Macro prudential policy and its tools
The macroprudential regulatory changes in terms of risk
weight, provisioning requirements and Loan-to-Value ratio (LTV) occurred with
respect to some specific sectors of the credits class viz., housing loans,
commercial real estate, capital market and other retails in emerging markets.
The tightening of prudential norms made the credit to targeted sectors
costlier, thereby operating the flow of credit to these sectors. There is
evidence that moderation in credit flow to these sectors was also in part due
to banks becoming cautious in lending to these sectors on the signaling effect
of the Central Bank’s perception of build-up of sectoral risks. Now the
question arises as to how to test the impact of macroprudential policies on the
loan supply in these specific sectors and to identify whether the changes in
the loan is due to the monetary policy shock or macroprudential shock and
further, whether it is demand driven or supply driven. ‘macroprudential’
approach to safeguard the financial system as a whole. Accordingly, the IMF
initiated the framework for Financial Soundness Indicators comprising
aggregated micro prudential indicators, financial market indicators and
macroeconomic indicators. In the aftermath of the recent global crisis, the new
Basel III framework has embraced macroprudential approach with emphasis on
systemic risk and stability. However, the benefits of introducing
macroprudential policy tend to be sizeable when financial shocks, which affect
the supply of loans, are important drivers of economic dynamics.
The macroprudential norms enabled banks to withstand some of
the adverse impacts when macroeconomic conditions changed especially when the
global financial crisis hit. First, the countercyclical prudential requirement
relating to investment fluctuations reserve enabled banks to absorb some of the
adverse impact when interest rates began moving in the opposite direction in
late 2004. When capital charge for market risk was introduced, banks did not
face any difficulty in meeting the same.
Second, banks’ capital to risk-weighted assets ratio
increased every year from 2007 to 2011. The
improved capital to risk weighted assets ratio was due to
improved profitability as well as also to the decline in the gross
non-performing assets ratio. This enabled banks to plough back increased
profits. The increase in risk weights for lending to certain sectors and
increased provisioning requirements against standard assets also enabled banks
to improve their capital adequacy ratio.
Macroprudential policy measures fall into the following
three broad categories (Table 4): (i) Credit controls including caps on ratios
of LTV and of debt-to-income (DTI) and on foreign currency lending as well as
ceilings on credit or credit growth; (ii) liquidity regulations that place
limits on net open currency positions or currency mismatches and on maturity mismatches
while establishing reserve requirements; and, (iii) capital requirements
including countercyclical capital requirements, time-varying and dynamic
provisioning, and restrictions on profit distribution. Macroprudential tools
such as minimum capital ratios and LTV ratios have been used for some time.
Reserve requirements could provide liquidity cushions while dynamic provisioning
could help build capital buffers during upturns.
Conceptual Basis of Macroprudential Policy Instruments
|
Instrument |
Conceptual
Basis |
|
Caps
on the loan-to-value ratio (LTV) |
The
LTV imposes a down payment constraints on household capacity to borrow. In
theory, the constraint limits the procyclicality of collateralized lending
since housing prices and household capacity to borrow based on the
collateralized value of the house interact in a procyclical manner. Set at an
appropriate level, the LTV address systematic risk whether or not it is
frequently adjusted, however, the adjustment of the LTV makes it a more
potent countercyclical policy instrument. |
|
Caps
on the debts to income ratio (DTI) |
The
DTI represents prudential regulation aimed at ensuring banks asset quality
when used alone. When used in conjunction with the LTV, however, the DTI can
help further dampen the cyclicality of collateralized lending by adding
another constraint on household capacity to borrow. As with the LTV,
adjustments in the DTI can be made in a countercyclical manner to address the
time dimension of systematic risk. |
|
Caps
on foreign currency lending |
Loans
in foreign currency expose the unhedged borrower to foreign exchange risk
with, in turn, subject the lender to credit risks. The risks can become
systemic if the common exposure is large. Caps (or higher risk weights,
deposit requirements, etc.) on foreign currency lending may be used to
address this foreign exchange induced systemic risk. |
|
Ceiling
on credit/credit growth |
A
ceiling may be imposed on either total bank lending or credit to a specific
sector. The ceiling on aggregate credit or credit growth may be used to
dampen the credit/assets price cycle--in the time dimension of systemic risk.
The ceiling on credit to a specific sector, such real estate, may be used to
contain a specific type of asset price inflation or limit common exposure to
a specific risk—the cross-sectional dimension of systemic risk. |
|
Reserve
requirement |
The
monetary policy tools may be used to address systemic risk in two senses.
First, the reserve requirement has a direct impact on credit growth, so it
may be used to dampen the credit/assets price cycle—the time dimeson of
systemic risk. Second, the required reserves provide a liquidity cushion that
may be used to alleviate a systemic liquidity crunch when the situation
warrants. |
|
Countercyclical
reserve requirement |
The
requirement can take the form of a ratio or risk weights raised during an
upturn as a restraint on credit expansion and reduced during a downtown to
provide a cushion so that banks do not reduce assets to meet the capital
requirement. A permanent capital buffer, which is built up during an upturn
and deleted during a downturn, serve the same purpose. Both can address the
cyclicality in the risk weights under Basel ii based on external rating that
are procyclical. |
|
Provisioning
|
Traditional
provisioning is calibrated historical bank-specific losses, but it can also
be used to dampen the cyclicality in the financial system. The provisioning
requirement can be raised during an upturn to build a buffer and limit credit
expansion and lowered during a downturn to support bank lending. It may be
adjusted either according to a fixed formula or at the discretion of the
policy maker to affect bank lending behavior in a countercyclical manner. |
|
Restriction
on profit distribution |
These
prudential regulation requirements are intended to ensure the capital
adequacy of banks. Since undistributed profits are added to bank capital, the
restrictions tend to have a countercyclical effect on bank lending of used in
a downturn. The capital conservation buffer of Basel III has a similar role. |
|
Limits
on net open positions/currency mismatch |
These
prudential regulation tools may be used to address systematic risk since the
choice of asset/liability maturity creates an externality—fire sale of
assets. In a crisis, the inability of a financial institution to meet its
short-term obligations due to maturity mismatches may force it to liquidated
assets thus imposing a fire sale cost on the rest of the financial system.
The funding shortages of a few institution could also result in a systemic
liquidity crisis due to the contagion effects. |
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