Andrew Haldane

Claire Jones writing for the Financial Times Alphaville column confesses a fondness for the speeches of Andrew Haldane (departing chief economist at the Bank of England) . She offered a selection of favourites (you can access her column by signing up to Alphaville if you are not an FT subscriber).

I also rate pretty much everything he writes as worth reading often more than once to reflect on the issues he raises. To her top three Haldane speeches, I will add one he did in 2016 titled “The Great Divide” which explored the gap between the way banks perceive themselves and how they are perceived by the community.

Tony – From the Outside

What Can We Learn from a Big Boat Stuck in a Canal?

Interesting post by Matt Stoller on the broader policy issues associated with the current problem in the Sues Canal.

Here is a short extract capturing the main idea …

“Industrial crashes, in other words, are happening in unpredictable ways throughout the economy, shutting down important production systems in semi-random fashion. Such collapses were relatively rare prior to the 1990s. But industrial crashes were built into the nature of our post-1990s production system, which prioritizes efficiency over resiliency. Just as ships like the Ever Given are bigger and more efficient, they are also far riskier. And this tolerance for risk is a pattern reproducing itself far beyond the shipping industry; we’ve off shored production and then consolidated that production in lots of industries, like semiconductors, pharmaceutical precursors, vitamin C, and even book printing.

What is new isn’t the vulnerability of the Suez Canal as a chokepoint, it’s that we’ve intentionally created lots of other artificial chokepoints. And since our production systems have little fat, these systems are tightly coupled, meaning a shortage in one area cascades throughout the global economy, costing us time, money, and lives.”

Irrespective of whether you agree with the solutions he proposes, I think the point he makes (i.e. the tension between efficiency and resilience and the systemic problem with systems that are “tightly coupled”) is a very real issue. We saw this play out in the financial system in 2008 and we saw it play out in global supply chains in 2020. There are differing views on whether the measures have gone far enough but the financial system has been substantially re-engineered to make it more resilient. It remains to be seen how global supply chains will evolve in response to the problems experienced.

Link to the post here

https://mattstoller.substack.com/p/what-we-can-learn-from-a-big-boat

Tony – From the Outside

In Search of a Post-Pandemic Modeling Paradigm – Risk Weighted

Nice post from Tony Hughes discussing the difference between modelling intended to forecast a most likely outcome and modelling tail risk …

“A forecasting mindset yields very tight models, whereas a tail risk mindset demands a far more liberal approach to model specification.”

— Read on riskweighted.com/2021/03/03/in-search-of-a-post-pandemic-modeling-paradigm/

Allowing companies to fail

I suspect (but can’t prove) that creative destruction is one of the under appreciated factors that underpin the health of the economy. There is quite a lot of evidence however that creative destruction has been suppressed since the 2008 Global Financial Crisis. The rights and wrongs of the extent to which bail-outs were and continue to be necessary is too big a topic to cover in this post.

For the record, I do believe that the bail-outs of the banks were necessary at the time but that “bail-in” gives bank supervisors a very real option to avoid having to do this in the future. The increase in capital requirements are also likely to reduce the risk of a bail-in being required. Others may disagree and my views chiefly relate to the Australian banking system which is where my professional expertise is based. The issues associated with COVID-19 raise a whole lot of related but, in many ways, different issues. At the risk of stating the obvious, it’s complicated.

Against that background, I found this short article published on the VoxEU website worth reading as another reminder of the value of allowing companies to fail and/or be restructured. The conclusion of the article (copied below) gives you the key points the authors derive from their research

We investigate a large number of stakeholders that could be negatively affected by a fire sale but find little evidence for negative externalities. The main effect of fire sales is a wealth transfer from the seller to the buyer. Thus, from a welfare perspective, the costs associated with fire sales of corporate assets are much lower than previously thought based on an analysis of seller costs only. From a policy perspective, these findings indicate that the merits of bailouts as a response to the potential losses associated with fire sales are limited, especially given the moral hazard and the other distortions caused by these bailouts. 

We recognise that the economic shock caused by the COVID-19 pandemic is unparalleled since the WWII and the Great Depression, and hence, some emergency measures and bailouts were likely necessary to prevent a meltdown of economic activity. However, one difference between the current crisis and the Global Crisis is the apparent lack of fire sales of struggling companies or investments into such companies at fire-sale prices. Warren Buffett’s Berkshire Hathaway, for instance, invested $5 billion in Goldman Sachs in September 2008 and $3 billion in General Electric in October 2008, while Warren Buffett’s firm has not undertaken any major investments during the COVID-19 crisis (Financial Times 2020). Our results therefore suggest that, at least at the margin, fire sales would have been an effective alternative to bailouts, especially for large bailouts such as for the airlines in the US.

“The merits of fire sales and bailouts in light of the COVID-19 pandemic”, Jean-Marie Meier and Henri Servaes, 18 January 2021.

APRA reflects on “… a subtle but important shift in regulatory thinking”

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.

Tony – From the Outside

Restructuring Basel’s capital buffers

Douglas Elliott at Oliver Wyman has written a short post which I think makes a useful contribution to the question of whether the capital buffers in the BCBS framework are serving their intended purpose.

The short version is that he argues the Countercyclical Capital Buffer (CCyB) has worked well while the Capital Conservation Buffer (CCB) has not. The solution he proposes is that the “the Basel Committee should seriously consider shrinking the CCB and transferring the difference into a target level of the CCyB in normal times”. Exactly how much is up for debate but he uses an example where the base rate for the CCyB is 1.0% and the CCB is reduced by the same amount to maintain the status quo.

The idea of having a non-zero CCyB as the default setting is not new. The Bank of England released a policy statement in April 2016 that had a non zero CCyB at its centre (I wrote about that approach in this post from April 2018). What distinguishes Elliott’s proposal is that he argues that the increased CCyB should be seeded by a transfer from the CCB. While I agree with many of his criticisms of the CCB (mostly that it is simply not usable in practice), my own view is that a sizeable CCB offers a margin of safety that offers a useful second line of defence against the risk that a bank breaches its minimum capital requirement. My perspective is heavily influenced by a concern that both bankers and supervisors are prone to underestimate the extent to which they face an uncertain world.

For anyone interested, this post sets out my views on how the cyclical capital buffer framework should be constructed and calibrated. This issue is especially relevant for Australian banks because APRA has an unresolved discussion paper which includes a proposal to increase the size of the capital buffers the Australian banks are expected to maintain. I covered that discussion paper here. A speech that APRA Chair Wayne Byres gave in May 2020 covering some of the things APRA had learned from dealing with the economic fallout of COVID-19 is also worth checking out (covered in this post).

Tony – From the Outside

What does the “economic perspective” add to an ICAAP?

… the question I reflected on as I read the ECB Report on Banks’ ICAAP Practices (August 2020).

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:

  1. Data quality
  2. The application of the “Economic Perspective” in the ICAAP
  3. 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.

The economic internal perspective

The ECB’s guide to the ICAAP defines the term “economic internal perspective” as follows:

“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.

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… 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. 

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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 the 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”.

For what it is worth, my template for how a bank might make explicit allowances in the ICAAP for unknown unknowns is included in this post on the construction of calibration of cyclical capital buffers. My posts on the broader issue of risk versus uncertainty can be found on the following links:

Feel free to let me know what I am missing …

Tony – From the Outside

Constructive dissent

I am currently reading “Thinking in Bets” by Annie Duke. It is early days but I suspect that this is a book that has some useful things to say about creating the kinds of corporate culture that truely reflect the values espoused in corporate mission statements. It is a truth that actions speak louder than words and she cites a practice employed by the American Foreign Service Association which has not one but four awards for employees who have exhibited behaviours that demonstrate initiative, integrity, intellectual courage and constructive dissent.

The attached quote comes from the AFSA website setting out the criteria employed for these awards

Criteria for the Dissent Awards

The awards are for Foreign Service employees who have “exhibited extraordinary accomplishment involving initiative, integrity, intellectual courage and constructive dissent”. The awards publicly recognize individuals who have demonstrated the intellectual courage to challenge the system from within, to question the status quo and take a stand, no matter the sensitivity of the issue or the consequences of their actions. The issue does not have to be related to foreign policy. It can involve a management issue, consular policy, or, in the case of the recently established F. Allen “Tex” Harris Award, the willingness of a Foreign Service Specialist to take an unpopular stand, to go out on a limb, or to stick his/her neck out in a way that involves some risk

https://www.afsa.org/constructive-dissent-awards

Climate change – a central banking perspective

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

  1. 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”.
  2. 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.
  3. 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.
  4. 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:

  1. 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.
  2. 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
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” .

Thomas Friedman’s article (“How we broke the world”) is also worth reading on this question …

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
Managing collective 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”

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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.

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