micro and macro prudential perspectives of financial stability mario bergara managing the capital...
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Micro and Macro Prudential Micro and Macro Prudential Perspectives of Financial StabilityPerspectives of Financial Stability
Mario Bergara
Managing the Capital Account and Regulating the Financial Sector: A Developing Country Perspective
UNDESA – IPD - IPEA, Rio de Janeiro, August 23, 2011
The relevance of Financial Stability in a contextof Macroeconomic Stability
Price StabilityPrice StabilitySound financial systemSound financial systemWell-functioning payment systemWell-functioning payment system
They contribute to generate credibility and long term perspective, allowing a better decision-making on savings, credit and investments. A healthy financial sector channels those decisions more efficiently.
A proper Financial Safety Net reduces the system’s vulnerability.
They complement social policies, by protecting the poor: lower income population has less ability to fight the effects of high inflation and financial crisis.
Micro and macro prudential Micro and macro prudential perspectives of Financial Stabilityperspectives of Financial Stability
The importance of economic and financial stability
No experiences showing economic and social development in contexts of macroeconomic and financial disorder.
The largest declines in production and the largest rises in poverty are linked to bank runs and macroeconomic crises.
Disconsidering price and financial stability is disconsidering their impacts on:
ProductionEmploymentIncome of householdsPovertyInequalityConsolidation of proper values in society
Micro and macro prudential Micro and macro prudential perspectives of Financial Stabilityperspectives of Financial Stability
The need for consistency among macroeconomic policies
FinancialStability
Micro and Macroprudencial Regulation
Monetary policyFiscal Policy
Identifying relevant systemic risks and addressing externalitiesMonetary and fiscal policies can help to mitigate costs of aggregate weaknesses and individual failuresThe ability to use monetary policy is limited in countries facing short term currency appreciation pressures
Micro and macro prudential Micro and macro prudential perspectives of Financial Stabilityperspectives of Financial Stability
Some lessons from the financial crisis:What are we discussing?
Current discussion influenced by the situation in developed countries
The lack of a macro-systemic approach was clear, but was the microprudential regulation working properly?
Failure of the regulatory approach and of the organizational design of financial regulation
The decentralized governance failed as well as the “light supervision” approach
The focus on the macroprudential issue will be fruitful only if it does not imply that the microprudential regulation was doing its job
Micro and macro prudential Micro and macro prudential perspectives of Financial Stabilityperspectives of Financial Stability
Some lessons from the financial crisis:What are we discussing?
A possible (dangerous) lesson from the crisis: “Everything was right except that the macroprudential approach was lacking”
Supervision was poor and the organization of the Financial Safety Net was inaccurate in some places and chaotic in others
From Financial Safety to Financial Stability: both micro and macro prudential perspectives are essential
Regulation should be determined by the assessment of risks, avoiding arbitrage incentives
Risks include those derived from externalities: micro and macro-systemic risks have to be taken into consideration
Micro and macro prudential Micro and macro prudential perspectives of Financial Stabilityperspectives of Financial Stability
Some lessons from the financial crisis:What are we discussing?
The discussion about the governance of macroprudential policies might be “smuggling” a more transparent debate about the failure of the decentralized regulatory approach and the need to move towards a more centralized fashion
This process might be determined by political economy considerations, but it is relevant to pose the right questions on the table
Governance implications could be wrong if we think that the only problem is to “add” the macro perspective
In order to revise that, we need to get back to the conceptual determinants of the optimal Financial Safety/Stability Net: conflict of objectives, incentive structures and organizational design
Micro and macro prudential Micro and macro prudential perspectives of Financial Stabilityperspectives of Financial Stability
Fundamental objectives of financial regulation
Financial Safety/Stability Net
AdverseSelection
Representinguninformed agents
Mitigating systemicrisks / externalities
MoralHazard
Costly StateVerification
Micro and macro prudential Micro and macro prudential perspectives of Financial Stabilityperspectives of Financial Stability
Preventivetools
Correctivetools
Lender ofLast Resort
ResolutionMechanisms
Control andSupervision
PrudentialRegulation
Financial Safety Net
Micro and macro prudential Micro and macro prudential perspectives of Financial Stabilityperspectives of Financial Stability
Monetary Policy
Lender of Last Resort
Prudential
Regulator and
Supervisor
Deposit Insurer
and Resolution
Agency
Explicit conflict of objectives and coordination
Financial Safety Net: Governance
Micro and macro prudential Micro and macro prudential perspectives of Financial Stabilityperspectives of Financial Stability
The decision-making of some crucial issues
Liquidatingfinancial institutions
Mergers andacquisitions
Short termfinancial assistance
Interveningfinancial institutions
Financial Safety Net: Governance and Conflict of Objectives
Micro and macro prudential Micro and macro prudential perspectives of Financial Stabilityperspectives of Financial Stability
Separation/Unification of theFinancial Safety Net agencies
Relative institutionalstrenght
Reputation andcredibility
Expertise andcapacities
Make explicit theconflict of objectives
Institutional Determinants of the Financial Safety Net Design
Micro and macro prudential Micro and macro prudential perspectives of Financial Stabilityperspectives of Financial Stability
The necessary consistency in supervisionand regulation across markets and agents
Capitalmarkets
Insurancemarkets
Pension fundadministrators
Financialintermediaries andnon-intermediaries
Degree of Centralization of Financial Regulation
Micro and macro prudential Micro and macro prudential perspectives of Financial Stabilityperspectives of Financial Stability
More centralized
Efficiency due tospecialization
Lower powerconcentration
Economies of scaleand scope
Lowerbureaucratic costs
Less centralized
Conglomerateslogic
Degree of Centralization of Financial Regulation
Micro and macro prudential Micro and macro prudential perspectives of Financial Stabilityperspectives of Financial Stability
Lower regulatoryarbitrage
Monetary Policy
Lender of Last Resort
Prudential
Regulator and
Supervisor
Deposit Insurer
and Resolution
Agency
Coordination and contribution for all agenciesto comply with their respective mandates
Financial Stability Net: Governance
Micro and macro prudential Micro and macro prudential perspectives of Financial Stabilityperspectives of Financial Stability
Ministry of Finance/
Treasury
The complementary roles of micro and macro perspectives
Both micro and macro perspectives have to be considered in order to set the optimal governance structure to the Financial Safety/Stability Net
The contribution of both approaches should be transversal to all the Financial Safety/Stability Net agencies
Micro and macro prudential Micro and macro prudential perspectives of Financial Stabilityperspectives of Financial Stability
Financial regulation Perspectives
Micro-prudencial
Macro-prudencialMitigating
systemic risks
Representation ofuninformed agents
The complementary roles of micro and macro perspectives
Sound risk management are needed not only of individual institutions but also of the financial system as a whole
Both approaches should help to make agents to internalize externalities in both static and dynamic dimensions of financial stability
All proposals (capital buffers, counter-cyclical provisioning, caps on Loan-to-Value ratios, liquidity requirements) require more understanding for implementation and impact evaluation
Rules vs. Discretion: equilibrium between flexibility and reputation
Corporate governance is also relevant: internal risk-management process and compensation schemes should be aligned with a reasonable risk-taking behavior
Micro and macro prudential Micro and macro prudential perspectives of Financial Stabilityperspectives of Financial Stability
Implications of systemic risks on rules and institutions
Systemic risks
Rules
Institutions
Risk-based regulation
Broad perimeter
Financial Safety Net
Financial Stability Framework
Centralized Regulation
Ownership/stockholding of non-financial entities
Corporate governance
Regulatory treatment of public entities
Exposure to common and correlated risks
Interconnectedness (players and markets)
Financial and real sector conglomerates/
cross border
New kinds of risks as markets develop
Regulatory arbitrage across entities with different licenses
Micro and macro prudential Micro and macro prudential perspectives of Financial Stabilityperspectives of Financial Stability