We think that the larger US and European national banks in general should be viewed in a different light. These banks are typically bigger and better diversified, with more stable sources of funding and more disciplined risk management—including oversight and hedging of interest-rate risks. They also tend to benefit from a “flight to quality” in times of stress. European banks are subject to more rigorous regulation than those US banks that have less than US$250 billion in assets, and can depend on more stable funding, with less competition for deposits from money-market funds and much less interest-rate exposure in their domestic fixed-income markets than in the US. As a group, European banks have outperformed large US peers during the crisis period.
CS was an exceptional case. After suffering years of losses in its investment banking arm and significant deposit outflows in late 2022, the CS management team implemented a significant restructuring plan with a notable lack of urgency. This left the bank vulnerable to a loss of clients’ and investors’ confidence during the panic triggered by the US regionals. Its rescue merger with UBS was negotiated with the Swiss authorities over the weekend of March 18/19, leaving CS shareholders with a fraction of their previous stock value and CS AT1 bondholders with nothing. This highly controversial resolution will likely lead to litigation and has prompted greater bondholder wariness of AT1s, especially in Switzerland.
Central banks across the UK, the EU and Asia have distanced themselves from the Swiss approach. They have reaffirmed AT1s’ priority over equity in the capital structure and reasserted that stockholders must be the first to take capital losses when a bank’s viability is at stake. Given time, these assurances should be supportive of a market that can offer attractive value.
Prospective Changes Mean Greater Protection for Bondholders
While changes to regulation will take time to enact, the crisis has forced authorities to focus on liquidity management, as shortage of cash was central in the recent panic.
Just as, following the 2008 global financial crisis (GFC), regulators forced banks to significantly strengthen their capital buffers, so after the 2023 bank failures we expect a regulatory review leading to tighter minimum liquidity standards, especially for smaller US banks. We also anticipate an ongoing debate about the potential moral hazard of extending deposit insurance coverage and the need for better and more timely bank reporting.
More stringent bank regulation may help reduce loan growth, hitting profitability. Although this would hurt stockholders, we expect it would create greater security and increased confidence for bondholders.
In the shorter term, the Fed, Bank of England and European Central Bank have all continued to raise rates, demonstrating their confidence in the banking system and their expectation that the crisis will result in tighter financial conditions that will help slow the economy. If commercial banks adopt more conservative lending policies, that would slow credit growth and improve security for bondholders.
Larger Banks’ Fundamentals Are Strong
The crisis has also highlighted some US regional banks’ relatively high exposure to riskier commercial real estate and leveraged private investments loans, which may threaten their capital positions.
But larger US and European banks continue to maintain very strong capital reserves in response to more stringent regulation. Common Equity Tier 1 (CET1) ratios remain high, notably in Europe (Display), providing a buffer for their AT1 bondholders.