The BIS recently published a paper summarising what had been learned from a series of interviews with nine central banks exploring how these institutions were thinking about the potential of a CBDC to support the pursuit of “financial inclusion” objectives explicit or implicit in their mandates.
A lot of what the paper documents and discusses will be pretty familiar to anyone who has been following the BIS and individual central banks on this topic but I think the following observations offered by the paper about the best way to pursue financial inclusion is worth noting
It needs to be noted that many of these features [i.e. the benefits of a CBDC] can, in isolation, be offered by other payment innovations, and many gaps could be addressed through regulation and sound oversight arrangements. Combining different payment innovations – such as open application programming interfaces (APIs), fast payment services, contactless chips and QR codes – could achieve many of the same goals. This is particularly true when accompanied by robust regulatory and oversight arrangements that public authorities can use to catalyse private sector players, enforce sound governance arrangements and foster required coordination and collaboration. Adoption of relevant technologies for supervisory and regulatory compliance could also improve the efficiency and effectiveness of regulators and supervisors. What is truly different about CBDC is that it is a direct claim on the central bank. It is an open question for central banks whether CBDCs or other policy interventions are the best fit for their jurisdiction. Yet if a CBDC is to be issued (for financial inclusion or other motives), interviews with central banks clearly point to the importance of inclusive design elements to successfully promote inclusive outcomes. We discuss these elements in the next subsection.
Page 13, paragraph 16
There is a narrative that sees CBDC adoption as inevitable based in part on the fact that so many central banks are looking at the question. In contrast, the BIS paper clearly states that a CBDC is not a “panacea” and that many of the outcomes a CBDC might deliver could equally be delivered by other payment innovations such as “open application programming interfaces (APIs) , fast payment services, contactless chips and QR codes”
It is also worth noting that, of the nine central banks interviewed, eight were emerging market and developing economies and only one (Bank of Canada) an advanced economy. The results should therefore be interpreted with that bias in mind.
Summing up, my take is that
the business case for a retail CBDC seems to have the most weight in the emerging market and developing economies with relatively poorly developed financial infrastructure
the business case for a retail CBDC in an advanced economy is less obvious
other initiatives such as central bank sponsorship of fast payment systems might be a better use of central bank resources
not explicitly referenced in the paper, but the recent experience with the roll out of fast payment systems in Brazil and India offer interesting case studies
the central bank focus on CBDCs seems to continue to be heavily weighted toward account based systems
token based CBDCs are mentioned in passing but do not seem to be high on the list of priorities
If you have not listened to it already then I can highly recommend this podcast in which Grant Williams interviews Luke Gromen. The podcast covers a lot of ground but the primary focus is the role of the USD in the international financial system in the aftermath of the sanctions imposed on Russia in response to its invasion of Ukraine. I have an understanding of pieces of the puzzle but this interview put them together in ways that I had not fully grasped or seen before.
It is far from clear what comes next for the international financial system in general and the USD in particular. The much discussed demise of the USD may be too apocalyptic but it seems reasonably certain that the status quo is going to change – here is a short summary of some of what the interview offers:
The first 20, minutes offers a short history of the Bretton Woods arrangements that have defined international finance since the late 1940s including the transition from a system based on the USD being based on gold (Bretton Woods 1) to a system where the USD is based on oil (Bretton Woods 2)
They discuss how the current regime (“keeping the dollar as good as gold for oil”) is breaking down analogous to the way the gold foundation broke down in the early 1970s
The USD’s role as an international reserve currency has been described as an “exorbitant privilege” but Gromen argues that the arrangement has also come at a cost via the role it has played in the loss of US domestic manufacturing capacity (Triffin’s Dilemma).
The consequences of this trade off has come under greater attention post the GFC, initially as the social consequences of lost jobs started to impact domestic politics, and more recently as globalised just in time supply chains struggled to respond to the economic shocks created by the response to Covid 19
Gromen argues that the USD Department of Defence has wanted to see repatriation of the US industrial base for some time and hence will be happy to see a decline in the USD’s role as an internal reserve currency because they believe it will enhance national security
Interestingly he argues that it would have looked like weakness for that to happen as a consequence of pressure from China and Russia but can now be presented as a sign of strength, of standing up to Russia (“we showed those Russians”)
They also discuss what this means for the price of gold
Hopefully I have done a decent job of capturing the key themes but there is a lot here and some may have been lost in my translation so by all means listen yourself. Personally I need to do a bit more research to better understand the references in the interview to the “Triffin Dilemma” and to Keynes’ “bancor” proposal.
Cross border payment is one of the areas of conventional banking where challengers believe that crypto/DLT solutions can shake up the existing order. There is little doubt that the cross border payment status quo has lots of room for improvement but Gillian Tett (Financial Times) offers a nice summary of central bank projects that are potentially introducing other vectors of innovation and competition.
What is interesting for students of banking is the parallels that Rubinstein notes between MakerDAO and the free banking systems that evolved during the 18th and 19th centuries. Scotland is one of the poster children of this style of banking and we can see a legacy of that system (albeit much more regulated and so not true free banking) in the form of the private bank notes that the three Scottish banks still issue in their own name. He quotes Rune Christensen (founder of MakerDAO) describing the way in which his project accidentally developed a form of fractional reserve banking”
In the very beginning of the project, I remember we didn’t even realise, in the beginning of Maker, that we were essentially just building a protocol that did the same things as fractional reserve banking, did something very similar to how a banking balance sheet works and we were just implementing that as a blockchain protocol. We thought we were doing something completely, totally different from how money usually worked in the traditional sense.”(source)
“Reinventing the Financial System” Marc Rubinstein Net Interest Newsletter, 12 June 2021
This statement should be qualified by the fact that they can only do this (i.e. replicate fractional reserve banking) because the currency of the decentralised bank is a form of money called Dai. Fractional Reserve Banking has proved to be a risky form of financial technology in the conventional banking system which has developed a range of tools to manage that risk (e.g. capital adequacy and liquidity requirements, deposit preference arrangements often coupled with deposit insurance to insulate the “money” part of the bank balance sheet from risk, high levels of supervision and other restrictions on the types of assets a bank can lend against).
MakerDAO has a stabilisation mechanism that employs “smart contracts” that manage the price of Dai by managing its supply and demand. The pros and cons of the various stabilisation mechanisms that underpin stable coins like Dai is a topic for another day.
Rubinstein describes the MakerDAO lending and “money” creation process as follows:
The bank he devised to create his money … works like this:
An investor comes into Maker DAO for a loan. He (yep, usually he) has some collateral he’s happy to keep locked in a vault. Right now, that collateral is usually a crypto asset like Ethereum. For every $100 worth of crypto assets, Maker is typically prepared to lend $66 – the gap adding a buffer of protection against a possible fall in the value of the collateral. Maker accepts the collateral and advances a loan, which it does by issuing its Dai money.
At this stage I am not sure where this is headed. It is not clear, for example, if the purpose of this “bank” is simply to create more Dai via trading in crypto-assets or to build something that translate outside CryptoLand. Rubinstein quotes Rune Christensen himself stating that
I don’t think that it will necessarily replace everything… The traditional financial system will actually largely remain the way it is. It will just replace certain parts of it that right now are really bad and really old… those things will be replaced with DeFi and blockchain, but the actual bank itself probably will remain.”
I am a long way from figuring this out but Marc’s post is I think worth reading for anyone who want to understand where these new (or possibly reinvented) forms of finance are heading. To the extent that DeFi is reinventing things that have been tried before, I suspect it would be useful to reflect on why free banking is no longer the way the conventional banking system operates. That is another topic for another day.
Izabella Kaminska (FT Alphaville) offers another perspective on what the development of a Central Bank Digital Currency CBDC) by the People’s Bank of China means for China itself, the rest of the world and the USD in particular.
Her column is titled “Is the central bank panic about the PBOC coin justified?”. It is not clear that central banks are actually panicking at this stage (equally I am not sure that Isabella has 100% control over the titles her sub-editors apply to her articles). The article does however offer some balance to the narrative that sees China’s moves in this space forcing other central banks to follow suite.
I am yet to fully come to terms with the questions posed in her article but this (for me at least) is definitely an area to watch and seek to understand.
Izabella has been a reliable source of insight on this and the broader questions associated with the increased role of fintech in our payment systems. I can also recommend a column she wrote in July 2019 titled “Why dealing with fin techs is a bit like dealing with pirates”. A paper by Tobias Adrian and Tommaso Mancini-Griffoli titled “The Rise of Digital Money” is also worth reading if you are interested in this topic (one of my posts offers a short overview of the paper and a link to the original).
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.
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?”
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
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.
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”
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.