RBNZ COVID 19 Stress Tests

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

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.

Tony – From the Outside

Banks Are Managing Their Stress – Bloomberg

The ever reliable Matt Levine discusses the latest stress test results for the US banks. In particular the disconnect between the severity of the assumptions in the hypothetical scenario and the actual results observed to date. He notes that it is still early and plenty of room for the actual outcomes to catch up with the hypothetical. However, one of the issues with stress testing is the way you model the way people (and governments) respond to stress.

As Matt puts it …

But another important answer is that, when a crisis actually happens, people do something about it. They react, and try to make it better. In the case of the coronavirus crisis, the Fed and the U.S. government tried to mitigate the effect of a real disaster on economic and financial conditions. Unemployment is really high, but some of the consequences are mitigated by stimulus payments and increased unemployment benefits. Asset prices fell sharply, but then rose sharply as the Fed backstopped markets. Financing markets seized up, and then the Fed fixed them.

The banks themselves also acted to make things better, at least for themselves. One thing that often happens in a financial crisis is that banks’ trading desks make a killing trading for clients in turbulent markets, which helps to make up for some of the money they lose on bad loans. And in fact many banks had blowout first quarters in their trading divisions: Clients wanted to trade and would pay a lot for liquidity, and banks took their money.

In a hypothetical stress test, you can’t really account for any of this. If you’re a bank, and the Fed asks you to model how you’d handle a huge financial crisis, you can’t really write down “I would simply make a ton of money trading derivatives.” It is too cute, too optimistic. But in reality, lots of banks just went and did that.

Similarly, you obviously can’t write down “I would simply rely on the Fed to backstop asset prices and liquidity.” That is super cheating. Much of the purpose of the stress tests is to make it so the Fed doesn’t have to bail out the banking system; the point is to demonstrate that the banks can survive a financial crisis on their own without government support. But in reality, having a functioning financial system is better than not having that, so the Fed did intervene; keeping people in their homes is better than foreclosing on them, so the government supported incomes. So the banks are doing much better than you might expect with 13.3% unemployment.

So it is likely that the Fed’s stress test is both not harsh enough, in its economic scenario, and too harsh, in its assumption about how that scenario will affect banks.

Notwithstanding the potential for people to respond to and mitigate stress, there is still plenty of room for reality to catch up with and exceed the hypothetical scenario. Back to Matt…

But the fact that the stress test imagines an economic crisis that is much nicer than reality is still a little embarrassing, and the Fed can’t really say “everything is fine even in the terrible downside case of 10% unemployment, the banks are doing great.” So it also produced some new stress-test results (well, not quite a full stress test but a “sensitivity analysis”) assuming various scenarios about the recovery from the Covid crisis (“a rapid V-shaped recovery,” “a slower, more U-shaped recovery,” and “a W-shaped double dip recession”). The banks are much less well capitalized in those scenarios than they are either (1) now or (2) in the original stress tests, though mostly still okay, and the Fed is asking the banks to reconsider stress and capital based on current reality. Also stop share buybacks:

Worth reading

Tony – From the Outside

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”

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.

Page 48

Bank dividends

Matt Levine’s “Money Stuff” column (Bloomberg) offers some interesting commentary on what is happening with bank dividends in the US. Under the sub heading “People are worried about dividends” he writes:

So, again, I am generally pretty impressed by the performance of bank regulation in the current crisis, but this is unfortunate:

US banks’ annual capital plans, due to be submitted to the Federal Reserve on Monday, are expected to include proposals to continue paying dividends, reinforcing comments from prominent bank chief executives in recent days, according to people familiar with the situation.

The bankers, including Goldman Sachs boss David Solomon, Morgan Stanley boss James Gorman and Citigroup chief Mike Corbat, argued that they had the means to continue paying dividends and that cutting them would be “destabilising to investors”.

“We’re in a very different position than what we see in Europe,” said Marty Mosby, a veteran banks analyst at Vining Sparks.

“How we set it up [post-crisis capital requirements] was to be able to not have those dividends collapse [in a crisis]. That’s what creates a financial crisis: when dividends start to be ratcheted lower that shakes confidence.”

What is unfortunate is not so much that U.S. banks want to continue paying dividends; for all I know some of them are so well capitalized and so well equipped to weather this crisis that they will actually make a lot of money and have plentiful profits to pay out to shareholders. What is unfortunate is that their explicit view is that cutting dividends would be destabilizing. Common shareholders are supposed to be the lowest-ranking claimants on a bank’s money. The point of equity capital is that you don’t have to pay it out, that it doesn’t create any cash drain in difficult times. But if your view is “we need to maintain our dividend every quarter or else there will be a run on the bank,” then that means that the dividend is destabilizing; it means that your common stock is really debt; it means that your equity capital is not as good—not as equity-like—as it’s supposed to be.

If you take seriously the claim that banks can’t cut dividends in a generational crisis, for fear of undermining investor confidence, then, fine, I guess, but then the obvious conclusion is that when times are good you can never let banks raise their dividends. Every time a bank raises its dividend, on this theory, it incurs more unavoidable quarterly debt and creates a new drain on its funding, one that can’t be turned off in the bad times for fear of being “destabilising to investors”

Bloomberg Opinion “Money Stuff” 7 April 2020

I get the argument that if banks have the means to pay a dividend then they should be free to make a commercial decision. People may however feel entitled to be skeptical given the ways in which some banks were slow to adjust to the new realities of the GFC. There is also a line where the position some US banks appear to be projecting risks becoming an expectation that the dividend should be stable even under a highly stressed and uncertain outlook. It is not clear if that is exactly what the US banks quoted in his column are saying but that is how Matt Levine frames it and it would clearly be a concern if that is their view. That does seem to a fair description of the view some investors and analysts are expressing.

Jamie Dimon seems to be offering a more nuanced perspective on this question. He has advised JP Morgan shareholders that the Board expects the bank to remain profitable under its base base projections but would consider suspending the dividend under an extremely adverse scenario.

Our 2019 pretax earnings were $48 billion – a huge and powerful earnings stream that enables us to absorb the loss of revenues and the higher credit costs that inevitably follow a crisis. For comparison, the Comprehensive Capital Analysis and Review (CCAR) results for 2020 that we submitted to the Federal Reserve in 2019 (which assumed outcomes like U.S. unemployment peaking at 10% and the stock market falling 50%) showed a decline in revenue of almost 20% and credit costs of approximately $20 billion more than what we experienced in 2019. We believe we would perform better than this if the Fed’s scenario were to actually occur. But even in the Fed’s scenario, we would be profitable in every quarter. These stress test results also show that following such a meaningful reduction in our revenue (and assuming we continue to pay dividends), our common equity Tier 1 (CET1) ratio would likely hold at a very strong 10%, and we would have in excess of $500 billion of liquid assets. 

Additionally, we have run an extremely adverse scenario that assumes an even deeper contraction of gross domestic product, down as much as 35% in the second quarter and lasting through the end of the year, and with U.S. unemployment continuing to increase, peaking at 14% in the fourth quarter. Even under this scenario, the company would still end the year with strong liquidity and a CET1 ratio of approximately 9.5% (common equity Tier 1 capital would still total $170 billion). This scenario is quite severe and, we hope, unlikely. If it were to play out, the Board would likely consider suspending the dividend even though it is a rather small claim on our equity capital base. If the Board suspended the dividend, it would be out of extreme prudence and based upon continued uncertainty over what the next few years will bring.

It is also important to be aware that in both our central case scenario for 2020 results and in our extremely adverse scenario, we are lending – currently or plan to do so – an additional $150 billion for our clients’ needs. Despite this, our capital resources and liquidity are very strong in both models. We have over $500 billion in total liquid assets and an incremental $300+ billion borrowing capacity at the Federal Reserve and Federal Home Loan Banks, if needed, to support these loans, as well as meet our liquidity requirements (these numbers do not include the potential use of some of the Fed’s newly created facilities). We could, of course, make our capital and liquidity buffer better by restricting our activities, but we do not intend to do that – our clients need us.

JP Morgan Chairman and CEO Letter to Shareholders 2019 Annual Report

Banks are cyclical investments – who knew?

Stress testing models must of course be treated with caution but what I think this mostly illustrates is that banks are highly cyclical investments. That may seem like a statement of the obvious but there was a narrative post GFC that banks were public utilities and that bank shareholders should expect to earn public utility style returns on their investments.

There is an element of truth in this analogy in so far as banks clearly provide an essential public service. I am also sympathetic to the argument that banking is a form of private/public partnership. This pandemic is however a timely reminder of the limits of the argument that banks are just another low risk utility style of business. Bank shareholders are much more exposed to the cyclical impacts than true utility investments.

In the interests of full disclosure, I have a substantial exposure to bank shares and I for one need a lot more than a single digit return to compensate for the pain that part of my portfolio is currently experiencing. The only upside is that I never bought into the thesis that banks are a low risk utility style investment requiring a commensurately low return.

The higher capital and liquidity requirements built up in response to the lessons of the GFC increase the odds that banks will survive the crisis and be a big part of the solution but banks are, and remain, quintessentially cyclical investments and the return bank investors require should reflect this. I think the lesson here is not to worry about the extent to which dividend cuts would be destabilising to investors but to focus on what kind of return is commensurate with the risk.

I will let APRA have the final say on what to expect …

APRA expects ADIs and insurers to limit discretionary capital distributions in the months ahead, to ensure that they instead use buffers and maintain capacity to continue to lend and underwrite insurance. This includes prudent reductions in dividends, taking into account the uncertain outlook for the operating environment and the need to preserve capacity to prioritise these critical activities. 

Decisions on capital management need to be forward-looking, and in the current environment of significant uncertainty in the outlook, this can be very challenging. APRA is therefore providing Boards with the following additional guidance.2 

During at least the next couple of months, APRA expects that all ADIs and insurers will:

– take a forward-looking view on the need to conserve capital and use capacity to support the economy;

– use stress testing to inform these views, and give due consideration to plausible downside scenarios (periodically refreshed and updated as conditions evolve); and

– initiate prudent capital management actions in response, on a pre-emptive basis, to ensure they maintain the confidence and capacity to continue to lend and support their customers. 

During this period, APRA expects that ADIs and insurers will seriously consider deferring decisions on the appropriate level of dividends until the outlook is clearer. However, where a Board is confident that they are able to approve a dividend before this, on the basis of robust stress testing results that have been discussed with APRA, this should nevertheless be at a materially reduced level. Dividend payments should be offset to the extent possible through the use of dividend reinvestment plans and other capital management initiatives. APRA also expects that Boards will appropriately limit executive cash bonuses, mindful of the current challenging environment.  

“APRA issues guidance to authorised deposit-taking institutions and insurers on capital management”, 7 April 2020

Tony (From the Outside)

Probabilities disguising uncertainty – Part II

This behavior makes one blind to all sorts of things. 

The first blind spot … is that it treats uncertain events – items of unknowable incidence and severity – as if they were risks that could be estimated probabilistically. 

Epsilon Theory ; “Lack of Imagination” 14 March 2020

One of my recent posts drew attention to an article by John Kay promoting a book he has co-written with Mervyn King on the topic of “radical uncertainty”. Epsilon Theory offers another useful perspective on the ways in which extending probabilistic thinking beyond its zone of validity can cause us to miss the big picture.

The Epsilon Theory post focusses on the Covid 19 fallout currently playing out but is also worth reading for the broader challenges it offers anyone trying to use models and probabilities to manage real world outcomes …

Tony

Capital Rules Get Less Stressful – Matt Levine

Nice quote from Matt Levine’s opinion piece on the change in US bank capital requirements

Everything in bank capital is controversial so this is controversial. Usually the controversy is that some people want higher capital requirements and other people want lower capital requirements. Here, pleasantly, part of the controversy is about whether this is a higher or lower capital requirement.

https://www.bloomberg.com/opinion/articles/2020-03-05/capital-rules-get-less-stressful

Using machine learning to predict bank distress

Interesting post on the Bank Underground blog by Bank of England staff Joel Suss and Henry Treitel.

This extract summarises their findings

“Our paper makes important contributions, not least of which is practical: bank supervisors can utilise our findings to anticipate firm weaknesses and take appropriate mitigating action ahead of time.

However, the job is not done. For one, we are missing important data which is relevant for anticipating distress. For example, we haven’t included anything that speaks directly to the quality of a firm’s management and governance, nor have we included any information on organisational culture.

Moreover, our period of study only covers 2006 to 2012 – a notoriously rocky time in the banking sector. A wider swathe of data, including both good times and bad, would help us be more confident that our models will perform well in the future.

So while prediction, especially about the future, remains tough, our research demonstrates the ability and improved clarity of machine learning methodologies. Bank supervisors, armed with high-performing and transparent predictive models, are likely to be better prepared to step-in and take action to ensure the safety and soundness of the financial system.”

Is the financial system as resilient as policymakers say?

This is the question that Sir Paul Tucker poses in a BIS Working Paper titled “Is the financial system sufficiently resilient: a research programme and policy agenda” (BIS WP790) and answers in the negative. Tucker’s current role as Chair of the Systemic Risk Council and his experience as Deputy Governor at the Bank of England from 2009 to 2013 suggests that, whether you agree or disagree, it is worth reading what he has to say.

Tucker is quick to acknowledge that his assessment is “… intended to jolt the reader” and recognises that he risks “… overstating weaknesses given the huge improvements in the regulatory regime since 2007/08”. The paper sets out why Tucker believes the financial system is not as resilient as claimed, together with his proposed research and policy agenda for achieving a financial system that is sufficiently resilient.

Some of what he writes is familiar ground but three themes I found especially interesting were:

  1. The extent to which recourse by monetary policy to very low interest rates exposes the financial system to a cyclically higher level of systemic risk that should be factored into the resilience target;
  2. The need to formulate what Tucker refers to as a “Money Credit Constitution” ; and
  3. The idea of using “information insensitivity” for certain agreed “safe assets” as the target state of resilience for the system.

Financial stability is of course one of those topics that only true die hard bank capital tragics delve into. The Global Financial Crisis (GFC) demonstrated, however, that financial stability and the resilience of the banking system is also one of those topics that impacts every day life if the technocrats get it wrong. I have made some more detailed notes on the paper here for the technically inclined while this post will attempt (and likely fail) to make the issues raised accessible for those who don’t want to read BIS working papers.

Of the three themes listed above, “information insensitivity” is the one that I would call out in particular. It is admittedly a bit clunky as a catch phrase but I do believe it is worth investing the time to understand what it means and what it implies for how the financial system should be regulated and supervised. I have touched on the concept in a couple of previous posts (here, here, and here) and, as I worked through this post, I also found some interesting overlaps with the idea introduced by the Australian Financial System Inquiry that systemically important banks should be required to be “unquestionably strong”.

How resilient is the financial system?

Tucker’s assessment is that Basel III has made the financial system a lot safer than it was but less resilient than claimed. This is because the original calibration of the higher capital requirements under Basel III did not allow for the way in which any subsequent reduction in interest rates means that monetary policy has less scope to help mitigate economic downturns. All other things being equal, any future stress will have a larger impact on the financial system because monetary policy will have less capacity to stimulate the economy.

We could quibble over details:

  • The extent to which the capital requirements have been increased by higher Risk Weights applied to exposures (Tucker is more concerned with the extent to which capital requirements get weakened over time in response to industry lobbying)
  • Why is this not captured in stress testing?
  • The way in which cyclical buffers could (and arguably should) be used to offset this inherent cyclical risk in the financial system.

But his bigger point sounds intuitively right, all other things being equal, low interest rates mean that central banks will have much less scope to stimulate the economy via monetary policy. It follows that the financial system is systemically riskier at this point in time than historical experience with economic downturns might suggest.

How should we respond (in principle)?

One response is common equity and lots of it. That is what is advocated by some academic commentators , influential former central bankers such as Adair Turner and Mervyn King, and most recently by the RBNZ (with respect to the quantum and the form of capital.

Tucker argues that the increased equity requirements agreed under Basel III are necessary, but not sufficient. His point here is broader than the need to allow for changes in monetary policy discussed above. His concern is what does it take to achieve the desired level of resilience in a financial system that has fractional reserve banking at its core.

”Maintaining a resilient system cannot sanely rely on crushing the probability of distress via prophylactic regulation and supervision: a strategy that confronts the Gods in its technocratic arrogance. Instead, low barriers to entry, credible resolution regimes and crisis-management tools must combine to ensure that the system can keep going through distress. That is different from arguing that equity requirements (E) can be relaxed if resolution plans become sufficiently credible. Rather, it amounts to saying that E would need to be much higher than now if resolution is not credible.”

“Is the Financial system sufficiently resilient: a research programme and policy agenda” BIS WP 790, p 23

That is Tucker’s personal view expressed in the conclusion to the paper but he also advocates that unelected technicians need to frame the question [of target resilience] in a digestible way for politicians and public debate“. It is especially important that the non-technical people understand the extent to which there may be trade-offs in the choice of how resilient the financial system should be. Is there, for example, a trade-off between resilience and the dynamism of the financial system that drives its capacity to support innovation, competition and growth? Do the resource misallocations associated with credit and property price booms damage the long run growth of the economy? And so on …

Turner offers a first pass at how this problem might be presented to a non-technical audience:

Staying with crisp oversimplification, I think the problem can be put as follows:

• Economists and policymakers do not know much about this. Models and empirics are needed.

• Plausibly, as BIS research suggests, credit and property price booms lead resource misallocation booms? Does that damage long-run growth?

• Even if it does, might those effects be offset by net benefits from greater entrepreneurship during booms?

• Would tough resilience policies constrain capital markets in ways that impede the allocation of resources to risky projects and so growth?

If there is a long-run trade off, then where people are averse to boom-bust ‘cycles’, resilience will be higher and growth lower. By contrast, jurisdictions that care more about growth and dynamism will err on the side of setting the resilience standard too low.

BIS WP790, Page 5

He acknowledges there are no easy answers but asking the right questions is obviously a good place to start.

A “Money-Credit Constitution”

In addition to helping frame the broader parameters of the problem for public debate, central bankers also need to decide what their roles and responsibilities in the financial system should be. Enter the idea of a Money-Credit Constitution (MCC). I have to confess that this was a new bit of jargon for me and I had to do a bit of research to be sure that I knew what Tucker means by it. The concept digs down into the technical aspects of central banking but it also highlights the extent to which unelected technocrats have been delegated a great deal of power by the electorate. I interpret Tucker’s use of the term “constitution”as an allusion to the need for the terms on which this power is exercised to be defined and more broadly understood.

A Money-Credit Constitution defined:

“By that I mean rules of the game for both banking and central banking designed to ensure broad monetary stability, understood as having two components: stability in the value of central bank money in terms of goods and services, and also stability of private-banking-system deposit money in terms of central bank money.”

Chapter 1: How can central banks deliver credible commitment and be “Emergency Institutions”? by John Tucker in “Central Bank Governance and Oversight Reform, edited by Cochrane and Taylor (2016)

The jargon initially obscured the idea (for me at least) but some practical examples helped clarify what he was getting at. Tucker defines the 19th and early 20th century MCC as comprising; the Gold Standard, reserve requirements for private banks and the Lender of Last Resort (LOLR) function provided by the central bank. The rules of the game (or MCC) have of course evolved over time. In the two to three decades preceding the 2008 GFC, the rules of the game incorporated central bank independence, inflation targeting and a belief in market efficiency/discipline. Key elements of that consensus were found to be woefully inadequate and we are in the process of building a new set of rules.

Tucker proposes that a MCC that is fit for the purpose of achieving an efficient and resilient financial system should have five key components:

– a target for inflation (or some other nominal magnitude);

– a requirement for banking intermediaries to hold reserves (or assets readily exchanged for reserves) that increases with a firm’s leverage and/or the degree of liquidity mismatch between its assets and liabilities;

– a liquidity-reinsurance regime for fundamentally solvent banking intermediaries;

– a resolution regime for bankrupt banks and other financial firms; and

– constraints on how far the central bank is free to pursue its mandate and structure its balance sheet, given that a monetary authority by definition has latent fiscal capabilities.

BIS WP, Page 9

In one sense, the chosen resilience strategy for the financial system is simply determined by the combination of the capital and liquidity requirements imposed on private banks. We are using the term capital here in its broadest sense to incorporate not just common equity but also the various forms of hybrid equity and subordinated debt that can be converted into equity without disrupting the financial system.

But Tucker argues that there is a bigger question of strategy that must be addressed; that is

“whether to place the regime’s weight on regulatory requirements that impose intrinsic resilience on bank balance sheets or on credible crisis management that delivers safety ex post. It is a choice with very different implications for transparency.”

BIS WP 790; Page 11

Two alternative strategies for achieving a target state of financial system resilience

Strategy 1: Crisis prevention (or mitigation at least)

The first strategy is essentially an extension of what we have already been doing for some time; a combination of capital and liquidity requirements that limits the risk of financial crisis to some pre-determined acceptable level.

“… authorities set a regulatory minimum they think will be adequate in most circumstances and supervise intermediaries to check whether they are exposed to outsized risks.

BIS WP 790, Page 11

Capital and liquidity requirements were increased under Basel III but there was nothing fundamentally new in this part of the Basel III package. Tucker argues that the standard of resilience adopted should be explicit rather than implicit but he still doubts that this strategy is robust. His primary concern seems to be the risk that the standard of resilience is gradually diluted by a series of small concessions that only the technocrats understand.

How did we know that firms are really satisfying the standard: is it enough that they say so? And how do we know that the authorities themselves have not quietly diluted or abandoned the standard?”

BIS WP 790; Page 11

Tucker has ideas for how this risk of regulatory capture might be controlled:

  each year central bank staff (not policymakers) should publish a complete statement of all relaxations and tightenings of regulatory and supervisory policy (including in stress testing models, rules, idiosyncratic requirements, and so on)

  the integrity of such assessments should be subject to external audit of some kind (possibly by the central auditor for the state).

BIS WP 790, Page 12

but this is still a second best approach in his assessment; he argues that we can do better and the idea of making certain assets “informationally insensitive” is the organising principle driving the alternative strategies he lays out.

Strategy 2: Making assets informationally insensitive via crisis-management regimes

Tucker identifies two approaches to crisis management both based around the objective of ensuring that the value of certain agreed liabilities, issued by a defined and pre-determined set of financial intermediaries, is insensitive to information about the financial condition of these intermediaries:

Strategy 2a: Integrate LOLR with liquidity policy.

Central bankers, as the suppliers of emergency liquidity assistance, could make short term liabilities informationally insensitive by requiring banks to hold reserves or eligible collateral against all runnable liabilities. Banks would be required to cover “x”% of short term liabilities with reserves and/or eligible collateral. The key policy choices then become

  • The definition of which short term liabilities drive the liquidity requirement;
  • The instruments that would be eligible collateral for liquidity assistance; and
  • The level of haircuts set by central banks against eligible collateral

What Tucker is outlining here is a variation on a proposal that Mervyn King set out in his book “The End of Alchemy” which I covered in a previous post. These haircuts operate broadly analogously to the existing risk-weighted equity requirements. Given the focus on emergency requirements, they would be based on stress testing and incorporate systemic risk surcharges.

Tucker is not however completely convinced by this approach:

“… a policy of completely covering short-term labilities with central bank-eligible assets would leave uninsured short-term liabilities safe only when a bank was sound. They would not be safe when a bank was fundamentally unsound.

That is because central banks should not (and in many jurisdictions cannot legally) lend to banks that have negative net assets (since LOLR assistance would allow some short-term creditors to escape whole at the expense of equally ranked longer-term creditors). This is the MCC’s financial-stability counterpart to the “no monetary financing” precept for price stability.

Since only insured-deposit liabilities, not covered but uninsured liabilities, are then safe ex post, uninsured liability holders have incentives to run before the shutters come down, making their claims information sensitive after all.

More generally, the lower E, the more frequently banks will fail when the central bank is, perforce, on the sidelines. This would appear to take us back, then, to the regulation and supervision of capital adequacy, but in a way that helps to keep our minds on delivering safety ex post and so information insensitivity ex ante.”

BIS WP 790, Page 14

Strategy 2b: Resolution policy – Making operational liabilities informationally insensitive via structure

Tucker argues that the objective of resolution policy can be interpreted as making the operational liabilities of banks, dealers and other intermediaries “informationally insensitive”. He defines “operational liabilities” as “… those liabilities that are intrinsically bound to the provision of a service (eg large deposit balances, derivative transactions) or the receipt of a service (eg trade creditors) rather than liabilities that reflect a purely risk-based financial investment by the creditor and a source of funding/leverage for the bank or dealer”

Tucker proposes that this separation of operational liabilities from purely financial liabilities can be “… made feasible through a combination of bail-in powers for the authorities and, crucially, restructuring large and complex financial groups to have pure holding companies that issue the bonds to be bailed-in” (emphasis added).

Tucker sets out his argument for structural subordination as follows.

“…provided that the ailing operating companies (opcos) can be recapitalised through a conversion of debt issued to holdco …., the opcos never default and so do not go into a bankruptcy or resolution process. While there might be run once the cause of the distress is revealed, the central bank can lend to the recapitalised opco …

This turns on creditors and counterparties of opcos caring only about the sufficiency of the bonds issued to the holdco; they do not especially care about any subsequent resolution of the holding company. That is not achieved, however, where the bonds to be bailed in … are not structurally subordinated. In that respect, some major jurisdictions seem to have fallen short:

  Many European countries have opted not to adopt structural subordination, but instead have gone for statutory subordination (eg Germany) or contractual subordination (eg France).

  In consequence, a failing opco will go into resolution

  This entails uncertainty for opco liability holders given the risk of legal challenge etc

  Therefore, opco liabilities under those regimes will not be as informationally insensitive as would have been possible.

BIS WP 790, Page 15

While structural subordination is Tucker’s preferred approach, his main point is that the solution adopted should render operational liabilities informationally insensitive:

“….the choice between structural, statutory and contractual subordination should be seen not narrowly in terms of simply being able to write down and/or convert deeply subordinated debt into equity, but rather more broadly in terms of rendering the liabilities of operating intermediaries informationally insensitive. The information that investors and creditors need is not the minutiae of the banking business but the corporate finance structure that enables resolution without opcos formally defaulting or going into a resolution process themselves

BIS WP 790 , Pages 15-16

If jurisdictions choose to stick with contractual or statutory subordination, Tucker proposes that they need to pay close attention to the creditor hierarchy, especially where the resolution process is constrained by the requirement that no creditor should be worse off than would have been the case in bankruptcy. Any areas of ambiguity should be clarified ex ante and, if necessary, the granularity of the creditor hierarchy expanded to ensure that the treatment of creditors in resolution is what is fair, expected and intended.

Tucker sums up the policy implications of this part of his paper as follows ...

“The policy conclusion of this part of the discussion, then, is that in order to deliver information insensitivity for some of the liabilities of operating banks and dealers, policymakers should:

a) move towards requiring that all short-term liabilities be covered by assets eligible at the central bank; and, given that that alone cannot banish bankruptcy,

b) be more prescriptive about corporate structures and creditor hierarchies since they matter hugely in bankruptcy and resolution.”

BIS WP 790, Page 16

Summing up …

  • Tucker positions his paper as “… a plea to policymakers to work with researchers to re-examine whether enough has been done to make the financial system resilient“.
  • His position is that “… the financial system is much more resilient than before the crisis but … less resilient than claimed by policymakers”
  • Tucker’s assessment “… is partly due to shifts in the macroeconomic environment” which reduce the capacity of monetary and fiscal policy stimulus but also an in principle view that “maintaining a resilient system cannot sanely rely on crushing the probability of distress via prophylactic regulation and supervision: a strategy that confronts the Gods in its technocratic arrogance“.
  • Tucker argues that the desired degree of resilience is more likely to be found in a combination of “… low barriers to entry, credible resolution regimes and crisis management tools …[that] … ensure the system can keep going through distress”.
  • Tucker also advocates putting the central insights of some theoretical work on “informational insensitivity” to practical use in the following way:
    • move towards requiring all banking-type intermediaries to cover all short-term liabilities with assets eligible for discount at the Window
    • insist upon structural subordination of bailinable bonds so that the liabilities of operating subsidiaries are more nearly informationally insensitive
    • be more prescriptive about the permitted creditor hierarchy of operating intermediaries
    • establish frameworks for overseeing and regulating collateralised money market, with more active use made of setting minimum haircut requirements to ensure that widely used money market instruments are safe in nearly all circumstancesarticulating restrictive principles for market-maker of last resort operations
  • Given the massive costs (economic, social, cultural) associated with financial crises, err on the side of maintaining resilience
  • To the extent that financial resilience continues to rely on the regulation and supervision of capital adequacy, ensure transparency regarding the target level of resilience and the extent to which discretionary policy actions impact that level of resilience

I am deeply touched if you actually read this far. The topic of crisis management and resolution capability is irredeemably technical but also important to get right.

Tony

Stress Testing – Do (really) bad things happen to good banks?

This post will focus on stress testing in response to some recent papers the RBNZ released (July 2018) describing both its approach to stress testing and the outcomes from the 2017 stress test of the major banks and a speech by Wayne Byres (APRA) which offered some detail of the Australian side of the joint stress testing undertaken by APRA and the RBNZ. I intend to make some observations related to this specific stress testing exercise but also some broader points about the ways that stress testing is currently conducted. The overriding point is that the cyclical scenarios employed to calibrate capital buffers seem to focus on “what” happened with less consideration given to “why” the historical episodes of financial stress the scenarios mimic were so severe.

There will be technical detail in this post but the question, simply put, is to what extent do really bad things happen to good banking systems? Paraphrased in more technical language, are we calibrating for scenarios based on the impact of some random exogenous shock on a sound banking system, or does the scenario implicitly assume some systemic endogenous factors at play that made the financial system less resilient in the lead up to the shock? Endogenous factors may be embedded in the balance sheets of the banks (e.g. poor credit quality amplified by excessive credit growth) or perhaps they are a feature of the economic system (e.g. a fixed exchange rate regime such as confronted many European economies during the GFC) that may or may not be universally relevant. I am focusing on the RBNZ stress test to explore these points mostly because they offered the most detail but I believe their approach is very similar to APRA’s and the observations apply generally to macro economic stress testing.

No prizes for guessing that I will be arguing that the kinds of really severe downturns typically used to calibrate capital buffers are usually associated with conditions where endogenous forces within the banking system are a key element in explaining the extent of the asset price declines and weak recoveries and that the severity of some historical scenarios was arguably exacerbated by unhelpful exchange rate, monetary or fiscal policy settings. This is not to say that we should not be using very severe downturns to calibrate the resilience of capital buffers. My argument is simply that recognising this factor will help make more sense of how to reconcile the supervisory approach with internal stress testing and how best to respond to the consequences of such scenarios.

The RBNZ approach to stress testing

The RBNZ characterises its approach to be at the less intensive end of the spectrum of supervisory practice so “stress tests are used to provide insights into the adequacy of bank capital buffers and can highlight vulnerabilities at the bank wide level or in its various loan portfolios” but “… the use of individual bank results in setting capital buffers and promoting market discipline is relatively limited“. The RBNZ stress tests fall into three categories 1)  cyclical scenarios, 2) exploratory stress tests and 3) targeted tests.

This post will focus on the cyclical scenario which was the focus of the RBNZ’s 2017 stress test and the place where the question of what happened and why it happened is most at risk of getting lost amongst the desire to make the test tough, coupled with the often daunting task of just running the test and getting some results.

The RBNZ states that the aim of a cyclical scenario is to help “… understand the resilience of participating banks to a macroeconomic downturn” so these scenarios “… mimic some of the worst downturns in advanced economies since World War 2, and typically feature sharp declines in economic activity and property prices, and stressed funding markets”. The repetition of the benchmark cyclical downturn scenario over time also allows the RBNZ “to track the resilience of the financial system over time (although the scenario will 

It is hard to argue with calibrating the resilience of the banking system to a very high standard of safety. That said, the concern I have with cyclical scenarios drawn from worst case historical events is that the approach tends to skip over the question of why the downturn of such severity occurred.

The RBNZ commentary does recognise the “… need to take account of the nature of the specific stress scenario” and for the cyclical scenario to “evolve based on new research and insights, such as the extent of over-valuation evident in property markets” and the possibility that “domestic monetary policy and a falling exchange rate would provide a significant buffer … that was unavailable during many of these stress episodes in countries without floating exchange rates“. “Exploratory” and “Targeted” stress testing may also be focussed on the endogenous risks embedded in the banking system without explicitly using that terminology.

So if the RBNZ, and APRA, are implicitly aware of the endogenous/exogenous risk distinction, then maybe I am just being pedantic but I would argue that greater clarity on this aspect of stress testing helps in a number of areas:

  • It can help to explain why there is often a gap between:The severity of outcomes modelled internally (where the bank will probably assume their portfolios has robust credit quality and none of the systemic weaknesses that were responsible for past episodes of severe financial weakness implicit in the downturn scenario adopted by the supervisors), andThe severity the regulator expects (possibly based on a skeptical view of the extent to which bank management has balanced risk and return with the reward of higher growth and market share).
  • The types of recovery actions that can be deployed and the amounts of capital they contribute to the rebuilding process are also very much shaped by the nature of the scenario (scenarios shaped by endogenous factors embedded in the banks’ balance sheets or business models require much more substantial responses that are more costly though the cost can be a secondary issue when the scale of the challenge is so large).
  • Supervisors rightly focus on the need for banks to maintain the supply of credit to the economy but endogenous scenarios may actually require that some customers de-gear themselves and become less reliant on bank credit.

The RBNZ discussion of the 2017 stress test of the major banks focussed on the Phase 2 results and noted that:

  • The four participating banks started the stress test with an aggregate CET1 ratio of 10.3% and an aggregate buffer ratio of 5.4%
  • The impact of the combined macro economic downturn and the operational risk event saw the aggregate CET1 ratio decline by 3.4 percentage points to 6.9% in the third year; driven in order of importance by:
    • Credit losses (including the large counter party loss) – 6.6 ppts
    • Growth in RWA – 1.4 ppts
    • Dividends and other capital deductions – 1.4 ppts
    • The operational risk event for misconduct risk – 0.7 ppts
    • Underlying profits which offset the gross decline in the CET1 ratio by 6.7 ppts to arrive at the net decline of 3.4 ppts
  • Mitigating actions improved the aggregate CET1 ratio by 1.1 ppts by year three to 8%; these actions included 1) reductions in lending, 2) additional interest rate repricing and 3) operating expense reductions.

There is not a lot of detail on individual bank outcomes. In the combined scenario, individual bank CET1 ratios declined to between 6.4% to 7.4% versus the 6.9% aggregate result. The individual buffer ratios fell to between 1.2 and 1.4% at their low points (no aggregate minimum buffer was reported).

Some observations on the outcomes of the RBNZ 2017 stress test

The fact that the major banks can maintain significant buffers above minimum capital requirements during quite severe stress scenarios offers a degree of comfort, especially when you factor in the absence of mitigating responses. Minor quibble here, but it is worth noting that the aggregate data the RBNZ uses to discuss the stress testing results does not map neatly to the minimum requirements and capital buffers applied at the individual bank level. A 5.4 ppt buffer over the 4.5% CET1 buffer equates to 9.9%, not 10.3%. Looking at Figure 1 in the “outcomes” paper also shows that there was a narrower range in the CCB at its low point than there was for the CET1 ratio so part of the CCB decline observed in the stress test may be attributable to shortfalls at either the Tier 1 or Total Capital Ratio levels rather than CET1. Small point, but it does matter when interpreting what the results mean for the target capital structure and how to respond.

The RBNZ is clearly correct to question the reliability of mitigating actions and the potential for some actions, such as tightening of lending standards, to generate negative feedback effects on asset prices and economic activity. However, it is equally open to question whether the market confidence that banks rely on to fund themselves and otherwise conduct business would remain resilient in the face of a three-year continuous decline in capital ratios. So I do not think we can take too much confidence in the pre mitigation outcomes alone; the mitigating responses matter just as much.

I have always thought of the capital buffer as simply “buying time” for management to recognise the problem and craft a response that addresses the core problems in the business while creating positive momentum in capital formation. The critical question in stress testing is how much time will the markets grant before they start to hold back from dealing with your bank. Markets do not necessarily expect a magic bullet, but they do expect to see positive momentum and a coherent narrative.  It would also be useful to distinguish between a core set of actions that could reasonably be relied on and other actions that are less reliable or come at a higher cost to the business.

It is hard to comment on the specific mitigating actions since the paper only reports an aggregate benefit of 1.1 ppts over the 3 years but I can make the following general observations:

  • Reductions in lending: The potential for reduced lending to generate negative feedback effects on asset prices and economic activity is a very valid concern but I do struggle to reconcile a 35% decline in house prices with a scenario in which the loans the banking system has outstanding to this sector do not appear to have declined.
    • I can’t see any specific numbers in the RBNZ paper but that is the inference I draw if the overall loan book has not declined, which seems to be implied by the statement that the 20% RWA growth over the first three years of the scenario was primarily due to higher risk weights.
    • Loan principal is progressively being repaid on performing loans but this balance sheet shrinkage is amplified in the scenario by elevated defaults, while the rate of new lending which would otherwise be the driver of growth in outstanding must be slowing if house prices are falling by such a large amount. In addition, the reduced volume of new loans being written are I assume for lower amounts than was the case prior to the decline in house prices.
    • I am very happy to be set straight on this part of the modelling but the numbers don’t quite add up for me. If I am right then a loan book that is stable or even declining in value may be what is implied by the scenario rather than something that adds further to the stress on capital ratios. At the very least, winding back loan growth assumptions relative to the benign base case seems a reasonable response.
  • Repricing: I can’t tell from the RBNZ paper how significant this factor was in contributing to the 1.1 percentage point 3 year improvement in CET1 but I am guessing it was reasonably material. Materiality therefore requires that the numbers be subject to a higher level of scrutiny.
    • History does offer a reasonable body of evidence that Australian and NZ banks have had the capacity to reprice loans under stress and in response to higher funding costs. The question is whether the collapse in trust in big banks has undermined the value of the repricing option they have traditionally benefited from.
    • I do believe that some of the critiques of bank repricing are not well founded but that does not change the real politic of the likely public and government push back should banks attempt to do so.
    • So the answer here is probably yes; the benefits of this particular mitigating action are likely not as reliable as they have been in the past. At the very least, there is likely to be a higher cost to using them.
  • The contribution of RWA growth to the decline in the capital ratio noted in the RBNZ paper is also worth calling out. There is not a lot of detail in the paper but it does appear that the 20% increase in RWA over the first three years of the scenario was driven primarily by an increase in the average credit RW from 45% to 54%.
    • This seems to imply that there was a significant cycle driven increase in capital requirements over the course of the scenario that was not driven by an increase in loans outstanding.
    • I believe that this kind of capital measurement driven impact on capital ratios is fundamentally different from the impact of actual losses and higher new lending but it is treated as equivalent for the purposes of the analysis. This looks to me like a category error; a decline in a capital ratio due to higher risk weights is not the same thing for the purposes of solvency as a loss due to a loan defaulting.
    • The solution probably lies in a better designed approach to counter cyclical buffers (see my post here and here for background) and the regulatory treatment of expected loss, but the stress testing analysis suffers by simply noting the outcome without going behind what that component of the decline in capital ratio actually represents.

Deposit growth under a stress scenario

I also struggled with the statement in Section 5 of the RBNZ paper that “Banks expected strong growth in retail deposits, in line with their experience during the Global Financial Crisis.

  • This statement seems to reflect the intuitive view that bank deposits increase under adverse conditions as people sell risky assets and put their money in banks. But we also know that selling a risky asset requires someone else to buy it, so the increase in cash in the account of the seller is offset by the decrease in the account of the buyer. There was an increase in bank deposits during the GFC but the simple sell risky assets and put your money in the bank does not seem to explain why it happened.
  • So what do we know about the GFC? Firstly, big banks continued to grow their loan book and we know that bank credit creation leads to deposit creation. The GFC was also a scenario where the collapse of securitisation markets saw lending for residential mortgages migrate back to big bank balance sheets. I think this also creates a net increase in deposits. Banks were also paying down foreign borrowings which I think is also positive for deposit creation via the balance of payments though this channel is murkier. We also observed money migrating from equities to property lending. The selling of the risky assets is net square for deposits by itself but the deposit creation comes as the cash in the hands of the seller gets leveraged up to support new credit creation via the increased property loans which are typically geared much more highly than other types of risk assets. The shift from equity to property also seems to be driven by the typical monetary policy strategy of reducing interest rates.
  • So it is not clear to me that the pool of deposits grows under the conditions of the RBNZ scenario. We do have the likelihood that people are selling risky assets but we seem to be missing a number of the elements specific to the GFC that saw new deposits get created in the banking system. The only deposit formation positive I can see is maybe via the balance of payments but, as noted above this, channel is very murky and hard to understand.
  • The other interesting question is whether bank deposits continue to be a safe haven for New Zealanders in future crises given that the RBNZ has implemented an Open Banking Resolution regime that exposes bank deposits to the risk of being bailed-in on a pari passu basis with other unsecured bank creditors. This is a unique feature of the NZ financial system which even eschews the limited guarantees of bank deposits that many other systems see as essential to maintaining the confidence of depositors under stress.

I may well be missing something here so I am very happy to hear the other side to any of the observations I have offered above. I am big believer in the value of stress testing which is why I think it is so important to get it right.

Tony

Minsky’s Financial Instability Hypothesis – Applications in Stress Testing?

One of the issues that we keep coming back to in stress testing is whether the financial system is inherently prone to instability and crisis or the system naturally tends towards equilibrium and instability is due to external shocks. Any stress scenario that we design, or that we are asked to model, will fall somewhere along this spectrum though I suspect most scenarios tend to be based on exogenous shocks. This touches on a long standing area of economic debate and hence not something that we can expect to resolve any time soon. I think it however useful to consider the question when conducting stress testing and evaluate the outcomes.

From roughly the early 1980’s until the GFC in 2008, the dominant economic paradigm has arguably been that the market forces, coupled with monetary and fiscal policy built on a sound understanding of how the economy works, meant that the business cycle was dead and that the primary challenge of policy was to engineer efficient capital allocations that maximised growth. The GFC obviously highlighted shortcomings with the conventional economic approach and drew attention to an alternative approach developed by Hyman Minsky which he labelled the Financial Instability Hypothesis.

Minsky’s Financial Instability Hypothesis (FIH)

Minsky focused on borrowing and lending with varying margins of safety as a fundamental property of all capitalist economies and identified three forms

  • “Hedge” financing under which cash flow covers the repayment of principal and interest
  • “Speculative” financing under which cash flow covers interest but the principal repayments must be continually refinanced
  • “Ponzi” financing under which cash flow is insufficient to cover either interest or principal and the borrower is betting that appreciation in the value of the asset being financed will be sufficient to repay loan principal plus capitalised interest and generate a profit

The terms that Minsky uses do not strictly conform to modern usage but his basic idea is clear; increasingly speculative lending tends to be associated with increasing fragility of borrowers and the financial system as a whole. Ponzi financing is particularly problematic because the system is vulnerable to external shocks that can result in restricted access to finance or which cause asset devaluation cycle as borrowers to sell their assets in order to reduce their leverage. The downward pressure on assets prices associated with the deleveraging process then puts further pressure on the capacity to repay the loans and so on.

The term “Minsky moment” has been used to describe the inflexion point where debt levels become unsustainable and asset prices fall as investors seek to deleverage. Investor psychology is obviously one of the primary drivers in this three stage cycle; investor optimism translates to a willingness to borrow and to pay more for assets, the higher asset valuations in turn allow lenders to lend more against set loan to valuation caps. Lenders can also be caught up in the mood of optimism and take on more risk (e.g. via higher Loan Valuation Ratio limits or higher debt service coverage ratios). Minsky stated that “the fundamental assertion of the financial instability hypothesis is that the financial structure evolves from being robust to being fragile over a period in which the economy does well” (Financial Crises: Systemic or Idiosyncratic by Hyman Minsky, April 1991, p16).

It should also be noted that a Minsky moment does not require an external shock, a simple change in investor outlook or risk tolerance could be sufficient to trigger the reversal. Minsky observed that the tendency of the endogenous process he described to lead to systemic fragility and instability is constrained by institutions and interventions that he described as “thwarting systems” (“Market Processes and Thwarting Systems” by P. Ferri and H. Minsky, November 1991, p2). However Minsky’s FIH also assumes that there is a longer term cycle in which these constraints are gradually wound back allowing more and more risk to accumulate in the system over successive business cycles.

What Minsky describes is similar to the idea of a long term “financial cycle” (25 years plus) being distinct from the shorter duration “business cycle” (typically 7-10 years) – refer this post “The financial cycle and macroeconomics: What have we learnt?” for more detail. An important feature of this longer term financial cycle is a process that gradually transforms the business institutions, decision-making conventions, and structures of market governance, including regulation, which contribute to the stability of capitalist economies.

The transformation process can be broken down into two components

  1. winding back of regulation and
  2. increased risk taking

which in combination increase both the supply of and demand for risk. The process of regulatory relaxation can take a number of forms:

  • One dimension is regulatory capture; whereby the institutions designed to regulate and reduce excessive risk-taking are captured and weakened
  • A second dimension is regulatory relapse; reduced regulation may be justified on the rationale that things are changed and regulation is no longer needed but there is often an ideological foundation typically based on economic theory (e.g. the “Great Moderation” or market discipline underpinning self-regulation).
  • A third dimension is regulatory escape; whereby the supply of risk is increased through financial innovation that escapes the regulatory net because the new financial products and practices were not conceived of when existing regulation was written.

Borrowers also take on more risk for a variety of reasons:

  • First, financial innovation provides new products that allow borrowers to take on more debt or which embed higher leverage inside the same nominal value of debt.
  • Second, market participants are also subject to gradual memory loss that increases their willingness to take on risk

The changing taste for risk is also evident in cultural developments which can help explain the propensity for investors to buy shares or property. A greater proportion of the population currently invest in shares than was the case for their parents or grandparents. These individual investors are actively engaged in share investing in a way that would be unimaginable for the generations that preceded them. Owning your own home and ideally an investment property as well is an important objective for many Australians but less important in say Germany.

These changes in risk appetite can also weaken market discipline based constraints against excessive risk-taking. A book titled “The Origin of Financial Crises” by George Cooper (April 2008) is worth reading if you are interested in the ideas outlined above. A collection of Minsky’s papers can also be found here  if you are interested in exploring his thinking more deeply.

I have been doing a bit of research lately both on the question of what exactly does Expected Loss “expect” and on the ways in which cycle downturns are defined. I may be missing something, but I find this distinction between endogenous and exogenous factors largely missing from the discussion papers that I have found so far and from stress testing itself. I would greatly appreciate some suggestions if anyone has come across any good material on the issue.

Tony