Tag: shadow banking

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.

Articles

Academic paper

Data

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.

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 documents and reports

Data

Questions

  1. Explain stress testing.
  2. What is shadow banking? Explain the factors driving the growth of credit in this part of the financial system.
  3. Compare and contrast the liquidity problems of banks with those of non-bank financial institutions (NBFIs).
  4. Analyse how financial crises can heighten problems of asymmetric information in financial markets.