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Oversight of Sovereign Exposure Concentration Zlata Komárková and Václav Hausenblas Financial Stability Department Agenda 1. 2. 3. 4. 5. Sovereign exposures and systemic risk Motivation for Holding of Sovereign debt Sovereign exposures in Czech banking sector Policy options CNB approach: enhanced Pillar 2 requirement a) A limit on sovereign exposures b) Sovereign risk indicator (ISR) 2 Main definitions Sovereign credit risk: a situation in which a sovereign sector (usually a national government) is unable to honour its pre-agreed financial obligations unaided and the country therefore defaults. Financial Stability: a situation where the financial system operates with no serious failures or undesirable impacts on the present and future development of the economy as a whole, while showing a high degree of resilience to shocks coming from various sectors of the economy, the financial markets and macroeconomic developments. The aim of this part of the presentation is to justify the designation of sovereign credit risk as systemic risk. (1.) Sovereign Exposures and Systemic Risk The nexus of banks and sovereigns The two-way interaction between the banking sector and the sovereign sector: sovereign sector: the ultimate source of insurance, the supply of risk-free GB – a basis for the pricing of other assets, banking sector: the smooth flow of credit to the real economy, an important creditor for sovereign sector. A close two-way link between banking and sovereign distress, with problems in the banking sector having a negative effect on the sovereign sector, and sovereign stress exacerbating the disruption in the banking system. Transmission of banking sector risk to sovereigns Three main transmission channels : 1. the provision of government support to banks, which increase sovereign debt => forms: liquidity measures, direct capital increase, troubled asset relief programs, government guarantees etc. 2. banking sector deleveraging, which, by amplifying the contraction in overall economic activity, leads to falling budget revenues and rising budget expenditures. 3. credit booms can give a one-off boost to government‘s fiscal balances: the government‘s fiscal position appears much stronger than it actually is, this may unjustifiably give governments the confidence to pursue policies that result in increases in spending that are unsustainable in the long run. Transmission of sovereign credit risk to banks Four main transmission channels : 1. direct portfolio exposures: the higher bond yields (lower bond prices) associated with higher sovereign risk can hurt banks through their holdings of sovereign debt. 2. funding conditions (sovereign securities as collateral): increases in sovereign risk reduce the availability or eligibility of collateral, and hence banks‘ funding capacity. 3. the perceived ability of the sovereign to provide a backstop to banks under strain: being perceived in a weaker fiscal position (for example rating cuts) provides less credible and valuable guarantees or financial support => higher liquidity and credit risk (more expensive funding) for banks. 4. crowding out – the possibility of government debt crowding out private sector debt, sovereign distress increase the cost and/or reduces the availability of bank funding through debt. … two more channels • The loss of availability of „the risk-free asset“ on whose existence most market risk management models are based. A loss of power of such models can in turn lead to a further increase in risk aversion and to knock-on effects on banks‘ portfolios. • The channel of change in the attitude to risk: sovereign tensions may cause a rise in investors‘ risk aversion, which in turn may increase the risk premiums demanded on sovereign and bank securities and reduce banks‘ funding availability. Financial Stability Review, April 2012, BdF Sovereign exposures – diversity across the EU Domestic sovereign exposures held by MFI (in % of total assets, selected EU economies) EE FI NE LV FR DE AT BE ES IT SI CZ SK RO 0 5 Source: ECB Note: As of November 2014. 10 15 20 (2.) Motivation for Holding of Sovereign Debt Sovereign securities are regarded as risk-free risk–free = zero default risk Government bond markets are generally the most liquid, therefore government bonds are used as a store of value. There are two main reasons: 1. intertemporal debt servicing: the sovereign sector as a debtor can carry its debt forward from one period to the next (from one generation to another). 2. government has power to change the degree of central bank independence: government can „print money“ to pay off their debts. Their ability to do so depends mainly on the degree of central bank independence and on their ability to change it. 12 Financial markets with a risk–free sovereign How will markets adjust to a loss of faith in the idea of risk–free sovereign? Do they need it? 1. sovereign securities serve as the base asset or reserve asset of the banking system: the low-volatility, low-credit-risk asset around which bankers and investors build their balance sheets and portfolios, 2. sovereign securities serve as a benchmark that is a reference for value, 3. sovereign securities serve as (high quality liquid) suitable collateral, 4. sovereign securities are used to hedge away certain risks, 5. sovereign securities as a proxy for the risk–free rate that helps to assess the riskiness of other assets. 13 The regulation gives preferential treatment to sovereign exposures The current and newly prepared European banking regulation treats sovereign risk by essentially not admitting the possibility of the domestic government defaulting on its debt, and the default risk associated with government bonds is considered to be zero up to a certain threshold: 1. a low or zero capital requirement for sovereign exposures denominated in the domestic currency, 2. a low capital requirement for exposures collateralized by government paper given the very low haircuts required for sovereigns with high ratings, 3. the exclusion of sovereign exposures from the existing limits on large exposures, 4. automatically to classify government bonds denominated in the domestic currency as highly liquid, high-quality assets, and 5. moreover, the new Solvency II framework for the insurance sector envisages a zero risk factor for sovereign exposures. 14 (3.) Sovereign exposures in Czech banking sector Sovereign exposures in Czech banking sector (1) Significance of Czech public debt • Czech government debt can be regarded as sustainable, even though its long-term trend is potentially risky. • Czech financial system is bankdominated and relatively small. • Banks operate in environment of structural liquidity surplus. • Czech capital market does not offer enough investment alternatives in local currency to domestic government bonds. • Czech government bonds are held mainly by domestic banking sector and mostly to maturity. (in %) 50 18 45 16 40 14 35 12 30 10 25 8 20 6 15 10 4 5 2 0 0 2008 2009 2010 2011 2012 2013 Debt to GDP Debt to MFI and insurance sector total assets Debt held by MFI as a share in assets (right axis) Source: ECB, Eurostat, Czech National Bank Public debt to GDP (in %, selected EU countries) EE FI NE LV FR DE AT BE ES IT SI CZ SK RO 0 20 Source: Eurostat Note: As of 2014 40 60 80 100 120 140 16 Sovereign exposures in Czech banking sector (2) • Shares of SE in assets of national banking sectors differ significantly. These shares are not necessarily directly related to size of government debt (see CZ and SK). • The share of Czech government bonds in Czech banking assets is above average by international comparison (EU average less than 4 %). Domestic sovereign exposures held by MFI Bank sector assets (in % of total assets, selected EU economies) (% of Total Equity, as of 30. 9. 2015) Loans: Central bank EE FI NE LV FR DE AT BE ES IT SI CZ SK RO 129,5 Loans: Interbank 61,5 Loans: Clients 569,8 Bonds: CZ government 144,6 Bonds: Other government 15,7 Bonds: CZ corporate 69,0 Bonds: Other corporate 7,4 Other assets 157,4 0 0 5 Source: ECB Note: As of November 2014. 10 15 100 200 300 400 500 600 20 Source: CNB 17 (4.) Policy options Policy options (1) • Discussion about changing regulatory approach has already started in EU and at global level. • Regulation of banks: • • • • • Pillar 1 capital requirements – removing „domestic carve-out“ in the SA, introducing a non-zero risk-weight floor in the SA, setting a minimum floor in the IRB approach…, Diversification requirements – removal of the examption to the large exposures regime …, Regulation of liquidity risk – haircuts that cater to credit risk…, Macroprudential regulation – capital add ons, applied to all sovereigns, a group of sovereigns or and individual sovereign, could be activated when certain conditions are fulfilled (decision by supervisors), Enhanced Pillar 2 or Pillar 3 requirements. 19 Policy options (2) • Concentration of SE in banks’ balance sheets important issue for Czech banking sector and for the CNB as bank supervisor: • The CNB ready to use Pillar 2-based approach until regulatory discussion delivers different options. • Constrained discretion concentration: necessary in responding to SE • fundamental macroprudential analysis of structural features of government debt required, • rules with some flexibility should be pre-announced. • Assessment needed when deciding whether to employ tools: • economic conditions (government debt characteristics, financial market possibilities, volume of savings, monetary regime, etc.), • initial situation of sectors and intensity of links between them (absorption capacity, room to adjust, size of buffers, etc.). 20 (5.) CNB approach: enhanced Pillar 2 requirement CNB approach: enhanced Pillar 2 requirement (1) • No scope for any radical solution to SE concentration (trying to avoid side-effect impacts). • Our new prudential supervisory tool to be applied for gradually reducing the risk of systemic concentration of SE under Pillar 2 – systemic important SE. • The tool is based on the fact that banks have to ensure consistent and effective management of concentration risk in their risk management system. • The CNB has to review and assess whether banks ensure proper management and coverage of this risk – from now on according to the new tool. • Aim of the tool is not to directly limit investment in sovereign bonds, but to motivate banks to behave in forward-looking and prudent manner far enough in advance. 22 CNB approach: enhanced Pillar 2 requirement (2) • SE defined as exposures to individual governments and their agencies in EU Member States in all currencies, to which exemptions apply under Pillar 1, • An important SE defined as exposures held by a bank with a minimum ratio of 100% to its eligible capital and become systemic if the assets of banks with important exposures exceed 5% of their total assets. • Fundamental principle of the tool: create additional capital from above-limit SE if increased sovereign risk is indicated three years ahead. • The add-on is applied with three-year time delay to enable banking and sovereign sectors to react in time. 23 Starting points for use of tool after detecting systemic important SE • Three main variables for computing the additional capital requirement: • Limit for determining above-limit part of systemic important SE at given time. • Estimate for a sovereign risk indicator (ISR as a degree of riskiness) three years ahead => monitoring of whether threshold value of the indicator is exceeded. • Loss given default (LGD, Article 161 of CRR for FIBR => 45%). 24 Above-limit sovereign exposure • SE limit is a decreasing function of the ISR in 0–100%. • As ISR rises, share of below-limit part of SE decreases and share of above-limit part increases. • If the ISR is 0%, the limit is at its upper bound of 222% of eligible capital, whereas if the ISR is 100%, the limit is at the lower bound of zero. • As the limit decreases linearly between the two ISR bounds, its amount can be expressed for any ISR value as ((1-ISR)*eligible capital)/0,45. 25 Above-limit sovereign exposure • Lower limit is 0% when ISR = 100%: the entire exposure is above limit and expected loss when LGD = 45% is covered by capital. • Lower limit highly unlikely to be reached – tool will send out timely signals needed for bank balance sheet adjustment. 26 Additional capital requirement • WHEN? The CNB will indicate setting additional capital requirements • at the earliest when the riskiness of sovereign exposures (the ISR ) three-year outlook exceeds a „soft“ threshold of 5% and the results of our analysis confirm necessity, • or if the ISR three-year outlook exceeds a „hard“ threshold of 8%, unconditionally. • WHO? Three years after the indication a bank will have to create the additional capital requirement: • if the bank holds the above-limit SE, • and its already allocated capital to cover risk stemming from the SE is not sufficient. • HOW HIGH? • • The above-limit part of SE for individual banks according the current ISR and eligible capital, The RWA derived from the standard formula set out of the CRR (instead PD the current ISR will be used). 27 Additional capital requirement 28 Public finance stress tests • To assess the riskiness of sovereign exposures in a forward-looking manner CNB conducts a public sector debt stress test: • • • • Since 2015, On a yearly basis, On 3Y horizon, To obtain stressed ISR based of projection of macro/fiscal fundamentals and market prices under sever stress. 29 Motivation behind ISR and its stress-testing 1. Stress-test allows for longer-term horizons. 2. Avoids reliance on and/or interference with rating agencies and market sentiment. 3. Stress-testing is a well founded tool in financial stability. Failure in stress-test is a clear and well-understood trigger for supervisor’s intervention. 30 Motivation behind ISR and its stress-testing (2) • Stress-testing framework for banks has relatively clear measures and benchmarks: capital ratio and its regulatory minimums (8% + add-ons) • What measures and benchmarks can we use for public finances? Traditional measures not suitable: • Government debt – low explanatory power. • Primary budget balance – good power, but very cyclical on its own. • CDS spreads – volatile, contains noise and other credit premiums • → Sovereign risk indicator (ISR) 31 Motivation behind ISR and its stress-testing (3) • ISR is (intentionally) not PD, although it is loosely related to 1Y PD. • Estimating PDs for sovereigns is art rather then science. • Many type of information cannot not be taken into account using quantitative methods. • It needs heavy support from expert judgement. • That would not be very transparent and therefore not suitable for communication. • ISR is a benchmarking measure tailor-made for CNB’s stress-testing framework. 32 Construction of the sovereign risk indicator (ISR) • ISR is constructed as a composite indicator recalibrated to 0–100% scale. • Composite of several sub-indicators (variables): • • • • Macroeconomic conditions, Fiscal conditions and debt structure (quality), Financial conditions, Quality of institutions. • Careful selection of indicators to meet the following criteria: • High goodness of fit. • Easily connects to stress-test. • Variables that are part of the scenario should not drive the ISR too much. 33 Construction of the sovereign risk indicator (ISR) (2) • Each variable has its critical threshold. Breaching the threshold sends a signal. • Thresholds were estimated statistically using historical data of 40 economies with/without fiscal stress event. • Noise-to-signal method: • Find a threshold that minimize both Type I and Type II errors (i.e. maximize 1-fpr-fnr). • Method used e.g. by the EC for S0 indicator of fiscal stress. • Other methods tends to be highly biased towards minimizing false positive rate, as the data are heavily unbalanced (to few fiscal stress observations). 34 Reminder: Type I and Type II errors • Type I error: indicator signals crisis when there’s no crisis coming • Type II error: indicator misses the crisis approaching outcome negative (0) positive (1) True positive False positive (Type I error) negative (0) False negative (Type II error) True negative test positive (1) 35 Construction of the sovereign risk indicator (ISR) (3) • Each signal has its weight. • The better the sub-indicator, the higher the weight. 1. 2. 3. 4. Find the signaling sub-indicators. Take the sum of the weights of signaling sub-indicators. Get a number (CI) from 0–100 interval. This is a great indicator of stress but its relationship to PD is highly nonlinear, so 5. recalibrate it using the formula: • • ISR = exp(-8.1+10.1CI)/(1+exp(-8.1+10.1CI)) Constant term (-8.1) and slope (10.1) in the logit expression were estimated using logistic regression. 36 Construction of the sovereign risk indicator (ISR) (4) Critical limit • Several kinds of driving factors: • Macroeconomic conditions, • Fiscal conditions and debt structure (quality), • Financial conditions, • Quality of institutions. • Careful selection to meet the following criteria: • Has high goodness of fit. • Easily connects to stress-test. • Variables that are part of the scenario should not drive the ISR too much. fpr (%) fnr (%) Weight (%) M acroeconomic variables Real GDP grow th (%) < -2,3 4,8 65,0 6,3 < -1,8 47,6 10,0 8,9 < 19,3 26,5 35,0 8,1 External debt (% of GDP) > 99,6 18,0 56,0 5,5 Difference betw een real GDP grow th and real GB yield (pp) > 6,3 9,0 69,3 4,5 Government debt (% of GDP) > 64,7 28,0 60,0 2,5 Primary balance (% of GDP) < -3,2 17,1 45,8 7,8 10Y government bond yield (%) > 10,8 30,5 34,1 7,4 > 19,0 23,9 62,3 2,9 > 21,7 52,7 24,6 4,8 > 27,1 31,0 47,2 4,6 > 34,9 49,9 20,2 6,3 < 1,0 33,9 16,8 8,3 Political stability (WGI score) < 0,8 40,4 13,4 7,8 Rule of law (WGI score) < 1,2 44,9 10,5 7,5 Banking crisis > 0 6,4 75,0 3,9 Past sovereign defaults > 0 21,5 65,0 2,8 Current account balance (% of GDP) Gross national savings (% of GDP) Fiscal variables Government debt maturing w ithin one year (% of GDP) Share of government debt maturing w ithin one year (%) Share of foreign currency debt (%) Share of non-residents in debt holdings (%) Institutional variables Government effectiveness (WGI score) 37 Modelling technicalities: Fiscal model Overview 38 Modelling technicalities: Fiscal model Primary balance – calculations summary Optimistic Variant Pessimistic Variant Income Direct taxes GDP x Ratio to GDP assumed in fiscal prognosis Indirect taxes GDP x Ratio to GDP assumed in fiscal prognosis Social insurance GDP x Ratio to GDP assumed in fiscal prognosis Other current income GDP x Ratio to GDP assumed in fiscal prognosis Sales income GDP x Ratio to GDP assumed in fiscal prognosis Capital income GDP x Ratio to GDP assumed in fiscal prognosis Expenditure Social payments: healthcare Social payments: illness and disability Social payments: pensions Social payments: unemployment Social payments: other Level assumed in fiscal prognosis GDP x Ratio to GDP assumed in fiscal prognosis Level assumed in fiscal prognosis Last value x Index of increase in unemployment rate GDP x Ratio to GDP assumed in fiscal prognosis Subsidies GDP x Ratio to GDP assumed in fiscal prognosis Level assumed in fiscal prognosis Other current income GDP x Ratio to GDP assumed in fiscal prognosis Level assumed in fiscal prognosis Interest payable Not enter Primary Balance Employees' remmuneration GDP x Ratio to GDP assumed in fiscal prognosis Level assumed in fiscal prognosis Consumption GDP x Ratio to GDP assumed in fiscal prognosis Level assumed in fiscal prognosis Investment GDP x Ratio to GDP assumed in fiscal prognosis Level assumed in fiscal prognosis Net acquisition of assets and inventories GDP x Ratio to GDP assumed in fiscal prognosis Level assumed in fiscal prognosis Capital transfers GDP x Ratio to GDP assumed in fiscal prognosis Level assumed in fiscal prognosis 39 Modelling technicalities: Fiscal model Interest payments • On the other hand, it is very sensitive to fiscal situation and accelerates effects of sovereign risk • • CZ (2014): 1.3% GDP; 3.1% total government expenditures Portugal 5% of GDP, Italy 4.7%, Greece 3.9% (2014 data) Thus it demands a proper modelling How to model interest payable? • Interest expense in our models consists of 2 segments • • Old debt – its structure and interest rate have already been determined; its development is thus largely automatic New debt – its interest rates and maturity structure have to be modelled Avg past bond yield Debt inherited from previous periods • Our approach uses 15 yearly maturity buckets • Data on maturity structure as to the initial year taken from Bloomberg Principal • Old debt 1Y 2Y 3Y 15Y Residual maturity New debt Debt originating due to 1. Old debt maturing (1Y bucket from previous years) 2. Current period budget deficit (current expenditures exceeding revenues) Current bond yield 3. Stock-Flow adjustments (accumulation or dissolution of government financial reserves) Principal Why to model interest payable? • Interest expense is rather small component of budget balance 1Y 2Y 3Y 4Y 5Y 15Y 40 Modelling technicalities: Fiscal model Interest payments Interest rates on new debt Maturity structure of new debt • • To determine interest rates on new debt, we use a panel regression (35 OECD countries and 24 years of annual data), and using variables of • • • • • • • • The analysis is conducted for 1Y, 5Y, and 10Y maturities • • Change in public debt to GDP over 2 years* 3M money market rate Inflation US government yield at relevant horizon Issuer credit rating GDP p.c. Lagged variable of past yield For other maturities up to 15 years, interpolation is used The model should be easy enough and work with variables we are able to project • Governments might optimize maturity structure of new debt according to current and expected financial market conditions Especially if credit risk worsens and longmaturity debt commands large premium, issuers might shift to shorter maturities • • • • This reduces interest expense But increases future refinancing need, which is penalized in the ISR Government response to the market conditions is inherently difficult to model Our model thus assumes previous year‘s maturity structure of new issues prevails in future * Notice the positive feedback loop between public debt raising interest rates, which raises public debt further due to higher interest expenses. 41 Results: FSR 2015/2016 Public finance stress test • FSR 2015/2016 sovereign stress test results: • Two sub-indicators send signals already for 2015. • These drives the ISR under very severe macro stress test scenario: • Real GDP growth, • GB yields and • Primary deficit, • ISR up to 0.8 and then back to 0.27 on three-year horizon. • This is well bellow the 5% threshold. Adverse Scenario M acroeconomic variables Real GDP grow th (%) Current account balance (% of GDP) Gross national savings (% of GDP)* External debt (% of GDP)* Difference betw een real GDP grow th and real 10Y GB yield (pp) Fiscal variables Government debt (% of GDP) Primary balance (% of GDP) 10Y government bond yield (%) Government debt maturing w ithin one year (% of GDP) Share of government debt maturing w ithin one year (%) Share of foreign currency debt (%) Share of non-residents in debt holdings (%)* Institutional variables Government effectiveness (WGI score)* Political stability (WGI score)* Rule of law (WGI score)* Banking crisis* Past sovereign defaults* Sovereign risk indicator (ISR, %) 2015 2016 2017 2018 Critical lim it 4.3 -2.7 -3.3 -0.7 < -2.3 0.6 3.3 2.6 1.0 < -1.8 28.2 28.2 28.2 28.2 < 19.3 70.0 70.0 70.0 70.0 > 99.6 -4.0 5.0 10.4 4.4 > 41.1 45.0 55.5 64.6 > 64.7 0.7 -0.5 -3.8 -5.8 < 0.7 1.7 2.4 3.1 > 10.8 6.7 8.9 12.0 13.4 > 19.0 16.4 19.7 21.6 20.7 > 21.7 15.4 15.5 15.8 11.7 > 27.1 38.4 38.4 38.4 38.4 > 34.9 1.02 1.02 1.02 1.02 < 1.0 1.0 1.0 1.0 1.0 < 0.8 1.1 1.1 1.1 1.1 < 1.2 No No No No > Yes No No No No > Yes - 0.23 0.80 0.27 Source: CNB, CZSO, ECB, WB, CNB calculation 42 6.3 -3.2 References • CNB (2016): Financial Stability Report 2015/2016 • Komárková, Dingová, Komárek (2013): Fiscal sustainability and financial stability, CNB FSR 2012/2013 • Interní metodika ČNB určená pro účely přezkumu a vyhodnocování rizika koncentrace svrchovaných expozic, CNB website (Czech only) • http://www.esrb.europa.eu/pub/pdf/other/esrbreportregulatorytreat mentsovereignexposures032015.en.pdf?c0cad80cf39a74e20d9d5 947c7390df1 • http://www.cnb.cz/miranda2/export/sites/www.cnb.cz/cs/financni_st abilita/zatezove_testy/download/InterniMetodika_SvrchovaneExpo zice.pdf • http://www.cnb.cz/miranda2/export/sites/www.cnb.cz/cs/financni_st abilita/zpravy_fs/fs_2012-2013/fs_2012-2013_clanek_ii.pdf 43 Thank you for your attention www.cnb.cz Financial Stability Department zlatuse.komarkova@cnb.cz vaclav.hausenblas@cnb.cz 44