Understanding Risk Management and Compliance, May 2012


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Understanding Risk Management and Compliance, May 2012

  1. 1. International Association of Risk and Compliance Professionals (IARCP) 1200 G Street NW Suite 800 Washington, DC 20005-6705 USA Tel: 202-449-9750 www.risk-compliance-association.comDear Member,Do you know that investor in London are betting on when aparticular set of US citizens will die and, if these people livelonger than anticipated, the investment may not function as expected …… and that the UK Financial Services Authority (FSA) has confirmedguidance that this is a high risk product that should not be promoted tothe vast majority of retail investors in the UK?We live in (mad) financial times. These “high risk products” are calledTraded Life Policy Investments (TLPIs). Yes, risk management is veryimportant. The risk is that policyholders will not die the day we wantthem to die.Investors hope to benefit by buying the right to the insurance payoutsupon the death of the original policyholder.Well, we speak about London, let’s see the interesting definition of theshadow banking sector from Mr Paul Tucker, Deputy Governor forFinancial Stability at the Bank of England, (speaking at the EuropeanCommission High Level Conference, Brussels, 27 April 2012).He said that “shadow banking” is not the same as the non-bankfinancial sector.For example, the vast majority of hedge funds are not shadow banks,and don’t trade in the credit markets or especially illiquid markets.Also, non-bank intermediation of credit is not a bad thing in itself.Indeed, it can be a very good thing, helping to make financial servicesmore efficient and effective and the system as a whole more resilient.But, as we know from this crisis and from previous ones, true shadowbanking can weaken the system. Regulatory arbitrage, which is alwayswith us, can distort and disguise channels of intermediation.Shadow banking comes in lots of shapes and colours. There are degreesto which any particular instance of shadow banking replicates banking.
  2. 2. The liquidity offered by some shadow banks relies pretty well entirely,and more or less openly, on committed lines of credit from commercialbanks.In these cases, the liquidity insurance offered by the shadow bank is“derivative”; there is a real bank in the shadows.But for other shadow banks, liquidity services are offered without suchback-up lines. In those cases, claims on the shadow bank have, in effect,become a monetary asset. Examples probably include money marketmutual funds and an element of the prime brokerage services offered bysecurities dealers to levered funds.Interesting!
  3. 3. Developing a Single Rulebook in bankingAndrea Enria, Chairperson European Banking Authority, Central Bankof Ireland – Stakeholder Conference ‘FINANCIAL REGULATION -THINKING ABOUT THE FUTURE’ 27 April 2012Ladies and Gentlemen,My main topic today will be the Single Rulebook, the main path aheadof us to achieve the objectives of the new European institutionalframework established with the endorsement of the recommendationsof the de Larosière report.I will primarily focus on owns funds, as this is a key issue forre-establishing the regulatory framework on a sound footing and theEBA is currently running a public consultation on this.I will also briefly touch on another important component of the SingleRulebook: the liquidity requirements.However, before tackling these issues, I would like to give you anoverview of the first year of existence of the EBA and especially of thework done to face the challenges posed by the current crisis.1. The efforts of the EBA in tackling the financial crisisIn the first year of its life, the priorities of the EBA had to be focused onthe challenges raised by the deterioration of the financial marketenvironment.The stress test exercise we conducted in the first part of 2011 focused oncredit and market risks but also, in recognition of the risks thatsubsequently crystallised, incorporated sensitivity to movements infunding costs.Banks were also required to assess the credit risk in their sovereignportfolios.In many respects, I believe the exercise was successful: in order toachieve the tougher capital threshold, anticipating many aspects of thenew Basel standards, banks raised € 50 bn in fresh capital in the first four
  4. 4. months of the year; we set up a comprehensive peer review exercise,which ensured consistency of the exercise across the Single Market,notwithstanding the many differences in national regulatoryframeworks; the exercise included an unprecedented disclosure of data(more than 3200 data points for each bank), including amongst otherthings detailed information on sovereign holdings.However, the progress of the stress test was tracked by a significantfurther deterioration in the external environment.The main objective of restoring confidence in the European bankingsector was not achieved, as the sovereign debt crisis extended to morecountries, thus reinforcing the pernicious linkage between sovereignsand banks.Most EU banks, especially in countries under stress, experiencedsignificant funding challenges.In this context, the IMF and the European Systemic Risk Board (ESRB)called for coordinated supervisory actions to strengthen the banks’capital positions.The EBA assessment was that without policy responses, the freeze inbank funding would have led to an abrupt deleveraging process, whichwould have hurt growth prospects and fuelled further concerns on thefiscal position of some sovereigns, in a negative feedback loop.We then called for coordinated action on both the funding and thecapitalisation side.While advising the establishment of an EU-wide funding guaranteescheme, the EBA focused its own efforts on those areas where it hadcontrol, primarily bank capitalisation.To this end, the Board of Supervisors, comprising the heads of all 27national supervisory authorities, discussed and agreed that a furtherrecapitalisation effort was required as part of a suite of coordinated EUpolicy measures.Our Recommendation identified a temporary buffer to address potentialconcerns over EU sovereign debt holdings and required banks to reach9% CT1.The total shortfall identified was € 115 bn.The measure was agreed in October and enacted in December 2012.It was swiftly followed by the ECB’s long term refinancing operations(LTROs), arguably the key “game changer” in this context.
  5. 5. But the recapitalisation was a necessary complementary measure: whilebanks needed unlimited liquidity support, to avoid a credit crunch, theyhad to be asked to accelerate their action to repair balance sheets andstrengthen capital positions.These measures have bought time but should not bring complacency.The recapitalisation plan has seen banks make significant efforts tostrengthen their capital position without disrupting lending into the realeconomy.The EBA’s intensive monitoring of the process shows that 96% of theshortfall identified was met by direct capital actions.Moreover, there has been a strong spirit of cooperation between homeand host supervisors in discussing and taking forward these plansthrough colleges of supervisors, which has acted as a meaningfulcounterweight to the trend for national concerns to come to the fore inthe current environment.Going forward, heightened attention to addressing residual credit risk,making efforts to meet the new CRD IV requirements, setting in placeplans to gradually restore access to private funding and exit theextraordinary support of the ECB will be key.2. The Single Rulebook in bankingAs the finalisation of the new legislative framework for capital andliquidity requirements was coming closer, the focus of the EBA workhas been increasingly moving to our tasks in the rule-making process.The key task that the reform proposed by the de Larosière report assignsto the EBA is the establishment of a Single Rulebook, ensuring a morerobust and uniform regulatory framework in the Single Market andpreventing a downward spiral of competitive relaxation of prudentialrules.The EBA is asked to draft technical standards that, once endorsed bythe Commission, will be adopted as EU Regulations.The standards will therefore be directly applicable to all financialinstitutions operating in the Single Market, without any need fornational implementation or possibility for additional layers of local rules.I see that at the moment, while the negotiations on the capitalrequirement directive and regulation (CRD4-CRR) are entering the finalstages, there is a call for more national flexibility.It is often argued that minimum harmonisation is all that is needed, as
  6. 6. the decision of a national authority to apply stricter requirements wouldonly penalise financial institutions chartered in that jurisdiction.This argument neglects the fact that we have lived in a world ofminimum harmonisation until now, and this has delivered an extremelydiverse regulatory environment, prone to regulatory competition.It is a fact that the flexibility left by EU Directives has been a keyingredient in the run-up to the crisis.The Directives left significant flexibility to national authorities in thedefinition of key prudential elements (e.g., definition of capital,prudential filters for unrealised gains and losses), the determination ofrisk weights (e.g., for real estate exposures), the approaches to ensurethat all the risks are captured by the requirements (e.g., effectiveness ofrisk transfers).All these elements of flexibility have been used by banks to put pressureon their supervisors, triggering a process that led to excessive leverageand fuelled credit and real estate bubbles.The heterogeneity of the regulatory environment also complicatedsignificantly the effective supervision of cross-border groups, whichwere at the epicentre of the crisis: supervisors had serious difficultiesboth building up a firm-wide view of risks and acting in a timely andcoordinated fashion.Furthermore, regulatory arbitrage drove business decision. Thisproblem has not been fixed yet.In its first year of activity, the EBA identified a number of differences inregulatory treatment that lead to very material discrepancies in keyrequirements.For instance, the EBA staff conducted a simple exercise on the datacollected for the recapitalisation exercise.The capital requirement for the same bank were calculated using theless stringent and the most restrictive approaches in four areas wherenational rules present important differences – the calculation of theBasel I floors, the application of the prudential filters, the treatment(deduction from capital or inclusion in assets with a 1250% weight) ofIRB shortfalls and of securitisations.As a result, the ratio was 300 bps lower when the stricter methodologieswere applied, showing that differences can be very material and difficultto spot.In integrated financial markets, these differences can have very
  7. 7. disruptive effects.Once risks generated under the curtain of minimum harmonisationmaterialise, the impact is surely not contained within the jurisdictionsthat adopted less conservative approaches.Without using exactly the same definition of regulatory aggregates andthe same methodologies for the calculation of key requirements, theproblem will not be fixed.At the same time, it is absolutely true that the new regulatory frameworkhas to be shaped in such a way to leave a certain degree of nationalflexibility in the activation of macroprudential tools, as credit andeconomic cycles are not synchronised across the EU.Also, there could be structural features of financial sectors, orcomponents thereof, which might require tweaking prudentialrequirements to prevent systemic risk.But the same source of systemic risk should be treated in a broadlyconsistent manner in different jurisdictions across the Single Market, toavoid an unlevel playing field and less stringent approaches that mightsubsequently generate spillovers in other countries.The ideal long-term solution for avoiding conflicts between theflexibility needed for macroprudential supervision and the degree ofregulatory harmonisation called for by the Single Rulebook isconstructing a suite of macroprudential instruments along the blueprintof the countercyclical buffer.This provides a significant leeway for tightening standards while theEuropean Systemic Risk Board (ESRB) is entrusted with the task ofdrafting guidance on the activation of the tool and of conducting ex postreviews.At the same time, reciprocity in the application of the tool allows forcross-border consistency and reduces the room for regulatory arbitrage.So, we may well have a single rule, adopted through an EU Regulation,while this rule provides for flexibility in its application, with a frameworkthat the Basel Committee has labelled as “constrained discretion”.3. Giving life to the Single Rulebook: the new regulatoryframework of bank capital and liquidityIn giving life to the Single Rulebook in banking, the EBA is facing amajor challenge.The CRD4-CRR proposal envisages around 200 tasks, more than 100
  8. 8. technical standards - 40 of which will have to be finalised by the end ofthis year.We will have to ensure standards of high legal quality as they will beimmediately binding in all 27 Member States when endorsed by theEuropean Commission.We will have to respect due process, with wide and open consultationsand adequate impact assessments.As to the substance of the new regulatory framework, I will focus todayon the definition of capital and the quality of own funds, which Iconsider as one of the cornerstones of the Single Rulebook in banking.3.1. Own fundsThe definition of capital has been a major loophole in the run-up to thecrisis.As financial innovation brought about increasingly complex hybridinstruments, national authorities have been played against each other bythe industry, with the result that the standards for the quality of capitalwere continuously relaxed.As a consequence, once the crisis hit, a significant amount of capitalinstruments proved to be of inadequate quality to absorb losses.In several cases, taxpayers’ money was injected while the holders ofcapital instruments continue to receive regular payments.The Basel Committee has done an outstanding job in significantlystrengthening the definition of capital and we must make sure that thisis not lost in the implementation of the standards.The EBA already achieved some progress in the use of stringentuniform standards when imposing the use of a common definition ofcapital for the purpose of the stress test and the recapitalisation exercise.This proves that collective enhancements can be reached whennecessary.But what can be done in periods of stress must be perpetuated in normaltimes.For this purpose, on 4 April, the EBA published a consultation on a firstset of regulatory technical standards on own funds.These cover most areas of own funds, fleshing out the features ofinstruments of different quality (from CET1 to Tier 2 instruments).
  9. 9. The consultation will provide appropriate input from interested partiesand regular contacts with banks and market participants are alreadyunder way.The standards elaborate on the characteristics of the instrumentsthemselves, as well as on deductions to be operated from own funds.It is indeed crucial to ensure that there is a uniform approach regardingthe deduction from own funds of certain items like losses for the currentfinancial year, deferred tax assets that rely on future profitability,defined benefit pension fund assets.It is also necessary to ensure that, where exemptions from andalternatives to deductions are provided, sufficiently prudentrequirements are applied.The standards cover also several areas affecting more directlycooperative banks and mutuals, whose particular features have to betaken into adequate account.At the same time, it is necessary to define appropriate limitations to theredemption of the capital instruments by these institutions.The standards will also contribute to increase the permanence of capitalinstruments more generally by strengthening the features of the latterand by specifying the need for supervisory consent when reducing ownfunds.Finally, the standards will also increase the loss absorbency features ofeligible hybrid instruments, in line with the objective to bring investorscloser to shareholders and share losses on a pari passu basis.In order to complete its current work on own funds, the EBA will soonpublish a technical standard on disclosure by institutions.The work of the EBA on own funds will not be concluded with theendorsement of the new technical standards.Indeed, although technical standards, like EU Regulations, should notleave room for interpretation, it cannot be excluded that some provisionswill not work as they are meant to.This is the reason why a close review of the application of the standardsis necessary to detect potential loopholes and propose changes whenneeded.A framework should be developed, probably in the form of a Q&Aplatform, in order to address technical issues that may well emerge inthe practical application of the standards.
  10. 10. Furthermore, an important task that has been attributed to the EBA isthe publication of a list of instruments included in Common Equity Tier1 (CET1) as well as the monitoring of the quality of capital instruments.I believe the current text of the CRD4-CRR does not go far enough inensuring a strong control on the instruments that will be included in thecapital of higher quality.I understand the decision of the EU institutions to follow an approachthat privileges substance over form: the definition of Common EquityTier 1 will not be restricted to ordinary shares, as there is no harmonisedEU-wide definition that could be relied upon.Instead, the legislation will require that only instruments that are in linewith all the principles defined by the Basel Committee will qualify.In order for this to ensure a strict control on the quality of theseinstruments, strong mechanisms should be put in place to make surethat there is no room for watering down the requirements.The “substance” needs to be checked and has to be the same across theSingle Market.From my perspective, the list that the EBA will keep should be legallybinding.There should be an in-depth scrutiny of the instruments conducted atthe EU level by the EBA, in cooperation with national supervisors, toconfirm the inclusion in the list.If an instrument is included in the list, it should be accepted throughoutthe Single Market.If it is not included in the list, no authority should have the possibility toconsider it eligible as CET1.The present text limits the role of the EBA to the publication of anaggregated list only based on the assessment done at national level.This would not bring any added value compared to a situation whereMember States would be required to publish by themselves a list ofinstruments recognised in their jurisdictions.On the contrary, this could be misleading, as it could convey theimpression that the instruments have received an EU-wide recognition.In any case, even if the legislative framework does not provide the EBAwith the necessary legal tools, we are committed to fully exploiting the
  11. 11. draft Regulation’s provisions that require the EBA to monitor the qualityof own funds across the Single Market and to notify the Commission incase of evidence of material deterioration in the quality of thoseinstruments.If we consider that some instruments that are not of sufficient qualityhave been accepted, we also have the possibility to open formalprocedures for breach of European law.Having strong enforcement tools is essential: supervisors have lostcontrol of the definition of capital once and we should not allow this tohappen again.We are acutely aware that the new rules will trigger a new wave offinancial innovation, aimed at limiting the restrictive impact of thereform. Indeed, this is already under way.We already hear that new ways are being devised to smooth the impactof permanent write-downs or to circumvent the prohibition of dividendstoppers for hybrid instruments.Our monitoring of capital issuances is ongoing.The EBA recently decided to develop a set of benchmarks for hybridinstruments to give more clarity on what are the terms and conditions –in terms of permanence, flexibility of payments, loss absorbency – thatmake an instrument compliant with applicable rules.The work in this area will begin when the final legislation is in place anda sufficient number of new issuances are available, in order to have ameaningful sample of instruments to assess.In the future, hopefully, this work could move a step further, towardsproviding common templates, which could lead to the harmonisation ofthe main contractual provisions of hybrid capital instruments, in linewith the objectives of a Single Rulebook.A concrete illustration of these common templates has already beengiven by the EBA when publishing a common term sheet for theconvertible instruments accepted for the purpose of the recapitalisationexercise.3.2. LiquidityThe new liquidity standards represent a second important area of workfor the EBA.The first deliverable is due at the end of 2012, when we will have toprovide for uniform reporting formats.
  12. 12. The framework is currently under development and is expected to bereleased for public consultation over the summer.However, we can already foresee that the reporting is likely to be fairlysimilar to that used by the Basel Committee for the quantitative impactstudy, which many European banks are already familiar with.But the most important and delicate area of work is the definition ofliquid assets and, more generally, the calibration of the newrequirements.We are aware that the banking industry has raised serious concerns onthe two liquidity standards defined by the Basel Committee, theliquidity coverage ratio (LCR) and the net stable funding ratio (NSFR).The Basel Committee itself is reviewing the calibration of the ratios,recognising that some underlying assumptions are excessivelyconservative, even if confronted with the toughest moments of thefinancial crisis.The key principles underlying the LCR and the NSFR are sound andcannot be given up by regulators: banks need to have sufficient buffersof liquid assets to withstand a shock for some time without the need forpublic support; maturity transformation needs to be constrained tosome extent, so as to prevent banks from adopting fragile businessmodels relying excessively on volatile, short term wholesale funding tosupport longer term lending.But it is essential to get the calibration right, as funding is and willincreasingly be the main driver of the deleveraging process at EU banks.Time is needed to do a proper job: we have to ensure that data ofadequate quality is available – hence the need for a uniform reportingprovided at the end of 2012 – and to allow for in-depth analyses.The first impact assessments on LCR and the NSFR are due in 2013 and2015 respectively.The EU has taken the decision to use the monitoring period until 2015for the LCR and 2018 for the NSFR, before proposing legislation for afinal calibration of the liquidity ratios.This monitoring phase exactly mirrors the Basel Committee’s timeline.It is in my view the right choice to allow for this extensive observationperiod. I would strongly argue that we should avoid making any policychoice before proper evidence on the potential impact of the two ratios.
  13. 13. ConclusionsLadies and gentlemen,Today I tried to convey to you a bird’s eye picture on the difficultchallenges the EBA is facing.In the first year of activity we have already done a huge effort tostrengthen the capital position of EU banks and to restore confidence intheir resilience. The work is not over in this area.The liquidity support provided by the ECB avoided an abruptdeleveraging process, but banks are still in the process of repairing anddownsizing their balance sheets and of refocusing their core business.We, as supervisors, need to accompany this process and do our utmostto ensure that it occurs in an ordered fashion, without adverseconsequences on the financing of the real economy.One way to support the process is the introduction of the reforms oncapital and liquidity standards endorsed by the G20.I strongly believe that we need to exploit this opportunity to move to atruly harmonised regulatory framework, a Single Rulebook that ensuresthat high quality standards are enforced throughout the Single Market.We have to be particularly rigorous on the definition of capital, as this isthe basis for most prudential requirements.We cannot afford anymore financial innovation that allows instrumentsto be accepted as capital, while not respecting the key principles ofpermanence, flexibility of payments and loss absorbency.The control on eligible capital instruments needs to be very strict andshould be performed at the EU level. Ideally, the co-legislators shouldgive the EBA the legal basis to perform this difficult task.But in any case we will conduct a close monitoring of capital issuances,as we consider our duty to ensure that only the instruments of the bestquality are accepted as regulatory capital.As to liquidity standards, I believe that while the principles embodied inthe Basel text are absolutely shared, we need to do more work on thecalibration of the requirements.We understand the concerns expressed by the industry, but it isimportant that we collect solid empirical evidence before taking anydecision in this delicate area, which will provide a major driver for theneeded changes in banks’ business models.
  14. 14. FSA confirms traded life policy investments should notgenerally be promoted to UK investors25 Apr 2012The Financial Services Authority (FSA) has confirmed guidance thattraded life policy investments (TLPIs) are high risk products that shouldnot be promoted to the vast majority of retail investors in the UK.The guidance is an interim measure – the FSA will shortly be consultingon new rules imposing significant restrictions on the promotion ofnon-mainstream investments, including TLPIs, to retail investors.TLPIs invest in life insurance policies, typically of US citizens.Investors hope to benefit by buying the right to the insurance payoutsupon the death of the original policyholder.Basically, a TLPI investor is betting on when a particular set of UScitizens will die and, if these people live longer than anticipated, theinvestment may not function as expected.The FSA has found evidence of significant problems with the way inwhich TLPIs are designed, marketed and sold to UK retail investors.Many of these products have failed, causing loss for UK retail investors.Many TLPIs take the form of unregulated collective investmentschemes, which cannot lawfully be promoted to retail investors in mostcases, but have often been marketed inappropriately to retail customers.Peter Smith, the FSA’s head of investment policy said:“The TLPI retail market is worth £1 billion in the UK and we were veryconcerned that it was likely to grow even more.At the time that we published our guidance over half of existing retailinvestments were in financial difficulty – even so, we were hearing aboutthe development of new products intended to be sold to UK retailcustomers.“The threat to new customers was significant and growing: the potentialfor substantial future detriment was clear.There was a concern that we were witnessing a repeating cycle ofunsuitable sales followed by significant customer detriment in the TLPImarket.
  15. 15. Following publication of the guidance for consultation, this threat hasreceded.“This is an interim measure – we believe that TLPIs and all unregulatedcollective investment schemes should not generally be marketed to retailinvestors in the UK and will be publishing proposals soon to preventthem being promoted except in rare circumstances.”Traded Life Policy Investments (TLPIs), Key risks associatedwith TLPIsLongevity riskAn accurate estimation of life expectancy is the most important factor inassessing the price of each underlying life insurance policy in a TLPI.Based on this, the primary risk is that the underlying policies’ livesassured live longer than expected (for example, because of medicaladvances and the incompatibility of life assurance actuarial models asthe basis for investment purposes) so the TLPI needs to continue tofund premiums on the policies for longer than expected.This could negatively affect the return on investment and liquidity on anongoing basis.Liquidity riskThe underlying investments are illiquid due to their specialised natureand there is only a limited secondary market for them.This may mean they are sold at a significantly reduced value if the TLPIneeds to raise funds at short notice, which has an impact on the value ofthe portfolio. Investors may therefore suffer financial loss at the point ofredemption.Parties involved in the TLPI may become insolventThis risk factor, though not unique to TLPIs, is often overlooked.For example, if an insurance company becomes insolvent and is unableto meet claims upon the deaths of the original policyholders the TLPIcould find itself in difficulties given the often large value of the policies itholds.Governance issuesTLPI product governance has often proven problematic and led toproduct difficulties.Some common issues are as follows:
  16. 16. Conflicts of interestConflicts exist among different participants in the product value chainthat lead to high fees being charged and may lead to detriment forinvestors.TLPI models/structureIn some models, yields are promised to previous investors, which canonly be sustained by using new investors’ money, so the model in effect‘borrows’ from itself.The underlying assets are located offshoreThis means there is an exchange rate risk, both in terms of the costs ofmeeting ongoing premiums and the final payout for the underlyinginsurance contracts.Currency hedging instruments may be used by TLPI providers, butthese may pose additional risks and involve extra costs.Many TLPIs sold in the UK are operated by firms basedoffshoreThis means investors may have limited or no recourse to the FinancialServices Compensation Scheme (FSCS) if things go wrong and theproduct fails.They may also not be covered by the Financial Ombudsman Service(FOS) if they have a complaint about the operation of the TLPI.Customers would be able to complain to the FOS if, for example, theadvice they have received from UK distributors was unsuitable or if apromotion from a UK provider or distributor was unfair, unclear ormisleading.Awareness of authorisation/compensation arrangementsMany TLPIs are operated by firms based abroad and outside of theFSA’s jurisdiction.There is evidence that providers and advisers have not fully understoodor conveyed to investors the risks involved in how or whether the client’sproduct will be authorised and what compensation arrangements apply.These factors could result in a significant risk of loss of capital (and anyincome provided) for customers.
  17. 17. FSA Japan - Press Conference by Shozaburo Jimi, Minister forFinancial Services (Excerpt)[Opening Remarks by Minister Jimi]This morning, the Minister of Economic and Fiscal Policy, the Ministerof Economy, Trade and Industry and the Minister for Financial Servicesheld a meeting, and I will make a statement regarding the policypackage for management support for small and medium-sizeenterprises (SMEs) based on the final extension of the SME FinancingFacilitation Act.Recently, the Diet passed and enacted an amendment bill to extend theperiod of the SME Financing Facilitation Act for one year for the lasttime and an amendment bill to extend the deadline for thedetermination of support by the Enterprise Turnaround InitiativeCorporation of Japan, over which Minister of Economic and FiscalPolicy Furukawa has jurisdiction, for one year, and the new laws werepromulgated and put into force.I believe that this year will be very important for creating anenvironment for vigorously implementing support that truly improvesthe management of SMEs, namely an exit strategy.From this perspective, the ministers who represent the Cabinet Office,the Financial Services Agency (FSA) and the Small and MediumEnterprise Agency held a meeting and adopted the policy formanagement support for SMEs.The FSA will seek to facilitate financing for SMEs through measuresrelated to the final extension of the period of the SME FinancingFacilitation Act, including this policy package, and will also create anenvironment favorable for management support for SMEs whilemaintaining cooperation with relevant ministries and agencies.
  18. 18. For details, the FSA staff will later hold a press briefing, so please askyour questions then.[Questions & Answers]Q. The G-20 meeting started on April 19.I hear that the expansion of the International Monetary Funds lendingfacility, which has been the focus of attention, may be put off, and themarket could fall into turmoil again, with the yield on Spanishgovernment bonds rising in Europe.Could you tell me how you view the recent financial marketdevelopments?A. As for the current situation surrounding the European debt problemthat you mentioned now, individual countries financial and capitalmarkets have generally been recovering for the past several months as aresult of efforts made by euro-zone countries and the European CentralBank, as you know.On the other hand, concern over the European fiscal problem has notbeen dispelled, as indicated by unstable market movements caused byconcern over Spains fiscal condition.The euro zone has set forth the path to fiscal consolidation andPresident Draghi of the European Central Bank (ECB) has taken boldmeasures, as you know well.Such measures as the ECBs long-term refinancing operation and thestrengthening of the firewall have been taken.To ensure that the market will be stabilized and the European debtproblem will come to an end, it is important not only that the series ofmeasures adopted by the euro zone is carried out but also that the IMFsfinancial base is strengthened.From this perspective, Minister of Finance Azumi recently expressed anintention to announce Japanese financial support worth 60 billiondollars for the IMF at the G-20 meeting.I hope that this Japanese action, combined with Europes own efforts,will help to resolve the European debt problem.As you know, it is unusual for Japan to exercise initiative and announcesupport for the IMF.
  19. 19. Although Japan has various domestic problems, it is the worldsthird-largest country in terms of GDP.In addition, as I have sometimes mentioned, Japan is the only Asiancountry that has maintained a liberal economy and a free market sincethe latter half of the 19th century.Even though Japan lost 65% of its wealth because of World War II, itwent on to recover from the loss.In that sense, it is very important for Japan to exercise initiative, onwhich the United States eventually showed an understanding from whatI have heard informally.Q. It has been decided that Kazuhiko Shimokobe of the NuclearDamage Liability Facility Fund will be appointed as Tokyo ElectricPower Companys new chairman.Tokyo Electric Powers management problem has had some effects onthe corporate bond market and also has affecteds SMEs through a hikein electricity rates. What do you think of this appointment?A. I am aware that Mr. Shimokobe, who is chairman of the NuclearDamage Liability Facility Funds management committee, hasaccepted the request to serve as Tokyo Electric Powers chairman, butthe FSA would like to refrain from commenting on personnel affairs.Formerly, I, together with Mr. Yosano, joined the cabinet task force,which was responsible for determining the scheme for rehabilitatingTokyo Electric Power, in response to the economic damage caused bythe nuclear station accident, as additional members, and our efforts ledto the enactment of the Act on the Nuclear Damage Liability FacilityFund.I understand that Tokyo Electric Power and the Nuclear DamageLiability Facility Fund are drawing up a comprehensive special businessplan.What kind of support Tokyo Electric Power will ask stakeholders toprovide and how stakeholders including financial institutions willrespond are matters to be discussed at the private-sector level, as I havebeen saying, so the FSA would like to refrain from making comments forthe moment.In any case, regarding Tokyo Electric Powers damage compensation,making damage compensation payments quickly and appropriately andensuring stable electricity supply are important duties that electricpower companies must fulfill.
  20. 20. Therefore, with the fulfillment of those duties as the underlying premise,it is important to prevent unnecessary, unpredictable adverse effects -you mentioned the effects on the corporate bond market earlier - so Iwill continue to carefully monitor market developments.Q. On April 19, the Democratic Party of Japans working team on theexamination of the future status of pension asset management and theAIJ problem adopted an interim report.Could you tell me about the status of the FSAs deliberation on measuresto prevent the recurrence of the problem, including when the measureswill be worked out?A. I read about that in a newspaper article.Regarding problems identified in this case, it is necessary to ensure theeffectiveness of countermeasures while taking account of practicalfinancial practices.That report is an interim one, so it stated that various measures will beworked out in the future. I have my own thoughts as the person incharge of the FSA.However, I think that the FSA needs to conduct a study on measuressuch as strengthening punishment against false reporting andfraudulent solicitation - as you know, false reports were made in thiscase - establishing a mechanism that ensures effective checks bythird-parties like companies entrusted with funds, auditing firms andtrust banks - the checking function did not work at all in this case - andincluding in investment reports additional information useful forpension fund associations to judge the reliability of companiesmanaging customers assets under discretionary investment contractsand the investment performance.In any case, regarding measures to prevent the recurrence of this case,we will quickly conduct deliberation while taking into consideration theresults of the Securities and Exchange Surveillance Commissionsadditional investigation and the survey on all companies managingcustomers assets under discretionary investment contracts - thesecond-round survey is underway - as well as the various opinionsexpressed in the Diet, including the arguments made in the interimreport, which was written under Ms. Renhos leadership.We will implement measures one by one after each has been finalized.Q. Regarding the policy package announced today, several people saidin the Diet that more efforts should be devoted to measures to support
  21. 21. SMEs in relation to the extension of the period of support by theEnterprise Turnaround Initiative Corporation of Japan.In relation to the policy package, do you see any problems with thecollaboration that has so far been made with regard to managementsupport for SMEs?A. Twenty-two years ago, in 1990, I became parliamentary secretary forinternational trade and industry, and served in the No. 2 post of theformer Ministry of International Trade and Industry for one year andthree months under then Minister of International Trade and IndustryEiichi Nakao.At that time, I was in charge of financing for SMEs, such as financingprovided by Shoko Chukin Bank, the Japan Finance Corporation forSmall and Medium Enterprise, the National Life Finance Corporationand the Small Business Corporation, for one year and three months.Many departments and divisions are involved in the affairs of SMEs.While diversity and nimbleness are important for SMEs, I know from myexperiences that they lack human resources and that unlike largecompanies, it is difficult for them to change business policies quickly inresponse to tax system changes.The FSA will continue to cooperate with relevant ministries andagencies and relevant organizations, such as the Enterprise TurnaroundInitiative Corporation of Japan, liaison councils on support for therehabilitation of SMEs, financial institutions and related organizations,including the Japanese Bankers Association, and commerce andindustry groups - there are four traditional associations of SMEs - as wellas prefectural credit guarantee associations, which play an importantrole for the governments policy for SMEs.In addition, the FSA will cooperate with government-affiliated financialinstitutions and take concrete actions, and I hope that recovery andrevitalization of local economies based on the rehabilitation of regionalSMEs will lead to the development of the Japanese economy.However, between the three ministers who held a meeting today, thepolicy toward SMEs tends to lack coordination.In Tokyo, Minister of Economy, Trade and Industry Edano andMinister of Economic and Fiscal Policy Furukawa and I workedtogether to adopt the policy package. In Japans 47 prefectures, there areliaison councils on support for rehabilitation of SMEs and there arecommerce and industry departments in prefectural and municipalgovernments, and these organizations will also be involved, so the policyfor SMEs is wide-ranging and involves various organizations.
  22. 22. Therefore, while we provide management support, these variousorganizations tend to act without coordination.Today, the three of us held a meeting to exercise central governmentcontrol, and we will keep close watch on minute details so as to ensurecoordination.As I have often mentioned, there are 4.3 million SMEs, which accountfor 99.7% of all Japanese corporations in Japan, and 28 million people,which translates into one in four Japanese people, are employed bySMEs, so SMEs have large influence on employment.We will maintain close cooperation with relevant organizations.Q. In relation to the previous question, I understand that the EnterpriseTurnaround Initiative Corporation of Japan has mostly handled casesinvolving SMEs.At a board meeting yesterday, it was decided that a former official of aregional bank will be appointed to head the corporation. How do youfeel about that?A. I read a newspaper article about the decision to appoint a formerpresident of Toho Bank.Toho Bank is the largest regional bank in Fukushima Prefecture, andpersonally, I am pleased that a very suitable person will be appointed asa new president.Fukushima Prefecture has been stressing that the revival of Japan wouldbe impossible without the revival of Fukushima in relation to the nuclearstation accident.In that sense, the selection of the former president of Toho Bank, a fairlylarge regional bank, who also served as chairman of the Regional BanksAssociation of Japan, is appropriate.This morning, Minister of Economic and Fiscal Policy Furukawareported on the selection.I think that a very suitable person has been selected.
  23. 23. There are many risk management experts thatdiscuss this interesting speechShareholder value and stability in banking: Isthere a conflict?Speech by Jaime Caruana, General Manager, Bank forInternational SettlementsUnderstandably, the global regulatory response to the global financialcrisis has stirred controversy.That response, with Basel III at its core, seeks to strengthen theresilience of the banking system.In doing so, it asks shareholders to give up high leverage as a source ofhigh returns on equity.And it asks bondholders, especially those of systemically importantinstitutions, to take more of a hit in the event of failure.In this light, it is easy enough to imagine that investors would have littlereason to hail the new framework.This view, however, tells only part of the story.It assumes that, on balance, bank investors were well served by thepre-crisis system.It also posits a conflict between value for shareholders on the one handand the public interest in safer banking on the other.In my remarks today I would like to suggest that this supposed conflictof interests is overstated.Yes, tensions may arise over a short investment horizon.But over long horizons, they tend to disappear – because, in the longterm, the focus necessarily shifts to sustainable profits and returns.This is not just theorising: we’ll take a look at the statistical evidence ina moment.And unless one believes that markets can be consistently timed – a raregift at best – it is long horizons that should matter for investors.Let me first outline what we in Basel mean by safer banking and takestock of where we stand in the development and implementation of newstandards.This is an issue in which, I am sure, you will have a keen interest.I shall then argue that the concerns of investors and bank supervisorsare remarkably well aligned in the long term.
  24. 24. Basel’s vision of safe bankingIn the past few years, the Basel Committee on Banking Supervision hasconducted a sweeping review of regulatory standards and it has put inplace a strengthened framework that incorporates new macroprudentialelements.This framework is in several ways a great improvement over thepre-crisis regulatory approach.First of all, it sets a much more conservative minimum ratio for capitalthat is of far better quality.When the whole Basel III package is implemented, banks’ commonequity will need to be at least 7% of risk-weighted assets.This compares to a Basel II level of 2% – and that is before takingaccount of the changes to definitions and risk weights that make theeffective increase in capital all the greater.Among the improvements in capturing risk on the assets side, I wouldespecially point to the improved treatment of risks arising fromsecuritisation and contingent credit lines.Moreover, these risk-based capital requirement measures will besupplemented by a non-risk-based leverage ratio, which will serve as abackstop and limit model risk.This new framework responds to the main lessons from the crisis: bankshad leveraged excessively, had understated the riskiness of certainassets (particularly those considered practically risk-free), and had madeinnovations that reduced the loss-absorbing capacity of headline capitalratios.Second, Basel III takes the notion of a “buffer” much more seriously.The 7% figure includes a 2.5% capital conservation buffer, which bankscan draw upon in difficult times.Dividends and remuneration will be restricted at times when banks areattempting to conserve capital.Supervisors will have the discretion to apply an additional,countercyclical buffer when risks show signs of building up in goodtimes, most notably in the form of unusually strong credit growth.The goal is to build up buffers in good times that banks can draw downin bad times.Third, the package contains elements to address systemic risk head-on,both by mitigating procyclicality and by cushioning the impact offailures on the entire system.I have already mentioned the countercyclical buffer, which aims toaddress the procyclical build-up of risk, and the leverage ratio, whichwill help contain the build-up of excessive leverage in good times.
  25. 25. The framework now also recognises explicitly that stresses at the largest,most complex financial institutions can threaten the rest of the system.The Financial Stability Board (FSB) and the Basel Committee envisagethat these systemically important financial institutions, or SIFIs, willhave greater loss absorbency, more intense supervision, strongerresolution and more robust infrastructure.These aims complement each other, and share a common rationale.Greater loss absorbency – including capital surcharges that range from 1to 2.5% for those institutions designated as SIFIs – and bettersupervision should reduce the probability that problems at these bigmarket players disrupt activity throughout the wider financial system.Stronger resolution and better infrastructure should reduce the systemicimpact of a SIFI’s closure or restructuring and thereby strengthenmarket discipline.In addition, methods to identify globally systemically important insurersare being developed and should be ready for public consultation by theG20 Leaders’ Summit in June 2012.And, work is under way to address the issue of banks that are systemicon a national rather than a global level, as well as to identify otherglobally systemic non-bank financial institutions.Fourth, liquidity standards have been introduced.These comprise a liquidity coverage ratio, or LCR, and a net stablefunding ratio, or NSFR.The standards will ensure that banks have a stable funding structure anda stock of high-quality liquid assets to meet liquidity needs in times ofstress.Importantly, the group of governors and heads of supervision thatoversees the Basel Committee has confirmed that this liquidity buffer isthere to be used.Specifically, banks will be required to meet the 100% LCR threshold innormal times.But, during a period of stress, supervisors would allow banks to drawdown their pools of liquid assets and temporarily to fall below theminimum, subject to specific guidance.The Committee will clarify its rules to state this explicitly, and willdefine the circumstances that would justify use of the pool.Since this is the first time that detailed global liquidity rules have beenformulated, we do not have the same experience and high-quality dataas we do for capital.A number of areas will require careful potential impact assessment as weimplement these rules.
  26. 26. The Basel Committee has therefore taken a gradual approach inadopting the standards between 2015 and 2018, and will meanwhileassess the impact during an observation period.At the same time, in order to reduce uncertainty and to allow banks toplan, key aspects of liquidity regulation, such as the pool of high-qualityliquid assets, are being reviewed on an accelerated basis.But any changes will not materially affect the framework’s underlyingapproach, which is to induce banks to lengthen the term of their fundingand to improve their risk profiles, instead of simply holding more liquidassets.Finally, it is time for these new rules and frameworks to beimplemented.The Basel Committee is already engaged in the full, consistent andtimely implementation of the framework by national jurisdictions.To this end, the Committee has started to conduct both peer andthematic reviews through its Standards Implementation Group.Last October, the Committee published the first regular progress reportson members’ implementation of what they have agreed.Each member will also undergo a more detailed peer review, startingwith the EU, Japan and the United States.And the Committee is currently reviewing the measurement ofrisk-weighted assets in banking and trading books, with an eye toconsistency across jurisdictions.The goal of these measures is clear: to have a stronger and saferfinancial system.This should benefit everyone – the banking industry, users of financialservices and taxpayers.But some may question whether shareholders will benefit as well.Has the leveraged business model of the past really served them well?The record, to which I turn next, suggests that it has not.Shareholder returns and the leveraged business modelOver the long term, banks have turned in a sub-par performance,whether assessed on accounting measures or by return on equity.Historically, the average return on equity in banking has matched thatof other sectors (see Table).But unlike in other sectors, these returns have involved the generous useof leverage, either on the balance sheet or, frequently, off it.We know that banking involves leverage and maturity transformation,but the question is how much is appropriate?
  27. 27. There may be no clear answer, but let’s look at the data. Bank equity wason average leveraged more than 18 times in 1995–2010. Equity innon-financial firms was leveraged only three times (see Table).This implies that, compared with other firms, banks have succeeded indelivering only average return on equity over the long term but at thecost of higher volatility and losses in bad times (Graph 1).Turn now to stock returns and the message does not change much.Anyone who at the start of 1990 had invested in a portfolio that was longglobal banking equities and equally short the broad market indiceswould today be sitting on a loss (Graph 2, right-hand panel).And, over the long term, risk-adjusted returns have been sub-par.The main exception is Canada, where banks have barely suffered in therecent crisis (Graph 2, left-hand panel).It is high leverage that has contributed to the volatility of bank profits.And it is high leverage that makes banks perform so badly on a rainyday.During periods that comprise the worst 20% of stock marketperformance, banks do worse than most other sectors (Graph 3,left-hand panel).Clearly, the flip side is that they do very nicely on sunny days (Graph 3,right-hand panel).For investors, this is not a compelling value proposition.To be sure, some may be agile enough to profit from the downside inbank stocks.But most investors inevitably entered the global financial crisis fullyinvested or overweight in bank stocks.And, historically, market timing has proved an elusive strategy.Not only is the performance of banks over time inconsistent with thenotion that shareholders can benefit from high leverage and statesupport; the evidence across banks actually suggests that the banks thatwere more strongly capitalised at the outset weathered the crisis better.The left-hand panel of Graph 4 suggests that no particular relationshipexisted between Tier 1 capital and the pre-crisis return on equity.Indeed, banks with stronger Tier 1 equity could and did match thereturns of less well capitalised peers.When the crisis hit, however, the less well capitalised banks scrambledto raise funds in difficult market conditions, while their strongercompetitors could avoid fire sales and distressed fund-raising (centrepanel).And it was the banks that had reported high-flying returns before thecrisis that were the most likely to resort to fire sales and distressedfund-raising (right-hand panel).
  28. 28. The conclusion is that stronger capital makes a difference.A further consideration is that it is easier and probably cheaper to raisecapital in good times.Together, these observations suggest that leverage is not the only way togenerate returns – and that, when returns don’t depend on leverage, theyare more sustainable.What investors can expect from banksAll this indicates that investors could reach a better understanding withbank managements.The key is sustained profitability through both good and bad times.Recent work at the BIS suggests that, when economic activity movesfrom peak to trough, the betas on bank stocks, relating percentagechanges in their value to that of broad market indices, increase by wellover 150 basis points.In effect, banks are generating good returns in good times by writingout-of-the-money puts that come back to haunt them when the marketfalls.How did we get here?The story of a major UK bank is symptomatic.Twenty years ago, the head of the bank promised investors that theinstitution would beat its cost of equity, which he took to be 19%.For a while, the bank was able to achieve this return by closingbranches.But ultimately such promises led bank managers to invest their liquidityreserve in asset-backed securities, boosting earnings in effect by writingputs on both credit and liquidity.When it came to the crunch, the bank could not keep its return on equityabove 20% during the global financial crisis and had to seek help fromthe state.Given the trend decline in inflation and government bond yields, 20% inthe early 1990s translates to something more like 15% today.Still, bank managements that continue to promise such returns may findthemselves again writing puts, effectively making themselves hostage tobad times in order to pump up returns in good times.Accounting norms that treat risk premia in good times as distributableprofits do not help.In any case, managements who promise sustained 15% returns in alow-inflation, deleveraging economy may be leading investors astray.Over time, sustained profitability at more reasonable levels should bringbank share prices back to a premium over book values.
  29. 29. Past behaviour supports this conclusion. In particular, my colleaguesestimate that if leverage decreases from 40 to 20, the required return –the return investors demand – drops by 80 basis points.The intuition is that, when banks increase their equity base (or reduceleverage), they work each unit of equity less – that is, the risk borne byeach unit of equity falls—and so does the return investors require.This prospect would characterise a new long-run understandingbetween shareholders and bank managements that produce sustainedprofits. But how should banks get there?Here I do not refer to the immediate problem banks face in bringingtheir assets into line with their capital, leading to considerabledeleveraging. Instead, I refer to the longer-term problem.How should banks generate returns in order to be sustainable?I would argue that such returns can arise from a reconsideration ofbanks’ business models.In line with the lessons drawn from the crisis by banks, investors andprudential authorities, these models would recognise that ourknowledge of systemic risk is incomplete.As a result, bank managers would seek sustainable profit less inrisk-taking and maturity transformation and more in operational andcost efficiency.Cost efficiency can powerfully contribute to bank earnings.As a rule of thumb, on average across countries, a 4% reduction inoperating expenses translates into roughly a 2 percentage point increasein return on equity.Moreover, experience strongly suggests that determined attempts toclean up balance sheets and cut costs can go hand in hand with asustained recovery in profits on the back of a stronger capital base.This is precisely the experience of Nordic countries, which sufferedserious banking crises in the early 1990s (Graph 5).With costs under control, banks can achieve higher profitability withstronger capital.ConclusionsLet me pull together the threads of the argument.The banks that fared better in the crisis were those that were moreprudently capitalised.Investors as well as regulators want to ensure that this wisdom is writteninto the rules of the game.The financial reforms that have been agreed will increase the quality andamount of bank capital in the system; they will also promote increases ofcapital buffers in good times that can be drawn down in bad times.
  30. 30. Big, interconnected and hard-to-replace banks will carry extra capital.The authorities are working to ensure that no bank is too complex to bewound down. They are refining new liquidity standards.And they are taking unprecedented steps to make sure that the newregulations are implemented effectively across countries.The outcome should be a stronger financial system. But regulation isonly part of the answer and stronger market discipline will also benecessary to ensure resilience.I have presented the case that, over the long term, there is no conflictbetween shareholder value and the public interest in safer banking.This proposition is supported by the record of return on equity and bankshare price performance – a record that refutes the argument that bankshave used leverage to produce sustained shareholder value – and the keyword here is “sustained”.Bank returns may have been comparatively high in good times.But those returns have melted away in bad times.And they have come at the cost of greater risk.In the long run, bank business models have produced middling returnswith substantial downside risk.This means that in good times banks have overpromised andoverestimated their underlying profitability.They have written put options on their liquidity and credit and reportedthe premia as current income.In effect, they have made distributions out of what should have beentreated as expected losses.How can investors help banks move in the right direction?They could encourage sustainable business models based less onrisk-taking and more on a careful analysis of competitive advantage andoperational efficiencies.And they should be wary of entertaining unrealistic expectations aboutsustainable rates of return.Only when solid business models and realistic commitments tosustainable returns are rewarded can shareholder value be reconciledwith safe banking.Indeed, there is no other way.*****As a postscript, and for the sake of completeness, let me outline threeother regulatory initiatives.First, the FSB, with the involvement of the IMF, the World Bank andstandard-setting bodies, will draft an assessment methodology thatprovides greater technical detail on the Key Attributes of EffectiveResolution Regimes for Financial Institutions.
  31. 31. The FSB will use the draft methodology to begin, in the second half of2012, a peer review evaluating member jurisdictions’ legal andinstitutional frameworks for resolution regimes (and of any plannedchanges).And supervisors plan to put in place resolution plans andinstitution-specific cooperation agreements for all 29 G-SIFIs byend-2012.Second, work continues towards strengthening OTC derivativesmarkets.This includes meeting the commitments by G20 Leaders to movetrading in standardised contracts to exchanges and centralcounterparties by end-2012.Market supervisors and settlement system experts are close to finalisingstandards for strengthening CCPs and other financial marketinfrastructures.Meanwhile, banking supervisors are reviewing the incentives for banksto trade and clear derivatives centrally.Another important initiative here is the establishment of a global,uniform legal entity identifier, for which the FSB, with the support of anindustry advisory panel, is developing recommendations to be presentedto the next G20 Summit in Mexico in June.Third, potential risks related to the shadow banking system are beingaddressed.Banking supervisors are examining banks’ interactions with shadowbanking, including issues related to consolidation, large exposurelimits, risk weights and implicit support, and will propose any neededchanges by July 2012.Market supervisors are looking at the regulation of money market fundsand at issues relating to securitisation on the same schedule.Multidisciplinary FSB task forces are examining other shadow bankingentities and, separately, securities lending and repo markets, with a viewto making policy recommendations later this year
  32. 32. Jens Weidmann: Global economicoutlook – what is the best policy mix?Speech by Dr Jens Weidmann, President of the Deutsche Bundesbank,at the Economic Club of New York, New York, 23 April 2012.1. IntroductionLadies and GentlemenGeorge Bernard Shaw is said to have made an interesting remark aboutapples – “If you have an apple and I have an apple and we exchangethese apples then you and I will still each have one apple.But if you have an idea and I have an idea and we exchange these ideas,then each of us will have two ideas.”I think those words perfectly encapsulate the intention of the EconomicClub of New York and of today’s event.Ideas multiply when you share them and they become better when youdiscuss them.I am therefore pleased and honoured to be able to share some ideas withsuch a distinguished audience today.And I look forward to discussing them with you.In a long list of speakers, I am the third Bundesbank President to speakat the Economic Club. The first was Karl Otto Pöhl in 1991, followed byHans Tietmeyer in 1996.Although only a few years have passed since then, the global economiclandscape has completely transformed in the meantime – just think ofthe spread of globalisation, think of the introduction of the euro, think ofthe Asian crisis or the dotcom bubble.All these events and others have constantly shaped and reshaped ourworld.Most recently, we have experienced a crisis that, once again, will changethe world as we know it – economically, politically and intellectually.It is this new unfolding landscape that provides the backdrop to myspeech.I shall address two questions: “Where do we stand?” and “Where do wego from here?”Of course, it is the second question that is the tricky one.
  33. 33. In answering it, we should be aware that every small step we take nowwill determine where we stand in the future.Specifically, I shall argue that measures to ward off immediate risks tothe recovery are closely interconnected with efforts to overcome thecauses of the crisis.They are interconnected much more closely and vitally than proponentsof more forceful stabilization efforts usually assume.But, first, let us see where we stand at the present juncture.2. Where do we stand?When we look back from where we are standing right now, we see acrisis that has left deep scars.The International Labour Organisation estimates that up to 56 millionpeople lost their jobs in the wake of the crisis.This number equals the combined populations of California and thestate of New York.Or look at government debt: Between 2007 and 2011, gross governmentdebt as a share of GDP increased by more than 20 percentage points inthe euro area and by about 35 percentage points in the United States.I think we all agree that the crisis was unprecedented in scale and scope.And the first thing to do was to prevent the recession turning into adepression.Thanks to the efforts of policymakers and central banks across theglobe, this has been achieved.Following a slight setback in 2011, the world economy now seems to berecovering.In its latest World Economic Outlook, the IMF confirms that globalprospects are gradually strengthening and that the threat of sharpslowdown has receded.Looking ahead, the IMF projects global growth to reach 3.5% in 2012and 4.1% in 2013.For the same years, inflation in advanced economies is expected toreach 1.9% and 1.7%.
  34. 34. Basically, I share the IMF’s view. However, we all are aware that theseestimates have to be taken with a grain of salt – probably a large one.Being a central banker, I am not quite as calm about inflation.Taking into account rising energy prices and robust core inflation,prices could rise faster than the IMF expects.We have to be careful that inflation expectations remain well anchoredand consistent with price stability.Expectations getting out of line might very well turn out to be anon-linear process.If this were to happen, it would be difficult and expensive to rein inexpectations again.Even though the outlook for growth has improved over the past months,some risks remain – the European sovereign debt crisis being one ofthem. And this seems to be the one risk that is weighing most heavily onpeoples’ minds – not just in Europe but here in the United States, too.The euro-area member states have responded by committing toundertake ambitious reforms and by substantially enlarging theirfirewalls.This notwithstanding, the sovereign debt crisis has not yet beenresolved.The renewed tensions over the past two weeks are a case in point.Thus, we have to keep moving, but each step we take has to beconsidered very carefully.As I have already said: each small step we take now will determinewhere we stand in the future.3. Where do we go from here?Eventually, three things will have to happen in the euro area.First, structural reforms have to be implemented so that countries suchas Greece, Portugal and Spain become more competitive.Second, public debt has to be reduced – a challenge that is not confinedto the euro area.
  35. 35. Third, the institutional framework of monetary union has to bestrengthened or overhauled, and we need more clarity about whichdirection monetary union is going to take.I think we all agree on this – including the IMF in its latest WorldEconomic Outlook.However, there is much less agreement on the correct timing.Since the crisis began, the imperatives I have just mentioned havetended to be obscured by short-term considerations.And surprisingly, this tendency seems to be becoming stronger now thatthe world economy is getting back on track.This view is reflected by something Lawrence Summers wrote in theFinancial Times about four weeks ago.Referring to the US, he said that “… the most serious risk to recoveryover the next few years […] is that policy will shift too quickly away fromits emphasis on maintaining adequate demand, towards a concern withtraditional fiscal and monetary prudence.”It is in this spirit that some observers are pushing for policies thateventually boil down to “more of the same”: firewalls and ex ante risksharing in the euro area should be extended, consolidation of publicdebt should be postponed or, at least, stretched over time, and monetarypolicy should play an even bigger role in crisis management.I explicitly do not wish to deny the necessity of containing the crisis.But all that can be gained is the time to address the root problems.The proposed measures would buy us time, but they would not buy us alasting solution.And five years after the bursting of the subprime bubble and three yearsafter the turmoil in the wake of the Lehman insolvency, we have to askourselves: Where will it take us if we apply these measures over and overagain – measures which are obviously geared towards alleviating thesymptoms of the crisis but which fail to address its underlying causes?In my view, this would take us nowhere.There are two reasons for this.First, the longer such a strategy is applied, the harder it becomes tochange track.
  36. 36. More and more people will realise this and they will start to loseconfidence.They will lose confidence in policymakers’ ability to bring about alasting solution to our problems.And we should bear in mind that the crisis is primarily a crisis ofconfidence: of confidence in the sustainability of public finances, incompetitiveness and, to some extent, in the workings of EMU.But there is a second reason why the “more of the same” will not take usanywhere.The analgesic we administer comes with side effects.And the longer we apply it, the greater these side effects will be, and theywill come back to haunt us in the future.In the end, it is just not possible to separate the short and the long term.You will be tomorrow what you do today.With these two caveats in mind, let us take a closer look at the suggestedpolicy mix.For the sake of brevity, I shall focus on monetary and fiscal policies.3.1 An even bigger role for monetary policy?To contain the crisis, the EMU member states have built a wall ofmoney that recently reached the staggering height of 700 billion euros.As I have already said, ring-fencing is certainly necessary, but again: it isnot a lasting solution.And it is not the sky that’s the limit – the limits are financial andpolitical.In the face of such limits, the Eurosystem is now seen as the “last manstanding”.Consequently, some observers are demanding that it play an even biggerrole in crisis management.More specifically, such demands include lower interest rates, moreliquidity and larger purchases of assets.But does the assumption on which these demands are based hold truewhen we take a closer look at it?
  37. 37. In the end, monetary policy is not a panacea and central bank“firepower” is not unlimited, especially not in monetary union.True, this crisis is exceptional in scale and scope, and extraordinarytimes do call for extraordinary measures.But the central banks of the Eurosystem have already done a lot tocontain crisis.Now we have to make sure that by solving one crisis, we are notpreparing the ground for the next one.Take, for example, the side effects of low interest rates.Research has found that risk-taking becomes more aggressive whencentral banks apply unconditional monetary accommodation in order tocounter a correction of financial exaggeration, especially if monetarypolicy does not react symmetrically to the build-up of financialimbalances.In the end, putting too much weight on countering immediate risks tofinancial stability will create even greater risks to financial stability andprice stability in the future.The Eurosystem has applied a number of unconventional measures tomaintain financial stability.These measures helped to prevent an escalation of the financial turmoiland constitute a virtually unlimited supply of liquidity to banks.But monetary policy cannot substitute for other policies and must notcompensate for policy inaction in other areas.If the Eurosystem funds banks that are not financially sound, and doesso against inadequate collateral, it redistributes risks among nationaltaxpayers.Such implicit transfers are beyond the mandate of the euro area’s centralbanks.Rescuing banks using taxpayers’ money is something that should onlybe decided by national parliaments.Otherwise, monetary policy would nurture the deficit bias that isinherent to a monetary union of sovereign states.In this regard, the situation of the Eurosystem is fundamentally differentfrom that of the Federal Reserve or that of the Bank of England.
  38. 38. Moreover, extensive and protracted funding of banks by the Eurosystemreplaces or displaces private investors.This breeds the risk that some banks will not reform unviable businessmodels.So far, progress in this regard has been very limited in a number ofeuroarea countries.And the Eurosystem has also relieved stress in the sovereign bondmarket.However, we should not forget that market interest rates are animportant signal for governments regarding the state of their financesand that they are an important incentive for reforms.Of course, markets do not always get it right.They may have underestimated sovereign risks for a long time and nowthey are overestimating it.But past experience taught us that their signal is still the most powerfulincentive we have.At any rate, I would not rely on political insight or political rules alone.After all, monetary policy must not lose sight of its primary objective: tomaintain price stability in the euro area as a whole.What does this mean?Let us say that monetary policy becomes too expansionary for Germany,for instance.If this happens, Germany has to deal with this using other, nationalinstruments.But by the same token, we could say this: even if we are concerned aboutthe impact on the peripheral countries, monetary policymakers must dowhat is necessary once upside risks for euro-area inflation increase.Delivering on its primary goal of maintaining price stability is essentialfor safeguarding the most precious resource a central bank cancommand: credibility.To sum up: what we do in the short-term has to be consistent with whatwe are trying to achieve in the long-term – price stability, financialstability and sound public finances.
  39. 39. This implies a delicate balancing act – a balancing act we shall upset ifwe overburden monetary policy with crisis management.3.2 Rethinking consolidation and structural reforms?Now, what about consolidation and structural reforms?Here, too, we have to strike the right balance between the short and thelong run.Those who propose putting off consolidation and reforms argue thatembarking on ambitious consolidation efforts or far-reaching structuralreforms at the present moment would place too great a burden onrecovery.They do not deny the necessity of such steps over the medium term, butin the short-run they consider it more important to maintain adequatedemand, avoid unsettling people and nurture the recovery.But in the end, the current crisis is, to a large degree, a crisis ofconfidence.And if already announced consolidation and reforms were to be delayed,would people not lose even more confidence in policymakers’ ability toget to the root of the crisis?We can only win back confidence if we bring down excessive deficitsand boost competitiveness.And it is precisely because these things are unpopular that makes it sotempting for politicians to rely instead on monetary accommodation.It is true that consolidation, in particular, might, under normalcircumstances, dampen aggregate demand and economic growth.But the question is: are these normal circumstances?It is quite obvious that everybody sees public debt as a major threat.The markets do, politicians do, and people on Main Street do.A widespread lack of trust in public finances weighs heavily on growth:there is uncertainty regarding potential future tax increases, whilefunding costs are rising for private and public creditors alike.In such a situation, consolidation might inspire confidence and actuallyhelp the economy to grow.
  40. 40. In my view, the risks of frontloading consolidation are beingexaggerated. In any case, there is little alternative.In the end, you cannot borrow your way out of debt; cut your way out isthe only promising approach.4. ConclusionAllow me to conclude by going back to the beginning of my speechwhere I mentioned the benefits of sharing and discussing ideas.I have stressed that we have to embark on reforms that make the crisiscountries more competitive; that we have to reduce public debt and thatwe have to further improve the institutional framework of monetaryunion.But the spirit of my argument was expressed succinctly some 20 yearsago by Karl Otto Pöhl.In his speech at the Economic Club he said: “The true function of acentral bank must be, however, to take a longer-term view.”And after five years of crisis, the long term might catch up with us fasterthan we expect.We therefore have to think about the future now – and we have to actaccordingly as well. Thank you for your attention.
  41. 41. Andreas Dombret: Towards a more sustainable EuropeSpeech by Dr Andreas Dombret, Member of the Executive Board of theDeutsche Bundesbank, at the Euromoney Germany Conference, Berlin,25 April 2012.***1 IntroductionLadies and GentlemenI am delighted to have the opportunity to speak to you today at theEuromoney Germany conference.Now in its 8th year, the conference has established itself as a first-classopportunity for policymakers and financial practitioners to exchangeviews.I firmly believe that this free flow of ideas is of benefit to us all, and I amlooking forward to sharing my views with you in the next 20 minutes.We are facing a crisis that is no longer confined to individual countries.Throughout and beyond Europe, it weighs heavily on people’s minds.Some believe, it even challenges the viability of monetary union in itscurrent form.Given the exceptional scale and scope of the crisis, it is hardly surprisingthat views diverge on how to overcome it.But it is worth recalling that despite intense debates on the best wayforward, we share a common vision for the future of our monetary union:a sound currency, sound public finances, competitive economies, and astable financial system.These are the principles enshrined in the Maastricht Treaty.With the adoption of the treaty, all euro-area member states committedto a European stability culture.Among those most eager to join were the countries with first-handexperience of the painful consequences of deficits spiralling out ofcontrol and of a monetary policy not always fully committed tomaintaining price stability.The unholy “marriage” between Banca d’Italia and the Italian treasuryin 1975 is a perfect example.Banca d’Italia vowed to act as buyer of last resort for government bonds.
  42. 42. Up to the “divorce” in 1981, Italian government debt more than tripledwhile average inflation stood at 17%.After Banca d’Italia was granted greater independence, inflation ratesbegan to fall significantly.The principles of a sound currency, sound public finances and acompetitive economy thus remain the cornerstones of a strong andsustainable monetary union.Far from being a specifically German conviction, they serve thewell-being of citizens throughout the euro area.And the ongoing validity of these principles is a prerequisite for thepublic acceptance of monetary union.Thus, any approach that does not respect and comply with theseprinciples will not bring about a lasting solution to the crisis.The current crisis is not a crisis of the euro as our common currency.Since the start of the euro, inflation has been in line with theEurosystem’s definition of price stability, and the euro continues to be astrong currency – to some, it actually appears to be too strong.But it is generally accepted that the two central elements of the crisis arelarge macroeconomic imbalances stemming from divergingcompetitiveness levels, and unsustainable levels of public debt.2 The root causes of the crisis: macroeconomic imbalances andover-indebtednessNo lasting solution to the crisis will be achieved unless these root causesare tackled.Firewalls can help some countries to cope better with the effects ofsudden shifts in investor sentiment, but, ultimately, all it can do is buytime.As the IMF points out in its recent World Economic Outlook , firewallsby themselves cannot solve the difficult fiscal, competitiveness andgrowth issues that some countries are now facing.2.1 Macroeconomic imbalancesThere is broad consensus that macroeconomic imbalances, which havebuilt up in recent years, lie at the heart of the crisis.
  43. 43. But the best way to correct these imbalances has been the subject ofintense debate.Exchange rate movements are usually an important channel throughwhich unsustainable current account positions are corrected – deficitcountries eventually see a devaluation, while surplus tend to revaluetheir currencies.The reactions that this triggers in imports, exports and correspondingcapital flows then help to bring the current account back closer tobalance.In a monetary union, however, this is obviously no longer an option.Spain no longer has a peseta to devalue; Germany no longer has adeutsche mark to revalue.Other things must therefore give instead: prices, wages, employmentand output.The question now is which countries have to shoulder the adjustmentburden.Naturally, this is where opinions start to differ.The German position could be described as follows: the deficit countriesmust adjust.They must address their structural problems, reduce domestic demand,become more competitive and increase their exports.But this position has not gone uncontested.Indeed, well-known commentators suggest that surplus countriesshould bear part of the adjustment burden in order to avoid deflation indeficit countries.They also point out that not all countries can act like Germany, in otherwords, not all countries can run a current account surplus.Hence, they suggest that surplus countries should shoulder at least partof the burden.But this criticism misses the point of what the correction of domesticimbalances actually means:As regards the lingering threat of a protracted deflation, it is rather aone-off reduction of prices and wages that is required, not a lastingdeflationary process.
  44. 44. In fact, frontloading reforms and necessary adjustment has proven to bemore successful than protracted adjustment, as experience in the Balticstates and Ireland shows.And while not all countries can run a current account surplus, all canbecome more competitive – higher competitiveness due to productivityincreases or lower monopoly rents in, up to now, overregulated sectors isnot a zero sum game.Structural reforms can unlock the potential to increase productivity andthus improve competitiveness without inducing deflation.There is no way around the fact that Europe is part of a globalised world.And, at the global level, we are competing with economies such as theUnited States or China.To succeed, Europe as a whole has to become more dynamic, moreinventive and more productive.Once the deficit countries start to become more competitive, surpluscountries will adjust automatically.They will become less competitive in relative terms, exporting less andimporting more.And we should acknowledge that this process has already been set inmotion.Exports of a number of peripheral countries have started to grow,bringing down current account deficits in the process.Correspondingly, German imports from the euro area have grownstrongly over the last two years, almost halving the current accountsurplus between 2007 and 2011.To facilitate the adjustment process, euro area members havecommitted significant funds within the framework of the EFSF and theESM.Germany is contributing the biggest share.This support is based on the high reputation Germany enjoys amonginvestors.We would put this trust in jeopardy if we were to give in to calls for fiscalstimulus in Germany in order to raise demand for imports from theperipheral euro area.
  45. 45. But weakening Germany’s fiscal position would lead to higherrefinancing costs and, therefore, either reduce the capacity of thefirewalls or raise the borrowing costs for programme countries.Moreover, studies by the IMF suggest that positive spill-over effectsfrom an increase in German demand to partner countries in the euroarea would be minimal.So, instead of stimulating exports in peripheral euro-area countries,additional fiscal stimulus at a time when Germany’s economy is alreadyrunning at normal capacity would be of detriment to all parties.2.2 Fiscal consolidationTurning to fiscal consolidation, it is often stressed that such measures,together with structural reforms, would be too much of a burden.They would create a vicious circle of decreasing demand and furtherbudget pressure that would eventually bring the economy down.But to the extent that the current output level was fuelled by anunsustainable ballooning of private and public debt, correction as suchis unavoidable, and the only question that remains is that of the besttiming.However, this crisis is a crisis of confidence.While, under normal circumstances, consolidation might dampen theeconomy, the lack of trust in public finances and in policymakers”willingness to act is a huge burden for growth.Thus, frontloaded, and therefore credible, consolidation would insteadstrengthen confidence, actually help the economy to grow and reducethe danger of the crisis spreading to the financial system.In addition, urgently needed structural reforms and consolidation areoften hard to disentangle.For example, a bloated public sector or very generous pension systemare both a drag on growth and a burden on the budget.The same applies to inefficient companies that are state-owned oroperate in highly regulated sectors.The risks to growth emanating from immediate fiscal consolidationtherefore have to be put into perspective.Negative short-term effects cannot be ruled out.
  46. 46. But to the extent that consolidation constitutes necessary corrections ofan unsustainable development and brings about greater efficiency, thelong-term gains do not only vastly exceed potential short-term pain, theyalso help to alleviate it now by restoring the lost credibility in the abilityto tackle the root causes of the crisis.3 The role of monetary policyUp to now, the picture has been mixed in this regard.We have seen substantial progress, often initiated by new, morereform-minded governments, but also some setbacks.A much clearer pattern has emerged with respect to the expectationsplaced on monetary policy.Whenever a new intensification of the crisis looms, the first questionseems to be “What can the central banks do about this?”To me, this is a worrisome development. Monetary policy has alreadygone a very long way towards containing the crisis.But we have to be aware that the medicine of a very low interest ratepolicy, ample provision of liquidity at very favourable conditions andlarge-scale financial market intervention does not come without sideeffects – which are all the more severe, the longer the drug isadministered.In the course of this crisis, the role of central banks has changedfundamentally.Before the crisis, they provided scarce liquidity; now they increasingserve as a regular source of funding for banks, and this threatens toreplace or displace private investors.This may give rise to new financial instability if, as a result of themeasures, banks and investors behave carelessly or embark onunsustainable business models, for instance, due to substantialcarry trades.But emergency measures will not become the “new normal”.Banks, investors and governments have to be fully aware of this, andcentral banks cannot tolerate that their well-intentioned emergencymeasures result in a delay in necessary adjustments in the financialsector or protracted consolidation and reform efforts amonggovernments.
  47. 47. 4 ConclusionLadies and Gentlemen, In my remarks, I have focused on necessaryreforms in the euro area member states.This is not to say that changes to the institutional set-up of monetaryunion are not important.If member states want to retain autonomy with regard to fiscal policy,we need stricter rules to account for the incentives to accumulate debtthat exist in a monetary union.The fiscal compact is a promising step forward. Now, it is essential thatthe rules are applied rigorously.Referring to the motto of this conference “A German Europe or aEuropean Germany”, how should one label the recipe to overcome thecrisis that I have just presented?Well, it is, quite obviously, a European solution.And that is because it fully reflects and respects the letter as well as thespirit of the European Treaty and therefore of the principles that Istressed at the beginning.The current crisis is most certainly a defining moment for monetaryunion.But the crisis and the measures taken to overcome it should not beallowed to redefine implicitly what monetary union actually is.This time we really cannot “let this crisis go to waste”, as the formerWhite House chief of staff, Rahm Emanuel, put it. The crisis has laidbare structural flaws at many levels.It has questioned the way we adhered to the principles of EMU, but didnot invalidate the principles themselves, quite the contrary.I am confident that having stared into the abyss, Europe will make theright choices and pave the way for a more prosperous and sustainablefuture – to the benefit of Germany as well as of the euro area as a whole.
  48. 48. ENERGY ≠ HEAT: DARPA SEEKS NON-THERMALAPPROACHES TO THIN-FILM DEPOSITIONChemistry and physics researchers wanted to develop new approachesto reactant flux, surface mobility, reaction energy, by-product removal,nucleation and other components of thin-film depositionWhen the Department of Defense (DoD) wants to build a jet engine, itdoesn’t put a team of engineers in a hangar with a block of metal andsome chisels.Jet engines are made up of individual components that are carefullyassembled into a finished product that possesses the desiredperformance capabilities.In the case of thin-film deposition—a process in which coatings withspecial properties are bonded to materials and parts to enhanceperformance—current science addresses the process as though it isattempting to build a jet engine from a block of metal, focusing on thewhole and ignoring the parts.Like a jet engine, the thin-film deposition process could work better if itwas addressed at the component level.Thin-film deposition requires high levels of energy to achieve theindividual chemical steps to deposit a coating on a substrate.Under the current state of practice, that necessary energy is generatedby applying very high temperatures—more than 900 degrees Celsius insome cases—at the surface of the substrate as part of a chemical vapordeposition process.The problem with using the thermal energy hammer is that theminimum required processing temperatures exceed the maximumtemperatures that many substrates of interest to DoD can withstand.As a result, a wide range of capabilities remain out of reach.DARPA created the Local Control of Materials Synthesis (LoCo)program to overcome the reliance on high thermal energy input byaddressing the process of thin-film deposition at the component level in
  49. 49. areas such as reactant flux, surface mobility, reaction energy, nucleationand by-product removal, among others.In so doing, LoCo will attempt to create new, low-temperaturedeposition processes and a new range of coating-substrate pairings foruse in DoD technologies.“What really matters in thin-film deposition is energy, not heat,” saidBrian Holloway, DARPA program manager.“If we break down the thin-film deposition process into components, weshould be able to achieve better results by looking at each pieceindividually and then merging those solutions into a new low -temperature process.It’s going to be researchers in specialties like plasma chemistry,photophysics, surface acoustic spectroscopy and solid-state physics whomake it possible.DARPA seeks scientists who can contribute pieces of the puzzle so thatthe LoCo team can put them together.”Breakthroughs in thin-film deposition could enhance performance andenable new capabilities across a range of DoD technologies, impactingareas as diverse as artificial arteries, corrosion-resistant paint and steelcombinations, erosion-resistant rotor blades, photovoltaics andlong-wavelength infrared missile domes, among others.As a second focus area, the LoCo program seeks performers to evaluatethe cost and performance impacts of coating application to existingDoD parts and systems.Through these assessments, DARPA hopes to identify a specific pieceof equipment that would benefit from a novel coating to use as a test bedfor any new thin-film deposition process.Through this parallel effort, LoCo intends to move from initial researchto practical application within three years.To answer questions regarding the LoCo program, DARPA will hold aProposers’ Day workshop on May 9, 2012.This live workshop and simultaneous webcast will introduce interestedcommunities to the effort, explain the mechanics of a DARPA programand address questions about proposals, participation and eligibility.The meeting is in support of the forthcoming Local Control of MaterialsSynthesis Broad Agency Announcement (BAA) that will formally solicitproposals.
  50. 50. More information on the Proposers’ Day is available at:http://go.usa.gov/y6M.The BAA will be announced on the Federal Business Opportunitieswebsite (www.fbo.gov).Note:DARPA’s – or ARPA’s, as it was called at the time – involvement in thecreation of the Internet began with a memo.
  51. 51. Dated April 23, 1963, the memo was dictated as its author, Joseph CarlRobnett Licklider, was rushing to catch an airplane.No surprise there:Licklider was spending a lot of his time on airplanes in those days.The previous fall, he had come to the Pentagon to organize theInformation Processing Techniques Office (IPTO), ARPA’s first effortto fund research into “command and control” – that is, computing.And he had been crisscrossing the country ever since, energeticallyassembling a network of principal investigators scattered from the RandCorporation in Santa Monica, Calif., to MIT in Cambridge, Mass.