Distance to compliance portfolios: An integrated shortfall measure for basel III

We apply our framework to two hypothetical banks and find that they achieve compliance by growth strategies without cutting lending. We corroborate that shareholders choose different compliance strategies than managers, emphasizing the importance of setting managers' incentives carefully. We compare our results to findings from impact studies that are not model-based and do not consider the interactions of the Basel III ratios. We observe that the synergies of LCR and NSFR are the most pronounced ones but of secondary order in absolute magnitude. This means that measuring “Distance to Compliance” on a ratio-by-ratio basis omitting synergies, as often done by regulators, does not introduce a major bias.