Watching the watchers: forward-looking assessment and
challenge of a central bank's own financial risks
Speech given by
Andrew Hauser, Executive Director, Banking, Payments and Financial Resilience
At the GARP 18th Annual Risk Management Convention, New York
7 March 2017
Introduction
Thank you very much for the opportunity to speak to you today.
The theme of this conference has been how to understand, and respond to, ever more diverse risks: from
the rise of populism and geopolitics to the opportunities and threats of new technology; from new forms of
financial risk in banks, capital markets and further afield, to the latest trends in stress testing.
Central banks of course worry about these things too, in pursuit of monetary and financial stability. Indeed
we are so good at worrying, we may be one of the few groups of people that can make Chief Risk Officers
look chilled out by comparison! But historically, for the Bank of England at least, much of that anxiety has
been outward-facing, focused on the ways in which private sector balance sheets might overheat, rather than
on our own financial exposures. And that reflects the fact that for long periods in the past, our market
operations were relatively simple and low-risk.
All of that has changed in recent years as central banks have taken exceptional actions to stabilise
economies and financial systems, driving a huge expansion in the scale and complexity of our market
operations and balance sheet exposures. Those actions have delivered vital policy outcomes. But they
have also led to entirely appropriate demands for central banks to demonstrate the highest levels of
professionalism, transparency and accountability in their management of what are, ultimately, public
exposures.
As Executive Director at the Bank of England in charge of our second line financial risk function, I want to
explain how we have responded to these developments: setting out the new framework, structures and tools
-
that we have put in place to monitor and challenge our own financial risk and illustrating them with some
practical case studies. A central goal of our work has been to apply the latest thinking in private sector risk
management wherever we can. But that has also highlighted a number of areas where central banks have
to handle risk in very different ways to commercial banks. Drawing out those similarities and differences will
be a key subsidiary theme of my remarks, and will I hope help frame a lively discussion later in our session
today.
Central banks as financial firefighters
Let me start with two of the most profound differences, because they colour everything that follows.
The first is that central banks use their balance sheets not, like commercial banks, to generate
economic returns for their shareholders, but to deliver the policy goals of monetary and financial
-
stability. That may sound innocent enough: dull even. But that would be misleading because
-
maintaining stability means central banks must be prepared to act like financial firefighters rushing into
burning buildings (taking on certain types of financial risk) when everyone else is rushing out.
That dynamic is clearest when central banks act as lenders of last resort: stepping in to provide temporary
liquidity (to individual firms, or the market as a whole) when private liquidity providers take fright. They are
uniquely able to do this because their ability to create fiat money means they face no liquidity risk in their
own currencies of issue. Of course, central bankers go to great lengths to limit the other forms of risk they
take on in such circumstances: lending only to institutions assessed as solvent and viable; taking
high-quality collateral, with conservative haircuts; charging suitably penal interest rates; and typically lending
only for limited periods. But they can still find themselves lending, sometimes in large size, when everyone
else prefers not to, in order to limit the financial instability that would be caused by wider contagion.
- -
That inversion of the normal definition of risk tolerance illustrated schematically in Chart 1 is strike one
against the risk professional's standard operating manual.
Strike two comes from the fact that central banks are not subject to financial solvency constraints in
the way that commercial banks are. And that, again, is because their ability to create fiat money means
they can always meet liabilities denominated in our own currencies. As a result, there is nothing impossible
about a central bank trading with negative capital. Indeed, some (particularly those defending foreign
exchange rate pegs) have done just that (Table 1).
Chart 1: Central banks as financial firefighters Table 1: Example central bank equity ratios
Equity /
Risk Total assets
Private
tolerance
financial
(%)
system
European Central Bank 16
Swiss National Bank 10
Bank of Japan 2
US Federal Reserve 1
Bank of England 1
Bank of Israel -6
Central banks
Central Bank of Chile -7
Degree of
Normal Liquidity
systemic
conditions crisis
Source: International Monetary Fund; Bank of England; central
stress
bank financial statements
Equity and total assets are measured on an accounting basis
so do not account for factors such as off-balance sheet
exposures or government indemnities. Balance dates are
February 2016 for the Bank of England, March 2016 for the
Bank of Japan and end 2015 for other central banks.
But before you all rush to sign up as central bank Chief Risk Officers, free forever from the headaches of
commercial capital management, a word of caution. Central banks cannot create money willy-nilly without
imperilling inflation, undermining their own monetary stability goals. They typically only lend large amounts
-
on a secured basis so their lending is limited by the supply of collateral available in the private sector. And,
perhaps most profoundly of all, weakly capitalised central banks may find it hard to convince markets that
they retain the ability to pursue their broader policy objectives without potentially costly recourse to fiscal
-
resources, or further currency debasement. These limits on central bank balance sheet expansion
sometimes referred to as 'policy solvency' constraints1 -
can be every bit as binding as financial solvency
requirements.
Recent developments in the Bank of England's own financial risks
Despite central bankers' readiness to enter burning buildings, and the lack of a binding financial
solvency
constraint, the Bank of England's balance sheet was actually very modestly sized in the decades leading up
the financial crisis, at less than 5% of UK GDP (Chart 2). The Bank did provide emergency assistance in the
mid-1980s and early 1990s2, but (by recent standards at least) those exposures were small and short-lived.
Other than that, the Bank primarily held high quality, low-duration assets to back a relatively stable stock of
sterling banknotes and commercial bank reserves. Financial risk management - though always core to the
Bank's thinking -
was not a particularly complex or resource-intensive activity.
1
For more on this issue, see for example 'Central bank financial strength, transparency and policy credibility' by Peter
Stella (IMF Staff
Papers, Vol. 52, No.2), available at https://www.imf.org/external/pubs/ft/wp/2002/wp02137.pdf
and 'Central bank finances' by David Archer and Paul
Moser-Boehm (BIS Papers, No.71), available at
www.bis.org/publ/bppdf/bispap71.htm.
2
Bank of England Report and Accounts 1985
See page 31 of the
(http://www.bankofengland.co.uk/archive/Documents/historicpubs/ar/1985accounts.pdf) and Balluck, K, Galiay A, Ferrara, G and
Hoggarth, G (2016), 'The small bank failures of the early 1990s'
(http://www.bankofengland.co.uk/publications/Documents/quarterlybulletin/2016/q1/a5.pdf).
Chart 2: Bank of England balance sheet Chart 3: Federal Reserve and Bank of England
balance sheets compared
Percentage of annual nominal GDP(a)
30 30
Percentage of annual nominal GDP
30 30
World
World
25 25
War II
War I
25 25
US Federal Reserve (b)
20 20
20 20
Bank of England (a)
15 15
15 15
10 10
10 10
5 5
5 5
0 0
0 0
1830 1860 1890 1920 1950 1980 2010 1830 1860 1890 1920 1950 1980 2010
Sources: Bank of England, ONS
Sources: Bank of England, Federal Reserve, U.S. Bureau of
Labour Statistics, ONS and Samuel H. Williamson (2017),
(a) Data as at February. Final data point shows the latest
'What Was the U.S. GDP Then?'.
published balance sheet data, at 29 February 2016, plus the
increase in the loan to the Asset Purchase Facility since this
(a) Data as at February. Final data point shows the latest
time. Excludes TARGET balances held at the Bank by
published balance sheet data, at 29 February 2016, plus the
European central banks in 1999-2001.
increase in the loan to the Asset Purchase Facility since this
time. Excludes TARGET balances held at the Bank by
European central banks in 1999-2001.
(b) Consolidated assets of all Federal Reserve banks. Data
as at end December.
Three key developments disturbed that calm, and led to the introduction of our new financial risk framework.
huge increase in the size of the Bank's balance sheet
The first was the following the start of the financial
crisis. Today the Bank of England holds assets worth about a quarter of UK annual GDP: a five-fold
increase on a decade earlier (Chart 2). In the early part of the financial crisis, much of that increase
reflected large scale liquidity assistance to the banking sector. For example the Bank lent £61.5bn to RBS
and HBOS in 2008-93, and its market-wide Special Liquidity Scheme peaked at £185bn in 20094. More
recently, the balance sheet expansion has primarily reflected outright asset purchases and long-term lending
schemes of unprecedented scale and duration, designed to deliver monetary stability when interest rates are
close to zero. Other major countries have seen increases of similar scale: Chart 3 for example compares
the expansion in the Bank's balance sheet with that of the US Federal Reserve.
These expansions, though primarily focused on maintaining monetary rather than financial stability, are
arguably further examples of the central bank as firefighter: injecting liquidity when other market-based
in the size of the Bank's balance sheet
channels are blocked. Chart 4 shows how closely the increase
mirrors the decrease in the scale of sterling lending to households and firms by UK banks in recent years: a
strikingly similar picture to the stylised relationship in Chart 1.
3
For a discussion, see for instance Ian Plenderleith's Review of the Bank of England's Provision of Emergency Liquidity Assistance in
2008-09 (http://www.bankofengland.co.uk/publications/Documents/news/2012/cr1plenderleith.pdf).
4
See John, S, Roberts, M and Weeken, O, 'The Bank of England's Special Liquidity Scheme'
(http://www.bankofengland.co.uk/publications/Documents/quarterlybulletin/qb120105.pdf).
Chart 5: Permanent shift in the Bank's firefighter role?
Chart 4: UK central and commercial bank
balance sheets
Risk
Private
tolerance
financial
Percentage of annual nominal GDP
system
120 120
110 110
100 100
90 90
80 80
Financial institutions - lending to private
Open for
70 non-financial sector (a) 70
business
60 60
50 50
Unconventional
Central banks MP
40 40
30 30
Degree of
Normal Liquidity
Bank of England(b)
systemic
conditions crisis
20 20
stress
10 10
0 0
2005 2008 2011 2014 2017
Sources: Bank of England, ONS
(a) Data as at February. Sterling net lending to non-financial
corporations and household sector.
(b) Data as at February. Final data point shows the latest
published balance sheet data, at 29 February 2016, plus the
increase in the loan to the Asset Purchase Facility since this
time.
The financial instruments underpinning these expansions tend not to be particularly complex when compared
to those on commercial bank balance sheets. But the Bank of England has also accumulated material new
contingent exposures, reflecting its much wider post-crisis range of policy responsibilities, and a more
comprehensive liquidity insurance toolkit. The Bank's new responsibilities for banking supervision,
macro-prudential policy and resolution imply a range of potential new calls on its balance sheet. And
operational reforms designed to address the deficiencies in the Bank's
pre-crisis lending tools and flag
clearly that the Bank was 'open for
business'5, have left the Bank capable of lending to a wide range of
banks and non-banks, against many different types of collateral, at lower prices, and through a broad range
of facilities. As of 2016, members of the Bank's Sterling Monetary Framework -
our main liquidity-providing
- the UK's total stock of
tool had pre-positioned over £400bn of collateral with us, including 30% of
household mortgage loans. Only a fifth of that collateral had been drawn against, through the Funding for
Lending Scheme and other Bank facilities. Even after accounting for the Bank's sizeable haircuts, that
leaves well over £250bn of available credit: a much higher proportionate level of contingent exposure for the
Bank than typically incurred by commercial banks through undrawn facilities. So our balance sheet may
stress: the Bank of England's role as
expand in both scale and riskiness at times of heightened liquidity
financial firefighter has shifted permanently upwards (Chart 5).
5
and the Bank's new framework at
See http://www.bankofengland.co.uk/publications/Documents/news/2012/cr2winters.pdf;
http://www.bankofengland.co.uk/markets/Documents/money/publications/liquidityinsurance.pdf. The reforms are summarised in a
speech by the Governor at http://www.bankofengland.co.uk/publications/Pages/speeches/2013/690.aspx.
The third key driver behind our new risk framework has been the strong public demand for greater
accountability and transparency from central banks since the financial crisis. In large part, that
demand follows directly from the increased breadth and scale of central banks' responsibilities and financial
exposures. But in the Bank of England's case the desire to build a strengthened financial
risk framework
also reflects an important consequence of taking on responsibility for the micro-prudential regulation of
banks, which is that we should be willing to do unto ourselves as we would do unto others: a Golden Rule
for central bankers. And it reflects a strong desire to investigate new ways of driving innovative analysis and
lean against the risks of groupthink.
Strengthening the Bank of England's financial risk framework
The Bank has had strong first- and third-line financial risk functions for some time. An expert first-line team
assesses, prices and haircuts the wide range of collateral pre-positioned with us, monitors the specific risks
taken in live operations on a day-to-day basis, and evaluates the financial condition of our counterparties,
liaising with our supervisory colleagues in the Bank's Prudential Regulation Authority
arm6. And internal and
external auditors regularly assess the effectiveness of the Bank's financial controls.
Until recently, however, the Bank has not had a dedicated second-line financial risk function, reflecting a
perception that central banking operations did not give rise to tensions of the sort seen between profit
making and risk control in private firms. The amount of residual risk to which the Bank was actually exposed,
after taking account of large collateral haircuts and government indemnities, was also felt to be relatively
small.
As the scale of the Bank's balance sheet persisted however, it became increasingly clear that we needed to
do more to bring our risk framework up to best practice. That was for three main reasons, each linked to the
drivers I listed a moment ago. First, the increasing complexity of the Bank's operations meant that we
needed more effective ways to measure the risks we were taking, add them up across the different specific
operations, and evaluate them against an explicit statement of the Bank's risk tolerance. Second, the
increasingly contingent nature of our risks meant we needed much better forward-looking tools for evaluating
how those risks might crystallise in different scenarios, and ensuring we had sufficient resources to respond.
And, third, the need to hold ourselves accountable, identify potential blindspots and safeguard against
groupthink in our internal work, required more effective internal challenge and reporting mechanisms.
In the summer of 2015, we therefore set up a brand new second line financial risk challenge function, staffed
using some of our risk experts who previously helped the PRA to challenge commercial banks: bringing the
'Golden Rule' to life. We developed a framework of risk tolerance, measurement, assessment, reporting and
challenge tools across the full range of credit, market, counterparty and liquidity risks facing the Bank, basing
6
on these functions are available in the Bank's annual report on the Sterling Monetary Framework, available at
More details
http://www.bankofengland.co.uk/markets/Documents/smf/annualreport16.pdf.
them where possible on industry best practice. And we agreed a new governance structure, giving the
second line a key role as independent counsel to our Board's Audit and Risk Committee, establishing a new
Executive Risk Committee and working-level challenge forums, and securing space for risk challenge on all
new policy proposals.
Now all of this will sound very familiar to you as risk professionals - and that in a sense is the point. In some
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cases, it is just central banks catching up! But in other cases we have had to blaze a new trail reflecting
the unusual nature of some aspects of risk management at a central bank. To illustrate those points, let me
take you through a few brief case studies of specific issues we have dealt with in our early months of
operation.
The new second line in action: five case studies
Purchases of government debt for monetary policy purposes ('Quantitative Easing')
(i)
The introduction of the new second line has in some cases primarily formalised and hardwired approaches
which had already been evolving as the balance sheet expanded.
By far the largest single item on the Bank's current balance sheet reflects the outright holding of some
£360bn of UK government bonds (or 'gilts') in notional terms, purchased on behalf of the Bank's Monetary
-
Policy Committee as part of the implementation of their unconventional monetary policy often known as
'quantitative easing'. This is by any standards a large portfolio - amounting to about a third of the total stock
'PV01' -
of conventional gilts in issue, with an average duration of 12 years, it has a so-called or valuation
-
sensitivity to a one basis point movement in average interest rates of about £450mn7.
Now an open position of this size would be many times larger than even the most aggressive traders in this
room would dream about running themselves. Your natural instinct as a risk professional if you came across
this in the private sector would probably be to seek an immediate reduction in the position, or a hedge in the
market. But any attempt to do this would undermine the very policy objective of the Monetary Policy
Committee in pursuit of their 2% inflation target: ie to induce a portfolio shift into riskier assets by removing
duration from the market. As I noted earlier, this is a classic example of the central bank policymaker as
fireman.
What then is the role for the central bank financial risk function? For the new second line, it is a classical
watching brief. Its first duty would have been to ensure there were sufficient resources to back the risk. In
this case, that was achieved some years ago by placing the portfolio in a separate subsidiary of the Bank
7
For more details on the current composition of the APF gilt portfolio and the operations, see
http://www.bankofengland.co.uk/markets/Pages/apf/gilts/results.aspx.
The Bank's exposure then consists simply of an overnight loan to that
backed by a government indemnity8.
subsidiary, matched against its primarily short-term liabilities (Table 2 illustrates this using the last published
accounts), and the government has a natural hedge for its indemnity in that changes in interest rates have
partly offsetting effects on the value of the indemnity and the cost of new debt issuance.
The other task for the second line financial risk function is to ensure that there is adequate transparency for
policymakers, government and the public over how the exposures can change over time, under different
-
scenarios, so that future decisions are made with full information. That is done as it has been since the
- through multiple channels, including periodic internal reports to the Bank's
onset of quantitative easing
Court and HM Treasury, and external analysis and data, including in the Bank's Quarterly Bulletin and the
BEAPFF annual accounts. As of January 2017, the fund had generated about £70bn9 in net interest income,
sufficient to cover the mark-to-market impact of a material increase in interest rates.
Table 2: 2015/16 Bank of England and BEAPFF balance sheets10
8
For more details, see the Bank of England Asset Purchase Facility Fund Limited Annual Report at
http://www.bankofengland.co.uk/publications/Documents/other/markets/apf/boeapfannualreport1606.pdf.
9
Not including unrealised mark to market profits. Data available in Appendix A of
https://www.ons.gov.uk/economy/governmentpublicsectorandtaxes/publicsectorfinance/bulletins/publicsectorfinances/jan2017.
10
See http://www.bankofengland.co.uk/publications/Documents/annualreport/2016/boereport.pdf and
http://www.bankofengland.co.uk/publications/Documents/other/markets/apf/boeapfannualreport1606.pdf.
Forward looking stress tests of the Bank's financial exposures
(ii)
If the first case study illustrated an example where risk was already being actively evaluated, my second
illustrates a completely new area of activity.
The concept of enterprise-wide stress tests has transformed private sector thinking on risk management in
recent years, driven in many cases by central bank regulators. The Bank of England conducts an extensive
-
annual supervisory stress testing programme in the United Kingdom and I note with interest the
discussions taking place elsewhere in this conference on the potential to expand such exercises well beyond
banks, something we have also been considering11.
But, ironically perhaps, the Bank of England has not until very recently applied such techniques to its own
balance sheet. That made sense when large-scale balance sheet expansions were expected to be rare and
permanent shift in the Bank's firefighter role illustrated in
highly idiosyncratic. But the more Chart 5 suggests
we need a more sophisticated, agile forward-looking way of evaluating the risks we might face, and
(importantly) the resources required to deal with them. Development of a suite of stress tests has therefore
been a core part of the early work of the new second line team.
To shape this work, key judgments are required on 'the 3 'S's': Scope, Scenarios and Severity.
Scope
describes the range of facilities that the Bank might be called upon to use. This is a challenging judgment for
-
an organisation specialising in tail risk insurance, and with a broad policy remit but initially we have focused
on the public commitments to provide market-wide and firm-specific liquidity insurance through the Bank's
current set of facilities and operations. The scenarios we have so far explored are also consistent with this
scope, and include examples of both domestic and international shocks, affecting banks, non-banks and
capital markets. Wherever possible these are based on the scenarios used by the Bank's
supervisors in
their work with industry, but with typically higher severity: consistent with the assumption that firms should
be capable of surviving supervisory stress tests using their own resources. It is only when firms' liquidity
needs go beyond the level that could reasonably be covered by their own resources that the central bank is
called upon to act in size: the image of the firefighter in action once again.
So what do we do with the results of this work? In the private sector, of course, stress tests are used to
inform desired capital levels, and that is certainly something we consider too. But they can also have a wider
influence, as we found last year when we ran an exercise to evaluate the potential implications of uncertainty
surround different possible outcomes of the UK referendum on membership of the European Union. The
results of that work helped to inform judgments on collateral pre-positioning and haircuts, engagement with
fellow central banks, and our own supervisory actions and conversations. Most importantly of all, it
confirmed that the Bank had sufficient lending capacity in place to meet an extremely severe liquidity shock,
11
See for instance: http://www.bankofengland.co.uk/publications/Documents/speeches/2017/speech960.pdf.
which allowed the Bank to make reassuring statements about its readiness to act. In the event no such
shock occurred. But the Bank's preparedness played a part in that. Just as we expect firms to be ready for
the unexpected, we hold ourselves to the same standard.
Indeed this exercise drove home an important broader point: for central banks to be effective watchmen (all
the time) and firefighters (occasionally), we first need private sector risk managers to have drawn up (and
shared with us) their own fire precaution and exit route plans. Without a good understanding of firms'
potential liquidity needs under stress, their alternative sources of liquidity and available collateral we cannot
fully evaluate our own capacity to lend. This sort of liquidity planning under stress is I know an increasing
focus for both banks and non-banks alike, and is something we would actively encourage.
Calibrating the Bank's own capital
(iii)
I mentioned at the start of my remarks that central bank capital is different to that of a commercial bank:
central banks need to meet a 'policy solvency' rather than a 'financial solvency'
test. It also sits at the base
of a particularly steep waterfall: since any loss in a lending operation would be expected to be met, first by a
solvent firm's own resources, second by the central bank's collateral haircuts, and only then by its capital.
Any loss beyond that implicitly falls to the government, as the ultimate owner of the central bank (Chart 6).
Chart 6: The central bank capital waterfall
banking system Central bank General Government
balance sheet
Probability
Risk-sharing with the
Self-insurance Haircuts
Treasury
Capital
More severe
losses
Central banks across the globe differ in how they divide up this pie. In the UK, the Bank of England operates
with a relatively low level of capital, and has few means of rapidly replenishing that capital if it is depleted
(Chart 7). As a result it has tended to rely heavily on UK government indemnities for its larger operations,
easing example I gave a few moments ago. The Bank's measured leverage ratio is
such as the quantitative
just 1%, reflecting the fact that it supports a balance sheet of around £1/2tn on less than £3bn of equity.12
But the ratio for its non-indemnified balance is materially higher, reflecting the significant role played by
indemnities.
Chart 7: Central bank capital replenishment tools13
The costs and benefits of these arrangements are quite subtle, and rest heavily on the extent to which the
markets and wider public perceive the Bank to have the means to deliver its substantially expanded remit
effectively without recourse to money creation, both in today's market conditions and in stressed
conditions14. Comprehensive stress testing, together with the other elements of the forward-looking toolkit
12
This capital figure consists of 'Capital and Retained Earnings'. It does not include 'Other Reserves' of £1.6bn which are
included in
accounting capital, but not considered loss-absorbing for regulatory purposes. For more details see
http://www.bankofengland.co.uk/publications/Documents/annualreport/2016/boereport.pdf.
13
Taken from BIS Papers No.71 (see footnote 1).
14
IMF's most recent UK Financial Sector Assessment Program review: see Box 1 on p.12 of
These issues are also discussed in the
https://www.imf.org/external/pubs/ft/scr/2016/cr16159.pdf.
developed by the Bank's new second line function, have improved our ability to assess the adequacy of
these arrangements considerably.
(iv) Risk tolerance, limits and thresholds
Board-level risk tolerance statements, and the specific trading and lending limits associated with them, are
amongst the risk manager's most powerful tools. But the calibration of both is an art as much as a science,
reflecting the difficulty of defining precise tolerance measures, and (in commercial banks) the inevitable
tension between revenue-generation and risk- or capital-reduction goals.
Applying these tools to central banking operations is both easier and harder than in the private sector.
Easier, because there is no tension between profit and risk: central banking operations are always designed
with risk in mind from the start. But harder, because the events in which central banks are called on to act
often lie in the very tails of the distributions, making it hard - often impossible - to calibrate risk tolerance
using historic data. And many of our operations are not discretionary, but reflect policy imperatives: so
binding risk limits which, if applied, might cause a policy to be aborted mid-course, have little chance of
success.
At the Bank of England, we have responded to these challenges in three ways. First, we have adopted a
risk tolerance that, though qualitative in nature, recognises the importance attached to the safeguarding of
public resources and the priority placed on ensuring that policy decisions are always made in full knowledge
of the financial risk implications. As I have described, maintaining monetary and financial stability - the
Bank's policy mission -
can sometimes mean we have to take on material levels of risk ourselves. But
where we do that, we should take on no more risk than is necessary, and we should do so with our eyes
open, conscious too of the tradeoffs between financial and non-financial risk. Second, as I have already
discussed, we have developed a toolkit for analysing how far different levels of financial resource can
support the Bank's operations under a range of severe but plausible shocks. And, third, we are in the
process of designing a tiered, enterprise-wide framework of limits and thresholds, consistent with the
resources available to the Bank, which (i) imposes macro-level limits that protect our capital base and (ii)
sets a series of early-warning thresholds. These thresholds will not immediately constrain live
non-discretionary operations, but they will flag buildups of risk concentrations and trigger internal discussion
and review on whether the increase in risk is warranted by policy objectives. That could lead to adjustment
of policy parameters, changes to the Bank's financial
resources or use of alternative Bank policy levers to
mitigate the underlying risks. At a more granular level, nested within these balance sheet wide thresholds,
the first line has discretion to impose hard limits on particular discretionary operations where it is feasible to
do so (eg. on the Bank's limited
own-funds foreign exchange reserves operations).
(v) Challenging new policy initiatives
One of the most profound changes to private sector risk management practice since the financial crisis has
been the near-universal introduction of processes to ensure that the business and risk implications of new
and sometimes complex products are fully understood before they can be launched.
Central banks are unlikely to come with anything as complex or potentially toxic as the CDO-squared or
cubed! But as I have covered in some detail, central bank operations frequently pose complex risk issues of
their own. Take the example of the collateral available to support our contingent lending for liquidity support,
and how to estimate the central bank's exposure to that. The closest this would get to in a commercial firm is
a Potential Future Exposure (PFE) calculation. However most risk managers are used to considering PFE in
-
the context of counterparty exposure through OTC derivatives instruments which is challenging enough!
But for us the underlying instrument is not a derivative product with a reasonable amount of pricing
information available: it is a set of non-traded mortgage portfolios, which have to be marked to market today
and at future points in time. So this is wha