Staff Discussion Notes showcase the latest policy-related analysis and research being developed by individual IMF staff and are published to elicit comment and to further debate. These papers are generally brief and written in nontechnical language, and so are aimed at a broad audience interested in economic policy issues. This Web-only series replaced Staff Position Notes in January 2011.

This study assesses the overall impact on credit of the financial regulatory reforms in Europe, Japan, and the United States. Long-term cost estimates are provided for Basel III capital and liquidity requirements, derivatives reforms, and higher taxes and fees. Overall, average lending rates in the base case would rise by 18 bps in Europe, 8 bps in Japan, and 28 bps in the United States. These results are similar to the official BIS assessments of Basel III and an OECD analysis, but lower as a result of including expense cuts and reductions in the returns required by investors. As a result, they are markedly lower than those of the IIF.

We show that distortion in the size distribution of banks around regulatory thresholds can be used to identify costs of bank regulation. We build a structural model in which banks can strategically bunch their assets below regulatory thresholds to avoid regulations. The resulting distortion in the size distribution of banks reveals the magnitude of regulatory costs. Using U.S. bank data, we estimate the regulatory costs imposed by the Dodd-Frank Act. Although the estimated regulatory costs are substantial, they are significatnly lower than those in self-reported estimates by banks.

Critics of health, safety, and environment regulation have sought to buttress the case against regulation by citing a 2010 report by economists Nicole Crain and Mark Crain called The Impact of Regulatory Costs on Small Firms. Among the Crain and Crain report's findings is one that has become a centerpiece of regulatory opponents' rhetoric: the “annual cost of federal regulations in the United States increased to more than $1.75 trillion in 2008.” It's easy to see why the anti-regulatory critics have seized on the Crain and Crain report and its findings. The $1.75 trillion figure is a gaudy number that was sure to catch the ear of the media and the general public. Upon examination, however, it turns out that the $1.75 trillion estimate is the result of transparently unreliable methodology and is presented in a fashion calculated to mislead. This report points out the severe flaws with the effort by Crain and Crain to estimate total regulatory costs. These flaws include: Omitted benefits of regulation. A discussion of regulation is inherently incomplete - and distorted - if it focuses on costs without also considering benefits. The Crain and Crain report simply ignores the benefits of regulation, focusing solely on one half of the equation. Questionable assumptions and flimsy data. The report's estimate of “economic regulatory” costs - financial regulations, for example - which account for 70 percent of the total regulatory costs, is not based on actual cost estimates. Instead, this estimate is based on the results of public opinion polling concerning the business climate of countries that has been collected in a World Bank report. Opaque calculations. Contrary to academic and government norms, Crain and Crain do not reveal their data or show the calculations they used to arrive at their cost estimates. As a result, it is impossible to replicate their results, a flaw so significant it would prevent the publication of their paper in any respectable academic journal. Slanted methodology. The Crain and Crain report suffers from several methodological problems, all of which tilt the results towards an overstatement of regulatory costs. Overstated costs. To estimate the cost of non-economic regulation, Crain and Crain almost always used the agency estimates of such costs that were submitted to OMB. Although OMB presents these costs as a range, Crain and Crain always used the upper bound estimate, effectively eliminating the agencies' careful efforts to draw attention to the uncertainties in these calculations. Moreover, cost estimates are typically based on industry data, and regulated entities have a strong incentive to overstate costs in this circumstance. Peer review rendered meaningless. The peer review process used by the SBA Office of Advocacy does not support the reliability of the report. Only two people examined the document. The authors ignored a significant criticism raised by one of the two reviewers concerning their estimate of economic regulatory costs. As for the second person, the entire review consisted of 11 words. This report concludes that the Crain and Crain report is sufficiently flawed that it does not come close to justifying regulatory reform efforts, re which seek to limit protection of people and the environment. If Crain and Crain had used a more straightforward and generally accepted methodology, they likely would have reached a figure that was several orders of magnitude smaller. And, if Crain and Crain had properly considered regulatory benefits, they likely would have found that regulation is a net economic plus for society.

The aim of this article is to offer a simple framework for estimating the benefits and costs of anti-money laundering regulation, based on a prudent estimation of the economic value of the worldwide money laundering. Using the multiplier model of the relationship between criminal markets revenues and money laundering activities and data for 2004, the value of money laundering is equal to US$ 1.2 trillions (2.7%of the world GDP), while the maximum theoretical benefit in combating money laundering using financial regulation - in steady state - is equal to S$ 280 billion (0.6% of the world GDP). If the aggregate figures keep to the previous more conservative estimates, the methodology is the crucial innovation. The estimates are the product of a explicit macro framework, and they can be replicated, improved using more consistent data, or contrasted implementing alternative models.

Staff Discussion Notes showcase the latest policy-related analysis and research being developed by individual IMF staff and are published to elicit comment and to further debate. These papers are generally brief and written in nontechnical language, and so are aimed at a broad audience interested in economic policy issues. This Web-only series replaced Staff Position Notes in January 2011.

This paper examines the extent to which accounting systems separately identify all the costs of environmental regulation. We estimate the relation between the quot;visiblequot; cost of regulatory compliance (costs that firms' accounting systems correctly classify as quot;environmentalquot;), and quot;hiddenquot; environmental costs embedded in other accounts. We use plant-level data from 55 steel mills to estimate hidden costs, and we follow up with structured interviews of corporate-level managers and plant-level accountants. Empirical results show that a $1 increase in the visible cost of environmental regulation is associated with an increase in total cost (at the margin) of $10-11, of which $9-10 are hidden in other accounts. The findings suggest that inappropriate identification and accumulation of the costs of environmental compliance are likely to distort costs in firms subject to environmental regulation.