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Evaluation of the effects of financial regulatory reforms on small and medium-sized enterprise (SME) financing

This consultative report presents the results of, and seeks comments on, the evaluation of the effects of financial regulatory reforms on the financing of small and medium-sized enterprises (SMEs). It is carried out under the FSB framework for the post-implementation evaluation of the effects of the G20 financial regulatory reforms, and is part of a broader evaluation on financial intermediation. The final report will be published in November 2019.

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Given that banks are the primary providers of external SME financing, the reforms that are most relevant and have been implemented to date are the initial Basel III capital and liquidity requirements agreed in 2010. These reforms were evaluated by means of both qualitative and quantitative analysis. Other G20 reforms that may be relevant for SME financing but are at an earlier implementation stage (e.g. Basel III reforms finalised in December 2017, accounting standards) are only reviewed qualitatively, given the lack of data required for a quantitative assessment. In addition to the G20 reforms, national and regional regulations (e.g. stress tests) may affect SME financing. Consistent with the FSB evaluation framework, these reforms have also been analysed qualitatively.

The main conclusion of the evaluation is that, for the reforms in scope, the analysis thus far does not identify material and persistent negative effects on SME financing in general, although there is some differentiation across jurisdictions. There is some evidence that the more stringent risk-based capital (RBC) requirements under Basel III slowed the pace and in some jurisdictions tightened the conditions of SME lending at the most “affected” banks (i.e. those least capitalised ex ante) relative to other banks. These effects are not homogeneous across jurisdictions and they are generally found to be temporary. This conclusion, which is subject to additional analysis, is consistent with the literature on the effects of bank capital regulations and with stakeholder feedback that SME financing is largely driven by factors other than financial regulation. The evaluation also provides some evidence for a reallocation of bank lending towards more creditworthy firms after the introduction of reforms, but this effect is not specific to SMEs.