-
Firms may abandon prudent risk management practices such as hedging with derivatives to avoid the SIFI designation. Agencies should have to prepare the equivalent of an Environmental Impact Statement before slapping the SIFI stamp on a firm.
July 18 -
FSOC makes its first official designation of large firms that will be subject to new Dodd-Frank regulatory regime.
July 18 -
Two years after Dodd-Frank became law, the banking system continues to lack the basic tenants of transparency into the workings of the largest institutions and the good governance that comes with strong board oversight.
July 18
Imagine a nuclear power reactor core meltdown caused by a complete breakdown in multiple parts of its cooling systems that an advanced coolant and pressure monitoring system might have averted.
Yet two years after the incident, reactors across the country remain on line with only minor engineering improvements to coolant systems implemented and no retrofitting of warning gauges has occurred. Instead, a new voluminous nuclear safety manual has been issued to the power industry and its regulators, covering virtually every aspect of nuclear power plant construction. But each day, reactors operate without the new technology.
As you probably guessed, this is a not so veiled reference to the financial system, where there are a number of signs that our ability to detect emerging systemic risks is only marginally better than before the 2008 crisis. The Office of Financial Research is the loss-of-coolant detection system and Dodd-Frank is its safety manual. Financial markets remain highly complex webs subject to major systemic shocks that we are ill-equipped to identify before our financial system melts down.
So far, there have been a number of incidences of small, non-catastrophic failures in the form of MF Global, the JPMorgan trading losses and the Libor probe. The mega-reactor equivalents, namely the U.S. fiscal cliff and the European debt crisis, are exhibiting erratic temperature fluctuations. We would hardly tolerate waiting several years before addressing such a systemic public safety problem.
But while we can't decommission the financial system, we can put the OFR's activities on a parallel two-path track: one focused on the long term, the other on developing a set of stopgap processes designed to improve detection of systemic risk as we build data and measurement capabilities for the future.
Last week the OFR released its first
The report offers one of the most comprehensive and well-documented assessments of systemic risk drivers, measurement techniques and data developed thus far. It's a must-read for those interested in the subject of systemic risk.
The OFR report provides a detailed account of a number of promising gauges of systemic risk, and in that commentary it becomes clear that none of these metrics at this point can provide a comprehensive and accurate view of systemic risk. We are in a real sense fully operational with limited ability to recognize when the system has gone critical. Partly this is due to poor data available to measure systemic risk, but it also is due to the fact that the metrics themselves are not fully developed to handle the scope and scale of financial market participants and activities.
It will take OFR and other agencies years before the data and measurement infrastructure for accurate assessment of systemic risk is on line. This may be one reason why no specifics were offered in the report for how the OFR will execute its plan or what the timetable might be for implementation.
In the meantime, the Financial Stability Oversight Council needs to embark on an interim joint initiative to provide reporting and assessment of potential financial threats cobbled together from existing data augmented by other information that can be made readily available within six months. Such an effort could be assigned to a joint interagency taskforce comprised of FSOC member agencies led by OFR. No doubt this would create some redundancy in the process; however, we do not have years to wait for the new capabilities to materialize.
The OFR in its report played out the scenario of what it might have been able to do in 2005 to forestall the crisis. It concluded that its ability to investigate important financial activities and request data on them would have been an ''appropriate role'' for the OFR. Such a role today for the OFR should not be lost on itself or the FSOC as an interim and proactive step in maintaining the safety of the financial system while we await development of reliable advance warning capabilities.
Clifford Rossi is an executive-in-residence and Tyser Teaching Fellow at the University of Maryland's Robert H. Smith School of Business. He has held senior risk management and credit positions at Citigroup, Washington Mutual, Countrywide, Freddie Mac and Fannie Mae.
