AKM Kamrul Hasan | Yasushi Suzuki
pages: 49-65;
JEL classification: E58, K20, K23;
Keywords: BCBS, Basel accord, ECAIs regulation, Sub-debt regulation;
Abstract: International concern on bank capital and minimum capital adequacy was first raised in 1980, in
the G-10 countries governors meeting at the Bank for International Settlements (BIS) to respond
to a series of bank failures and financial instability observed in Western developed economies.
Later, the Basel Committee on Banking Supervision (BCBS) of the BIS proposed the Basel accord
I, II and III in 1988, 2004 and 2010, respectively. Bangladesh Bank (BB) has introduced the ‘capital
to risk weighted assets’-based approach for assessing the capital adequacy of banks in 1996 and
later formally introduced the Basel framework in the early 2000s for its regulated banks. However,
during Basel accord II and III implementation period (2009-2018), the banking industry accumulated
huge non-performing loans which eroded its profitability. This creates a skepticism regarding any
loopholes within the institutions. This paper argues that the naïve and excess reliance on External
Credit Assessment Institutions (ECAIs’) credit rating in the process of adopting the Basel-type capital
adequacy amounted to a risky strategy for the Bangladeshi banking industry in a sense that ECAIs
allocate less efforts on accumulation of credit risk screening skills . We also document that the huge
transaction cost and high coupon rate embedded within the debt instrument like the subordinated
debt (sub-debt) issued by the regulated banks as Tier 2 capital might shrink the bank’s profitability
and its contribution to the national exchequer.