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Macroprudential policy – a framework Jan Frait Executive Director Financial Stability Department „ … in tracking systemic risk … we should avoid a false sense of precision … it is better to be approximately right than precisely wrong“ Claudio Borio, BIS (2010) 2 I. Concept of Macroprudential Policy 3 What is a „macroprudential“ policy? • Following the global financial crisis, on the global, the EU level as well as on the national levels the ways how to establish the additional pillar for financial stability – macroprudential policy framework – has been discussed. • Until the crisis, the concept of macroprudential policy was discussed primarily within the central banking community under the leadership of the Bank for International Settlements (BIS henceforth). • After the crisis, the term “macroprudential” has become a buzzword (Clement, 2010) and the establishment of effective macroprudential policy framework has become one of the prime objectives of the G20, EU, IMF and other structures. • In the EU, such a desire has already been reflected in the decision to create the European Systemic Risk Board as the EU-wide authority of macroprudential supervision and by number of iniciatives focusing on defining the EU-wide framework for macroprudential regulation. 4 What is a macroprudential policy? • The term “macroprudential” as applied now is too embracive and often used outside of the scope of its original meaning. • The CNB looks at the concept of macroprudential policies from relatively narrow perspective of the original BIS approach (e.g. Borio, 2003, Borio and White, 2004). • The objective of a macroprudential approach in the BIS tradition falls within the macroeconomic concept and implicitly involves monetary and fiscal policies (Borio and Shim, 2007, and White, 2009). • In the BIS tradition, the phenomenon of financial market procyclicality (mainly the procyclical behaviour in credit provision) stands centrally (Borio and Lowe, 2001, or Borio, Furnine and Lowe, 2001). • The CNB‘s analyses are focused mainly on risks associated with procyclicality, credit cycle in particular. 5 Two credit booms and one bust thus far in the CR • Credit boom in early 1990s followed by sharp increase in credit losses and major financial crisis. • Credit “boom” of 2005-2008 had benign consequences. • What made the difference? Credit cycle in the Czech Republic (1993-2012, v %) GDP growth and credit risk in the Czech Republic (1993-2012, in %) 30 25 65 35 60 30 55 25 10 8 20 15 6 4 10 50 20 2 5 45 15 0 40 10 35 5 30 0 0 -2 -5 -4 -10 -15 I/93 I/96 I/99 I/02 credit growth (MA) I/05 I/08 I/11 -6 -8 I/93 I/99 %NPL credit-to-GDP (rhs) Source: CNB Note: Credit growth is year-over-year increase in total bank credit. % NPL is the share of nonperforming loans on total bank credit. Data from the beginning of 1990s are based on authors' estimates. I/96 I/02 I/05 I/08 I/11 GDP growth (rhs) Source: CNB Note: % NPL is the share of non-performing loans on total bank credit. Data from the beginning of 1990s are based on authors' estimates. 6 What is a macroprudential policy? • Financial market structures matter as well. • The other stream of macroprudential thinking is more micro-oriented and focusing on individual institutions and their mutual interactions. • By comparison with the BIS logic, in this approach systemic risk arises primarily through common exposures to macroeconomic risk factors across institutions, i.e canonical models of financial instability like Diamond and Dybvig (1983) emphasizing interlinkages and common exposures among institutions. • The analyses of this sort (common exposures among institutions, network risks, infrastructure risks, contagion ...) has been intensively studied by the IMF (see special chapters in some Global Financial Stability Reports). • The ESRB analytical work also puts more emphasis on structural issues than conjunctural ones. • The reason is natural – financial cycles differ significantly within EU economies, the ESRB started to operate during financial crisis characterized by number of contagion risk channels. 7 The CNB’s historical interpretation of financial stability • • • Consensus in the central bank community - the financial stability objective is to achieve continuously a level of stability in the provision of financial services which will support the economy in attaining maximum sustainable economic growth. The CNB adopted a definition consistent with this way of thinking about the financial stability objective back in 2004. • It has defined financial stability as a situation where the financial system operates with no serious failures or undesirable impacts on the present and future development of the economy as a whole, while showing a high degree of resilience to shocks. Financial stability analysis as the study of potential sources of systemic risk arising from the links between vulnerabilities in the financial system and potential shocks coming from various sectors of the economy, the financial markets and macroeconomic developments. • The sources of systemic risks can be viewed as externalities associated with behaviour of financial institutions (for details of such approach see Nicolò et al., 2012), and financial markets and their participants (short-termism, myopia, risk ignorance, herding). 8 The CNB’s historical interpretation of financial stability Sound financial system Yes: resilience No Financial stability Yes Financial volatility Shocks • The CNB’s approach to financial stability has historically been strongly macroprudential and close to the relatively narrow BIS interpretation focusing primarily on risks associated with the financial cycle. • Its objective is to ensure that the financial system does not become so vulnerable in the course of cycle that unexpected shocks ultimately cause financial instability in the form of a crisis. No: vulnerability Financial vulnerability Financial instability (crisis) 9 The CNB’s current interpretation of financial stability • Robustness is the key to avoiding vulnerability. • For a bank-based system, robustness can be achieved via high loss absorbency, strong liquidity, barriers to credit boom and plenty of luck. • Loss-absorbency: • expected losses – sufficient provisions (Frait and Komárková, 2009), • unexpected losses – capital cushions, • microprudential (Basel II) component, • countercyclical component (Frait, Geršl and Seidler, 2011; Geršl and Seidler, 2011), • cross-section SIFI component (Komárková, Hausenblas and Frait, 2012). • Strong liquidity (buffers and stable funding) is essential way for limiting fragility of liabilites (Komárková, Geršl and Komárek, 2011). • Some macroprudential tools for creating barriers to credit booms, excessive leverage are needed too. 10 Financial stability vs. macroprudential policy • The CNB considers macroprudential policy to be an element of financial stability policy (Frait and Komárková, 2011). • the other part is microprudential oversight (regulation and supervision) • • The main distinguishing feature of macroprudential policy is that unlike traditional microprudential regulation and supervision (focused on the resilience of individual financial institutions to mostly exogenous events): • it focuses on the stability of the system as a whole; • it primarily monitors endogenous processes in which financial institutions that may seem individually sound can get into a situation of systemic instability through common behaviour and mutual interaction, • the objective of financial stability analysts is therefore avoid the risk of the fallacy of composition – wrong assumption that the state of the whole is the sum of the state of seemingly independent parts, for the trees the forest is not seen. Hanson et al. (2011) mark the microprudential approach as partial equilibrium conception while macroprudential approach as one in which general equilibrium effects are recognized. 11 Macroprudential policy and systemic risk - objectives • The macroprudential policy objective is to prevent systemic risk from forming and spreading in the financial system. • Systemic risk has two different dimensions: • The time dimension (cyclical, conjunctural dimension) reflects the buildup of systemic risk over time due to the pro-cyclical behaviour of financial institutions contributing to the formation of unbalanced financial trends. • The second dimension is cross-sectional (structural dimension) and reflects the existence of common exposures and interconnectedness in the financial system. • The two dimensions of systemic risk cannot be strictly separated, as they largely evolve jointly over the financial cycle. • The experience commands that the time dimension of systemic risk has to be regarded as more important. • Cross-sector dimension cannot be ignored especially due to the risk of contagion from domestic as well as foreign environment. 12 Macroprudential policy and systemic risk - objectives • • • The time and cross-sectional dimensions to a large extent evolve jointly and so cannot be strictly separated. Shin (2010) argues that increased systemic risk from interconnectedness of banks is a corollary of excessive asset growth and a macroprudential policy framework must therefore address excessive asset dynamics and fragility of bank liabilities. • In a growth phase of the financial cycle, rapid credit growth is accompanied by a growing exposure of a large number of banks to the same sectors (usually the property market) and by increasing interconnectedness in meeting the growing need for balance-sheet liquidity. • Financial institutions become exposed to the same concentration risk on both the asset and liability sides. This makes them vulnerable to the same types of shocks and makes the system as a whole fragile. • When the shock comes, banks face problems with funding, their lending is tightened and all market participants try to sell their assets at the same time, which creates the downward spiral in both the financial and the real sectors. The time dimension shows up in degree of solvency, while the cross-sectional dimension manifests itself in the quality of financial institutions’ balance-sheet liquidity. However, solvency and liquidity are also interconnected, as liquidity problems often transform quite quickly into insolvency. 13 Macroprudential policy and systemic risk - definition • Macroprudential policy can be defined as the application of a set of instruments that have the potential to • increase preventively the resilience of the system, in the accumulation phase of systemic risk, against the likelihood of emergence of financial instability in the future by • creating capital and liquidity buffers, • limiting procyclicality in the behaviour of the financial system • containing risks that individual financial institutions may create for the system as a whole. • mitigate the impacts, in the materialization phase of systemic risk, of previously accumulated risks if prevention fails. 14 II. Financial Cycle and Systemic Risk 15 Conseptual approach to macroprudential policy • The key source of systemic risk is financial cycle and one of the key concerns of macroprudential policy has to be containment of procyclicality. • In periods of fast economic growth the financial institutions and their clients may start mispricing the risks associated with their decisions or may even be incentivized to increase the extent of risk taken. • In such periods, access to external sources of financing improves significantly such access is more dependent on current risk perceptions on the side of both banks and their clients, which, in turn, are strongly dependent on current economic activity. • If economic agents start to misconstrue a temporary cyclical improvement in the economy as a long-term increase in productivity, virtuous cycle can start to develop, supported by an increased willingness of households, firms and government to accept a higher level of debt and use it to buy risky assets. • This sets off a spiral (positive feedback loop) manifesting itself as a decreasing ability to recognize risk, trend growth in asset prices, weakened external financial constraints and high investment activity supported by output growth, increased revenue growth and improved profitability. In the background of this cycle, financial imbalances grow and systemic risk builds up unobserved. 16 Conseptual approach to macroprudential policy • Systemic risk often shows up openly later on, when economic activity starts to weaken as a result of a negative stimulus. • Recession subsequently sets in, opposite processes take place, and the spiral turns around. • Economic agents realise that their income has been rising at an unsustainably high rate, they are burdened with too much debt, their assets have fallen in value and so they need to restructure their balance sheets. • Both banks and their clients start to display excessive risk aversion and vicious circle gains momentum. • To a large extent, the processes described above are as natural as the business cycle itself. • However, the financial imbalances can sometimes get too big and, as a result, a dangerous vicious cycle can arise in the contraction phase. • If the desirable adjustment is combined with strong increase in general and with fire-sales of overvalued assets, the downward movement can become extremely rapid and destabilising. 17 Credit cycle and systemic risk – the case for forwardlooking approaches in conduct of macroprudential policy • In a credit cycle, systemic risk evolves differently in two stages: accumulation (build-up) and materialization (manifestation). • Note the financial (in)stability paradox: a system is most vulnerable when it looks most robust. Build-up of systemic risk period of financial exuberance Materialisation of systemic risk period of financial distress period of low current risk time period of high current risk time normal conditions marginal risk of financial instability degree to which risks materialise as defaults, NPLs and credit losses 18 Good booms, bad booms and systemic risk • It is difficult to convince people of the system heading into a big mess, after all a tranquil situation of this sort does not always mean that the financial system accumulates systemic risk dangerously. • A low level of risk indication can simply mean that a truly good and longlasting boom is under way. • At any particular point in time it is likely that some indicators are giving contradictory results. • The financial instability paradox occurs only occasionally and irregularly. • Still, the analysts have to keep in mind the risk of being trapped by the financial instability paradox, i.e. that unusually good values of current indicators signal a growing risk of financial instability. • One can be rather sure that if credit and some asset prices are going up quickly and moving away from historical norms, and both the quantitative and qualitative evidence indicates excessive optimism and mispricing of risk, there is a problem ahead, unless decision-making bodies take action. 19 Paradox in practice – the case of Irish boom and bust • Remember Ireland – it looked so well in 2007: • real-estate-price gap and credit-to-GDP gap indicated exuberance, • sources of systemic risk may be increasing when banks and their clients consider their business risks to be the lowest - non-performing loans ratio close to zero “indicated“ resilience. Ireland (end 2007 vs. June 2010) (credit risk ratios in %) 80% Leading Indicators of Systemic Risk Accumulation in Ireland Coverage ratio (provisions to NPLs) 60 40 20 0 -20 60% 40% 20% 0% 0% -40 I/00 I/02 I/04 I/06 credit-to-GDP gap (IE, %) real estate price gap (IE, %) Source: IMF. 5% 10% 20% 25% Non-performing loans ratio Note: Size of the ring indicates relative volume of non-performing loans Source: Central Bank of Ireland 20 Paradox in practice again – corporate spreds today • What do the low corporate debt spreads mean today? Spreads of High-Yield Corporate Bonds (in basis points) 2500 2000 1500 1000 500 0 US High Yield Source: Bloomberg Euro High Yield