On the 29 November, the Bank of England published the results of its latest stress test of the UK financial system. Annual stress testing was introduced in the wake of the 2008 financial crisis. It models the ability of the financial system to withstand severe macroeconomic and financial market conditions. Typically, the focus has been on testing the resilience of the banking system.
This year’s was the first system-wide exploratory scenario (SWES). This recognises the growing significance of ‘shadow banking’. Shadow banking involves borrowing and lending involving non-bank financial institutions (NBFIs). Such institutions sit outside the regulatory cordons around banking but have become significant actors in the financial system.
However, this obscure part of the financial system poses systemic risks which are not clearly understood and from time to time require costly interventions. Examples include: problems in liability-driven investments (LDIs) for pension funds in September 2022; the money market liquidity crisis involving hedge funds in March 2020; the collapse of Long-term Capital Management (LTCM) in 1998 following the Russian Federation’s default (LTCM had significant holdings of Russian government bonds – see linked article on LTCM below).
The growing significance of shadow banking means that regulators have become increasingly concerned about the vulnerabilities in the financial system which arise from outside the traditional banking system.
In this blog we will explain stress-testing of the financial system and trace the rise in shadow banking which motivated the recent system-wide exploratory scenario (SWES). We will discuss the findings of the stress test, highlighting the systemic risks of shadow banking. Finally, we will discuss the implications for the regulation and supervision of the financial system.
What is stress testing?
Stress testing was introduced by the Bank of England after the financial crisis to assess the ability of the financial system to withstand severe economic and market scenarios.
In the run-up to the 2008 financial crisis, the liquidity and capital buffers of many banks had been extremely thin. These were only able to withstand moderate economic shocks and moderate conditions and buckled under the stresses of the crisis.
Regulators argued that the buffers needed to become much more robust and be able to withstand rare but severe economic and market conditions. The stress testing analogy was derived from engineering, where parts are expected to work not just in benign conditions but also in extreme, hostile environments.
Since 2014, the Bank of England has conducted annual stress testing. Stress testing models the impact of adverse economic conditions on banks’ liquidity, profitability and capital. The results are used to set policy for individual banks (microprudential) and for the system as a whole (macroprudential). Stress test results have allowed the Bank to adjust the loss-absorbing capital that banks must hold to reduce their likelihood of failure.
The scope of the testing has expanded over time to incorporate insurers, central counterparties (financial institutions that provide clearing and settlement services between financial traders) and cyber security. The most recent scenario recognised the increasing significance of non-deposit taking financial institutions in channelling credit. Fifty City of London institutions modelled how a period of intense stress would ripple through the shadow banking sector.
The arcane world of shadow banking
Shadow banking refers to borrowing and lending which occurs outside the banking sector. Traditionally banking involves taking deposits and using these to finance lending.
Shadow banking involves non-deposit taking financial institutions (NBFIs) such as hedge funds, insurance companies, pension funds, private equity funds, as well as some activities of investment banks. These institutions channel funds in different ways from lenders to borrowers. Typically, they use funds from investors to buy securities through financial markets. The emergence and growth of shadow banking has been explained by changing regulation and innovation.
Its first significant period of expansion in the late 1980s was driven by financial innovation. Increased use of ‘disintermediation’ – the replacement of credit channels through banks with ones through markets – meant an increase in the assets invested through NBFIs.
Despite this process playing a major role in the expansion of housing credit in the run-up to the 2008 financial crisis, it was the significant bailouts that banks received that drew the attention of regulators, not the role of shadow banking. This led to more stringent liquidity and capital requirements for banks under the BASEL III international regulations.
This regulatory tightening limited banks’ ability to offer credit, which meant that much of this activity migrated to the shadow banking sector.
Data from the Bank of England show that the percentage of total assets held by NBFIs rose from 41% in 2007 to 49% in 2020. The chart illustrates the total financial assets held by non-bank financial institutions in the UK between 2019 Q4 and 2023 Q3 (click here for a PowerPoint). The amount held has growth by approximately a third in that time, from £4321bn to £6069bn, peaking at £6670bn in 2022 Q3.
The lack of regulatory oversight stems from the nature of the activities in the shadow banking sector. While NBFIs conduct maturity transformation, provide liquidity and help manage risk, unlike banks, they do not accept deposits and are not part of the payments system involving the general public.
Consequently, the consensus among regulators has been that their activities do not pose the same systemic risks as banking of the breakdown of the payments mechanism and associated collapse in business and consumer confidence. Therefore, NBFIs are not subject to conventional regulation and supervision involving liquidity and capital requirements.
However, as the scale of borrowing and lending running through the sector has grown, this argument has become less difficult to justify. There is a concern that ‘regulatory arbitrage’ is happening and that the systemic risks associated with shadow banking are being underestimated.
The familiar risks of shadow banking
The systemic consequences of liquidity and solvency problems in the shadow banking sector may not seem obvious. Much of their activities are arcane and technical. However, there are plenty of examples of instances where the problems of hedge funds or pension funds have caused systemic issues.
While the consequences are not the same as those involving banks, in that the payments mechanism is not directly affected, the risks are. Just like banks, these institutions are exposed to liquidity risks, credit default risks and counterparty risks. The concern is that they do not have the same levels of liquidity or capital buffers as banks to insulate them from the consequences of such risks. Therefore, it might not take much economic stress for one or more of these institutions to fail and, given the increasing significance and interconnectedness of these activities, impose significant costs on the rest of the financial system.
It was for this reason that the Bank of England conducted its first system-wide exploratory scenario to analyse the impact of economic and market stress on these institutions and assess the nature and extent of systemic risks which resulted. Fifty City of London institutions modelled how a period of intense stress would ripple through the non-bank sector.
The scenario involved rising geopolitical tensions which caused a sharp rise in risk aversion and a demand for higher expected rates of return as compensation. This produced sharp rises in both sovereign and corporate bond yields and matching sharp declines in asset prices (remember bond yield and prices have a negative relationship).
The scenario found that the position and behaviour of NBFIs amplified the shock. These institutions invest significantly in marketable financial securities and their liquidity and solvency are susceptible to such falling prices.
The sharp decline in asset prices triggered margin calls – payments to cover open loss positions in financial securities. In response to these demands, while some NBFIs’ internal risk and leverage measures were breached, others illustrated greater risk-aversion and took precautionary action. These institutions acted to deleverage, derisk and recapitalise. Given the interconnectedness of financial markets, the individual actions of institutions rippled across financial markets, causing problems in other segments.
The significant decline in asset prices led insurance companies and pension funds to seek to improve their liquidity and solvency position by liquidating positions in money market funds and hedge funds. This, in turn, required these funds to seek liquidity. Such institutions tend to rely a lot on the repo market (involving short-term sale and repurchase credit agreements) to provide liquidity to investors. This avoids them having to sell assets. This practice has echoes of the banking sectors use of the short-term wholesale markets in the run-up to the 2008 financial crisis.
However, the SWES found that while banks were willing to take on some of the risk, their own concerns about liquidity and counterparty credit risk meant they did not offer sufficient short-term liquidity through the repo markets. If such funding dried up because of a higher risk perception, it could compromise the hedge funds’ ability to raise funds, requiring asset sales. This would amplify the shock to financial markets, driving prices of financial securities even lower.
The scenario concluded that the resulting heavy selling could seize up financial markets, particularly the UK sovereign and corporate bond markets, reducing the ability of companies to finance investment. This is a different type of credit crunch from 2008, which was restricted to banks – but a credit crunch, nonetheless.
At the same time, funds may make capital losses as they sell securities in the downturn. This creates solvency problems and the potential for failure.
In the SWES the institutions were often not able to anticipate how their counterparties, investors, or markets they operate in would behave in the stressed scenario, which echoes the experience of banks in 2007 and 2008 – a significant reason for the ‘crunch’ in banking credit was uncertainty about the creditworthiness of counterparties, meaning that banks were not prepared to lend to anybody.
Conclusion
Since the 2008 financial crisis, there has been a tightening of the regulation and supervision of banks which has limited their ability to channel credit. This has produced an expansion in the shadow banking sector.
However, while the shadow banking sector has not been subject to the same regulation and supervision as banks, there are still potential systemic risks associated with its operations. There have been several examples of such risks in the shadow banking sector which have led regulators to pay more attention. These underpinned the 2024 system-wide exploratory scenario (SWES) conducted by the Bank of England.
The scenario showed the possible transmission mechanism through which problems for NBFIs can have broader consequences. The report nevertheless concluded that:
…the UK financial system was well-capitalised, maintained high levels of liquidity and that asset quality remained strong.
Therefore, the UK financial system was resilient enough to withstand problems in shadow banking.
Although the results of the exercise provide a ‘framework of future system-wide analysis which can be embedded in future market-wide surveillance,’ history indicates that risks tend to exist in obscure and arcane parts of the financial system and that these never tend to be fully appreciated until a crisis occurs. This then tends to involve significant costs for taxpayers.
Articles
- Bank of England warns of risks from non-banks in future markets crisis
- BoE finds non-bank financial firms pose wider risks in crisis periods
- Finance Firms Beyond Banks Not Ready For Crisis, BOE Warns
- Shadow Banking System: Definition, Examples, and How It Works
- US Treasuries: the lessons from March’s market meltdown
- LDI: the better mousetrap that almost broke the UK
- Long-Term Capital Management
- Neil Woodford: the continuing fallout of a scandal
Financial Times from MSN, Martin Arnold (29/11/24)
Reuters, Lawrence White (2/12/24)
Bloomberg from Yahoo finance, Laura Noonan and Greg Ritchie (29/11/24)
Investopedia, Michael Bromberg (18/10/24)
Financial Times, Colby Smith and Robin Wigglesworth (29/7/20)
FT Alphaville, Alexandra Scaggs and Louis Ashworth (29/9/22)
CFA Institute, Ron Rimkus (18/4/16)
Financial Times, Owen Walker (19/3/21)
Bank of England documents and reports
- The Bank of England’s system-wide exploratory scenario exercise final report
- Stress testing
- Assessing the resilience of market-based finance
Bank of England (29/11/24)
Bank of England
Bank of England (13/7/21)
Data
Questions
- Explain stress testing.
- What is shadow banking? Explain the factors driving the growth of credit in this part of the financial system.
- Compare and contrast the liquidity problems of banks with those of non-bank financial institutions (NBFIs).
- Analyse how financial crises can heighten problems of asymmetric information in financial markets.
On 25 October 2024, Moody’s, one of the major credit ratings agencies, announced that it was downgrading France’s economic outlook to negative. This was its first downgrading of France since 2012. It followed a similar revision by Fitch’s, another ratings agency, on 11 October.
The yield on 10-year French government debt began 2024 at 2.56% and had an upward trend for the first half of the year. The yield peaked at 3.34% on 1 July. It then fell back below 3% for a while. The negative economic outlook then pushed yields back above 3% and they finished October at 3.12%, half a percentage point above the level at the start of the year. This represents a significant increase in borrowing costs for the French government. 
If the expected rate of return rises, this increases the discount rate applied to future cash flows and reduces their present value. At the current price, the fixed coupon is not sufficient to compensate investors. So, investors sell the bonds and price falls until it reaches a point where the yield offered is equal to that required. The reverse happens if the expected rate of return falls. 
Governments in France last achieved a balanced budget in 1974. They have run deficits ever since. Figure 2 illustrates the French government budget deficits from 1990 to 2023 (click 
Further, political instability has grown due to the inconclusive parliamentary elections which Emmanuel Macron surprisingly called in July. No single political grouping has a majority and the President has appointed a Centrist Prime Minister, Michel Barnier (the former EU Brexit negotiator). His government is trying to pass a budget through the Assemblée Nationale involving a mixture of spending cuts and tax hikes which amount to savings of €60 billion ($66 billion). This is equivalent to 2% of GDP.
In the past, bond investors were more tolerant of France’s budget deficits. French government bonds were attractive options for investors wanting to hold euro-denominated bonds while avoiding riskier Southern European countries such as Greece, Italy, Portugal and Spain. Since France has run persistent government deficits for a long time, it offered bond investors a more liquid market than more fiscally-parsimonious Northern European neighbours, such as Germany and the Netherlands. Consequently, France’s debt instruments offered a slight risk premium on the yields for those countries. 
As Figure 3 illustrates, this was the culmination of a trend evident throughout 2024, with the difference in yields between the two declining steadily (click