stress-test scenarios, rather than models which seek to infer the probability distribution of risks
from the observation of the past. New approaches will need to reflect the lessons learnt from
the financial crisis – that market-wide collapses in the liquidity of specific asset or funding
markets can have huge impacts which analysis of individual specific risks will not capture.
4.9 SYSTEMIC RISK
Looking beyond the financial crisis to improved regulation, US federal agencies need to think
about what is needed to avoid a similar scenario occurring in the future. As identified by Lord
Turner, the major failure, shared by bankers, regulators, central banks, finance ministers and
academics across the world, was the failure to identify that the whole system was fraught
with market-wide, systemic risk (Turner 2009). The key problem was not that the supervision
of individual banks was insufficient, but that the regulator failed to see the wood for the
trees. They failed to piece together the jigsaw puzzle of a large US current account deficit,
rapid credit extension and house price rises and the purchase of mortgage-backed securities
by US institutions performing a new form of maturity transformation.27 Regulators, not only
in the US, failed to realise that there was an increase in total system risk to which financial
regulators, overall authorities, central banks and fiscal authorities needed to respond. To their
detriment regulators had been too preoccupied with institution-by-institution supervision of
idiosyncratic risk28 rather looking at the broad horizon.
SIFMA Study
The Securities Industry and Financial Markets Association (SIFMA), in response to the credit
crisis, undertook a study (in conjunction with Deloitte and Touche) to examine systemic risk
in the financial sector. The outcome of their study is reported in their aptly named publication,
“Systemic Risk Information Study”. SIFMA hope the study will provide useful guidance
on how new policies on monitoring systemic risk can be effectively implemented. SIFMA
recommends the creation of a systemic risk regulator and highlights that better qualitative
and quantitative information regarding the identification and mitigation of systemic risk will
be critical components of any comprehensive financial regulatory reform. The study does not
offer a definition of systemic risk, it states that at the time of publication there was no single
agreed-upon definition but declares that the industry and regulators must have a common
understanding of what the term means. The study records two contemporary definitions of
systemic risk.29,30 The study identified nine drivers of systemic risk: size; interconnectedness;
liquidity; concentration; correlation; tight coupling; herding behaviour; crowded trades; and
leverage. These are described in summary form in Box 4.4.