Showing posts with label banks. Show all posts
Showing posts with label banks. Show all posts

Monday, September 16, 2013

IMF: Key Aspects of Macroprudential Policy + Implementing Macroprudential Policy/Selected Legal Issues

Key Aspects of Macroprudential Policy - Background Paper
IMF, June 10, 2013
http://www.imf.org/external/pp/longres.aspx?id=4804

Summary

The countercyclical capital buffer (CCB) was proposed by the Basel committee to increase the resilience of the banking sector to negative shocks. The interactions between banking sector losses and the real economy highlight the importance of building a capital buffer in periods when systemic risks are rising. Basel III introduces a framework for a time-varying capital buffer on top of the minimum capital requirement and another time-invariant buffer (the conservation buffer). The CCB aims to make banks more resilient against imbalances in credit markets and thereby enhance medium-term prospects of the economy—in good times when system-wide risks are growing, the regulators could impose the CCB which would help the banks to withstand losses in bad times.


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IMF: Implementing Macroprudential Policy - Selected Legal Issues
IMF, June 10, 2013
http://www.imf.org/external/pp/longres.aspx?id=4802

Summary
As countries design and implement macroprudential policies, they face the challenge of determining what—if any—changes need to be made to their legal and institutional framework to ensure that these policies are effective. Based on a review of experience, it is clear that there are a variety of approaches that can be taken by members, in light of the legal constraints and institutional preferences of each country. Whichever approach is followed, a number of issues need to be addressed when designing legislation in this area, both with respect to the substantive legal provisions and the allocation of institutional responsibilities. As background to ”Key Aspects of Macroprudential Policy“, this paper provides an overview of these legal and institutional issues, while recognizing that macroprudential policy is an area that is still evolving.

Friday, September 13, 2013

Financial Inclusion for Financial Stability: Improving Access to Deposits and Bank Resilience in Sync

Financial Inclusion for Financial Stability: Improving Access to Deposits and Bank Resilience in Sync. By Martin Melecky
World Bank Blogs
Tue, Sep 10, 2013
http://blogs.worldbank.org/allaboutfinance/financial-inclusion-financial-stability-improving-access-deposits-and-bank-resilience-sync

From 2006 to 2009, growth of bank deposits dropped by over 12 percentage points globally. The most affected by the 2008 global crisis were upper middle income countries that experienced a drop of 15 percentage points on average. Individual countries such as Azerbaijan, Botswana, Iceland, and Montenegro switched from deposit growth of 58 percent, 31 percent, 57 percent, and 94 percent in 2007 to deposit declines (or a complete stop in deposit growth) of -2 percent, 1 percent, -1 percent, -8 percent in 2009, respectively.

In times of financial stress, depositors get anxious, can run on banks, and withdraw their deposits (Diamond and Dybvig, 1983). Large depositors are usually the first ones to run (Huang and Ratnovski, 2011). By the law of large numbers, correlated deposit withdrawals could be mitigated if bank deposits are more diversified. Greater diversification of deposits could be achieved by enabling a broader access to and use of bank deposits, i.e. involving a greater share of adult population in the use of bank deposits (financial inclusion). Based on this assumption, broader financial inclusion in bank deposits could significantly improve resilience of banking sector funding and thus overall financial stability (Cull et al., 2012).

In the recent background paper for the World Development Report 2014 (Han and Melecky, 2013), we investigate the implications of a broader access to deposits for the dynamics of bank deposits during the global financial crisis. Namely, we analyze whether access to bank deposits by a larger share of a country’s population can help explain differences in the drop of deposit growth over 2007-2010 across our sample of 95 countries. We also separately estimate the differences in the relationship between the drop in deposit growth and access to deposits for low-income (LIC), middle-income (MIC), and high-income (HIC) countries.

Our paper responds to an existing gap in the empirical literature linking greater access to deposits with greater financial (banking sector) stability. While the literature postulates that an inclusive financial sector will have a more diversified, stable retail deposit base that can increase systemic stability, empirical research confirming existence of such a relationship, especially at the level of the financial system, is largely absent in the literature (Cull et al., 2012; Prasad, 2010).

We find that a broader access to and use of bank deposits can significantly mitigate bank deposit withdrawals or growth slowdowns in times of financial stress. Specifically, the estimated coefficient on the variables measuring access to deposits indicates that a 10 percent increase in the share of people that have access to bank deposits can mitigate the deposit growth drops (or deposit withdrawal rates) by about three to eight percentage points. While this finding holds for the entire sample of HICs, MICs, and LICs, it could be particularly strong in MICs, where a large share of population still lacks access to bank deposits, trust in banks is yet to be firmly established, and the integration in global financial flows is growing.

Our findings have important policy implications. Policy makers face tradeoffs when deciding whether to focus on reforms to promote financial development (financial inclusion, innovation, competition, etc.) or whether to focus on further improvements in financial stability (microprudential, macroprudential, business conduct supervision, etc.). However, synergies between promoting financial development and financial stability can also exist as shown in our paper.

We recommend that policy makers focus first on taking advantage of such synergies in their framework for financial sector policy. This framework is typically formulated in a national financial sector strategy which sets the development goals in finance, in view of systemic risk associated with achieving these goals and the risk preference of the country government. Namely, we argue that involving more people in the use of bank deposits could be beneficial for people, economic development, and stability of the financial system alike.

Drawing on our paper, the World Development Report 2014, in its chapter on the financial system, makes similar recommendations; namely, that countries should strive to promote a broader and responsible use of financial tools not only to aid economic development and poverty alleviation, but also to complement the mainstream (macroprudential) policies to enhance financial stability and prevent financial crises.

Again, these policy efforts, their synergetic effects, and the plan for their implementation, including the resulting responsibilities of different government agencies, should be clearly described in the national financial sector strategy. With proper regulation and oversight in place, initiatives such as Kenya’s M-PESA and M-KESHO projects (Demombynes and Thegeya, 2012) or South Africa’s Mzansi accounts (Bankable Frontier Associates, 2009) could serve as good examples of promoting a broader use of bank accounts (deposits) and enhancing the reliability of bank deposit funding at the same time.

References

  • Bankable Frontier Associates. 2009. "The Mzansi Bank Account Initiative in South Africa." Report commissioned by FinMark Trust. Bankable Frontier Associates, Somerville, MA.
  • Cull, Robert, Asli Demirguc-Kunt and Timothy Lyman. 2012. "Financial Inclusion and Stability: What Does Research Show?" CGAP Brief 71305, CGAP, Washington, DC.
  • Demombynes, Gabriel and Aaron Thegeya. 2012. "Kenya's Mobile Revolution and the Promise of Mobile Savings." Policy Research Working Paper 5988. World Bank, Washington, DC.
  • Diamond, Douglas W. and Philip H. Dybvig. 1983. "Bank Runs, Deposit Insurance, and Liquidity." Journal of Political Economy 91(3): 401­–19.
  • Huang, Rocco, and Lev Ratnovski. 2011. "The Dark Side of Bank Wholesale Funding." Journal of Financial Intermediation 20: 248–263.
  • Prasad, Eswar S. 2010. "Financial Sector Regulation and Reforms in Emerging Markets: An Overview." NBER Working Paper 16428, Cambridge, MA.

Monday, September 2, 2013

Margin requirements for non-centrally cleared derivatives - final report issued by the Basel Committee and IOSCO

Margin requirements for non-centrally cleared derivatives - final report issued by the Basel Committee and IOSCO
September 2, 2013

The Basel Committee on Banking Supervision and the International Organization of Securities Commissions (IOSCO) released today the final framework for margin requirements for non-centrally cleared derivatives. The framework is available on the websites of the Bank for International Settlements and IOSCO.

Under the globally agreed standards published today, all financial firms and systemically important non-financial entities that engage in non-centrally cleared derivatives will have to exchange initial and variation margin commensurate with the counterparty risks arising from such transactions. The framework has been designed to reduce systemic risks related to over-the-counter (OTC) derivatives markets, as well as to provide firms with appropriate incentives for central clearing while managing the overall liquidity impact of the requirements.

The final requirements have been developed taking into account feedback from two rounds of consultation (a July 2012 consultative paper and a February 2013 near-final proposal) as well as a quantitative impact study that helped inform the policy deliberations.

Compared with the near-final framework proposed earlier this year, the final set of requirements includes the following modifications:
  • The framework exempts physically settled foreign exchange (FX) forwards and swaps from initial margin requirements. Variation margin on these derivatives should be exchanged in accordance with standards developed after considering the Basel Committee supervisory guidance for managing settlement risk in FX transactions.
  • The framework also exempts from initial margin requirements the fixed, physically settled FX transactions that are associated with the exchange of principal of cross-currency swaps. However, the variation margin requirements that are described in the framework apply to all components of cross-currency swaps.
  • "One-time" re-hypothecation of initial margin collateral is permitted subject to a number of strict conditions. This should help to mitigate the liquidity impact associated with the requirements.
A number of other features of the framework are also intended to manage the liquidity impact of the margin requirements on financial market participants. In particular, the requirements allow for the introduction of a universal initial margin threshold of €50 million below which a firm would have the option of not collecting initial margin. The framework also allows for a broad array of eligible collateral to satisfy initial margin requirements, thus further reducing the liquidity impact.

Finally, the framework published today envisages a gradual phase-in period to provide market participants with sufficient time to adjust to the requirements. The requirement to collect and post initial margin on non-centrally cleared trades will be phased in over a four-year period, beginning in December 2015 with the largest, most active and most systemically important derivatives market participants.

The Basel Committee and IOSCO acknowledge that the margin requirements are new to the market and that their precise impact will depend on a number of factors and market conditions that will only be realised over time as the requirements are put into practice. Accordingly, the Basel Committee and IOSCO will monitor and assess the impact of the requirements as they are implemented globally.

Tuesday, August 27, 2013

Macroeconomic impact assessment of OTC derivatives regulatory reforms report issued by the Macroeconomic Assessment Group on Derivatives

Macroeconomic impact assessment of OTC derivatives regulatory reforms report issued by the Macroeconomic Assessment Group on Derivatives (MAGD)
August 26, 2013
www.bis.org/press/p130826.htm

The Macroeconomic Assessment Group on Derivatives (MAGD) today published a report on the macroeconomic effects of OTC derivatives regulatory reforms.

In this report, the MAGD focuses on the effects of (i) mandatory central clearing of standardised OTC derivatives, (ii) margin requirements for non-centrally cleared OTC derivatives and (iii) bank capital requirements for derivatives-related exposures. In its preferred scenario, the Group found economic benefits worth 0.16% of GDP per year from avoiding financial crises.

It also found economic costs of 0.04% of GDP per year from institutions passing on the expense of holding more capital and collateral to the broader economy. This results in net benefits of 0.12% of GDP per year. These are estimates of the long-run consequences of the reforms, which are expected to apply once they have been fully implemented and had their full economic effects.

The MAGD was set up by the OTC Derivatives Coordination Group (ODCG), comprised of the Chairs of the Basel Committee on Banking Supervision (BCBS), the Committee on the Global Financial System (CGFS), the Committee on Payment and Settlement Systems (CPSS), the Financial Stability Board (FSB) and the International Organization of Securities Commissions (IOSCO). It comprises financial and economic modelling experts from 29 central banks and other authorities, chaired by Stephen Cecchetti, Economic Adviser of the Bank for International Settlements (BIS).


Executive summary (excerpts)

In February 2013, the Over-the-counter Derivatives Coordination Group (ODCG) commissioned a quantitative assessment of the macroeconomic implications of over-the-counter (OTC) derivatives regulatory reforms to be undertaken by the Macroeconomic Assessment Group on Derivatives (MAGD), chaired by Stephen G Cecchetti of the Bank for International Settlements (BIS). The Group comprised 29 member institutions of the Financial Stability Board (FSB), working in close collaboration with the IMF. Guided by academics and other official sector working groups, and in consultation with private sector OTC derivatives users and infrastructure providers, the Group developed and employed models that provide an estimate of the benefits and costs of the proposed reforms. This report presents those findings.

Counterparty exposures related to derivatives traded bilaterally in OTC markets helped propagate and amplify the global financial crisis that erupted in 2008. Many of these exposures were not collateralised, so OTC derivatives users recorded losses as counterparty defaults became more likely or, as in the case of Lehman Brothers, were realised. Furthermore, since third parties had little information about the bilateral exposures among derivatives users, they became less willing to provide credit to institutions that might face such losses.

In response, policymakers have developed and are implementing reforms aimed at reducing counterparty risk in the OTC derivatives market. These include requirements for standardised OTC derivatives to be cleared through central counterparties (CCPs), requirements for collateral to be posted against both current and potential future counterparty exposures, whether centrally cleared or non-centrally cleared, and requirements that banks hold additional capital against their uncollateralised derivative exposures.

While these reforms have clear benefits, they do entail costs. Requiring OTC derivatives users to hold more high-quality, low-yielding assets as collateral lowers their income. Similarly, holding more capital means switching from lower-cost debt to higher-cost equity financing. Although these balance sheet changes reduce risk to debt and equity investors, risk-adjusted returns may still fall. As a consequence, institutions may pass on higher costs to the broader economy in the form of increased prices.

This report assesses and compares the economic benefits and costs of the planned OTC derivatives regulatory reforms. The focus throughout is on the consequences for output in the long run, ie when the reforms have been fully implemented and their full economic effects realised. The main beneficial effect is a reduction in forgone output resulting from a lower frequency of financial crises propagated by OTC derivatives exposures, while the main cost is a reduction in economic activity resulting from higher prices of risk transfer and other financial services.

These long-run benefits and costs depend on how the reforms interact with derivatives portfolios and affect the structure of the derivatives market more broadly, as this can significantly alter the amount of netting obtainable from gross counterparty exposures. In response, the Group analysed three scenarios that differ mainly in terms of the assumed degree of netting. [...]

Briefly, the main benefit of the reforms arises from reducing counterparty exposures, both through netting as central clearing becomes more widespread and through more comprehensive collateralisation. The Group estimates that in the central scenario this lowers the annual probability of a financial crisis propagated by OTC derivatives by 0.26 percentage points. With the present value of a typical crisis estimated to cost 60% of one year’s GDP, this means that the reforms help avoid losses equal to (0.26 x 60% =) 0.16% of GDP per year. The benefit is balanced against the costs to derivatives users of holding more capital and collateral. Assuming this is passed on to the broader economy, the Group estimates that the cost is equivalent to a 0.08 percentage point increase in the cost of outstanding credit. Using a suite of macroeconomic models, the Group estimates that this will lower annual GDP by 0.04%. Taken together, this leads to the Group’s primary result: the net benefit of reforms is roughly 0.12% of GDP per year.

As one would expect, for the scenarios with higher and lower netting these net benefits are respectively slightly higher and slightly lower. Importantly, the Group concludes that the economic benefits are essentially constant across scenarios because the reforms demand collateralisation of the vast majority of net counterparty exposures, whatever their size. But shifting between netting and collateralisation does affect the estimated costs and hence the net benefits.

Uncertainties arising from a combination of modelling limitations and data scarcity were handled in a variety of ways. First, examining a variety of macroeconomic models helped the Group to improve the precision of estimates of the impact of the reforms’ direct costs on the real economy. Second, by varying the structure of the network of bilateral OTC derivatives exposures within feasible limits as well as the strength of the relationship between losses on these exposures and the creditworthiness of the institution incurring them, the Group managed two other potentially large uncertainties. And finally, while some assumptions bias the results towards higher net benefits, many deliberately bias them in the other direction. For example, the funding costs of increased collateral and capital holdings were based on historical prices, rather than prices that reflect improvements in credit quality associated with these balance sheet changes.

In the course of completing the analysis reported here, the Group encountered a number of technical challenges. One related to a shortage of information about the structure of the OTC derivatives exposure network. In the absence of data on bilateral exposures, these were estimated using aggregate data and distributional assumptions. Conversations with derivatives users, infrastructure providers and regulators then helped to validate the estimated network. More generally, the Group found little prior analysis of how derivatives can affect the economy.

Despite statistical uncertainty and the need to make various modelling assumptions and to employ only the limited data available, the group concludes that the economic benefits of reforms are likely to exceed their costs, especially in the scenarios with more netting. Therefore, to maximise the net benefit of the reforms, regulators and market participants must work to make as many OTC derivatives as possible safely centrally clearable, with either a modest number of central counterparties or with central counterparties that interoperate. This should include efforts to harmonise the rules governing cross-border transactions, so that market participants have equal access to CCPs.

Wednesday, August 21, 2013

Mortgage insurance: market structure, underwriting cycle and policy implications

Mortgage insurance: market structure, underwriting cycle and policy implications
Joint Forum, Aug 20, 2013
http://www.bis.org/press/p130820.htm

The Joint Forum released today its final report on Mortgage insurance: market structure, underwriting cycle and policy implications.   

The events of the last few years, particularly those in the global financial crisis that began in 2007, demonstrate that mortgage insurance is subject to significant stress in the worst tail events. This report examines the interaction of mortgage insurers with mortgage originators and underwriters. It makes the following set of recommendations directed at policymakers and supervisors which aim at reducing the likelihood of mortgage insurance stress and failure in such tail events:
  1. Policymakers should consider requiring that mortgage originators and mortgage insurers align their interests;
  2. Supervisors should ensure that mortgage insurers and mortgage originators maintain strong underwriting standards;
  3. Supervisors should be alert to - and correct for - deterioration in underwriting standards stemming from behavioural incentives influencing mortgage originators and mortgage insurers;
  4. Supervisors should require mortgage insurers to build long-term capital buffers and reserves during the troughs of the underwriting cycle to cover claims during its peaks;
  5. Supervisors should be aware of and take action to prevent cross-sectoral arbitrage which could arise from differences in the accounting between insurers' technical reserves and banks' loan loss provisions, and from differences in the capital requirements for credit risk between banks and insurers;
  6. Supervisors should be alert to potential cross-sectoral arbitrage resulting from the use of alternatives to traditional mortgage insurance; and
  7. Supervisors should apply the FSB Principles for Sound Residential Mortgage Underwriting Practices to mortgage insurers noting that proper supervisory implementation necessitates both insurance and banking expertise.
The Joint Forum based its recommendations on an analysis of existing mortgage underwriting standards and the underwriting cycle.

Thomas Schmitz-Lippert, Chairman of the Joint Forum and Executive Director International Policy at the German Federal Financial Supervisory Authority, BaFin, said: "Mortgage origination and mortgage insurance were at the very core of the financial crisis. The Joint Forum Recommendations on Mortgage Insurance provide guidance to national policymakers and supervisors in order to avoid mistakes of the past and strengthen resilience in the future."

An earlier version of this report was issued for consultation in February 2013.

Saturday, August 17, 2013

Do Relationships Matter? Evidence from Loan Officer Turnover

Do Relationships Matter? Evidence from Loan Officer Turnover. By Alejandro, Drexler, and Antoinette Schoar
World Bank Blogs, Mon Aug 12, 2013
http://blogs.worldbank.org/allaboutfinance/do-relationships-matter-evidence-loan-officer-turnover

One of the most frequent causes of credit constraints is the presence of asymmetric information between businesses and investors. Asymmetric information is particularly problematic for micro-entrepreneurs where the information about cash flows and investment decisions is not formally recorded. Furthermore, micro-entrepreneurs many times have few assets to pledge as collateral and do not have a guarantor with a solid financial condition, making it even more difficult for them to access the credit market.

Microfinance institutions specialize in lending to these types of borrowers and have lending technologies that do not rely on formal records. Instead, revenues and expenses are estimated based on non-verifiable information collected by loan officers during field visits to the borrowers’ houses and businesses.

During these field visits, loan officers observe the premises of the business, the inventory, and other relevant information the borrowers can demonstrate. They also discuss business matters with the entrepreneurs as well as personal matters that might affect their repayment capacity.

Loan officers’ expertise is crucial to estimate the financial health of a business during these short visits. For example, experienced loan officers are able to estimate businesses’ inventories and revenues by observing key variables, including the products on the shelves or the number of clients that show up at the business during the visit. Although these observations cannot be verified and are considered soft information, the types of skills that lead to such information can be acquired through training, are not loan officer-client specific, and can be applied even if the loan officer is not acquainted with the entrepreneur.

However, an important fraction of the information required to make a microfinance lending decision is private and is collected during the social interactions between the loan officers and the entrepreneurs. The flow of this type of information strongly depends on the interpersonal ties between the borrowers and the loan officers (Uzzi, 1996). For example,it is unlikely that borrowers would disclose their health expenses, alimony expenses, or other expenses they incur to support family members in need to a stranger. Therefore, this type of information is lost when a loan officer leaves the bank, unless the private information can be credibly transferred to a new loan officer, and/or if the departing loan officer can convince borrowers to share “personal information” with the new loan officer.

The social relationship between the loan officers and the borrowers not only helps the bank to make better lending decisions, but also might increase the willingness of the borrowers to get debt. This is particularly important for borrowers that associate a negative connotation with debt, are unfamiliar with financial services, or mistrust financial institutions. On the downside, making lending decisions based on these social interactions makes banks dependent on loan officers and subject to their misinterpretation or misreporting of information.

While it is recognized that the social relationship between the loan officers and the entrepreneurs can have important implications for the lenders and the borrowers, little is known about the costs associated with disruptions to these relationships.

In a recent study, we test the importance of interpersonal relationships in the lending process. In particular, we study whether the banks’ lending decision and the borrowers’ repayment rate, willingness to get debt at the bank, and willingness to get debt at other banks are affected when a loan officer is absent for long periods of time.

We find that the relationship between loan officers and borrowers has first-order implications on entrepreneurs’ credit availability, repayment behavior, and borrowing decisions. When loan officers are absent, we observe a 20% decrease in the probability that clients get a new loan. This reduction is the consequence of both a 5% decrease in the bank’s loan approval rate and a 15% reduction in the number of applications. We do not observe a change in credit terms such as interest rates or maturity; this indicates that the bank adjusts the risk by cutting credit and not by adjusting the price of the loans. We also observe a 22% increase in the probability of missing a payment and an 18% increase in the probability of default for the borrower.

To understand the conditions in which this information can be transferred or generated by the new loan officer, we look at variations in: (1) how well the absence of loan officers can be planned in advance, since it is more difficult to transfer soft information in the case of completely unplanned leaves, and (2) whether the departing loan officers have any incentives to collaborate in conveying information to replacement loan officers. We observe four different types of absences due to sickness, resignation, pregnancy, and dismissal. We use sickness leaves as a baseline, because they are both unexpected and exogenous.

During sickness leaves, we still observe a decrease in lending and an increase in delinquency, but we do not see an increase in outright default. This finding indicates that most payment delays are caused by reduced monitoring and not caused by financial distress. We also observe a decrease in the probability of applying for a new loan at the bank, but an increase in the probability of applying for credit at other banks, suggesting a reduction in the loyalty of clients toward the bank.

We observe similar results during maternity leaves, but we do not observe an increase in the probability of approaching other banks. This is natural since maternity leaves are exogenous but anticipated, and the loan officers can set up their clients with new loans before they leave.

The strongest reduction in credit and the strongest increase in default are observed after loan officers are dismissed. We believe this is the result of poor past performance of the dismissed loan officers as well as a lack of incentive to transfer any soft information.

However, clients of resigning loan officers are less affected by the leave; application probability does not present a significant decrease and the default rate does not increase. This might indicate that when given enough time, loan officers can brief the replacing loan officers about the soft information of the clients. It also suggests that when having the right incentives, the departing loan officers can familiarize the new loan officers with the clients and gain their confidence.

We also study whether the importance of social relationships depends on borrowers’ characteristics. As expected, the probability of the bank approving a loan to firms with larger and better credit risks less affected by loan officer leaves, probably because hard information about the clients is more readily available. However, we also observe that the probability of applying for a new loan at the bank and the probability of applying for a new loan at other banks do not change after the leave. This finding can indicate that the relationship between clients with large and good credit scores and the bank is less dependent on loyalty.

We also find that female clients are more affected by loan officers’ absences, which is probably because female clients have fewer assets and many times operate informal businesses from home. Therefore, cash flows are particularly difficult to verify and personal information is particularly relevant. This finding highlights the importance of micro-credit lending on promoting women’s financial inclusion.

Overall the results in the study support the view that personal relationships are crucial to reduce credit constraints and improve entrepreneurs’ incentives to repay. The results suggest that close social ties between the loan officers and the borrowers can increase the offer of credit to micro entrepreneurs, but also indicate that the demand for credit can depend on social ties. In light of these results, the high turnover observed in the loan officers’ labor market can be very costly for banks and borrowers and can be one of the factors that impede many micro-businesses to grow beyond subsistence level.



References

Drexler, Alejandro, and Antoinette Schoar. 2012. Do Relationships Matter? Evidence from Loan Officer Turnover. Working Paper. http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2144337

Uzzi, Brian. 1996. The Sources and Consequences of Embeddedness for the Economic Performance of Organizations: The Network Effect. American Sociological Review pp. 674–698.

Friday, August 16, 2013

Longevity risk transfer markets: market structure, growth drivers and impediments, and potential risks - consultative report

Longevity risk transfer markets: market structure, growth drivers and impediments, and potential risks - consultative report
The Joint Forum
August 2013
http://www.bis.org/publ/joint31.htm

The ageing population phenomenon being observed in many countries poses serious social policy challenges. Longevity risk - the risk of paying out on pensions and annuities longer than anticipated - is significant when measured from a financial perspective. Longevity risk transfer markets: market structure, growth drivers and impediments, and potential risks (PDF) is a forward-looking report released by the Joint Forum on longevity risk transfer (LRT) markets.


Recommendations:

Whether or not policymakers should play a more active role in encouraging longevity risk transfer from private pension plans to (re)insurers and ultimately to broader capital markets depends on considerations regarding where this risk is best held. Answering this question is beyond the scope of this preliminary analysis, but some relevant factors are worth mentioning.

Advocates of more LRT (see, e.g., Towers Watson, 2011, and Swiss Re, 2012) point to already visible and unwieldy corporate pension benefit obligations and to the heavy underfunding of DB pension funds.31 In this context, they recognise that not only are pension obligations a sizeable distraction to corporate core business lines, but a significant longevity shock could undermine the firm’s own existence. In addition, they point out that some LRT instruments (namely buy-outs) may provide pensioners with a more stringently regulated (re)insurer counterparty.

In addition, policymakers may want to encourage (re)insurers to use LRT markets to free up capital in order to give (re)insurers (or any other entities allowed to provide annuity products) the possibility of writing more of these annuities, which are useful and unique retirement products. On the other hand, the transfer of risk from a mature sector with significant capital requirements to an LRT market that may not have these safeguards may not be in the employees’ best interests, and may even create new systemic risks.

At the same time, when longevity risk is shifted from the corporate sector to a limited number of (re)insurers, with global interconnections, there may be systemic consequences in the case of a failure of a key player (as was the case in the CRT market). Most countries in which this view is shared incentivise the private sector to provide adequate retirement benefits to employees, sometimes providing explicit protection to corporate pension funds with government-supported guarantee schemes. In other countries, this view is expressed implicitly by allowing pension funds to value their liabilities with a discount rate that is higher than the one used for (re)insurers’ reserves.

Motivated by the aforementioned preliminary findings, the Joint Forum proposes the following recommendations to supervisors and policymakers:
  1. Supervisors should communicate and cooperate on LRT internationally and cross-sectorally in order to reduce the potential for regulatory arbitrage.
  2. Supervisors should seek to ensure that holders of longevity risk under their supervision have the appropriate knowledge, skills, expertise and information to manage it.
  3. Policymakers should review their explicit and implicit policies with regards to where longevity risk should reside to inform their policy towards LRT markets. They should also be aware that social policies may have consequences on both longevity risk management practices and the functioning of LRT markets.
  4. Policymakers should review rules and regulations pertaining to the measurement, management and disclosure of longevity risk with the objective of establishing or maintaining appropriately high qualitative and quantitative standards, including provisions and capital requirements for expected and unexpected increases in life expectancy.
  5. Policymakers should consider ensuring that institutions taking on longevity risk, including pension fund sponsors, are able to withstand unexpected, as well as expected, increases in life expectancy.
  6. Policymakers should closely monitor the LRT taking place between corporates, banks, (re)insurers and the financial markets, including the amount and nature of the longevity risk transferred, and the interconnectedness this gives rise to.
  7. Supervisors should take into account that longevity swaps may expose the banking sector to longevity tail risk, possibly leading to risk transfer chain breakdowns.
  8. Policymakers should support and foster the compilation and dissemination of more granular and up-to-date longevity and mortality data that are relevant for the valuations of pension and life insurance liabilities.

References
  • Aegon, 2011, “Paying the Price for Living Longer: What is the Right Price for Removing Longevity Risk?” Aegon Global Pensions View.
  • A.M. Best, 2009, “Life Settlement Securitization,” Criteria – Insurance-Linked Securities, November 24.
  • An, Heng, Zhaodan Huang, and Ting Zhang, 2013, "What Determines Corporate Pension Fund Risk-Taking Strategy?" Journal of Banking & Finance, Vol. 37, No. 2, pp. 597–613.
  • Aon Hewitt, 2011, Global Pension Risk Survey 2011. Available at www.aon.com/netherlands/persberichten/2011/Aon_Hewitt_GRS_EURO_2011.pdf)
  • Barrieu, Pauline, Harry Bensusan, Nicole El Karoui, Caroline Hillairet, Stephane Loisel, Claudia Ravanelli, Yahia Salhi, 2012, "Understanding, Modelling and Managing Longevity Risk: Key Issues and Main Challenges," Scandinavian Actuarial Journal, Volume 2012, Issue 3, pp. 203-231.
  • Biffis, Enrico and David Blake, 2009, “Mortality-Linked Securities and Derivatives,” October 7. Available at SSRN: http://ssrn.com/abstract=1340409
  • Biffis, Enrico and David Blake, 2012, “How to Start a Capital Market in Longevity Risk Transfers,” Unpublished manuscript, September.
  • Biffis, Enrico, David Blake, Lorenzo Pitotti, and Ariel Sun, 2011, “The Cost of Counterparty Risk and Collateralization in Longevity Swaps,” Cass Business School Pension Institute Working Paper (London: City University, April.
  • Black, Fischer, 1980. "The Tax Consequences of Long-Run Pension Policy," Financial Analysts Journal, Vol. 36, No. 4, pp. 21-28.
  • Blake, David, Tom Boardman, and Andrew Cairns, 2010, “Sharing Longevity Risk: Why Governments Should Issue Longevity Bonds,” Cass Business School Pension Institute Working Paper, (London: City University, March).
  • Bodie, Zvi, Jay O. Light, Randall Morck, and Robert A. Taggart Jr., 1987. "Funding and Asset Allocation in Corporate Pension Plans: An Empirical Investigation," In: Bodie, Zvi, John B. Shoven, and David A. Wise, (Eds.), Issues in Pension Economics, University of Chicago Press, Chicago, pp. 15-47.
  • Brown, Jeffrey R., Jeffrey R. Kling, Sendhil Mullainathan, and Marian V. Wrobel, 2008, “Why Don’t People Insure Late Life Consumption? A Framing Explanation of the Under-Annuitization Puzzle,” National Bureau of Economic Research Working Paper No. 13748, January.
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Thursday, August 15, 2013

Evaluating early warning indicators of banking crises: Satisfying policy requirements

Evaluating early warning indicators of banking crises: Satisfying policy requirements
By Mathias Drehmann and Mikael Juselius
BIS Working Papers No 421
Aug 2013
Early warning indicators (EWIs) of banking crises should ideally be evaluated on the basis of their performance relative to the macroprudential policy maker's decision problem. We translate several practical aspects of this problem - such as difficulties in assessing the costs and benefits of various policy measures as well as requirements for the timing and stability of EWIs - into statistical evaluation criteria. Applying the criteria to a set of potential EWIs, we find that the credit-to-GDP gap and a new indicator, the debt service ratio (DSR), consistently outperform other measures. The credit-to-GDP gap is the best indicator at longer horizons, whereas the DSR dominates at shorter horizons.

JEL classification: C40, G01
Keywords: EWIs, ROC, area under the curve, macroprudential policy


Excerpts:

In the empirical part of the paper, we apply our approach to assess the performance of 10 different EWIs. We mainly look at the EWIs individually, but at the end of the paper we also consider how to combine them. Our sample consists of 26 economies, covering quarterly time series starting in 1980. The set of potential EWIs includes more established indicators such as real credit growth, the credit-to- GDP gap, growth rates and gaps of property prices and equity prices (eg Drehmann et al (2011)) as well as the non-core liability ratio proposed by Hahm et al (2012).  We also test two new measures: a country’s history of financial crises and the debt service ratio (DSR). The DSR was first suggested in this context by Drehmann and Juselius (2012) and is defined as the proportion of interest payments and mandatory repayments of principal to income. An important data-related innovation of our analysis is that we use total credit to the private non-financial sector obtained from a new BIS database (Dembiermont et al (2013)).

We find that the credit-to-GDP gap and the DSR are the best performing EWIs in terms of our evaluation criteria. Their forecasting abilities dominate those of the other EWIs at all policy-relevant horizons. In addition, these two variables satisfy our criteria pertaining to the stability and interpretability of the signals. As the credit-to- GDP gap reflects the build-up of leverage of private sector borrowers and the DSR captures incipient liquidity constraints, their timing is somewhat different. While the credit-to-GDP gap performs consistently well, even over horizons of up to five years ahead of crises, the DSR becomes very precise two years ahead of crises. Using and combining the information of both indicators is therefore ideal from a policy perspective. Of the remaining indicators, only the non-core liability ratio fulfils our statistical criteria. But its AUC is always statistically smaller than the AUC of either the credit-to-GDP gap or the DSR. These results are robust with respect to different aspects of the estimation, such as the particular sample or the specific crisis classification used.

Wednesday, August 14, 2013

Recovery of financial market infrastructures - consultative report

Recovery of financial market infrastructures - consultative report
BIS, Aug 2013
www.bis.org/publ/cpss109.htm

The Committee on Payment and Settlement Systems (CPSS) and the International Organization of Securities Commissions (IOSCO) have published for public comment a consultative report on the Recovery of financial market infrastructures.

The report provides guidance to financial market infrastructures such as CCPs on how to develop plans to enable them to recover from threats to their viability and financial strength that might prevent them from continuing to provide critical services to their participants and the markets they serve. It also provides guidance to relevant authorities in carrying out their responsibilities associated with the development and implementation of recovery plans and tools.

The report has been produced in response to comments received on the July 2012 CPSS-IOSCO report on Recovery and resolution of financial market infrastructures that requested more guidance on what recovery tools would be appropriate for FMIs.

The report supplements the CPSS-IOSCO Principles for financial market infrastructures (PFMI) , the international standards for financial market infrastructures (FMIs) published in April 2012. It provides guidance on how FMIs can observe the requirements in the PFMI that they have effective recovery plans. It does not itself create additional standards for FMIs. The report is also consistent with the Financial Stability Board's Key attributes of effective resolution regimes for financial institutions, published in October 2011 and which also covers the importance of recovery planning. Aspects of the consultation report concerning FMI resolution have been included in a new draft annex to the FSB Key attributes and will be included in a forthcoming assessment methodology for the Key attributes.

Financial market infrastructures (FMIs), which include payments systems, securities settlement systems, central securities depositories, central counterparties and trade repositories, play an essential role in the global financial system. The disorderly failure of an FMI could lead to severe systemic disruption if it caused markets to cease to operate effectively.

 Published with the report is a cover note that lists specific issues on which the committees seek comments during the public consultation period. Comments on the report are invited from all interested parties and should be sent by 11 October 2013 to both the CPSS secretariat (cpss@bis.org) and the IOSCO secretariat (fmirecovery@iosco.org). The comments will be published on the websites of the BIS and IOSCO unless commentators have requested otherwise.

Friday, August 9, 2013

HEAT! A Bank Health Assessment Tool. By Li L. Ong, Phakawa Jeasakul and Sarah Kwoh

HEAT! A Bank Health Assessment Tool. By Li L. Ong, Phakawa Jeasakul and Sarah Kwoh
IMF Working Paper No. 13/177
August 09, 2013
http://www.imf.org/external/pubs/cat/longres.aspx?sk=40872.0

Summary: Developments during the global financial crisis have highlighted the importance of differentiating across financial systems and institutions. Assessments of financial stability have increasingly considered the characteristics of individual banks within a financial system, as well as those with significant international reach, to identify vulnerabilities and inform policy decisions. This paper proposes a simple measure of bank soundness, the Bank Health Index (BHI), to facilitate preliminary analyses of individual financial institutions relative to their peers. The evidence suggests that the BHI is useful for a first-pass identification of bank soundness conditions. Automated spreadsheet templates of the bank Health Assessment Tool (HEAT!) are provided for users with access to the BankScope, Bloomberg and/or SNL database(s).

Introduction

The impact of the global financial crisis on individual banking systems and banks has highlighted the importance of differentiating across countries and among financial institutions. Traditionally, macroprudential surveillance of the financial sector has complemented the microprudential oversight of individual financial institutions by supervisors (The World Bank/IMF, 2005). However, the growing systemic importance of these institutions, notably banks, and their potential impact on policy and the public purse have underscored the need to extend any macroprudential analysis to include individual systemic institutions as well.

The depth and protracted nature of the current crisis have revealed vast divergences in the resilience of individual banks. This is, in large part, attributable to banks’ business models and management quality, sometimes mitigated by the various pre-emptive or supportive policy actions taken by country authorities. In many cases, specific knowledge of characteristics underpinning individual banks’ financial health has been crucial for identifying vulnerabilities and informing policy decisions for crisis prevention or management purposes. Looking ahead, lessons learned from this crisis suggest that more granular, bank-specific analysis will become increasingly more important in that it could:

  • enable early identification of vulnerabilities in global systemically important banks (G-SIBs) and domestic systemically important banks (D-SIBs), which could help prevent widespread spillovers from any realization of tail risks if appropriate mitigation actions are put in place;
  • inform system-wide reform strategies by differentiating the core, healthy banks from the very weak ones that require significant restructuring or even resolution, so that the strong banks are not burdened with a “one size fits all” solution for an entire system; and 
  • inform restructuring decisions, such as mergers and acquisitions, recapitalization and/or liquidity support, by highlighting banks’ weaknesses or identifying the weak banks.

To this end, this paper proposes a simple, broadly-based measure of bank soundness that would allow preliminary, first-pass analysis of the health of individual financial institutions and, consequently, financial systems. We develop a Bank Health Index (BHI) and provide automated spreadsheet templates, the bank Health Assessment Tool (HEAT!), to facilitate the exercise. We show that the BHI, albeit simple, can be useful for initial identification of relative bank soundness and is also able to identify more specific areas of vulnerability.  However, we also note its limitations and acknowledge that such analyses would need to be complemented by more rigorous and robust quantitative (e.g., stress tests) and qualitative (e.g., supervisory and regulatory frameworks) assessments.


Concluding Remarks

The global financial crisis has underscored the importance of individual banks to the stability of their own or even the global financial system. Thus, analyses of the health of individual banks, especially the systemic ones, are becoming a matter of course for surveillance purposes and for crisis management decisions. We have developed the BHI to enable simple, preliminary analyses of individual banks in financial systems around the world and introduced an Excel-based spreadsheet tool (HEAT!) to facilitate its calculation and presentation. Our back-test, based on actual developments in the Spanish banking system, suggests that the BHI is able to accurately differentiate banks according to their financial soundness.

That said, there are strong caveats attached to the use of the BHI and its components. Any representation about the health of individual banks using this method should be made with care. Specifically, the Index is an aggregation of ratios, so the performance of the individual components should also be considered in any analysis. Moreover, the associated z-scores do not provide an absolute assessment of the health of banks, but rather, their relative health within a sample, which means that the selection of the sample itself matters. The differences in banks’ business models at any point in time and their changing nature over time, as well as the definitions used in calculating the constituent components of the BHI should also be taken into account when interpreting the results. Last but not least, it is also important for the user to be familiar with the peculiarities of any banking system being analyzed and to ensure that any assessment is supplemented with other quantitative and qualitative information.

Saturday, July 20, 2013

Liquidity coverage ratio disclosure standards - consultative document

Liquidity coverage ratio disclosure standards - consultative document
BCBS, July 19, 2013
http://www.bis.org/publ/bcbs259.htm

The Basel Committee on Banking Supervision has today issued for consultation Liquidity coverage ratio disclosure standards.

Following the publication of the LCR standard in January 2013, the Basel Committee indicated its intention to develop associated disclosure standards. Public disclosure improves transparency, reduces uncertainty in the markets and strengthens market discipline. To promote the benefits of disclosure the Committee believes that it is important that banks adopt a common disclosure framework to help market participants consistently assess the liquidity risk position of banks. Moreover, to promote consistency and ease of use of disclosures related to the LCR, the Basel Committee has agreed that internationally-active banks across Basel member jurisdictions will be required to publish their LCR according to a common template.

In designing the disclosure standards for the LCR, the Basel Committee has balanced the benefits of promoting market discipline against the challenges associated with disclosure of liquidity positions under certain circumstances, including the potential for undesirable dynamics during periods of stress.

Friday, July 19, 2013

Bank Resolution Costs, Depositor Preference, and Asset Encumbrance

Bank Resolution Costs, Depositor Preference, and Asset Encumbrance. By Daniel C. Hardy
IMF Working Paper No. 13/172
July 18, 2013
http://www.imf.org/external/pubs/cat/longres.aspx?sk=40799.0

Summary: Depositor preference and collateralization of borrowing may reduce the cost of settling the conflicts among creditors that arises in case of resolution or bankruptcy. This net benefit, which may be capitalized into the value of the bank rather than affect creditors’ expected returns, should result in lower overall funding costs and thus a lower probability of distress despite increasing encumbrance of the bank’s balance sheet. The benefit is maximized when resolution is initiated early enough for preferred depositors to remain fully protected.


Conclusions and next steps (edited)


Bank resolution, like bankruptcy and debt restructuring generally, inherently involves a great deal of negotiation and uncertainty; these are situations in which contracts are far from complete. Experience from many sectors, most notably the financial sector, suggest that the attendant conflicts among claimants can add substantially to costs and delays in resolution.

The prospective costs attached to such conflicts, which should depend on the magnitude of residual assets, can influence the optimal composition and conditions of financing, and, in particular, motivate the introduction of provisions that make some claims “bankruptcy remote.” Bankruptcy remoteness can be achieved through statute and policy, as when depositors enjoy preferred status as a matter of law, or through private agreements, as when banks issue covered bonds backed by a pool of high-quality assets. The asset encumbrance that results from either mechanism can be desirable insofar as it reduces bankruptcy costs, and, through lower overall funding costs, lowers the probability of distress. This substantive effect from the composition of financing is not due to asymmetric information or related mechanisms, but to the gain from containing conflict resolution costs.

In the first instance, the gain should be capitalized into the value of the bank, which enjoys an overall reduction in funding costs. The extension of preferred status to some creditors (including a DGS) need not make them better off. Nor need non-secured borrowers be disadvantaged in expectational terms: they earn more when the bank survives but bear larger net losses in case of resolution (though they spend less contending for their claims). Granting preferred status to (some) depositors need not provoke increased collateralization of other credits: from the point of view of the borrowing bank, collateralization and statutory depositor preference are near substitutes, with the difference that collateralization can be increased at the bank’s initiative, albeit at an increasing marginal cost. However, the achievement of full benefits and their distribution will depend on pricing being risk-sensitive; the probability of distress might not be reduced if those that benefit from collateralization demand an interest rate that ignores the reduction in LGD that collateralization should achieve.

For these measures to be valuable, a high degree of legal certainty of their implementation must be achieved, and it is important that the resolution process starts when the borrowing bank still has enough residual assets that preferred or collateralized claims can be met. If, ex post, these conditions are not met, conflict may be intensified. Hence, bank stability might be enhanced by limiting total asset encumbrance (preferred deposits plus collateralized borrowing) to below the likely minimum level of residual assets. Authorities that are willing and able to take early corrective action, and therefore rarely have to deal with banks left with scant residual assets, can be more sanguine about asset encumbrance.

The analysis presented here lead on to other questions of practical relevance, which may be addressed in further research using an extension of the framework. Some of these questions include the following:

• What systematic evidence might be examined to determine whether and how bankruptcy costs depend on the intensity of conflict over residual assets? Some anecdotal evidence indicates that bankruptcy proceedings and bank resolutions are characterized by intensive lobbying in various forms, which considerably inflate the costs to all concerned. There is also some statistical evidence that bankruptcy costs and delays are related to the complexity of the affected corporation, and complexity is plausibly connected to the number of interest groups and thus expenditure on lobbying. But it would be worthwhile to investigate also who bears costs and receives benefits ex ante, as measured, for example, by the reaction of market prices to relevant regulatory innovations.

• Why is information on bank asset encumbrance not more readily available? Appropriate pricing of both collateralized and non-collateralized borrowing depends on making good estimates of probability of failure and of loss given default facing different creditors, and thus of the degree of outstanding asset encumbrance. Yet it is difficult to obtain current or detailed, bank-by-bank information: one may use published accounts to quantify a bank’s deposit base—if deposits enjoy preferential status—and the volume of covered bonds that it has issued, but typically one cannot know the volume of assets pledged in the interbank market, to the central bank, in liquidity swap and derivative deals, etc. Presumably a bank in a weak position is afraid to reveal that fact and face a “squeeze” on its position. However, there seem to be incentives for strong banks to disclose information, and thus to force others to reveal more. To some extent this occurs: many banks repaid as early as possible financing from the ECB’s Long-Term Refinancing Operation, presumably to demonstrate their strength. If banks do not volunteer much information on encumbrance, there could be grounds for imposing greater transparency through regulation, but national authorities have traditionally reserved the right to provide central bank refinancing on a confidential basis. [The European Systemic Risk Board recently issued recommendations to enhance prudential oversight of asset encumbrance and related market transparency, but explicitly prohibits the revelation of data on assets encumbered to central banks (see "Recommendations of European Systemic Risk Board of 20 December 2012 on funding of credit institutions" (ESRB/2012/2), available at http://www.esrb.europa.eu/pub/pdf/recommendations/2012/ESRB_2011_2.en.pdf?e622821b9c3171124f1d85f3a1b4d40e ).]

• What are the implications for funding behavior and stability of heterogeneity among creditors in their litigating/lobbying ability and incentives? Welch (1997) has initiated a discussion of the question, with a focus on a non-financial corporate facing a dominant bank creditor, but the situation of banks, with many retail and wholesale counterparties, may be rather different. The interests of those most effective in lobbying may not coincide with those of society or the prudential regulator. One advantage of depositor preference is that it protects the interests of a large number of creditors with a substantial portion of claims for whom, however, it is individually relatively expensive to defend those claims in case of resolution; the weak atomistic depositors are molded into one dominant creditor. In this connection, differences in lobbying ability could account for aspects of market segmentation: those with low costs might specialize in the holding of certain instruments, and those with high costs (or funding constraints) might want to concentrate on holding secured, bankruptcy-remote assets.

• In what ways would statutory bail-in of unsecured creditors be symmetric to the granting depositors preferred status, and in what ways would contingent capital (“CoCos”) be symmetric to collateralized credit?


The framework would need to be extended to analyze how different forms of asset encumbrance might affect bank liquidity risk, taking into account the availability of other liquidity buffers and interaction with solvency risk. Indeed, liquidity and solvency risk are deeply connected, especially for banks. Furthermore, illiquidity, like bankruptcy, is “a situation in which existing claims are inconsistent,” and so suited to an analysis based on costly resolution of conflict, rather than the application of predetermined rules and contracts. In all cases, one category of claimant is assigned a special status in case of bankruptcy or resolution—some are assigned an especially weak position, others an especially strong one. The incentives for, and ability of the different claimants to lobby for larger compensation is therefore affected. For example, those clearly subject to a statutory bail-in would not devote resources to contesting claims with those in a clearly superior position, and thus bankruptcy costs could be reduced. Holders of bail-in-able securities or CoCos would presumably demand higher yields to compensate for this risk, which in itself may increase risk of distress, but there could be some net benefit.

Wednesday, July 17, 2013

IMF Papers on Macroprudential Policies and Systemic Risk Monitoring

1  The Macroprudential Framework: Policy Responsiveness and Institutional Arrangements

Author/Editor:     Cheng Hoon Lim ; Ivo Krznar ; Fabian Lipinsky ; Akira Otani ; Xiaoyong Wu

IMF Working Paper No. 13/166, July 17, 2013
http://www.imf.org/external/pubs/cat/longres.aspx?sk=40789.0

Summary: This paper gauges if, and how, institutional arrangements are correlated with the use of macroprudential policy instruments. Using data from 39 countries, the paper evaluates policy response time in various types of institutional arrangements for macroprudential policy and finds that the macroprudential framework that gives the central bank an important role is associated with more timely use of macroprudential policy instruments. Policymakers may also tend to use macroprudential instruments more quickly if the ability to conduct monetary policy is somehow constrained. This finding points to the importance of coordination between macroprudential and monetary policy.




2  Evaluating the Net Benefits of Macroprudential Policy: A Cookbook

Author/Editor:     Nicolas Arregui ; Jaromir Benes ; Ivo Krznar ; Srobona Mitra ; Andre Santos

IMF Working Paper No. 13/167, July 17, 2013
http://www.imf.org/external/pubs/cat/longres.aspx?sk=40790.0

Summary: The paper proposes a simple, new, analytical framework for assessing the cost and benefits of macroprudential policies. It proposes a measure of net benefits in terms of parameters that can be estimated: the probability of crisis, the loss in output given crisis, policy effectiveness in bringing down both the probability and damage during crisis, and the output-cost of a policy decision. It discusses three types of policy leakages and identifies instruments that could best minimize the leakages. Some rules of thumb for policymakers are provided.



3   Systemic Risk Monitoring ("SysMo") Toolkit—A User Guide

Author/Editor:     Nicolas R. Blancher ; Srobona Mitra ; Hanan Morsy ; Akira Otani ; Tiago Severo ; Laura Valderrama

IMF Working Paper No. 13/168, July 17, 2013
http://www.imf.org/external/pubs/cat/longres.aspx?sk=40791.0

Summary: There has recently been a proliferation of new quantitative tools as part of various initiatives to improve the monitoring of systemic risk. The "SysMo" project takes stock of the current toolkit used at the IMF for this purpose. It offers detailed and practical guidance on the use of current systemic risk monitoring tools on the basis of six key questions policymakers are likely to ask. It provides "how-to" guidance to select and interpret monitoring tools; a continuously updated inventory of key categories of tools ("Tools Binder"); and suggestions on how to operationalize systemic risk monitoring, including through a systemic risk "Dashboard." In doing so, the project cuts across various country-specific circumstances and makes a preliminary assessment of the adequacy and limitations of the current toolkit.

Bhidé and Phelps: Central Banking Needs Rethinking: The Fed's monetary policy is hazardous, its bank supervision ineffectual

Bhidé and Phelps: Central Banking Needs Rethinking. By Amar Bhidé and Edmund Phelps
The Fed's monetary policy is hazardous, its bank supervision ineffectual.
The Wall Street Journal, July 16, 2013, on page A15
http://online.wsj.com/article/SB10001424127887324879504578597721920923596.html

The Federal Reserve did well to supply liquidity after Lehman Brothers failed in September 2008 and the world was plunged into financial crisis. But since then the Fed's monetary policy has been increasingly hazardous and bank supervision by the Fed and other regulators dangerously ineffectual.

Monetary policy might focus on the manageable task of keeping expectations of inflation on an even keel—an idea of Mr. Phelps's in 1967 that was long influential. That would leave businesses and other players to determine the pace of recovery from a recession or of pullback from a boom.

Nevertheless, in late 2008 the Fed began its policy of "quantitative easing"—repeated purchases of billions in Treasury debt—aimed at speeding recovery. "QE2" followed in late 2010 and "QE3" in autumn 2012. Fed Chairman Ben Bernanke said in November 2010 that this unprecedented program of sustained monetary easing would lead to "higher stock prices" that "will boost consumer wealth and help increase confidence, which can also spur spending."

It is doubtful, though, that quantitative easing boosted either wealth or confidence. The late University of Chicago economist Lloyd Metzler argued persuasively years ago that a central-bank purchase, in putting the price level onto a higher path, soon lowers the real value of household wealth—by roughly the amount of the purchase, in his analysis. (People swap bonds for money, then inflation occurs, until the real value of money holdings is back to where it was.)

True, stock prices did rise in real terms in 2009-10. But surely that rebound in share prices from the panic of 2008 was mainly due to a stunning rise in after-tax corporate profits, much of it overseas. Stock markets did not begin their recent breakout until late 2012, by which time other factors were at work, such as Washington's heightened concern over continuing fiscal deficits on top of already high public debt and entitlements. Had Fed purchases raised stock prices to levels that caught the eye of business owners, the purchases might have prompted accelerated business investment, a powerful creator of jobs. But the rise was evidently too little and too late to hasten markedly the recovery.

Moreover, the Fed's quantitative easing appears not to have increased confidence and may have reduced it. No one—the Fed included—knows how much more it will buy or how much of its mountain of Treasurys will be sold back to the market. The Fed said it would end easing at serious signs of faster inflation. But as the housing bubble that preceded the financial crisis showed, imprudent speculation can be destructive without high inflation. Today we have banks, insurance companies and pension funds leveraging their assets and loading up on credit risks because prudence cannot provide acceptable returns.

The cost of this uncertainty can be considerable. An attendant foreboding may lie behind some of the depression in business investment—even if myopic traders in bonds and currencies are impervious to it and too-big-to-fail banks go on making one-way bets. Also, the time and money that businesses give to innovation and efficiency gains are squeezed if the businesses are distracted by the uncertainties surrounding monetary policy.

This ambiguity notwithstanding, President Obama commends Mr. Bernanke for "helping us recover much stronger than, for example, our European partners." Sure, the European Central Bank did not adopt quantitative easing. But the delay in Europe's recovery plausibly derives from the severity of its fiscal and banking problems and its structural disadvantages, such as inflexible labor markets and lack of institutions for early renegotiation of debts.

The Fed attributes persistent joblessness in the U.S. to a deficiency of aggregate demand, which the Fed blames on foreigners' thrift. But if the West's problem were simply that, it long ago would have increased its money supply to meet the increases demanded and would have invested in businesses at an increased pace to take advantage of the cheap credit.

Households have maintained their strong propensity to consume, persuaded that their retirement incomes will be topped up with entitlements. But consumer-goods production—giant machines needing only a guard and a dog, as some wag put it—is generally not labor-intensive enough to provide high employment at normal wages. A central bank's monetary policy, no matter how ambitious, cannot solve this structural problem.

What we do need from the Fed is reform of the ways banks are regulated and supervised. Tough, on-the-ground examination of individual banks not only helps keep them solvent, such scrutiny can also prevent out-of-control money growth without suppressing productive lending. Similarly, rules that discourage banks from relying on yield-chasing hot money will limit the runs and panics the Fed has to fight.

Unfortunately, over the past couple of decades, bank regulation, like the Fed's macro-interventions, has become more top-down and formulaic.

Until the 1980s, for instance, bank examiners would assess how large a capital buffer each bank should have, taking into account its specific risks instead of relying on internationally standardized ratios.

Dysfunctional rules have also sustained the growth of monolithic megabanks that have little interest in traditional productive lending.

Unsurprisingly, the Fed's aggressive monetary easing has helped large companies already flush with cash issue bonds at low rates, while small businesses have struggled to secure working-capital loans.

In a modern economy some areas of top-down control are likely to be unavoidable. But that does not mean we should settle for institutions that are less participatory or accountable. It is not desirable that seven people on the Federal Open Market Committee have the power to intervene on a massive scale based on theories that may or may not be right and do not reflect a popular consensus.

America has a constitutional takings clause, as well as checks and balances on the state's power of eminent domain. Such matters as tax laws and budgets are subject to votes rather than being left to "experts." These arrangements are as much about legitimacy and consent of the governed as they are about economic efficiency.

Congress passed the Federal Reserve Act in 1913 mainly to forestall and contain panics, discourage speculation and improve the supervision of banks, not to steer the economy. Indeed, the Federal Reserve System was set up as 12 more-or-less independent reserve banks to assuage concerns about centralized control and capture by financial interests.

Restoring the modest foundational aims and diffused governance of the Fed would be good for our economy and good for our democracy.

Mr. Bhidé, a professor at Tufts University's Fletcher School, is the author of "A Call for Judgment: Sensible Finance for a Dynamic Economy" (Oxford, 2010). Mr. Phelps, the 2006 Nobel laureate in economics and director of Columbia University's Center on Capitalism and Society, is the author of "Mass Flourishing: How Grassroots Innovation Created Jobs, Challenge and Change," forthcoming from Princeton University Press.

Tuesday, July 16, 2013

The Financial Instability Council - Regulators want to make insurers too big to fail. Uh-oh.

The Financial Instability Council
Regulators want to make insurers too big to fail. Uh-oh.
The Wall Street Journal, July 16, 2013, on page A14
http://online.wsj.com/article/SB10001424127887324634304578537490141477314.html

There's finally a healthy discussion in Washington about how to end too-big-to-fail banks. But before the government can start getting rid of taxpayer-backed behemoths, it first has to stop creating them.

The 2010 Dodd-Frank law classified all banks with more than $50 billion in assets as systemically important, and the federal Financial Stability Oversight Council (FSOC) is considering which non-banks should also be deemed too big to fail. Last year the board of regulators slapped the systemic tag on eight "financial market utilities," including clearinghouses, which means taxpayers now stand behind derivatives trading. Congratulations.

And last week the council, chaired by Treasury Secretary Jack Lew, declared that GE Capital, the finance arm of General Electric, GE and AIG are also officially important. Now the council is trying to designate insurer Prudential as systemic, and perhaps MetLife too.

GE Capital was rescued in the 2008 panic and thus deserves the systemic label. AIG seems to welcome the designation, perhaps because its current mix of businesses means that it will face a lighter regulatory burden than some competitors. But taxpayers should be cheered to learn that Prudential and MetLife are resisting membership in the too-big-to-fail club, and for good reason. It's a giant and counterproductive leap to conclude that the insurance business presents a systemic risk to the financial system.

AIG was a giant insurer when it failed, but its disastrous housing bets largely occurred outside its traditional insurance businesses, which have always been regulated by the states. The company's catastrophic wagers on the mortgage market were overseen by the U.S. Treasury's Office of Thrift Supervision. So of course Treasury's solution is to expand federal regulation to the businesses that weren't overseen by the department and didn't fail. Makes perfect Beltway sense.

But this logic should give taxpayers pause. Along with the "systemic" designation comes regulation that was created for banks, not for insurance companies, and that will create problems for taxpayers and policyholders. Any firm dubbed "systemically important" will be regulated by the Federal Reserve. This will likely mean heavy new capital requirements designed to prevent problems that generally don't exist at an insurer.

Banks accept short-term liabilities in the form of deposits and use them to fund long-term loans. This "maturity transformation" has wonderful economic benefits but carries the risk of failure if lots of depositors suddenly want to withdraw their funds. To address this risk, banks are required to maintain capital cushions and liquidity to meet deposit withdrawals that can occur at any time.

Insurers, by contrast, match long-term liabilities with long-term assets. Premiums to cover some event likely to occur decades in the future are invested in assets of a similar duration. There is little risk of a "run on the bank" because policyholders, unlike depositors, typically cannot demand the face value of their policies in cash. Tornadoes, car accidents and terminal cancer do occur, but they don't occur everywhere at once, and they are not triggered by a panic in financial markets.

Insurers can fail, but since customers cannot immediately demand their money the way bank depositors can, the failures tend to play out slowly over many years. States also typically require insurers to contribute to a fund to make up for the shortfall if one of them fails and its assets and liabilities don't match. Without the same immediate demands for cash as at a bank that's heading south, there is less risk of an asset fire sale that could roil markets.

Treating insurers like banks would also raise costs substantially at insurers as they scramble to comply with the new burdens. This means higher premiums for customers. MetLife hired consultant Oliver Wyman to calculate the consumer costs of bank regulation if applied to several insurers that could potentially fall under federal bank rules. The industrywide estimate: $5 billion to $8 billion a year.

If companies can't pass along these higher costs to customers and stay competitive, they are likely to exit the business, especially the capital-intensive life insurance market. That would mean less competition.

The other big risk is that the systemic risk designation could turn out to be self-fulfilling. If an insurer has to accept bank regulation, it might as well consider expanding into bank businesses. If it has to pay the regulatory costs of holding short-term liabilities, then the natural next step is to consider relying more on short-term funding, which almost everyone agrees was a key vulnerability leading into the 2008 crisis. Insurers may become riskier institutions than they now are, which means more risks for taxpayers.

This is no idle fear because the only certainty about financial regulation is that it never prevents the next crisis. Yet in order to reinforce the illusion of effective regulation, and vindicate the folly of Dodd-Frank, regulators are about to force insurance companies and customers who didn't cause the last crisis to pay more while encouraging firms to pursue riskier business thanks to an implied federal backstop. They should have called it the Financial Instability Council.

Monday, July 8, 2013

Discussion on balancing risk sensitivity, simplicity and comparability within the Basel capital standards initiated by the Basel Committee

Discussion on balancing risk sensitivity, simplicity and comparability within the Basel capital standards initiated by the Basel Committee
July 8, 2013
http://www.bis.org/press/p130708.htm

The Basel Committee on Banking Supervision today released a Discussion Paper on the balance between risk sensitivity, simplicity and comparability within the Basel capital standards.

In response to the financial crisis, the Basel Committee introduced a range of reforms designed to substantially raise the resilience of the banking system against shocks. In addition to these reforms, during 2012 the Committee commissioned a small group of its members (the Task Force on Simplicity and Comparability) to undertake a review of the Basel capital framework. The goal of the Task Force was to identify opportunities to remove undue complexity within the framework, and improve the comparability of its outcomes. The creation of the Task Force acknowledged that the framework has steadily grown over time as risk coverage has been expanded and more sophisticated risk measurement methodologies have been introduced.

The paper being released today discusses the reasons behind the evolution of the current framework, and outlines the potential benefits and costs that arise from a more risk sensitive methodology. The paper also discusses ideas that could possibly be explored to further reform the framework with the objective that it continues to strike an appropriate balance between the complementary goals of risk sensitivity, simplicity and comparability.

The purpose of the discussion paper is to seek views on this critical issue so as to help shape the Committee's thinking. At this stage, the Committee has not made a decision to pursue any of the ideas presented; the paper is being published to elicit comments and feedback from interested stakeholders, which will help the Committee refine its thinking in this area. Furthermore, the Committee remains firmly of the view that full, timely and consistent implementation of Basel III remains fundamental to building a resilient financial system, maintaining public confidence in regulatory ratios and providing a level playing field for internationally active banks. Adopting the Basel III reforms (higher and better quality capital, improved risk coverage, capital buffers, and liquidity and funding requirements) in accordance with the internationally-agreed transition period deadlines is itself an important step in improving the consistency of bank regulation globally.

Mr Stefan Ingves, Chairman of the Basel Committee and Governor, Sveriges Riksbank said: "The Committee is keenly aware of the current debate concerning the complexity of the current regulatory framework. For that reason, the Committee set up a Task Force last year to look at this issue in some depth. The Committee believes that it would benefit from further input on this critical issue before deciding on the merits of any specific changes to the current framework. The paper being released today is designed to encourage discussion amongst, and solicit views from, a broad set of stakeholders."

The Committee welcomes views on the issues outlined in this paper. Comments should be submitted by Friday 11 October 2013 by e-mail to baselcommittee@bis.org. Alternatively, comments may be sent by post to: Secretariat of the Basel Committee on Banking Supervision, Bank for International Settlements, CH-4002 Basel, Switzerland. All comments may be published on the website of the Bank for International Settlements unless a respondent explicitly requests confidential treatment.

Saturday, July 6, 2013

Report on the regulatory consistency of risk-weighted assets in the banking book issued by the Basel Committee

Report on the regulatory consistency of risk-weighted assets in the banking book issued by the Basel Committee
http://www.bis.org/press/p130705.htm
BCBS, Jul 5, 2013

The Basel Committee on Banking Supervision has today published its first report on the regulatory consistency of risk-weighted assets (RWAs) for credit risk in the banking book. This study is a part of its wider Regulatory Consistency Assessment Programme (RCAP), which is intended to ensure consistent implementation of the Basel III framework. The study draws on supervisory data from more than 100 major banks, as well as additional data on sovereign, bank and corporate exposures collected from 32 major international banks as part of a portfolio benchmarking exercise.

There is considerable variation across banks in average RWAs for credit risk in the banking book. The study published today finds that most of the variation in RWAs can be explained by broad differences in the composition of banks' assets, reflecting differences in risk preferences as intended under the risk-based capital framework. However, there is also material variation driven by diversity in bank and supervisory practices.

Through a portfolio benchmarking exercise, the study found a high degree of consistency in banks' assessment of the relative riskiness of obligors. That is, there was a high correlation in how banks rank a portfolio of individual borrowers. Differences exist, however, in the levels of estimated risk, as expressed in probability of default (PD) and loss-given-default (LGD), that banks assign. These differences drive the variation in risk weights attributable to individual bank practices, and could result in the reported capital ratios for some outlier banks varying by as much as 2 percentage points from a 10% risk-based capital ratio benchmark (or 20% in relative terms) in either direction, although the capital ratios for most banks fall within a narrower range.

Notable outliers are evident in each asset class, with the corporate asset class showing the tightest clustering of banks around a central tendency, and the sovereign asset class showing the greatest variation. The low-default nature of the benchmark portfolios and the consequent challenges in obtaining appropriate data for risk estimation may be one factor contributing to differences across banks, especially for banks' estimates of LGDs in the sovereign and bank asset classes.

The report also includes a preliminary discussion of potential policy options that the Committee could pursue in seeking to minimise excessive practice-based variations. The Committee is conscious of the need to ensure that the capital framework retains its risk sensitivity, while at the same time promoting improved comparability of regulatory capital calculations by banks.

Commenting on the report, Stefan Ingves, Chairman of the Basel Committee and Governor of Sveriges Riksbank, said: "While some variation in risk weightings should be expected with internal model-based approaches, the considerable variation observed warrants further attention. In the near term, information from this study on the relative positions of banks is being used by national supervisors and banks to take action to improve consistency. In addition, the Committee is using the results as part of its ongoing work to improve the comparability of the regulatory capital ratios and to enhance bank disclosures. The Committee will be considering similar exercises to monitor consistency in capital outcomes and assess improvement over time."

Friday, July 5, 2013

Credit and growth after financial crises, by Elod Takats and Christian Upper

Credit and growth after financial crises, by Előd Takáts and Christian Upper
BIS Working Papers No 416
July 2013
http://www.bis.org/publ/work416.htm

We find that declining bank credit to the private sector will not necessarily constrain the economic recovery after output has bottomed out following a financial crisis. To obtain this result, we examine data from 39 financial crises, which - as the current one - were preceded by credit booms. In these crises the change in bank credit, either in real terms or relative to GDP, consistently did not correlate with growth during the first two years of the recovery. In the third and fourth year, the correlation becomes statistically significant but remains small in economic terms. The lack of association between deleveraging and the speed of recovery does not seem to arise due to limited data. In fact, our data shows that increasing competitiveness, via exchange rate depreciations, is statistically and economically significantly associated with faster recoveries. Our results contradict the current consensus that private sector deleveraging is necessarily harmful for growth.

Keywords: creditless recovery, financial crises, deleveraging, household debt, corporate debt

JEL classification: G01, E32


Conclusion
We find that bank lending to the private sector and economic growth are essentially uncorrelated after those financial crises that were preceded by credit booms. This result is relevant for the major advanced economies recovering from the financial crisis, since the current crisis was also preceded by a credit boom. Our results suggest that the ongoing deleveraging in advanced economies might not be as harmful for the recovery as many fear.

We also find that depreciating real exchange rates are statistically and economically significantly associated with substantially stronger economic growth.  This finding on real exchange rates shows that the price channel for external adjustment can contribute to stronger economic activities. Consequently, if crisis hit countries can generate substantial real effective exchange rate depreciation, either via nominal exchange rate depreciation or internal cost adjustments, this could hasten their recovery. However, given the global nature of the current crisis this solution might not be available for all countries at the same time.

Furthermore, we find some weak negative association between public debt ratios and recoveries: increasing public debt seems to lead to somewhat weaker recoveries. This might cast doubt on the claims that fiscal stimulus is the appropriate answer to fasten the recovery now.

While we are aware that these results come with caveats, we believe that our results provide a useful contribution to the creditless recovery literature. We hope that these finding would elicit debates and further research to understand debt dynamics, financial crises and how recoveries work.