Macro-Prudential Regulation by maclaren1


									NOTE NUMBER 6

                                                                                                                                                           PUBLIC POLICY FOR THE PRIVATE SECTOR
JULY 2009

                                                                                        Macro-Prudential Regulation

                                                           Avinash Persaud              Fixing Fundamental Market (and Regulatory) Failures
                                                           Avinash Persaud              This is not the fir s t int e r na t io na l b a nk ing c r is is t he wo r ld h a s s e e n .
                                                  is chairman
                                                                                        The p re vious on e s o c c ur r e d wit ho ut c r e d it d e f a ult s wa p s , s pe c i a l
                                                           of Intelligence Capital      investme nt ve hi c le s , o r e v e n c r e d it r a t ing s . I f c r is e s k e e p r e p e a t i n g
                                                           Limited and emeritus
                                                                                        the mselve s, it s e e m s r e a s o na b le t o a r g ue t ha t p o lic y m a k e r s n e e d t o
                                                           professor at Gresham
                                                           College in London.           caref ully consid e r wha t t he y a r e d o ing a nd no t jus t “ d o ub le u p ” b y
                                                                                        sup e rf icially re a c t ing t o t he s p e c if ic f e a t ur e s o f t o d a y ’ s c r is i s . W h i l e
                                                           This is the sixth in a
                                                           series of policy briefs on   we cannot hop e t o p r e v e nt c r is e s , we c a n p e r ha p s m a k e t he m f e w e r
                                                           the crisis—assessing the     and mild er b y a d o p t ing a nd im p le m e nt ing b e t t e r r e g ula t io n — i n
                                                           policy responses, shedding
                                                           light on financial reforms
                                                                                        p articular, more m a c r o - p r ud e nt ia l r e g ula t io n.
                                                           currently under debate,
                                                                                        There is a widely held view that the current finan-       85th.1 If crises keep repeating themselves, it seems
                                                           and providing insights
                                                                                        cial crisis resulted from an insufficient reach of        reasonable to argue that policy makers need to
                                                           for emerging-market policy
                                                                                        regulation and that the solution is to take existing      carefully consider what they are doing and not
                                                                                        regulation and spread it without gaps across insti-       just “double up.” It also means that policy makers
                                                                                        tutions and jurisdictions. If this were to be the         should not superficially react to the characters
                                                                                        main policy response, it would be a mistake for           and colors of the current crisis. The last 84 crises
                                                                                        several reasons. The most important one is that           occurred without credit default swaps and special
                                                                                        at the heart of the crisis lay highly regulated insti-    investment vehicles. The last 80-something had
                                                                                        tutions in sophisticated jurisdictions—Northern           nothing to do with credit ratings. The solution

                                                                                        Rock, IKB, Fortis, Royal Bank of Scotland, UBS,           to the crisis is not more regulation, though more
                                                                                        Citigroup. If there were no mortgage fraud, no            comprehensive regulation may be required in
                                                                                        tax secrecy, and no conflicts of interest, a crisis       some areas. Instead, it is better regulation—in
                                                                                        would still have occurred. And while risk did shift       particular, regulation with a greater macro-
                                                                                        outside the capital adequacy regime, the special          prudential orientation, as recommended by
                                                                                        investment vehicles were not secret and supervi-          numerous recent official reports.2
                                                                                        sors had the discretion to look at how regulated
                                                                                        institutions were managing risks and to respond           What is macro-prudential regulation?
                                                                                        if necessary.                                             It seems banal today to point out that the reason
                                                                                            This is not the first international banking crisis    we try to prevent financial crises is that the costs to
                                                                                        the world has seen. By some estimates it is the           society are invariably enormous and exceed the

                         private cost to individual financial institutions.       degree of leverage, and interconnectedness with
                         We regulate to internalize these externalities in        the rest of the system.
                         the behavior of such institutions. One of the main          The existing framework of banking regulation
                         tools regulators use to do this is capital adequacy      was insufficiently macro-prudential and had been
                         requirements. But the current approach to capi-          recognized as such by commentators for some
                         tal adequacy is too narrow. Capital adequacy lev-        time (see Borio 2005; Borio and White 2004; and
                         els are set on the implicit assumption that we can       Persaud 2000). Moreover, the emphasis on micro-
                         make the system as a whole safe by ensuring that         prudential regulation may have contributed to
                         individual banks are safe. This represents a fal-        the buildup of some macro risks.
                         lacy of composition. In trying to make themselves           Through many avenues, some regulatory
                         safer, banks and other highly leveraged financial        and some not, often in the name of prudence,
                         intermediaries can behave in ways that collec-           transparency, and sensitivity to risk, the growing
                         tively undermine the system. This is in essence          influence of current market prices has intensi-
                         what differentiates macro-prudential from micro-         fied homogeneous behavior in financial systems.
                         prudential concerns.                                     These avenues include mark-to-market valuation
                             Here is an example of macro-prudential               of assets; regulator-mandated market-based mea-
                         concerns. Selling an asset when it appears to be         sures of risk, such as the use of credit spreads
                         risky may be considered a prudent response for           in internal credit models or price volatility in
                         an individual bank and is supported by much              market risk models; and the increasing use of
                         current regulation. But if many banks do this,           credit ratings, where the signals are slower mov-
                         the asset price will collapse, forcing risk-averse       ing but positively correlated with financial mar-
                         institutions to sell more and leading to general         kets. Where measured risk is based on market
                         declines in asset prices, higher correlations and        prices, or on variables correlated with market
                         volatility across markets, spiraling losses, and         prices, it can contribute to systemic risk as market
                         collapsing liquidity. Micro-prudential behavior          participants herd into areas that appear to be
                         can cause or worsen systemic risks. A macro-             safe.3 And measured risk can be highly procycli-
                         prudential approach to an increase in risk is to         cal, because it falls in the buildup to booms and
                         consider systemic behavior in the management             rises in volatile busts.
                         of that risk: who should hold it, and do they have
                         the incentive to do so? If it is liquidity risk, is it   Macro-prudential regulation and the cycle
                         in the interests of the system if all institutions,      The economic cycle is a major source of homo-
                         regardless of their liquidity conditions, sell the       geneous behavior, so addressing it is a critical
                         same asset at the same time? Risk in a financial         macro-prudential concern. In the up phase of
                         system is more than an aggregation of risks in           the cycle, price-based measures of asset values
                         individual institutions; it is also about endog-         rise, price-based measures of risk fall, and com-
                         enous risks that arise as a result of the collective     petition to increase bank profits grows. Most
                         behavior of institutions.                                financial institutions spontaneously respond by
                             Macro-prudential regulation concerns itself          expanding their balance sheets to take advan-
                         with the stability of the financial system as a whole.   tage of the fixed costs of banking franchises and
                         By contrast, micro-prudential regulation, con-           regulation; trying to lower the cost of funding by
                         sisting of such measures as the certification of         using short-term funding from money markets;
                         those working in the financial sector and rules          and increasing leverage. Those that do not do so
                         on how financial institutions operate, concerns          are seen as underleveraging their equity and are
                         itself with the stability of individual entities and     punished by stock markets. In the more prosaic
                         the protection of individuals. Micro-prudential          words of former Citigroup CEO Chuck Prince,
                         regulation examines the responses of an indi-            in a July 2007 interview with the Financial Times,
                         vidual bank to exogenous risks. By construction,         “when the music is playing, you have to get up
                         it does not incorporate endogenous risk. It also         and dance.” By contrast, when the boom ends,
                         ignores the systemic importance of individual            asset prices begin to fall and short-term fund-
                         institutions resulting from such factors as size,        ing to institutions with impaired and uncertain
assets or high leverage dries up. Forced sales of      Politicians want to reap electoral benefit from
assets drive up their measured risk, and the boom      the sense of well-being and prosperity during
inevitably turns to bust.                              a boom. Policy officials convince themselves,
    One of the key lessons of this crisis is that      and try to convince others, that the boom is not
market discipline is little defense against the        an unsustainable credit binge but the positive
macro-prudential risks that come with the eco-         result of structural reforms that they have put
nomic cycle. The institutions that have been           into place. Booms have social benefits. They are
most resilient to the crisis, such as HSBC and         associated with a higher appetite for risk and a
J.P. Morgan, had lower equity “ratings” (lower         perception that risks have fallen, and this often
price-earnings ratios) than those that proved to       means greater access to finance for the previ-
be less resilient, such as Northern Rock, Bear         ously unbanked and underinsured. Booms are
Stearns, Fortis, and Lehman Brothers. Market           not quite a conspiracy of silence, but there are
discipline has an important role to play in the        few who gain from their early demise. So booms
efficiency of the financial sector, but it cannot be   tend to be explained away, excused, and accom-
on the front line of defense against crises.           modated, allowing them to grow larger and larger
    One reason that market discipline was seen as      and thus to cause more damage when they even-
such an important pillar in the precrisis approach     tually collapse.
to banking regulation was the implicit model that
regulators had in mind: financial crashes occur        Countercyclical charges and buffers
randomly as a result of a bad institution failing,     In light of the observations above, there is a grow-
and that failure becomes systemic. The histori-        ing consensus around three ideas: Capital require-
cal experience is rather different: crashes follow     ments need to have a countercyclical element in
booms. In the boom almost all financial institu-       order to, in the words of the G-20 communiqué
tions look good, and in the bust almost all look       of April 2, “dampen rather than amplify the finan-
bad. Differentiation is poor. The current crisis       cial and economic cycle” by “requiring buffers of
is another instance of this all-too-familiar cycle.    resources to be built up in good times.” There
But if crises repeat themselves and follow booms,      should be greater emphasis on rules rather than
banning the products, players, and jurisdictions       supervisory discretion to counterbalance the politi-
that were merely the symptoms of the latest boom       cal pressures on supervisors. And these rules should
will do little to prevent the next one.                include leverage limits and liquidity buffers.
    Moreover, the notion that some financial               The references in the G-20 communiqué echo
products are safe and some are not, and that           a statement by the Basel Committee on Banking
the use of unsafe products is the problem, also        Supervision following its March 2009 meeting,
looks suspect in a boom-bust world. The booms          recommending the “introduction of standards to
are often a result of things appearing to be safer     promote the buildup of capital buffers that can be
than they are. Securitization was viewed as a way      drawn down in periods of stress.” These statements
of making banks safer. Diversified portfolios of       by the G-20 and the Basel Committee, coupled with
subprime mortgages were viewed as having low           similar conclusions by other official reports, sug-
delinquency rates. Micro-prudential regulation         gest that the argument in favor of macro-prudential
is necessary to weed out the truly reckless insti-     regulation has been won. But how countercycli-
tutions and behavior. But it needs to be supple-       cal capital charges and liquidity buffers are to be
mented with macro-prudential regulation aimed          implemented has not yet been addressed in great
in part at acting as a countervailing force against    detail. Given the politics of booms, the how is almost
the decline of measured risk in a boom (and thus       as important as the whether.
excessive levels and interconnectivity of risk tak-        In practical terms, Goodhart and Persaud
ing) and against the rise of measured risk in the      have recommended that regulators increase the
subsequent collapse.                                   existing or base capital adequacy requirements
    Supervisors have plenty of discretion, but         (based on an assessment of inherent risks) by two
they find it hard to use because of the politics       multiples calculated using a few simple, transpar-
of booms. Almost everyone wants a boom to last.        ent rules.4

                             The first multiple would be a function of the       which increases systemic fragility and intercon-
                         growth of credit and leverage. Regulators should        nectedness. This private incentive to create sys-
                         meet with monetary policy officials (where they         temic risk can be offset through new capital or
                         are separate) in a financial stability committee.       reserve requirements. It is partly this notion that
                         This meeting would produce a forecast of the            the G-20 communiqué refers to when stating that
                         growth of aggregate bank assets that is consis-         the G-20 leaders have agreed to introduce mea-
                         tent with the central bank’s target for inflation       sures “to reduce the reliance on inappropriately
                         (or other macroeconomic nominal target). The            risky sources of funding.” Liquidity buffers, with
                         forecast would have a reasonable band around            their size related to maturity mismatches between
                         it reflecting uncertainty. If a bank’s assets grow      assets and liabilities, would have similar effect.
                         above this band, the bank would have to put aside       But once again there is little discussion of meth-
                         a higher multiple of its capital for this new lend-     odology and implementation. Measuring the true
                         ing. If its assets grow less than the lower bound,      maturity of bank assets and liabilities is not a
                         it may put aside a lower multiple.                      straightforward exercise.
                             For example, suppose that the financial stabil-         In the framework set out in the Geneva Report
                         ity committee concluded that growth in aggre-           (Brunnermeier and others 2009), assets that can-
                         gate bank assets of between 7.5 percent and 12.5        not be posted at the central bank for liquidity
                         percent was consistent with its inflation target of 3   can be assumed to have a minimum maturity
                         percent. Growth in a bank’s assets by 25 percent,       of two years or more. If a pool of these assets
                         or twice the upper range, may lead to a doubling        was funded by a pool of two-year term deposits,
                         of the minimum capital adequacy level from 8            there would be no liquidity risk and no liquidity
                         percent to 16 percent of risk-weighted assets. A        charge. But if the pool of funding had a maturity
                         related approach is to have one minimum capital         of one month and so had to be rolled over every
                         adequacy requirement for “bad” times and one            month, the liquidity multiple on the base capital
                         that is twice that level for “good” times, with good    charge would be near its maximum—say 2, so the
                         and bad times being determined by bank prof-            minimum capital adequacy requirement would
                         itability. Of course it is impossible to ascertain      rise from 8 percent to 16 percent.
                         whether these capital levels would have made                In a boom in which the first countercycli-
                         the system safe, but the consensus today is that        cal multiple is also 2, the final capital adequacy
                         they would have at least made it safer.                 requirement would be 32 percent of risk-weighted
                             Financial stability committees exist in many        assets (8 percent 2 2). Liquidity multiples
                         countries. But they generally work poorly because       would make lending costlier, since banks tradi-
                         their deliberations have no consequence.                tionally fund themselves short and lend long.
                         Requiring such committees to agree on a sus-            But the liquidity multiples would give banks an
                         tainable level of growth in bank assets could           incentive to find longer-term funding, and where
                         make their work more penetrating and action             they cannot do so, a liquidity buffer or liquidity
                         oriented.                                               reserve that could be drawn down in times of
                             The second multiple on capital requirements         stress would buy time for institutions to deal with
                         would be related to the mismatch in the matu-           a liquidity problem.
                         rity of bank assets and liabilities. One significant
                         lesson of the crisis is that the risk of an asset is    Can the cycle be measured?
                         determined largely by the maturity of its funding.      Many people, most notably former U.S. Federal
                         Northern Rock and other casualties of the crash         Reserve Chairman Alan Greenspan, voice the
                         might well have survived with the same assets if        concern that it is very hard to know when we
                         the average maturity of their funding had been          are in a boom. Of course, measuring the cycle
                         longer. The liquidity of banks’ assets has fallen far   is what inflation-targeting central banks do on
                         more than the credit quality of those assets.           a daily basis. But this misses the point a little. If
                             If regulators make little distinction on how        the purpose of countercyclical capital charges
                         assets are funded, however, financial institu-          were to end boom-bust cycles, we would need
                         tions will rely on cheaper, short-term funding,         to be more confident about the calibration of
booms than we are today. But if the purpose is          were still performing from a credit point of view,
to lean against the wind, our calibrations can be       but had become highly illiquid, had long-term
less precise.                                           funding. In the absence of fair-value accounting
    Recall that without countercyclical charges,        standards, they would not have joined the selling
the natural inclination in a boom is to lend even       frenzy that compounded the crisis. Second, with-
more because measured risks fall. The precrisis         out the mark-to-market volatility, institutions with
regulatory approach took the economic cycle             long-term funding would have been more willing
and amplified it. The goal instead should be to         to buy these assets. That would have provided
moderate the worst excesses of the cycle, not to        greater price support, limiting the spiral of losses
kill it. Indeed, the cycle is an important source       that endangered so many banking institutions.
of creative destruction in our economic system.
Valuation and mark-to-funding accounting                In the G-20 communiqué and elsewhere, great
Many commentators consider accounting issues            attention is given to dealing with the incentives
to be central in the crisis. They argue that the use    of individual bankers and traders. But there are
of fair-value accounting has added to the spiral        clear limits to how much governments should
of sales. But suspending fair-value accounting is       be involved in private firms’ decisions on execu-
not helpful in an environment made worse by             tive pay. While measures to lengthen bankers’
uncertainty. Instead, financial institutions should     horizons are necessary, greater hopes should be
complement mark-to-market accounting with               placed in macro-prudential regulation pushing
mark-to-funding valuations (see Brunnermeier            banks to develop incentive packages that better
and others 2009).                                       promote through-the-cycle behavior. If that failed,
    Under mark-to-funding valuations there are          however, regulators should certainly do more to
essentially two alternative prices for an asset:        address the important issue of incentives.
today’s market price and the discounted present
value of the future earnings stream. In normal          Macro-prudential regulation beyond the cycle
times these two prices are nearly the same. But         The other dimension of macro-prudential regu-
in a liquidity crisis the market price falls substan-   lation is the cross-sectional one: how to manage
tially below the present value. If an institution       the buildup of risks arising from the structure of
has short-term funding, the realistic price to use      the financial system.
is the market price. If it has long-term funding,
the present-value price is a better measure of the      Risk assignment
risks faced by the institution. Under a mark-to-        Requiring the banking system to hold more capi-
funding accounting framework, a weighted aver-          tal on average will not improve the resilience of
age of the market price and present-value price         the financial system as a whole unless there is
would be used whose weights would depend on             also a better match of risk taking to risk capac-
the weighted average maturity of the institution’s      ity. Indeed, piling up capital requirements may
funding. The combination of liquidity charges           act as an anticompetitive barrier, reinforcing the
and mark-to-funding value accounting would cre-         specter of a few banks holding a government
ate incentives for institutions to seek longer-term     hostage because they are too big to fail.
funding and would encourage a tendency for                  Micro-prudential regulation was often accom-
illiquid assets to be owned by institutions with        panied by a misguided view of risk as an absolute,
longer-term funding.                                    constant property of an asset that can be mea-
    At first sight, mark-to-funding would not           sured, sliced, diced, and transferred. This is an
appear to alleviate the problem facing banks            elegant view of risk and has the merit of allowing
today—in fact, it could make matters worse—             banks to build highly complex valuation mod-
because they have short-term funding. But this          els and to sell highly complex risk management
proposal would have had two ameliorating effects        products to handle and distribute risk. But it is
in the crisis. First, many of the bank-owned spe-       also an artificial construct that has little bearing
cial investment vehicles that managed assets that       on the nature of risk.

                             In reality, there is not one constant risk. The       rent system, the natural risk absorbers behave like
                         three broad financial risks—credit risk, liquid-          risk traders, selling and buying when everyone
                         ity risk, and market risk—are very different.             else is doing so.
                         Moreover, the potential spillover risk from some-            Capital requirements encouraging those with
                         one holding an asset depends as much on who is            a capacity to absorb a type of risk to hold that
                         holding the asset as on what it is. Different hold-       risk not only will make the system safer without
                         ers have different capacities for different risks.        destroying the risk taking that is vital for eco-
                         The distinction between “safe” and “risky” assets         nomic prosperity; they also will introduce new
                         is deceptive: one can do a lot of damage with a           players with risk capacities. This would both
                         simple mortgage, for example.                             strengthen the resilience of the financial system
                             The capacity for holding a risk is best assessed      and reduce our dependence in a crisis on a few
                         by considering how that risk is hedged. Liquidity         banks that appeared to be well capitalized during
                         risk—the risk that an immediate sale would lead           the previous boom.
                         to a large discount in the price—is best hedged
                         over time and is best held by institutions that do        Systemic institutions
                         not need to respond to an immediate fall in price.        Not all financial institutions pose systemic risks.
                         A bank funded with short-term money market                Regulation should acknowledge that some banks
                         deposits has little capacity for liquidity risk. Credit   are systemically important, and others less so.
                         risk—the risk that someone holding a loan will            In each country supervisors establish a list of
                         default—is not hedged by having more time for             systemically important institutions that receive
                         the default to happen but by having offsetting            closer scrutiny and require greater containment
                         credit risks. Banks, with access to a wide range          of behavior. Critical factors that determine sys-
                         of credits, have a far greater capacity than most         temic importance for an institution, instrument,
                         to diversify and hedge credit risks.                      or trade are size of exposures, especially with
                             The way to reduce systemic risk is to encourage       respect to the core banking system and retail
                         individual risks to flow to where there is a capacity     consumers; degree of leverage and maturity
                         for them. Unintentionally, much micro-prudential          mismatches; and correlation or interconnectiv-
                         regulation did the opposite. By not requiring firms       ity with the financial system.
                         to put aside capital for maturity mismatches and by           In the past, interconnectivity has been under-
                         encouraging mark-to-market valuation and daily            stood to include issues such as payment and set-
                         risk management of assets by everyone, regulators         tlement systems, and these remain vital. Today,
                         encouraged liquidity risk to flow to banks even           interconnectivity may also include institutions
                         though they had little capacity for it. By requiring      that behave in a highly correlated manner even
                         banks to hold capital against credit risks, regula-       if individually they appear small relative to the
                         tors encouraged credit risk to flow to those that         size of the financial system.
                         were seeking the extra yield, were not required to            Goodhart and Persaud, as members of the
                         set aside capital for credit risks, and had limited       UN Commission of Experts on Reforms of the
                         capacity to hedge that risk. No reasonable amount         International Monetary and Financial System,
                         of capital can remedy a system that inadvertently         have urged the commission to recommend
                         leads to risk-bearing assets being held by those          establishing a list of systemically important instru-
                         without a capacity to hold them.                          ments. And where instruments are declared sys-
                             What can regulators do? They need to differ-          temically important because of their volume,
                         entiate institutions less by what they are called         link to leverage, or interconnectivity, they rec-
                         and more by how they are funded. They should              ommend requiring that the instruments be reg-
                         require more capital to be set aside for risks where      istered and, where appropriate, exchange traded
                         there is no natural hedging capacity. This will           and centrally cleared.
                         draw risks to where they can be best absorbed.
                         They also must work to make value accounting              Host and home country regulation
                         and risk management techniques sensitive to               A gathering view is that financial institutions are
                         funding and risk capacity. Instead, under the cur-        global and so financial regulation needs to be
global. But reality does not rhyme so easily. The      for individual institutions to lend more. Micro-
crisis would not have been averted by more inter-      prudential regulation is not enough; it must be
national meetings, and it has taught us that there     supplemented by macro-prudential regulation
is much that needs to be done at the national level    that catches the systemic consequences of all
to strengthen regulation. Countercyclical and          institutions acting in a similar manner. While we
liquidity charges cannot be set or implemented         cannot hope to prevent crises, we can perhaps
globally but need to be handled nationally in          make them fewer and milder by adopting and
accordance with national cycles.                       implementing better regulation—in particular,
    Although there is a clear need for cross-          more macro-prudential regulation.
border sharing of information and coordination of
regulatory actions and principles (particularly in
micro-prudential regulation), the setting of capital
rules and banking supervision is likely to switch      Notes
back from “home country” to “host country.” This       The author would like to thank Constantinos Stepha-
should not be resisted because it would have two       nou, Aquiles Almansi, and Damodaran Krishnamurti
additional benefits, particularly for emerging         for their comments, although the views expressed in
economies. First, if foreign banks were required to    this policy brief remain those of the author.
set up their local presence as independent subsid-     1. For a discussion on the history of financial crises, see
iaries that could withstand the default of an inter-   Reinhart and Rogoff (2008).
national parent, it would reduce exposure to lax       2. These include the April 2 communiqué of the G-20
jurisdictions more effectively than trying to force    leaders, the Turner Review (FSA 2009), the G-30 report
everyone to follow a standard that could be inap-      (2009), the de Larosiere Group report (2009), the UN
propriate and would in any case be enforced with       Commission of Experts recommendations (2009), and
different degrees of intensity. Second, nationally     the 11th Geneva Report (Brunnermeier and others
set countercyclical charges could give common-         2009).
currency areas or countries with fixed or managed      3. See Persaud (2000) for a discussion on how, through
exchange rates a much-needed additional policy         the financial sector’s use of value-at-risk models, “the
instrument—one that could provide a more dif-          observation of safety creates risk and the observation of
ferentiated response than a single interest rate       risk creates safety.” The late economist Hyman Minsky
could to a boom in one member state and defla-         also argued in more general terms, and long before
tion in another. This policy instrument may also       the advent of value-at-risk models, that risks are born in
be important in emerging economies, where, per-        periods of stability.
haps as a result of the absence of developed bond      4. The original ideas were published in Goodhart and
and currency markets, interest rates are not an        Persaud (2008a, b) and expanded in Brunnermeier and
effective regulator of the economic cycle.             others (2009).

Conclusion                                             References
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   tional Bureau of Economic Research.                                                    The World Bank,
UN Commission of Experts on Reforms of the Interna-                                       1818 H Street, NW,
   tional Monetary and Financial System. 2009. Recom-                                     Washington, DC 20433.
   mendations. New York: United Nations.
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