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The financial crisis and the future of financial regulation

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The financial crisis and the future of

financial regulation





Related information

Slides:

The Economist’s Inaugural City Lecture







Speech by Adair Turner, Chairman, FSA

The Economist's Inaugural City Lecture

21 January 2009

It is stating the obvious to say that over the last 18 months, and even more so the last four, the world

financial system – and particularly but not exclusively the world banking system – has suffered a

crisis as bad as any since the stock market crashes of 1929 and the various banking crises that

followed. As a result, banking systems in many countries are suffering from an impaired ability to

play their vital role in credit extension to the real economy and a process of deleveraging threatens

severe adverse effects on real economic prospects. The crisis therefore presents the financial

authorities – central banks, regulators and finance ministries – with two challenges:

• The first and most urgent is to design short-term policies so as to at least limit the adverse

impact of deleveraging and deflation on the real economy. We cannot make that impact nil,

but we do know how to avoid the policy mistakes which turned the initial problems of 1929-

30 into the Great Depression. Fiscal and monetary policies need to be carefully designed,

and – as we approach a zero interest rate and consider quantitative easing options – need to

be increasingly coordinated. And there are a wide range of policies which can be taken to

free up financial markets – measures which Ben Bernanke last week labeled “Credit Easing”

– funding guarantees, liquidity provision, tail risk insurance, direct central bank purchases of

assets, and regulatory approaches to capital regulation which avoid unnecessary pro

cyclicality in capital adequacy requirements. The measures announced by the Chancellor of

Exchequer on Monday were designed as an integrated package, which will have a

significant impact. And if more measures are acquired they can and will be taken.

• It is not, however, on this challenge of short-term economic management – where the lead

must be with the fiscal and monetary authorities – that I’m going to talk tonight. But instead

on the second challenge: how to design the future regulation and supervision of financial

services so that we significantly reduce the probability and severity of future financial

crises? Last September, when I took over as Chairman of the FSA, the Chancellor asked me

to conduct a review of our regulation and supervision of the banking system, and I will

deliver that Review in March, alongside the publication of a comprehensive FSA Discussion

Paper. That paper will set out the changes the FSA has already made, those where we have

proposals in principle but need to consult on details, and those where we have defined our

objectives but now need to play our role in achieving international agreement.

Those proposals for regulatory change need to be grounded in analysis of what happened – why this

crisis occurred. Tonight therefore I will concentrate on that analysis. I will then draw out some

issues and possible implications relating to the future shape and size of the banking and credit

mediation markets. I will finally and briefly outline three changes which we know are in principle

essential.

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What happened and why?

So what happened? Why did this extreme crisis occur? I think with hindsight – and it is only with

hindsight – a fairly compelling and broadly agreed explanation of what has occurred can be set out.

At the core of the crisis was an interplay between macroeconomic imbalances which have become

particularly prevalent over the last 10-15 years, and financial market developments which have been

going on for 30 years but which accelerated over the last ten under the influence of the macro

imbalances.

Macro-imbalances. First, the macro side. The last decade [Exhibit 1] has seen an explosion of world

macro-imbalances, with very large current account surpluses piling up in the oil exporting

countries, China, Japan and some other east Asian developing nations, and large current account

deficits piling up in the USA, but also in the UK, in Ireland, Spain and some other countries. A key

driver of those imbalances has been very high savings rates in countries like China; since these high

savings are in excess of domestic investment, China and other countries must accumulate claims on

the rest of the world. But since, in addition, those countries are committed to fixed or significantly

managed exchange rates, these rising claims take the form of central bank reserves, typically

invested not in a wide array of equity, property or fixed income assets – but almost exclusively in

apparently risk-free or close to risk-free government bonds or government guaranteed bonds.

This in turn has driven a reduction in real risk free rates of interest to historically low levels

[Exhibit 2]. In 1990 you could invest in the UK or the US in risk-free index-linked government

bonds at a yield to maturity of over 3% real; for the last five years the yield has been less than 2%

and at times as low as 1%.

These very low medium- and long-term real interest rates have in turn driven two effects:

• First, they have helped drive rapid growth of credit extension in some developed countries,

particularly in the US and the UK – and particularly but not exclusively for residential

mortgages [Exhibit 3] – with this growth accompanied by a degradation of credit standards,

and fuelling property price booms which for a time made those lower credit standards

appear costless.

• And secondly, they had driven among investors a ferocious search for yield – a desire among

any investor who wishes to invest in bond-like instruments to gain as much as possible

spread above the risk-free rate, to offset at least partially the declining risk-free rate. Twenty

years ago a pension fund or insurance company selling annuities could invest at 3.5% real

yield to maturity on an entirely risk-free basis; now only 1.5%: any products which appear

to add 10, 20 or 30 basis points to that yield without adding too much risk look very

attractive.

Financial sector innovation. The fundamental macro economic imbalances have thus stimulated

demands which have been met by a wave of financial innovation, focused on the origination,

packaging, trading and distribution of securitised credit instruments. Simple forms of securitised

credit – corporate bonds – have of course existed for almost as long as modern banking. In the US,

securitised credit has also played a major role in mortgage lending since the creation of Fannie Mae

in the 1930s; and securitisation had been playing a steadily increasing role in the global financial

system and in particular in the American financial system for a decade and a half before the mid-

1990s. But it was from the mid-1990s that the system entered explosive growth in both scale and

complexity:

• With huge growth in the value of the total stock of credit securities [Exhibit 4]

• An explosion in the complexity of the securities sold, with the growth of the alphabet soup

of structured credit products.

• And with the related explosion of the volume of credit derivatives, enabling investors and

traders to hedge underlying credit exposures, or to create synthetic credit exposures. [Exhibit

5]

All of these developments, in different ways, seeking to satisfy the demand for yield uplift, and all

predicated on the belief that by slicing and dicing, structuring and hedging, using sophisticated

mathematical models to understand and manage risk, we can “create value” by offering investors

combinations of risk and return which are more attractive than those available from direct purchase

of the underlying credit exposures.

This explosion was supported by and in itself drove big increases in the leverage of major financial

institutions – in particular investment banks and the investment banking activities of some large

universal banks. [Exhibit 6]

And as it developed the rapid growth began to drive and to be driven by one of those self-fulfilling

cycles of falling risk aversion and rising irrational exuberance to which all liquid traded markets

seem at times to be susceptible:

• Credit spreads on a wide range of securities and loans falling to clearly inadequate levels.

[Exhibit 7]

• The price charged for the absorption of volatility risk falling because volatility seemed to

have declined. [Exhibit 8]

• And these falling spreads and volatility prices driving up the current value of a range of

instruments, marked to market value on the books of banks, investment banks and hedge

funds – fuelling in turn higher apparent profits and higher bonuses, and as a result

reinforcing management and traders certainty that they must be doing the right thing.

Until we reached the point where people began to fear that the music was about to stop – but where

others felt, in Chuck Prince’s words, that they had to keep dancing till the band stopped, which it

did in summer and autumn 2007.

A cycle therefore of irrational boom and then bust; and therefore in some ways no different from

other cycles which we have seen in markets in the past: in equities, in property, in South Sea project

participations, in tulips. But what makes this one different – and potentially more economically

destructive to the real economy – is that it is the first major global boom and bust of securitised

credit instruments. Because at the core of this story is the development of a new model for

delivering credit intermediation – the originate and distribute model of securitised credit. And one

of the crucial questions we therefore have to ask is whether this originate and distribute model is

inherently riskier than the one that it has partially replaced – or whether, provided we regulate it

more effectively, it is capable of being a more stable system, or indeed of delivering the positive

benefits of increased financial stability which its advocates originally proposed.

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So before talking about the response to the crisis, I will make four observations relating to the

growth and the implications of the securitised credit intermediation model:

Securitised credit: initial proposition and subsequent

evolution

First, as already said, securitised credit has a history going back many decades. But it really began

to take off in the 1980s, and it is interesting to revisit the arguments made in its favour at that time.

One argument was greater liquidity for end investors (an issue I’ll come back to), but another

crucial argument was that securitisation would reduce risks for individual banks by passing credit

risk to end investors, reducing the need for unnecessary and expensive bank capital [Exhibit 9].

Rather than a regional bank in the US holding a dangerously undiversified holding of credit

exposures in that particular region, which created the danger of a self-reinforcing cycle between the

decline in a regional economy and the decline in the capital capacity of regional banks – much

better to package up the loans and sell them through to a diversified set of end investors. And

indeed it was argued that securitised credit intermediation could reduce risks for the whole banking

system, since while some of the credit risk would be held by the originating bank and some by other

banks acting as investors, much would be passed through to end non-bank investors. Credit losses

would therefore be less likely to produce banking system failure.

But that is not what happened. Because when the music stopped – as these figures from the IMF

Global Financial Stability Report of April, 2008 make clear [Exhibit 10] – the majority of the

holdings of the securitised credit, and the vast majority of the losses which arose, did not lie in the

books of end investors intending to hold the assets to maturity, but on the books of highly leveraged

banks and bank-like institutions.

Because what increasingly happened [Exhibit 11] was that the credit securitised and taken off one

bank’s balance sheet, rather than being simply sold through to an end investor, was:

bought by the propriety trading desk of another bank;

or sold by the first bank but with part of the risk retained via the use of credit derivatives; or

used as collateral to raise short-term liquidity – creating a complex chain of multiple

relationships between multiple institutions, each performing a different small size of the

credit intermediation and maturity transformation process, and each with a leveraged

balance sheet requiring a small slice of capital to support that function.

Some banks were truly doing “originate and distribute”: but the trading operations of other banks

(and sometimes of the same bank) were doing “acquire and arbitrage1. The new model left most of

the risk still somewhere on the balance sheets of banks and bank-like institutions but in a much

more complex and less transparent fashion.





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Changing forms of maturity transformation

My second point is that in this story, what happened to maturity transformation and to assumptions

about liquidity was particularly important. One of the key socially valuable functions of the banking

system is to deliver maturity transformation, holding longer term assets than liabilities, and thus

enabling the non-bank sector to hold shorter term assets than liabilities. This absorbs the risks

arising from uncertainties in the cash flows of households and corporates, and results in a term

structure of interest rates more favourable to long-term capital investment than would pertain if no

such maturity transformation were being performed.

It is a very important function of undeniable social value, but also one which creates risks. If

everybody wants their money back on the contractual date, no bank could repay them all. Therefore

we have insurance via lines from other banks, liquidity policies to measure and limit the extent of

maturity transformation, and ‘lender of last resort’ facilities provided by the central bank. A

complex balancing act of individual bank practices, regulatory policies and central bank facilities

and discretion, but at least one we know is of central importance.

But one of the striking developments of the last several decades has been that a growing part of this

maturity transformation has been occurring not on the books of regulated banks with central bank

access, but on the off-balance sheets of banks, and on the balance sheets of shadow banks or near

banks. SIVs and conduits performed large-scale maturity transformation between short-term

promises to noteholders and much longer term instruments held on the asset side. Investment banks

funded holdings of long-term to maturity assets with much shorter term liabilities. And while

mutual funds with long-term assets and immediately available redemption were not banks since

their liabilities to investors did not have certain capital value, the implicit promise not to “break the

buck” meant that their behaviour in a liquidity crisis – selling assets rapidly to meet redemptions –

could reinforce the liquidity crisis elsewhere.

While it is difficult to get the aggregate figures, it therefore seems highly likely that the aggregate

degree of maturity transformation being performed by the financial system in total has increased

substantially over the decades. And it is certainly clear that a wide range of institutions – both banks

and near banks – have been relying on “liquidity through marketability” to assure themselves that

their maturity transformation activity is safe. “Liquidity through marketability” – i.e. I can count

this as a one-day asset because I can sell it within a day in a liquid market – has always been an

important concept. Instruments which have long contractual tenor but which can be sold or

discounted to generate immediately funds have been a key element in bank liquidity management

since the days of Bagehot. But the extent to which the bank and near-bank system in total has relied

on “liquidity through marketability” has increased dramatically over the last three decades and

particularly in the years running up to the crash. The system in total has become significantly more

reliant on the assumption that a very wide range of assets could be counted as liquid because they

would always be sellable in liquid markets2.

And while some of these developments – in particular the growth of SIVs, and investment bank

balance sheets and mutual funds – were most prevalent in the US and less important elsewhere, the

impact in a global funds market was felt throughout the world. Northern Rock and Bradford &

Bingley were directly or indirectly dependent on the maturity transformation function of US

mutual funds and SIVs, enabling them to access the funds of short-term US investors to provide

long-term UK mortgages , with the macro-imbalances I mentioned earlier, including the feature that

while the US was a huge net recipient of Asian central bank investment, it was simultaneously on

the private-sector side, a large net investor in, among other things, British residential mortgage

backed securities [Exhibit 12]

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Irrational exuberance in credit prices more harmful than

in equities?

So we have had the huge growth in securitised credit intermediation and a related increasing

reliance of the total system on liquidity assured by marketability. That raises the question of

whether a system of securitised credit intermediation is inherently more risky, at the systemic rather

than the idiosyncratic level, than a system of on-balance sheet intermediation.

In a securitised system, credits become marketable instruments, tradeable in liquid markets. And we

know from history that all liquid markets – markets where you can buy something one day in the

hope of selling it the next day for profit – can be susceptible to swings in sentiment which produce

significant divergence from rational equilibrium prices. The historical record of such irrational

swings has been extensively documented by economists such as Kindlebeger, Minsky and Shiller:

and the root causes of these swings in human psychology and in the incentives facing institutions

and individual traders are increasingly well understood. Internet equity prices in 2000 were driven

irrationally high by irrational exuberance, and subsequently fell. Bond yields were driven

irrationally low and prices irrationally high by irrational exuberance between 2002 and early 2007,

and the yields subsequently soared, the prices collapsed.

But while the former boom and bust in equity prices had surprisingly small consequences for the

real economy, the latter boom and bust is likely to have a much bigger one. And that contrast may

be inherent. It may well be that the world economy has greater ability to absorb without dire

consequences severe cases of irrational exuberance and then depression in equity prices, than in the

prices of a broad range of credit instruments, held to a significant extent on the trading books of

banks, shadow banks or near banks. Banks are highly leveraged: they perform maturity

transformation which exposes them to liquidity risk: and they are involved in a process of continual

rollover of new credit supply to the real economy without which economies will contract. Irrational

swings in the prices of credit securities held by banks, and thus in their capital resources, are

therefore likely to be far more economically significant than irrational swings in the prices of equity

investments held by end investors.

It is therefore possible that the growth of the securitised credits intermediation model has increased

some aspects of systemic risk in ways which are not just the result of poor execution – bad

remuneration practices, inadequate risk management or disclosure, failures in the credit-rating

process – but absolutely inherent.

But if that is true, it would be precisely the opposite of what many clever, hardworking and well-

meaning people believed about the securitised credit markets only two years ago. The IMF’s Global

Financial Stability Report of April 2006 stated that [Exhibit 13] ‘the dispersion of credit risk by

banks to a broader and more diverse set of investors, rather than warehousing such risk on their

balance sheets, has helped to make the banking and overall financial system more resilient’. It

noted that this dispersion would help to “mitigate and absorb shocks to the financial system” with

the result that “improved resilience may be seen in fewer bank failures and more consistent credit

provision”. And many other economists argued that in addition to increasing financial stability, the

development of securitised credit, structured credit, and of credit derivatives, by creating or

completing markets which had not previously existed, must have increased economic allocative

efficiency.

The core issue which we now need to face is whether in that analysis we significantly overstated the

allocative efficiency benefits which could possibly have arisen from this completion of markets,

even if they had operated rationally, and significantly underestimated the inherent dangers that any

liquid-traded market will at times be susceptible to irrational exuberance followed by irrational

despair.

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The growth of the financial sector: fundamental benign

effects, illusory profits and rent extraction.

My fourth and final observation about the growth of the securitised credit markets is that it is

striking that it has been accompanied by a quite remarkable growth in the relative size of wholesale

financial services within the overall economy. If, for instance, we look at debt as a percent of GDP –

an income measure of leverage – [Exhibit 15] we do indeed see a growth of household debt as a

percent of GDP, and to a smaller extent of corporate debt as a percent of GDP, but what is really

striking is the extent to which the debt of financial companies as a percent of GDP has grown, both

in the US and in the UK.

On a consolidated basis of course – i.e. stripping out claims between financial institutions –

financial sector assets and liabilities can only grow pari passu with non-financial sector liabilities

and assets. So what this disproportionate growth represents is an explosion of claims within the

financial system, between banks and investment banks and hedge funds – that multiplication of

balance sheets involved in the credit intermediation process which I suggested earlier has

accompanied the increasing complexity of securitization.

This huge growth of intra-financial system leverage has a relevance to the urgent issue of short-term

macro-economic management. The more that we can ensure that bank deleveraging takes the form

of the stripping out of inter-trader complexity, and the less it takes the form of leveraging vis-á-vis

the non-bank real economy, the better. But for this evening my focus is on why this growth has

occurred, why indeed many other measures of financial system importance – output as a percent of

total GDP, profits as a percent of total corporate profits, as financial sector market cap as a percent

of total equity market capitalisation [Exhibit 16], show a similar long-term trend, with a strong

acceleration in the last five years up to 2007.

For this growth appears to be at variance with one of the other arguments made for securitisation,

that it would be a more cost efficient system – delivering the service of credit intermediation to the

real economy at a lower total cost. So why has the wholesale financial services industry instead had

to grow so significantly?

Well, there are some underlying and entirely benign factors which do tend to increase the relative

importance of financial services (retail and wholesale combined) as incomes grow. The wealthier

people become, the more lifecycle consumption smoothing that occurs, and the more diverse they

become in their preferences for consumption at different points in their life cycle; as a result there is

a simultaneous increase in demand for both savings and borrowing products. And the more complex

and globalised the world economy becomes, the more complex are the functions which the world’s

banks have to perform in intermediating credit and other flows, and in themselves managing and

helping corporates manage, the risks that arise from global operations, and fluctuating exchange

rates, interest rates and commodity prices. In general, income per capita and financial sector value

added as a percent of GDP are somewhat correlated, across at least a range of income per capita

levels, for inherent and benign reasons.

But it is also possible that the importance of financial services as a percent of GDP has been

swollen by two other factors – one of which is illusory and short term, and the other harmful and

longer term.

• The illusory one arises from mark to market profits in a rising market. If the bank and near-

bank system in total holds a net long position in those assets which we mark to market –

which it does – and if irrational exuberance can push the price of those assets to irrationally

high levels (which I think it clearly did in the years running up to early 2007) then mark to

market accounting will swell declared profit in an unsustainable way, but in a way which,

reflected in bonuses, may reinforce management and traders’ determination to do more of

the clever stuff, which is delivering those profits.

• The possible long-term and harmful possibility is rent extraction. For there must be a

suspicion that some and perhaps much of the structuring and trading activity involved in the

complex version of securitised credit, was not required to deliver credit intermediation

efficiently, but achieved an economic rent extraction made possible by the opacity of

margins and the asymmetry of information and knowledge between end users of financial

services and producers. Simply put, wholesale financial services, and in particular that

element devoted to securitised credit intermediation and to the trading of securitised credit

instruments – grew to a size unjustified by the value of its service to the real economy, and is

now going through a downsizing, part of which is cyclical, but part a permanent one-off

adjustment to a more economically efficient size.

Now of course, if you are an extreme Chicago school economic liberal, what I have said cannot be

the case. If the industry grew dramatically in the decade to 2007 that must be because it was

performing value added services: if complex product innovations were able to sustain themselves

economically, they must have been socially useful innovations. But after what has happened, I think

we know that that is not the case. I think we know that imperfections and irrationality in financial

markets which are not fixable just by disclosure, but are inherent, mean that financial innovation

which delivers no fundamental economic benefit, can for a time flourish and earn for the individuals

and institutions which innovated, very large returns.

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Not all innovation is equally useful. If by some terrible accident the world lost the knowledge

required to manufacture one of our major drugs or vaccines, human welfare would be seriously

harmed. If the instructions for creating a CDO squared have now been mislaid, we will I think get

along quite well without. And in the years running up to 2007, too much of the developed world’s

intellectual talent was devoted to ever more complex financial innovations, whose maximum

possible benefit in terms of allocative efficiency was at best marginal, and which in their

complexity and opacity created large financial stability risks.





Implications and what to do next

So if that’s what happened, and some of the reasons why it happened, what are the implications for

the possible future shape of the financial system, and what are the implications for how we should

manage the future financial system?

One implication is that there is a very important macro element to the required response.

Major macro-economic imbalances – large surpluses and deficits – were an important underlying

driver of what occurred, and their more effective management is important not just to a more stable

global system in the long term, but to the challenge of limiting the severity of the immediate

economic downturn. The fundamental problem of potentially asymmetries between the policy

responses of deficit countries and surplus countries, which lay at the root of the mismanagement of

the gold standard in the 1920s and early 30s, and which Keynes warned of ahead of Bretton Woods,

remain a crucial issue today. Without more Chinese consumption to balance more Americans

saving, the deflationary impact of the crisis could be prolonged.

And looking to the long-term, as we think about what is needed to avoid future crises, it is clear that

better analysis of and response to macro-prudential problems – problems which lie at the interface

between macro-economic policy and financial system regulation – will be vital. The FSA has been

more open than I think any institution involved in this crisis in admitting that it made mistakes in

the institution specific supervision of northern rock. But I think the best judgement is that better

institution specific supervision of Northern Rock would have made only a very small difference to

the shape and impact of this global crisis.

The far bigger failure – shared by bankers, regulators, central banks, finance ministers and

academics across the world – was the failure to identify that the whole system was fraught with

market-wide, systemic risk. The key problem was not that the supervision of Northern Rock was

insufficient, but that we failed to piece together the jigsaw puzzle of a large UK current account

deficit, rapid credit extension and house price rises, the purchase of UK mortgage-backed securities

by institutions in the US performing a new form of maturity transformation, and the potential for

irrational exuberance in the market price of credit. We failed to realize that there was an increase in

total system risk to which financial regulators overall – authorities, central banks and fiscal

authorities – needed to respond.

Regulators were too focused on the institution-by-institution supervision of idiosyncratic risk:

central banks too focused on monetary policy tightly defined, meeting inflation targets. And reports

which did look at the overall picture, for instance the IMF Global Financial Stability Report which

I quoted earlier, sometimes simply got it wrong, and when they did get it right, for instance in their

warnings about over rapid credit growth in the UK and the US, were largely ignored.

In future, regulators need to do more sectoral analysis and be more willing to make judgements

about the sustainability of whole business models, not just the quality of their execution. Central

banks and regulators between them need to integrate macro-economic analysis with macro-

prudential analysis, and to identify the combination of measures which can take away the punch

bowl before the party gets out of hand. We also need to create deliberate mechanisms to increase the

likelihood that major analytical institutions such as the IMF challenge the conventional wisdom

rather than go along with it. And we need to ensure that when the IMF or other international

surveillance bodies do issue warnings, that big powerful countries, and not just weaker developing

countries potentially dependent on IMF support, feel that they have to respond.

Alongside that more effective macro-prudential analysis, however, we also need more effective

approaches to the regulations which govern the financial system. That regulation needs to be

designed in the light of how the system we are regulating is likely to evolve. Two questions can help

frame our thinking about the future: what is going to happen, and what should happen, to the

originate and distribute securitised credit model: and what will and should be the institutional

relationship between “narrow banking” – deposit taking, extending loans, and providing payment

services – and more complex treasury and trading activities?

On the originate and distribute, securitised credit model, I argued earlier that, especially if it

involved a substantial holding and trading of securitised credit instruments on the balance sheets of

banks involved in maturity transformation, it created significant and inherent risks. But it does not

follow that the originate and distribute model will now or should now largely disappear. Some of

the arguments which were advanced in favour of this model can be good ones: taking regionally or

sectorally concentrated credit risk off bank balance sheets and distributing it to diversified investors,

could be beneficial. Many forms of credit, for instance residential mortgages, are best credit

assessed via quantitative scoring techniques, rather than by individual bank officer judgement, and

can therefore be turned into securities, the risk of which can be well captured in credit ratings. And

while we are now facing a crisis of the securitised credit model, we must remember that the past has

had many examples of credit crises in good old fashioned on balance sheet banking – the British

secondary banking crisis of 1973 to 74, the US savings and loans debacle of the 1980s, the Japanese

and Swedish banking crises of the 1990s.

It is therefore, I believe, highly likely that the future system will and should involve a combination

of traditional on balance sheet credit intermediation and securitised intermediation, and that a

combination of better regulation and market response to the crisis, should and will produce a safer

version of the originate and distribute model – less complex, more transparent to end investors,

with less exclusive reliance on credit ratings and more independent judgement, and with less

packaging and trading of securitised credit through multiple balance sheets. The securitised

originate and distribute model will change significantly but it will still play an important role in

national and global credit intermediation.

Back to top

Narrow banking and investment banking. The somewhat related issue is then, should the different

functions of classic on balance sheet banking – deposit taking, loan extension, and payment services

provision – and more complex and risky investment banking activities be done in the same

institutions or in separate firms. The actual trend of the last year has clearly been for these functions

to be combined to a greater extent than before – as Bear Stearns has folded into JP Morgan, Merrill

Lynch into Bank of America, and part of Lehmans into Barclays, and as Morgan Stanley and

Goldman Sachs have become bank holding companies with access to the Fed discount window and

covered by the implicit assumption that the US government would consider them too important to

fail.

But even while this is been the de facto trend, several commentators have argued that regulation

should be designed to produce the precisely opposite result – a separation of “narrow banking” from

risky investment bank trading activities, a re-imposition in the US of the Glass Steagall separation

of commercial and investment banking, and the introduction of that separation for the first time into

European bank regulation.

At times this vision is expressed in terms close to a nostalgic elegy for a past age of innocence and

stability: with Captain Mainwaring back behind the desk in the branch at Walmington-on-Sea

casting a censorious eye over any householder or small-business man silly enough to want to take

on too much credit, while the wide boys of the City and Wall Street are free to speculate but well

away from sober middle England. But there is a very important issue here; we need to think

carefully about how to insulate the vital functions of deposit taking, maturity transformation, and

credit extension, from adverse impacts arising from the potential irrationality of liquid traded

markets; we need to control the extent to which large universal banks can take the benefits of stable

retail funding, deposit insurance and too big to fail status, and use them to fund activities of little

economic value and/or of high risk, such as unnecessarily large proprietary trading.

I am not convinced, however, that this can or should take the form of any absolute separation

between institutions which do to narrow banking and those which perform investment banking

activities. The desire for this distinction fails, I think, to reflect the fact that the originate and

distribute model can have some advantages, and the fact that in between narrow banking as

performed by say a building society, and pure proprietary trading performed by say a hedge fund,

there are a wide range of functions essential to the provision of finance to major corporates, to the

lubrication of global capital flows, and to the management of risk naturally arising in a world of

fluctuating exchange rates, interest rates and commodity prices, which mean that global banks

involved in deposit taking, and credit extension are also involved in complex treasury and market

making activities.

A crucial issue for regulators is therefore going to continue to be how we regulate the very large and

very complex systemically important banks which are too big to fail and which are involved both in

narrow banking and in complex treasury and trading activities. The Group of 30 Report Financial

Reform: A Framework for financial stability, published last Thursday, suggested that “large

systemically important banking institutions should be restricted in undertaking proprietary

activities that present particularly high risks”. The precise ways in which we achieve this end need

to be carefully considered, and the crucial change may be simply the better treatment of trading

book capital, which I will come to shortly: but the issue certainly needs to be addressed.

So let me turn finally to the key elements of the regulatory response required to reduce the

probability and severity of future financial crises, whether arising from classic on balance sheet

banking or from the securitized model of credit intermediation. The response needs to be

multifaceted, and there are many facets which I am not going to discuss tonight, but which will be

covered in the Review and Discussion Paper to be published in March. These include actions

relating to remuneration and incentives, to rating agencies, to counterparty risk in derivatives. They

also involve consideration of the appropriate balance between mark to market and accrual

accounting principles in published accounts. And, very importantly, we need to address issues

relating to the regulation of large cross-border financial institutions, the realistic scope for global

supervisory coordination, appropriate structures for local operations (subsidiaries or branches) and

the appropriate balance of responsibility between home and host supervisors; the events of the last

year – the Icelandic bank and Lehmans failures in particular – have taught us that we live in a

world of global finance and global banks, but where, when disaster strikes, bankruptcy procedures

and fiscal support are national, and we need to be clear about the implications of such a world.

But while all these issues are all important, there are three regulatory responses which I would like

to highlight as the most fundamental and where what we need to do is in principle now clear.

Back to top

New approaches to capital adequacy

The first is new approaches to the regulation of the capital adequacy of banks. These have of course

been extensively revised by the introduction of Basel 2, which has aimed to achieve greater

sensitivity of capital levels to the different risks which banks are running, and there are certainly

benefits to the Basel 2 approach on which the future system should build. It is important to realize

that the crisis developed under the Basel 1 regime not Basel 2, and that Basel 2 would have

addressed some of the problems which led to it – for instance the failure to distinguish between the

capital required to support mortgages of different credit quality. But it is also clear that we will

need to adjust Basel 2 in a number of ways. The general direction of travel will be towards higher

levels of bank capital than have been required in the past, and in particular capital which moves

more appropriately with the economic cycle and more capital required against trading books and

the taking of market risk.

• On the economic cycle, there has been considerable commentary on the procyclical nature

of Basel 2 risk-sensitive capital measures, and it is inevitable that any system which is risk

sensitive, unless deliberate countervailing adjustments are made, will be to a degree

procyclical i.e. capital requirements will rise as we head into a recession and credit quality

declines. But it is important to note that the degree to which Basel 2 is procyclical in relation

to the banking books – credit extension on balance sheet – depends crucially on how it is

implemented and can be significantly reduced if banks use appropriate through-the-cycle

approaches to estimation of probability of default and loss given default. It is therefore

important to ensure that the detailed implementation of Basel 2 does not introduce

unnecessary and unintended procyclicality, and the FSA on Monday issued a clarification of

our approach designed to ensure this.



Looking forward, however, we need to go beyond the avoidance of unnecessary

procyclicality and to create a system which introduces significant counter cyclicality,

requiring banks to build up substantial capital buffers in good economic times – ratios well

above absolute minimum levels – so that they can run them down in bad. Such an approach

makes sense from a micro-prudential point of view, reducing the risk of bank failure. But it

is also desirable from a macro-prudential and macro-economic perspective: it will tend to

place at least some restraint on over-rapid expansion in the boom, and it will reduce the

danger that impaired capital makes it more difficult for banks to lend in recessionary times,

thus making the recession worse. Ideally, such a regime must be agreed at international

level, and the FSA is working closely within the Basel Committee on Banking Supervision

and the Financial Stability Forum to design the details. There are many of those details to be

worked out; whether the buffer requirements will be defined in formulaic terms, as in the

Spanish dynamic provisioning system, or by regulator discretion; and how to deal with the

complexity of different economic cycles in the different countries in which a cross-border

bank may operate. But the principle is clear.

• And equally it is clear that in respect to the trading books of banks, we need to remove

procyclicality and to increase capital requirements not just marginally but by several times.

The present system of capital regulation of trading books is from a prudential point of view

seriously deficient. Its reliance on value at risk (VAR) measures derived (usually) from the

observation of the last year’s movements in market prices is clearly procyclical: if volatility

goes down in a year, the measure tells banks that risks looking forward have reduced, and

thus fails to allow for the fact that historically low volatility may actually be an indication of

irrationally low risk aversion and therefore increased systemic risk. It fails to allow

effectively for the low probability tail events which are crucial to extreme idiosyncratic and

even more so to overall systemic risk. And, overall, the level of capital required against

trading books has been simply too low relative to the risks being taken, given what we now

understand about the systemic dangers of relying on liquidity through marketability, and

about the susceptibility of securitised credit markets to irrational exuberance, sudden

liquidity disappearance and rapid price collapse. Major banks with a large percentage of

their balance sheets devoted to trading activity, have been required to hold only very thin

slices of capital against it [Exhibit 16]. That will change radically given the proposals

already issued by the Basel Committee, and these changes in themselves are likely to result

in a significant contraction in the scale of future trading books.



And, looking forward, the FSA believes that a fundamental review is required of how

trading books are defined and how risks in trading books are estimated. VAR-based

approaches were originally developed to model the risks in trading in markets likely to be

continually and deeply liquid (e.g. government securities, major currency FX swaps and

interest rates derivatives), and were adopted by regulators in the mid-1990s when a high

proportion of bank trading was concentrated in such highly liquid instruments. Over the last

decade and a half, however, trading books have expanded rapidly to encompass the holding

of many debt securities whose markets are imperfectly liquid even in normal times and

which became suddenly illiquid when the downturn occurred; this booking of potentially

illiquid assets in trading books was indeed in part driven by the lower capital charge there

incurred. The FSA will be proposing to the Basel Committee that a fundamental review of

the division between the trading and banking books and of the appropriate use of VAR to

measure risk is now required.

Back to top





New approaches to liquidity

New approaches to the management and regulation of liquidity are equally important. Indeed, we

need to ensure that the regulation of liquidity is recognised as being at least as important as capital

adequacy, a sense which was to a degree lost over the last several decades, with intense regulatory

focus and international debates on capital adequacy, but less focus on liquidity – no Basel 1 or Basel

2 for liquidity to match the equivalents for capital.

That lack of a defined international standard has reflected the extreme complexity of the liquidity

risk, which makes it difficult to achieve effective regulation through generally applicable

quantitative ratios equivalent to capital adequacy ratios. Many developed economies did in the past

require limits to defined ratios, such as loans to deposits; but it is less clear today that deposits are

inherently more sticky than other categories of funding in a world of internet retail deposits and

wholesale depositors (corporates, local authorities, charities, etc) with multiple options to redeploy

spare funds.3 And the emergence of the originate and distribute securitised credit model has been

accompanied by increasing options to manage liquidity through secured funding (e.g. repos), and an

increased reliance on liquidity through marketability, making bank liquidity risk assessment

crucially dependent on assumptions about the liquidity of specific asset and secured funding

markets, which it is difficult to reduce to simple quantitative rules.

Measuring and limiting liquidity risk is, however, crucial and reforms to regulation need to include

both far more effective ways for assessing and limiting the liquidity risks which individual

institutions face and a better understanding of market-wide liquidity risks. The FSA’s Consultation

Paper on Liquidity published in December, therefore proposes a major reform of our liquidity

supervision. It will put in place:

• Significantly enhanced reporting requirements focused on a detailed mismatch ladder

analysis and applicable to all banks and building societies.

• Regulations which will require all banks to focus on the combined liquidity effect of their

holdings of liquid assets, the maturity (on both a contractual and behavioural basis) of their

assets and liabilities, and the term, diversity and reliability of funding sources.

• For simpler mortgage banks and building societies this will be underpinned by a

quantitative “buffer ratio” rule, which will restrain reliance on wholesale funds.

• And for larger banks it will be achieved by a regime which requires the development

by each bank and review by supervisors of a detailed Individual Liquidity

Assessment, on the basis of which we will give Individual Liquidity Guidance,

including the required level of a liquid assets buffer, which will be defined on a

standardised basis but whose required level will be tailored to individual

circumstance.



At the core of the assessment and guidance will be stress-test scenarios, rather than

models which seek to infer the probability distribution of risks from the observation

of past fluctuations. This reflects the fact that liquidity risk assessment is inherently

concerned with low probability but extreme events. And crucially the stress tests

will need to cover potential market-wide stresses as well as idiosyncratic stresses,

reflecting the lesson of the financial crisis that market-wide collapses in the liquidity

of specific asset or funding markets can have huge impacts which analysis of

individual specific risks will not capture.

This new regime and the related reporting requirements will greatly enhance our ability to

understand emerging liquidity risks in individual institutions and across the whole economy, and to

conduct sectoral analysis which can identify outlier business models and management practices.

On the basis of this increased understanding, we will keep under review the appropriate balance of

quantitative rules, stress test based analyses, and discretionary guidance. We anticipate that the new

regime will result in major changes in the extent and nature of maturity transformation in the

overall banking system, with banks holding more liquid assets and a greater proportion of those

assets held in government securities, an incentive for banks to encourage more retail time deposits

and less instant access, less reliance on short-term wholesale funding, and, as a result, a check on

rapid and unsustainable expansion of bank lending during favourable economic times.

Back to top





Regulation by economics substance: shadow banks and

near banks

The third key priority is to ensure that in future financial activities are always regulated according to

their economic substance not their legal form. One of the striking features of the years running up to

the crisis, as I stressed earlier, was that a core banking function – maturity transformation – was

increasingly being performed by institutions which were not legally banks, but the off balance

sheet vehicles of banks, (SIVs and conduits), investment banks and mutual funds. To different

degrees in different countries these ‘near banks’ or shadow banks escaped the capital, leverage and

liquidity regulation which would apply to banks. In the case of SIVs they also escaped the degree of

disclosure and accounting treatment which would have applied if the economic activities were

performed on balance sheet. In future it is essential that if an economic activity is bank-like and

poses a significant risk to consumer or financial stability, regulators can extend banking-style

regulation. And essential that accounting treatment reflects the economic reality of risks being

taken.

Applying these principles will have more implications for legal powers and regulatory structures in

some other countries – and in particular in the US – than in the UK. European approaches to the

bank capital adequacy have always applied to investment banks: the requirements set down for

trading book capital were in retrospect inadequate, but in Europe investment banks did not lie

outside a regulatory boundary. In the US, with a fragmented regulatory structure, there is a greater

need to look at structures and powers. But, across the world, regulators need to continually assess

how evolving industry structures and institutional roles are changing the nature of risk, both for

individual institutions and for the whole system, and if necessary to adapt the coverage of

prudential regulation over time.

This will at times require judgements about the appropriate treatment of institutions which have

some of the risk characteristics of banks but not others. Two examples:

• The first is mutual funds taking consumer investments which are liquid in nature (immediate

or very short redemption) and investing in long-term securities. These are not banks, the

crucial distinction being that the liquidity of the promise to savers is not matched by

certainty of capital value at redemption. But if they have made assurances that they will

maintain a stable net asset value, that they will not “break the buck”, they may in a liquidity

crisis act in a fashion which exacerbates that crisis, selling rapidly to meet redemptions and

fuelling the deflationary cycle. That is why the G30 report recommends that “money market

funds which want to continue to offer bank-like services… and assurances” should be

reorganised as special purpose banks and regulated as such. This is a pressing issue for the

US but not the UK: for a variety of reasons mutual funds of this character have not

developed here. But if they ever did develop in future, we would need to keep under review

at what point bank-like characteristics justify bank like regulation.

• The second is hedge funds, whose asset managers are present in the UK, and who are

regulated as asset managers by the FSA, though the actual legal fund is usually registered

offshore and not subject to prudential regulation. Here the issue, now being considered by

fora such as the Financial Stability Forum, is whether the funds themselves should be

regulated and subject to prudential limits on leverage or liquidity. The argument against is

that these institutions are not banks: they do not deal directly with the general population but

with professional sophisticated investors; leverage levels are in general (though with some

exceptions) far lower than those of banks (typically two or three not twenty); and they do

not perform contractual maturity transformation, since they have the power to limit the

speed of redemptions via redemption gates. In general (again with some possible exceptions)

they neither have the scale nor the characteristics which would require that individual hedge

funds be treated as systemically important and thus too big to fail. But in aggregate, they

may nevertheless play a role with systemic effects which regulators and central banks need

to understand, but which currently we lack the data to analyse effectively. Rapid

deleveraging by hedge funds has probably over the last six months played a non-trivial role

in exacerbating financial instability. It is for these reasons that the G30 report suggested that

regulators should have the power to gather detailed information from hedge funds, so that

we and central banks are better able to judge their evolving systemic importance: and

recommended that “for funds above the size judged to be potentially systemically

significant, the prudential regulator should have the authority to establish appropriate

standards for capital, liquidity and risk management”. That halfway house on hedge funds –

information and the power to respond to future developments in size, concentration,

leverage levels, and practices – would be in line with the principle of focusing on economic

substance not legal form.





Conclusion

To conclude, let me return to my opening thought. We are in the middle of an economic downturn

which, to a far greater extent than any since the 1930s, is the result of developments which were to

a degree internal to the global financial system. Developments in the banking and the near-bank

system, which had been lauded as improving allocative efficiency and financial stability, have in

fact caused serious harm to the real economy. The changes which we need to make to create a

sounder system for the future will be profound. Their guiding principle should be that they should

create a banking system focused on the delivery of the value-added functions of banking which are

so essential to a market economy.

1 Even the banks which were largely doing “originate and distribute” would often however have to

warehouse significant quantities on balance sheet before packaging and distributing, and could be

left with liquidity strains and future potential losses if liquidity suddenly dried up (e.g. Northern

Rock)

2This assumption seems also at time to have been based on a misunderstanding of the inference that

could be drawn from a credit rating, with high ratings treated as carrying the inference of liquidity,

rather than simply lower credit default.

3Loan to deposit ratios limits continue however to be used in some emerging economies. A number

of emerging economies e.g. India, also continue to use reserve asset ratios as monetary policy

instruments, with significantly liquid balance sheets a resulting byproduct.



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