MANAGING A BANK-SPECIFIC CRISIS: A UK PERSPECTIVE Ian Bond, Head of Financial Crisis Management Division, Bank of England

Similar documents
that each of you in the audience is finding it to be well worth your time.

Susan Schmidt Bies: An update on Basel II implementation in the United States

OPRISK USA. New York 25 March The view from Europe. Arnoud Vossen, Secretary General of CEBS

The Role of Regulation in Global Financial Markets

Ben S Bernanke: Modern risk management and banking supervision

Jürgen Stark: Financial stability the role of central banks. A new task? A new strategy? New tools?

Stefan Ingves: Regulatory challenges of cross-border banking possible ways forward

COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL. A Roadmap towards a Banking Union

FINANCIAL SECURITY AND STABILITY

INTERNATIONAL ASSOCIATION OF INSURANCE SUPERVISORS

First Progress Report on Supervisory Convergence in the Field of Insurance and Occupational Pensions for the Financial Services Committee (FSC)

The Financial Turmoil - The role of the EU-Commission

International Conference. Bank Resolution and Public Awareness on Deposit Insurance. X Annual Meeting of the Asia-Pacific Regional Committee

Basel Committee on Banking Supervision. Consultative Document. Pillar 2 (Supervisory Review Process)

1. The following terms used in this CA will have the following meaning:

Dan Waters, FSA Director of Retail Policy and Themes. and Sector Leader, Asset Management. 8 April Testimony to the European Parliament

11 th July 2011

Response to the Commission s Communication on An EU Cross-border Crisis Management Framework in the Banking Sector

FRAMEWORK FOR SUPERVISORY INFORMATION

Global Financial Reform: A Regulator s Perspective

Basel II: Requirements for European Integration Kangaroo Group Brussels, 6 October 2004

Christian Noyer: Basel II new challenges

THE EU ARRANGEMENTS FOR FINANCIAL CRISIS MANAGEMENT

Independent Review of the Operation of Monetary Policy in New Zealand: Report to the Minister of Finance

INTERNATIONAL ASSOCIATION OF INSURANCE SUPERVISORS

Progress of Financial Regulatory Reforms

Andreas Dombret: Between global competition and the regional principle - which bank needs which rules?

IRSG Opinion on Potential Harmonisation of Recovery and Resolution Frameworks for Insurers

Financial Instrument Accounting

Re: Implications of Fintech Developments for Banks and Bank Supervisors

Committee on Payments and Market Infrastructures. Board of the International Organization of Securities Commissions

MSB Roundtable 2010 Managing Risk for Growth & Development. Mona Visitors Lodge & Conference Centre University of the West Indies, Mona.

Remarks. Dr. C. L. Dhliwayo. Deputy Governor, Reserve Bank of Zimbabwe

Consultation Paper CP29/17 International banks: the Prudential Regulation Authority s approach to branch authorisation and supervision

Ben S Bernanke: Risk management in financial institutions

Is it implementing Basel II or do we need Basell III? BBA Annual Internacional Banking Conference. José María Roldán Director General de Regulación

Regulatory reform. Operating twin peaks and the move towards legal cutover (LCO)

MODULE 10 Supervision and Regulation. Introduction

11 th Annual International Seminar on Policy Challenges for the Financial Sector

Banking union: restoring financial stability in the Eurozone

The impact of bank resolution and bail-in mechanisms on bank management.

Keynote Address As Prepared for Delivery - The 2015 NAIC International Insurance Forum -

The Rt Hon Philip Hammond MP Chancellor of the Exchequer HM Treasury 1 Horse Guards Road London SW1A2HQ 5 December 2018

IOSCO Annual Conference Paris 28 May, Jane Diplock AO Chairman Executive Committee, IOSCO New Zealand Securities Commission.

The Bank of England s oversight of interbank payment systems under the Banking Act September 2009

Progress of Financial Reforms

Response to submissions on the Consultation Paper: Serviceability Restrictions as a Potential Macroprudential Tool in New Zealand.

International Monetary and Financial Committee

Authorisation to execute merger plans

Alan Bollard: Supervising overseas-owned banks: New Zealand s experience

Communication on the Resolution Strategy. of ACPR Resolution Board

Resolution of Cross-border Banking Groups: Challenges and Proposed Remedies

Insurance, stability and the UK s new regulatory architecture

Statement to Economic and International Trade Transition Team Regarding Regulation of Financial Services

Chapter 3 BASEL III IMPLEMENTATION: CHALLENGES AND OPPORTUNITIES IN CAMBODIA. By Ban Lim 1

Trust Everyone--But Brand Your Cattle Finding the Right Balance in Cross-Border Resolution. Remarks by. Randal K. Quarles

Distinguished guests, Ladies and gentlemen, A very good morning to you all.

a new Financial Policy Committee within the Bank of England (the FPC ) responsible for macro-prudential regulation and financial stability ;

Recovery and Resolution Planning Progress& Resolution Work I

Address to the 48 th Annual Meeting of the Central Bank of Iceland

SUPERVISORY POLICY STATEMENT (Class 1(1) and Class 1(2))

Public consultation. on a draft Addendum to the ECB Guide on options and discretions available in Union law. Explanatory memorandum

Public consultation on the Capital Requirements Directive ('CRD IV')

Elke König Keynote Speech (Sveriges Riksbank, De Nederlandsche Bank, and Deutsche Bundesbank) Stockholm 15 June :30-18:15

The distinct nature of insurance business and the introduction of a specific insurance objective;

Mortgage Market Review: Responsible Lending

Deepening Europe s Economic and Monetary Union. Commission Note ahead of the European Council and the Euro Summit of June 2018

ISA qualifying investments: including peer-to-peer loans HM Treasury

Limiting Spillovers Through Focused Supervision

The shared response to climate change: turning momentum into action

Supervisory Statement SS5/17 Dealing with a market turning event in the general insurance sector. July 2017

THE FCA PRACTITIONER PANEL S. Response to HM Treasury s Review of the Balance of Competences:

BANK STRUCTURAL REFORM POSITION OF THE EUROSYSTEM ON THE COMMISSION S CONSULTATION DOCUMENT

Jean-Claude Trichet: European financial integration

Supervising overseas-owned banks: New Zealand s experience

THE FUTURE FOR DEPOSIT INSURANCE. David G Mayes University of Auckland. Abstract

DP05/4 - HEDGE FUNDS: A DISCUSSION OF RISK AND REGULATORY ENGAGEMENT ABI RESPONSE TO FSA DISCUSSION PAPER

GOVERNMENT BORROWERS FORUM May 9-12, 2011 Hosted by the Ministry of Finance, Chile. Wednesday, May 11, 2011

Helping you reach your destination

The Bank of England s response to the Independent Evaluation Office s evaluation of its approach to providing sterling liquidity

Protecting Financial Stability in the Era of Too Big to Fail

September 28, Overview of Submission

Financial Turmoil: latest developments on policy response

Policy Statement PS16/17 Dealing with a market turning event in the general insurance sector. July 2017

Basel Committee on Banking Supervision. Principles for the homehost recognition of AMA operational risk capital

FACTORS INFLUENCING THE FINANCIAL SYSTEM STABILITY ORIENTED POLICIES OF A SMALL COUNTRY SOON TO BECOME AN EU MEMBER ESTONIAN EXPERIENCE 1

Bank of Canada Lender-of-Last-Resort Policies

Risk Management Policy and Procedures.

Dr Andreas Dombret Member of the Executive Board of the Deutsche Bundesbank

Tarisa Watanagase: The Thai economy risks, challenges, and opportunities

The Bank of England s approach to resolution. October 2017

Lars Heikensten: The IMF - mandate, means and governance in a changing world

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL

ECA-

EIOPA, Solvency II and the Loss Adjusting profession

MIDDLE EAST IPO SUMMIT DUBAI 5-6 MARCH 2006 THE IMPORTANCE OF EFFECTIVE STANDARDS FOR MARKET REGULATION

Financial markets today are a global game between a variety of highly interconnected players. Financial regulation sets out the rules of this game.

The IMF s work on financial soundness indicators 1

EXECUTIVE SUMMARY EXECUTIVE SUMMARY

To G20 Finance Ministers and Central Bank Governors

Transcription:

MANAGING A BANK-SPECIFIC CRISIS: A UK PERSPECTIVE Ian Bond, Head of Financial Crisis Management Division, Bank of England BBA workshop on managing a bank-specific crisis Pinners Hall 26 October 2006 Introduction The motivation for today s workshop really puts me as a representative of the UK authorities on the spot: the authorities are, so it is said, faced with new challenges; our roles and responsibilities are not clearly defined; and conflicts of interest may arise and hinder effective crisis solutions. And I have to say that I agree up to a point. Crisis management is indeed challenging, and has probably become rather more so in recent years. The complexity and connectedness of the financial system, the speed with which events can unfold, the crucial role now played by collateral (and the ability to use it efficiently) all suggest that the problems we would face in handling a crisis would be greater than ever before. But I m less convinced that the challenges are (in form, at least) particularly new. After all, it was more than thirty years ago now, in September 1974, that the G10 central bank governors issued the so-called Basle Communique to reassure financial markets about the adequacy of euromarket lender of last resort arrangements, in the wake of the Herstatt collapse. So recognition of the importance of cooperation in handling crises in crossborder banks is not new. And it is reflected in the work of a number of the international financial fora which have emerged since that collapse. UK domestic arrangements Before I turn to the challenges of managing a crisis in an internationally active bank, though, I thought it might be helpful to remind you all of the current domestic arrangements in the UK partly because they may not yet be widely understood, and partly because we firmly believe that robust national arrangements are an essential part of robust international crisis management. We take a resolutely tripartite approach to crisis management in the UK: central bank, regulator and government (in the form of the Treasury) all have roles to play. But they are

distinct roles, and need to be clearly understood by all parties so that there is no confusion on the day about who is responsible for what. And these roles need to be carried out co-operatively. The framework for this cooperation is provided by the tripartite Memorandum of Understanding, first drawn up in 1997 when responsibility for banking supervision moved from the Bank to the newly-established FSA. A revised MoU was published in March this year, at the time of the Budget. As the bankers bank, maintenance of the stability of the financial system as a whole is naturally one of the Bank s two core purposes. We contribute to this by Ensuring the stability of the monetary system, acting in the markets to deal with fluctuations in liquidity Overseeing systemically significant financial system infrastructure in particular, core payment systems Maintaining a broad overview of the system as a whole In exceptional circumstances, undertaking official support operations in order to limit the risk of problems in or affecting particular institutions spreading to other parts of the financial system The FSA is responsible for the authorisation and prudential supervision of financial firms; the supervision of financial markets and clearing/settlement systems; carrying out various actions in response to problem cases; and for regulatory policy in these areas. FSA incrisis actions might include, for example, changing capital or other regulatory requirements; or the facilitation of a market solution which might involve the introduction of new third party capital into a troubled firm. For its part, the Treasury is responsible for the overall institutional structure of financial regulation, and for informing and accounting to Parliament for the management of serious problems in the financial system. The principal forum for coordinating and agreeing action between the three authorities is the Tripartite Standing Committee: the Standing Committee on Financial Stability, to give it its full title. This is chaired by the Treasury and comprises senior representatives of the three authorities. It meets monthly at deputies level, and meetings can be called at other times by any of the participating authorities if they feel that there is an issue which needs to be addressed urgently. 2

In exceptional circumstances, for instance where a support operation is being considered, Standing Committee would meet at principals level: the Chancellor, the Governor and the Chairman (or senior alternates). What would actually happen, were a bank-specific crisis to develop? The tripartite authorities have established a more detailed working level co-ordination procedure which would underpin these Standing Committee arrangements. These processes are designed to ensure that the authorities response is orderly, that they gather and share relevant information quickly and that they act in a coordinated way. They have been developed in the light of experience from two simulation exercises, one in June 2004 and another in October 2005; and they will be regularly reviewed in the light of experience and periodic testing. The over-arching guiding principle for the UK response to a financial crisis is that support operations or other exceptional interventions should only be undertaken in the case of a genuine threat to the stability of the financial system to avoid a serious disturbance in the UK economy.. That s a hard test, but a sensible one: the authorities cannot and should not be expected to intervene with a support package every time a bank even a large one gets into difficulties. The cost of such an interventionist approach, in terms of market discipline and fiscal burden, would be substantial. And it would in all likelihood compromise the efficient provision of financial services and inhibit the exit of weak firms from the industry. Ultimate responsibility for authorising support operations rests with the Chancellor. He would do so with advice (for which we would be accountable) from both the Bank and the FSA: the MoU requires each authority to assess the seriousness of the crisis and its potential implications, and to provide separate assessments to the Treasury together with their views on the options available to the Chancellor. That may sound distinctly un-cooperative, but the process for preparing these assessments would be less like a competitive examination than this appears. For example, we would share information freely, so that the assessments would be based on a common information set we have worked together to develop a common framework for assessing the severity of a crisis, to ensure that we are covering similar ground and using a common language to talk about the impact 3

we are adopting a common template for assembling the analysis and presenting the assessment to the Treasury. If so much is similar, what is separate about the assessments? First, as the MoU notes, the Bank and FSA have distinct responsibilities and expertise. So we might attach weight to different factors, or attach different weight to the same factors, in offering our separate advice. FSA, for example, has a consumer protection objective; the Bank does not. And second, more importantly, systemic assessment is not and never can be a purely mechanical exercise: it depends crucially on judgments. Information will inevitably be incomplete and potentially also unreliable; and future actions or events will be uncertain. So reasonable, well-informed people could arrive at different conclusions even on the same evidence. To me, one of the strengths of this process is that it forces these uncertainties and ambiguities into the open, and creates an environment in which they will be considered from different perspectives before the big decisions are taken. So they should be better decisions. And it is likely to be clearer, after the event, why they were taken and whether the advice was reasonable, given what was known at the time. This is perhaps a good point for me to mention a couple of recent practical developments which support these UK arrangements. The first is the factbooks project, which many of you will be aware of. I ve already emphasised the importance of information sharing between the tripartite authorities (and particularly between Bank and FSA) to support crisis management decisions and actions. We know from experience, though, that getting hold of the right information quickly can be quite a challenge. So the idea of assembling key information in advance, and being open about what additional information might need to be called for on the day, has obvious attractions. That is what factbooks are all about: they are a tool for mobilising and sharing information quickly between the Tripartite authorities. Despite a fair amount of international discussion and even some trialling under the auspices of the FSF the idea has been slow to become a reality, in part because there always seem to be more pressing jobs to do. But we re now embarked on a project (led by FSA) to do just that, in the UK, and hope to have basic factbooks for the larger firms in place by next spring. The second development I want to mention is the Bank s new money market arrangements and, specifically, the standing facilities associated with them. These facilities offer participants the unlimited capacity to borrow from the Bank against eligible collateral, usually at a penalty rate of interest, and so make the provision of emergency liquidity 4

much more straightforward. Following major operational or financial disruption, we can reduce the penalty if necessary, to the point at which we are lending at Bank Rate. Banks accounting for some 95% of the banking system s sterling liabilities have signed up for access to these facilities, materially enhancing our capacity to provide rapid liquidity assistance when it is needed. That should reduce the risk of a short-term liquidity problem developing into a full-blown crisis. For completeness, I should also mention that there are separate but broadly similar arrangements for handling operational emergencies in which the Government s Emergency Response machinery comes into action. These give a rather greater role to the Treasury than does the TCP, reflecting their participation in key Governmental crisis management groups. As with the TCP, though, it is Standing Committee which is responsible for strategic decision taking. Mapping UK arrangements to international crises So how do these domestic arrangements work, if the bank in difficulties has overseas operations (or, indeed, is based abroad but operates also in the UK)? Our approach here is to operate on a basis of like with like cross-border interactions and to rely on our domestic processes to join things up. That builds on the normal day to day relationships, and as with our domestic arrangements should avoid duplication and delay. So ELA coordination, for example, would generally be a matter for central bank to central bank contacts; regulatory issues would be handled by the FSA; and for fiscal and other inter-governmental aspects the relevant finance ministries would normally take the lead (based of course on the agreed tripartite strategy in each case). One of the first thing one notices on looking at other countries is that they each have their own domestic financial structures and mapping between the UK tripartite authorities and our overseas counterparts is not always straightforward. There will generally be natural counterparts to the Treasury and Bank of England, but the organisation of supervision is much less uniform. While a unified national financial regulator, separate from the central bank, is becoming a more common structure, many variants exist and dispersed responsibilities for supervision, often with some degree of direct central bank involvement, remain common. But cross-border supervisory channels of communication particularly within the EU are well-established now, so in practice this is unlikely to be a major problem. A bigger challenge, perhaps, is simply the number of authorities which might have a material interest in problems affecting a major international bank. 5

And alongside these different structures, there are many differences in roles, powers and responsibilities; and more or less well articulated processes and approaches to crisis management. How does one bring this disparate set of players and contexts together to deliver effective cross-jurisdiction crisis management? One important feature of this complicated landscape, which helps to tie it together into a coherent whole, is the growing network of Memoranda of Understanding which set out the various authorities commitments to share information and to work together to handle crises. It s perhaps not surprising that the EU has led the way here, building on the precedent of the supervisory arrangements which support the single market in banking services. The most recent EU MoU embraces supervisors, central banks and finance ministries and is a significant advance on previous understandings. But the EU is not alone: there are other important regional agreements, often reflecting particular features of their financial systems which make such agreements self-evidently necessary: the Nordics, for example; and Australia and New Zealand. Further progress in this area is plainly desirable, and it s certainly not being neglected. Indeed, the UK authorities and the FSF are jointly hosting an international workshop in London in mid-november to take stock of current arrangements and to consider ways of taking this strand of work forward. One practical way of building on the MoUs and other cooperation agreements is to make information sharing part of a continuing dialogue, not just part of the crisis management machinery. So I see considerable attractions in the notion of so-called interest groups : groups comprising authorities linked by a shared interest in an internationally active firm, which is systemically important within their jurisdiction. The idea is a close cousin to that of colleges of supervisors, though the constituency for interest groups is probably both broader (in that it would need to include central banks) and narrower (in that practicality probably dictates some threshold below which a host country would not normally be invited to participate directly). Regular dialogue within such a group perhaps also, on occasion, directly with the firm concerned could do much to increase the relevant authorities awareness and understanding of the issues they might face in handling a crisis in that firm. It could also constitute the core of a forum within which possible courses of action could be discussed, if a crisis were to arise. 6

Some fundamental issues But these steps should not disguise the fact that the effective handling of financial crises faces (and has long faced) some challenging obstacles beyond the basic sharing of information. There is much talk these days, for example, of burden sharing: do we know how the costs of supporting an internationally-active bank would be apportioned? That s certainly an issue, but for me is some way down the track. There are formidable and more immediate issues about how and by whom decisions should be taken; what the criteria for action by the authorities should be; which authorities should be expected to act, and in which capacities, to avert or minimise the impact of a crisis; even, what measures are realistically available to the authorities in handling a major crisis. Underlying these issues is, I think, a more fundamental conundrum. The business and structural realities of modern international banking, and the supervisory approach which accompanies them, pay little regard to national boundaries. Large banks now manage their liquidity and capital on a regional or even global basis, and their risk management and IT systems have developed accordingly. That s sensible, if the goal is to achieve efficient, broadly diversified banks which can deliver financial services as cheaply as possible Yet legal and fiscal realities both of which inevitably intrude on crisis management remain resolutely national in their scope and instincts. A single bank may in fact comprise a large family of entities in different countries, both branches and subsidiaries, and so be subject to no single overriding jurisdiction. How could it be closed in an orderly way? How, indeed, could it be kept going, in these litigious times, where a single creditor in any one of these jurisdictions could unravel a carefully-assembled rescue or restructuring plan? The bottom line is that we may be paying a hidden price for efficient banking: crises if and when they occur may as a result be more difficult to deal with. I would not for a moment seek to argue that the tide of international banking should be rolled back, and that we should somehow re-instate a parochial, national approach to supervisory matters. That would be unthinkable. But what can we do, to strengthen the authorities capability to deal with troubled banks? Our crisis management capability can of course be improved, and that is being actively pursued. But I think that it is likely to be a slow process particularly if the legal and fiscal issues are to be tackled effectively. 7

The other important strand is that of crisis avoidance: making as sure as we can that the chances of incurring these extra costs are as low as possible. A stable macroeconomic environment, supported by effective monetary and fiscal policies, is an important part of that. So too is early identification of potential problems, and prompt response to them. Regular risk assessment work such as the Bank publishes periodically in the Financial Stability Report is part of that. It helps us to spot vulnerabilities early, and to mitigate them before they have become the germ of a crisis. So too is stress testing, both by banks and by the authorities. And of course the steady improvements which have been made to supervisory processes and techniques over the years, and the development of more robust financial system infrastructure, also help to increase the shock-resilience of the financial system. So it s a varied strategy, combining both vigilance and prompt action to minimise the risks that crises will occur with longer-term work to overcome some of the long-standing obstacles to effective crisis management. Both are necessary. And if we neglect either of them, perhaps the price we will eventually pay in a more costly crisis will outweigh the benefits we currently enjoy from having allowed commercial and investment banking to evolve into the efficient cross-border business it is today. October 2006 8