14 February 2011

Macroprudential policy tools and frameworks
Update to G20 Finance Ministers and Central Bank Governors
1.

Introduction

The financial crisis has intensified the official sector’s interest in strengthening themacroprudential orientation of current policy arrangements. At their meeting in Seoul in
November 2010, G20 Leaders concluded that further work on macroprudential frameworks
was a priority (see paragraph 41 of the Seoul Summit Document):
Further work on macro-prudential policy frameworks: In order to deal with systemicrisks in the financial sector in a comprehensive manner and on an ongoing basis, wecalled on the FSB, IMF and BIS to do further work on macro-prudential policy
frameworks, including tools to mitigate the impact of excessive capital flows, andupdate our Finance Ministers and Central Bank Governors at their next meeting.
These frameworks should take into account national and regional arrangements. We
look forward to a joint report which should elaborate on the progress achieved in
identification of best practices, which will be the basis for establishing in the futureinternational principles or guidelines on the design and implementation of theframeworks.
This update summarises the work underway internationally and nationally to develop effective
macroprudential policies and frameworks, by drawing also on surveys conducted by the BIS(via the CGFS) and IMF. These efforts include regulatory reforms and the design of policy
tools to strengthen the resilience of the financial system, as well as efforts at the national andregional level to develop fully-fledged macroprudential policy frameworks. An Annex
discusses issues related to managing capital flows.
This note finds that major steps have already been taken. That said, further work is needed toaddress the remaining challenges in successfully implementing macroprudential policies andinstitutional frameworks, including:Design and collection of better information and data to support systemic risk
identification and modelling;Design of techniques to identify and measure systemic risk that utilise this informationand help inform the design of policies;Design of an effective macroprudential toolkit of powers and instruments, including
the criteria for the choice and calibration of the instruments and methods to assess
their effectiveness, as well as the respective merits of rules versus discretion; and1Design of appropriate governance arrangements for the exercise of themacroprudential policy powers.

The FSB, BIS and IMF will provide an update on progresses in these areas to G20 Leaders attheir November meeting.
2.

Terminology and typology

The term “macroprudential” has become increasingly common in discussions of possible
changes to regulatory and supervisory frameworks. However, different users have different
ways of defining it. We define macroprudential policy as a policy that uses primarily
prudential tools to limit systemic or system-wide financial risk, thereby limiting the incidenceof disruptions in the provision of key financial services that can have serious consequences forthe real economy, by

dampening the build-up of financial imbalances and building defences that contain the
speed and sharpness of subsequent downswings and their effects on the economy;identifying and addressing common exposures, risk concentrations, linkages andinterdependencies that are sources of contagion and spillover risks that may jeopardise
the functioning of the system as a whole.

The defining elements of macroprudential policy are the objective (limiting systemic or
system-wide financial risk), the scope of analysis (the financial system as a whole and its
interactions with the real economy), a set of powers and instruments and their governance(prudential tools and those specifically assigned to macroprudential authorities).
Macroprudential policy is a complement to microprudential policy and it interacts with othertypes of public policy that have an impact on financial stability. No matter how different
policy mandates are structured, addressing financial stability and systemic risk is a common
responsibility. Many policies could and should influence financial stability and systemic risk,
but not all such policies should be considered macroprudential.
For what are typically regarded as non-prudential instruments to be considered part of themacroprudential policy toolkit, the instruments should: (i) target explicitly and specificallysystemic risk; and (ii) be underpinned by the necessary governance arrangements for the
institutional framework chosen to conduct macroprudential policy to ensure there is noslippage in their use (clear mandate, necessary degree of operational independence andaccountability). Macroprudential policy complements but cannot substitute for soundmicroprudential and macroeconomic policies.
Macroprudential polices aim to address two dimensions of system-wide risk: first, theevolution of system-wide risk over time – the “time dimension;” and second, the distributionof risk in the financial system at a given point in time – the “cross-sectional dimension.”
The key issue in the time dimension is to mitigate or dampen financial system procyclicality,i.e., how financial system-wide risk can be amplified by interactions within the financial
system and between the financial system and the real economy, sometimes leading tofinancial crises. In economic upswings, the financial system creates and tends to become
overexposed to aggregate risk, via ample credit availability, rapid increases in asset prices,leverage and maturity mismatches. If the system has not built sufficient buffers in good times,2

when the financial cycle turns, the downturn can induce widespread financial distress and be
amplified by substantial deleveraging, reducing the provision of credit and key financial
services to the economy. A specific focus here is how to put in place various forms of buffersthat act countercyclically, thereby also possibly restraining the build-up of systemic risk.
The key issue in the cross-sectional dimension is to reduce systemic risk concentrations,which can arise from similar exposures across financial institutions (from assets, liabilities,
dependence on common services) or because of the direct balance-sheet linkages among them(e.g., counterparty risk). A specific focus here is ensuring that protections at individual
institutions are commensurate with their contribution to system-wide risk and containing
spillovers from their failure.
Macroprudential policymaking requires monitoring system-wide risks in both dimensions.
3.

Identifying and measuring systemic risk

Effective diagnosis of systemic risks is critical for macroprudential policymaking. The crisis
highlighted deficiencies in the ability of authorities to identify and measure systemic risk.
Improvements in financial statistics and in the analytical toolkit to assess the build-up of risks
in the system as a whole are important elements of a stronger macroprudential framework.
A substantial programme of work is underway nationally and internationally to address
important data gaps. Previous reports by the IMF staff and FSB Secretariat, with inputs fromthe BIS, CGFS, and a variety of other data users and statistical agencies, provided 20
recommendations to strengthen information and set out a detailed work programme to
implement each of the recommendations.1 A further update on progress will be provided to
Finance Ministers and Governors in mid-2011. Within the overall programme, priorities are toprovide better information on aspects where the absence of good information has proved very
costly, and in particular: (i) the interlinkages between large, globally systemically important
institutions; (ii) emerging concentrations of risk in terms of both exposures and funding
dependencies to certain institutions, countries and financial sectors;2 (iii) the transfer andultimate holding of risk; (iv) system-wide leverage and maturity mismatches; and(v) international financial integration through cross-border banking and investment flows.
Separately, the BIS and CGFS are pursuing improvements to the BIS’ international banking
statistics, which will help to better analyse the transmission of funding and other shocks
across countries through the banking system.
Improved information in these areas will help the authorities to better understand the key
interconnections within the financial system and to develop analytical tools to gauge thelikelihood and impact of common reactions to shocks that can amplify financial market
responses and precipitate severe system-wide stress. However, addressing information gaps
will not be a one-off exercise. As systemic risk oversight is strengthened, and as financial
markets continue to adapt and innovate in response to technological developments and
1‘The Financial Crisis and Information Gaps’ October 2009, followed by ‘The Financial Crisis and Information Gaps:
progress report, action plans and timetables’ May 2010.

2

Better data on (i) and (ii) will enable authorities to answer questions such as: “Do large globally systemically importantbanks have growing risk concentrations to common obligors (such as AIG or Lehman Brothers during the crisis)?”, “Arethe links between banks and hedge funds intensifying?”, and “How exposed are the different banking systems to a run on
one of the largest Money Market Funds (such as the Reserve Primary Fund during the crisis)?”3

regulatory initiatives, it is highly likely that new information gaps will emerge. Ensuring thatstatistical frameworks are adaptable and responsive to developments in financial markets willthus remain a policy priority.
Closing information gaps will help improve the analytical toolkit to assess system-wide risks.
But already now, significant progress is being made and is being incorporated in structured
assessments of vulnerabilities and regulatory initiatives. International efforts include those of
the FSB Standing Committee for the Assessment of Vulnerabilities, the IMF’s regularbilateral and multilateral surveillance, the IMF-FSB Early Warning Exercise presented twice
yearly to senior policymakers, covering major systemic risks and adverse scenarios, andvarious workstreams at the BIS, notably the work of central bank experts that informs regular
discussions among Governors. These efforts focus on the identification of common exposures,risk concentrations and interlinkages within and across financial systems, and on the build-up
of macroeconomic and financial imbalances, both domestically and globally.
In the time dimension, the countercyclical capital buffer adopted in Basel III is a notable
example of a new regulatory initiative that draws on advancements in the toolkit to measuresystemic risk. The so-called buffer guide will form the starting point for discussions on whento activate the buffer in each national jurisdiction. The buffer guide signals increases in the
countercyclical capital buffer if the credit-to-GDP ratio is rising significantly relative to its
long-term trend. This captures the fact that many systemic crises are preceded by credit andasset price booms. However, it is recognised that no single variable can fully capture thecomplex dynamics of the financial cycle, thus requiring judgement when calibrating thebuffer. This judgement will be supported by a broad range of simple indicators, which are
already currently used in financial stability assessments, such as macroeconomic conditions,balance-sheet indicators and/or information from market prices.
Significant research is also underway to better model the interactions between the real
economy and the financial sector. Some of these models have already been used to assess themacroeconomic impact of the regulatory reform underway.3 In addition, macroeconomic
stress tests will also help to inform policymakers’ judgement about the stage of the financial
cycle. Building on earlier tools often developed as part of the IMF-World Bank Financial
Sector Assessment Program (FSAP), current models are being enhanced to better capture
feedback effects between financial institutions as well as financial institutions and the real
economy.
In the cross-sectional dimension, the Basel Committee on Banking Supervision (BCBS) isdeveloping a methodology for the identification of banks that are systemically important froma global perspective. As part of the overall identification process, benchmark indicators reflectrobust measures of the different factors that drive systemic importance of financial firms: theirsize, the degree of their interconnectedness with other financial firms and the degree to which
they provide specialised services for which there are few substitutes. They also include
measures of the participation of the bank in international markets. The International
Association of Insurance Supervisors (IAIS) has embarked on a similar exercise focusing on

3

Basel Committee on Banking Supervision (2010): An assessment of the long-term economic impact of stronger capitaland liquidity requirements; and Basel Committee on Banking Supervision and Financial Stability Board (2010):
Assessing the macroeconomic impact of the transition to stronger capital and liquidity requirements

4the insurance sector.4 Finally, work is also underway on structural methodologies to identify
systemic importance at the IMF, the BIS, national central banks and academia based on inputs
capturing size, probabilities of failure, similarities in exposures and interconnectedness.
4.

Policy tools in the time dimension

Since the crisis, key steps have been taken to address procyclicality. Some have been agreed
or proposed at the international level; others have been adopted purely at the national level.
Some are clearly macroprudential, in the sense of being prudential in character and targetingsystemic risk specifically; others, while falling somewhat short of these strict criteria, have asignificant impact on procyclicality. Several are in line with the FSF report submitted to the
G20 Leaders in April 2009.5(i)International level: Basel III

Basel III includes a number of provisions that should dampen procyclicality. In addition to
steps taken to reduce the procyclicality of risk-weighted assets and hence of the minimum
requirement (e.g., the use of stress parameters for the trading book), Basel III puts in place a
specific macroprudential overlay in the form of a countercyclical capital buffer. The buffer isdesigned to be accumulated during periods when systemic risk builds up, as signalled for
instance by excessive credit growth, and can be used without restrictions when risksmaterialise. It is thus structured to act as a stabiliser during both the expansion and contraction
phases of the financial cycle. The build-up of the buffer is encouraged through restrictions on
capital distributions. Authorities would then release the buffer based on incipient signs ofstrains, such as aggregate losses or tighter credit terms. In both cases, the exercise of judgment
remains critical. The buffer applies to Common Equity Tier 1 (CET 1) and fully lossabsorbing capital and ranges from 0 to 2.5% of risk-weighted assets, though national
authorities can implement a buffer in excess of 2.5% if deemed appropriate in their national
context. Banks with credit exposures to several jurisdictions will need to hold a buffer thatreflects the weighted average of a bank’s domestic and international exposures. Importantly,
the buffer is activated by the host authorities (i.e., the authorities where the exposures arelocated) and the arrangements contain reciprocity clauses. The home supervisory authority (iethe supervisor of the bank that has the exposures) has the option of imposing a higher bufferthan the host authority for the same exposures but should not impose a lower one. This
reciprocity agreement represents an important step towards achieving a better coordination
between home and host authorities, in light of the (new) macroprudential orientation ofprudential policy.
Next to the countercyclical capital buffer, other provisions of Basel III can help to dampen
procyclicality, although they are not exclusively designed to address it. First, a permanent
capital conservation buffer (2.5% CET 1 equity) allows banks to absorb losses without hitting
the minimum, thereby lessening pressure to restrict credit. Dipping into it, however, will
4

5

The IAIS is also establishing a macroprudential policy and surveillance working group with a mandate to develop amacroprudential policy framework. This includes the development of a global macroprudential surveillance frameworkfor systemic risks that may arise as a result of activities in the insurance sector or may be of concern for the insurance
sector, such as those related to pandemics and common economic or market shocks.
See FSF “Report of the Financial Stability Forum on Addressing Procyclicality in the Financial System”, April 2009.

5

involve some costs, in the form of restrictions on capital distributions to shareholders. This
will help to conserve capital, but could also make bank managers somewhat reluctant to draw
on the buffer. The size of the capital conservation buffer was set partly based on a top-down
assessment of loss experience during crisis, not just on the individual loss experience ofbanks. Second, the additional minimum leverage ratio and the new liquidity standards could
help limit the build-up of financial imbalances during the expansion phase of the financial
cycle. In particular, the leverage ratio provides an important backstop in cases where
excessively optimistic point-in-time risk measures tend to shrink risk-weighted assets andrequired capital cushions.6(ii)

International level: Margins and haircuts on securities used as collateral

The CGFS has developed recommendations7 for ways to strengthen haircut-setting andmargining practices to limit the build-up of leverage in good times and soften the system-wide
effects during a market downturn. It has also explored measures involving countercyclicalvariations in margins and haircuts to dampen the procyclicality of leverage in securities
financing markets and to soften the systemic impact of subsequent deleveraging
The recommendations aim to promote margining practices that are more stable across thecycle and calibrated to include periods of stressed market conditions, thereby reducing
financial system procyclicality. Margining practices are defined broadly to include thehaircuts applicable to funding collateral as well as the mark-to-market and collateralrequirements applicable to over-the-counter (OTC) derivatives These recommendations arebeing implemented, some in the Basel III accord, and also in various jurisdictions, such as
those that are developing qualitative surveys of credit terms used in OTC derivatives markets
to assess financing conditions.
(iii)

International level: Expected loss provisioning

Accounting standards for loan loss provisioning, while not set to address procyclicality, canhave a first-order impact on it. Both the International Accounting Standards Board (IASB)
and the US Financial Accounting Standards Board (FASB) have issued exposure drafts for
expected loss provisioning approaches that will facilitate earlier recognition of credit losses
and thus help to dampen procyclicality. The Basel Committee has developed a concrete
proposal (set out in a June 2010 comment letter) to operationalise the expected loss approachto provisioning proposed by the IASB. More recently, the IASB and the FASB have
responded to requests by the G20 and FSB to reach a common solution that provides a more
forward-looking approach to accounting for credit losses through a joint IASB-FASB
exposure draft on a converged expected loss approach. Once the Boards’ provisioning
standards are finalised, the BCBS plans to issue guidance that will include principles forsupervisory review processes to reinforce robust provisioning practices in ways that could
mitigate procyclicality.

6

The BCBS has set a parallel-run period to understand the dynamics of the ratio and its interaction with risk-based capitalratios.

7

See “The role of margin requirements and haircuts in procyclicality”, CGFS Paper no. 36, 2010.

6

(iv)

National level: Addressing excessive credit or asset price increases

Quite independently of these new internationally agreed macroprudential standards, somecountries have for some time used other prudential tools, both price- and quantity- based, tomitigate procyclicality. Among price based tools, countercyclical changes in risk weights on
exposures to certain instruments, sectors, or markets (e.g., for foreign currency-denominatedloans, consumer credit, real estate, the construction sector, or the stock market) have beenused to protect the financial system against the build-up of credit risk during periods ofexcessive credit growth or asset price booms. In addition, quantity-based prudential tools havebeen adjusted countercyclically by imposing time-varying caps and limits on the demand of
credit. Such limits can be calibrated with respect to aggregate credit or specific exposures,e.g., by sector. Examples include time-varying, discretionary caps on loan-to-value (LTV),
debt-to-income, loan-to-income ratios, or criteria for loans’ eligibility. Liquidity requirements
on foreign currency exposures have also been introduced recently to limit excessive credit
growth (such as in Korea).
(v)

National level: Other instruments

In addition to the measures reviewed above, a number of tools that are not typically prudential
in nature have been used or proposed as part of the macroprudential toolkit.
They take a variety of forms. In a number of countries tools often associated with monetary
policy have been used to restrict credit expansion. These have included marginal reserves
requirements on banks’ funding, limits on the level or growth rate of aggregate credit or
specific exposures, when used explicitly in a countercyclical fashion. In addition, proposals
have been made for a levy on non-deposit liabilities that would mitigate externalities fromexcessive recourse to vulnerable wholesale funding and contain overly rapid asset growthduring upswings.8
Some of these could in principle be considered part of the macroprudential toolkit. But thatwould require that: (i) they target explicitly and specifically systemic risk; and (ii) the chosen
institutional framework is underpinned by the necessary governance arrangements to ensure
there is no slippage in their use (clear definition of powers and mandate, necessary degree of
operational independence and accountability).
5.

Policy tools in the cross-sectional dimension

Policies in this dimension are under development at the international level, and national
experience in this area remains limited.
(i)International level: Basel III

The first protection for the stability of the financial system is to enhance the resilience of eachindividual institution to adverse shocks; this should be expected to reduce spillovers fromfailures. Thus, the Basel III standards for increased bank capital and liquidity will provide astrong anchor for macroprudential policies. In addition, several provisions in Basel III help toaddress systemic risk and interconnectedness among (global) systemic institutions by
mitigating the risks arising from firm-level exposures. These include: higher capital
8

IMF, A Fair and Substantial Contribution by the Financial Sector, 2010.

7requirements for trading and derivative activities, complex securitization and off-balancesheet exposures and capital incentives for banks to use central counterparties for OTC
derivatives; liquidity requirements that better address the funding risks related to the excessive
reliance on wholesale short term funding; and higher capital requirements for inter-financial
sector exposures.
(ii)International level: SIFI framework

In November, the G20 endorsed the FSB’s policy framework to address the moral hazard risks
and externalities posed by Systemically Important Financial Institutions (SIFIs).9 The key
policy objectives of the FSB SIFI framework are to (i) increase their loss absorption capacity
to reduce the likelihood of their failure, to (ii) facilitate the orderly restructuring or unwindingof a failing SIFI to reduce the impact of its failure on the financial system; (iii) to intensify
supervisory oversight for SIFIs; (iv) to strengthen core financial market infrastructures toreduce contagion risk from failure. The increase in the loss absorption capacity beyond theminimum agreed Basel III standards should reflect the greater risks these institutions pose tosystemic stability, and their contribution to the build up of systemic risk. Standard setters areworking to determine both the extent of greater loss absorption capacity needed as well as thetype and combination of instruments to be used for this purpose. To lessen the impact of theirfailure on the rest of the system, thereby containing the risks posed by these institutions tooverall financial stability, work is underway to: (i) set out the attributes and tools of effective
national resolution regimes; (ii) develop co-operation agreements to facilitate cross-borderresolution; and (iii) put in place mandatory recovery and resolution plans for Global SIFIs that
includes assessments of, and removal of obstacles to, their resolvability. Effective resolution
frameworks reduce moral hazard risk and ex ante risk taking behaviour and therefore support
macroprudential objectives. Furthermore, through strengthening SIFI supervision, supervisors
are expected to detect problems proactively, and intervene early to reduce the impact ofpotential stresses on financial system as a whole. (As for strengthening core financial market
infrastructures, please see below.)(iii)

International level: OTC derivatives infrastructure

Another area of policy development that complements and reinforces the effectiveness ofmacroprudential policy aims at lowering contagion risks by strengthening the financial
infrastructure underpinning over-the-counter derivatives markets. In September 2009, G20
Leaders committed to OTC derivatives market reforms to improve transparency in thederivatives markets, mitigate systemic risk, and protect against market abuse by end-2012. In
November 2010, G20 Leaders endorsed the FSB recommendations designed to promoteinternational consistency in implementing these commitments to standardisation, central
clearing, organised platform trading, and reporting to trade repositories of OTC derivativetransactions. The recommendations set deadlines to meet the G20’s end-2012 commitments,and specify bodies to take the recommendations forward. The recommendations also identify
a number of areas where monitoring will need to continue and exploration of additional
measures is warranted.10

9

See FSB Report, “Reducing the moral hazard posed by systemically important financial institutions”, October 2010.

10

For details, see FSB Report, “Implementing OTC Derivatives Market Reforms”, October 2010.

8

The recommendations address the need to reinforce oversight and regulation of central
counterparties (CCPs) and other core financial market infrastructure given their pivotal role in
the financial system. This specific work is being taken forward jointly by the Committee on
Payment and Settlement Systems (CPSS) and the International Organization of Securities
Commissions (IOSCO). Work to explore the scope for greater use of organised trading
platforms, increased pre- and post-trade transparency, and reporting of all derivatives to traderepositories is being taken forward by IOSCO and other authorities, working in cooperation.
(iv)

National level: Other instruments

Oversight of national payment settlement and clearing arrangements has long played a role in
reducing systemic spillovers from the failure of individual firms. More recently, somecountries have proposed or recently introduced structural measures to manage risk
concentrations, notably restrictions on permissible activities of systemic institutions. For
instance, in the United States, part of the Dodd-Frank Act known as the “Volcker Rule”
prohibits insured depository institutions from engaging in proprietary trading. The Act also
assigns new powers to the Federal Reserve to require divestment by firms subject to enhanced
prudential standards under the Act of certain assets or businesses if their orderly resolution
cannot be assured.
6.

Remaining challenges

Efforts to strengthen system-wide oversight and macroprudential policy frameworks aretaking place at national, regional, and international levels (Box 1).The conduct of effective
macroprudential policy requires further progress on a number of fronts, from design andcollection of data to support systemic risk identification and modelling, to techniques andanalytical tools to assess systemic risk, to design of an effective macroprudential toolkit andits use within well specified institutional and governance arrangements.

Box 1. Surveys on Macroprudential Policy Institutional Arrangements and Frameworks
In November 2009, the Committee on the Global Financial System (CGFS) launched a project to examine
conceptual issues that arise as macroprudential policy frameworks are developed and applied. The project
included a survey of central banks’ conceptions of macroprudential policy and its various elements, and of
the instruments that had been used in their jurisdictions for macroprudential purposes.
The CGFS survey suggests that macroprudentially motivated interventions have been fairly widely used.
They have targeted a variety of problems arising from the financial system and financial behaviour, at bothaggregated and highly sector-specific levels. Instruments such as caps on loan-to-value ratios in property
lending have been used fairly often in response to property market exuberance, and seem to have shieldedbanking systems from severe property market downturns. A number of measures in emerging economies
targeting excessive risk-taking or the build-up of vulnerabilities in property lending markets were seen as
having been successful in protecting banking system resilience during property market cycles. To date,authorities have taken pragmatic approaches, based on judgmental and discretionary use of instruments
already used for other, typically microprudential, purposes. The report concludes that in developing
macroprudential policy frameworks further, the design choices open to authorities will depend on theireconomic and financial system structures, as well as prevailing law and market practices.1
In mid-2010 the CGFS followed up on this stocktaking with an analysis of some practical matters in thedesign and conduct of macroprudential policies. This more recent work looks at the systemic risk

9

developments in key economies in the lead-up to the crisis, and examines how macroprudential authorities
could have acted to reduce those risks, given what was known at the time. These case studies suggest that,in some areas, macroprudential authorities with suitable mandates could have intervened, for example withcapital or liquidity requirements or restraints on particular kinds of risk-taking, to respond to some of theidentified systemic risks. However, the case studies also show that other systemic risks, such as the growthof the shadow banking system and dependence on cross-currency funding, were either missed or not fully
appreciated at the time. Overall, the CGFS concludes that there is clear scope for progress in thedevelopment of macroprudential policy and sets out priorities for the development of macroprudential
policies, notably in the areas of systemic risk monitoring, including interlinkages between financial
institutions and markets; the design of macroprudential instruments; international information-sharing; theinstitutional set-up of macroprudential policy and the related governance and accountability arrangements;
and communication strategies.
The institutional arrangements for macroprudential policy are evolving in a number of countries, reflectinga refocusing on financial stability as a key policy objective and a greater appreciation of the need for afinancial regulatory architecture that is conducive to attaining financial stability.
The IMF conducted a survey among some 60 member countries in late 2010 to take stock of existing
analytical approaches to systemic risk identification and monitoring, the use of macroprudential tools, andthe institutional setup for macroprudential policy. The results of the survey are currently being analysedand further detail will be available shortly. Most of the surveyed countries have an explicit financial
stability mandate, and slightly less than half of them (most of which are from emerging market countries)
have an explicit mandate for macroprudential policy. Plans to introduce a mandate for macroprudential
policy are also widespread. A wide range of policy instruments are mentioned as being available formacroprudential policy—primarily prudential tools, but also instruments of fiscal, monetary andcompetition policies as well as capital controls. Efforts to introduce institutional arrangements for systemwide oversight and macroprudential policy are taking place in several countries, though the specific set-up
can vary significantly. In line with the notion that central banks can bring strong expertise and incentives tothe task of mitigating systemic risks,2 the survey indicates that the central banks are given a financial
stability mandate in most of the countries (90%) that responded to the survey.
The survey also confirms that the conduct of macroprudential policy often involves inter-agency
coordination. As a way to institutionalize macroprudential policy coordination, a growing number ofcountries (44%) have in place or are establishing a financial stability committee or council. The committee
or council can be given direct powers over specific macroprudential tools, as planned in the United
Kingdom. It can alternatively or in addition be given some degree of control over actions taken by other(constituent) agencies. This can range from providing policy advice, making formal recommendations totaking direct decisions on policy actions. The committee or council can finally provide governance for
specific macroprudential action taken by constituent agencies, as envisaged in the United States.
_________________
1
2

See “Macroprudential instruments and frameworks: a stocktaking of issues and experiences”, CGFS Papers, no. 38, 2010.
IMF, Central Banking: Lessons from the Crisis, 2010.

The development of policy in several areas has still some way to go. In particular the designof national and regional institutional arrangements faces a number of challenges.
First, as the financial sector evolves rapidly, the specific sources and manifestations ofsystemic risk are subject to change. As a result, the conduct of macroprudential policy calls
for continuous monitoring of a broad set of information, to identify systemically important
institutions, markets, and infrastructures on an ongoing basis; and to capture firms that might
be outside the perimeter of regulation and supervision, and new products created through10

financial innovation. And authorities need to be able to respond flexibly to risks. Extending
the perimeter of regulation is one option to expand the reach of policy and to lower the risk ofregulatory arbitrage. In this respect, also, the unintended consequences of policy measures
addressed at subsets of the financial system may need to be considered, including diversion offinancial intermediation to the unregulated sector. The FSB is presently working to (i) clarify
a working definition of the shadow banking system; (ii) set out potential approaches for amonitoring framework; and (iii) develop a range of options of possible additional regulatory
measures.
Second, there is a need for continued work to identify the quantitative tools that are mostuseful to measure and monitor systemic risks, and to fill the key analytical gaps in this area,
including possible adverse consequences of using some tools (e.g., administrative measures).
Key priorities in this regard are the capacity to capture the main risks in a forward looking
manner; robustness in assessing both the likelihood and impact of shocks; and ease of use(e.g., data availability) and interpretation for policy-making purposes.
Third, there is a need to put in place appropriate governance arrangements. Not least, sincemacroprudential policy involves managing tail risk (the incidence of a financial crisis), thebenefit of taking an action becomes apparent only in the long run, while the costs will often behighly visible and felt immediately. This may lead to a strong bias in favour of inaction. Thisbias can be further exacerbated by lobbying on the part of financial institutions and by otherpolitical pressures. It puts a premium on governance arrangements for the chosen institutionalframework that strengthen the policymaker’s ability and willingness to act. Strong governancearrangements require: clear and specific mandates for the powers of macroprudential policy
making; control over macroprudential instruments that are commensurate with thosemandates; arrangements that safeguard the necessary operational independence; andprovisions to ensure accountability, supported by transparency and clear communication ofdecisions and decision-making processes.
Fourth, the institutional set-up for macroprudential policy needs to support domestic policy
dialogue among different authorities, as the range of instruments that can affect systemic risk
extends beyond that which may be under the formal authority of the macroprudential body.
The choice and implementation of appropriate instruments in a macroprudential frameworkneeds to take into account their interaction with other key policy objectives and instruments,
such as those governing microprudential, monetary, fiscal, competition policies, and policies
to manage risks from capital inflows (see Annex). This issue requires arrangements that candeliver good communication among the various authorities and governance frameworks thatclearly assign responsibilities and roles. Because of potential synergies and possible tensions
between macroprudential and other public policies, the main challenge is how to set up aframework to support policy consistency across the authorities responsible formacroprudential and other policies. Solutions will need to be tailored to country-specificcircumstances.
Finally, as the stability of the financial system often has regional and global dimensions, themultilateral aspects of macroprudential policy will need to be fully considered, including by
ensuring that frameworks in individual countries are mutually consistent, while taking into
account country-specific circumstances. One important question in this respect is what room
for manoeuvre individual countries would have within the agreed international framework.
This highlights the importance of information sharing and cooperation arrangements among
11

national and regional macroprudential bodies. The arrangements would reinforce the efficacyof global cooperation mechanisms, such as the FSB and the G20 Mutual Assessment Process
as well as the IMF multilateral surveillance.
7.

Conclusions and work going forward

The previous section has outlined the programme of work underway to fully develop andoperationalise macroprudential policy frameworks. To support this work, in the coming
months, the FSB, IMF and BIS will primarily focus on the following priorities:

continuing to pursue the analytical challenges outlined above;continuing to distil from stocktaking exercises, surveys and contacts with national andregional authorities, the lessons for the development of policies and frameworks; andproviding forums for authorities to learn from each other, to share perspectives andexperiences in implementing macroprudential policies, and to enhance cooperation in
their responses to systemic threats which pose material risks to the international
financial system.

The three organisations will submit a joint progress report, outlining advances in the state ofknowledge and covering both international and national developments, to G20 leaders at theirNovember 2011 Summit.

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Annex: Managing risks from capital inflows
Capital inflows are normally beneficial, but can at times pose challenges. In particular,
macroeconomic imbalances and systemic vulnerabilities stemming from large inflows havelong been of concern to policymakers. The macroeconomic effects of large inflows include
overheating of the economy and appreciation of the currency, which can reduce
competitiveness.
From a macroprudential perspective, the relevant concern is the contribution of capital inflows
to the build-up of systemic vulnerabilities, by facilitating the build-up of imbalances in thefinancial and non-financial sector, unsustainable asset price booms, and financial sector
distress as flows stop or reverse direction.
These issues are currently being examined in detail by the IMF, with a view to further
developing guiding principles for the use of policies to manage capital flows, both from theperspective of individual countries and taking into account the multilateral dimension.
Macroeconomic policies can be used to address the risks from large inflows.
If these policies are not sufficient, prudential tools and in some circumstances, also capital
controls can be used.
Some prudential tools can reduce potential systemic risks associated with capital inflows
without targeting inflows per se. These tools differ from capital controls in that they do notdiscriminate between residents and non-residents. One example is a countercyclical capital
buffer linked to the build-up of credit, which could be triggered by a broad indicator of credit
growth that captures both domestic and foreign provision of loans. A second example is capson LTV and debt-to-income ratios, which would discourage an erosion of lending standards.
In addition, a levy or charges on short-term wholesale funding could also potentially
discourage overreliance on vulnerable wholesale funding, irrespective of whether that funding
is sourced domestically or from abroad.
Macroprudential tools can also be used to reduce indirectly systemic risks in the non-financial
sector associated with capital inflows. Korea’s leverage cap on banks’ off-balance sheet
foreign exchange positions introduced in June 2010 aims to achieve this objective.
Capital controls are motivated by various considerations, both macroeconomic and financial.
As such, they are not macroprudential instruments, although they could be if they specificallytargeted systemic risk and were underpinned by strict governance arrangements that ensured
no slippage in their use (see main text)
Given that policies to manage capital inflows can have significant international repercussions,the multilateral aspects of these prudential or capital control measures will need to be fully
considered, along with their effectiveness. Some countries have subscribed to international
instruments that limit their ability to use capital controls, but even those that have not willneed to be aware of the broader implications of such measures for the international monetaryand financial system, and reflect this in their policy governance.

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