Bandid Nijathaworn: Rethinking procyclicality - what is it now and what
can be done?
Presentation by Mr Bandid Nijathaworn, Deputy Governor of the Bank of Thailand, at the
Bank for International Settlements/Financial Stability Institute-Executives' Meeting of East
Asia-Pacific Central Banks (BIS/FSI-EMEAP) High Level Meeting on "Lessons Learned from
the Financial Crisis - An International and Asian Perspective", Tokyo, 30 November 2009.
* * *
First, let me thank FSI and the EMEAP Working Group on Banking Supervision for the
invitation, and also a special thanks to our host, the Bank of Japan and the Financial
Services Agency, for the excellent arrangement.
The topic of this session is procyclicality and macroprudential supervision. As the first
speaker, I have been asked to give an overview of the issue. A good starting point to discuss
the issue is to remind ourselves that the issue of procyclicality, especially procyclicality of the
financial system, is not new. Discussion about interactions between the financial system and
the real economy, especially the idea that the financial sector can amplify economic activities
and business cycles, has been well documented by economists, for example, in the financial
accelerator model.
Here in Asia, the issue of procyclicality had been brought to the fore during the Asian
financial crisis, after which the issue was extensively discussed. Two important conclusions
emerged from those early discussions. First, procyclicality of the financial system poses risk
to financial stability, and to address it, efforts call for policy to dampen the procyclical effects
through counter-cyclical financial regulation and macroprudential measures. Second, to
avoid large build-up of excesses, macroeconomic policy especially monetary policy has an
important role to play. And in the case of emerging markets, the procyclical behaviour of
international capital flows adds another dimension of challenge because of its effects on
domestic monetary conditions. Hence, to effectively address the issue, a combination of
macroeconomic policy and financial regulation is needed to restrain the build-up of
imbalance, a process to which procyclical financial behaviour is a key contributing factor.
The current financial crisis also raises the issue of procyclicality. Apart from its global nature,
a key feature of the current crisis when compared with past crises is the scale of excessive
risk-taking and leverage that took place that was accentuated by procyclical financial
behaviour. This, therefore, puts the issue of procyclicality and financial regulation into the
policy spotlight.
What I want to do this afternoon is to discuss procyclicality and the policy approach to
address it from a wider perspective of macroeconomic management aimed at ensuring
financial stability. My focus is to offer a framework for analyzing procyclicality, and to propose
a view that policies from different orientations, especially financial regulation, are needed to
deal effectively with the issue.
In its simplest form, procyclicality refers to the interactions between the financial system and
the real economy which are mutually reinforcing. Such interactions tend to amplify the
amplitude of the bussiness cycle, thereby heightening the risk to financial stability. This
description of procyclicality presupposes the existence of two cycles, namely the business
cycle and the financial cycle, that interact and reinforce each other. However, economic and
financial decisions underlying the two cycles are not independent. They are inherently linked
by the risk-taking behaviour of economic agents: the behaviour which is prone to change in
response to incentive, perception of risk, regulation, and new information. It is this change in
risk-taking behaviour that explains large swings in investor sentiment, from a period of
optimism when risk is disregarded to a period of pessimism when there is no willingness to
take risk. And it is this change in risk-taking behaviour that underscores the abrupt change in
financial behaviour, and in the direction and momentum of economic activities.
It follows therefore that procyclicality is a mechanism that encompasses the interactions of at
least three reinforcing cycles that move in tandem. They are the business cycle, the financial
cycle, and the cycle of risk-taking beheviour represented by fluctuations in asset prices or the
asset price cycle. The three cycles are self-reinforcing, and it is the ways the cycles interact
with each others that define the amplitude and the momentum of the cyclical flunctuations, as
well as risk of a financial crisis.
Interactions of the three cycles can be illustrated with reference to a typical boom-bust cycle.
In the beginning, a period of low macroeconomic volatility usually brings about an
expansionary phase of the business cycle. As the period of stability grows longer, we have
rising investor and consumer confidence, depicting a bout of optimism. The rise in optimism
leads to increased risk-taking, resulting in increased demand for credit and rise in asset
prices.
In this period of optimism, the pricing of risk tends to fall, lending spread narrows, and banks
tend to provision less as they focus more on a short-term outlook rather than a longer-term
perspective of risk. This leads to an upswing in the financial cycle. Demand for credit is
further bolstered by a rise in asset price which raises the valuation of collactoral, further
raising confidence and magnifying the risk-taking behaviour and leverage. Next, greater
availability of credit leads to more spending and adds to the expansionary forces as business
outlook is elevated by perception of low risk and strong profitability.
It is when confidence changes that the interactions of the three cycles go into reverse.
Decline in confidence closes down the risk-taking behaviour, leading to a fall in credit
demand. Banks respond to this re-assessment of risk by de-risking their financial exposure,
exacerbating the downturn in the financial cycle. This results in large adverse impacts on the
real economy that further weaken confidence. In the downturn, the three cycles interact and
move in synchronization, propagated by deteriorations in the balance sheets. It is only when
confidence improves, typically following a major policy intervention, that the downturn both in
the business and financial cycles begin to stabilize.
With reference to the current crisis, there were at least two specific features of the financial
structures in the advanced economies that amplified the procyclical tendencies in the three
cycles I have just described, thereby making the situations worse than might have been.
First, the duration of the upswing in the financial cycle was made longer by changes in the
financial structures that resulted from financial innovation, misplaced incentives, and the way
businesses had expanded by circumventing financial regulation which allowed risk to be
underrecognized for a long period. A case in point is the originate-to-distribute model, the
CDO derivatives, and the use of SIVs as a vehicle for taking risk out of banks' balance
sheets.
Second, in this crisis the downturn of the cycles were particularly damaging partly because
of the interactions or feedbacks within the financial system, as opposed to the interactions
between the financial system and the real economy. These within-the-system interactions
took the form of positive feedback loops in various market segments that were set in motion
in the downturn as market participants responded to the emerging problems and distress.
Such feedback loops included the SIV shutdown and its compounding effects on CDO
losses, the asset fire sales driven by risk management response by banks, and heightened
concern about counterparty risk that precipitated the hoarding of liquidity. Moreover, while
these feedback loops were important in setting into motion self-reinforcing losses and
deleveraging, it was also the interactions amongst them, through joint exposure to common
risk drivers and network linkages, that contributed to the multiplication of losses.
Let me now turn to the second part of my talk which I will focus on the policy approach to
deal with procyclicality.
A good starting point to discuss policy is to recognize that business cycles are a normal
feature of market economies and their existence - especially the interaction of the three
cycles - can not be eliminated. The best we can do is to recognize the cycles and find ways
to manage them in a way that markets continue to function without risking systemic
instability. Reflecting this, it is clear that the objective of policy is to reduce the amplification
of the cycles and their interactions by limiting the build-up of excesses. A common wisdom at
this time is that policy should aim to limit the build-up of excess in the good time and ensure
that the system has adequate capacity or buffers to manage the downturn in the bad time.
But because the build-up of financial excess tends to be a result of many factors, some of
which are not related to financial institutions, therefore, a broader approach to policy is
needed so that many measures, both macro and micro, are used to help solve the problem.
Apart from being more comprehensive, such approach will help ensure that the economic
cost of policy or regulation is spreaded out, thereby avoiding an undue burden falling on a
particular sector of the economy or measure.
Table 1. summarizes the policy framework along the line I have just described. The
framework encompasses a three-pronged approach to address procyclicality, focusing on
taming the business cycle, the financial cycle, and the risk-taking behaviour cycle through a
combined use of macroeconomic policy, financial regulation, and other education and
disclosure measures.
On macroeconomic policy, especially monetary policy, the role of policy is to achieve
longterm economic growth with stability. This means avoiding too-eased monetary conditions for
too long by tightening policy when there are signs that risk is being underestimated and
imbalance is developing. For financial regulation, its role is to reduce the procyclical
behaviour in the financial institutions by limiting excessive risk-taking. And the role of
education and disclosure is to promote greater awareness of risk by making available
information to improve risk assessment by market, so that extreme shifts in sentiment and
confidence are avoided. Important in this context for emerging markets is the abrupt shift in
investors' confidence that drives sudden reversals of capital flows and liquidity. But amongst
all these measures, financial regulation remains the core approach to addressing
procyclicality. This is because large and sustained booms on credit and asset prices, once
they occur, are typically a reflection of the failure of financial institutions to manage risk.
Let me now turn specifically to financial regulation. To the extent that financial regulation
contributes to procyclicality and excessive risk-taking, supervisors could design their
regulation in a counter-cyclical fashion to reduce procyclical behaviour of financial
institutions. Reflecting this thinking, discussion to date on the role of financial regulation to
address procyclicality has focused on four areas.
The first is to reduce procyclical tendencies of the Basel II capital regulation by aligning
capital requirement more with a longer-term perspective of risk. On this, key measures under
discussion include: (1) building capital buffers by capital conservation measures; (2) reducing
procyclical effects of minimum capital requirement by adopting through-the-cycle risk
parameters to achieve a less pro-cyclical capital ratio; (3) promoting forward-looking
provision that can cover loan losses that are not yet incurred but expected, with supporting
accounting rule and valuation; and (4) using additional capital charge for the large and more
complex banks based on indicators of systemic relevance.
The area of focus is the use of macroprudential supervision. The aim is to use
second
prudential measures, when needed, to restrain the build-up of risk either in the overall
financial markets or in specific asset class. Examples here include use of loan-to-value ratio
on real estate loans and margin requirements for derivatives and securities transactions.
Also, a recent idea of using leverage ratio to help take account of the unknown risk beyond
those identified by the risk-adjusted capital regulation also falls into this category.
The third area of focus is the macro-surveillance of the financial system to monitor
aggregate risk and identify structural change that opens up new vulnerabilities by making
liquidity and capital regulations less binding, thereby exacerbating the procyclical financial
behaviour. Important in this context is the subtle shifts in market due to financial innovation or
changes in business model that effectively dilute or even arbitrage regulations that are
designed to dampen procyclicality. In the current crisis, the combination of the
originate-todistribute model, together with CDOs, unregulated hedged funds, and undercapitalized
investment banks creates an interlinked market structure that adds vulnerability to the
system, by effectively removing the liquidity and capital constraints of banks in underwriting
loans and in investing in securitized products.
Finally, the fourth area is to contain incentives in the context of remuneration to limit
excessive risk-taking. The argument is that, in this crisis, misaligned incentives based on
short-term performance did encourage excessive risk-taking and contributed to increased
leverage. The solution under discussion is to align compensation scheme more with a
longer-term prespective of risk and profitability, as well as to promote greater transparency of
rewards and incentives through public disclosure.
What I have outlined is an overview of the procyclicality issue and the direction that the
current policy effort is taking to address it. My view is that, to be effective, a consistent set of
policies at both the macro and the micro levels is needed to address the issue. As I noted at
the outset, procyclicality is not a new issue. It has long been a feature of the financial system
in the market economies and always has a role to play in a financial crisis. The current crisis
is no exception. The difference this time is that efforts are being made at the global level to
systemically address the issue through the revision of international regulatory standards. The
hope is that we can make progress on the issue by taking the right and balanced approach
so that the issue can be tackled without unsettling the level playing field, without repressing
financial developments and liberalization which is important for emerging markets, and
without undermining the spirit of innovation which is the hall-mark of market economies.