It is our view that the Basel Committee of Banking Supervision, in its Basel II proposals, has failed to address many of the key deficiencies of the global financial regulatory system and even created the potential for new sources of instability. This document highlights our concerns that the failure of the proposals to address key issues can have destabilising effects and thus harm the global financial system. In particular, there is considerable scope for under-estimation of financial risk, which may lead to complacency on the part of policy makers and insufficient understanding of the likelihood of a systematic crisis. Furthermore, it is unfortunate that the Basel Committee has not considered how financial institutions will react to the new regulations. Of special concern is how the proposed regulations would induce the harmonisation of investment decisions during the crises with the consequence of destabilising rather than stabilising the global financial system.
