I am very far from expert on the issues discussed in the podcast this post links to, I am trying however to “up-skill”. The subject matter is a touch wonky so this is not a must listen recommendation. That said, the questions of DeFi and cryptocurrency are ones that I believe any serious student of banking and finance needs to understand.
In the podcast Demetri Kofinas (Host of the Hidden Forces podcast) is interviewed by two strong advocates of DeFi and crypto debating the potential of computer code to supplant legal structures as an operating framework for society. Demetri supports the idea that smart contracts can automate agreements but argues against the belief that self-executing software can or should supplant our legal systems. Computer code has huge potential in these applications but he maintains that you will still rely on some traditional legal and government framework to protect property rights and enforce property rights. He also argues that it is naïve and dangerous to synonymize open-source software with liberal democracy.
I am trying to keep an open mind on these questions but (thus far) broadly support the positions Demetri argues. There is a lot of ground to cover but Demetri is (based on my non-expert understanding of the topic) one of the better sources of insight I have come across.
I have posted a number of times on the question of residential mortgage risk weights, either on the general topic of the comparison of the risk weights applied to the standardised and IRB ADIs (see here) or the reasons why risk weights for IRB ADIs can be so low (see here).
On the question of relative risk weights, I have argued that the real difference between the standardised and IRB risk weights is overstated when framed in terms of simplistic comparisons of nominal risk weights that you typically read in the news media discussion of this question. I stand by that general assessment but have conceded that I have paid insufficient attention to the disparity in risk weights at the higher quality end of the mortgage risk spectrum.
A Discussion Paper released by APRA offers a useful discussion of this low risk weight question as part of a broader set of proposals intended to improve the transparency, flexibility and resilience of the Australian capital adequacy framework.
In section 4.2.1 of the paper, APRA notes the concern raised by standardised ADIs…
A specific concern raised by standardised ADIs in prior rounds of consultation has been the difference in capital requirements for lending at low LVRs. Stakeholders have noted that the lowest risk weight under the standardised approach would be 20 per cent under the proposed framework, but this appears to be significantly lower for the IRB approach. In response to this feedback, APRA has undertaken further analysis at a more detailed level, noting the difference in capital requirements that need to be taken into account when comparing capital outcomes under the standardised and IRB approaches (see Box 2 above).
But APRA’s assessment is that the difference is not material when you look beyond the simplistic comparison of risk weights and consider the overall difference in capital requirements
APRA does not consider that there is a material capital difference between the standardised and IRB approaches at the lower LVR level. For loans with an LVR less than 60 per cent, APRA has estimated that the pricing differential that could be reasonably attributed to differences in the capital requirements between the two approaches would be lower than the differential at the average portfolio outcome.
In explaining the reasons for this conclusion, APRA addresses some misconceptions about the IRB approach to low LVR lending compared to the standardised approach
In understanding the reasons for this outcome, it is important to understand the differences in how the standardised and IRB approaches operate. In particular, there are misconceptions around the capital requirement that would apply to low LVR lending under the IRB approach. For example, it would not be appropriate to solely equate the lowest risk weight reported by IRB ADIs in market disclosures with low LVR loans. The IRB approach considers a more complex range of variable interactions compared to the standardised approach. Under the standardised approach, a low risk weight is assigned to a loan with a low LVR at origination.
One of the key points APRA makes is that IRB ADIs do not get to originate loans at the ultra low risk weights that have been the focus of much of the concern raised by standardised ADIs.
In particular, IRB estimates are more dynamic through the life of the loan, for example, they are more responsive to a change in borrower circumstances or movements in the credit cycle. Standardised risk weights generally do not change over the life of a loan. For an IRB ADI, the lowest risk weight is generally applied to loans that have significantly prepaid ahead of schedule. A low LVR loan on the standardised approach is not necessarily assigned the lowest risk weight under the IRB approach at origination.
APRA states that it is not appropriate to introduce “dynamic”factors into the standardised risk weight framework.
APRA is not proposing to include dynamic factors in determining risk weights under the standardised approach for the following reasons:
– the standardised approach is intended to be simple and aligned with Basel III. For the standardised approach, APRA considers it more appropriate to focus on origination rather than behavioural variables as this has more influence on the quality of the portfolio and leads to less procyclical capital requirements; and
– the average difference between standardised and IRB capital outcomes is much narrower at the point of origination, which is the key point for competition. While the difference between standardised and IRB capital outcomes could widen over the life of the loan, APRA has ensured that the difference in average portfolio outcomes remains appropriate
But that it does intend to introduce a 5 per cent risk weight floor into the IRB approach to act as a backstop.
That said, APRA is proposing to implement a 5 per cent risk-weight floor for residential mortgage exposures under the IRB approach, to act as a simple backstop in ensuring capital outcomes do not widen at the lower risk segment of the portfolio. This is consistent with the approach taken by other jurisdictions and will limit the difference in capital outcomes between the standardised and IRB approaches for lower risk exposures. This risk-weight floor is in addition to other factors that will reduce the difference in capital outcomes between standardised and IRB ADIs, such as the higher CCB for IRB ADIs and lower CCF estimates for standardised ADIs.
As always, it remains possible that I am missing something. The explanation offered by APRA however gives me confidence that my broad argument about the overstatement of the difference has been broadly correct. Equally importantly, the changes to residential mortgage risk weights proposed in the Discussion Paper will further reduce the gap that does exist.
Wayne Byres speech to the Risk Management Association covered a range of developments but, for me, the important part was the discussion of the distinction between strength and resilience referenced in the title of this post.
This extract from the speech sets out how Mr Byres frames the distinction …
… in the post-GFC period, the emphasis of the international reforms was on strengthening the global financial system. Now, the narrative is how to improve its resilience. A perusal of APRA speeches and announcements over time shows a much greater emphasis on resilience in more recent times as well.
What is behind this shift? Put simply, it is possible to be strong, but not resilient. Your car windscreen is a great example – without doubt it is a very strong piece of glass, but one small crack and it is irreparably damaged and ultimately needs to be replaced. That is obviously not the way we want the financial system to be. We want a system that is able to absorb shocks, even from so-called “black swan” events, and have the means to restore itself to full health.
In saying that, financially strong balance sheets undoubtedly help provide resilience, and safeguarding financial strength will certainly remain the cornerstone of prudential regulation and supervision. But it is not the full story. So with that in mind, let me offer some quick reflections on the past year, and what it has revealed about opportunities for the resilience of the financial system to be further improved.
APRA Chair Wayne Byres – Speech to the 2020 Forum of the Risk Management Association – 3 December 2020
To my mind, the introduction of an increased emphasis on resilience is absolutely the right way to go. We saw some indications of the direction APRA intend to pursue in the speech that Mr Byres gave to the AFR Banking and Wealth Summit last month and will get more detail next week (hopefully) when APRA releases a consultation paper setting out a package of bank capital reforms that is likely to include a redesign of the capital buffer framework.
This package of reforms is one to watch. To the extent that it delivers on the promise of increasing the resilience of the Australian banking system, it is potentially as significant as the introduction of the “unquestionably strong” benchmark in response to the Australian Financial System Inquiry.
APRA released a discussion paper in August 2018 titled “Improving the transparency, comparability and flexibility of the ADI capital framework” which offered two alternative paths.
One (“Consistent Disclosure”) under which the status quo would be largely preserved but where APRA would get involved in the comparability process by adding its imprimatur to the “international harmonised ratios” that the large ADIs use to make the case for their strength compared to their international peers, and
A second (“Capital Ratio Adjustments”) under which APRA would align its formal capital adequacy measure more closely with the internationally harmonised approach.
I covered those proposals in some detail here and came out in favour of the second option. I don’t imagine APRA pay much attention to my blog but in a speech delivered to the AFR Banking and Wealth Summit Wayne Byres flagged that APRA do in fact intend to pursue the second option.
The speech does not get into too much detail but it listed the following features the proposed new capital regime will exhibit:
– more risk-based – by adjusting risk weights in a range of areas, some up (e.g. for higher risk housing) and some down (e.g. for small business); – more flexible – by changing the mix between minimum requirement and buffers, utilising more of the latter; – more transparent – by better aligning with international minimum standards, and making the underlying strength of the Australian framework more visible; – more comparable – by, in particular, making sure all banks disclose a capital ratio under the common, standardised approach; and – more proportionate – by providing a simpler framework suitable for small banks with simple business models.
… while also making clear that
… probably the most fundamental change flowing from the proposals is that bank capital adequacy ratios will change. Specifically, they will tend to be higher. That is because the changes we are proposing will, in aggregate, reduce risk-weighted assets for the banking system. Given the amount of capital banks have will be unchanged, lower risk-weighted assets will produce higher capital ratios.
However, that does not mean banks will be able to hold less capital overall. I noted earlier that a key objective is to not increase capital requirements beyond the amount needed to meet the ‘unquestionably strong’ benchmarks. Nor is it our intention to reduce that amount. The balance will be maintained by requiring banks to hold larger buffers over their minimum requirements.
One observation at this stage …
It is hard to say too much at this stage given the level of detail released but I do want to make one observation. Wayne Byres listed four reasons for the changes proposed;
To improve risk sensitivity
To make the framework more flexible, especially in times of stress
To make clearer the fundamental strength of our banking system vis-a-vis international peers
To ensure that the unquestionably strong capital built up prior to the pandemic remains a lasting feature of the Australian banking system.
Pro-cyclicality remains an issue
With respect to increasing flexibility, Wayne Byres went on to state that “Holding a larger proportion of capital requirements in the form of capital buffers main that there is more buffer available to be utilised in times of crisis” (emphasis added).
It is true that the capital buffer will be larger in basis points terms by virtue of the RWA (denominator in the capital ratio) being reduced. However, it is also likely that the capital ratio will be much more sensitive to the impacts of a stress/crisis event.
This is mostly simple math.
I assume that loan losses eating into capital are unchanged.
It is less clear what happens to capital deductions (such as the CET1 deduction for Regulatory Expected Loss) but it is not obvious that they will be reduced.
Risk Weights we are told will be lower and more risk sensitive.
The lower starting value for RWA in any adverse scenario means that the losses (we assume unchanged) will translate into a larger decline in the capital ratio for any given level of stress.
There is also the potential for the decline in capital ratios under stress to be accentuated (or amplified) to the extent the average risk weights increase in percentage terms more than they would under the current regime.
None of this is intended to suggest that APRA has made the wrong choice but I do believe that the statement that “more buffer” will be available is open to question. The glass is however most definitely half full. I am mostly flagging the fact that pro-cyclicality is a feature of any risk sensitive capital adequacy measure and I am unclear on whether the proposed regime will do anything to address this.
The direction that APRA has indicated it intends to take is the right one (I believe) but I think there is an opportunity to also address the problem of pro-cyclicality. I remain hopeful that the consultation paper to be released in a few weeks will shed more light on these issues.
Tony – From the Outside
p.s. the following posts on my blog touch on some of the issues that may need to be covered in the consultation
The 50th anniversary of Milton Friedman’s 1970 essay has triggered a deluge of commentary celebrating or critiquing the ideas it proposed. My bias probably swings to the “profit maximisation is not the entire answer” side of the debate but I recognised that I had not actually read the original essay. Time, I thought, to go back to the source and see what Friedman actually said.
I personally found this exercise useful because I realised that some of the commentary I had been reading was quoting him out of context or otherwise reading into his essay ideas that I am not sure he would have endorsed. I will leave my comment on the merits of his doctrine to another post.
Friedman’s doctrine of the limits of corporate social responsibility
Friedman’s famous (or infamous) conclusion is that in a “free” society…
“there is one and only one social responsibility of business—to use its resources and engage in activities designed to increase its profits so long as it stays within the rules of the game, which is to say, engages in open and free competition without deception fraud.”
My more detailed notes on what Friedman wrote can be found here. That note includes lengthy extracts from the essay so that you can fact check my paraphrasing of what he said. My summary of his argument as I understand it runs as follows:
Friedman first seeks to establish that any meaningful discussion of social responsibility has to focus on the people who own or manage the business, not “the business” itself.
If we focus on the corporate executives who manage the business as agents of the shareholders, Friedman argues that these executive should only use the resources of a company to pursue the objectives set by their “employer” (i.e. the shareholders).
What do the shareholders want the business to do?
Friedman acknowledges that some may have different objectives but he assumes that profit maximisation constrained by the laws and ethical customs of the society in which they operate will be goal of most shareholders
The key point however is that corporate executives have no authority or right to pursue any objectives other than those defined by their employer (the shareholders) or which otherwise serve the interests of those people.
Friedman also argues that the expansion of social responsibilities introduces conflicts of interest into the management of the business without offering any guide or proper process for resolving them. Having multiple (possibly ill defined and conflicting) objectives is, Friedman argues, a recipe for giving executives an excuse to underperform.
Friedman acknowledges that corporate executives have the right to pursue whatever social responsibilities they choose in their private lives but, as corporate executives, their personal objectives must be subordinated to the responsibility to achieve the objectives of the shareholders, their ultimate employers.
It is important to understand how Friedman defined the idea of a corporate executive having a “social responsibility”. He argues that the concept is only meaningful if it creates a responsibility that is not consistent with the interests of their employer.
Friedman might be sceptical on the extent to which it is true, but my read of his essay is that he is not disputing the rights of a business to contribute to social and environmental goals that management believe are congruent with the long term profitability of the business.
Friedman argues that the use of company resources to pursue a social responsibility raises problematic political questions on two levels: principle and consequences.
On the level of POLITICAL PRINCIPLE, Friedman uses the rhetorical device of treating the exercise of social responsibility by a corporate executive as equivalent to the imposition of a tax
But it is intolerable for Friedman that this political power can be exercised by a corporate executive without the checks and balances that apply to government and government officials dealing with these fundamentally political choices.
On the grounds of CONSEQUENCES, Friedman questions whether the corporate executives have the knowledge and expertise to discharge the “social responsibilities” they have assumed on behalf of society. Poor consequences are acceptable if the executive is spending their own time and money but unacceptable as a point of principle when using someone else’s time and money.
Friedman cites a list of social challenges that he argues are likely to lay outside the domain of a corporate executive’s area of expertise
Private competitive enterprise is for Friedman the best way to make choices about how to allocate resources in society. This is because it forces people to be responsible for their own actions and makes it difficult for them to exploit other people for either selfish or unselfish purposes.
Friedman considers whether some social problems are too urgent to be left to the political process but dismisses this argument on two counts. Firstly because he is suspicious about how genuine the commitment to “social responsibility” really is but mostly because he is fundamentally committed to the principle that these kinds of social questions should be decided by the political process.
Friedman acknowledges that his doctrine makes it harder for good people to do good but that, he argues, is a “small price” to pay to avoid the greater evil of being forced to conform to an objective you as an individual do not agree with.
Friedman also considers the idea that shareholders can themselves choose to contribute to social causes but dismisses it. This is partly because he believes that these “choices” are forced on the majority by the shareholder activists but also because he believes that using the “cloak of social responsibility” to rationalise these choices undermines the foundations of a free society.
That is a big statement – how does he justify it?
He starts by citing a list of ways in which socially responsible actions can be argued (or rationalised) to be in the long-run interests of a corporation.
Friedman acknowledges that corporate executives are well within their rights to take “socially responsible” actions if they believe that their company can benefit from this “hypocritical window dressing”.
Friedman notes the irony of expecting business to exercise social responsibility by foregoing these short term benefits but argues that using the “cloak of social responsibility” in this way harms the foundations of a free society
Friedman cites the calls for wage and price controls (remember this was written in 1970) as one example of the way in which social responsibility can undermine a free society
But he also sees the trend for corporate executives to embrace social responsibility as part of a wider movement that paints the pursuit of profit as “wicked and immoral”. A free enterprise, market based, society is central to Friedman’s vision of a politically free society and must be defended to the fullest extent possible.
Here Friedman expands on the principles behind his commitment to the market mechanism as an instrument of freedom – in particular the principle of “unanimity” under which the market coordinates the needs and wants of individuals and no one is compelled to do something against their perceived interests.
He contrasts this with the principle of “conformity” that underpins the political mechanism.
In Friedman’s ideal world, all decisions would be based on the principle of unanimity but he acknowledges that this is not always possible.
He argues that the line needs to be drawn when the doctrine of “social responsibility” extends the political mechanisms of conformity and coercion into areas which can be addressed by the market mechanism.
Friedman concludes by labelling “social responsibility” a “fundamentally subversive doctrine”.
But the doctrine of “social responsibility” taken seriously would extend the scope of the political mechanism to every human activity. It does not differ in philosophy from the most explicitly collectivist doctrine. It differs only by professing to believe that collectivist ends can be attained without collectivist means.
That is why, in my book “Capitalism and Freedom,” I have called it a “fundamentally subversive doctrine” in a free society, and have said that in such a society, “there is one and only one social responsibility of business—to use its resources and engage in activities designed to increase its profits so long as it stays within the rules of the game, which is to say, engages in open and free competition without deception fraud.”
Hopefully what I have set out above offers a fair and unbiased account of what Friedman actually said. If not then tell me what I missed. I think he makes a number of good points but, as stated at the beginning of this post, I am not comfortable with the conclusions that he draws. I am working on a follow up post where I will attempt to deconstruct the essay and set out my perspective on the questions he sought to address.
This interview with Rob Johnson (Institute for New Economic Thinking) does not contain any revelations but it does offer a good history of the politics of how the financial system was deregulated.
The RBNZ just released the results of the stress testing conducted by itself and a selection of the larger NZ banks to test resilience to the risks posed by COVID 19.
The extract below summarises the process the RBNZ followed and its key conclusions:
COVID-19 stress test consisted of two parts. First, a desktop stress test where the Reserve Bank estimated the impact on profitability and capital for nine of New Zealand’s largest banks to the impact of two severe but plausible scenarios. Second, the Reserve Bank coordinated a process in which the five largest banks used their own models to estimate the effect on their banks for the same scenarios.
The pessimistic baseline scenario can be characterised as a one-in-50 to one-in-75 year event with the unemployment rate rising to 13.4 percent and a 37 percent fall in property prices. In the very severe scenario, the unemployment rate reaches 17.7 percent and house prices fall 50 percent. It should be noted that these scenarios are hypothetical and are significantly more severe than the Reserve Banks’ baseline scenario.
The overall conclusion from the Reserve Bank’s modelling is that banks could draw on their existing capital buffers and continue lending to support lending in the economy during a downturn of the severity of the pessimistic baseline scenario. However, in the more severe scenario, banks capital fell below the regulatory minimums and would require significant mitigating actions including capital injections to continue lending. This reinforces the need for strong capital buffers to provide resilience against severe but unlikely events.
The results of this stress test supports decisions that were made as part of the Capital Review to increase bank capital levels. The findings will help to inform Reserve Bank decisions on the timing of the implementation of the Capital Review, and any changes to current dividend restrictions.
“Outcome from a COVID-19 stress test of New Zealand banks”, RBNZ Bulletin Vol 83, No 3 September 2020
I have only skimmed the paper thus far but there is one detail I think worth highlighting for anyone not familiar with the detail of how bank capital adequacy is measured – specifically the impact of Risk Weighted Assets on the decline in capital ratios.
The RBNZ includes two useful charts which decompose the aggregate changes in CET1 capital ratio by year two of the scenario.
In the “Pessimistic Baseline Scenario”(PBS), the aggregate CET1 ratio declines 3.7 percentage points to 7.7 percent. This is above both the regulatory minimum and the threshold for mandatory conversion of Additional Tier 1 Capital. What I found interesting was that RWA growth contributed 2.2 percentage points to the net decline.
The RBNZ quite reasonably points out that banks will amplify the downturn if they restrict the supply of credit to the economy but I think it is also reasonable to assume that the overall level of loan outstandings is not growing and may well be shrinking due to the decline in economic activity. So a substantial portion of the decline in the aggregate CET1 ratio is due to the increase in average risk weights as credit quality declines. The C ET1 ratio is being impacted not only by the increase in impairment expenses reducing the numerator, there is a substantial added decline due to the way that risk weighted assets are measured
RBNZ Desktop Results – Very Severe Scenario
In the “Very Severe Scenario”(VSS), the aggregate CET1 ratio declines 5.6 percentage points to 5.8 percent. The first point to note here is that CET1 only remains above the 4.5% prudential minimum by virtue of the conversion of 1.6 percentage points of Additional Tier 1 Capital. Assuming 100% of AT1 was converted, this also implies that the Tier 1 ratio is below the 6.0% prudential minimum.
These outcomes provide food for thought but I few points I think wroth considering further before accepting the headline results at face value:
The headline results are materially impacted by the pro cyclicality of the advanced forms of Risk Weighted Asset measurement – risk sensitive measures offer useful insights but we also need to understand they ways in which they can also amplify the impacts of adverse scenarios rather than just taking the numbers at face value
The headline numbers are all RBNZ Desktop results – it would be useful to get a sense of exactly how much the internal stress test modelling conducted by the banks varied from the RBNZ Desktop results – The RBNZ stated (page 12) that the bank results were similar to its for the PBS but less severe in the VSS.
As always, it is entirely possible that I am missing something but I feel that the answer to bank resilience is not just a higher capital ratio. A deeper understanding of the pro cyclicality embedded in the system will I think allow us to build a better capital adequacy framework. As yet I don’t see this topic getting the attention it deserves.
That I should be asking the question is even more curious given the years I spent working with economic capital but there was something in the ECB position that I was not comfortable with. There is nothing particularly wrong in the ways that the ECB envisages that an economic perspective can add value to a bank’s ICAAP. The problem (for me), I came to realise, is more the lack of emphasis on recognising the fundamental limitations of economic models. In short, my concern is that the detailed focus on risk potentially comes at the expense of an equally useful consideration of the ways in which a bank is subject to radical uncertainty.
The rest of this post offers an overview of what the ECB survey observed and some thoughts on the value of explicitly incorporating radical uncertainty into an ICAAP.
The ECB report sample set
The ECB report, based on a survey of 37 significant institutions it supervises, assesses the extent to which these organisations were complying (as at April 2019) with ECB expectations for how the ICAAP should be constructed and executed. The selected sample focuses on the larger (and presumably more sophisticated) banks, including all global systematically important banks supervised by the ECB. I am straying outside my area of expertise (Australian bank capital management) in this post but there is always something to learn from considering another perspective.
The ECB assessment on ICAAP practices
The ECB notes that progress has been made in some areas of the ICAAP. In particular; all banks in the survey have risk identification processes in place, they produce summary documents (“Capital Adequacy Statements” in ECB parlance) that enable bank management (not just the technical specialists) to engage with and take responsibility for the capital strength of their bank and the sample banks do incorporate stress testing into their capital planning process.
The ECB believes however that there is still a lot of room for improvement. The general area of concern is that the banks it supervises are still not paying sufficient attention to the question of business continuity. The ECB cites three key areas as being particularly in need of improvement if the ICAAPs are to play their assigned role in effectively contributing to a bank’s continuity:
Data quality
The application of the “Economic Perspective” in the ICAAP
Stress testing
The value of building the ICAAP on sound data and testing the outcomes of the process under a variety of severe stress scenarios is I think uncontentious.
The value the economic perspective contributes is less black and white. Like many thing in life, the challenge is to get the balance right. My perspective is that economic models are quite useful but they are far from a complete answer and dangerous when they create an illusion of knowledge, certainty and control.
“Under this perspective, the institution’s assessment is expected to cover the full universe of risks that may have a material impact on its capital position from an economic perspective. In order to capture the undisguised economic situation, this perspective is not based on accounting or regulatory provisions. Rather, it should take into account economic value considerations for all economically relevant aspects, including assets, liabilities and risks. …. The institution is expected to manage economic risks and assess them as part of its stress-testing framework and its monitoring and management of capital adequacy”
ECB Guide to the internal capital adequacy assessment process (ICAAP) – Principles, November 2018 (Paragraph 49 / pages 18-19)
So far so good – the key points seem (to me) to be quite fair as statements of principle.
The ECB sees value in looking beyond the accounting and regulatory measures that drive the reported capital ratios (the “normative perspective” in ECB terminology) and wants banks to consider “the full universe of risks that may have a material impact on its capital position”. The ECB Report also emphasises the importance of thinking about capital from a “business continuity” perspective and cites the “… unjustified inclusions of certain capital components (e.g. minority interests, Additional Tier 1 … or Tier 2 … instruments) … which can inflate the internal capital figures” as evidence of banks failing to meet this expectation. Again a fair point in my view.
These are all worthy objectives but I wonder
firstly about the capacity of economic capital models to reliably deliver the kinds of insights the ECB expects and
secondly whether there are more cost effective ways to achieve similar outcomes.
The value of a different perspective
As a statement of principle, the value of bringing a different perspective to bear clearly has value. The examples that the ECB cites for ways in which the economic perspective can inform and enhance the normative perspective are all perfectly valid and potentially useful. My concern is that the ECB seems to be pursuing an ideal state in which an ICAAP can, with sufficient commitment and resources, achieve a degree of knowledge that enables a bank to control its future.
Business continuity is ultimately founded on a recognition that there are limits to what we can know about the future and I side with the risk philosophy that no amount of analysis will fundamentally change this.
The ECB’s economic perspective does not neccesarily capture radical uncertainty
I have touched on the general topic of uncertainty and what it means for the ICAAP a couple of times in this blog. The ECB report mentions “uncertainty” twice; once in the context of assessing climate change risk
Given the uncertainty surrounding the timing of climate change and its negative consequences, as well as the potentially far-reaching impact in breadth and magnitude along several transmission channels via which climate-related risks may impact banks’ capital adequacy, it is rather concerning that almost one-third of the banks has not even considered these risks in their risk identification processes at all.
Page 39
… and then in the context of making allowances for data quality
However, … in an internal deep dive on risk quantification in 2019, half of the risk quantifications showed material deficiencies. This finding is exacerbated by the data quality issues generally observed and moreover by the fact that one-half of the banks does not systematically ensure that the uncertainty surrounding the accuracy of risk quantifications (model risk) is appropriately addressed by an increased level of conservatism.
Page 54
This is not a question of whether we should expect that banks can demonstrate that they are thinking about climate change and making allowances for model risk along with a host of other plausible sources of adverse outcomes. It is a surprise that any relatively large and sophisticated banks might be found wanting in the ways in which these risks are being assessed and the ECB is right to call that out.
However, it is equally surprising (for me at least) that the ECB did not seem to see value in systematically exploring the extent to which the ICAAPs of the banks it supervises deal with the potential for radical uncertainty.
Business continuity is far more likely if banks can also demonstrate that they recognise the limits of what they can know about the future and actively plan to deal with being surprised by the unexpected. In short one of the key ICAAP practices I would be looking for is evidence that banks have explicitly made allowances for the potential for their capital plan to have to navigate and absorb “unknown unknowns”.
Corporate Plans can be pretty dry reading but I had a quick skim of what is on APRA’s agenda for the next four years. The need to deal with consequences of COVID 19 obviously remains front and centre but APRA has reiterated its commitment to pursue the objectives laid out in its previous corporate plan.
Looking outward (what APRA refers to as “community outcomes”) there are four unchanged objectives
maintaining financial system resilience;
improving outcomes for superannuation members;
transforming governance, culture, remuneration and accountability across all regulated institutions; and
improving cyber resilience across the financial system.
Looking inward, APRA’s priorities are:
improving and broadening risk-based supervision;
improving resolution capacity;
improving external engagement and collaboration;
transforming data-enabled decision-making; and
transforming leadership, culture and ways of working.
What is interesting – from a bank capital managementperspective
What I found interesting was a reference in APRA’s four year roadmap for strategy execution to a commitment to “Finalisation of ADI capital regime” (page 26). The schematic provides virtually no detail other than a “Milestone” to be achieved by December 2020 and for the project to be completed sometime in 2022/23.
“… options to modify the ADI capital framework to improve transparency and comparability of reported capital ratios. The main conceptual approaches APRA is considering and seeking feedback on are:
developing more consistent disclosures without modifying the underlying capital framework; and
modifying the capital framework by adjusting the methodology for calculating capital ratios.”
The First Approach– “Consistent disclosure” – seems to be a beefed up version of the status quo in which APRA gets more directly involved in the comparability process by adding its imprimatur to the internationally harmonised ratios some Australian banks currently choose to disclose as an additional informal measure of capital strength.
“Under this approach, ADIs would continue to determine regulatory capital ratios using APRA’s definitions of capital and RWA. However, APRA would also specify a methodology for ADIs to determine certain adjustments to capital and RWA that could be used for disclosure (Pillar 3) purposes. As noted above, the methodology would focus on aspects of relative conservatism that are material in size and able to be calculated simply and objectively.”
APRA argues that “The supplementary disclosure would allow all stakeholders to better assess the capital strength of an ADI on a more comparable basis. However, it would result in two APRA-endorsed capital ratios: an APRA regulatory capital ratio to be compared against minimum requirements, and an additional disclosure-only capital ratio for, in particular, international comparison.”
A Second Approach – “Capital ratio adjustments” would involve APRA modifying the calculation of regulatory capital ratios to utilise more internationally harmonised definitions of capital and RWA.
The DP explains that this “… alternative approach would involve APRA modifying the calculation of regulatory capital ratios to utilise more internationally harmonised definitions of capital and RWA. This would involve removing certain aspects of relative conservatism from ADIs’ capital ratio calculations and lifting minimum regulatory capital ratio requirements in tandem. This increase in regulatory capital ratio requirements could be in the form of a transparent adjustment to minimum capital ratio requirements—for the purposes of this paper, such an adjustment is termed the ‘APRA Overlay Adjustment’.”
“To maintain overall capital adequacy, the APRA Overlay Adjustment would need to be calculated such that the total dollar amount of Prudential Capital Requirement (PCR) and Capital Conservation Buffer (CCB) would be the same as that required if these measures were not adopted. In other words, the risk-based capital requirements of ADIs would be unchanged in absolute dollar terms, maintaining financial safety, but adjustments to the numerator and the denominator of the capital ratio to be more internationally comparable would increase reported capital ratios.”
APRA clarify that
“These options are not mutually exclusive, and there is potential for both approaches to be adopted and applied in different areas.”
A BIS paper titled “Green Swan 2 – Climate change and Covid-19: reflections on efficiency versus resilience” initially caught my attention because of the reference to the tension between efficiency versus resilience. This tension is, for me at least, one of the issues that has tended to be ignored in the pursuit of growth and optimised solutions. The papers mainly deal with the challenges that climate change creates for central banks but I think there are also some insights to be drawn on what it means for bank capital management.
A core argument in the paper is that challenges like climate change and pandemics ….
“… require us to rethink the trade-offs between efficiency and resilience of our socio-economic systems … one way to address this issue is to think about buffers or some necessary degree of redundancy for absorbing such large shocks. Countries build FX reserves, banks maintain capital buffers as required by regulators, and so on. Perhaps similar “buffers” could be used in other areas of our societies. For example, could it be time to reassess our production systems, which are meant to be lean and less costly for maximum efficiency?”
The paper draws on a (much longer and more technical) BIS research paper titled “The green swan: Central banking and financial stability in the age of climate change”. Both papers contain the usual caveat that the views expressed do not necessarily reflect those of their respective institutions. With that warning noted, this post draws on both papers to make some observations about what the papers say, and what this means for bank capital management.
There is a lot of content in the combined papers but the points that resonated the most with me were
Climate change shares some of the features of a Black Swan event but is better thought of a distinct type of risk which the authors label a “Green Swan”.
Green swan problems are created in part by choices we have made regarding the value of efficiency over resilience – part of the solution lies in rethinking these choices but this will not be easy.
Climate change is a “collective action” problem which cannot be addressed by individual actors (including banks) operating independently – market based solutions like a carbon price may also be insufficient to bring about a solution that does not involve an unacceptable level of financial disruption.
Scenario analysis (including stress testing) appears to be one of the better tools for dealing with climate change and similar types of risk – but it needs to be used differently (by both the supervised and the supervisors) from the way it is applied to conventional risks.
I am not an expert on climate change modelling, but Chapter 3 of the second paper also has what looks to be a useful overview of the models used to analyse climate change and how the outputs of these models are used to generate economic impacts.
Black, white and green swans
Climate change clearly operates in the domain of radical uncertainty. As such it shares some common elements with “black swan” events; in particular the fact that conventional risk models and analysis are not well suited to measuring and managing the potential adverse impacts. It is equally important however to understand the ways in which climate change differs from a classic black swan event. There is a longer list but the ones that I found most relevant were:
Predictability – Black Swans are, by definition, not predictable whereas the potential for adverse Climate Change outcomes is well understood even if not universally accepted. The point is that understanding the potential for adverse impact means we have a choice about what to do about it.
Impact – Black Swan events can have substantial impacts but the system can recover (e.g. the GFC has left a lasting impact but economic activity did recover once the losses were absorbed). The impacts of climate change, in contrast, may be irreversible and have the potential to result in people dying in large numbers.
Given the conceptual differences, the authors classify Climate Change as a distinct form which they label a “Green Swan”. To the best of my knowledge, this may be the first time the term has been used in this way. That said, the general point they are making seems to be quite similar to what other authors have labelled as “Grey Rhinos” or “Black Elephants” (the latter an obvious allusion to the “elephant in the room”, a large risk that is visible to everyone but no one wants to address).
A typology of swans
A typology of Swans: similarities and differences – BIS Green Swan 2 – Climate change and Covid-19: reflections on efficiency versus resilience
Categorising climate risk
The papers distinguish two main channels through which climate change can affect financial stability – physical risks and transition risks.
Physical risks are defined as
… “those risks that arise from the interaction of climate-related hazards […] with the vulnerability of exposure to human and natural systems” (Batten et al (2016)). They represent the economic costs and financial losses due to increasing frequency and severity of climate-related weather events (eg storms, floods or heat waves) and the effects of long-term changes in climate patterns (eg ocean acidification, rising sea levels or changes in precipitation). The losses incurred by firms across different financial portfolios (eg loans, equities, bonds) can make them more fragile.
Transition risks are defined as those
“… associated with the uncertain financial impacts that could result from a rapid low-carbon transition, including policy changes, reputational impacts, technological breakthroughs or limitations, and shifts in market preferences and social norms.
A rapid and ambitious transition to lower emissions, for example, would obviously be desirable from the perspective of addressing climate change but might also mean that a large fraction of proven reserves of fossil fuel cannot be extracted, becoming “stranded assets”. The write down of the value of these assets may have potentially systemic consequences for the financial system. This transition might occur in response to policy changes or by virtue of some technological breakthrough (e.g. problem of generating cheap energy by nuclear fusion is solved).
Efficiency versus resilience
I started this post with a quote from the first (shorter) paper regarding the way in which the Covid 19 had drawn attention to the extent to which the pursuit of efficiency had made our economies more fragile. The paper explores the ways in which the COVID 19 pandemic exhibits many of the same features that we see in the climate change problem and how the global response to the COVID 19 pandemic might offer some insights into how we should respond to climate change.
The paper is a useful reminder of the nature of the problem but I am less confident that it offers a solution that will work without some form of regulation or public sector investment in the desired level of redundancy. The paper cites bank capital buffers introduced post GFC as an example of what to do but this was a regulated outcome that would most likely not be acceptable for non-financial companies in countries that remain committed to free market ideology.
The Economist published an article on this question that offered numerous examples of similar problems that illustrate the propensity of “humanity, at least as represented by the world’s governments … to ignore them until forced to react” .
If recent weeks have shown us anything, it’s that the world is not just flat. It’s fragile.
And we’re the ones who made it that way with our own hands. Just look around. Over the past 20 years, we’ve been steadily removing man-made and natural buffers, redundancies, regulations and norms that provide resilience and protection when big systems — be they ecological, geopolitical or financial — get stressed. We’ve been recklessly removing these buffers out of an obsession with short-term efficiency and growth, or without thinking at all.
The New York Times, 30 May 2020
Managingcollective action problems
The second paper, in particular, argues that it is important to improve our understanding of the costs of climate change and to ensure that these costs are incorporated into the prices that drive the resources we allocate to dealing with the challenge (e.g. via a carbon price or tax). However one of its key conclusions is that relying on markets to solve the problem is unlikely to be sufficient even with the help of some form of carbon price that reflects a more complete account of the costs of our current carbon based economy.
In short, the development and improvement of forward-looking risk assessment and climate- related regulation will be essential, but they will not suffice to preserve financial stability in the age of climate change: the deep uncertainty involved and the need for structural transformation of the global socioeconomic system mean that no single model or scenario can provide sufficient information to private and public decision-makers. A corollary is that the integration of climate-related risks into prudential regulation and (to the extent possible) into monetary policy would not suffice to trigger a shift capable of hedging the whole system again against green swan events.
The green swan: Central banking and financial stability in the age of climate change; Chapter 5 (page 66)
Using scenario based methodologies to assess climate related risks
Both papers highlight the limitations of trying to measure and understand climate change using conventional probability based risk management tools. The one area they do see as worth pursuing is using scenario based approaches. This makes sense to me but it is also important to distinguish this kind of analysis from the standard stress testing used to help calibrate capital buffers.
The standard application of stress testing takes a severe but plausible macro economic scenario such as a severe recession and determines what are the likely impacts on capital adequacy ratios. This offers a disciplined way of deciding how much capital surplus is required to support the risk appetite choices a bank has made in pursuit of its business objectives.
A simplistic application of climate based stress testing scenarios might take the same approach; i.e. work out how much the scenario impacts the capital and ensure that the buffer is sufficient to absorb the impact. That I think is not the right conclusion and my read of the BIS papers is that they are not advocating that either. The value of the scenario based modelling is to first get a handle on the size of the problem and how exposed the bank is to it. A capital response may be required but the answer may also be to change the nature of your exposure to the risk. That may involve reduced risk limits but it may also involve active participation in collective action to address the underlying problem. A capital management response may be part of the solution but it is far from the first step.
Conclusion
I have only scratched the surface of this topic in this post but the two papers it references are worth reading if you are interested in the question of what climate change, and related Green Swan or Black Elephant problems, mean for the banking system and for central banking. There is a bit more technical detail in the appendix below but it is likely only of interest for people working at the sharp end of trying to measure and manage the problem.
I want to dig deeper into the question of how you use stress testing to assess climate change and related types of risk but that is a topic best left for another post.
Tony – From the outside
Appendix – Modelling the impacts of climate change
Section 3 of the longer paper (“Measuring climate-related risks with scenario-based approaches”) discusses the limitations of the models that are typically used to generate estimates of the ecological and financial impacts of climate change scenarios. There is plenty of material there for climate sceptics but it also assists true believers to understand the limits of what they can actually know and how coming to terms with the radical uncertainty of how climate change plays out shapes the nature of our response.
I have copied some extracts from the chapter below that will give you a flavour of what it has to say. It is pretty technical so be warned …
“… the standard approach to modelling financial risk consisting in extrapolating historical values (eg PD, market prices) is no longer valid in a world that is fundamentally reshaped by climate change (Weitzman (2011), Kunreuther et al (2013)). In other words, green swan events cannot be captured by traditional risk management.
The current situation can be characterised as an “epistemological obstacle” (Bachelard (1938)). The latter refers to how scientific methods and “intellectual habits that were useful and healthy” under certain circumstances, can progressively become problematic and hamper scientific research. Epistemological obstacles do not refer to the difficulty or complexity inherent to the object studied (eg measuring climate-related risks) but to the difficulty related to the need of redefining the problem”
Page 21
nothing less than an epistemological break (Bachelard, 1938) or a “paradigm shift” (Kuhn (1962)) is needed today to overcome this obstacle and more adequately approach climate-relate risks (Pereira da Silva (2019a)).
In fact, precisely an epistemological break may be taking place in the financial sector: recently emerged methodologies aim to assess climate-related risks while relying on the fundamental hypothesis that, given the lack of historical financial data related to climate change and the deep uncertainty involved, new approaches based on the analysis of prospective scenarios are needed. Unlike probabilistic approaches to financial risk management, they seek to set up plausible hypotheses for the future. This can help financial institutions integrate climate-related risks into their strategic and operational procedures (eg for the purpose of asset allocation, credit rating or insurance underwriting) and financial supervisors assess the vulnerability of specific institutions or the financial system as a whole
Climate-economic models and forward-looking risk analysis are important and can still be improved, but they will not suffice to provide all the information required to hedge against “green swan” events.
As a result of these limitations, two main avenues of action have been proposed. We argue that they should be pursued in parallel rather than in an exclusive manner. First, central banks and supervisors could explore different approaches that can better account for the uncertain and nonlinear features of climate-related risks. Three particular research avenues (see Box 5 below) consist in: (i) working with non- equilibrium models; (ii) conducting sensitivity analyses; and (iii) conducting case studies focusing on specific risks and/or transmission channels. Nevertheless, the descriptive and normative power of these alternative approaches remain limited by the sources of deep and radical uncertainty related to climate change discussed above. That is, the catalytic power of scenario-based analysis, even when grounded in approaches such as non-equilibrium models, will not be sufficient to guide decision-making towards a low-carbon transition.
As a result of this, the second avenue from the perspective of maintaining system stability consists in “going beyond models” and in developing more holistic approaches that can better embrace the deep or radical uncertainty of climate change as well as the need for system-wide action (Aglietta and Espagne (2016), Barmes (2019), Chenet et al (2019a), Ryan-Collins (2019), Svartzman et al (2019)).
Pages 42 – 43
Embracing deep or radical uncertainty therefore calls for a second “epistemological break” to shift from a management of risks approach to one that seeks to assure the resilience of complex adaptive systems in the face of such uncertainty (Fath et al (2015), Schoon and van der Leeuw (2015)).38 In this view, the current efforts aimed at measuring, managing and supervising climate-related risks will only make sense if they take place within a much broader evolution involving coordination with monetary and fiscal authorities, as well as broader societal changes such as a better integration of sustainability into financial and economic decision-making.
From the outside 