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Pro-cyclicality of accounting standards: an overview Paolo Angelini Banca d’Italia Florence, 18 September 2009 The views expressed in this presentation are the author’s own and do not necessarily reflect those of the Bank of Italy Outline of presentation 1. A macro perspective: The (new) financial accelerator. The role of leverage 2. Accounting standards: impact on procyclicality 3. Corrective actions What is pro-cyclicality? Financial sector pro-cyclicality: features of the fin. system that amplify the cyclical fluctuations of the economy The (New) financial accelerator • Little o no money&finance in macro models until the late nineties • Recent developments: • Kyiotaki and Moore (1997), BGG (1999): Demand side financial frictions (the financial accelerator) • Current crisis is contributing to change • Flourish of DSGE models including supply side financial frictions (the “new” financial accelerator; Adrian and Shin, 2008) The (New) financial accelerator A L Loans 50 Capital 10 Shares 50 Deposits 90 100 100 Leverage =100/10=10 The (New) financial accelerator Assume a shock to share prices: A L Loans 50 Capital 5 Shares 45 Deposits 90 95 95 Leverage =95/5=19 ! The (New) financial accelerator If operators do not adjust leverage, no feedback: Equilibrium before shock Asset prices New equilibrium Leverage The (New) financial accelerator If operators have leverage target, will try to reduce leverage by selling assets / liquidating deposits Targeted leverage Asset prices Excessive leverage Leverage The (New) financial accelerator • Empirical evidence on this mechanism? FINANCIAL ASSETS AND LEVERAGE IN THE US: HOUSEHOLDS Total assets growth, % QoQ Leverage growth, % QoQ Source: Adrian & Shin (2008) FINANCIAL ASSETS AND LEVERAGE IN THE US: COMMERCIAL BANKS Total assets growth, % QoQ Leverage growth, % QoQ Source: Adrian & Shin (2008) FINANCIAL ASSETS AND LEVERAGE IN THE US: INVESTMENT BANKS Total assets growth, % QoQ Leverage growth, % QoQ Source: Adrian & Shin (2008) FINANCIAL ASSETS AND LEVERAGE: MONETARY&FINANCIAL INSTITUTIONS (MFIS) Total assets growth, USA UK DE FR IT JAP % QoQ Leverage growth, % QoQ Source: Panetta&Angelini (2009) GDP AND LEVERAGE: MONETARY&FINANCIAL INSTITUTIONS (MFIS) USA UK GDP growth, DE FR IT JAP % QoQ Leverage growth, % QoQ Source: Panetta&Angelini (2009) Summing up: • Not obvious that NFA is at work in normal times Not obvious that pro-cyclicality was a major cause of the current crisis • However, NFA was clearly major amplifier of current crisis Factors affecting NFA/pro-cyclicality • • • Technological progress Financial globalization (chart) … • • • • Capital regulation (Basel II) Managers incentives …. Accounting: Fair value accounting FVA: Main innovations 1. Fair Value principle 2. Classification according to holder intention 3. Prohibition to accumulate generic reserves FVA: 1. Fair Value principle • The amount for which an instrument “could be exchanged between knowledgeable, willing parties in an arm’s length transaction” • Level 1, 2 , 3 assets: 1. Observable market prices (mark-to-market) 2. Comparable instruments or models w/ observable inputs 3. Mark-to-model (thin or no mkt; ABS, CDOs, …) FVA: 1. Fair Value principle Implications for pro-cyclicality: FVA immediately transposes asset price changes into balance sheets Gains/losses feed immediately into New Financial Accelerator FVA: 2. Classification based on intention Balance sheet P&L L&R, HTM Amortised cost less impairment Not m-to-m, unless impaired AFS Fair value Not m-to-m, unless impaired HFT, FVO Fair value m-to-m FVA: 2. Classification based on intention Implications for pro-cyclicality Potential for increased discretionality in representing accounting situation increased opacity reduced market liquidity when confidence evaporates wider asset prices swings feed into NFA Increased discretionality: examples 1. Mark-to-model done using proprietary models 2. Distorted use of HFT 3. Hedge accounting (detail) 2. + 3. excessive recourse to FV valuation. At some banks, assets in FVO+HFT exceeded 50% of total assets, with peaks above 70% FVA: 3. Prohibition of generic reserves • Narrow accounting definition of expected losses: impairment losses must be actually incurred • Prudential reserves eliminated • Objective of prohibition: reduce managers’ discretionality, enhance accounts transparency FVA: 3. Prohibition of generic reserves Implications for pro-cyclicality • Reduced income smoothing, stronger expansion of lending in booms and contraction in downturns FVA: other issues • Treatment of liabilities • Liabilities still largely carried at historical cost (chart) • Valuing liabilities at FV would clearly reduce pro-cyclicality • However, paradox might emerge FVA: other issues • Treatment of goodwill • HCA: buyer amortizes goodwill • FVA: goodwill is indefinite lifetime asset, but subject to annual impairment test, with losses affecting the P&L account • In good times pro-cyclical M&A contribute to expansion of balance sheets • In bad times impairment testing causes losses on goodwill to emerge, further depressing profits FVA: other issues • Treatment of risks • HCA: risks play no role • FVA: implicitly endorses the market estimate of risk – a huge improvement • However: if market prices understimate risk, so does fair value • Key observation: Risks tend to materialize in downturns, but to accumulate in booms (Borio and Lowe (2001)) (charts) The role of FVA should not be overemphasized • Many “mechanisms” pre-date adoption of FVA: • Mark-to-market of certain assets (derivatives, traded shares) • Haircuts, margin calls • The underestimation of liquidity risk can hardly be ascribed to FVA • SIVs existed well before FVA Possible corrective actions Going back to historical cost accounting?? • Estimating a phenomenon based on one observation is never good statistical practice Kalman gain • In principle, HCA is strictly dominated by FVA Possible corrective actions • Excessive recourse to FVA should be prevented (e.g. a minimum turnover rate/maximum holding period could be set for the inclusion in the HFT portfolio) • Consolidation and derecognition rules should be improved (not a problem of FV) The treatment of special purpose entities is decisive in assessing leverage and hence pro-cyclicality Possible corrective actions • Prohibition of generic reserves: Critical issue, at the joint between accounting and regulation • Solution requires agreement between supervisors and accountants Possible corrective actions • Two cornerstones of the current system: 1. capital requirements unexpected losses 2. provisions expected losses Possible corrective actions 1. Capital requirements: adopt mechanisms which reduce pro-cyclicality while preserving the risk measurement improvements introduced by Basel II • Adjust the inputs, the output or the parameters of the regulatory function (detail) • Recent proposal by CEBS: (i) replace current PDs with downturn PDs in the regulatory function; (ii) use outcome to set capital buffers under Pillar 2 Possible corrective actions • CEBS proposal: – Flexible, does not affect P&L solves conflict with accounting rules – Discretionary ( opacity, level playing field concerns), risk of regulatory forbearance in good times Possible corrective actions 2. Broaden the accounting concept of expected losses, acknowledging that they increase in good times • Dynamic provisioning (Spain): Gt= Gt-1 + gt gt = αΔLt + Lt - current losses • Compatibility with accounting principles? Possible corrective actions • Provisions/valuation reserves should not be restricted to credit risk: • • • • Model risk (level 2-3 assets, mark-to-model) (chart) Illiquid assets Maturity mismatches New financial instruments Latest developments • IASB: use of FV likely not reduced • FASB: use of FV likely increased • Risk of divergence across the Atlantic Financial vs trade integration Source: Lane&Milesi-Ferretti (2007) (back) Fair value hierarchy Source: Panetta&Angelini (2009) (back) Hedge accounting Hedge is “highly effective”? • Yes both the derivative and the hedged item (only part hedged) valued at FV • No hedged item: • entirely valued at amortized cost • entirely valued at FV strong incentive to resort to estimates and to excessively expand share of instruments at FV (back) Share of Bank Assets and Liabilities Valued at Fair Value (December 2007) % Source: Panetta&Angelini (2009) (back) Ratings drift and GDP growth Source: Panetta&Angelini (2009) Default rates and GDP growth Source: Panetta&Angelini (2009) Implied volatility: 1 year euro swap rate Source: Thomson Financial Implied volatility: 1 year dollar swap rate Source: Thomson Financial Implied volatility: euro area stock market (VSTOXX) Source: Thomson Financial Implied volatility: US stock market (VIX) Source: Thomson Financial (back) The Basel II capital function K = Capital requirement PD = Probability of default LGD = Loss given default = Correlation among borrowers = Normal c.d.f. (back)