A study about whether the organizational structure of a cooperative bank is still relevant in modern times.
The aim of this thesis is to identify whether cooperative banks are still relevant in the current banking sector. Cooperative banks were historically of great importance to improve the accessibility of capital with great social focus. As years went by, cooperatives grew substantially and started to act more like commercial entities. Therefore the question rises what the added value of being a cooperative bank nowadays is. The structural differences of a cooperative bank are not particularly beneficial as the member structure leads to enormous corporate governance issues. The ownership structure also leads to a different financial management that does not specifically lead to a more stable bank. Also cooperative banks have substantial problems with fitting in the current Basel III regulation. Because of the limitations in raising capital and the focus of Basel III on a common ownership structure, requirements such as the CET1 ratio are hard to fulfill. Particularly in the short term, cooperative banks are very limited in the compliance with Basel norms due to their inflexibility with altering the risk level and the impossibility of a share issuance. Several cooperative banks among Europe have substantial problems and high capital shortfalls before being able to fulfil the Basel demands. As both structurally and financially the cooperative structure only leads to disadvantages and the compliance with Basel is particularly difficult, the importance and relevance of cooperative nowadays in a modern economy is nihil.
1 Inhoud 2
2 Introduction 2
3 Cooperative banks and Corporate Responsibility 3
3.1 Differences in Objectives 3
3.2 Differences in Corporate Governance 4
4 Financial Differences of Cooperative Banks 5
4.1 Differences in Ownership 5
4.2 Differences in Business Model 5
4.2.1 Capital 6
4.2.2 Leverage 7
4.2.3 Liquidity 7
5 Cooperative banks and Regulation 7
5.1 Common Equity Tier 1 8
5.2 Countercyclical Buffer 8
5.3 Liquidity Coverage Ratio 8
5.4 Consequences of Basel demands 9
5.5 Governance 10
6 Conclusion 10
7 Literature 11
Cooperative banks emerged in the middle of the 19th and the beginning of the 20th century due to economic difficulties and the impossibility of accessing capital. Most of the cooperative banks in Europe are based on the conception of both Hermann Schulze and Friedrich Wilhelm Raiffeisen. The rise of cooperative initiatives enhanced possibilities to access microfinance and so growth in several countries among Europe (Fonteyne, 2013).
As described by the International Co-operative Bank Association (ICBA), a cooperative bank is ‘a financial entity which belongs to its members, who are at the same time the owners and the customers of their bank.’ All cooperative banks have the same key features (European Commission, 2001) being (I) a changing cooperative capital base due to free application and deregistration; (II) a non-ability to transfer membership, meaning no market for membership shares; (III) democratic member control, implying every member has one vote and equal right of say; (IV) the distribution of profits is regularly restricted; (V) ownership rights are confined to the nominal cooperative capital that is defined by the member shares (and not extended by the total economic value); and (VI) acting in interest of the members instead of profit maximization.
Recently the biggest cooperative bank of the Netherlands, the Rabobank, merged 110 local banks into one bank with one balance and one banking license due to pressure of the ECB and the De Neederlandsche Bank (DNB), the central bank of the Netherlands. As both banks are obliged to supervise the decisions made by Rabobank, it is impossible for the central banks to reach 110 banks for one question. (NOS, 2015) Besides that, too many local banks were under guardianship of the headquarter of Rabobank due to their financial problems and incomplete customer databases.
As one of the biggest cooperative banks has restructured most of the fundamental characteristics of cooperative banking, the question rises what the social relevance of cooperative banks nowadays is. Therefore my thesis question is: Are cooperative banks still relevant in the current banking sector?
I would like to research whether cooperative banks still fit in the current society by first looking into the general differences and whether this leads to either advantages or disadvantages. Then I examine the differences in financial management as a result of the general differences and if this results in a more stable bank. Lastly, I would like to examine whether cooperative banks still fit in the current Basel regulation determined by the Bank of International Settlements (BIS).
Cooperative banks and Organization
Cooperative banks are historically focused on improving the accessibility to individuals or small and medium enterprises (SME) of capital in order to stimulate local projects. Though this has formerly been of big importance, nowadays obtaining a loan does not take as much effort as it did before. In this section, the current position of cooperative banking with regards to social consciousness is discussed based on differences in objectives and difficulties in corporate governance.
Differences in Objectives
Cooperative banks, for example the Rabobank, like to focus on their cooperative structure and feeling of togetherness in their marketing campaigns to show people that they do not have the same objectives as commercial banking. Due to the local operating banks, cooperative banks do indeed serve a rather social, locally-focused purpose in contrary to the profit- and globally focused perspective of commercial banks, leaving cooperative banks with a trust advantage.
However, as stated by Kay (2006) the trust advantage of cooperative banks declines when the banks start to increase in size. As cooperatives grow and start to focus on sales targets, their comparative advantage declines as they become indistinguishable from regular banks.
Differences in Ownership Structure
Due to the impossibility of issuing shares, cooperatives need to find a different way of funding, which they mostly do through their retained earnings (Fonteyne, 2013). Cooperative banks have a comparative disadvantage regarding the accessibility of capital in the financial market. Smaller cooperative banks do not have enough expertise and scale to engage in financial products. Since most cooperatives are focused on retail banking, the use of securitization, syndication and refinancing by the central bank is not always possible. (Fonteyne, 2013) The ownership model makes it hard to fund rapid growth or mergers and acquisitions. (NEF, 2012)
The absence of shareholders reduces the asset substitutability problem, because members would not pressure the board to increase their leverage in order to obtain a higher share price. (Ayadi, Llewellyn, Schmidt, Arbak & De Groen, 2010)
Differences in Corporate Governance
The main difference of cooperative banks is that they have members instead of shareholders. Although shareholders are allowed to attend the Annual General Meeting (AGM), the word of say is much less democratically than it is with cooperative banks since their votes depend on their percentage of shares. The existence of membership instead of shares results in a more long-term than short-term focus, because shareholders mostly strive for short-term profits. (Fonteyne, 2013).
As this might seem like an advantage, it also increases the lack of willingness to monitor decisions made by the board. Originally, the mechanism worked because the amount of members was limited. However, as most cooperative banks evolved into profit-maximizing cooperatives, their organizational structure remained the same. Resulting into members having very little word of say in bigger cooperatives, so why would they even bother to do their research on the board? (Ferri, 2012)
Furthermore, the level of financial expertise of members is questionable, as the management provides information to the members. Besides that, there cannot be either a take-over threat or a significant change in share prices, so a market disciplining factor is absent. (Fonteyne & Hardy, 2011)
Another big problem with cooperative banking is the corporate governance. Local cooperative banks are able, mostly up to a certain level, to make their own decisions regarding the granting of loans. This leads to high vulnerability to bad management in small local banks, where the incentive to monitor is very small. (Fonteyne, 2013)
A well-known critic on cooperative banking is the existence of untouchable directors that are infrequently replaced, resulting in self-referential acting directors. On the other hand, this will also induce a longer-term focus, rather than the shortsighted view of many commercial banks (Bongini & Ferri, 2007).
In short, as cooperative banks start to grow, they start to operate more like commercial banks and the trust advantage regarding their local and social focus disappears over time. Besides that, the corporate governance of cooperative banks is very poorly controlled, resulting in a lack of adequate control whether local banks are exploiting customers or not operating according the guidelines.
Cooperative Banks and Financial Behavior
The corporate governance is a very important difficulty that is a consequence of the different structure of cooperative banks. In this part the consequences of the differences in financial behavior are summed up. Based on a model established by Kohler a clear image of their business model will be created to get an insight whether the differences lead to a more stable bank.
Differences in Business Model
Kohler (2011) researched factors determining the risk-taking behavior of banks by proposing a dynamic regression model for panel data. The research was based on bank data of all types of banks, both listed and unlisted, in 15 EU countries between 2002-2009. The regression analysis is based on the following variables:
This variable is defined as how much the loan growth rate of a particular bank differs from the median loan growth rate of all banks from the same country and year. Lending activity is endogenous due to the decrease of lending is risk is high.
This variable indicates the part of income that is not earned by interest as this reveals the business strategy very well. The engagement in non-lending activity might increase the risk diversification, but can also reduce the stability of banks as those earnings are more volatile. Also the ratio of loans to bank assets is used to indicate whether a bank is more dependent on customer deposits. Those banks will take a lower share in securitized assets.
This variable is defined by the ratio of customer loans to customer deposits and indicates the level of wholesale funding. Also the ratio of liquid assets to total assets to indicate liquidity, the logarithm of bank assets to control bank size and the net interest margin to measure profitability are taken into account.
The empirical model is defined as follows:
‘Z-score’_ict=’_(i=1)^2”’Z-score’_(ict-l) ??_l+B_ict ??_3+C_ct ??_4+BANK TYPE??_5+??_i+??_c+??_t+??_ict ‘
Z-scoreict indicates the logarithm of the Z-score of a specific bank i in country c and year t. B is the matrix of the three factors stated above. C is the matrix of country-specific factors. The factor Bank Type indicates what kind of bank it is (savings, cooperative and listed banks) and the ?? is the error-term. The term ?? is introduced to cancel out bank-specific effects regarding the corporate governance of banks. Factor ?? is related to time-specific events, for example a common shock in advance of the financial crisis. All betas are coefficients.
Cooperative banks typically are more focused on lending than commercial banks that engage highly in non-lending activities. This results for example in much higher loan-to-asset ratios for cooperative banks (62%) than commercial banks (48%). When observing the non-interest income to total income, cooperative banks can be characterized by a much smaller part involved in non-lending activities. According to the model, banks with higher non-interest income compared to total income are found to be more stable. This can be explained by the fact that non-interest income may enhance the diversification of the bank’s activities (Stiroh, 2004).
Cooperative banks typically engage less in originate-to-distribute financing (OTD). This way of lending money ensures flexibility for banks to change the amount of mortgages held in balance quickly without making alterations to the asset portfolio or capital structure and the impact on the whole bank is very little. (Rosen, 2011) However, many critic was made on the reduced incentive for banks to understand and monitor the risks they were incurring (Purnanandam, 2009). Cooperative banks made less use of the OTD financing due to their lower risk-seeking behaviour and statutory limits (Ferri, 2012).
When the capital markets collapsed, many banks that used OTD financing were hit. Therefore, the lack of use of cooperative banks was rather an advantage than an disadvantage. But regardless of the big collapse, loan sales can come in very convenient for banks to alter their desired level of risk (Ferri, 2012). Commercial banks mostly finance through their wholesale funds, cooperative banks use their customer deposits as a way of funding (Fonteyne 2013; Kohler, 2011).
The existence of pro-cyclicality of leverage behavior among different kinds of banks is an important topic that is researched by Brei & Gambacorta (2015). The research includes 105 of the biggest banks internationally, including 28 cooperative banks, from 1995-2012. By proposing a regression equation they find that cooperative and saving banks are averagely more pro-cyclical in their leverage behavior than commercial banks when total assets are expanding.
The lower leverage of cooperative banks could have been explained by the reduced conflict between owners and depositors. Depositors do not prefer a highly leveraged bank if that puts their deposits in danger. Hence, there is lower moral hazard although not fully cancelled out. (Fonteyne & Hardy, 2011) But according to the large-scaled research by Chun, Kim & Ko (2012) the leverage of cooperative banks is not particularly lower compared to other types of banks.
Commercial banks are much more liquid than other banks, which is proven by their higher proportion of liquid assets to the total assets. This can be explained by their dependency on wholesale funds, leading to the need of a buffer against liquidity shocks. As cooperatives mostly fund through deposits, there is less need for a buffer and so less liquidity. The significant liquid-to-total-assets determinant proves that liquid banks are more stable than others. (Kohler, 2012)
Financially, cooperative banks experience difficulties due to their focus on lending activities, resulting in a low diversification. Cooperative banks are not less leveraged, irrespectively of the absence of the asset substitution problem. Furthermore, the banks are characterized by a lower liquidity and are inflexible with risk-level changing.
Cooperative Banks in the Financial System
Diversity in segments is often well
Cooperative banks and Regulation
Cooperative banks thus have different financial characteristics than other banks, that make those banks more vulnerable. However, in the current banking system, in the aftermath of the crisis, vulnerabilities need to be reduced in order to maintain a stable banking sector. Therefore all banks are obliged to comply with the Basel demands, which will be discussed in this part. Do cooperative banks still fit in the current regulation?
Basel III was brought to life in in order to obtain more resilient banks and bank system. In contrary to Basel I and II which were more focused on the level of capital, Basel III focuses on requiring different reserves for different deposits (BNP Paribas, 2013). In the following, the new Basel demands that are particularly difficult for cooperative banks are stated.
Common Equity Tier 1
The core equity tier 1 (CET1) ratio demands are strongly increased in Basel III. In 2019 the minimum common equity plus capital conservation buffer must be 7%. In addition to that, a countercyclical buffer is required which can raise the demanded level of CET1 up to 9,5%. According to the new Basel III the demanded percentage of CET1 is classified on their total assets and so systematic risk. (BIS, 2011)
To obtain the demanded CET1 ratio banks can either raise their regulatory capital or decrease the risk-weighted assets (RWA). Increasing the regulatory capital can be done by either increasing the amount of retained earnings or by the issuance of shares. As there is no regulated market for cooperative shares, this is not a solution for cooperative banks. The only other possibility is to increase the retained earnings, which is quite hard to raise.
The other possibility is to decrease risk-weighted assets by substituting risky assets for less risky assets. Obviously when there is short-term pressure it is more convenient to decrease the risky assets, rather than restructuring retained earnings which is more favorable for a longer term horizon. OTD financing can be a tool to effectively share risk, but as stated before cooperatives do not really engage in OTD finance.
Schatzle (2012) took a closer look to almost 250 banks in Germany and found that it might be hard for cooperative banks to satisfy the CET1 ratio. On 31-12-2012 the capital shortfall of banks that were unable to comply with the CET1 ratio was 1.17 billion. The required alteration of RWAs on the other hand was more than 13 billion. So the capital shortfall is much smaller, though harder to comply with.
To address pro-cyclicality and to prevent the amplification of business cycles resulting in large fluctuations in financial stability, the countercyclical buffer is introduced in Basel III. (BASEL) The demanded percentage of buffer varies between 0-2,5% depending on geographical spread of credit exposure.
According to Brei & Gambacorta (2015) cooperative banks are more likely to increase their leverage if there is asset expansion. Therefore the need for a buffer will be higher and the need to expand retained earnings even higher.
Liquidity Coverage Ratio
The Liquidity Coverage Ratio (LCR) is defined to prevent liquidity disruptions over a period of 30 days. Therefore banks have to retain sufficient liquid assets in order to obtain a buffer for unexpected short-term stress situations (BIS, 2011). The LCR is determined by the high quality assets divided by the net cash outflows. The high quality assets consist for 60% of level 1 assets, which can be cash, central bank reserves and sovereign debt, and for 40% of level 2 assets, which can be corporate and covered bonds (at least AA- level). Net cash outflows are the total expected outflows minus the total expected inflows for a period of 30 days. This ratio must be 100% in 2019. (BIS, 2011)
In a large-scaled monitoring research by the European Banking Association (EBA) in 2014 was stated that although many banks start to comply with the LCR, there are still large shortfalls for particular business models such as cooperative banks and well-diversified banks (EBA, 2014). In 2013Q4 77% of the banks of the sample made by EBA satisfies the LCR. The co-operatives have compared to the different types of business models the lowest average LCR as can be seen in table 1 below.
As a bank has a higher liquidity risk exposure, they tend to increase their liquidity buffer. Since cooperative banks have a low volatility of returns and low liquidity risk, the incentive to take on high buffers is not so high compared to other banks. (DNB, 2013)
Cooperative banks can either increase their high quality liquid assets or shorten the maturity of their lending so its maturity will be below the one-year requirement. Another possibility is increasing their retail deposits and long-term wholesale funding.
Source: EBA (2014)
Net Stable Funding Ratio
The Net Stable Funding Ratio (NSFR) demands stable funding associated with the level of liquidity of the assets. The NSFR is defined as the available amount of stable funding (ASF) divided by the required amount of stable funding (RSF). The ASF measure indicated the most stable sources of funding, including regulatory capital, deposits and funding with a maturation of over a year. The RSF factor regards assets in terms of the proportion of stable funding (Sherman & Sterling, 2014). In 2018 a minimum required percentage will be introduced.
The aim of the introduction of the NSFR is to require stable funding for short-term exposure to banks, derivative exposure and assets booked as initial margin for derivative contracts. The goal is to improve the matching of maturities and therefore reducing risks. This will lead to higher costs and therefore unintended consequences regarding the lending to SME, which is of great importance for cooperative banks.
Consequences of Basel demands
The aim of the Basel rules is to improve the matching of maturities and therefore reducing risks. Obviously, complying with this regulation will lead to higher costs for cooperative banks as they particularly have struggles with fulfilling the demands. Due to the higher demands, banks are forced to spike the interest rates resulting in a lower demand for loans. Commercial banks will probably engage more in non-interest income activities such as advisory.
Also, as banks might decrease their lending activity, companies will probably depend more on financial markets. Furthermore, recapitalizations can be expected in order to obtain the minimum ratio, so bond issues and deposits will rise. Lastly, banks might want to sell asset classes that require high stable funding. Therefore some specific asset classes such as mortgage loans might increase substantially due to a lower required stable funding. (Sia Partners, 2013)
Carbo Valverde (2011) finds that the credit availability to small and medium enterprises (SME) substantially declined after the introduction of the tougher solvency demands. Because cooperative banks rely much more on lending activity, the increased demands particularly hurt the cooperatives.
In contrary to the stringent financial requirements of Basel III, the demands for corporate governance are less restrictive and not intended to provide a regulatory framework.
However, some clear statements are made on what challenges arise and how they should be treated. For example, banks with ownership structures that are unduly complex should make sure that transparency is safeguarded. As cooperative banks have very complex ownership structures, the management board should consider the side-effects.
Furthermore regards membership structures, the Basel guidelines state that controlling shareholders can be beneficial, but should still be clearly supervised to maintain a sound corporate governance.
Regarding group structures Basel III states that the board of the parent company should have complete responsibility for a suitable corporate governance through the entire group. Also they should impose adequate governance policies applicable to the specific groups and entities’ structure and risk. (BIS, 2014)
‘Are cooperative banks still relevant in the current banking sector?
The benefits of the cooperative structure, the local focus and good customer relationship management, are overruled by the fact that as cooperatives grow this focus weakens and the control among banks is practically impossible. The absence of shares eliminates the asset substitution problem and the pressure to involve in high risk activities, but also leads to a lack of efficiency as there is no market-disciplining factor. Funding new projects, mergers or acquisitions through shares is impossible, resulting in difficulties when quickly trying to respond to the market. The fact that members have a democratic word of say is fair, but it creates a sense of unimportance to monitor because no-one is really responsible. Also members can be anyone, without financial knowledge, who have to advise the board in their decision-making.
The differences in structure lead to a business model that is more focused on lending, resulting in a lower diversity of earnings. The cooperative banks are not very involved in OTD-financing, leading to more difficulties when there is a need to quickly alter risks. Also, cooperative banks are typically less liquid.
Cooperative banks do also not predominantly fit in in the current Basel regulation. The CET1 ratio is a hard demand to comply with as they cannot raise capital on the equity market. Besides that, decreasing their risk-weighted assets is also harder due to their lack of engagement in OTD financing to easily alter their level of risk. The impact of Basel III will be a higher maturity mismatch and the need to either raise their retained earnings or to alter their risk level. The countercyclical buffer increases the need for the earlier mentioned increase in retained earnings or the decrease in risk level.
The LCR is another hard measure to fulfill for cooperative banks as they are typically less exposed to liquidity risk, so the need for a buffer is much lower. However, of course they still also need to fulfill the requirement. The impact of this requirement is that cooperatives have to either reduce their lending to maturities below one year or to increase their high-quality lending. Since most cooperative banks are merely depending on customer deposits, the renewed Basel demands has a much bigger impact on cooperating banking activity.
The guidelines of corporate governance are also not particularly in favor of the difficult structure of cooperative banks.
So are cooperative banks still relevant in the current banking sector? No, cooperative banks are not relevant in the current banking system because the historical importance is gone nowadays and there is no specific added value of the structure of a cooperative banks compared to the regular structure.
In my opinion, I think the cooperative banks still exist because it sounds good in marketing campaigns, rather than cooperative banks really adding something to the society. It is the thought that counts.
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