Regulatory arbitrage via non‑bank affiliates weakens the transmission of macroprudential policy, posing new challenges for financial‑stability oversight.
The post‑crisis era has seen non‑deposit‑taking financial intermediaries expand their footprint, now holding a majority share of global financial assets. This structural shift coincides with stricter capital and liquidity rules for banks, prompting regulators to rely on macroprudential tools that constrain bank balance sheets. As banks face tighter loan‑growth limits, their broader corporate groups can tap lighter‑regulated affiliates—broker‑dealers, asset managers, and insurers—to keep credit flowing, especially in the syndicated‑loan market that finances large non‑financial corporations.
Empirical analysis of 963 banking groups across 27 economies reveals a clear substitution pattern. A one‑standard‑deviation macroprudential shock reduces bank‑subsidiary lending by about 1 % while NBFI subsidiaries raise their loan supply by 2 %, effectively recapturing more than half of the lost credit. The reallocation is most pronounced in groups with weaker balance sheets and is driven largely by U.S. investment banks and euro‑area affiliates. Crucially, the additional NBFI lending does not concentrate in higher‑risk borrower segments, suggesting that the credit volume is preserved without a proportional rise in portfolio risk.
These dynamics raise important policy questions. By shifting credit to entities under lighter supervision, banking groups dilute the reach of macroprudential measures and create hidden channels of risk transmission. Regulators may need to broaden the supervisory perimeter, improve data on intra‑group flows, and consider coordinated oversight of bank‑non‑bank linkages, especially for cross‑border activities. Addressing this emerging arbitrage will be essential to maintain the effectiveness of macroprudential policy and safeguard financial stability.
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