New EU Regulation on Nonperforming Loans

According to Moody’s, on 14 March, the European Parliament voted in favor of a regulation setting minimum loan loss provisioning requirements for nonperforming loans (NPLs). The European Union (EU) regulation aims to prevent the excessive accumulation of soured loans, a scenario that unfolded in several European countries during the global financial crisis. The new rules, which will become effective in the coming weeks, will be credit positive for EU banks.

All European banks will be subject to the same prudential standards. Until now, banks’ provisions were driven by two factors; accounting rules, which were recently amended to make them more prudent and forward-looking (IFRS 9), and supervisory expectations, which the euro-area banking supervisor, the Single Supervisory Mechanism’s (SSM), in March and July 2018 made more explicit by providing qualitative and quantitative guidance.

However, the SSM’s quantitative guidance on NPL coverage (the so-called
addendum) has been criticised because the SSM is not empowered to set rules; regulation is the joint responsibility of the European Council (of governments) and the European Parliament.

The new regulation will operate as a backstop to the accounting standard IFRS 9, which can be interpreted in different ways in different jurisdictions. The SSM will continue to have influence over banks’ provisioning decisions in rare instances that it considers the NPL regulation does not provide appropriate coverage.

The regulation directs minimum provisions (prudential provisions) on loans according to a prescribed timetable. The volume of provisions required may vary from the amount computed under IFRS 9 accounting standards.

The new rules categorize banks’ loans as unsecured and secured loans. For secured loans the regulation differentiates between immovable collateral such as property (the highest quality) and other eligible credit protection (the lowest quality). For unsecured loans that move into the NPL category, no provisions would be required for the first two years; a minimum provision of 35% of the outstanding amount would be required during the third year; and 100% coverage should be in place before the end of the
fourth year. This final timetable is slightly longer than that originally proposed (100% after two years of nonperformance).

For secured loans, provisioning follows a longer timetable. For loans with the highest quality immovable collateral, the timetable spans nine years, beyond which NPLs must be 100% covered by provisions. For loans with the lowest quality collateral, 100% coverage must be in place by the end of the seventh year after a sound loan is moved to the NPL category.

The new rules will not tackle the outstanding stock of NPLs, but we expect them to have an effect over time. NPLs still are a large proportion of banks’ loans portfolios in several EU countries, including Italy, where we estimate they comprise 10% of total loans. The scope of the NPL regulation, however, is restricted to new loans EU banks extend from the date of implementation. Consequently EU banks’ provisioning decisions on legacy NPLs will still be driven by IFRS 9 accounting rules and guidance from the SSM.

Nevertheless, we expect the SSM’s approach to legacy NPLs will mirror the new regulation, and at some point banks will find it untenable to maintain
two parallel provisioning policies.

Adams/North: A War On Cash Is A War On The People

Economist John Adams and Analyst Martin North discuss the trend towards zero interest rates, the removal of cash from circulation, and the use of digital currency to control the system.

Is the black economy initiative all that it seems to be?

Keep On Keeping On – The Property Imperative Weekly To 16 March 2019

Welcome to the Property Imperative weekly to the sixteenth of March 2019 – our digest of the latest finance and property news with a distinctively Australian flavour.   

Watch the show, or read the transcript.

The talk is now of more sustained property price falls, the RBA cutting rates, and risks in the broader economy building. The news just keeps on coming and reconfirming our central scenarios.  That said, it looks like the global economy will be stoked by more stimulus, for a time, so the question becomes will we be the first to crack?

Straight into the property markets first, with the CoreLogic Index to 14th March falling another 0.13% in the past week.  Over the last 12 months, the index has fallen by 8.3%, driven by Sydney, Melbourne and Perth, and since the last peaks, dwelling values have fallen by 9.4%, led by Sydney (-13.6%), Melbourne (-9.9%) and Perth (-17.8%). And Auction clearance rates were weak again, on low volumes with the final clearance rate in Sydney sitting at 52.3%  and Melbourne at 49.2%, while the other states were around 29%, including Canberra.  And final auction clearances were still 9.9% (Sydney) and 21.6% (Melbourne) below the same weekend last year when dwelling values were also falling. Moreover, auction volumes were also down 28% and 52% respectively in both Sydney and Melbourne. No signs of a recovery here!

Taking a longer-term view, it’s worth reflecting on Corelogic’s latest Property Pulse which says that At a national level, since 1980 there have been eight separate housing market downturns. The current downturn which commenced after October 2017, has seen values fall by -6.8%. Although that may not seem like a substantial downturn, since the early 80’s there have only been two downturns which were larger, 2008-09 and 1982-83. National housing market downturns have also been generally fairly short-lived with the current downturn of 16 months already the second longest with the 2010-12 decline running two months longer than the current downturn.

The decline in values throughout the current downturn has been larger across the combined capital cities, with values now -8.6% lower. By next month, assuming the falls continue, this will be the largest downturn in the combined capital city index any time since 1980. The current downturn is also closing in on being the longest. With values having peaked in September 2017, they have now been falling for 17 months with the previous longest period of decline coinciding with the last recession, running for 20 months between 1989 and 1991.

Of course, it’s worth remembering this one is being driven by right-sizing credit, not rising interest rates or unemployment, but ahead, we do expect unemployment to turn upwards, and the RBA to cut the cash rate, but this may not automatically translate to lower mortgage rates. And if credit supply remains predicated on lower loan to income ratios, and more forensic analysis of income and expenditure, then prices will indeed continue to fall. We will get the odd “unnatural act” such as extra first-time buyer incentives, or ANZ’s loosening of terms for Interest Only loans (which we discussed in yesterdays post). But unless we go back to the illegal behaviour revealed through the Royal Commission, and lending standards drop substantially again, credit will remain tight.

And mortgage arrears continue to trend higher according to S&P Global Ratings’ latest edition of “RMBS Performance Watch: Australia.”.  Arrears on the mortgages underlying Australian residential mortgage-backed securities (RMBS) have increased year on year, while prepayment rates have slowed. In particular, arrears that are in an advanced stage (more than 90 plus days) reached a record high of 0.75% in December 2018. Arrears in this advanced stage now represent 55% of total loans, up from 40% five years ago. Prime mortgage arrears have increased to 1.38% in December 2018 from 1.30% in December 2017. Softening macroeconomic conditions are likely to keep arrears elevated over the next 12 months given that borrowers’ refinancing prospects, particularly in the current environment of tightened lending conditions, are more challenging. While we expect most borrowers to be able to manage these headwinds, loans in the more advanced arrears stages are less likely to cure in the current environment they say.

We are watching the apartment market in particular, as demand fades, and quality of construction question come to the fore. Indeed, the UBS property round table made the point that “apartments are increasingly out of the money. That’s where you get settlement issues. What’s happened to buyers now as they come to settlement, is bank valuations might come in 10 per cent or even 20 per cent below the contract price and the bank is also probably assessing you with more stringent expenses potentially hair-cutting any bonus or commission or other income a bit more. As they reassess you on tighter lending standards you might find that your borrowing capacity is significantly reduced particularly if you are a repeat buyer who already has other debts and they are realising that you are already on six or seven times debt to income.

And there are signs of construction of existing tower stalling, according to the AFR.  “An analysis by The Australian Financial Review of Cordell/CoreLogic data showed about 21,000 out of about 36,000 approved apartments in Melbourne worth about $6.5 billion over the two years have been categorised as “deferred” or “possible” but have not firmed up to go ahead. In Sydney, just over 10,000 out of 26,000 units with an end value of about $3 billion are in the same boat. And data from construction information provider BCI Australia confirmed the pattern in Sydney and Melbourne, adding that the ACT was the only state where almost all approvals in 2015 – while much fewer than NSW and Victoria – proceeded to construction.

Indeed, we are seeing a smattering of building companies now. As the ABC reported, Two more South Australian building companies are facing collapse amid ongoing pressure from the national housing downturn. An application to wind up Cubic Homes, based in Kilburn, will be heard later this month and JML Home Constructions, which operates the Onkaparinga GJ Gardner franchise, has closed its doors. It follows the recent demise of a string of local companies, including ODM Group, OAS Group and Platinum Fine Homes. Master Builders SA chief executive Ian Markos said low population growth, reluctant bank lending, planning laws and inefficient land release had created a perfect storm.

And something else to bear in mind is the rise of AirBnB type short term letting. As the New Daily reported, “Airbnb spends a lot of time saying they have no impact on markets. What this paper shows is that they do,” University of Sydney professor, Peter Phibbs said, referring to the recent RBA modelling.  The RBA report found that vacancy rates are the “strongest predictor” of rents, Professor Phibbs said, and while that in itself seems “pretty obvious”, it also shows the conversion of long-term rental stock into Airbnb-style tourist accommodation is reducing rental stock, and subsequently reducing vacancy rates. “Hobart is the standout because they have the lowest vacancy rates in the country and they’ve probably also got the highest uptake of Airbnb”.

We know from our surveys that household are expecting home prices to fall further, as revealed in our latest data out this week – see “What Are Households Thinking Now?”  Demand for credit is easing, too. And we know from our earlier surveys that mortgage stress is rising as income remain constrained as costs rise.  WA is being hard hit, as reported in the West Australian. “In January and February alone, 112 people sought help from Legal Aid WA after defaulting on their home loan repayments, more than a third of the number of people who sought assistance in 2018. The 2018 figures saw Legal Aid support 301 people — a 550 per cent increase from 2013 when only 46 people required help. The dramatic jump in cases has prompted Legal Aid WA to launch outreach facilities of the Statewide Mortgage Hardship Service in three locations in Perth’s worst affected suburbs.   LAWA’s director of civil law Justin Stevenson said… “Concerningly the ongoing financial hardship in the West Australian community, with a sustained softening of property prices, unemployment and an end to interest-only loans mean we are only going to see more struggle to pay their mortgage in 2019… Without assistance from LAWA, homelessness is a real consequence for these West Australians”…

Meantime, the economic indicators worsen. For example, Roy Morgan’s alternative unemployment indicators of 9.6% for February is significantly higher than the current ABS estimate for January 2019 of 5.0% although Roy Morgan’s under-employment estimate of 8.6% is comparable to the current ABS underemployment estimate of 8.1%.     According to the ABS definition, a person who has worked for one hour or more for payment or someone who has worked without pay in a family business, is considered employed regardless of whether they consider themselves employed or not.     The ABS definition also details that if a respondent is not actively looking for work (ie: applying for work, answering job advertisements, being registered with Centre-link or tendering for work), they are not considered to be unemployed. The Roy Morgan survey, in contrast, defines any respondent who is not employed full or part-time and who is looking for paid employment as being unemployed.    Since Roy Morgan uses a broader definition of unemployment than the ABS, it necessarily reports a higher unemployment figure. In addition, Roy Morgan’s measure tends to be far more volatile, owing to the fact that it draws on a smaller sample than the ABS and is not seasonally adjusted.

 The impact of the Royal Commission into the Financal Services sector continues to be watered down, as Josh Frydenberg walked away from his plan to ban mortgage broker trailing commissions, pushing the issue to a review in 2022. The Treasurer said the government had backflipped on its crackdown on the industry because it wanted to keep competition in the mortgage market, amid concerns that only the largest banks could afford to pay steeper bonuses to brokers. The issue will be reviewed in three years if the Coalition remains in power by the Australian Competition and Consumer Commission and the Council of Federal Financial Relations. There is a real issue of competition, here, but remember the underlying issues is the conflict arising when a Broker is paid more for recommending a larger loan. Once again, consumers loose to political expiedency!

And the data this week continues the bad news, as nicely summarised by Westpac.  Markets are now giving about a 50% chance of an RBA cut by June, up from a 40% chance immediately following the December quarter GDP release. Westpac continues to favour moves coming later in the year – August and November the likeliest timing – with the Bank still seeming reluctant to cut and likely to require more evidence around the ‘consumer-housing nexus’ and the labour market outlook before taking action.

The NAB business survey indicates that both business conditions and business confidence weakened in February – with both at below average levels. The business conditions index fell by 3pts to +4, down sharply from the average +18 read over the first half of 2018. Business confidence also fell by 2pts to +2. We see the soft business update as a significant development. The February read is less affected by holiday season volatility, and is a clearer confirmation that the sharp loss of economic momentum since mid-2018 has extended into 2019. That is consistent with Westpac’s view of GDP growth running at a below trend 2.2% pace in 2019. The detail shows particularly weak conditions for retail, the December–February period marking the weakest three month run since 2013, and construction which saw conditions dip into contractionary territory. The state breakdown continues to show a sharp loss of momentum in NSW and Victoria. All of this is consistent with increasing negative spillovers from the Sydney and Melbourne housing corrections. Importantly, the shift is clearly starting to affect businesses willingness to hire and invest. While the employment component of the survey moved sideways in the February month, at +5 it continues to show a clear easing from the +11 averaged over the first nine months of 2018. Meanwhile, the March survey points to downside risks around investment, with capacity utilisation falling to below average levels and capital expenditure plans down to a three year low.

Consumer confidence is also starting to falter. The WestpacMelbourne Institute Consumer Sentiment Index fell 4.8% to 98.8 in March from 103.8 in February. The move takes the index back below 100, indicating pessimists again outnumber optimists, in contrast to the ‘cautiously optimistic’ reads that prevailed throughout 2018. At 98.8, the index is still only ‘cautiously pessimistic’ and comfortably above the average level recorded in 2017. However, the March fall looks likely to be sustained with the survey detail indicating the poorer run of economic news is starting to weigh more heavily. Indeed, responses collected after the March 6 GDP release were much weaker, consistent with an Index level of 92.7. We suspect that the national accounts release clarified what were previously somewhat mixed signals about the extent of Australia’s growth slowdown. As such this aspect of the March weakening in consumer sentiment looks likely to be sustained. Other aspects of the March consumer sentiment survey also suggest the shift is starting to have a bearing on decisions. Job loss concerns rose sharply in the month, the WestpacMelbourne Institute Unemployment Expectations Index recorded an 8.9% jump, indicating more consumers expect unemployment to rise in the year ahead. Responses to additional questions on the ‘wisest place for savings’ also show risk aversion rising to extremely elevated levels. Two thirds of consumers favouring safe options – bank deposits, superannuation or paying down debt – and just 17% nominating risky options such as real estate and shares. The mix is more risk averse than at the height of the global financial crisis.

We can assume significant stimulus in the upcoming budget, but then that could all get swept away with an election due soon after and the chance of a change to Labor, which would reset the agenda to some extent. So its safe to say, we just keep on keeping on.

So to the markets.

A wave of green washed over U.S. stocks after on Friday, led by technology companies, as a report on progress in U.S.-China trade talks lifted sentiment, pushing the S&P 500 to its best week since November. The Dow racked up gains on Friday, snapping a two-week losing streak.

China’s state-run Xinhua news agency said Washington and Beijing were making substantive progress on trade talks, providing relief after news that a summit to seal a deal between the two sides would not happen at March-end. Many investors expect a deal will eventually happen.

But U.S. data showed manufacturing output fell for a second straight month in February and factory activity in New York state was weaker than expected this month. That followed a batch of weak data this week that lent support to the Federal Reserve’s dovish stance on future interest rate hikes.

The S&P 500 posted its best weekly gain since the end of November and Nasdaq had its best weekly gain so far this year. For the week, the S&P 500 was up 2.9 percent, the Nasdaq was up 3.8 percent, and the Dow was up 1.6 percent.

Brexit of course rumbled on with the date extended but little else firming up. And in China, Policy targets announced at the start of China’s 13th National People’s Congress (NPC) on 5 March underscore the policy challenges facing the government as it seeks to support growth without adding significantly to economic imbalances. The 2019 GDP growth target was lowered to 6%-6.5% from “around 6.5%” in 2017 and 2018, and against actual growth outturns of 6.9% and 6.6%, respectively.

As Fitch pointed out, the adoption of a lower growth target reflects, an acceptance by the government that medium-term growth is slowing, to perhaps a medium-term potential growth at around 5.5%, a significant decline from historical trends as the economy rebalances towards consumption and away from capital accumulation. Import growth turned negative in yoy terms at the end of 2018, reflecting a slowdown in domestic investment and private consumption. The official manufacturing purchasing managers’ index dropped to its lowest in three years in February to 49.2, a third consecutive month below 50, indicating contraction. As Australia’s major trading partner, this could impact the local economy ahead.

So, standing back, it seems to me that international markets are being supported by hopes of more stimulus and trade agreements, which then puts the acid back on the local Australian economy. In fact it may be that Australia becomes one of the first victims of this current economic cycle, and the fact is, most of the risk has been created by poor government, and policy failure. There is no blaming some third party, this is a home based problem – in every sense of the word. Finally, a quick reminder that our next live event will be on Tuesday 19th March at 20:00 Sydney time. As usual we will take questions live via the chat, or ahead of time. You can send me questions via the DFA Blog. I look forward to seeing you then.

ANZ’s IO Loan Changes Have Risk Written All Over

ANZ have announced a new flavour of interest only loans.  They said that from 25th March 2019 they will increase the maximum Loan to Value Ratio of Interest Only Loans from 80% to 90%, and increase the maximum term from 5 years to 10 years.

These loans will be marketed only for high-income professionals with stable jobs. And timing means people could transact before the election in May (probably) and so lock in tax benefits relating to negative gearing, which Labor are going to remove for existing property purchased after a certain data, TBA.

ANZ says their response to APRA’s responsible Lending guidelines from 2017 was to manage down the growth of IO loans. But they have decided to increase their focus on the investor market, wiliest ensuring they remain in line with  the APRA requirements.

Just to remind ANZ, the key APRA points are :

  1. Take 80% of rental streams as income to allow for vacancy rates
  2. Assess the risk on a principal and interest rate loan basis
  3. Ensure the borrower has firm plans to repay the capital
  4. Ensure adequate validation of income and expenditure
  5. Ignore any tax breaks or benefits, so asses on a pre-tax basis.

ANZ says these changes will apply to new loans, either fixed or variable interest rate.

The LVR limit is inclusive of the Lenders Mortgage Insurance Premium

For Owner Occupier Home Loan products: Interest Only term cannot exceed a maximum 5 years per application OR 5 years in total since the last full credit critical application.

For Residential Investment Home Loan products: Interest Only term cannot exceed a maximum 10 years per application OR 10 years in total since the last full credit critical application.

For servicing, the customer is assessed based on their ability to repay the loan over 20 years P&I.  And we understand these new loans are assessed at a minimum floor rate of 8.25%, which is a very high hurdle to cross.

These are not available to Owner Occupied Borrowers.

Two comments, first this is to be expected, as ANZ has seen their mortgage portfolio growth drop away, and they are desperate to write business. They are trying to target a specific customer segment, and some who are currently facing a loan reset may be rescued.

But then, our modelling suggests only a very small cohort who might be eligible, and we expect other lenders to react, so they will lift competition for that small segment.

Talking of reaction, we think APRA should step in to ban loans of this duration, but they probably won’t, and the RBA might even welcome the move behind the scenes as generating a rise in credit.

But frankly, this is just one more of those unnatural acts I keep talking about from actors who are trying to keep the property bubble alive. But potential investors should realise that prices are likely to keep falling, rental streams are diminishing, especially in Sydney, and a repayment plan over 20 years, will require higher monthly repayments down the track. This has high risk written all over it!

US Debt Grew By 5.1%

Moody’s says that US debt continues to rise (with strongest growth in the public sector) and a powerful enough external shock could force U.S. benchmark interest rates up to levels that shrink business activity considerably.

The latest version of the Federal Reserve’s “Financial Accounts of the United States” was released on March 7. As of 2018’s final quarter, the total outstandings of private and public nonfinancial-sector debt grew by 5.1% year-to-year to a record high $51.796 trillion. The year growth rate of the broadest estimate of U.S. nonfinancial-sector debt has slowed from second-quarter 2018’s current cycle high of 5.6%. Since the end of the Great Recession, the 3.9% average annualized rise by nonfinancial-sector debt
has slightly outpaced nominal GDP’s accompanying 3.7% average annual increase.

By contrast, during 2002-2007’s upturn, the 8.1% average annualized advance by nonfinancial-sector debt was much faster than nominal GDP’s comparably measured growth rate of 5.3%. As a result, the moving yearlong ratio of total nonfinancial-sector debt to GDP climbed from the 197% of 2001’s final quarter to the 225% of 2007’s final quarter. Because of the current recovery’s much slower growth of debt vis-a-vis GDP, debt barely rose from second-quarter 2009’s 243% to fourth-quarter 2018’s 249% of
GDP.

Today’s near record high ratio of nonfinancial-sector debt to GDP limits the upside for benchmark interest rates. Just as highly leveraged businesses exhibit a more pronounced sensitivity to higher benchmark interest rates, highly leveraged economies are likely to slow more quickly in response to an increase by benchmark rates. Relatively low interest rates do much to lessen the burden implicit to a comparatively high ratio of debt to GDP.

Nevertheless, a powerful enough external shock could force U.S. benchmark interest rates up to levels that shrink business activity considerably. Under this scenario the Fed would be compelled to hike rates in defense of the dollar exchange rate despite how a deterioration of domestic business conditions requires lower rates.

The federal government has dominated the growth of total nonfinancial-sector debt during the current business cycle upturn. In terms of moving yearlong averages, U.S. government debt’s 9.3% average annualized surge has well outrun the accompanying 2.2% growth rate for the sum of private and state and local government nonfinancial-sector debt.

Regarding 2018’s final quarter, the outstandings of U.S. government debt advanced by 7.6% annually to $217.865 trillion. By comparison, household-sector debt rose by 3.1% to $15.628 trillion, nonfinancial corporate debt increased by 6.5% to $9.759 trillion, unincorporated business debt grew by 4.9% to $5.485 trillion, while state and local government debt shrank by 1.7% to $3.060 trillion. Thus, fourth quarter 2081’s U.S. nonfinancial-sector debt excluding the obligations of the federal government grew by a modest 3.9% annually. Over the past 10-years, the faster growth of federal government debt compensated for the sluggish debt growth of non-federal borrowers.

RBA On Climate Change and the Economy

RBA Deputy Governor Guy Debelle, spoke at a public forum hosted by the Centre for Policy Development. Here are some edited highlights.

I will talk about how climate change affects the objectives of monetary policy and some of the challenges that arise in thinking about climate change.

Finally, I will also briefly discuss how climate change affects financial stability.

Let me start by highlighting a few of the dimensions that we need to consider:

  • We need to think in terms of trend rather than cycles in the weather. Droughts have generally been regarded (at least economically) as cyclical events that recur every so often. In contrast, climate change is a trend change. The impact of a trend is ongoing, whereas a cycle is temporary.
  • We need to reassess the frequency of climate events. In addition, we need to reassess our assumptions about the severity and longevity of the climatic events. For example, the insurance industry has recognised that the frequency and severity of tropical cyclones (and hurricanes in the Northern Hemisphere) has changed. This has caused the insurance sector to reprice how they insure (and re-insure) against such events.
  • We need to think about how the economy is currently adapting and how it will adapt both to the trend change in climate and the transition required to contain climate change. The time-frame for both the impact of climate change and the adaptation of the economy to it is very pertinent here. The transition path to a less carbon-intensive world is clearly quite different depending on whether it is managed as a gradual process or is abrupt. The trend changes aren’t likely to be smooth. There is likely to be volatility around the trend, with the potential for damaging outcomes from spikes above the trend.
  • Both the physical impact of climate change and the transition are likely to have first-order economic effects.

Climate Change, Economic Models and Monetary Policy

The economics profession has examined the effects of climate change at least since Nobel Prize winner William Nordhaus in 1977. Since then, it has become an area of considerably more active research in the profession.[4] There has been a large body of research around the appropriate design of policies to address climate change (such as the design of carbon pricing mechanisms), but not that much in terms of what it might imply for macroeconomic policies, with one notable exception being the work of Warwick McKibbin and co-authors.[5]

How does climate affect monetary policy? Monetary policy’s objectives in Australia are full employment/output and inflation. Hence the effect of climate on these variables is an appropriate way to consider the effect of climate change on the economy and the implications for monetary policy. The economy is changing all the time in response to a large number of forces. Monetary policy is always having to analyse and assess these forces and their impact on the economy. But few of these forces have the scale, persistence and systemic risk of climate change.

A longstanding way of thinking about monetary policy and economic management is in terms of demand and supply shocks.[6] A positive demand shock increases output and increases prices. The monetary policy response to a positive demand shock is straightforward: tighten policy. Climate events have been good examples of supply shocks. Indeed, droughts are often the textbook example used to illustrate a supply shock. A negative supply shock reduces output but increases prices. That is a more complicated monetary policy challenge because the two parts of the RBA’s dual mandate, output and inflation, are moving in opposite directions. Historically, the monetary policy response has been to look through the impact on prices, on the presumption that the impact is temporary. The banana price episode in 2011 after Cyclone Yasi is a good example of this. The spike in banana prices and inflation was temporary, although quite substantial. It boosted inflation by 0.7 percentage points. The Reserve Bank looked through the effect of the banana price rise on inflation. After the banana crop returned to normal, prices settled down and inflation returned to its previous rate.

The response to such a shock is relatively straightforward if the climate events are temporary and discrete: droughts are assumed to end; the destruction of the banana crop or the closure of the iron ore port because of a cyclone is temporary; things return to where they were before the climate event. That said, the output that is lost is generally lost forever. It is not made up again later, but rather output returns to its former level.

The recent IPCC report documents that climate change is a trend rather than cyclical, which makes the assessment much more complicated. What if droughts are more frequent, or cyclones happen more often? The supply shock is no longer temporary but close to permanent. That situation is more challenging to assess and respond to.

Climate Change and Financial Stability

Having talked about the macroeconomic impact of climate change and how that might affect monetary policy, I will briefly discuss climate through the lens of financial stability implications.[10] Financial stability is also a core part of the Reserve Bank’s mandate. Challenges for financial stability may arise from both physical and transition risks of climate change. For example, insurers may face large, unanticipated payouts because of climate change-related property damage and business losses. In some cases businesses and households could lose access to insurance. Companies that generate significant pollution might face reputational damage or legal liability from their activities, and changes to regulation could cause previously valuable assets to become uneconomic. All of these consequences could precipitate sharp adjustments in asset prices, which would have consequences for financial stability.

The reason that I will only cover the implications of climate change for financial stability only briefly today is that it has been very eloquently discussed by Geoff Summerhayes (APRA) and John Price (ASIC) including at this forum over the past two years.[11] I would very much endorse the points that Geoff and John have made. Geoff stresses the need for businesses, including those in the financial sector to implement the recommendations of the Task Force for Climate-related Financial Disclosures (TCFD).[12] I strongly endorse this point. We have seen progress on this front in recent years, but there is more to be done. Financial stability will be better served by an orderly transition rather than an abrupt disorderly one.

One area that Geoff highlighted in a recent speech is that there is a data gap which needs to be addressed:[13] ‘The challenge governments, regulators and financial institutions face in responding to the wide-ranging impacts of climate change is to make sound decisions in the face of uncertainty about how these risks will play out.’ In that regard, Geoff mentions one challenge that I spoke about earlier in the context of monetary policy. Namely, taking the climate modelling and mapping that into our macroeconomic models. For businesses and financial markets, that challenge is understanding the climate modelling and conducting the scenario analysis to determine the potential impact on their business and investments.

Lending to households falls 2.4 per cent

The value of new lending commitments to households fell 2.4 per cent in January 2019, seasonally adjusted, according to the latest Australian Bureau of Statistics (ABS) figures on new lending to households and businesses.

The fall in lending to households in January follows a revised 3.6 per cent monthly fall in December 2018.

ABS Chief Economist, Bruce Hockman said: “Weaker lending for dwellings (-2.1 per cent) again drove much of the overall fall in lending to households, with further falls in lending for investment dwellings (-4.1 per cent) and for owner occupier dwellings (-1.3 per cent) in January.”

“Reflecting the impact of both supply and demand side factors, new lending for dwellings is down over 20 per cent from January 2018, the largest through the year decline since late 2008.”, he said.

This weaker lending activity was evident across the states and territories in January, with new lending for investment dwellings down in all states and territories. Only Queensland and the Northern Territory recorded rises in lending for owner occupier dwellings.

While there was also a fall in the number of loans to owner occupier first home buyers (-0.3 per cent) in January, this was more stable than the 3.2% fall in the number of loans to owner occupier non-first home buyers.

Lending to households for personal finance (up 1.2 per cent) was the only household lending category to record a rise in January, however new lending is down 16.0 per cent compared to January 2018, seasonally adjusted. The value of lending to households for refinancing fell 3.4 per cent.

In trend terms, the value of new lending commitments to businesses fell 1.3 per cent in January, but is up 2.5 per cent from January 2018.

US Bank Disclosure Reduced Again

More evidence of the peeling back of US bank disclosure, which may reduce the incentive for bank managements to continually improve their capital and risk management processes.

On 6 March, Moody’s says the US Federal Reserve Board (Fed) announced the elimination of the qualitative objection in its 2019 Comprehensive Capital Analysis and Review (CCAR) for most stress test participants. Only five banks, all US subsidiaries of foreign banks, will remain subject to qualitative objection in the current stress tests cycle. In the past, the Fed has used the qualitative objection to address deficiencies in banks’ capital-planning process. Its elimination is credit negative because it reduces public transparency around the quality of banks’ internal capital and risk management processes.

Under the revised rules, a bank must participate in four CCAR cycles before it qualifies for exemption from a potential qualitative objection in future years. If a firm receives a qualitative objection in its fourth year, it will remain subject to a possible qualitative objection until it passes. For most of the five firms still subject to the qualitative objection, their fourth year will be the 2020 CCAR cycle. In total, 18 firms are subject to this year’s CCAR exercise, with five of them subject to a possible qualitative objection.

All five firms subject to the qualitative assessment in 2019 are foreign-owned intermediate holding companies (IHCs), most of which were first subject to the Fed stress tests on a confidential basis in 2017. If the IHC has a bank holding company subsidiary that was subject to CCAR before the formation of the IHC, then the IHC is not considered the same firm for the purpose of the four-year test.

The Fed noted that since CCAR was implemented in 2011, most firms have significantly improved their risk management and capital planning process. Going forward, its capital-planning assessments will be through the regular supervisory process. The Fed highlighted as an example the new rating system for large financial institutions, which will assign component ratings of a firm’s capital planning and positions. However, these ratings will be confidential supervisory information and unavailable to the public unless the deficiencies are so severe that they warrant formal enforcement action. The new process replaces an independent comparative assessment.

The lack of public disclosure may also reduce the incentive for bank managements to continually improve their capital and risk management processes, which the CCAR qualitative review encouraged.

As previously announced, 17 large and non-complex bank holding companies, generally with $100-$250 billion of consolidated assets, will not be subject to CCAR in 2019 because of the Economic Growth, Regulatory Relief, and Consumer Protection Act (the EGRRCPA), which became law in May 2018. They will next participate in 2020. Most of these banks were removed from the qualitative objection in 2017 and the Fed will only object to their capital plans if they fail to meet one of the minimum capital ratios under the stress scenarios on quantitative grounds.

The Fed’s announcement was incorporated with its release of instructions for the 2019 CCAR cycle. The Fed also provided information on allowable capital distributions for those firms whose CCAR cycle was extended to 2020. For those banks, the Fed published letters that address each bank’s individual 2019 capital plans. The Fed pre-authorized the firms to distribute, net of any issuance of capital, up to the sum of:

  • The additional capital the firm could have distributed in CCAR 2018 and remained above the minimum requirements; plus
  • Capital accretion (change in capital ratios since CCAR 2018); plus
  • its already approved capital distributions for first-quarter 2019 and second-quarter 2019; minus
  • its actual distributions for first-quarter 2019 and planned distribution for second-quarter 2019

This plan is also credit negative because it permits capital distributions based on last year’s results, which incorporated a modestly less stringent severely adverse scenario than the 2019 stress test, and it also fails to incorporate any interim changes in the banks’ risk profiles. If any of the 17 banks wants to distribute more than its maximum pre-authorized amount, it may submit a capital plan to the Fed by 5 April 2019 and will be subject to the 2019 CCAR supervisory stress test.