A week full of confusion that just ended in relation to the long-awaited reform of cooperative credit. After the announcements of the "here we are, it's done!" movement, or the "self-reform project goes to the Council of Ministers on the 11th to receive the government's endorsement and the identification of the acts necessary for its launch", we moved on to clarifications from government sources that nothing on the subject was included in the agenda for that date, to then arrive at the meeting of Iccrea Holding in which the level of disintegration manifested itself plastically. We are still on the high seas, the few certainties have melted like snow in the sun, the level of conflict has exploded with the cry "this reform has nothing to do due to its blatant unconstitutionality!".
But perhaps the less explicit critical positions are even more numerous (and insidious). Many CCBs, single or grouped together in sub-groupings, believe they are in a position to oppose the plan to bring into a single group, led by a bank holding company in the form of a joint-stock company, with absolute powers in matters of Governance, Strategies, Production Choices and Technological, the 380 mutual banks scattered throughout Italy. And so far the references to the principles of cooperativism, to the centuries-old history of the Movement and to attempts to demonstrate the benefits of the reductio ad unum, rationalizing a system characterized by too many redundancies, have been of no use.
On the other hand, autonomistic claims, individualisms and even wishful thinking are strengthened, one proceeds in random order, or rather by cultivating the hope of one's own reform, claimed as the best. I don't intend to waste time analyzing the differences between the various proposals, simply because there are no differences, since all of them, as I have already written, lack industrial design. Instead, let us consider the possible effects of the current stalemate, with some schematizations that we hope will not appear excessive.
A) the Government, worried by a possible dispute corroborated by the threatening tones of those waving risks of unconstitutionality, lets go, gets out of the question, leaves everything as it is. Let the CBs fend for themselves, perhaps entrusting the solution to the problem to the Bank of Italy, and let's wait to see how it turns out. Knowing the decision-making of the current executive and the goodwill effort already made, accepting the excerpt concerning the reform of this segment of banks with respect to the changes introduced by decree relating to the "popular", it seems to me a very unlikely hypothesis and in any case read also point D) about the effective decision-making autonomy of national legal systems in the new European context in matters of banking policies.
B) the Movement definitively takes note of the lack of representation and of the responsibilities connected with the present and serious criticalities of the cooperative banking system, referring them to the current top management and promotes their replacement. Restoring the authority of the Governance could restart the process of sharing the changes to be introduced. This hypothesis does not seem entirely to be excluded, also given the willingness of some exponents to vacate important top management positions. But we still have to wait. It should be noted that the renewal of the top bodies, as a result of external pronouncements, to be understood by the Authority, in addition to being more effective, would also be more consistent with the worried and repeated analyzes on the state of health of cooperative credit, for the improvement of which it has not yet been possible to pass from words to deeds. Indeed, the situation has progressively deteriorated, attracting the criticism of "vox clamans in desert" towards the Authority itself.
C) With respect to the unitary project, compromises of various kinds are beginning to be accepted (several groups instead of a single group, individual derogations, way out towards the popular bank or joint-stock bank model based on alternative projects lacking objective motivations). In that case, the reform would essentially fail, leaving some more or less satisfied with having obtained some individual recognition. In short, an Italian solution, identifiable with the Gattopardesco saying of "everything changes so that nothing changes", in yet another, but also pathetic, attempt to buy some time. It would certainly not be the wish to formulate for the good fortune of the cooperative banking movement, given that, in doing so, the situation would become definitively unmanageable, in all probability requiring the direct intervention of the ECB.
D) At this point, the only thing left is to talk about the non-sustainability of this situation in the European perspective. The reform, which must operate with the objective of strengthening the capital and risk sharing of the members, is fully integrated in this context in that a) the Iccrea group has assumed the nature of a significant entity in terms of systemic risk for the banking market b) the procedures for managing banking crises, as implemented in recent years, are close to being replaced by those envisaged by the new European directives on crisis resolution and on the deposit guarantee scheme. Entry into force: 1 January 2016. Underlying technicality: clear identification of situations of structural imbalance, involvement of several stakeholders (shareholders, bondholders, large depositors) with non-derogable order of priority for the sacrifice to be made in the event of default, operation of the Guarantee Fund limited to a maximum repayment of 100.000 euros per deposit.
As can be understood, the rescue of the intermediary in crisis with the means of the Fund is not the primary objective of this scheme; compulsory liquidation will become the most common case in determining the exit from the market of the bank which is no longer competitive. For the movement, the reputational risk will become very concrete because the schemes now in use, based on the conservation of the species even in uneconomical conditions, have raised the accusation of state aid from the European bodies responsible for protecting competition and must therefore abandoned. It must be said, but at the level of the various structures of the Union, including the ECB, there does not seem to be a very positive sentiment these days regarding our banking system and our rules which have often artificially kept alive banks marked by crises for some time not reversible.
E) Lastly, it would be necessary to return to the theme of those BCCs that intend to escape, by presenting credible projects, the more or less narrow meshes according to which the aggregative reform will be articulated. This credibility is based, for the writer, on the close interdependence between Governance and Technology, necessary for the real renewal of banking localism. These projects are complex and require investment skills in banking innovation. Therefore, the simple desire to transform into a cooperative bank or joint-stock company is not enough to formulate requests for derogation, but a careful assessment of the sustainability of alternative paths which are by definition within the reach of a few and to which the aggregation of several mutual banks gives per se profiles of objective robustness.
Maybe I'm wrong, but with the various proposals outlined so far, the issue of consolidation seems to be definitively out of the picture. In conclusion, the (self) reform of cooperative credit is not only the search for a new structure to improve efficiency conditions, but the very model for the survival of the system, where there will be less and less room for tailor-made solutions, as policies mainly dedicated to unifying very different national systems. From now on, the assessment of the effective situation of the banks and the consequent action by European banking supervision will be increasingly clear-cut: black and white and not the "fifty shades of grey" with which for too long it has aimed to safeguard the numerous and expensive Italian peculiarities. Wouldn't this be enough to quickly promote the self-reform needed to secure the system?
