Deposit insurance and moral hazard

Depositors tend to be a protected species

It is generally agreed that bank deposits have a privileged position in the financial system. There are exceptions to the rule such as NZ which, not only eschews deposit insurance, but also the practice of granting deposits a preferred (or super senior) claim on the assets of the bank. NZ also has a unique approach to bank resolution which clearly includes imposing losses on bank deposits as part of the recapitalisation process. Deposit insurance is under review in NZ but it is less clear if that review contemplates revisiting the question of deposit preference.

The more common practice is for deposits to rank at, or near, the top of the queue in their claim on the assets of the issuing bank. This preferred claim is often supported by some form of limited deposit insurance (increasingly so post the Global Financial Crisis of 2008). An assessment of the full benefit has to consider the cost of providing the payment infrastructure that bank depositors require but the issuing bank benefits from the capacity to raise funds at relatively low interest rates. The capacity to raise funding in the form of deposits also tends to mean that the issuing banks will be heavily regulated which adds another layer of cost.


The question is whether depositors should be protected

I am aware of two main arguments for protecting depositors:

  • One is to protect the savings of financially unsophisticated individuals and small businesses.
  • The other major benefit relates to the short-term, on-demand, nature of deposits that makes them convenient for settling transactions but can also lead to a ‘bank run’.

The fact is that retail depositors are simply not well equipped to evaluate the solvency and liquidity of a bank. Given that even the professionals can fail to detect problems in banks, it is not clear why people who will tend to lie at the unsophisticated end of the spectrum should be expected to do any better. However, the unsophisticated investor argument by itself is probably not sufficient. We allow these individuals to invest in the shares of banks and other risky investments so what is special about deposits.

The more fundamental issue is that, by virtue of the way in which they function as a form of money, bank deposits should not be analysed as “investments”. To function as money the par value of bank deposits must be unquestioned and effectively a matter of faith or trust. Deposit insurance and deposit preference are the tools we use to underwrite the safety and liquidity of bank deposits and this is essential if bank deposits are to function as money. We know the economy needs money to facilitate economic activity so if bank deposits don’t perform this function then you need something else that does. Whatever the alternative form of money decided on, you are still left with the core issue of how to make it safe and liquid.

Quote
“The capacity of a financial instrument like a bank deposit to be accepted and used as money depends on the ability of uninformed agents to trade it without fear of loss; i.e. the extent to which the value of the instrument is insulated from any adverse information about the counterparty”

Gary Gorton and George Pennacchi “Financial Intermediaries and Liquidity Creation”

I recognise that fintech solutions are increasingly offering alternative payment mechanisms that offer some of the functions of money but to date these still ultimately rely on a bank with a settlement account at the central bank to function. This post on Alphaville is worth reading if you are interested in this area of financial innovation. The short version is that fintechs have not been able to create new money in the way banks do but this might be changing.

But what about moral hazard?

There is an argument that depositors should not be a protected class because insulation from risk creates moral hazard.

While government deposit insurance has proven very successful in protecting banks from runs, it does so at a cost because it leads to moral hazard (Santos, 2000, p. 8). By offering a guarantee that depositors are not subject to loss, the provider of deposit insurance bears the risk that they would otherwise have borne.

According to Dr Sam Wylie (2009, p. 7) from the Melbourne Business School:

“The Government eliminates the adverse selection problem of depositors by insuring them against default by the bank. In doing so the Government creates a moral hazard problem for itself. The deposit insurance gives banks an incentive to make higher risk loans that have commensurately higher interest payments. Why?, because they are then betting with taxpayer’s money. If the riskier loans are repaid the owners of the bank get the benefit. If not, and the bank’s assets cannot cover liabilities, then the Government must make up the shortfall”

Reconciling Prudential Regulation with Competition, Pegasus Economics, May 2019 (p17)

A financial system that creates moral hazard is clearly undesirable but, for the reasons set out above, it is less clear to me that bank depositors are the right set of stakeholders to take on the responsibility of imposing market discipline on banks. There is a very real problem here but requiring depositors to take on this task is not the answer.

The paper by Gorton and Pennacchi that I referred to above notes that there is a variety of ways to make bank deposits liquid (i.e. insensitive to adverse information about the bank) but they argue for solutions where depositors have a sufficiently deep and senior claim on the assets of the bank that any volatility in their value is of no concern. This of course is what deposit insurance and giving deposits a preferred claim in the bank loss hierarchy does. Combining deposit insurance with a preferred claim on a bank’s assets also means that the government can underwrite deposit insurance with very little risk of loss.

It is also important I think to recognise that deposit preference moves the risk to other parts of the balance sheet that are arguably better suited to the task of exercising market discipline. The quote above from Pegasus Economics focussed on deposit insurance and I think has a fair point if the effect is simply to move risk from depositors to the government. That is part of the reason why I think that deposit preference, combined with how the deposit insurance is funded, are also key elements of the answer.

Designing a banking system that addresses the role of bank deposits as the primary form of money without the moral hazard problem

I have argued that the discussion of moral hazard is much more productive when the risk of failure is directed at stakeholders who have the expertise to monitor bank balance sheets, the capacity to absorb the risk and who are compensated for undertaking this responsibility. If depositors are not well suited to the market discipline task then who should bear the responsibility?

  • Senior unsecured debt
  • Non preferred senior debt (Tier 3 capital?)
  • Subordinated debt (i.e. Tier 2 capital)
  • Additional Tier 1 (AT1)
  • Common Equity Tier 1 (CET1)

There is a tension between liquidity and risk. Any security that is risky may be liquid during normal market conditions but this “liquidity” cannot be relied on under adverse conditions. Senior debt can in principle be a risky asset but most big banks will also aim to be able to issue senior debt on the best terms they can achieve to maximise liquidity. In practice, this means that big banks will probably aim for a Long Term Senior Debt Rating that is safely above the “investment grade” threshold. Investment grade ratings offer not just the capacity top issue at relatively low credit spreads but also, and possibly more importantly, access to a deeper and more reliable pool of funding.

Cheaper funding is nice to have but reliable access to funding is a life and death issue for banks when they have to continually roll over maturing debt to keep the wheels of their business turning. This is also the space where banks can access the pools of really long term funding that are essential to meet the liquidity and long term funding requirements that have been introduced under Basel III.

The best source of market discipline probably lies in the space between senior debt and common equity

I imagine that not every one will agree with me on this but I do not see common equity as a great source of market discipline on banks. Common equity is clearly a risky asset but the fact that shareholders benefit from taking risk is also a reason why they are inclined to give greater weight to the upside than to the downside when considering risk reward choices. As a consequence, I am not a fan of the “big equity” approach to bank capital requirements.

In my view, the best place to look for market discipline and the control of moral hazard in banking lies in securities that fill the gap between senior unsecured debt and common equity; i.e. non-preferred senior debt, subordinated debt and Additional Tier 1. I also see value in having multiple layers of loss absorption as opposed to one big homogeneous layer of loss absorption. This is partly because it can be more cost effective to find different groups of investors with different risk appetites. Possibly more important is that multiple layers offer both the banks and supervisors more flexibility in the size and impact of the way these instruments are used to recapitalise the bank.

Summing up …

I have held off putting this post up because I wanted the time to think through the issues and ensure (to the best of my ability) that I was not missing something. There remains the very real possibility that I am still missing something. That said, I do believe that understanding the role that bank deposits play as the primary form of money is fundamental to any complete discussion of the questions of deposit insurance, deposit preference and moral hazard in banking.

Tony

Automatic stabilisers in banking capital | VOX, CEPR Policy Portal

I am in favour of cyclical capital buffers but not the kind the BCBS has developed.

I have attached a link to a post by Charles Goodhart and Dirk Schoenmaker which highlights the problems with the BCBS Counter Cyclical Capital Buffer (CCyB) and proposes an alternative more rules based approach.

While banking is procyclical, the capital framework is largely static. The countercyclical capital buffer is discretionary, with potential danger of inaction, and is also limited in scale. This column proposes an expanded capital conservation buffer, which would act as an automatic stabiliser. This could incorporated in the next Basel review and the upcoming Solvency II review.

I have my own preferred alternative approach to the cyclical buffer problem but I agree very much with their critique of the CCyB.

Their post on this question is not long but worth reading.

— Read on voxeu.org/article/automatic-stabilisers-banking-capital

Tony

A BCBS review of the costs and benefits of higher bank capital requirements

The economic rational for higher bank capital requirements that have been implemented under Basel III is built to a large extent on an analytical model developed by the BCBS that was published in a study released in 2010. The BCBS has just (June 2019) released a paper by one of its working groups which reviews the original analysis in the light of subsequent studies into the optimal capital question. The 2019 Review concludes that the higher capital requirements recommended by the original study have been supported by these subsequent studies and, if anything, the optimal level of capital may be higher than that identified in the original analysis.

Consistent with the Basel Committee’s original assessment, this paper finds that the net macroeconomic benefits of capital requirements are positive over a wide range of capital levels. Under certain assumptions, the literature finds that the net benefits of higher capital requirements may have been understated in the original Committee assessment. Put differently, the range of estimates for the theoretically-optimal level of capital requirements … is likely either similar or higher than was originally estimated by the Basel Committee.

The costs and benefits of bank capital – a review of the literature; BCBS Working Paper (June 2019)

For anyone who is interested in really understanding this question as opposed to simply looking for evidence to support a preconceived bias or vested interest, it is worth digging a bit deeper into what the paper says. A good place to start is Table 1 from the 2019 Review (copied below) which compares the assumptions, estimates and conclusions of these studies:

Pay attention to the fine print

All of these studies share a common analytical model which measures Net benefits as a function of:

Reduced Crisis Probability x Crisis Cost – Output Drag (loan spreads).

So the extent of any net benefit depends on the extent to which:

  • More capital actually reduces the probability of a crisis and/or its economic impact,
  • The economic impact of a financial crisis is a permanent or temporary adjustment to the long term growth trajectory of the economy – a permanent effect supports the case for higher capital, and
  • The cost of bank debt declines in response to higher capital – in technical terms the extent of the Modigliani Miller (MM) offset, with a larger offset supporting the case for higher capital.

The authors of the 2019 Review also acknowledge that interpretation of the results of the studies is complicated by the fact that different studies use different measures of capital adequacy. Some of the studies provide optimal capital estimates in risk weighted ratios, others in leverage ratios. The authors of the 2019 Review have attempted to convert the leverage ratios to a risk weighted equivalent but that process will inevitably be an imperfect science. The definition of capital also differs (TCE, Tier 1 & CET1).

The authors acknowledge that full standardisation of capital ratios is very complex and lies beyond the scope of their review and nominate this as an area where further research would be beneficial. In the interim (and at the risk of stating the obvious) the results and conclusions of this 2019 Review and the individual studies it references should be used with care. The studies dating from 2017, for example, seem to support a higher value for the optimal capital range compared to the 2010 benchmark. The problem is that it is not clear how these higher nominal ratio results should be interpreted in the light of increases in capital deductions and average risk weights such as we have seen play out in Australia.

The remainder of this post will attempt to dig a bit deeper into some of the components of the net benefit model employed in these types of studies.

Stability benefits – reduced probability of a crisis

The original 2010 BCBS study concluded that increasing Tangible Common Equity from 7% to 10% would reduce the probability of a financial crisis by 1.6 percentage points.

The general principle is that a financial crisis is a special class of economic downturn in which the severity and duration is exacerbated by a collapse in confidence in the banking system due to widespread doubts about the solvency of one or more banks which results in a contraction in the supply of credit.

It follows that higher capital reduces the odds that any given level of loss can threaten the actual or perceived solvency of the banking system. So far so good, but I think it is helpful at this point to distinguish the core losses that flow from the underlying problem (e.g. poor credit origination or risk management) versus the added losses that arise when credit supply freezes in response to concerns about the solvency or liquidity of the banking system.

Higher capital (and liquidity) requirements can help to mitigate the risk of those second round losses but they do not in any way reduce the economic costs of the initial poor lending or risk management. The studies however seem to use the total losses experienced in historical financial crises to calculate the net benefit rather than specific output losses that can be attributed to credit shortages and any related drop in employment and/or the confidence of business and consumers. That poses the risk that the studies may be over estimating the potential benefits of higher capital.

This is not saying that higher capital requirements are a waste of time but the modelling of optimal capital requirements must still understand the limitations of what capital can and cannot change. There is, for example, evidence that macro prudential policy tools may be more effective tools for managing the risk of systemic failures of credit risk management as opposed to relying on the market discipline of equity investors being required to commit more “skin in the game“.

Cost of a banking crisis

The 2019 Review notes that

“recent refinements associated with identifying crises is promising. Such refinements have the potential to affect estimates of the short- and long-run costs of crises as well as our understanding of how pre-crisis financial conditions affect these costs. Moreover, the identification of crises is important for estimating the relationship between banking system capitalisation and the probability of a crisis, which is likely to depend on real drivers (eg changes in employment) as well as financial drivers (eg bank capital).

We considered above the possibility that there may be fundamental limitations on the extent to which capital alone can impact the probability, severity and duration of a financial crisis. The 2019 Review also acknowledges that there is an ongoing debate, far from settled, regarding the extent to which a financial crisis has a permanent or temporary effect on the long run growth trajectory of an economy. This seemingly technical point has a very significant impact on the point at which these studies conclude that the costs of higher capital outweigh the benefits.

The high range estimates of the optimal capital requirement in these studies typically assume that the impacts are permanent. This is big topic in itself but Michael Redell’s blog did a post that goes into this question in some detail and is worth reading.

Banking funding costs – the MM offset

The original BCBS study assumed zero offset (i.e. no decline in lending rates in response to deleveraging). This assumption increase the modelled impact of higher capital and, all other things equal, reduces the optimal capital level. The later studies noted in the BCBS 2019 Review have tended to assume higher levels of MM offset and the 2019 Review concludes that the “… assumption of a zero offset likely overstated the costs of higher capital nonbank loan rates”. For the time being the 2019 Review proposes that “a fair reading of the literature would suggest the middle of the 0 and 100% extremes” and calls for more research to “… help ground the Modigliani-Miller offset used in estimating optimal bank capital ratios”.

Employing a higher MM offset supports a higher optimal capital ratio but I am not convinced that even the 50% “split the difference” compromise is the right call. I am not disputing the general principle that risk and leverage are related. My concern is that the application of this general principle does not recognise the way in which some distinguishing features of bank balance sheets impact bank financing costs and the risk reward equations faced by different groups of bank stakeholders. I have done a few posts previously (here and here) that explore this question in more depth.

Bottom line – the BCBS itself is well aware of most of the issues with optimal capital studies discussed in this post – so be wary of anyone making definitive statements about what these studies tell us.

The above conclusion is however subject to a number of important considerations. First, estimates of optimal capital are sensitive to a number of assumptions and design choices. For example, the literature differs in judgments made about the permanence of crisis effects as well as assumptions about the efficacy of post crisis reforms – such as liquidity regulations and bank resolution regimes – in reducing the probability and costs of future banking crisis. In some cases, these judgements can offset the upward tendency in the range of optimal capital.

Second, differences in (net) benefit estimates can reflect different conditioning assumptions such as starting levels of capital or default thresholds (the capital ratio at which firms are assumed to fail) when estimating the impact of capital in reducing crisis probabilities.2

Finally, the estimates are based on capital ratios that are measured in different units. For example, some studies provide optimal capital estimates in risk-weighted ratios, others in leverage ratios. And, across the risk-weighted ratio estimates, the definition of capital and risk-weighted assets (RWAs) can also differ (eg tangible common equity (TCE) or Tier 1 or common equity tier 1 (CET1) capital; Basel II RWAs vs Basel III measures of RWAs). A full standardisation of the different estimates across studies to allow for all of these considerations is not possible on the basis of the information available and lies beyond the scope of this paper.

This paper also suggests a set of issues which warrant further monitoring and research. This includes the link between capital and the cost and probability of crises, accounting for the effects of liquidity regulations, resolution regimes and counter-cyclical capital buffers, and the impact of regulation on loan quantities.

The costs and benefits of bank capital – a review of the literature; BCBS Working Paper (June 2019)

Summing up

I would recommend this 2019 Literature Review to anyone interested in the question of how to determine the optimal capital requirements for banks. The topic is complex and important and also one where I am acutely aware that I may be missing something. I repeat the warning above about anyone (including me) making definitive statements based on these types of studies.

That said, the Review does appear to offer support for the steps the BCBS has taken thus far to increase capital and liquidity requirements. There are also elements of the paper that might be used to support the argument that bank capital requirements should be higher again. This is the area where I think the fine print offers a more nuanced perspective.

Tony

Bank funding costs and capital structure

Here is another paper for anyone interested in the optimal bank capital structure debate. It is a Bank of England Staff Working Paper titled “Bank funding costs and capital structure” by Andrew Gimber and Aniruddha Rajan.

The authors summarise their paper as follows:

“If bail-in is credible, risk premia on bank securities should decrease as funding sources junior to and alongside them in the creditor hierarchy increase. Other things equal, we find that when banks have more equity and less subordinated debt they have lower risk premia on both. When banks have more subordinated and less senior unsecured debt, senior unsecured risk premia are lower. For percentage point changes to an average balance sheet, these reductions would offset about two thirds of the higher cost of equity relative to subordinated debt and one third of the spread between subordinated and senior unsecured debt.”

Abstract

The paper adds support to the argument that the cost of higher capital requirements will be mitigated by a reduction in leverage risk which translates into lower borrowing costs and a decline in the required return on equity. In the jargon of the corporate finance wonks, the paper supports a Modigliani Miller (MM) offset.

I need to dig a bit deeper into the results but I am struggling with the finding that increasing the level of subordinated debt at the expense of senior debt results in a reduction in the cost of senior debt. In the interests of full disclosure, I recognise that this may simply reflect the fact that my experience and knowledge base is mostly limited to the Australian and New Zealand banking systems but here goes. As always, it is also possible that I am simply missing something.

The problem for me in these results

We are not debating here the principle that risk (and hence required return) increases as you move through the loss hierarchy. This is a common challenge thrown out at anyone who questions the thesis that risk should decline as you reduce leverage. My concern is that MM did not anticipate a financing structure in which the risk of certain liabilities is mitigated by the existence of an assumption that the public sector will support any bank that is deemed Too Big To Fail (TBTF).

I am not seeking to defend the right of banks to benefit from this implied subsidy. I fully support the efforts being made to eliminate this market distortion. However, so far as I can determine, the reality is that increasing the level of subordinated debt and/or equity may reduce the value of the implied TBTF assumption but senior debt itself does not seem to be any less risky so far as senior debt investors are concerned. So why should they adjust their required return?

This seems to be what we are observing in the response of the debt ratings of the major Australian banks to proposals that they be required to maintain increased levels of subordinated debt to comply with Basel III’s Total Loss Absorbing Capital (TLAC) requirement.

My second concern is not specific to the Bank of England paper but worth mentioning since we are on the topic. One of the MM predictions tested in this study is that “the risk premium on a funding source should fall as that funding source expands at the expense of a more senior one” with the study finding evidence that this is true. This proposition (now supported by another study with empirical data) is often used to argue that it really does not matter how much equity a bank is required to hold because the cost of equity will decline to compensate (the “Big Equity” argument).

What is missing, I think, is any consideration of what is the lower boundary for the return that an equity investor requires to even consider taking the junior position in the financing structure in what is ultimately one of the most cyclically exposed areas of an economy. My last post looked at a study of the returns on both risky and safe assets over a period of 145 years which suggested that risky assets have on average generated a real return of circa 7% p.a.. When you factor in an allowance for inflation you are looking at something in the range of 9%-10% p.a. In addition, there are a range of factors that suggest a bank should be looking to target a Return on Equity of at least 2%-3% over the average “through the cycle” expected return. This includes the way that loan losses are accounted for in the benign part of the cycle and I don’t think that IFRS9 is going to change this.

This is a topic I plan to explore in greater detail in a future post. For the moment, the main point is that there has to be a lower boundary to how much the cost of equity can decline to in response to changes in capital structure but this seems to be largely absent from the Big Equity debate.

I have added a bit of background below for anyone who is not familiar with the detail of how a bank financing structure tends to be more complicated than that of a typical non-financial company.

Tell me what I am missing …

Tony

Appendix: A bit of background for those new to this debate

The extent of this MM offset is one of the more contentious issues in finance that has generated a long and heated debate stretching back over more than half a century. Both sides of the debate agree that there is a hierarchy of risk in a company financing structure. Common equity is unambiguously at the high end of this risk hierarchy and hence should expect to earn the highest return. Layers in the hierarchy, and hence the relative protection from solvency risk, are introduced by creating levels of seniority/subordination amongst the various funding sources.

An industrial company could just have debt and equity in which case the MM offset is much easier to analyse (though still contentious). Bank financing structures, in contrast, introduce a variety of issues that render the debate even more complicated and contentious:

  • Prudential capital requirements introduce at least three layers of subordination/seniority via the distinction between minimum capital requirements for Common Equity Tier 1, Additional Tier 1 and Tier 2 capital
  • The transition to a “bail-in” regime potentially introduces another level of subordination/seniority in the form of an additional requirement for certain (typically large and systemically important) banks to hold Non-Preferred Senior debt (or something functionally equivalent)
  • Next comes senior unsecured debt that is one of the workhorses of the bank financing structure (which in turn may be short or long term)
  • In certain cases a bank may also issue covered bonds which are secured against a pool of assets (to keep things simple, I will skip over securitisation financing)
  • Banks are also distinguished by their capacity to borrow money in the form of bank deposits which also serve as a means of payment in the economy (and hence as a form of money)
  • Bank deposits often have the benefit of deposit insurance and/or a preferred super senior claim on the assets of the bank

Apart from the formal protections afforded by the seniority of their claim, certain liabilities (typically the senior unsecured) can also benefit from an implied assumption that the government will likely bail a bank out because it is Too Big To Fail (TBTF). Eliminating this implied subsidy is a key objective of the changes to bank capital requirements being progressively implemented under Basel III.

Until this process is complete, and the implied balance sheet value of being considered TBTF is eliminated, the response of bank funding costs to changes in leverage will not always follow the simple script defined by the MM capital irrelevancy thesis.

“The rate of return on everything”

This is the focus of a paper titled “The Rate of Return on Everything, 1870-2015 that seeks to address some fundamental questions that underpin, not only economic theory, but also investment strategy.

To quote the abstract:

This paper answers fundamental questions that have preoccupied modern economic thought since the 18th century. What is the aggregate real rate of return in the economy? Is it higher than the growth rate of the economy and, if so, by how much? Is there a tendency for returns to fall in the long-run? Which particular assets have the highest long-run returns? We answer these questions on the basis of a new and comprehensive dataset for all major asset classes, including—for the first time—total returns to the largest, but oft ignored, component of household wealth, housing. The annual data on total returns for equity, housing, bonds, and bills cover 16 advanced economies from1870 to 2015, and our new evidence reveals many new insights and puzzles.ets.

“The Rate of Return on Everything” Òscar Jordà, Katharina Knoll, Dmitry Kuvshinov, Moritz Schularick, Alan M. Taylor – December 2017

The paper is roughly 50 pages long (excluding appendices) but the 5 page introduction summarises the four main findings which I have further summarised below:

  1. Risky Returns: The study finds that “… residential real estate and equities have shown very similar and high real total gains, on average about 7% per year. Housing outperformed equity before WW2. Since WW2, equities have outperformed housing on average, but only at the cost of much higher volatility and higher synchronicity with the business cycle”.
  2. Safe Returns: The study finds that “Safe returns have been low on average, falling in the 1%–3% range for most countries and peacetime periods“. However, “the real safe asset return has been very volatile over the long-run, more so than one might expect, and oftentimes even more volatile than real risky returns.” This offers a long-run perspective on the current low level of the safe returns with the authors observing that “… it may be fair to characterize the real safe rate as normally fluctuating around the levels that we see today, so that today’s level is not so unusual. Which begs the question “… why was the safe rate so high in the mid-1980s rather than why has it declined ever since.”
  3. The Risk Premium: The study finds that the risk premium has been very volatile over the long run. The risk premium has tended to revert to about 4%-5% but there have been periods in which it has been higher. The study finds that the increases in the risk premium “… were mostly a phenomenon of collapsing safe rates rather than dramatic spikes in risky rates. In fact, the risky rate has often been smoother and more stable than safe rates, averaging about 6%–8% across all eras” . This for me was one of the more interesting pieces of data to emerge from the study and has implications for the question of what should be happening to target return on equity in a low interest rate environment such as we are currently experiencing. In the Authors’ words “Whether due to shifts in risk aversion or other phenomena, the fact that safe rates seem to absorb almost all of these adjustments seems like a puzzle in need of further exploration and explanation
  4. On Returns Minus Growth: This is the question that Thomas Piketty explored in his book “Capital in the Twenty-First Century”. Piketty argued that, if the return to capital exceeded the rate of economic growth, rentiers would accumulate wealth at a faster rate and thus worsen wealth inequality. The study finds that, “for more countries and more years, the rate of return on risk assets does in fact materially exceed the rate of growth in GDP… In fact, the only exceptions to that rule happen in very special periods: the years in or right around wartime. In peacetime, r has always been much greater than g. In the pre-WW2 period, this gap was on average 5% per annum (excluding WW1). As of today, this gap is still quite large, in the range of 3%–4%, and it narrowed to 2% during the 1970s oil crises before widening in the years leading up to the Global Financial Crisis.

So why does this matter?

There is a lot to think about in this paper depending on your particular areas of interest.

The finding that the long run return on residential housing is on par with equity but lower volatility is intriguing though I must confess that I want to have a closer look at the data and methodology before I take the conclusion as a fact. In particular, I think it is worth paying close attention to the way that the study deals with taxation. Fortunately, the paper offers a great deal of detail on the way that residential property is taxed (Appendix M in the December 2017 version of the paper) in different countries which is useful in its own right. I have been looking for a source that collates this information for some time and this is the best I have seen so far.

For me at least, the data on how the Equity Risk Premium (ERP) expands and contracts to offset changes in the return unsafe assets was especially interesting. This observation about the relationship is not new of itself but it was useful to find more data in support of it. I have been thinking a lot about Cost of Equity in a low interest rate environment and this seems to support the thesis that the target Return on Equity (ROE) should not necessarily be based on simply adding a fixed measure of the ERP (say 4%-5%) to whatever the current long run risk free rate is. It is at least worth having the question in mind when considering the question of whether Australian bank ROE is excessive at this point of the cycle.

If you are interested in the issues covered above then it is also worth having a look at an RBA Research Discussion Paper titled “A History of Australian Equities” by Thomas Matthews that was published this month.

From The Outside

Mortgage risk weight fact check – APRA’s perspective

I have posted a number of times on the extent to which the differential between mortgage risk weights applied to large and small banks is as big as is (repeatedly) asserted. APRA’s response to submissions on “Revisions to the capital framework for authorised deposit-taking institutions” (released 9 June 2019) has what I hope will be the definitive statement on the extent and justification for this difference.

I have copied the entire APRA comment on this differential below but the short version is that APRA does not see the difference being as large as it is claimed to be.

“When looked at holistically, the existing differential between the standardised and IRB approaches is small. While the precise calibration of the risk weights remains subject to further analysis, it is APRA’s intention that any differential in overall capital requirements, and hence any impact on pricing by standardised and IRB ADIs, will remain negligible.

So far, it seems that the argument I have been making for some time on this question stands. Read on if you want more detail.

Risk weight differential in mortgage lending

For some time, there has been considerable interest in the impact, from a competition perspective, of the differential between standardised and IRB risk weights for mortgage lending.

Commentary on this issue has often focussed on the differential in average risk weights between ADIs using the two approaches. Superficially, this suggests a material differential exists. However, by only examining risk weights for on-balance sheet exposures, the impact of other important differences is ignored.

Beyond prescribed risk weights, differences in capital requirements for mortgage lending are driven by:

• differences in the credit quality of the underlying portfolio;

• differences in the ‘unquestionably strong’ capital benchmarks applied to standardised and IRB ADIs;

• differences in the treatment of credit conversion factors (CCFs) for standardised and IRB ADIs;

• the application of capital requirements for IRRBB to IRB, but not standardised, ADIs; and

• the requirement for an expected loss adjustment for IRB, but not standardised, ADIs.

Ignoring any differences in portfolio quality, each of the above factors serves to narrow any impact from standardised risk weights being higher than IRB risk weights. Under the current regulatory framework (i.e. before applying the proposals in this paper), APRA estimates that the impact of the overall difference in capital requirements on mortgage pricing is likely to be minimal – in the order of 5 basis points.

The analysis does not consider the operational costs arising from investing in developing and maintaining risk management systems to support IRB status, as well as data requirements.

Furthermore, the application of an additional capital buffer to those banks designated a domestically systemically important further narrows, if not completely eliminates, the overall difference for those banks.

APRA does not expect the changes proposed in this paper to materially change the above conclusions. When looked at holistically, the existing differential between the standardised and IRB approaches is small. While the precise calibration of the risk weights remains subject to further analysis, it is APRA’s intention that any differential in overall capital requirements, and hence any impact on pricing by standardised and IRB ADIs, will remain negligible.

Mortgage risk weights fact check revisited – again

The somewhat arcane topic of mortgage risk weights is back in the news. It gets popular attention to the extent they impact the ability of small banks subject to standardised risk weights to compete with bigger banks which are endorsed to use the more risk sensitive version based on the Internal Ratings Based (IRB) approach. APRA released a Discussion Paper (DP) in February 2018 titled “Revisions to the capital framework for authorised deposit-taking institutions”. There are reports that APRA is close to finalising these revisions and that this will address the competitive disadvantage that small banks suffer under the current regulation.

This sounds like a pretty simple good news story – a victory for borrowers and the smaller banks – and my response to the discussion paper when it was released was that there was a lot to like in what APRA proposed to do. I suspect however that it is a bit more complicated than the story you read in the press.

The difference in capital requirements is overstated

Let’s start with the claimed extent of the competitive disadvantage under current rules. The ACCC’s Final Report on its “Residential Mortgage Price Inquiry” described the challenge with APRA’s current regulatory capital requirements as follows:

“For otherwise identical ADIs, the advantage of a 25% average risk weight (APRA’s minimum for IRB banks) compared to the 39% average risk weight of standardised ADIs is a reduction of approximately 0.14 percentage points in the cost of funding the loan portfolio. This difference translates into an annual funding cost advantage of almost $750 on a residential mortgage of $500 000, or about $15 000 over the 30 year life of a residential mortgage (assuming an average interest rate of 7% over that period).”

You could be forgiven for concluding that this differential (small banks apparently required to hold 56% more capital for the same risk) is outrageous and unfair.

Just comparing risk weights is less than half the story

I am very much in favour of a level playing field and, as stated above, I am mostly in favour of the changes to mortgage risk weights APRA outlined in its discussion paper but I also like fact based debates.

While the risk weights for big banks are certainly lower on average than those required of small banks, the difference in capital requirements is not as large as the comparison of risk weights suggests. To understand why the simple comparison of risk weights is misleading, it will be helpful to start with a quick primer on bank capital requirements.

The topic can be hugely complex but, reduced to its essence, there are three elements that drive the amount of capital a bank holds:

  1. The risk weights applied to its assets
  2. The target capital ratio applied to those risk weighted assets
  3. Any capital deductions required when calculating the capital ratio

I have looked at this question a couple of times (most recently here) and identified a number of problems with the story that the higher risk weights applied to residential mortgages originated by small bank places them at a severe competitive disadvantage:

Target capital ratios – The target capital adequacy ratios applied to their higher standardised risk weighted assets are in some cases lower than the IRB banks and higher in others (i.e. risk weights alone do not determine how much capital a bank is required to hold).

Portfolio risk – The risk of a mortgage depends on the portfolio not the individual loan. The statement that a loan is the same risk irrespective of whether it is written by a big bank or small bank sounds intuitively logical but is not correct. The risk of a loan can only be understood when it is considered as part of the portfolio the bank holds. All other things being equal, small banks will typically be less diversified and hence riskier than a big bank.

Capital deductions – You also have to include capital deductions and the big banks are required to hold capital for a capital deduction linked to the difference between their loan loss provisions and a regulatory capital value called “Regulatory Expected Loss”. The exact amount varies from bank to bank but I believe it increases the effective capital requirement by 10-12% (i.e. an effective RW closer to 28% for the IRB banks).

IRRBB capital requirement – IRB banks must hold capital for Interest Rate Risk in the Banking Book (IRRBB) while the small standardised banks do not face an explicit requirement for this risk. I don’t have sufficient data to assess how significant this is, but intuitively I would expect that the capital that the major banks are required to hold for IRRBB will further narrow the effective difference between the risk weights applied to residential mortgages.

How much does reducing the risk weight differential impact competition in the residential mortgage market?

None of the above is meant to suggest that the small banks operating under the standardised approach don’t have a case for getting a lower risk weight for their higher quality lower risk loans. If the news reports are right then it seems that this is being addressed and that the gap will be narrower. However, it is important to remember that:

  • The capital requirement that the IRB banks are required to maintain is materially higher than a simplistic application of the 25% average risk weight (i.e. the IRB bank advantage is not as large as it is claimed to be).
  • The standardised risk weight does not seem to be the binding constraint so reducing it may not help the small banks much if the market looks through the change in regulatory risk measurement and concludes that nothing has changed in substance.

One way to change the portfolio quality status quo is for small banks to increase their share of low LVR loans with a 20% RW. Residential mortgages do not, for the most part, get originated at LVR of sub 50% but there is an opportunity for small banks to try to refinance seasoned loans where the dynamic LVR has declined. This brings us to the argument that IRB banks are taking the “cream” of the high quality low risk lending opportunities.

The “cream skimming” argument

A report commissioned by COBA argued that:

“While average risk weights for the major banks initially rose following the imposition of average risk weight on IRB banks by APRA, two of the major banks have since dramatically reduced their risk weights on residential mortgages with the lowest risk of default. The average risk weights on such loans is now currently on average less than 6 per cent across the major banks.”

“Despite the imposition of an average risk weight on residential home loans, it appears some of the major banks have decided to engage in cream skimming by targeting home loans with the lowest risk of default. Cream skimming occurs when the competitive pressure focuses on the high-demand customers (the cream) and not on low- demand ones (the skimmed milk) (Laffont & Tirole, 1990, p. 1042). Cream skimming has adverse consequences as it skews the level of risk in house lending away from the major banks and towards other ADIs who have to deal with an adversely selected and far riskier group of home loan applicants.”

“Reconciling Prudential Regulation with Competition” prepared by Pegasus Economics May 2019 (page 43)

It is entirely possible that I am missing something here but, from a pure capital requirement perspective, it is not clear that IRB banks have a material advantage in writing these low risk loans relative to the small bank competition. The overall IRB portfolio must still meet the 25% risk weight floor so any loans with 6% risk weights must be offset by risk weights (and hence riskier loans) that are materially higher than the 25% average requirement. I suspect that the focus on higher quality low risk borrowers by the IRB banks was more a response to the constraints on capacity to lend than something that was driven by the low risk weights themselves.

Under the proposed revised requirements, small banks in fact will probably have the advantage in writing sub 50% LVR loans given that they can do this at a 20% risk weight without the 25% floor on their average risk weights and without the additional capital requirements the IRB banks face.

I recognise there are not many loans originated at this LVR band but there is an opportunity in refinancing seasoned loans where the combined impact of principal reduction and increased property value reduces the LVR. In practice the capacity of small banks to do this profitably will be constrained by their relative expense and funding cost disadvantage. That looks to me to be a bigger issue impacting the ability of small banks to compete but that lies outside the domain of regulatory capital requirements.

Maybe this potential arbitrage does not matter in practice but APRA could quite reasonably impose a similar minimum average RW on Standardised Banks if the level playing field argument works both ways. This should be at least 25% but arguably higher once you factor in the fact that the small banks do not face the other capital requirements that IRB banks do. Even if APRA did not do this, I would expect the market to start looking more closely at the target CET1 for any small bank that accumulated a material share of these lower risk weight loans.

Implications

Nothing in this post is meant to suggest that increasing the risk sensitivity of the standardised risk weights is a bad idea. It seems doubtful however that this change alone will see small banks aggressively under cutting large bank competition. It is possible that small bank shareholders may benefit from improved returns on equity but even that depends on the extent to which the wholesale markets do not simply look through the change and require smaller banks to maintain the status quo capital commitment to residential mortgage lending.

What am I missing …