I may not always agree with everything they have to say, but there are a few people who reliably produce content and ideas worth reading, Andy Haldane is one and Claudio Borio is another (see previous posts on Haldane here and Borio here for examples of their work). So I was interested to read what Borio had to say about the introduction of Expected Credit Loss (ECL) provisioning. ECL is one of those topic that only interests the die-hard bank capital and credit tragics but I believe it has the potential to create some problems in the real world some way down the track.
Borio’s position is that:
- Relative to the “incurred loss” approach to credit risk that precedes it, the new standard is likely to mitigate pro cyclicality to some extent;
- But it will not be sufficient on its own to eliminate the risk of adverse pro cyclical impacts on the real economy;
- So there is a need to develop what he calls “capital filters” (a generic term encompassing capital buffers and other tools that help mitigate the risk of pro cyclicality) that will work in conjunction with, and complement, the operation of the loan loss provisions in managing credit risk.
There are two ways to respond to Claudio Borio’s observations on this topic:
- One is to take issue with his view that Expected Credit Loss provisioning will do anything at all to mitigate pro cyclicality;
- The second is to focus on his conclusion that ECL provisioning by itself is not enough and that a truly resilient financial system requires an approach that complements loan provisions
Will ECL reduce the risk of pro cyclicality?
It is true that, relative to the incurred loss model, the ECL approach will allow loan loss provisions to be put in place sooner (all other things being equal). In scenarios where banks have a good handle on deteriorating economic conditions, then it does gives more freedom to increase provisions without the constraint of this being seen to be a cynical device to “smooth” profits.
The problem I see in this assessment is that the real problems with the adequacy of loan provisioning occur when banks (and markets) are surprised by the speed, severity and duration of an economic downturn. In these scenarios, the banks may well have more ECL provisions than they would otherwise have had, but they will probably still be under provisioned.
This will be accentuated to the extent that the severity of the downturn is compounded by any systematic weakness in the quality of loans originated by the banks (or other risk management failures) because bank management will probably be blind to these failures and hence slow to respond. I don’t think any form of Expected Loss can deal with this because we have moved from expected loss to the domain of uncertainty.
The solution to pro cyclicality lies in capital not expected loss
So the real issue is what to do about that. Borio argues that, ECL helps, but you really need to address the problem via what he refers to as “capital filters” (what we might label as counter cyclical capital buffers though that term is tainted by the failure of the existing system to do much of practical value thus far). On this part of his assessment, I find myself in violent agreement with him:
- let accounting standards do what they do, don’t try to make them solve prudential problems;
- construct a capital adequacy solution that complements the accounting based measurement of capital and profits.
Borio does not offer any detail on exactly what these capital solutions might look like, but the Bank of England and the OFSI are working on two options that I think are definitely worth considering.
In the interim, the main takeaway for me is that ECL alone is not enough on its own to address the problem of pro cyclicality and, more importantly, it is dangerous to think it can.
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