credit Supply
Since 2000, a total of 557 commercial banks in the United States have failed, with only 28 of them closing on any day other than Friday. Friday is the preferred closure day for the Federal Deposit Insurance Corporation (FDIC), and acquirers are typically arranged before the failure occurs. This means that modern bank failures are rarely triggered by market forces such as deposit runs, but instead follow supervisory closure decisions. For comparison, between 1865 and 1935, before the establishment of the federal deposit insurance system, bank failure dates were distributed almost uniformly across the days of the week—the researchers believe that at that time, depositors and shareholders usually determined the timing of the closure themselves.
But there is an easily overlooked feedback loop here: the basis for supervisors to close banks is book capital (the CET1 ratio), and book capital itself is partly produced by supervisory examinations. The researchers found that the probability of a bank revising its previously submitted financial statements (call reports) sharply increases around on-site supervisory examinations; over the five years preceding a bank's failure, its equity-to-assets ratio typically declines by 8 percentage points, nearly 3 of which come from revisions triggered by examination-induced loss recognition. In other words, supervisors force banks to write potential losses into their statements through examinations, and then use those worsened figures to decide on closure. In the CAMELS rating system, the capital sub-component is mechanically related to book capital, while the management sub-component allows for supervisory discretion—for well-capitalized banks, the composite rating is closer to the management rating; for severely undercapitalized banks, the composite rating is almost equivalent to the capital rating.
The researchers further validated the causal direction using a natural experiment during the 2008 financial crisis: under identical financial conditions, banks assigned to 'stricter' examiners recognized more losses and reported lower book capital, thereby increasing their probability of failure. Stricter supervision indeed reduced the FDIC's resolution costs, but also led to a short-term contraction in credit supply. This constitutes a core trade-off: strict supervision can curb speculative 'gambling for resurrection' behavior and prevent zombie banks from misallocating credit, but it may do so at the cost of further tightening supply when credit conditions are already weak; lenient supervision may preserve credit but raise ultimate resolution costs. The deposit insurance system weakens depositor discipline, making this trade-off even more prominent.
The researchers explicitly state that their analysis is entirely empirical and they make no normative judgments regarding the 'optimal degree of regulatory strictness.' The applicable boundaries of the conclusions are also worth noting: the natural experiment sample is limited to the 2008 crisis period, and the definition of 'strict supervisors' relies on examiners who assign worse CAMELS ratings for the same financial condition—a difference that may partially reflect subjective judgment rather than objective standards. For investors, the value of this research lies in providing an actionable analytical framework: when observing an abnormally high frequency of a bank's financial statement revisions, this is not only a signal of deteriorating asset quality, but also possibly a process where supervisors are actively creating the conditions for closure.
Sources:Liberty Street Economics