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A Framework to Monitor Systemic Risk G-20 Conference on Financial Systemic Risk Sep. 27-28, 2012 Tobias Adrian, Dan Covitz, Nellie Liang The views expressed herein are solely the author’s, and do not reflect those of the Federal Reserve Bank of New York, the Federal Reserve Board or its staff. All information presented here is publicly available. Outline New regulatory structure from the Dodd-Frank Act Lessons learned Framework for monitoring systemic risk Data and implementation challenges Systemic Risk Framework – Adrian, Covitz, Liang - 2 DFA and Financial Stability • Stronger emphasis on pre-emptive policies • Stronger capital and liquidity standards for SIFIs, bank and designated non-banks • Infrastructure: FMUs and OTC derivatives reform • Limits on crisis management, ex post policies • New resolution regime • Stronger limits on guarantees, liquidity provision • Tighter standards could push activities into the shadows • DFA did not reform wholesale short-term funding markets • Maturity transformation without deposit insurance or direct access to lender of last resort will continue Systemic risk remains and will build with financial cycles Systemic Risk Framework – Adrian, Covitz, Liang - 3 Lessons from the Crisis about Systemic Risk • • • • • • Ensuring the safety and soundness of individual firms does not ensure financial stability Need to broaden focus from individual firms to potential effects on the broader financial system and economy • Systemic risk externalities via direct and indirect interconnections amplify distress Nonfinancial sector leverage also increases systemic risk Shadow banking without government backstops is subject to run-like coordination failures Shadow banking affects core financial institutions • Implicit and explicit support from core institutions Systemic risk builds up during periods of low volatility • Regulators need to be forward looking • Risk measurement problems and accounting can obscure risk taking Systemic Risk Framework – Adrian, Covitz, Liang - 4 Process for Monitoring Systemic Risk • Motivated by research on amplification mechanisms o Bernanke and Gertler (1989), Kyotaki and Moore (1997), (Geanakoplos (2003), Allen and Gale (2000), Adrian and Shin (2010), Brunnermeier and Pedersen (2009), He and Krishnamurthy (2012), Adrian and Boyarchenko (2012) • Pre-emptive assessment process: 1. Identify possible shocks 2. Assess vulnerabilities (structural or cyclical): • Amplification channels that could transmit and amplify possible shocks • Could disrupt financial intermediation and impair real economic activity • Explicit recognition that cannot forecast shocks and triggers • Focus on vulnerabilities helps to identify micro- and macroprudential policy responses Systemic Risk Framework – Adrian, Covitz, Liang - 5 Stylized Framework for Systemic Risk Monitor • Systemic risk is a marked increase in price of risk P • P is increasing in shocks s and vulnerabilities V • Goal is to measure V o Could be determined by intermediary funding constraints that depend on past shocks • Policy trade-off – Reduction in V raises the price of risk when shocks are low, but reduces systemic risk Systemic Risk Framework – Adrian, Covitz, Liang - 6 Conceptual Framework for Monitoring and Policy Responses • Monitoring indicates the extent to which shocks might trigger systemic events o Monitoring informs us about exposures to changes in the price of risk o Sharp increases in the price of risk can generate systemic risk • Policy tradeoff between the price of risk and systemic risk o Higher price of risk today may reduce build-up of systemic risk • Macroprudential policies o Structural – capital surcharge, “through the cycle” haircuts o Cyclical –countercylical capital buffer, stress tests, underwriting standards, monetary policy Systemic Risk Framework – Adrian, Covitz, Liang - 7 Broad Monitoring Framework 1. SIFIS (bank and nonbank) and FMUs Firms are systemically important if their distress or failure could disrupt the functioning of the broader financial system and inflict harm on the real economy 2. Shadow Banking Shadow banking provides maturity and credit transformation without public sources of backstops and pose systemic risks because of interconnections to other financial institutions 3. Nonfinancial Sector Greater leverage amplifies negative shocks and imposes losses on the financial sector, increasing the likelihood of an adverse feedback loop through credit provision Systemic Risk Framework – Adrian, Covitz, Liang - 8 1. SIFIs and FMUs • Default risk – Capital and leverage ratios; off-balance sheet commitments – Stress test results (CCAR) – best forward-looking measure – Market-based measures • CDS, sub-debt bond spreads • Stock prices, price to book, market equity capitalization, market betas • Liability risk: runs and funding squeezes, cross border • Systemic importance – Size, interconnectedness, complexity, and critical services – Market-based measures of systemic risk – CoVaR, SES, DIP • Adrian and Brunnermeier (2008), Huang, Zhou, Zhu (2009), Acharya et al (2010) Systemic Risk Framework – Adrian, Covitz, Liang - 9 Monitoring SIFIs: Example Post-stress Tier 1 Common ratio in the Supervisory Stress Scenario (%) Systemic Risk Framework – Adrian, Covitz, Liang - 10 Monitoring SIFIs: Example Abnormal Stock Returns of CCAR 2012 Firms Systemic Risk Framework – Adrian, Covitz, Liang - 11 Monitoring SIFIs: Example Assets and Liabilities Systemic Risk Framework – Adrian, Covitz, Liang - 12 Monitoring SIFIs: Example Market-based Systemic Risk Measures Systemic Risk Framework – Adrian, Covitz, Liang - 13 Monitoring SIFIs: Example Interconnectedness of CCPs, Dealers, and non-dealers in CDS Source: Celso Brunetti and Michael Gordy, "Monitoring Counterparty credit risk and interconnectedness in CDS trade repository data" mimeo June 2012. Systemic Risk Framework – Adrian, Covitz, Liang - 14 2. Shadow Banking • Potential for Destabilizing Drops in Asset Prices o Shadow banking could inflate asset valuations in booms and amplify asset price crashes in busts o Price and non-price measures of potential bubbles, extremely low volatility • Leverage Cycle, Maturity Mismatch, and Run Risk o Leverage in the financial system (including on and off balance sheet exposures) o Maturity mismatch, non-deposit short-term liabilities o Activities not backed by government backstops: MMFs, cash pools, securities lending / repo activities, prime brokerage o Nonbank financial firms – finance companies, insurers, asset managers • Risk Transformation and New Products Systemic Risk Framework – Adrian, Covitz, Liang - 15 Monitoring Shadow Banking: Example Credit Spreads and Issuance Systemic Risk Framework – Adrian, Covitz, Liang - 16 Monitoring Shadow Banking: Example Money Market Funds Systemic Risk Framework – Adrian, Covitz, Liang - 17 Monitoring Shadow Banking: Example Shadow Banking Liabilities Shadow Liabilities Trillions 25 Trillions 25 Shadow Liabilities Net Shadow Liabilities 20 20 Bank Liabilities 15 15 10 10 5 5 0 1990 0 1994 1998 2002 2006 Source: Flow of Funds Systemic Risk Framework – Adrian, Covitz, Liang - 19 2010 Monitoring Shadow Banking: Example Commercial Paper and Repo Financing CP and Repo Financing Billions 3000 Billions 1250 ABCP (right axis) Triparty Repo (left axis) 2500 1000 750 2000 1500 500 Financial CP (right axis) Source: FRBNY and Federal Reserve Board Systemic Risk Framework – Adrian, Covitz, Liang - 18 Jul-11 Jan-11 Jul-10 Jan-10 Jul-09 Jan-09 Jul-08 Jan-08 Jul-07 Jan-07 Jul-06 Jan-06 Jul-05 Jan-05 Jul-04 250 Jan-04 1000 3. Real Economy Monitoring • Nonfinancial sector risk o Leverage of nonfinancial sector—households, businesses, governments • Effect of financial sector on economic activity o Indicators of macro-economy vulnerability to financial risks o Balance sheet capacity of financial institutions, collateral quality Systemic Risk Framework – Adrian, Covitz, Liang - 20 Real Economy Monitoring: Example Nonfinancial Sector Credit-to-GDP Ratio Systemic Risk Framework – Adrian, Covitz, Liang - 21 Real Economy Monitoring: Example Private Nonfinancial Sector Credit-to-GDP Ratio Systemic Risk Framework – Adrian, Covitz, Liang - 22 Data Challenges Information needs are immense – detailed data and complex interlinkages Measurement can change behavior • Supervisory stress tests Detailed data - loans to businesses and households, securities held, revenues, operational risks Trading book – sensitivities to shocks Counterparty exposures - build network of interconnections in trading book Potential to simulate effects of specific firm failures o o o o • Current stress test challenges SCAP 2009 – revealed weak practices Subsequent CCARs led to substantial improvements How to avoid resource allocation to guessing supervisor models and focused on own risk management o o o • Nonbank SIFIs and shadow banking Finance companies, insurers, broker-dealers, asset managers o • • • o In designation process, can ask firms for data New data for MMFs, and new report forms for hedge funds and private equity funds But need market-wide data on interconnections Repo – tri-party, bilateral – and CDS data not yet available Systemic Risk Framework – Adrian, Covitz, Liang - 23 Measurement and Implementation Challenges • Measurement: o Are market indicators forward looking? (VIX, stock prices, CDS) o Data needs for interconnections are immense and require cooperation among regulatory agencies, domestic and foreign, for confidential data (exposures, repo transactions) o Firms often don’t have the data required for systemic risk analysis o Is network analysis well-suited for economic interlinkages? o Measures may be hard to construct in real time (credit-to-GDP gap) o Measurement may change behavior (stress tests) • Implementation: o Requires much greater cooperation and a change in mindset among policymakers o Difficult given governance and policy uncertainty