Various regulatory initiatives that followed the onset of the financial crisis called for more stress testing by financial companies. This presentation describes the requirements that relate to US financials.
2. +
Plan of the Talk
Scope of stress testing requirements
Who‟s affected and when
Requirements under different rules
CCAR
Dodd-Frank
Supervisory Guidance SR 12-7
4. +
Sorting out CCAR and D-F
Dodd-Frank (Sect. 165)
Annual supervisory stress testing for “SIFIs”, includes Banks>$50B
in assets
Annual company-run stress testing for Banks and Financial HCos.
>$10B in assets
Semi-annual company-run stress testing if >$50B in assets
Company-run scenarios must include a severely adverse scenario
Minimum of three supervisory scenarios required: Baseline,
Adverse, Severely Adverse
Mandates public disclosure of results
CCAR
Annual supervisory severe adverse stress test for large, complex
bank HCos., >$100B in assets originally, now >$50B
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Number of Affected Firms
as of Q3 2012
120
100
Bank HoldCos > $100B
80
Fin HoldCos >$10B
60
*Fin HoldCos >$50B
40
Banks & S&Ls >$10B
20 SIFIs
0
Categories
Source: FFIEC, FDIC, Federal Reserve
7. +
Who‟s In the 2012-2013 Cycle?
CapPR 11
Other US BHC‟s
>$50B in Assets
8. +
D-F/CCAR Stress Testing Cycle
November
October 1 January 5 March15
15
Fed & Banks Fed Runs Biggest
Public
Banks Run Own Tests Banks‟
Reporting
Develop Scenarios Analyzes Mid-cycle
of Results
Scenarios Capital Process
9. +
Stress Test Creation
Supervisory Scenarios begin with economic shocks to 26 (for
2012-2013) macroeconomic variables
The stress test must then translate these into their impact on
various categories of income and expense, and
Flow those impacts through to net income on a quarterly
basis, which
Combined with forecast changes in the capital account, are
used to estimate impact on regulatory capital
Trading books are subject to an instantaneous shock as
specified by the supervisor
11. +
Severely Adverse – Market Shocks
Equity by Geography
0%
-15%
New Zealand
Switzerland
United Kingdom Chile
Sweden Mexico Philippines Turkey
-30% Germany Malaysia
Australia Euro Stoxx 50 India
United States Poland SouthMSCI EAFE
Africa
Stoxx Europe 600 South Korea
FranceJapan China
Hong Kong MSCI World
Index
Belgium
Finland MSCI All Country
Canada
-45% Denmark Hungary
Czech Republic Brazil
Taiwan WorldIndex
Index
Netherlands Indonesia
Singapore Israel (ACWI)
Greece Argentina MSCI EM Index
Italy
Norway MSCI EMEA
-60% Austria MSCI EM Latin Index
Spain America Index
Bulgaria
-75% Russia
IrelandPortugal
Ukraine, -84.30%
-90%
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From economic shocks to gains and
losses
Crucial! Two ways to go:
simulation historical relationship
See, e.g., CCAR 2012: Methodology and Results for Stress Scenario
Projections, Appendix A
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Stress Testing under CCAR & D-F
The details
9 quarter horizon, instantaneous shock for trading books
As-of dates
9/30 (and 3/31) for annual (mid-cycle) tests
Random end-Q4 as-of date for trading books
Implementation decisions
Interpolation, extrapolation, proxying shocks
Bank baseline scenario – adopt supervisory baseline?
Models don‟t work with shocks
Documentation
Must use standard templates
must document and justify deviations
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Disclosure
From banks to the supervisor
FR Y-14M (and 14A and 14Q)
From the supervisor to the public
Details of economic and market shocks
Using both D-F and bank capital plan assumptions, lowest quarterly
and end of forecast horizon capital ratios, severe adverse scenario
Using D-F capital plan assumptions, time-aggregated net
revenue, loan losses (by type), trading and counterparty credit
losses, net income
15. +
Disclosure
From Banks to the public
types of risks included in the stress test;
description of scenarios developed by the company, including
key variables used (such as GDP, unemployment
rate, housing prices);
description of the methodologies to estimate
losses, revenues, and changes in capital; and
aggregate losses, pre-provision net revenue, allowance for
loan losses, net income, and pro forma capital levels and
capital ratios over the planning horizon under each scenario.
16. +
Reverse Stress Testing
New concept for banks
FSA (UK) leading in requiring this
Regulators like it but are silent on method
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Reverse Stress Testing Defined
“assume a known adverse outcome…
“then deduce the types of events that could lead to
such an outcome.” (Federal Reserve Board SR 12-
7, p. 12)
Sounds
simple, but…
18. +
Reverse Stress Testing History
FSA FSA
BIS Principles US
Proposed Requirements
CRMPG III for Sound UK banks go Supervisory
Rules Formalized
2008-08 Stress Testing live 2011-12 Guidance
(CP08/24) (PS09/20)
2009-05 2012-11
2008-12 2010-12
19. +
Reverse Stress Testing Illustration
Mirzai & Müller. 2013. On Reverse Stress Testing. Intelligent Risk, 8-11.
Pick critical loss level
(„CLL‟)
Obtain 30K samples from
joint distribution of risk
factor returns
Revalue portfolio 30K times
Onlylook at those samples
where portfolio loss > CLL
By CaitlinJo [CC-BY-3.0
(http://creativecommons.org/licenses/by/3.0)],
via Wikimedia Commons
20. +
Reverse Stress Testing Illustration
Mirzai & Müller. 2013. On Reverse Stress Testing. Intelligent Risk, 8-11.
Can we find economic meaning in
these large loss samples?
First,
look for statistical commonalities using k-
means clustering
Second, relate cluster behavior to market risk factors
through heuristic analysis
a U.S. BHC that is owned and controlled by a foreign bank that is an FHC that the Board has determined to be well-capitalized and well-managed will not be required to comply with the Board's capital adequacy guidelines.” E.g., Deutschebank.
Annual Company-Run Stress Test Requirements Are Delayed Until Fall of 2013 Fornational banks, savings associations and state non-member banks with average total consolidated assets of less than $50 billion; (no reporting for another year after that)BHCs with average total consolidated assets of less than $50 billion U.S.-domiciled BHC subsidiaries of FBOs relying on SR 01-1 for which implementation begins 2015; andstate member banks with average total consolidated assets greater than $10 billion (other than state member bank subsidiaries of SCAP BHCs).
38,975 separate shocks, benchmarked to 2nd half 2008
Reasons given for RST:Outside normal business thinkingExplore hidden vulnerabilitiesChallenge assumptions about threats to business viability