Simple Tools and Techniques for Enterprise Risk Management
proponent of deregulation of our financial markets. Certainly you were the
most influential voice for deregulation. You have been a staunch advocate
for letting markets regulate themselves. Let me give you a few of your past
statements. In 1994, you testified in a congressional hearing on regulation
of financial derivatives. You said “there is nothing involved in Federal regulation
which makes it superior to market regulation.” In 1997, you said,
“There appears to be no need for government regulation of off-exchange
derivative transactions.” In 2002 when the collapse of Enron led to renewed
congressional efforts to regulate derivatives, you wrote the Senate, “We do
not believe a public policy case exists to justify this governments’ intervention.”
Earlier this year, you wrote in the Financial Times, “Bank loan
officers, in my experience, know far more about the risks and workings
of their counter parties than do bank regulators.” My question for you is
simple: were you wrong?
Greenspan: Well, I think that’s true of some products, but not all. I think that’s the
reason why it’s important to distinguish the size of this problem and its
nature. What I wanted to point out was that – excluding credit default
swaps – derivatives markets are working well.
Waxman: Well, where do you think you made a mistake then?
Greenspan: I made a mistake in presuming that the self-interest of organizations, specifically
banks and others, were such that they were best capable of protecting
their own shareholders and their equity in the firms.
Provisions of the Act
The Act, as anticipated, focuses on risk management, systemic risk, capital and liquidity
adequacy, as well as the interconnectedness of banks. Regulators in the past (on both sides of
the Atlantic) had been too focused on the institution-by-institution supervision of idiosyncratic
risk.
New Approaches to Capital Adequacy
New approaches were required to the regulation of the capital adequacy of banks, accepting
that these have been extensively revised by the introduction of Basel II, which has aimed to
achieve greater sensitivity of capital levels to the different risks that banks are running. It is
important to remember that the crisis developed under the Basel I regime, not Basel II, and
that Basel II would have addressed some of the problems which led to it – for instance, the
failure to distinguish between the capital required to support mortgages of different credit
quality. However, it would appear that Basel II still needs to be adjusted for instance by
introducing higher levels of bank capital to reflect the nature of the recent financial crisis.
New Approaches to Liquidity
The Act recognises that liquidity is at least as important as capital adequacy, which was
overlooked in the wake of intense regulatory focus on capital adequacy. There is no Basel I
or Basel II for liquidity to match the equivalents for capital. Assessment will need to be on
The Global Financial Crisis of 2007–2009: A US Perspective 79
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.