Tag: non-bank financial intermediaries

Recently, a flurry of bankruptcies among non-bank financial intermediaries (NBFIs) in the USA has drawn attention to the risks associated with alternative credit channels in the shadow-banking sector – lending which is not financed with deposits. There is concern that this could be the start of a wave of bankruptcies among such NBFIs, especially given concerns about a potential downswing in the economic cycle – a time when defaults are more likely.

While providing alternative sources of funding, the opacity of lending in the shadow-banking sector means it is not clear what risks NBFIs face themselves and, more significantly, what risks they pose to the financial system as a whole. There is particular concern about the impact on regulated banks.

Already, JP Morgan Chase in its third quarter earnings report announced a $170m charge stemming from the bankruptcy of Tricolor, which specialised in sub-prime car financing. Mid-sized banks, Western Alliance and Zions Bancorp, have reported losses from loans to a group of distressed real estate funds. This has highlighted the interconnectedness between NBFIs and regulated banking, and the potential for problems in the shadow-banking sector to have a direct impact on mainstream banks.

In this blog, we will trace the secular trends in the financial systems of more advanced economies which have given rise to alternative credit channels and, in turn, to potential banking crises. We will explain the relationship between regulated banks and shadow banks, analysing the risks involved, the potential impact on the financial system and the policy implications.

What are the secular trends in banking?

The traditional model of commercial banking involved taking deposits and using them to finance loans to households and firms. However, cycles of banking crises, regulatory changes and financial innovation over the past 50 years produced new models.

First, banks diversified away from direct lending to providing other banking services – on-balance sheet activities, such as investing in financial securities, and off-balance sheet activities, such as acting as agents in the sale of financial securities.

Second, alternative credit channels based on financial markets have grown in significance.

In the 1980s, international regulations around traditional banking activities – taking deposits and making loans – were being formalised by the Bank for International Settlements (BIS) under what became known as the Basel framework (see, for example, Economics section 18.2 or Economics for Business section 28.2). For the first time, this stipulated liquidity and capital requirements for international banks relating to their traditional lending activities. However, at the same time the deregulation of financial markets and financial innovation provided banks with opportunities to derive revenues from a range of other financial services.

After the financial crisis, liquidity and capital requirements for banks were tightened further through the Basel III regulations. Commercial banks had to have even higher levels of capital as a buffer for bad debts associated with direct lending. A higher level of capital to cover potential losses increases the marginal cost of lending, since each pound of additional loan requires additional capital. This reduced the marginal return, and consequently, the incentive to lend directly.

These regulatory developments created an incentive to pursue activities which do not require as much capital, since their marginal cost is lower and potential return is higher. Consequently, banks have placed less emphasis on lending and more on purchasing short-term and long-term financial securities and generating non-interest income from off-balance sheet activities. For instance, research by the Bank of England found that during the 1980s, interest income accounted for more than two-thirds of total income for large international banks. In contemporary times, non-interest income tends to be greater than interest income. Figure 1 illustrates the declining proportion of total assets represented by commercial and consumer loans for all regulated US banks. (Click here for a PowerPoint.)

With banks originating less lending, activity has migrated to different avenues in the shadow-banking sector. This sector has always existed, but deregulation and financial innovation created opportunities for the growth of shadow banking – lending which is not financed with deposits. Traditionally, non-bank financial intermediaries (NBFIs), such as pension funds, hedge funds and insurance companies, use funds from investors to buy securities through financial markets. However, new types of NBFIs have emerged which originate loans themselves, notably private credit institutions. As Figure 2 illustrates, a lot of the expansion in the activities of NBFIs has been the due to increased lending by these institutions (defined as ‘other financial institutions (OFIs)). Note that the NBFI line includes OFIs. (Click here for a PowerPoint.)

Since, NBFIs operate outside conventional regulatory frameworks, their credit intermediation and maturity transformation are not subject to the same capital requirements or oversight that banks are. As a result, they do not need to have the same level of capital to insulate against loan losses. Therefore, lending in the shadow-banking sector has a lower marginal cost compared to equivalent lending in the banking sector. Consequently, it generates a higher rate of return. This can explain the large growth in the assets of OFIs illustrated in Figure 2.

Risks in shadow banking

Banking involves trade-offs and this is the case whether the activities happen in the regulated or shadow-banking sector. Increasing lending increases profitability. But as lending continues to increase, at some point the risk-return profile becomes less favourable since institutions are lending to increasingly higher-risk borrowers and for higher-risk projects.

In downturns, when rates of defaults rise, such risks become apparent. Borrowers fail and default, causing significant loan losses for lenders. With lower levels of capital, NBFIs will have a lower buffer to insulate investors from these losses, increasing the likelihood of default.

Is this a problem? Well, for a long-time regulators thought not. It was thought that failures in the shadow-banking sector would have no implications for deposit-holders in regulated banks and the payments mechanism. Unfortunately, current developments in the USA have highlighted that this is unlikely to be the case.

The connections between regulated and shadow banking

The financial system is highly interconnected, and each successive financial crisis has shown that systemic risks lurk in obscure places. On the face of it, NBFIs appear separate from regulated banks. But banks’ new business models have not removed them from the lending channel, merely changed their role. Short-term financing used to be conducted and funded by banks. Now, it is conducted by NBFIs, but still financed by banks. Long-term loan financing is no longer on banks’ balance sheets. However, while the lending is conducted by NBFIs, it is largely funded by banks.

NBFIs cannot be repositories of liquidity. Since they do not have deposits and are not part of the payments system, they have no access to official liquidity backstops. So, they do so indirectly by using deposit-taking banks as liquidity insurance. Banks provide this liquidity in a variety of ways:

  • Investing in the securities issued by private capital funds;
  • Providing bridge financing to credit managers to securitise credit card receivables;
  • Providing prime broker financing to a hedge fund engaged in proprietary trading.

Furthermore, banks have increasingly made loans to NBFIs. Data for US commercial banks lending to the shadow-banking sector are publicly available only since 2015. But, as Figure 3 illustrates, it has seen a steady upward trend with a surge in activity in 2025. (Click here for a PowerPoint.)

Banks had an incentive to diversify into these activities since they are a source of revenue requiring less regulatory capital. The model requires risk and return to follow capital out of the banking system into the shadow-banking sector. However, while risky capital and its associated expected return have moved in the shadow-banking system, not all of the liquidity and credit default risk may have done so. Ultimately, some of that risk may be borne by the deposit-holders of the banks.

This is not an issue if banks are fully aware of the risks. However, problems arise when banks do not know the full risks they are taking.

There are reasons why this may be the case. Credit markets involve significant asymmetric information between lenders and borrowers. This creates conditions for the classic problems of moral hazard and adverse selection.

Moral hazard is a hidden action problem, whereby borrowers take greater risks because they share the possible downside losses with the lender. Adverse selection is the hidden information problem, whereby lenders do not have full information about the riskiness of borrowers or their activities.

The economics of information suggests that banks exploit scale, scope and learning economies to overcome the costs associated with asymmetric information in lending. However, that applies to direct lending when banks have full information about credit default risk on their loan book. When banks finance lending indirectly through NBFIs, there is an extension of the intermediation chain, and while banks may know the NBFIs, they will have much less information about the risks associated with the lending they are ‘underwriting’. This heightens their problems of asymmetric information associated with credit default risk.

What are the risks at present?

The level of debt in the global economy is at unprecedented levels. Data from the International Monetary Fund (IMF) show that it rose to $351 trillion dollars in 2024, approximately 235% of weighted global gross domestic product (GDP). It is in this environment that private credit channels through NBFIs have been expanding. With this, it is more likely that NBFIs’ trade-off between credit risk and return has tilted greatly in favour of the former. Some point to the recent collapse of Tricolor and First Brands – both intermediary financing companies funded by private credit – as evidence of elevated levels of risk.

Many are pointing out that the failures observed in the USA so far have a whiff of fraud associated with them, with suggestions of multiple loans being secured against the same working capital. However, such behaviour is symptomatic of ‘late-cycle’ lending, where the incentive to squeeze more profit from lending in a more competitive environment leads to short-cuts – short-cuts that banks, at one stage removed along the intermediation chain, will have less information about.

It is in a downturn that such risks become apparent. Widening credit spreads and the reduced availability of credit causes financial stress for higher-risk borrowers. Inevitably, that higher risk will lead to higher defaults, more provision for loan losses and write-downs in the value of loan assets.

While investors in NBFIs are first in line to bear the losses, they are not the only ones exposed. At moments of stress, the credit lines that banks have provided get drawn and that increases the exposure of banks to the risks associated with NBFIs and whoever they have lent to. As NBFIs fail, the financing provided by banks will not be repaid and they will thus have to absorb losses associated with the lending of the NBFIs. So, while it appears that risk has left the banking system, it hasn’t. Ultimately, the liquidity and credit default risk of the non-bank sector is financed by bank deposits.

Furthermore, the opaqueness of the exposure of banks to risks in the shadow-banking sector may have issues for the wider financial system. In 2008, banks became wary of lending to each other during the financial crisis because they didn’t know the exposure of counterparty institutions to losses from securitised debt instruments. Now, as more and more banks reveal exposures to NBFIs, concerns about the unknown position of other banks may produce a repeat of the credit crunch which occurred then. A seizing up of credit markets will worsen any downturn. However, unlike 2008, the financial resources available to central banks and governments to deal with any consequences are severely limited.

Only time and the path of the US economy will reveal the extent of any contagion related to lending in the shadow-banking sector. However, central banks are already worried about the risks associated with the shadow-banking sector and have been taking steps to identify and ameliorate them. Events in the USA over the past few weeks may accelerate the process and bring more of that lending within the regulatory cordon.

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Questions

  1. Explain why the need to hold more capital raises its cost for banks.
  2. Why does this reduce the lending they undertake?
  3. What is the attraction of ‘off-balance sheet transactions’ for regulated banks?
  4. Analyse the asymmetric information that banks face when providing liquidity to non-bank financial institutions (NBFIs).
  5. Examine the dangers for the financial system associated with regulated banks’ exposure to NBFIs?
  6. Discuss some policy recommendations regarding bank lending to NBFIs.