Findings on the Interaction of Market and Credit Risk (BIS,
May 200)
Executive summary
For many reasons, both historical and practical,
market
and credit risk have often been treated as if they are
unrelated sources of risk: the risk types have been
measured separately, managed separately, and economic
capital against each risk type has been assessed
separately.
The development of
credit risk transfer
markets and the moves to mark-to-market accounting
for
portions of held-to-maturity banking book positions,
however, have blurred distinctions
between them and
raise questions regarding approaches that treat the two
types of risks separately.
Market participants have
argued that there are significant diversification
benefits to be reaped from the integrated measurement
and management of market and credit risks.
The recent
financial crisis, however, has illustrated
how the two
risks may reinforce each other and that in such stress
situations illiquidity can worsen losses further.
From a
supervisory perspective, these developments raise
important questions related to how the two types of
risks can be defined and what relationships exist
between them, how they should be aggregated and how
precisely their joint risk is measured, what role
liquidity plays in their interaction and under what
conditions securitisation – as one driver of the above
developments – can work as a risk management approach.
Against this background, but before the start of the
ongoing financial crisis,
the Basel Committee on Banking
Supervision established a working group under its
Research Task Force to study the interaction of market
and credit risk (the IMCR group).
The group’s mandate
was to undertake research that contributes to the
understanding of the interaction between market and
credit risk in the context of risk measurement and
management.
Working group members’ research efforts are
documented in a number of individual and jointly
authored working papers that are available from the
authors or their home institutions.
This paper
summarises the findings of the IMCR group’s efforts,
focusing on the main lessons for supervisors and on the
answers to the questions mentioned above.
Many of the
projects were underway or largely completed prior to the
crisis that began in August 2007. Even though many
issues that have become apparent since its start are not
directly reflected in the group’s research agenda, the
paper highlights the aspects of the findings that
are
particularly relevant for it, for example by
contributing to the understanding of its causes and
propagation mechanisms.
This “Findings” paper is
organised around four related sets of conclusions.
The first set of conclusions deals with conceptual
distinctions and empirical relationships between market
and credit risk.
Market risk and
credit risk are often distinguished by identifying the
latter with (actual or expected) default.
(A
straightforward way to define default is the failure to
meet a contractually pre-determined obligation.)
As the
same economic factors tend to affect both types of risk,
drawing a clear distinction between them in
practical risk measurement and management is, however,
very difficult.
Even if distinct factors could
be separately associated with the two types of risk, the
factors often interact significantly in determining
asset values, and therefore risk measurement and
management needs to explicitly account for their joint
influence.
In practice,
market and credit risk are often distinguished in
relatively simple ways on the basis of instruments,
market liquidity, accounting treatments or holding
periods.
Care should be exercised to
ensure that such pragmatic distinctions
do not lead risk managers to
ignore important risks that emanate from the
interactions between market and
credit risk.
The important interactions between market and credit
risk and their form lead to the second set of
conclusions, which summarises some central research
results by the IMCR group.
These concern errors in
aggregating the two types of risk
and the issue of
whether diversification benefits can be identified.
Ideally, an integrated risk modelling approach would be
preferable to account for material interactions between
market and credit risk.
This requires, inter alia, that
all gains and losses are captured in a consistent way
across the two types of risk.
Compared to approaches
often encountered in practice, adjustments may be
necessary, for example to not only consider losses on
held-to-maturity loan portfolios but also (interest)
earnings.
Moreover, in certain portfolios market and
credit risk are related in a non-linear way.
Since this
means that they are inextricably linked,
conventional
approaches that estimate each risk type separately and
then aggregate them (such as “top-down” risk aggregation
approaches), which are widely used in the industry, may
lead to sizable biases in overall risk estimates.
For
example adding the separately estimated risk components
may not be conservative, as often thought, because
non-linear interactions may lead to compounding
effects.
[Compounding describes a situation in which the overall
risk is greater than the sum of the separately measured
different risk components.]
Examples of positions in which such
compounding effects may be present include
foreign
currency loans, adjustable rate loans (including
sub-prime mortgage loans) or matching long and short
positions in OTC derivatives.
There may also be cases in
which diversification benefits are underestimated.
On
balance, the IMCR results suggest a rather “cautionary
tale”.
Claims about the presence of diversification
benefits between market and credit risk should be
regarded with great caution if they are not derived from
an integrated (“bottom-up”) approach.
Successful management of market and credit risk often
relies on liquid markets to hedge risks and unwind
positions, as the ongoing financial crisis has
abundantly illustrated.
Therefore, the third set of
conclusions addresses the role of market liquidity for
the relationships between market and credit risk. (Other
liquidity concepts such as funding liquidity were not
considered by the IMCR group.)
Liquidity conditions
interact with market risk and credit risk through the
horizon over which assets can be liquidated.
In
particular, deteriorating market liquidity often forces
banks to lengthen the horizon over which they can
execute their risk management strategies.
As this time
horizon lengthens, overall risk exposures increase, as
does the contribution of credit risk relative to market
risk.
The liquidity of traded products can vary
substantially over time and in unpredictable ways.
Theoretical IMCR research indicates that such liquidity
fluctuations, all else equal, should have a larger
impact on prices of products with greater credit risk.
Conversely, as the current financial crisis illustrates,
valuation uncertainties or other shocks that enhance
actual or perceived credit risks can have adverse
effects on liquidity and put in motion a downward spiral
between market prices and liquidity of traded credit
products (see for example the case of tranches from
collateralised debt obligations based on sub-prime
loans).
Securitisation transforms credit risk into market risk
by pooling loans and issuing tradable claims against the
pool.
It is a risk management and funding tool that
relies on the liquidity of primary markets for placing
asset-backed securities.
The final set of conclusions
selects a few research results relating to
securitisation in this sense, without addressing many of
the other problems currently discussed in this area.
Securitisation offers potential benefits by allowing
banks to focus on intermediation and (only) selected
risk bearing to better manage their loan portfolios.
The
current financial crisis has, however, demonstrated
problems that can arise in securitisation.
Work
undertaken by members of the IMCR group illustrates that
widespread mis-pricing and distorted investments can
occur if the incentives of underwriting banks and
investors are improperly aligned.
As a consequence the
markets for risk sharing and funding can become illiquid,
exposing the banks to significant risks.
Insufficient
knowledge about pricing parameters, such as
credit
correlations, further increase the risks associated with
risk management strategies that rely on securitisation.
Findings on the interaction of market and credit risk
1. Introduction
For many reasons, both historical and practical,
market
and credit risks have often been treated as if they are
unrelated sources of risk: the risk types have been
measured separately, managed separately, and economic
capital against each risk type has been assessed
separately.
The development of
credit risk transfer
markets and the moves to mark-to-market accounting
for
portions of held-to-maturity banking book positions,
however, have blurred distinctions between them and
raise questions regarding approaches that treat the two
types of risk separately.
Market participants have
argued that there are significant diversification
benefits to be reaped from the integrated measurement
and management of market and credit risks.
The recent
financial crisis, however, has illustrated
how the two
risks may reinforce each other and generate large losses
if not managed jointly in the appropriate fashion.
It
has also illustrated the significant role that
illiquidity can play in such stress situations.
From a supervisory perspective, these developments raise
important questions.
Can one usefully define and
distinguish the two forms of risk?
What relationships
exist between them?
Are present risk management and
aggregation approaches precise in measuring and managing
their combined risk?
How should risk aggregation within
the economic capital framework recognise the links
between the two risk categories?
How should regulation
and supervision account for these relationships?
What
role does market liquidity play in the interaction of
them? Finally, given the importance of securitisation
for the developments described above, what are the
conditions under which this bank risk management and
funding tool can deliver its main benefits?
Against this background, but before the start of the
ongoing financial crisis, the Basel Committee on Banking
Supervision established a working group under its
Research Task Force to study the interaction of market
and credit risk (the IMCR group).
The mandate of the
group was to conduct research that would lead to an
improved understanding of the interaction between market
and credit risk and how this interaction is related to
risk measurement and management.
The IMCR group operated between 2006 and 2008. Working
group members studied many specific issues related to
the interaction of market and credit risk and their
research efforts are documented in a number of
individual and jointly authored working papers.
The
papers are available from the authors themselves or
their sponsoring institutions.
The group also held a public
conference in December 2007, which featured a selection
of its own projects, academic and industry
contributions, and kept it abreast of relevant risk
management developments in the banking sector.
This paper summarises the main findings of the IMCR
group.
In so doing, it focuses on the answers to the
questions mentioned above, which have emerged from the
group’s different streams of work.
It is organised
around four related sets of conclusions.
The first set
of conclusions deals with some conceptual issues, in
particular regarding the distinction between market and
credit risk.
They lead to the
second set of conclusions, which summarises some central research results of the
group.
These concern problems in aggregating the two
types of risk and whether diversification effects can be
identified.
The third set of conclusions addresses the
role of market liquidity for the relationships between
market and credit risk.
The final set
of conclusions
involves selected results related to securitisation.
Even though the bulk of the work was already completed
before the onset of the current financial crisis, the
report highlights the aspects of the group’s findings
that are particularly relevant for it, for example by
contributing to the understanding of its causes and
propagation mechanisms.
2. Conceptual issues: Distinctions and relationships
between market and credit risk
Market risk and credit risk can be distinguished on the
basis of identifying the latter with (actual or
expected) default.
A straightforward way to
define
default is the failure to meet a contractually
pre-determined obligation.
As the same economic factors
tend to affect both types of risk, drawing a clear
distinction between them in practical risk measurement
and management is, however, very difficult.
Even if
distinct factors could be separately associated with the
two types of risk, they often interact significantly
in
determining asset values, and therefore risk measurement
and management needs to explicitly account for their
joint influence.
In practice, market and credit risk are
often distinguished in relatively simple ways on the
basis of instruments, market liquidity, accounting
treatments or holding periods.
Care should be exercised
to ensure that such pragmatic distinctions do not lead
risk managers to ignore important risks that emanate
from the interactions between market and credit risk.
Economic risk,
as contrasted with operational or legal risk, for banks
refers to uncertainty about the future (economic as
opposed to accounting) value of assets and liabilities.
Very often
distinctions are made between market and credit
components of economic risk and their respective
risk drivers.
In fact, market and credit risk can be distinguished by
relating the latter to some notion of default, be it the
actual occurrence of default or changes in the
expectations about the probability of default.
A
straightforward way to define default is the
non-delivery of a contractual obligation by the obligor
counterparty.
Starting from this view on credit risk,
market risk can then be described as fluctuations in
value (or expectations about future fluctuations)
that
relate to changes in relative prices (such as exchange
rates, commodity prices, etc), in the discount factor (ie
interest rates and risk premia) or in the level of cash
flows,
which
are not nominally pre-determined by contract.
[An
investment in stocks represents only market risk because
dividends are not pre-determined by contract.
By
contrast, holdings of bonds issued by the same company
would be subject to credit (and market) risk because the
timing of the repayment of coupon and principal amounts
is specified in the contract.]
This (and other) distinction(s) should not be
overstated, however, as default may be affected by
fluctuations in asset prices.
Market and credit risk
tend to be driven by the same economic factors.
For
example, stock and bond values both change with the
macroeconomic environment, shifts in general asset
prices (including the yield curve) and specific business
prospects, managements and capital structures of the
companies concerned.
Still, the effect of each of these
factors on a firm’s stock price will typically be
different from its effect on the firm’s bond price.
The identification of common risk drivers foreshadows
important interactions between market and credit risk.
As a consequence,
it is very difficult to distinguish
these two risks clearly in practical risk measurement
and management.
Even in cases when each risk can be
associated with different risk drivers these may be
correlated.
In some situations
models that treat market
and credit risk as independent may be adequate whereas
in other situations accurate risk measurement will
require that the joint influence of common or correlated
risk drivers be explicitly recognised when measuring
these risks.
Research of the IMCR group provides
evidence for these interactions both at the “macro”
level of the economy as a whole and at the “micro” level
of the sensitivity of individual bank risk to different
risk drivers.
At a “macro” level, empirical results from research
conducted by group members highlight
dynamic aspects of
linkages between market and credit risk.
Correlations
between macroeconomic variables and asset prices
reflecting the impact of interest rates, default rates
and charge-offs, equity prices, and prices of
default-sensitive instruments are significant from both
a statistical and an economic point of view.
Furthermore, the interactions between these variables
become more apparent when examined through their dynamic
responses to different shocks.
For instance, empirical
results for Italy suggest that a shock in the short-term
interest rate (as caused, for example, by a tightening
of monetary policy) has a larger effect on firm default
rates when the credit risk model accounts for feedback
from interest rates on equity prices and other proxies
of market risk.
At the “micro” level, a study of the IMCR group of the relationship between
credit default
swap (CDS) spreads and equity prices provides evidence
consistent with the hypothesis that market and credit
risks emerge from similar risk drivers.
The study finds
a close positive correlation between the risks of CDS
portfolios and equity portfolios for the same
companies.
The prior analysis that identifies common risk drivers
and strong interactions among market and credit risk
measures suggests some caution towards simple ways to
distinguish the two types of risk on the basis of
specific characteristics of exposures.
First, little
distinction can be made on the basis of the identity of
instruments.
While exposure profiles of some instruments
may be predominantly composed of market or credit risk,
there are many assets that combine elements of both
types of risk.
Second, separating the two on the basis
of the existence of liquid markets is problematic.
Tradable assets are often treated as being mainly
subject to market risk.
This method of identification
may mask important features of credit risk in that few
models explicitly account for the risk that market
liquidity conditions may change and inhibit the ability
to hedge or trade a position.
What was
once identified as a liquid tradable position perceived
to be predominantly subject to market risk
may become a
held-to-maturity position with a risk profile dominated
by credit risk.
Third, accounting treatments may also
not be a reliable way to distinguish between market and
credit risk, as for example the fair-value accounting
option can be used for loan portfolios and more
frequently traded credit instruments tend to be
marked-to-market.
Finally, there are
significant dangers of associating
market and credit risk too closely with the intended use
or holding period of an investment, as indicated by the
booking of specific positions in the trading or banking
book.
In particular, the trading portfolio of banks is
often treated by practitioners as being primarily (if
not exclusively) subject to market risk even though
unexpected defaults may occur, for example, in a traded
bond portfolio.
As evidenced by the recent financial
crisis, this is clearly a mis-conception.
Underestimation of the credit risk embodied in
structured products, inter alia, resulted in large
write downs by financial institutions.
This includes
credit-related event risk in the trading book.
Given
the significant and increasing importance of credit risk
in the trading book, the Basel Committee has addressed
it in Basel II and currently goes further in the context
of its trading book review.
Similarly, it would be
wrong to ignore the market risk from changes to the
discount rate in a loan portfolio. Subsection 3.2 below
addresses the issue of interest rate risk in the banking
book from the perspective of interacting market and
credit risk and the potential for diversification
effects.
For practical reasons, however,
distinctions between
market and c redit risk still play a significant role in
risk measurement and management practices.
But such
practices should not lead risk managers to ignore the
common and interdependent features of market and credit
risk, as they need to be taken into account to measure
and manage overall economic risk appropriately.
3. Aggregation issues: Diversification versus
compounding between market and credit risk
Ideally, an
integrated risk modelling approach would be
preferable to account for material interactions between
market and credit risk.
This requires, inter alia, that
all gains and losses are captured in a consistent way
across the two types of risk.
Compared to approaches
often encountered in practice adjustments may be
necessary, for example to not only consider losses on
held-to-maturity loan portfolios but also (interest)
earnings.
Moreover, in certain portfolios the two types
of risk are related in a non-linear way.
Since this
means that they are inextricably linked,
conventional
approaches that estimate each risk type separately and
then aggregate them up (such as “top-down” risk
aggregation approaches), which are widely used in the
industry, may lead to sizable biases in overall risk
estimates.
For example,
adding the separately estimated
risk components may not be conservative, as often
thought, because non-linear interactions may lead to
compounding effects.
There may also be cases in which
diversification benefits are underestimated.
Claims
about the presence of diversification effects between
market and credit risk, however, should be regarded with
great caution if they are not derived from an integrated
(“bottom up”) approach.
Despite the relationships between market and credit
risks discussed in the previous section, applied risk
measurement often proceeds in a compartmentalised
fashion.
The frequently used “top-down” approach first
aggregates each risk type across positions and then only
combines them at a higher level, often in a linear way.
Since it therefore
neglects a multitude of market-credit
risk interactions, the question arises whether such an
approach may lead to appreciably biased estimates or
whether overall economic risk is still well
approximated.
A series of IMCR research papers suggest
that the potential for biased risk assessments is
substantial and that an integrated, “bottom-up” approach
– combining market and credit risk measurement from the
level of individual exposures and building it up to the
level of portfolios and the bank as whole – may be able
to avoid biases.
This section starts with cases in
which compartmentalised approaches may lead to the
underestimation of risk.
Then cases are reported in which
they would overestimate risk.
After reporting an
analysis in which both cases can emerge,
practical
challenges to the integrated measurement of market and
credit risks are discussed.
3.1 Compounding effects
A commonly held view suggests that simply summing up the
separately measured risk components under the top-down
approach leads to “conservative” estimates of overall
risk
The argument is that the summing of components
assumes perfect correlation between market and credit
risks
But if they are imperfectly correlated, then
diversification effects are ignored and total risk
overestimated.
This intuition, however, does not necessarily hold when
market and credit risk interact in a non-linear fashion.
Non-linear interaction
emerges when losses from default on an instrument depend
on movements in market risk factors, or conversely, when changes in
the values of instruments due to movements of market
risk factors depend on whether there is a default or
rating migration.
In these circumstances, the two types of risk
are inextricably linked, and attempts to measure them
separately and then combine them can lead to substantial
biases.
In fact, IMCR research shows
cases in which the combined risk is actually higher than
the sum of the components
(“compounding
effects”, the opposite of diversification effects).
A particularly clear example is
foreign
currency loans, which constitute a sizable part of
lending in certain countries.
Consider a bank lending in
foreign currency to domestic borrowers.
These positions
contain market risk (exchange rate risk) and
credit risk
(default risk of borrowers).
Now assess the two risks
separately.
When for example the domestic economy slows,
ceteris paribus, the probability of domestic borrowers
defaulting increases.
When the domestic currency
depreciates, ceteris paribus, the value of the loan in
domestic currency increases as it is denominated in
foreign currency.
So, on the surface
one could think
that the two effects offset each other. But this
reasoning would neglect the strong relationship between
exchange rate changes and default risk in this type of
contract.
The ability of a domestic borrower to repay a
loan in foreign currency depends in a non-linear way on
fluctuations in the exchange rate (unless the domestic
borrower has other revenues in the foreign currency in
which the loan is denominated).
A home currency
depreciation has a particularly malign effect on the
repayment amount and therefore repayment probability of aforeign currency loan by an unhedged domestic borrower,
which tends to be stronger than the valuation effect
mentioned above.
An analysis of foreign currency loans in Austria
indicates that simply adding up the separately measured
exchange rate and default risk components underestimates
the actual level of risk several times.
For example, for
a B+ rated obligor the integrated risk measurement
approach leads to an overall risk that is 1.5 to 7.5
times larger than the risk derived from a
compartmentalised approach (each risk measured
separately and then added up).
This bias becomes more
pronounced for portfolios with lower ratings and vice
versa.
The box describes a number of other examples where
nonlinear interactions between credit and market risk
allow for the possibility of compounding effects to
occur. It shows that the case of foreign currency loans
is not just a peculiar exception.
The possible emergence
of compounding effects and the fact that adding up
separately measured market and credit risk components
may not lead to conservative estimates of overall
economic risk are of high practical relevance.
Box: Further examples of portfolios where compounding
effects may emerge
(i) Adjustable rate loans
Adjustable rate loans have coupons that change as
interest rates change.
Therefore, if the coupons on the
loans adjust frequently (or in the limit continuously),
then the interest rate risk of the loan is passed on to
borrowers, and therefore, assuming the loans do not
default, they have no market risk for the bank.
If credit risk is computed separately from market risk,
then the credit risk of the loans is computed while
holding interest rates constant.
This treatment of
credit risk can miss an important interaction between
market and credit risk.
For example, if probabilities of
default are increasing in interest rates, then holding
rates constant can easily lead to an understatement of
the true probability of default and hence the sum of
market and credit risk, when computed separately, would
lead to an understatement of total risk.
(ii) Carry trades and foreign currency loans
The carry trade is an investment strategy that borrows
funds in a low interest rate currency, and then lends
the funds at a high interest rate in another currency.
For example, suppose a UK investor does the carry trade
by borrowing from a Japanese bank at a fixed rate in
yen, and then invests the proceeds in pounds sterling.
If the Japanese bank computes its market risk and credit
risk separately, then market risk is computed assuming
the UK counterparty cannot default, in which case the
only source of market risk for the Japanese bank is due
to fluctuations in the yen term structure.
If credit risk is computed under the assumption that
interest rates and exchange rates do not fluctuate, then
the credit risk estimates do not depend on the potential
for fluctuations in interest rates and exchange rates.
If the probability that the borrower defaults and losses
given default depend on whether the carry trade is
ex-post profitable for the UK investor, then separate
treatment of market and credit risk can lead to total
risk being underestimated, because credit risk treatment
which holds exchange rates and interest rates constant
can lead to an understatement of credit risk.
(iii) Matching long and short positions in OTC
derivatives
If a bank buys an over-the-counter (OTC) derivative from
one counterparty and sells an exactly offsetting OTC
derivative position to another counterparty, then
assuming that the counterparties do not default, the
bank has no market risk because the losses on one
position are exactly offset by gains on the other
position.
Assuming the market values of the OTC derivatives do not
change (or are marked to market and re-collateralised
daily), then if one party defaults, its deliverable can
be purchased on the market at the same price.
Therefore,
there is no credit risk.
However, if market risk variables move and one of the
counterparties defaults at the same time, then movement
of the market risk variable and the default together
generate a loss for the bank.
A historical example of this mechanism is what happened
to foreign currency forwards during the Russian crisis
in August 1998.
Western banks held dollar/rouble
forwards with Russian banks and exactly opposite
positions with Western customers.
These portfolios were
fully hedged against moves in the dollar/rouble exchange
rate.
Furthermore, for a given exchange rate, default
risk was irrelevant to these positions.
If some
counterparty defaulted, it was always possible to get
the currency deliverable to the other counterparty on
the market at no loss at the given exchange rate.
In
August 1998 adverse credit events and market moves
occurred simultaneously.
The Russian counterparties
defaulted and at the same time the rouble floated and
its value dropped dramatically.
The dollars deliverable
to the Western customers had to be purchased on the
market, and the roubles banks received in return had
lost much value. This led to considerable losses for the
banks involved.
3.2 Diversification effects
Highlighting positions or portfolios in which
compounding effects between market and credit risk occur
does not mean that the opposite, diversification
effects, is not possible in other circumstances or
portfolios.
Research by the IMCR group demonstrates
this for the interactions between interest rate and
credit risk in the banking book, taking the example of a
representative UK bank.
This bottom-up analysis
highlights the importance of modelling the whole banking
book including assets, liabilities and interest
sensitive off-balance sheet items.
The interaction of
interest rates and default probabilities tends to create
non-linear effects that are difficult to capture outside
an integrated model of overall economic risk.
The main mechanisms at work are described by means of a
stress test simulation based on a model calibrated to
data from the UK and starting from a shock to interest
rates.
On the negative side for bank profits, higher
interest rates lead to more borrower defaults and
decreased net-interest income because of a margin
compression between short term borrowing and long term
lending.
Over time, however,
banks regain their
profitability as assets re-price and lending margins
recover as higher interest rates and credit risk are
passed on to borrowers.
The consideration of loan
revenue (and deposit cost) developments is of course an
important difference to standard credit risk models that
focus on the probability of loan losses.
Using a stylised set of assumptions,
the model
calibrated to the profile of a typical UK bank is then
used to assess aggregate risk and required capital.
The results suggest significant diversification benefits
between interest rate and credit risk in the banking
book.
In fact, the gains of passing on interest rate and
credit risk changes to borrowers over time are estimated
to be so large that the economic capital set against
interest rate and credit risk together is lower than the
capital that would have to be set against credit risk
considered in isolation.
One implication of these
results is that non-linear interactions between market
and credit risk do not necessarily lead to compounding
effects (see Subsection 3.1), while compartmentalised
measurement of market and credit risk could still lead
to sizable mistakes in the assessment of overall risk in
the banking book.
The analysis provides an example in
which there are large diversification benefits, but
recognition of these benefits requires that all risk and
profit sources are measured on a consistent basis.
A key
feature driving the diversification results in this
model is the assumption that lending margins revert to
long/run equilibrium levels and the recognition that
earnings on banking book positions can, over time,
offset market and credit risk stress scenario losses.
3.3 Value of and obstacles to integrated risk
measurement
Further research from the IMCR group suggests that the
value of integrated risk measurement and modelling goes
beyond whether specific positions or portfolios exhibit
either diversification or compounding effects between
market and credit risk.
Mis-measurement of overall risk
may go in both directions; overestimation and
underestimation, even for the same portfolio
structure.
From a longer term perspective, all the research results
reported in this section underscore the importance of
risk measurement on the basis of integrated, bottom-up,
rather than compartmentalised approaches.
Given the
strong and complex interactions between market and
credit risk, the different biases identified can only be
avoided through integrated approaches.
Market
information suggests, however, that integrated risk
modelling is currently only observed in specific,
usually trading-related areas such as securitisation and
credit derivatives businesses.
Moreover, the recent
survey by the Senior Supervisors Group finds that some
banks that are more severely affected by the current
financial crisis had difficulties in integrating certain
market and credit risks across business lines, whereas
firms that are less affected had not.
The practical challenges of moving to a fully integrated
measurement and management of economic risk, however,
are currently substantial.
A first major obstacle to
integrating market and credit risk measurement and
management is that the metrics typically used for each
of them are not fully comparable, with market risk
models capturing a full distribution of returns and
credit risk models focusing on losses from default and
neglecting gains.
For example,
market risks are often
measured using value-at-risk from “dirty” mark-to-market
valuation changes on a portfolio.
These valuation
changes include profits and losses that arise from
changes in modelled pricing factors, but they typically
exclude trading fee revenues, accrued interest and
dividends on trading book positions, and specific
position returns (specific risk) that are not measured
in the value-at-risk model.
As the measurement time
horizon lengthens, not only will appropriate
value-at-risk estimation methods change, but the
importance of accrued fees, interest and dividend
earnings and specific risk can become important
components of the economic profit and loss position on
the trading book.
Similarly, as the time horizon
lengthens, it becomes important for market risk economic
capital estimates to account for expected returns on
portfolio positions and funding interest costs.
On the credit
risk side, few credit risk or capital models attempt to
model the full profit and loss distribution on
held-to-maturity positions.
Typically models
estimate credit losses and ignore the interest earnings
on performing credits and interest costs to fund the
portfolio.
Second, the arguably most important obstacle to the
further integration of market and credit risk
assessments is the different horizons over which risks
are measured.
This is clear from current practices,
despite the increased tradability of credit risk through
the expansion of securitisation and related financial
innovations over the last decade.
Finally, it should be
mentioned that an integrated model makes very
significant demands on data and technological
infrastructure.
In sum, an integrated approach must measure market and
credit risk components on a consistent basis; account
for profits as well as losses, recognise all sources of
income and impose a common horizon.
In practice,
few
models of market or credit risk fully respect these
requirements.
In this light, an IMCR study constructs a
model, similar in structure to the models used in
practice, but fully consistent in horizon and revenue
recognition andcompares the integrated risk measures to
the ones derived from compartmentalised approaches.
The model recognises default and migration credit risks
as well as market risk that arises from volatility in
the risk free term structure and spread factors that
determine discount rates for different rating classes of
loan exposures.
When it is calibrated to reflect a
typical portfolio profile of BBB-rated obligors,
estimates suggest that the compartmentalised approaches
for estimating risk can underestimate economic capital
in some cases by a factor of two while in others they
may overstate it by as much as 60%.
The bias in
compartmentalised capital estimates relative to the
integrated model depends on how the compartmentalised
capital estimates are constructed relative to horizon,
revenue recognition and recognition of portfolio funding
costs.
Against the claims by the industry about substantial
diversification benefits to be reaped from integrating
market and credit risk, the results of the IMCR group
rather suggest a “cautionary tale”.
Supervisors
confronted with the aggregation methodologies of banks
(such as in the calculation of economic capital, for
example) should be alert to the fact that
diversification benefits are by no means a foregone
conclusion.
Careful supervisory validation of estimated
diversification effects is fully justified, especially
when they are derived from top-down methods and involve
simple correlations.
In fact, market information
indicates that top-down is the dominant approach among
banks.
Supervisors need to require bank risk managers to
explain and justify diversification effects in terms of
the interactions between market and credit risk
components of overall risk, which may not always be
linear and easily captured by (linear) correlation
measures.
For specific positions or portfolios in which
particularly malign non-linear interactions between
market and credit risk components exist, supervisors may
even require risk managers to explain the absence of
compounding effects.
An important area for future research remains a
systematic study of how prevalent the compounding
effects in the aggregation of market and credit risks
described above are relative to the diversification
effects often stressed by market participants.
4. Liquidity issues: The role of the liquidity horizon
for the interaction between market and credit risk
Liquidity conditions interact with market risk and
credit risk through the horizon over which assets can be
liquidated.
In particular, deteriorating market
liquidity often forces banks to lengthen the horizon
over which they can execute their risk management
strategies.
As this time horizon lengthens,
overall risk
exposures generally increase, as does the contribution
of credit risk relative to market risk.
The liquidity of
traded products can vary substantially over time and in unpredictable ways.
Such liquidity fluctuations, all else
equal, should have a larger impact on prices of products
with greater credit risk.
Conversely, as the current
financial crisis illustrates, valuation uncertainties or
other shocks that enhance actual or perceived credit
risks can have adverse effects on liquidity and put in
motion a downward spiral between market prices and
liquidity of traded credit products.
Banks’ exposures to market and credit risk depend on
their risk management strategies.
Because many
strategies rely on liquid markets for hedging, or for
unwinding positions to limit losses on exposures that
cannot be hedged, asset market liquidity is an important
determinant of banks’ overall risk profile.
Additionally, since liquidity is time varying, and
markets typically become less liquid when risk increases
appreciably, recent events make abundantly clear that
how liquidity interacts with other sources of risk needs
to be better understood.
This section first describes
which aspects of liquidity the IMCR group considered.
It then discusses
how changing market liquidity can
alter the relative balance of market and credit risk in
bank portfolios.
Next it provides an example of how changing
market liquidity is associated with interactions between
market and credit risk.
Last it addresses the reverse
direction, how increased uncertainty and risk impairs
market liquidity, and links it to observations from the
current financial crisis.
The focus of the IMCR group was primarily on market
liquidity and not on funding liquidity or any other
liquidity concept.
Market liquidity conditions determine
the liquidity horizon, which measures the amount of time
required to unwind a position without unduly affecting
the underlying instrument prices (including in a
stressed market).
Unanticipated shocks to market
liquidity conditions can change a bank’s liquidity
horizon and alter the blend of market and credit risk in
its portfolio.
This occurs for two reasons.
First, over
very short horizons, in normal circumstances, defaults
tend to be largely idiosyncratic.
Therefore, in well
diversified portfolios, losses due to unexpected
defaults are expected to be negligible over short
horizons.
The dominant risk in credit portfolios over
short horizons is expected to materialise through
mark-to-market price changes, not defaults.
Such
valuation changes are likely to be categorised as market
risk, especially if the positions are in the trading
book.
If instead the positions are not marked to market
and held to maturity, the risk might not be measured at
all.
Over longer horizons,
defaults are driven by
changes in macroeconomic conditions that are not
diversifiable.
Therefore, risk from unexpected defaults
becomes relatively more important.
A second reason for why the liquidity horizon affects
the blend of risk is that market risk and default risk
may grow at different rates through time.
For example,
common models of default risk tend to assume that, over
modest horizons, the probability of default grows
approximately linearly with time.
By contrast common
value-at-risk models of market risk assume that risk
increases with the square root of time.
Therefore, for
assets with typically short liquidity horizons, such as
stocks, most of the risk occurs through changes in
market prices over the liquidity horizon.
Other
assets, such as bonds and CDS, trade far less and are
likely to have longer liquidity horizons and
consequently a larger share of credit risk.
The impact
of both changes in the liquidity horizon and changes in
credit risk on the overall risk of a portfolio is
explored in a simulation study carried out by the IMCR
group.
According to this research, a drying up of
liquidity associated with an increase in the liquidity
horizon from two weeks to six months would have the same
effect on the value-at-risk of a portfolio of A3-rated
assets as a downgrade of these assets by two notches
from A3 to Baa2 over a two-week liquidity horizon.
In
an alternative scenario in which the lengthening of the
liquidity horizon and the rating downgrade both occur at
the same time, the combined impact on the value-at-risk
is 2.3 times stronger than the sum of both effects
measured separately, showing that nonlinearities can
also have strong effects in the interaction of credit
and liquidity risk.
Although credit risk generally becomes more important
relative to market risk over longer time horizons, this
does not imply that positions that are held for short
horizons are immune from credit risk.
It rather means
that the credit risk may manifest itself through price
changes over short horizons (see above).
It also shows
well how difficult it has become in practice to sharply
distinguish market from credit risk (see Section 2).
If
banks held these loans on balance sheet and they were
not traded, their default would have affected the banks’
P&L only over time.
By holding CDOs that referenced the
loans, however, the perceived losses due to credit risk
were rapidly priced in and realised.
Given the importance of liquidity horizons for the
relative balance of market and credit risks in bank
portfolios, the IMCR group has also performed empirical
research on the trading activity in markets for certain
credit-risky instruments.
These studies indicate that
the liquidity in these markets is generally inferior
relative to a variety of other markets, such as stock
markets on public exchanges or major money and foreign
exchange markets.
In line with other research, they
find, for example, that in a sample of 3,755 US
corporate bonds only 15% traded at least once a week
over the period 2005–06, while less than half were
traded once every four weeks.
A similar message comes
from the analysis of market quotes for single-name CDS
spreads.
In a sample of 161 of the most liquid (obligor)
names almost 5% may not have a spread quoted on any
given day, and it takes on average six calendar days
before a new quote appears for the same contract.
An
important feature of financial markets is that liquidity
can change in unpredictable ways.
Asset prices will
reflect this in the form of risk premiums.
When the
horizon over which an asset is liquefiable changes,
asset prices will move in relation to their risk
exposures, since investors require larger risk premiums
for being exposed to certain risks for longer.
Theoretical IMCR research adds that changes in liquidity
should have a larger effect on the prices of assets
that, all else equal, have more credit risk.
This is
an illustration of how liquidity that is time-varying
causes market and credit risk to interact.
The relationships between market liquidity and different
risks need not only go in one direction: from
fluctuations in liquidity to changes in exposures to
market and credit risk. Often, dramatic changes in
liquidity are preceded by changes in risk and in risk
perceptions.
For example, further IMCR research shows
that changes in risk and uncertainty about valuation
models can cause liquidity conditions in markets to
deteriorate, which in turn lengthens liquidity horizons,
and reinforces the market and credit risk faced by
market participants, leading to even more exaggerated
price movements.
Market reports about the crisis paint a similar, though
more detailed, picture.
Investors lost faith in the
model-implied and rating-related prices for a number of
structured products, such as complex CDOs.
As a
consequence, investors required increasingly higher
premiums reflecting their declining appetite for the
risks embodied in structured products.
This happened on
top of deteriorating fundamentals, such as rising
interest rates, declining house prices and a general
slow down in the US economy, which also caused rising
default correlations.
All these factors launched a
downward spiral between market prices and liquidity in
structured product markets.
The implied lengthening of
the respective liquidity horizons contributed to the
risk of higher price fluctuations and defaults.
Against
this background, it turned out that the actual liquidity
horizons of some important credit instruments, such as CDO tranches, were much longer than market participants
had anticipated, so that loss-generating positions could
either not be unwound at all or liquidated only at a
large additional cost.
Overall, IMCR studies suggest that banks’ exposures to
market risk and credit risk vary with liquidity
conditions in the market, and liquidity conditions in
turn are also determined by perceptions of market and
credit risk.
Going forward, this finding suggests that
banks and regulators need to think about a framework
that better integrates all three types of risk.
From a
practical perspective, a promising way for banks to
account for this type of interaction may be through the
use of stress tests, where the impact of deteriorating
market liquidity conditions is explicitly examined and
their impact on measured risk accounted for.
The
assessment and development of stress testing tools is,
however, outside the scope of the IMCR group.
A more
structured approach through the joint modelling of
liquidity and other factors that drive value may
well become more important in the future.
It is particularly important for
risk management methods and business models that rely on
liquid markets for their success.
This issue is revisited in the
following section in the context of securitisation.
The more general need to
strengthen liquidity management and its regulatory
treatment is recognised by the Basel Committee, which
issued a sound practice guidance on this in September
2008.
5. Selected issues related to securitisation
Securitisation allows banks to manage market and credit
risk by selling them selectively rather than holding or
hedging the total risk.
It holds potential benefits by
allowing banks to focus on intermediation and selective
risk bearing.
It relies heavily, however, on the
liquidity of primary markets for placing asset-backed
securities.
The current financial crisis has
demonstrated problems that can arise in securitisation.
Research illustrates that widespread mis-pricing and
distorted investments can occur if the incentives of
underwriting banks and investors are improperly aligned.
As a consequence the markets for risk sharing and
funding can become illiquid, exposing the banks to
significant risks.
Insufficient knowledge about pricing
parameters, such as credit correlations, further
increase the risks associated with risk management
strategies that rely on securitisation.
By transforming credit risk into market risk and pricing
default, the growth of securitisation over the recent
years has made it increasingly more important to better
understand the interaction of market and credit risk.
This section contributes, inter alia,
a few points to
the current debate on the problems of securitisation
that came to the surface through the ongoing financial
crisis.
Since the remit of the IMCR group is limited to
the interaction of market and credit risk, the
discussion is very selective and does not address many
other important issues in this area.
As noted in Section 2, market and credit risk are both
driven by the same underlying economic forces, but how
they interact depends on a bank’s business model and
risk management strategy.
Securitisation is
fundamentally different from traditional bank lending
because banks, after having originated the loans, hold
them only for a short time before the loans are sold or
before the associated risks of the loans are sliced into tranches and then sold.
In other words,
with
securitisation banks manage the credit and market risks
of securitised loans by selling both to the market.
When
structured appropriately, securitisation is economically
valuable because
(i) it allows a
bank to manage credit and other risks of its loan
portfolio and optimise its risk profile and
(ii) it allows a
bank to focus on financial intermediation activities,
such as borrower screening and monitoring, which are
areas where banks should have a comparative advantage,
and it allows a bank to move away from risk-bearing
(where it may have little comparative advantage) toward
risk-sharing with other market participants, including
other banks.
The recent experience suggests, however, that incentive
problems at various stages of the securitisation process
can lead to severe mis-pricing and distorted
investments.
For example, if the incentives
of originators are not sufficiently aligned with those
of the holders of risk then banks’ intermediation
function, including screening and monitoring of
borrowers, can be severely impaired.
Once these problems become
apparent to the wider market, risk sharing markets
become dysfunctional or even disappear.
If
securitisation markets become illiquid, banks can be
exposed to heightened risk from exposures to both credit
risk (defaults), for example as loans can no longer be
securitised, and to market risk from changes in the
mark-to-market value of the securitised assets.
In addition, when risk-sharing
markets become illiquid, the signals from prices can
become distorted or even disappear, rendering risk
measurement especially challenging.
Because securitisation relies on
the presence of liquid markets for sharing the risks of
securitised assets, it is important that securitisation
practices help to promote the liquidity of risk sharing
markets, for example by solving the above problems.
Economic research suggests that
an important element in aligning the incentives between
underwriters and investors is that banks retain a
sufficiently strong economic interest in the securitised
assets they sell.
In general,
this would mean retaining some
exposure to securitisation cash flows whose payoffs are
especially sensitive to how well the bank performs its
origination, monitoring and servicing activities.
A further requirement for well functioning markets is
that investors in securitisation instruments should have
a firm understanding of the associated risks.
Recent
events exposed deficits in this understanding that were
partly related to problems with the availability of
information and to the complexity of certain
securitisation structures that obscured the links
between the performance of the underlying assets and the
price of the instruments.
For example, the price of CDO
tranches is very sensitive to unobservable factors such
as forward-looking perceptions of credit default
correlations.
For more complex structures
(re-securitisations, synthetic transactions etc), the
sensitivity to unobservables is even more severe, making
such products very difficult to hedge or price.
Analysis in selected IMCR studies illustrates the
importance of underlying assumptions in the pricing of
credit risk transfer instruments with the examples of
single name CDS and CDS index tranches that have become
an industry reference point.
Depending on the
particular model assumptions adopted,
the implied
parameters that are used to price the assets may differ
substantially, suggesting that there may be substantial
basis risk when using these implied parameters for
hedging.
On balance, valuation and risk measurement in
the context of structured finance instruments is subject
to high levels of model uncertainty, which should be
explicitly incorporated in the analysis of the risk
associated with these positions.
Failure to fully take
account of this uncertainty, in particular in complex
forms of securitisation, was one of the
contributing
factors to the crisis.
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