20. Estimates of losses being faced by banks vary but are likely to be sizeable. On a
gross basis, staff’s review of available estimates and methodologies suggests that the losses
faced by banks through the end of 2010 could be about €35 billion, or about 20 percent of
GDP.
The authorities did not formally produce any estimate for aggregate bank losses. They
have focused on the needed restructuring of property-development loans, which they rightly
view as at the heart of stress faced by banks. Staff noted that losses are likely to extend
beyond the property-development sector as the economy weakens and the design of NAMA
should incorporate that possibility
A key aspect of NAMA’s success will be the prices at which the assets are
purchased. This will determine the extent to which banks’ losses are transferred to the
taxpayer. Since price determination is a major challenge, risk-sharing structures could be
usefully explored. For example, if sold at a price that is clearly lower than the expected
eventual recovery value, bank shareholders could be given a share in the upside. Similarly,
the government could be given an opportunity to participate in the upside of the residual
healthy bank. The authorities noted that they remained open to a number of refinements,
including such upfront risk-sharing structures. Also, while there has been some public
discussion of a bank-specific ex post “claw back” provision, the authorities are considering
an industry-wide levy to recoup any losses suffered by NAMA.
24 T
he authorities took note of these considerations for their further deliberations
on setting up NAMA. They agreed that piecemeal efforts could keep banks dependent on
official support and unable to resume normal functioning. The Japanese experience is
particularly cautionary. The authorities saw merit in staff’s suggestion that NAMAimplementing
legislation should encompass a broader range of loan types.5
25.
Staff noted that nationalization could become necessary but should be seen as
complementary to NAMA. Where the size of its impaired assets renders a bank critically
undercapitalized or insolvent, the only real option may be temporary nationalization. Recent
Fund advice in this regard is: “Insolvent institutions (with insufficient cash flows) should be
closed, merged, or temporarily placed in public ownership until private sector solutions can
be developed ... there have been numerous instances (for example, Japan, Sweden and the
United States), where a period of public ownership has been used to cleanse balance sheets
and pave the way to sales back to the private sector.”6 Having taken control of the bank, the
shareholders would be fully diluted in the interest of protecting the taxpayer and thus
preserving the political legitimacy of the initiative. The bad assets would still be carved out,
but the thorny issue of purchase price would be less important, and the period of price
discovery longer, since the transactions are between two government-owned entities. The
management of the full range of bad assets would proceed under the NAMA structure.
Nationalization could also be used to effect needed mergers in the absence of more far
reaching resolution techniques.
26.
The authorities prefer that banks stay partly in private ownership to provide
continued market pricing of their underlying assets. They disagreed with the staff’s view
that pricing of bad assets would be any easier under nationalization. They were also
concerned that nationalization may generate negative sentiment with implications for the
operational integrity of the banks. Staff emphasized nationalization would need to be
accompanied by a clear commitment to operate the banks in a transparent manner on a
commercial basis. In particular, nationalized banks should be subject to the same capital
requirements and supervisory oversight as non-nationalized banks. And, a clear exit strategy
to return the banks to private operation would be needed.