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DEVELOPING MACRO-STRESS TESTS SESSION 9 1 MINDAUGAS LEIKA MACROPRUDENTIAL POLICY FRAMEWORK I. Macroprudential policy definition, targets, policy transmission channels and relationships with other policies (Monday) II. Institutional structure (Tuesday) III. Policy tools (Tuesday) 2 IV. Risk identification and quantification: stress testing (This lecture) AGENDA What is macro stress testing? Macro stress testing framework Macro ST process Use of stress tests 3 Did STs fail? FINANCIAL STABILITY ANALYSIS Qualitative judgment Quantitative analysis Risks and vulnerabilities Stress-testing Transmission mechanism Sensitivity analysis, forecasts 4 Shocks HOW CAN WE GROUP RISKS: A) Credit risk B) Market risk Usually arises gradually C) Liquidity risk Arise instantly 5 D) Operational risk (e.g. failure of SWIFT, software etc. BoE quantifies this) WHAT IS THE PURPOSE OF MACRO STRESS TESTING? Provide quantitative and forward looking assessment of the capital adequacy of the banking system*. Accountability to the public Decision-making support Measuring the impact of systemic risk *Source: Bank of England (2013). A framework for stress testing the UK banking system. 6 Macro prudential policy tool: addresses banking system vulnerabilities (capital buffers, exposures to particular sector, absence of diversification, capital planning, investor confidence etc.) WHY MACRO STRESS TESTING: TWO CONCEPTS OF LOSSES There are two concepts linked to risk mitigation techniques: I Expected losses (loan loss provisions, loan impairment charges); II Unexpected losses (economic capital). Expected losses are mean loss rate, i.e. amount that bank reasonably expects to lose. Expected losses are usually covered by loan loss provisions or loan impairment charges. It is called known part of losses. Unexpected losses represent volatility of losses, i.e. unknown part. Shareholders equity is used to absorb these losses. We have to presume, that banks not only need capital to absorb these losses, but also have to stay above minimum regulatory capital requirements through the full business cycle. 7 The targeted level of unexpected losses depends on two factors: minimum capital requirements and targeted rating. EXAMPLE I Example: Bank has 100 bn in assets with 100% risk weight. Average interest rate is 8%. Shareholders equity is 8 bn (CAR 8%). Liabilities (deposits and bonds) is 92 bn. Average return on liabilities is 4%. At the end of the year bank expects to receive 8 bn in return from its assets and pay to debt holders 3,68 bn. Return to shareholders is 4,32 bn. However, if bank’s expected losses are 3% (PDs), return to shareholders is lower (return to debt holders is fixed!): 4,32-3=1,32 bn. 8 What happens, if during an economic downturn, PDs increase up to 8% ? Bank’s losses are much higher than expected and equal to 8 bn. In this case, bank’s income is equal to its losses: 8bn8bn=0. Bank’s payments to debt holders is fixed, hence bank needs to tap its capital base to pay interest rate: 8-3,68=4,32 bn capital left. That’s below minimum CAR of 8%. Bank needs to be closed or recapitalized. EXAMPLE II How much additional capital bank needs to hold? Bank provisions 3% for expected losses and needs additional reserves of 5 bn just to have zero profit. In this case return to its shareholders is 0. To come up with the worst case scenario, and calculate additional reserves, we need to perform a stress test and model expected and unexpected losses. Under Basel II IRB approach we have to model PDs, LGDs. EADs are given. Losses are expressed as: Expected losses=PDs x LGDs x EADs Under Basel II STD approach non IFRS and Basel I we model loan loss provisions (LLPs): ∆LLPs=∆NPLs x provisioning rate 9 Unexpected losses can be measured as a number of standard deviations from expected losses (VaR concept). FROM SHOCKS TO THEIR OUTCOME: HOW TRANSMISSION MECHANISM WORKS Credit risk Non- financial corporate sector Shocks originating in Real sector Real estate sector Households Transmission channels: exposure Public sector Banks Shocks originating in Financial sector Insurance companies Other institutions Payment systems Feedback effects Transmission channels: common ownership, exposure etc. 10 Market, liquidity, counterparty, contagion risks Financial institutions: profit/loss, capital MACRO CREDIT RISK STRESS TESTING MODEL Real estate prices: collateral value for LGD calculation Macroeconomic forecasts CB’s macro model GDP, Housing prices, interest rates, FX rate, unemployment Short-term equations with AR(1) terms and/or ECM: NPLs depencence on selected macro variables calculated for 1 to 4 quarters Long-term equations: NPLs depencence on selected macro variables calculated up to 3 years Equations on a bank-by-bank basis Banking sector data Loan migration matrix Projected additional provisions On a bank-by-bank basis NPLs, provisions, credit growth FX risk, concentration risk, income/expense, duration gap models Unexpected losses Monte-carlo simulation Projected net losses/profit CAR Number of banks that do not meet minimum CAR 11 Banking sector data Interest income, expenses, credit growth, doeposits, interest rate etc. 12 TOP-DOWN STRESS TESTING FRAMEWORK THREE TYPES OF MODELS FOR MACRO STRESS TESTING I Portfolio models (Credit Risk plus; Risk Metrics; Credit Portfolio View etc.) II Balance sheet models (Cihak, Boss et all. and modifications). III Market data based models (CCA). 13 First type of models dominate in private sector, second and third type dominate in regulatory institutions. 14 MACRO ST PROCESS Increase capital buffers Reduce RWA Reduce exposure Review concentration limits etc. 15 Losses are calculated using either sensitivity or scenario analysis or both approaches Losses in terms of CAR are presented Actions Main risks are identified and scenarios constructed. III types of scenarios: I economic/industry downturn II market risk events III liquidity crisis Loss calculation and mapping Risk identification MACRO ST PROCESS UNDERSTANDING THE INCENTIVES There are at least three stakeholders in the stress-testing process: financial institutions, regulators and the public/markets. 16 Usually they have different incentives: regulators want more data, more time, more extreme scenarios; financial institutions want to provide less data, use in-house models, usually less extreme scenarios. Regulators want to find the weakest components of the banking system, whereas institutions want to show resilience. Public wants “blood”- know institutions that fail the test. MACRO STRESS TESTING STEPS Determine the objective of the stress test Design scenario Perform stress test Calculate stress losses Report results 17 Determine actions Pillar I Pillar II Pillar III Minimum capital Supervisory review Market discipline Minimum capital requirement; point in time assessment Individual capital guidance: Pilar I risks+additional (bank specific) risks Stress tests ICAAP: Internal capital adequacy assessment process; Calculation of economic capital 18 BASEL II/III SCENARIO DESIGN (1) High probability Low probability High impact Main focus Watch Low impact Summary mention Ignore 19 Shock matrix SCENARIO DESIGN (2) Risk mapping: from systemic risks to exogenous shocks Scenario design Shock calibration Risk correlation Macroeconomic models Scenario output: macro and financial variables Adverse scenario 20 Baseline scenario HISTORICAL EXPERIENCE 21 Credit risk depends on the state of economy (business cycle) DEFINING THRESHOLDS Expected (mean losses) E[x]=μ(x) P(X) Pass/Fail criteria and minimum capital requirements Confidence interval is identical to default probability: A AA BBB AAA 0,07% 0,03% 0,01% 0,1% Economic capital Expected shortfall Loss 22 Loan loss provisions APPLYING SHOCKS: NORMAL AND SHOCKED PDF P(X) X2 represents shocked PDs, and as it has higher variance, it bears more risk than X1 Loan loss provisions Loan loss provisions Economic capital Economic capital X2 Expected shortfall Loss 23 X1 LOSSES AND BUSINESS CYCLE X1=f(GDP↑, FX rate, Unemployment↓, Interest rates↓, Concentration↓ etc.) X2=f(GDP↓, FX rate, Unemployment↑, Interest rates↑, Concentration↑ etc.) P(X) X1 represents upward trend X2 represents downward trend X1 Loan loss provisions Economic capital Expected shortfall Loss Economic capital 24 Loan loss provisions X2 25 CALCULATING LOSSES CALCULATING CAR Current Tier I and II capital (regulatory capital) Current RWA for: credit, market and operational risks Satellite credit growth model Migration matrices Loan loss provisions; Forecasted from satellite credit loss model 26 Net income before loan loss provisions; Forecasted from satellite income model Loan loss provisions; Forecasted from satellite credit loss model 27 USE OF STRESS TESTS THEORETICAL USE OF STRESS TESTS What answers stress tests should provide: How much capital a bank needs to support its risk taking activities? (Forward looking) Is the current level of capital adequate? (Present) Lehman Brothers, Bear Stearns, Dexia, JP Morgan…. Did they do it right? 28 Capital that is available vs. Capital that is needed vs. Capital that regulators need. ACTUAL USE OF STRESS TESTS DURING THE CRISIS Stress tests popped out as a tool to address loss in public confidence Confidence was boosted by disclosing individual banks’ results, scenarios and data about exposures 29 SCAP (US) vs. EBA (EU). STS BEFORE AND AFTER CRISIS After Very little public disclosure, usually : “All banks are adequately capitalized, however challenges remain, thus we will be vigilant” Comprehensive analysis, data available on a bank by bank basis. Not all banks pass tests, capital shortfalls are public Static analysis Dynamic analysis Usually single shocks, VaR based Macro based, multiple scenarios, dependency among various risk factors, CoVaR In most cases solo, individual entity based Consolidated at the parent (group) level Simple models, usually for credit and market risk separately Comprehensive models: credit, market, liquidity risks and lost income Not necessarily linked to CAR Linked to CAR No macroprudential measures or capital conservation plans Macroprudential measures (system wide) and capital conservation plans (individual) 30 Before CAN STRESS TESTS DETECT SYSTEMIC RISKS? In theory, macroprudential STs should unveil the sources of systemic risk (see IMF (2012) In practice, sources indeed were identified correctly (e.g housing market in the US, contagion from Greece in the EU etc). 31 Magnitude of shocks and subsequently their impact was miscalculated 32 DID STS FAIL? WHY STRESS TESTS CAN FAIL? (1) We can find many “wrongs”: Wrong models: too complex Wrong (absence of) data: where risks were “parked”? Wrong scenarios: underestimation of tail risk events and contagion effects Wrong incentives: no need to rock the boat, public will not understand Wrong scale: “shadow institutions” escaped 33 Wrong policy measures WE CALCULATE ECONOMIC CAPITAL USING 2 OR THREE STANDARD DEVIATIONS….. 34 If we use a normal distribution, two standard deviations from the mean means we still have almost 5 percent of observations outside of our horizon (2,5 percent in each tail). This means, we overestimate earnings and underestimate losses. HOWEVER DURING THIS GLOBAL FINANCIAL CRISIS VOLATILITY WAS MUCH HIGHER….. In August 2007, the Chief Financial Officer of Goldman Sachs, David Viniar, commented to the Financial Times: “We are seeing things that were 25-standard deviation moves, several days in a row”. As Andrew Haldane, executive director at the bank of England noticed: 35 “Assuming a normal distribution, a 7.26-sigma daily loss would be expected to occur once every 13.7 billion or so years. That is roughly the estimated age of the universe. A 25-sigma event would be expected to occur once every 6 x 10124 lives of the universe.” 36 VOLATILITY DEPENDS ON TIME PERIOD (SAMPLE FROM HALDANE (2009)) 0.09 0.07 0.08 Default rates observed historically Default rates during crisis Model estimated historically Model during crisis 0.06 Asset default rate 0.10 DRAFT: COMMENTS WELCOME A HYPOTHETICAL EXAMPLE OF A FACTOR WHOSE RELATIONSHIP TO DEFAULT IS NOT CLEAR UNTIL Figure 4 Hypothetical example of a factor whose relationship to default is not A CRISIS PUSHES ITclear TOuntilNEW LEVELS a crisis pushes it to new levels 2 4 6 8 10 Hypothetical macro-economic factor 37 Source: S&P (2010) First, the underlying relationships between a macro-economic factor and, (e.g.) the default rate of an asset may be non-linear in a way that makes it hard to understand the true relationship from historical data. Figure 4 shows an example of this type of “different” behavior during a crisis. In this example, it is not until a key macro-economic factor be- BIMODAL NATURE OF RATING TRANSITIONS 38 Source: Moody’s (2013) Stress Testing of Credit Migration. A Macroeconomic approach. WHY STRESS TESTS CAN FAIL? (2) 39 Underestimated probability of adverse outcomes (disaster myopia) Reluctance to include severe scenarios Willingness to hold capital under less extreme scenario only Postponement of crisis Reverse engineering: scenarios are such, that bank never violates minimum CAR Short time series in emerging market countries Data quality issues We usually never look beyond economic capital! Historical scenarios are based on historical data. We can not test anything new using data from the past only REDUCED FORM VS. FULL-SCALE STRESS TESTS Most of the stress tests banks do are reduced form stress tests Reduced form – Monte Carlo simulation Full scale – links with macro variables. Correlations 40 Why reduced form? If probabilities are unknown, we face uncertainty. In this case randomization is an answer. WHY REDUCED FORM IS NOT SUITABLE FOR MACRO STS Reduced form does depend on assumptions about distribution. Beta distribution has fatter tails than the normal one Reduced form ST has very little connection with macro variables Is opaque 41 Is good, once we deal with random, uncorrelated price movements or volatilities. Is not suitable, once we deal with systemic events or highly correlated movements How to incorporate balance sheet adjustments into core models? How to avoid modeling partial equilibrium situations only, i.e. include feedback effects and adjustments in broader sectors of economy? How to model nonlinearities? System’s stability is most vulnerable then nobody anticipates shocks, i.e. risks are underpriced, real estate prices are at their peaks, GDP and credit grows fast. How to model aggressive risk taking and rapid build-up of imbalances? How to model financial innovations and market liberalization (historical data are not available at all or structural breaks emerge)? How to extend stress tests to other (non-bank) financial institutions? 42 THE WAY AHEAD IMPORTANCE FOR MACROPRUDENTIAL POLICY Based on Borio, Drehmann and Tstatsaronis (2012) objective of the stress tests is to support crisis management and resolution. Drilling down we can formulate this objective more precisely: a) calculation of how much capital should be injected into the system to prevent credit crunch; b) Identification of weakest financial institutions; c) signaling to the market about losses and restoring confidence in the banking system; d) Improve risk management practices, models and data collection; 43 e) Story telling: use stress tests to describe shocks, transmission channels and possible impact on financial system and broader economy. SEVEN BEST PRACTICE PRINCIPLES PROPOSED BY THE IMF 1. Define appropriately the institutional perimeter for the tests. 2. Identify all relevant channels of risk propagation. 3. Include all material risks and buffers. 4. Make use of the investors’ viewpoint in the design of stress tests. 5. Focus on tail risks. 6. When communicating stress test results, speak smarter, not just louder. 7. Beware of the “black swan.” 44 Source: Macrofinancial Stress Testing—Principles and Practices (2012) WHAT TO DO? Do not constrain yourselves with historical experience and scenarios (it is not contrary to the “this time is different” syndrome, i.e. one should think that worst crisis might repeat again or my country is not necessarily too much different from the ones that experienced crisis earlier) Use judgmental adjustments in scenarios Use reverse stress testing more often to find break-even points (especially important in liquidity stress-testing) Make it simple. Last CCAR (2013) emphasized simplicity. Simplicity means no complicated “black box”: executives should be able to understand and supervisors to verify 45 In the end, follow the advise by J.M. Keynes: “It is better to be roughly right than precisely wrong”