mindful governance of systemic financial risk

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Mindful governance of systemic financial risk Seminari IAFI – Barcelona, 9 May 2014 Gilbert Peffer CIMNE

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Page 1: Mindful governance of systemic financial risk

Mindful governance of systemic financial risk

Seminari IAFI – Barcelona, 9 May 2014

Gilbert PefferCIMNE

Page 2: Mindful governance of systemic financial risk

Shifting perspective on an emerging reality

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The “characteristic processes by which society defines and handles its problems. In this general sense, governance is about the self-steering of society."

“We shall here define governance as the process of steering society and the economy through collective action and in accordance with some common objectives.” – Torfing et al. (2012)

Governance

Mindless

Mindful

Thoughtless, careless, heedless, inattentive, neglectful, rash, irreflective

Aware, observant, thoughtful, cognisant, attentive, conscious 3

Voß et al. (2007)

Torfing et al. (2007)

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The great financial crisis

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Bank of England (2008)

Anatomy of a crisis

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European Central Bank (2008)

Valuation

Leverage

Funding

Margin calls

Uncertainty

Social psychology

Credit quality

Interactions among these factors magnify systemic risks

Contagion channels – From incubation to symptoms

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Zooming in – The complex contagion channel of RMBS-CDO-CDO2

Financial Crisis Inquiry Commission [FCIC] (2011) 7

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Effects on growth, markets, banks, credit, and households

Internal Monetary Fund (2009a, 2009b) 8

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The cost of the financial crisis in the U.S. in terms of output loss

*Atkinson, Lutrell, and Rosenblum (2013)

Scenario 2: Return to trend output per working-age adult*

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Case 1 – Trouble in Spain, 7 years on

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‘Brotes verdes’ – Myopia, wishful thinking, hubris?

11

Mindless?

Casado (2013), Efe/Bilbao (2014), Efe/Valladolid (2014), Efe/Washington (2014), Jiménez (2014).

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European Commission (2013)

Access to finance

12

Precarious state of small businesses in Spain

EU

Spain

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OECD (2013b)

Adult literacy and numeracy among the worst

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Fitch et al. (2009)

Villar (2013)

Unemployment by age group Long-term unemployment (> 2 yrs)

Growing inequality

Increasing poverty

1

2

1

2

OECD (2013a)

Long-term effects on the population

Mental health and debt

34

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Case 2 – Institutional blind spots

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BULLARD – “My sense is that the level of systemic risk associated with financial turmoil has fallen dramatically. For this reason, I think the FOMC should begin to de-emphasize systemic risk worries. […] My sense is that, because the turmoil has been ongoing for some time, all of the major players have made adjustments […]. They have done this not out of benevolence but out of their own instincts for self-preservation. […] I say that the level of systemic risk has dropped dramatically and possibly to zero.”

LACKER – “I want to commend President Bullard’s discussion ofsystemic risk. […] To invoke the notion of systemic risk to support a particular policy course requires […] some theory, some coherent understanding of the way you think the world works. The Committee might be surprised that the literature provides only relatively tenuous rationales—I think is a fair judgment—for policy intervention. To invoke the notion of systemic risk to support a particular policy course requires theory.”

MISHKIN – “I have to disagree very strenuously with the view that, because you have been in a “financial stress” situation for a period of time, there is no potential for systemic risk. In fact, I would argue that the opposite can be the case.”

BERNANKE – “Systemic risk is an old phenomenon. There are literally dozens and dozens of historical episodes that are suggestive of that phenomenon. There is also an enormous theoretical literature.”

Federal Reserve (2014)

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What the FOMC 8/8 tells us

Appelbaum (2014)

Sharf (2014)

Federal Reserve (n.d.) 16

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Mr. GREENSPAN. “[…] those of us who have looked to the self-interest of lending institutions to protect shareholders equity, myself especially, are in a state of shocked disbelief.”

Mr. GREENSPAN. “I found a flaw in the model that I perceived is the critical functioning structure that defines how the world works, so to speak. “

Chairman WAXMAN. “In other words, you found that your view of the world, your ideology, was not right, it was not working.”

Mr. GREENSPAN. “Precisely. That’s precisely the reason I was shocked, because I had been going for 40 years or more with very considerable evidence that it was working exceptionally well.”

The Financial Crisis and the Role of Federal Regulators (2008)

17

Lanman and Mathews (2008)

Greenspan: “I found a flaw”Hearing by the House Oversight Committee, 23 Oct 2008

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“As everyone knows, however, there is with us another source of confusion and another barrier to advance: most of us, not content with their scientific task, yield to the call of public duty and to their desire to serve their country and their age, and in doing so bring into their work their individual schemes of values and all their policies and politics - the whole of their moral personalities up to their spiritual ambitions.”

“But there exist in our minds preconceptions about the economic process that are much more dangerous to the cumulative growth of our knowledge and the scientific character of our analytic endeavours because they seem beyond our control in a sense in which value judgments and special pleadings are not. Though mostly allied with these, they deserve to be separated from them and to be discussed independently. We shall call them Ideologies.”

Schumpeter (1949)

On ideology in economics

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“if the Federal Reserve […] is not capable of confronting this type of problem, I think it is telling us something about the nature of the problem which itself is incapable of being handled in the way we all would like”

Alan Greenspan, Congressional hearing Oct 2008

“I stood up at a Fed meeting in 2005 and said, ‘How many anecdotes [on mortgage fraud] makes it real? ... How many tens [of] thousands of anecdotes will it take to convince you that this is a trend?”

Margot Saunders, National Consumer Law Centre

Patricia McCoy called it the ‘classic Fed mindset’: “If you cannot prove that it is a broad-based problem that threatens systemic consequences, then you will be dismissed”

Patricia McCoy, Fed Consumer Advisory Council

FCIC (2011)

World views, mindsets, groupthink@Federal Reserve

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Independent Evaluation Office (2011)

“The IEO found that the IMF’s ability to identify the mounting risks was hindered by a number of factors, including a high degree of groupthink; intellectual capture; and a general mindset that a major financial crisis in large advanced economies was unlikely. Governance impediments and an institutional culture that discourages contrarian views also played important roles.”

“What is it that despite continued prodding and nudging by evaluations and investigations into the Fund’s workings makes this organisation so resistant to change?”

World views, mindsets, groupthink@International Monetary Fund

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Governance: “the process of steering society and the economy through collective action and in accordance with some common objectives.”

Possible sources of failure:

• The process and outcomes of ‘steering’

• The way collective action is decided, conducted, and who it affects

• The nature of the common objectives and how they are determined

• The impossibility to reflect on governance and its underlying assumptions and premises

Reflexive governance: “Reflexive governance refers to the problem of shaping societal development in the light of the reflexivity of steering strategies – the phenomenon that thinking and acting with respect to an object of steering also affects the subject and its ability to steer.”

“Reflexive governance thus implies that one calls into question the foundations of governance itself, that is, the concepts, practices and institutions by which societal development is governed, and that one envisions alternatives and reinvents and shapes those foundations.”

Voss, Bauknecht, and Kemp (2006)

Torfing et al. (2012)

A crisis of governance?

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Mindful governance of systemic financial risk

Mindful science

Mindful organisations

Mindful individuals

Reflexive governance

Mindful governance, what’s in it?

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Mindful individuals

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Mindfulness is an approach “to reduce cognitive vulnerability to stress and emotional distress”

Two-component model of mindfulness

“The first component involves the self-regulation of attention so that it is maintained on immediate experience, thereby allowing for increased recognition of mental events in the present moment.“

“The second component involves adopting a particular orientation toward one’s experiences in the present moment, an orientation that is characterized by curiosity, openness, and acceptance.”

Bishop et al. (2004)

Mindfulness in clinical psychology

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Goal: Translate key elements of mindfulness into the domain of financial decision-making and developing approaches to online delivery of mindfulness training.

Study showed that less experienced traders had lower ability to regulate their levels of emotional arousalduring stressful trading than more experienced traders.

The fact that more experienced traders had learned to regulate their emotions pointed to emotion regulation as a skill that could be trained.

Studies using physiological sensors with student participants identified mindfulness as a valid techniquefor managing emotional arousal.

Peffer et al. (2012)

Fenton-O’Creevy et al. (2011)

Mindfulness in financial trading xDelia project

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“Mindfulness is a flexible state of mind in which we are actively engaged in the present, noticing new things andsensitive to context.”

“When we are in a state of mindlessness, we act like automatons who have been programmed to act according to the sense our behaviour made in the past, rather than the present.“

“Most of the reigning theories held that human behaviour was the product of rational, calculated thought”

“Langer showed that instead of cognition determining behaviour, thinking – and sometimes the absence of it – often emerges from behaviour.”

Langer (2000).

Source: Feinberg (2010)

Mindfulness in social psychology“Mindfulness without mediation” – Ellen Langer

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“Mindful leaders…• …are preoccupied with possibility of something going wrong• …know that bad news does not move upwards• …lie awake at night worrying• …feel 'chronic unease'• …go an find out for themselves”

Source: Preview to mindful leadership training by Prof. Andrew Hopkins (http://goo.gl/pFVa68)

Mindfulness in leadershipAndrew Hopkins

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Mindful organisations

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Congressional hearings, the FCIC, and academic writings on the financial crisis have largely ignored insights and lessons from organisational research into change and crises. Important themes from that literature are:

• Normal accident theory• High reliability organisations• Organisational learning• Sense making• Safety drift• Normalisation of deviance• Resilience engineering• Mindful organisations

The organisational perspective on crises

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Comparing two inquiries: FCIC versus CAIB

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“The Board recognized early on that the accident was probably not an anomalous, random event, but rather likely rooted to some degree in NASAʼs history and the human space flight programʼs culture. Accordingly, the Board broadened its mandate at the outset to include an investigation of a wide range of historical and organizational issues. […] this report, in its findings, conclusions, and recommendations, places as much weight on these causal factors as on the more easily understood and corrected physical cause of the accident.”

Cultural traits and organizational practicesdetrimental to safety were allowed to develop, including:

• reliance on past success as a substitute for sound engineering practices

• organizational barriers that prevented effective communication of critical safety information and stifled professional differences of opinion

• lack of integrated management across program elements

• the evolution of an informal chain of command and decision-making processes that operated outside the organisationʼs rules.

MINDFUL of key mechanisms leading to organisational failure

CAIB: History, organisation, cultureC

olu

mb

ia A

ccid

ent

Inve

stig

atio

n B

oar

d

CAIB (2003)

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“These conclusions must be viewed in the context of human nature and individual and societal responsibility.

• First, to pin this crisis on mortal flaws like greed and hubris would be simplistic. It was the failure to account for human weakness that is relevant to this crisis.

• Second, we clearly believe the crisis was a result of human mistakes, misjudgements, and misdeeds that resulted in systemic failures for which our nation has paid dearly.”

“If we do not learn from history, we are unlikely to fully recover from it.”

LESS MINDFULL of key mechanisms leading to organisational failure

“We do place special responsibility with the public leaders charged with protecting our financial system. […] These individuals sought and accepted positions of significant responsibility and obligation.”

“But as a nation, we must also accept responsibility for what we permitted to occur. Collectively, but certainly not unanimously, we acquiesced to or embraced a system, a set of policies and actions, that gave rise to our present predicament.”

“This is our collective responsibility. It falls to us to make different choices if we want different results.”

FCIC: Choice, responsibility, blame

But how?

No reference to any of the highly relevant organisational literature

Fin

anci

al C

risi

s In

qu

iry

Co

mm

issi

on

FCIC (2011)

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The ignorance of what is going on is organisational and prevents any attempt to stop the unfolding harm. Then, what can be done?

• “organizations must go beyond the easy focus on individual failure to identify the social causes in organizational systems, a task requiring social science input and expertise.”

• Target leaders, culture, and signals

“normalisation of deviance means that people within the organization become so much accustomed to a deviant behaviour that they don't consider it as deviant”

“[…] for years preceding both [space shuttle] accidents, technical experts defined risk away by repeatedly normalizing technical anomalies that deviated from expected performance”

Asymmetry of proof requirement

Prove there is a problem versus prove there is no problem

At one point the key [NASA] engineer said, «You know, I can’t prove it. I just know it’s away from goodness in our data base.» But in that culture, that was considered an emotional argument, a subjective argument, it was not considered a strong quantitative data argument in keeping with the technical tradition at that time.”

the ‘classic Fed mindset’: “If you cannot prove that it is a broad-based problem that threatens systemic consequences, then you will be dismissed”

Patricia McCoy, Fed Consumer Advisory Council

Lessons for the GFC?

Normalisation of devianceDiane Vaughan

Starbuck and Farjoun (2005)

CAIB (2003), FCIC (2011).

Starbuck and Farjoun (2005), CAIB (2003).

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What can be done? From the high reliability organisation literature:

• strong safety cultures• good managerial control systems• effective learning• greater attention to near-accidents

“The nature of latent errors and ambiguous feedback about the state of safety in the organization requires a healthy disbelief in current performance indicators.”

Starbuck and Farjoun (2005)

Safety failure cycle

Lessons for the GFC?

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Safety driftMoshe Farjoun

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During the week of August 6, 2007, a number of high-profile and highly successful quantitative long/short equity hedge funds experienced unprecedented losses.

International Atomic Agency (2005)

Khandani and Lo (2007)

Lessons for the GFC?

Near misses in financial markets?

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“In an unknowable, unpredictable world, ongoing mutual re-adjustment is a constant, and it is this adaptive activity that generates potential information about capability, vulnerability, and the environment. That information is lost unless there is continuous mindful awareness of these variations. By this line of argument, unreliable outcomes occur when cognitive processes vary and no longer stay focused on failures, simplifications, recoveries, situations, and structuring, or when patterns of activity fail to vary and unexpected events are normalized.”

Lessons for the GFC?

Example “Simplification” – Members of all organizations handle complex tasks by simplifying the manner in which the current situation is interpreted. These simplifications, variously referred to as worldviews, frameworks, or mindsets, basically allow members to ignore data and keep going. […] Simplifications increase the likelihood of eventual surprise. They allowanomalies to accumulate, intuitions to be disregarded, and undesired consequencesto grow more serious.

Mindfulness in high-reliability organisationsKarl Weick

Weick, Sutcliffe, and Obstfeld (1999)

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Mindful science

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Imprudent & fraudulent

mortgage lendingHousing bubble Global imbalances Securitisation

Rating agenciesMark-to-market

accountingDeregulation Shadow banking

Bank-type runsLending via off-balance sheet

vehicles

Failure of risk management

Financial innovation

Originate-to-distribute business

modelGreed and fear Complexity

Broken computer models

Excessive leverageBalkanisation of

regulatorsCredit default

swapsShort-term incentives

Lack of systemic risk regulator

Minsky moment

Tail risk

Black swan

Federal home lending

programmes

Jickling (2010)

No simple cause of the (a) financial crisis

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Jickling 2010. Causes of the financial crisis.

A → BB → AC → A & BA ↔ B

We observe that two events co-occur:A and B. What is their causal relation?We observe that two events co-occur:A and B. What is their causal relation?

Correlation does not imply causation

INUS – insufficient but non-redundant part of an unnecessary but sufficient condition

(A&B&C or D&E&F or G&H&I) → E

A: short circuit; E: house fireA: housing bubble; E: SIVs, CDOs; H: rating agencies

The pitfalls of causal explanations

Bank of England (2006)

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“So, it strikes me that if you go back and ask yourself how in the early years anybody could realistically make a judgment as to what was ultimately going to happen to subprime, I think you are asking more than anybody is capable of judging. And we have this extraordinarily complex global economy which, as everybody now realizes, is very difficult to forecast in any considerable detail.“

The view from mindful organising

“A very significant amount of regulation in the economic area is based on a forecast to know in advance””

“If we are right 60 percent of the time in forecasting, we’re doing exceptionally well. That means we are wrong 40 percent of the time, and when you observe the extent of the broad failure, the difficulty is that nobody can forecast”

“We can try to do better, but forecasting is never—never gets to the point where it’s 100 percent accurate.”

“We cannot expect perfection in any area where forecasting is required, and I think we have to do our best, but not expect infallibility or omniscience.”

“Just let me say quickly, the Federal Reserve has an as sophisticated a modelling structure and capable people as any organization I am aware of. It did not forecast what is happening”

Greenspan testimony at the 23 Oct 2008 congressional hearing

"For complex phenomena, Hayek maintains that it is difficult to predict individual events. Instead he argues that many events must be observed. Often the events being observed form a pattern. It is the pattern which is potentially predictable rather than individual events. For many patterns, prediction may give way to a weaker criterion. At most what may be achieved is an explanation of the principle or the central factors which give a systemic pattern its characteristic appearance."

The curse of the prediction neurosis

No preoccupation with forecasting

The Financial Crisis and the Role of Federal Regulators (2008)

Colander (2002) 40

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Empirical

Real

induction

deduction

Positivism Critical realism

Empirical

Actual

induction

deduction

Real

retroduction

past future

Empirical

Induction

VaR Mechanisms = Real

Dispositional metaphysics

Explanations and critical realism

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A philosophically principled pluralism: “[a pluralism] that regards the various “schools” of economics, including neoclassicalism, as offering different windows on economic reality, each bringing into view different subsets of economic phenomena . . . [and] rejects the idea that any school could possess final or total solutions, but accepts all as possible means for understanding real-life economic problems.”

“[P]luralism is a meta-methodological position. It offers no specific methodological advice to economists.”

“Methodological pluralism makes no epistemological claims; it is not grounded in any theory of truth.”

“Advocates of [a monistic] approach to methodology generally choose one criterion of demarcation to distinguish science from nonscience”

In mainstream economics, one such criterion is rationality. In science more generally, Popper put forward falsifiability as a demarcation criterion.

It is my own view that a much better case can be made for the kind of instrumental conception of science set forth in general terms by Peirces Dewey, and their successors. In this view, scientific activity is perpetual problem solving. No area of experience is totally and completely settled by

providing a set of basic truths; but rather, we are continually confronted with new situations and new problems, and we bring to these problems and situations a potpourri of scientific methods, techniques, and concepts, which in many cases we have learned to use with great facility.

Pluralism in economics

Suppes (1978)

Fullbrook (2003)

Caldwell (1988)

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“[N]o podemos pensar que un minorista es un ignorante financiero y tampoco un jubilado que cobra una pensión es un ignorante”

“[Ellos eran] responsables de lo que firmaban, de lo que leían o no leían, porque en el folleto y en el tríptico estaba toda la información”

Mindfulness and evidence-based financial consumer protection

Guindal (2014) De Barrón (2014)

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By occupation By education

Level 3Level 2 Level 3Level 2

It’s the skills, stupid (not the information)

OECD (2013b) 44

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85%

Adult literacy surveyQuiz 1 – Low difficulty

OECD (2005)

correct

45

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OECD (2013b)

30%correct

Adult literacy surveyQuiz 2 – Medium difficulty

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Compare the per cent of change in Dioxin level from 1975 to 1985 to the per cent of change in Dioxin level from 1985 to 1995. Which per cent of change is larger, and explain your answer.

377

OECD (2005)

Adult literacy surveyQuiz 3 – High difficulty

<1%correct

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Invest €1,000 with us and we

double your money in 7 years.

Fixed annual interest: 10%380

380380

Adult literacy surveyQuiz 4 – Highest difficulty

<<1%correct

OECD (2005)

This is the most difficult numeracy exercise that interviewees were asked to do. It is much less complex than the typical decisions that consumers have to make when dealing with their banks.

Question: Will you in fact double your money in 7 years when they pay you a 10% interest every year?

Only a fraction of the 1% of the almost 50,000 subjects (7 countries) responded correctly to this question.

OECD (2013)

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Reflexive governance

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What are the assumptions?

• Definition of goals – The goal, i.e. the direction of the steering attempt is defined clearly and unambiguously.

• Analysis of system dynamics – Predictive knowledge on system dynamics can be developed, allowing the effects of action to be assessed.

• Organisation of collective action – The power to control influential factors for system development is given or can be organized.

These assumptions are unlikely to hold in the context of systemic risk.

Goals

• Conflict of goals• Vagueness of goals

Knowledge

• Heterogeneity of interacting factors• Feedback loops and emergent

dynamics

Power

• Horizontal distribution of power• Vertical distribution of power

Where are the problems?

Conventional modes of steering and regulation

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Voß et al. (2007)

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Steering concepts

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Voß et al. (2007)

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Governance – “We shall here define governance as the process of steering society and the economy through collective action and in accordance with some common objectives.”

Political sciences

Interactive governance – “The complex process through which a plurality of social and political actors with diverging interests interact in order to formulate, promote, and achieve common objectives by means of mobilizing, exchanging, and deploying a range of ideas, rules, and resources.”

Quasi markets

PartnershipsGovernance

networks

• “the presence of capable and resourceful actors• a high degree of trust among public and private actors• the possibility of ensuring voluntary compliance”

Conditions of emergence of interactive governance

• “political cultures and traditions• the need to enhance input and output legitimacy• the capacity to metagovern interactive

governance”

Interactive governanceTorfing et al. (2012)

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Torfing et al. (2007)

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Sustainable development

Governance – “the characteristic processes by which society defines and handles its problems. In this general sense, governance is about the self-steering of society.”

Reflexive governance = governance becoming part of the problem

“[It] involves the establishment of institutions and process which facilitate the actors within a domain for learning not only about policy options, but also about their own interests and preferences. Learning, within open and deliberative processes, might cause participants not only to conceive of better techniques or instruments but also, beyondpolicy solutions, to reorder the way that the policy problems are conceived and prioritised“

Reflexive governanceVoß et al. (2012)

53

Radulova (2007)

Voß et al. (2007)

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Gilbert Peffer

CIMNE

[email protected]

Thank you for your interest!

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Langer, E. J. (2000). Mindful learning. Current Directions in Psychological Science, 9(6), 220-223.

Lanman, S., & Mathews, S. (2008). Greenspan Concedes to `Flaw' in His Market Ideology. Bloomberg. Retrieved from http://goo.gl/7Oxf8i.

Lawson, T. (2003). Reorienting economics. London ; New York: Routledge.

Molnar, G., & Armstrong, D. M. (2007). Powers: A study in metaphysics. Oxford: Oxford University Press.

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