导读
当今全球金融体系交错复杂，金融稳定已成为各国经济政策的核心议题之一。英国央行副行长Sarah Breeden的演讲从系统性视角出发，阐述了如何通过协调监管机构和实施宏观审慎政策，确保金融系统在风险和冲击中仍能稳定运行。
就金融稳定含义而言，金融稳定意味着即使在面临冲击时，金融系统也能持续提供如支付、贷款和保险等关键服务。Breeden指出，金融稳定并非仅仅是“没有危机”，而是指在面对各种经济冲击时，系统能够继续运转，尤其是在面临结构性变化（如气候风险、网络安全威胁）或周期性波动（如经济衰退）仍能提供可靠的金融服务。Breeden阐释了金融监管中的两个重要概念：微观审慎监管和宏观审慎监管。微观审慎监管关注单个金融机构的稳健性，通过资本充足率和风险控制防止个别机构倒闭。而宏观审慎监管更注重整个系统的稳定，尤其是系统内部的相互依存关系。Breeden强调，系统性思考是确保金融稳定的必要途径，单纯依靠微观审慎措施无法应对系统性风险，尤其当这些风险在市场或机构间相互放大时。
就金融稳定与经济增长来说，Breeden认为，金融稳定与经济增长并非相互对立的目标，而是相辅相成的。金融系统的韧性可以支撑经济在冲击中保持正常运转，促进长期可持续增长。然而，Breeden也警告过度的审慎监管可能会导致“墓地中的稳定”，即过度稳健限制了经济活力，阻碍了增长。而政策制定者应追求金融系统韧性与经济增长之间的平衡。下图无差异曲线表明，在不影响系统关键服务的前提下，政策者愿意牺牲部分经济增长来换取更高的系统韧性。
Breeden提到，全球金融危机前英国金融系统缺乏足够韧性，导致危机时金融服务迅速中断。但在危机后的改革中，金融系统韧性显著提升，不仅提高了服务的稳定性，也增强了经济增长的潜力。
此外，Breeden在演讲中着重讨论了金融系统应对多种操作性冲击的能力。随着全球金融体系的日益数字化，金融系统受到网络攻击、流动性危机等运营风险日益增多。她以2022年和2024年重大金融市场动荡为例，论述了如何金融机构如何通过系统性分析与迅速反应，避免这些事件引发全面的金融危机。与此同时，Breeden还提到英国央行推出的一项创新性分析工具——系统性探索情景分析（SWES）。SWES用于模拟极端市场冲击下不同金融市场（如政府债券、企业债券、回购市场等）如何相互作用，并评估这些冲击对整个金融系统的潜在影响。通过这种系统性分析，英国央行能够识别金融机构之间的依赖关系，评估在市场压力下的风险管理能力，从而更好地应对未来可能的系统性危机。
最后，Breeden强调央行政策制定应注重灵活性和适应性。她指出，宏观审慎监管不仅要关注当前的风险，还需要对金融市场的未来演变保持敏感。随着非银行金融机构在全球金融体系中的作用日益突出，监管机构必须不断调整政策工具，以应对这些新兴市场中的潜在风险。例如，她提到英国央行通过压力测试评估银行、保险公司和其他金融机构在不同经济情景下的抗压能力，并根据测试结果进行相应的政策调整。这种灵活的监管方式不仅确保了金融系统在面对多变的外部环境时，而且能够保持金融系统的韧性和适应性。
作者 | 莎拉·布里登(英国央行副行长)
Based on remarks given at Wharton-IMF Transatlantic Dialogue,
Washington DC
Sarah Breeden
Deputy Governor, Financial Stability
10 September 2024
So, how are we applying systemic thinking in practice?
The System-Wide Exploratory Scenario (SWES)—where we have been working closely with the Financial Conduct Authority and the Pensions Regulator over the past year—is a novel exercise that illustrates the benefits of system-wide scenario analysis.
For a long time, central bankers and academics have spoken about the importance of understanding feedback and interconnections in assessing financial stability risks. But we have struggled to run exercises that qualitatively explore these dynamics at a system-wide level in advance of a shock occurring. The SWES is our first attempt to do just that.
The SWES focuses on markets that are core to UK financial stability—markets for government and corporate bonds, repo markets for these assets, and associated derivatives markets, such as interest rate, cross-currency, and inflation swaps. Participants have been asked to consider how they would behave in a hypothetical market shock with price moves that are faster, wider-ranging, and more persistent than observed both in the March 2020 ‘dash for cash’ and the 2022 LDI crisis. We are analyzing how those behaviors interact and cascade across markets to better understand the system-wide impact of such a shock. Indeed, it is system-wide analysis like this that helps firms understand their dependencies on others’ actions—and so, whether their approach to risk management in theory will withstand stress in practice.
All of these markets ultimately support the provision of services to households and businesses. The gilt market—and the associated repo market—underpins a wide set of other transactions through its role in pricing risk-free assets and in allowing liquidity to flow around the system. Derivatives markets allow participants to hedge against the risks they face, and corporate bond markets directly provide a source of corporate financing.
The system-wide thinking in the SWES is thus helping us understand systemic risk as a means to an end—where the end is supporting reliable service provision.
What happens to our systemic thinking after the SWES?
We are on course to deliver the final report on the SWES in November this year. But how might we take this work forward as part of our overall approach to macroprudential policy and systemic risk assessment?
The SWES has illustrated the value of system-wide exercises, and given the investment we have made into the first exercise, we think we could get much of the benefit of a further one through a leaner, more data-driven approach. Importantly, the SWES is now a proven addition to our toolkit for exploring risks where interconnections, feedback, or data constraints are important. We could, for example, use this sort of exercise to explore risks to corporate financing, where a range of market participants, including both banks and non-banks—with complex interconnections and interdependencies across the two—are involved in providing services to businesses.
Many of the benefits from the SWES have come from the constructive engagement of participants. We have learned as much from discussions with firms about investment approaches and risk management as we have through data-based work. We will engage firms in our deliberations about what comes next, continuing the active dialogue about system-level risks.
While scenario exercises are an important part of our work, our systemic thinking must extend beyond them, into our wider policy and risk assessment work. The normalization of central bank balance sheets, for example, will affect bank funding and liquidity conditions in the UK banking sector in coming years. In that context, my colleagues have recently spoken about the critical role that central bank reserves play in the financial system to meet our objectives for price stability and financial stability, and the related thinking around how to structure our steady-state balance sheet facilities. A microprudential approach to that question might lead you to conclude that reserves should be abundant to help banks manage their liquidity risk. But a systemic approach would place more weight on the importance of providing incentives to manage liquidity well—endogenously reducing liquidity risk-taking by banks—and ensuring that liquidity flows freely around the financial system, including to non-banks, so that the system is more resilient in stress.
Operational resilience is another area where systemic thinking is important. When individual financial firms are operationally resilient, it helps them provide vital services to households and businesses. However, sometimes this is not enough to prevent operational disruptions from impacting the financial system as a whole. For example, firm-level disruptions can lead to a widespread loss of confidence in the system, or firms may be exposed to common vulnerabilities. A systemic approach ensures that financial firms consider how their operational weaknesses affect the stability of the system more widely, not just their own businesses.
How does the FPC decide where and when it should take action?
Given the wide range of potential vulnerabilities in the system and the large policy toolkit available to the FPC, it has to be deliberate about where, when, and how it takes action, including working in concert with other regulators, given the vital role they play in ensuring the resilience of individual institutions.
First, the FPC has to take action where microprudential regulation has not adequately addressed systemic risks. In most instances, building the resilience of individual firms—which is the role of microprudential policy—will build the resilience of the system. But in some cases, macroprudential policy has to build more resilience than microprudential policy otherwise might—such as with LDI funds, given the correlated, concentrated nature of their positions. In other instances, macroprudential policy has to intervene to lean against defensive actions aimed at building individual resilience that would weaken the system as a whole. For example, the FPC can release the UK countercyclical capital buffer in downturns that would otherwise lead to unwarranted reductions in lending.
Second, the FPC must remain focused on the biggest risks to the provision of services. Stress testing is an established way of sizing risks. The Bank is evolving its stress testing framework in several ways. I’ve already mentioned the SWES and the future work that may allow us better to take into account systemic risk arising from amplification, feedback channels, and interconnectedness. We are also taking stock of our framework for concurrent bank stress testing—to embed the adaptability it has shown in recent years and allow us to make best use of it to reflect the risk environment. Importantly, where banks went first, others have now followed: as well as the concurrent stress tests of the banking system, we now conduct stress tests of the insurance and CCP sectors.
Third, the FPC has to continually adapt to the changing shape of the financial system. In the early years of the FPC, almost all of its policy recommendations focused on banks. Since then, reflecting the increase in bank resilience and the structural shift in activity towards non-banks, the FPC’s recommendations have shifted away from banks—notwithstanding the greater difficulties in identifying risks in a more complex ecosystem and in tackling vulnerabilities in a global market.
Fourth, macroprudential authorities should be pragmatic and creative about where they can make a difference. In some cases, the most effective way to change behavior is by communicating privately or publicly with market participants. At the same time, the FPC must be deliberate and targeted in its public communications, focusing its public statements when it needs to get a particular message to market participants or the public—for example, to encourage behavior changes. The FPC’s Brexit checklist, for instance, encouraged others to take action to reduce the risks associated with the UK’s departure from the European Union.
Fifth, we invest time in engaging with international authorities, because shocks and financial markets are global. As an international financial center and small open economy, the UK is particularly exposed to global shocks. That underlines the importance of pursuing strong international standards to support UK financial stability. We have also learned that while global actions are sometimes needed, they need not hold up domestic action where it can be effective.
In many areas, the cross-border nature of finance means that the most effective way to take action is in coordination with our global partners, through bodies like the Basel Committee or Financial Stability Board. But in some cases, we can take effective action to build resilience domestically or in coordination with smaller groups of jurisdictions, as we did for LDI funds recently.
How can the financial system contribute to growth?
As financial stability policymakers, the best contribution we can make to sustainable economic growth is to ensure the system has enough resilience to reliably provide vital services even as shocks hit. That is recognized by the FPC’s primary objective. The FPC also has a secondary objective, which should be pursued "subject to" its primary objective: to support the economic policy of the government, including its objectives for growth and employment. It is therefore incumbent upon us to remain open to the possibility that in some areas we might be able to increase the system’s ability to contribute to sustainable economic growth without undermining financial stability.
To take one example, there has recently been some debate around whether the pensions sector can play a greater role in supporting growth in the wider UK economy. The government recently launched a review and is gathering evidence from interested parties. Previous Bank work explored whether arrangements in the pension sector had struck an optimal balance between pensioner protection, economic growth, and financial stability. More recent work has looked at how the sector could facilitate greater investment in longer-term, less-liquid assets. There may be ways to increase the sector’s contribution to economic growth without impacting the resilience of service provision or financial stability.
Other specific aspects of the provision of financial services might have a particular impact on growth that we might want to consider as we go about our work. For example, the financial system’s provision of services to small and medium enterprises (SMEs), innovations in the money and payments landscape, and how the financial system supports the transition to a lower-emissions economy. Much more evidence is required before we can draw firm conclusions, but policymakers should take seriously any opportunities to increase the system’s contribution to growth if it can be done in a way that doesn’t undermine financial stability.
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编译：毛歆语
监制：崔洁
来源｜国际货币基金组织
版面编辑｜傅恒恒
责任编辑｜李锦璇、阎奕舟
主编｜朱霜霜
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