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Private Actors and Public Policy: A Requiem for the New Basel Capital Accord

After the Asian crisis of 1997-98, policy-makers invested much energy in designing a new international financial architecture. However, many of the policy proposals that have emerged from think tanks and the multilateral agencies have proven unworkable or politically unpalatable. The debate focuses on state-led initiatives. But the assumption that public policy is by definition an output of public institutions is difficult to sustain in an era of global change. This article considers specialized forms of intelligence gathering and judgment determination which seem increasingly important as sources of governance in this era of financial market volatility: Moody's Investors Service and Standard & Poor's, the major bond rating agencies. More specifically, we examine a proposal of the Basel Committee on Banking Supervision to reform the existing capital adequacy framework by incorporating banks' own internal ratings and external bond ratings from the rating agencies, in order to calculate bank risk-weighted capital requirements. The article identifies a series of negative implications from the use of private rating agencies as a substitute for state-based regulation, premised on the organizational incentives that shape the ratings industry. Cementing these organizational incentives into the emerging financial architecture will, we argue, lead to negative social and economic consequences.