Het houden van toezicht op banken (2009)

De economische principes achter het houden van toezicht

Waarom is het houden van toezicht eigenlijk nodig of nuttig? Wat zit daar voor economische logica achter? Het is daarbij aardig het zeer lezenswaardige boek ‘De grote recessie’ (2009) van het Centraal Planbureau te volgen op dit punt.

Het begint eigenlijk met iemand die een goed idee heeft en dat wil realiseren maar daar het benodigde geld niet voor heeft. Aan de andere kant zijn er vermogende mensen die wel het geld hebben maar niet het idee. De ene partij kan de andere helpen waardoor een win-win situatie ontstaat. Het idee wordt gerealiseerd en als alles goed gaat krijgt de geldschieter een passende vergoeding voor het ter beschikking stellen van zijn vermogen.

Moreel risico

Het probleem bij deze transactie is nu dat de geldschieter niet zonder meer weet of de ondernemer van goede kwaliteit is en zuinig met zijn centen zal omgaan. Er is hier sprake van asymmetrische informatie: de ondernemer weet meer over zijn eigen achtergronden en werkelijke beweegredenen dan de geldschieter. In de economie wordt dit ‘moral hazard’ of moreel risico genoemd. Dit probleem kan worden opgelost door iemand in opdracht van de geldschieter het bedrijf en de ondernemer in de gaten te laten houden.

Meeliftersgedrag

Maar er is nog een probleem. In de praktijk zal het niet gaan over een enkele grote geldschieter maar over meerdere kleinere geldschieters. Nu is de vraag wie van de geldschieters de ondernemer in de gaten gaat houden. Hier speelt het tweede probleem, het probleem dat in de economie bekend staat als het ‘free rider’ probleem oftewel in goed Nederlands het meeliftersprobleem. Elke geldschieter ziet het liefst dat iemand anders de controle op zich gaat nemen zodat hijzelf zijn tijd beter en nuttiger kan besteden. Als dit probleem te groot wordt is het eind van het liedje dat per saldo niemand het bedrijf controleert. Hoe deze patstelling te doorbreken?

Banken als bewaker

En dan komt de rol van banken als toezichthouders of bewakers in opdracht van de vele (grotere en kleinere) geldschieters. De banken lossen het meeliftersgedrag en het morele risico op door als intermediair tussen geldschieters en ondernemers op te treden. Ze verdiepen zich in de ondernemers en hun producten en markten en zien toe op een goed bedrijfsmanagement ook op langere termijn. De bank houdt dus toezicht op het risico en rendement van de haar toevertrouwde gelden door het controleren en bewaken van de ondernemers.

Wie bewaakt de bewaker?

Maar we zijn er nog niet. Ook de bank is geen neutrale partij die gratis dingen vanzelfsprekend goed doet voor een hoger doel. Ook een bank is een onderneming die zelf geld verdient en eigen vermogen aanhoudt (en er dus belang bij heeft dat eigen vermogen veilig te houden en anderen het risico te laten lopen als het mis gaat). De vraag is dan dus weer: wie controleert de bank zodat zij hun taak goed uitvoeren, wie bewaakt de bewakers? Hoe weet ik als kleine spaarder dat de bank zijn taak goed uitvoert (moreel risico) en hoe krijg ik als kleine spaarder voor elkaar dat iemand anders voor mij de eventuele controle uitvoert (meeliftersprobleem)? Hier doet de overheid zijn intrede via het bankentoezicht en de depositoregeling. De overheid neemt op deze manier het risico van de schuldeisers van de bank over.

Ontstaan crisis: toezicht omzeild

De wereldwijde crisis heeft uiteindelijk kunnen ontstaan (is mijn lezing van het boek van het CPB) doordat de banken zulke slimme constructies hebben weten te verzinnen dat hun echte verplichtingen deels buiten de balansen bleven en onzichtbaar werden voor de toezichthouders. Toezichthouders hadden onvoldoende zicht op de werkelijke risico’s.

Daarnaast werden banken zich steeds meer bewust dat ze zo groot en belangrijk waren voor de werking van het hele systeem dat niemand het zich kon permitteren ze failliet te laten gaan. Wat betekent dat in termen van de getrapte opbouw van toezicht zoals hierboven beschreven? Dat de uiteindelijke prikkel en noodzaak om toezicht te houden verdween. Dat er een weeffout in de logica was geslopen die het meeliftersgedrag weer volop kans gaf. Omdat banken niet om mogen vallen en de overheid de laatste toezichthouder in de keten van toezicht is, is het de belastingbetaler die uiteindelijk de prijs van mismanagement betaalt. Uiteindelijk betaalt iedereen de prijs en is dus niemand verantwoordelijk. Hierdoor kan iedereen zijn eigen dingetjes doen en korte termijn belangen laten prevaleren zonder dat het hem iets kost.

De moraal van dit verhaal?

Een paar voorlopige conclusies wat mij betreft:

  • Dat toezicht noodzakelijk is en blijft, nu meer dan ooit
  • Dat de keten wordt bepaald door de laatste of zwakste schakel. De overheid moet daarom als ‘zwakste schakel’ van extra wet- en regelgeving worden voorzien. Het CPB boek gaat hier verder op in.
  • Dat effectief toezicht omzeild kan worden bij toename aan complexiteit en ondoorzichtigheid in combinatie met onvoldoende kennis en inzicht bij de toezichthouders.
  • Er is ook nog sprake van wat men in de economie een ‘agency’ probleem noemt (overigens niet als zodanig apart genoemd in de CPB publicatie). Een bank is niet alleen een bank en een ondernemer is niet alleen een ondernemer. Uiteindelijk zijn het personen met hun eigen belangen die concrete taken uitvoeren. Een bank heeft een directeur en een management team. Die voeren officieel de hun toevertrouwde taken uit maar houden daarnaast ook goed hun eigen belang in de gaten (bonussen, carriereperspectief, hobbies, uitstapjes, status etc). De verschillende belangen lopen niet altijd gelijk op. Ook het in de gaten houden van mogelijk divergerende belangen kost geld, de zogenaamde ‘agency costs’.
  • Welke toezichthouder je ook bent: het begint bij het in kaart brengen van de partijen (stakeholders) en hun belangen. Het gaat niet aan om belangen als zodanig ter discussie te stellen. Een belang is wat het is, en dan kun je het maar beter zonder waardeoordeel boven tafel proberen te krijgen. Een belang is wat iemand aanzet tot zijn gedrag en door het niet te benoemen of door het af te keuren verdwijnt het belang immers niet. Ook het belang van de toezichthouder zelf moet hierin worden meegenomen. Als de belangenmatrix helder is, wordt duidelijk waar de belangrijkste problemen en kansen zitten en kan de discussie pas goed starten.


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