The Bank of Canada has released the June 2009 Financial System Review with the usual high level views of government and corporate finance.
I was most interested to see a policy recommendation in the review of the funding status of pension plans. First they state the problem:
Assets fell in 2008, largely because of the steep decline in Canadian and international equity markets. At the same time, declines in long-term bond yields caused the present value of liabilities to increase.
… and provide an illustration:
… and provide a prescription:
In this environment, plan members are concerned about pension obligations being met.
To address these issues, reforms should focus on: (i) flexibility to manage risks and (ii) proper incentives. Reforms (regulatory, accounting, and legal) should also focus on providing sponsors with the flexibility needed to actively maintain a balance between the future income from the pension fund and the payouts associated with promised benefits. Small pension funds should be encouraged to pool with larger funds to better diversify market risk as another way to help make pension funds more resilient to market volatility.
I may be a little slow, but I fail to follow the chain of logic between the premises and the conclusion that “small pension funds should be encouraged to pool with larger funds to better diversify market risk”.
This will not affect the liability side, which is based on the long Canada rate. But the Bank fails to show – or even to suggest – that the decline in assets was exacerbated by lack of diversification, that large pools are better diversified than small funds, or that pooled funds outperform small funds.
It may well be that these logical steps can be justified – but they ain’t, which makes me suspicious. The recommendation is supportive of the Ontario government’s lunatic plan to encourage the bureaucratization of the Ontario Teachers’ Pension Plan (OTPP) and OMERS, as discussed on March 31, without either mentioning the proposal or providing any of the supporting arguments that were also missing from the original.
This has the look of a quid pro quo – either institution to institution, or the old regulatory game of setting up some lucrative post-retirement consulting gigs. Even if completely straightforward and honest, the argumentation in this section is so sloppy as to be unworthy of the Bank.
Of more interest to Assiduous Readers will be the section on banks, commencing on page 29 of the PDF.
There are two things of interest here: first, for all the gloom and doom, credit losses are not as high as the post-tech-boom slowdown, let alone the recession of 1990; second, that the graph is cut off after the peak of the 1990 recession.
Why was the graph prepared in this manner? Given the Bank’s increased politicization (also evidenced by the pension plan thing) and increased regulatory bickering with OSFI, I regret that I am not only disappointed that they are not encouraging comparison with the last real recession, but suspicious that there is some kind of weird ulterior purpose. Whatever the rationale, this omission reflects poorly on the Bank’s ability to present convincing objective research.
There are a number of longer articles on the general topic of procyclicity:
- Procyclicality and Bank Capital
- Procyclicality and Provisioning: Conceptual Issues, Approaches, and Empirical Evidence
- Regulatory Constraints on Leverage: The Canadian Experience
- Procyclicality and Value at Risk
- Procyclicality and Margin Requirements
- Procyclicality and Compensation
The second article includes a chart on provisioning; not the same thing as credit losses, but a much better effort than that given in the main section of the report:
I was disappointed to see that bank capital and dynamic provisioning were discussed in the contexts of the general macro-economy and with great gobbets of regulatory discretion. I would much prefer to see surcharges on Risk Weighted Assets related to both the gross amount and the trend over time of RWA calculated by individual bank.
The emphasis on regulatory infallibility is particularly distressing because it is regulators who bear responsibility for the current crisis. The banks screwed up, sure. But we expect the banks to screw up, that’s why they’re regulated. And the regulators dropped the ball.
The paper on leverage has an interesting chart:
Update, 2009-7-21: