“…If capital requirements have to face the only unexpected losses, provisioning policies can reduce their pro-cyclicality, since banks would increase loan loss reserves by making more provisions during an economic expansion, while they would draw from these reserves when the credit losses amount gets higher, as economic conditions deteriorate. This mechanism lies at the basis of the so called "dynamic" provisioning currently adopted in Spain (Pérez et al, 2008;Fern andez de Lis et al, 2000; see also Dermine and Neto de Carvalho, 2008, for an analysis of the peculiar provisioning schedule imposed by the central bank of Portugal). On the contrary, if capital requirements are intended to cover also the expected loss, pro-cyclicality stretches to the provisions as well (see Bouvatier and Lepetit, 2012, for a study showing how in a forward-looking provisioning system, where statistical provisions are used to smooth the evolution of total LLPs, the issue of pro-cyclicality of loan market fluctuations does not exist).…”