Climate risks – Is the macroprudential framework fit for purpose?
Introduction
There is nowadays broad acknowledgement that the financial sector has a central role to play in enabling the transition to an environmentally sustainable economy. The Paris Agreement obliges its Signatories and their institutions to make finance flows consistent with a pathway towards low greenhouse gas emissions (GHG) and climate-resilient development (Article 2.1(c)). At the same time, banks and other financial institutions are themselves exposed to significant financial risks caused by rising temperatures – risks that may be systemic in nature and not be internalized by market players. This is where macroprudential policy comes into play.
1. Climate change as a source of financial instability
What are climate risks? It has become customary to distinguish between two main sources of climate risks. The first involves physical risks, representing the economic costs and financial losses due to the increasing frequency and severity of climate-related weather events (e.g., storms, floods, and heat waves) and the effects of chronic changes in climate patterns (e.g., ocean acidification and rising sea levels). The second, transition risks, are associated with the uncertain financial impacts that could result from changes in climate policy, technological breakthroughs or limitations, and shifts in market preferences and social norms during the economic adjustment to net zero. In particular, a rapid and ambitious transition means that a large fraction of proven reserves of fossil fuel cannot be extracted and become ‘stranded assets’.
For financial institutions, physical and transition risks can materialize directly, through their exposures to sovereigns, corporations and households that experience physical or transition risks – or indirectly at the macro-level, through the effects of climate change on the wider economy and feedback effects within the financial system. Physical and transition risks are drivers of conventional financial risk types, including credit risks, market risks, liquidity risks, operational risks and – for insurance undertakings – underwriting losses. For example, changes in consumption behavior may lead to a sudden repricing of investments in emission-dependent sectors and potential fire sales of assets, hence market risk. Or real estate located in coastal areas may depreciate in value due to physical risk and thus lead to higher credit risk for banks.
2. Methodological challenges in the assessment of climate risks
Climate risks can become systemic, if they do not only affect individual financial institutions, but broader parts of the financial system, where risks are concentrated. The ECB’s latest Financial Stability Review indeed suggests that the banking sector is already exposed to climate risks and that these risks may be particularly concentrated in certain sectors, geographical regions, and individual banks. And yet, discussions on potential macroprudential policy measures to tackle climate risks are still in their infancy.
A key explanation for the inaction of macroprudential policymakers is that climate risks are hugely complex to forecast. First, they are inter-systemic in that they relate to interactions between two systems – the climate and economic/financial system – in addition to interactions within each of them. Second, climate, social and technological tipping points render climate risks non-linear and their dynamics thus inherently difficult to predict. And third, climate risks are subject to unusually long-term horizons, which significantly increase the uncertainty around economic and financial projections. The long horizons associated with the impacts of climate change reinforce existing inaction biases as hard (quantitative) indicators for action are lacking.
These specific features of climate risks have led some central bankers and economists to conclude that we find ourselves in a situation of radical uncertainty. In their Green Swan Paper, they argue that climate-economic models are inherently incapable of representing the complex natural, societal, economic, financial, and technological dynamics climate risks are subjected to. An epistemological break is needed instead, including through more qualitative and politically grounded approaches.
The Network for Greening the Financial System (NGFS) is less radical in its approach. It embraces climate scenario analysis and macro stress testing as vital tools to help prepare for a range of future pathways, but at the same time cautions against (remaining) significant uncertainties. The NGFS Climate Scenarios are groundbreaking, but should be taken for what they are: a range of hypothetical, yet plausible future outcomes.
3. Including climate risks in the macroprudential toolkit
Most of the instruments macroprudential policymakers in the Union have at hand could be used to (also) counteract the buildup of climate risks and their concentration in the financial system. For the time being, adapting the existing toolkit to the reality and specificities of climate risks seems to be the more promising approach than to implement a specific (new) macroprudential tool to address climate risks. [1]
Macroprudential policymakers broadly distinguish between two sets of tools. The first set of tools addresses the procyclicality in the financial system, the so-called time dimension of systemic risks. The second set of tools aims to counteract common exposures and interconnectedness of financial institutions, the so-called cross-sectional dimension of systemic risk. Macroprudential policy addresses these sources of risk with different policy strategies. Countercyclical buffers are used to cope with procyclicality: buffers are built up as aggregate risk grows (upswing), so that they can be drawn on as risk materializes (downswing). Common exposures and interlinkages are dealt with by calibrating prudential tools to the (estimated) contribution of each institution to systemic risk.
How do climate risks fit into this analytical framework? Due to the irreversibility of climate change, physical risks are likely – and sadly – of a permanent nature and bound to go in only one direction. Macroprudential policy will thus primarily seek to limit concentration of exposures to firms (and potentially individuals) that are subject to certain physical risk indicators (e.g. geographic location). These indicators will aim to capture widespread climate risk drivers, including wildfires, heat waves or water stress, potentially amplified by chronic stresses, such as rising sea levels, in the second half of this century. As the ECB points out in its latest Financial Stability Review, a systemic amplifier could result from the fact that collateral used to secure banks’ exposures to physical climate hazards may itself be subject to damage or loss of value due to physical risk. Also, the role of insurance in mitigating physical risk is limited and may continue to shrink with more and more risks becoming uninsurable. To address exposure concentrations, macroprudential policymakers may either increase banks’ loss absorption capacity, e.g. by activating or increasing the systemic risk buffer (SyRB) or the own funds conservation buffer, or directly limit concentration risk through large exposures restrictions.
Transition risks, in contrast, exhibit arguably not only a cross-sectional dimension but also a time dimension. Even if technologies for carbon capture and storage were to improve significantly, reaching the climate targets of the Union will require substantial reductions in GHG emissions. Meanwhile, banks continue to lend to and invest in economic activities that directly or indirectly cause such emissions. It is thus not unfair to assume that there will be a correction of the now excessive credit growth in emission-intensive and dependent sectors. The difficulty with the assumed ‘carbon cycle’ is that its time horizon and pattern differs greatly from the financial cycle, which macroprudential policy normally targets. It has not become an actual cycle yet, as carbon emissions at the global level continue to rise. Conceptually, the carbon cycle may best be understood as a single, very long-term cycle. However, it cannot be ruled out that there will be short-term increases in demand for fossil fuels, and therefore ‘dips’ in the carbon cycle, during the transition to net zero, e.g. due to ineffective climate policy or unfulfilled expectations in alternative energy sources.
Classical instruments to address procyclicality in the financial system include the countercyclical capital buffer (CCyB), loan-to-value (LTV) and loan-to-income (LTI) or debt-service-to-income (DSTI) caps and sectoral capital requirements. The CCyB, applied on a sectoral basis, e.g. to banks’ credit exposures to economic activities with high scope 1-3 emissions, would provide an interesting broad-based instrument. It could be drawn on once transition risks materialize – e.g. in case of a sudden unanticipated rise of the carbon price – and would at the same time provide an incentive for banks to limit credit provision to emission-intensive or dependent firms. However, in light of the long horizon of transition risks, a carbon CCyB may stay activated for a long time, rendering its effects similar to those of a permanent brown penalizing factor under Pillar 1. A SyRB for banks overexposed to emission-intensive and dependent firms may offer a more targeted alternative to a carbon CCyB. Primarily aimed at increasing banks’ loss absorption capacity and reducing their exposures, such SyRB may have an indirect impact on the carbon cycle through higher funding costs.
Borrower-based measures, applied according to national law in some Member States, could be adjusted as well to consider climate risks. LTV ratios could require banks to include climate risk drivers, such as the geographical location or the energy efficiency of the underlying real estate, in the calculation of the property value. This may help reallocate credit from high-climate risk to low-climate risk housing markets. Moreover, macroprudential policymakers could include the emission intensity of the source of income as an indicator of creditworthiness under the DSTI/LTI ratios to prevent household overindebtedness due to climate risks. However, this latter option is not only politically sensitive, but also challenging and costly to implement and may bear a high risk of false negative and positive.
4. Conclusions: the role of macroprudential policy
Macroprudential policy is in many ways uniquely placed to tackle climate risks. First, climate risks are bound to affect every financial institution in one way or another. With its system-wide perspective, macroprudential policy can help identify and take precautions against concentrated vulnerabilities in the system. Second, while it is ideally evidence-based, macroprudential policy must naturally cope with significant uncertainties. It does so by striving for the best possible solution, partially by deploying heuristics. This could guide the way to deal with the many and partially deep uncertainties associated with the dynamics of climate risks and their impacts on the economic and financial systems. Third, climate risks fall squarely in the pre-emptive approach of macroprudential policy, which seeks to take precautions also against rare and hard-to-predict shocks. And forth, unlike monetary policy, macroprudential policy is by design not market neutral. While it may not be designed to counteract imbalances directly, it does so at least indirectly by increasing the system’s resilience and capacity to absorb shocks. Macroprudential policy may thus reduce the vulnerability of the financial system to climate shocks, while positively impacting the goal of emission reduction.
Nevertheless, macroprudential measures to address climate risks need careful calibration and strong political backing. Many carbon-intensive or dependent firms will need financing to reduce their carbon footprint and adapt to the net zero target. Disincentivizing or even prohibiting banks from lending to or investing in such firms for fear of transition risks would be counterproductive not only to the Commission’s Green Deal agenda, but also to financial stability. Assessments as to how firms are using the money they borrow will naturally increase the complexity for macroprudential policymakers and require them to more frequently deploy heuristics. Moreover, macroprudential measures to address physical risks will affect the economies of some Member States more than others and likely cause political controversies. Macroprudential policy therefore needs to be embedded in a much broader coordination effort between monetary, [2] financial, fiscal, and environmental policies, ultimately aimed at limiting the physical risks of climate change altogether.