Overview

192 Quarterly Bulletin 2013 Q3

A vital element of recent reforms to the UK architecture of financial regulation is the creation of a
macroprudential authority at the Bank of England the Financial Policy Committee (FPC).
This article explains the role and powers of the FPC. It also describes some of the processes
supporting the Committee.
(1) The authors would like to thank Victoria Kinahan and Michael Snapes for their help in
producing this article. Aashish Pattani left the Bank in June 2013.
Macroprudential policy at the
Bank of England
By Paul Tucker, Deputy Governor for Financial Stability, and Simon Hall and Aashish Pattani of the Banks
Macroprudential Strategy Division.
(1)
A typical FPC quarterly cycle
Brieng
Analysis and research from Bank
economists about risks to nancial
stability
Market intelligence from the Banks
network of nancial market contacts
Supervisory intelligence and analysis
from the PRA and FCA
Assessment of the impact of existing
FPC policies
FPC issues meetings
FPC assesses and discusses the
major risks to UK nancial stability
Discussion of potential
macroprudential policy actions
that might be required
Communication
Policy set out in FPC statement/FSR
and communicated to addressees of
Recommendations and/or Directions
Details of FPC deliberations set out in
the FPC Record
FSR sets out assessment of, and
outlook for, the nancial system
Analysis promulgated including via
the Banks Agents and market
contacts
FPC policy meeting
FPC discusses and decides any
macroprudential policy measures

FPC reviews the setting of Direction
instruments (CCB and SCR)
FPC reviews the status of existing
policies
The FPCs primary role is to identify, monitor, and take action
to remove or reduce risks that threaten the resilience of the
UK financial system as a whole. It comprises five Executives
of the Bank of England, the Chief Executive of the Financial
Conduct Authority, four external members and a non-voting
HM Treasury member.
The FPC can issue Directions and Recommendations to the
Prudential Regulation Authority (PRA) and Financial Conduct
Authority (FCA), and can make Recommendations to other
bodies. For banks, the FPC has been given a power of
Direction over sectoral capital requirements (SCRs) and will
also be given a power to set the countercyclical capital buffer
(CCB) under new EU legislation.
The FPC meets quarterly to a published schedule. Each
quarterly round comprises a briefing on financial system
developments; focused discussions of key threats to stability
and potential macroprudential policy interventions; and a
formal meeting to agree on policy decisions, for example to
make Directions and/or Recommendations.
Accountability is a key element of the new arrangements.
The FPC must explain the decisions it has taken, publish a
Record of its formal meetings and, twice a year, publish a
Financial Stability Report (FSR). FPC members also appear
regularly at Treasury Committee hearings.
Topical articles Macroprudential policy at the Bank of England 193
The crisis has underlined the importance of financial stability
as a precondition for monetary stability and broader economic
health and prosperity. Policymakers around the world
recognised that focusing separately on price stability and on
microprudential regulation of individual firms and markets was
not enough. A broader approach macroprudential policy
was needed to ensure the resilience and stability of the
financial system.
In the United Kingdom, the Financial Policy Committee (FPC)
was created to fill that gap. Its work is important globally,
as well as domestically, given Londons role as an international
financial centre. That was recognised by the International
Monetary Fund (IMF) in deciding to include the
United Kingdom as one of five globally systemic economies
covered in the IMFs spillover reports on cross-country
economic and financial linkages.
(1)
Other countries are also introducing macroprudential regimes
in the wake of the crisis. For example, in the United States the
Financial Stability Oversight Council is responsible for
identifying risks and responding to emerging threats to
financial stability, with the Federal Reserve Board responsible
for establishing enhanced prudential standards for systemically
important firms. The European Systemic Risk Board (ESRB)
contributes to the prevention or mitigation of systemic risks to
financial stability in the European Union (EU). Within the EU,
countries, including France and Germany, are also creating
macroprudential authorities, partly in response to
recommendations from the ESRB.
(2)
An article in the 2013 Q1 Quarterly Bulletin summarised the
main changes to the Bank of England as a result of recent
reforms to the United Kingdoms system of financial
regulation, including the creation of the new Prudential
Regulation Authority (PRA) and the FPC. This article provides
more detail on the specific role and powers of the FPC. It also
describes some of the processes supporting the Committee.
Objectives of the FPC
Under the Bank of England Act 1998 (the Act), as amended by
the Financial Services Act 2012, the Bank has a statutory
objective to protect and enhance the stability of the financial
system of the United Kingdom. The FPC is tasked with helping
the Bank meet that objective and, subject to that, also
supporting the Governments economic policy, including its
objectives for growth and employment. Before determining or
revising the Banks financial stability strategy, the Banks Court
of Directors must consult the FPC.
HM Treasury is required to give the FPC written notice each
year of the Governments economic policy and must make
recommendations about the Committees responsibility in
relation to the financial stability objective. The Treasury may
also make recommendations to the Committee, including
regarding the Committees responsibility in relation to support
for the Governments economic policy and matters that the
Committee should have regard to in exercising its functions.
The Treasury sent the FPC a first remit and recommendations
letter on 30 April 2013, to which the FPC responded in
June 2013.
(3)
The FPC has a statutory responsibility to identify, monitor, and
take action to remove or reduce risks that threaten the
resilience of the UK financial system as a whole. This is
supported by the objectives of the microprudential regulators.
The PRA is part of the Bank. It is responsible for the
microprudential regulation of individual deposit-takers,
insurers and major investment firms.
(4)
The Financial Conduct
Authority (FCA) is a separate institution responsible for
ensuring that relevant markets function well, for conduct
regulation and for microprudential regulation of financial
services firms not supervised by the PRA, such as asset
managers, hedge funds, many smaller broker-dealers and
independent financial advisers.
(5)
Examples of systemic risks highlighted by the legislation
include:
risks relating to structural features of financial markets, such
as connections between financial institutions;
risks relating to the distribution of risk within the financial
sector; and
unsustainable levels of leverage, debt or credit growth.
Risks from linkages within the financial system
Linkages among financial institutions including via common
membership of payment, settlement and clearing systems
can, if infrastructure is strong, bolster system resilience, by
allowing risks to be shared and managed. But if key firms or
funds within the system are fragile, heightened
interconnectedness can also make the system more vulnerable
to shocks spreading from one institution to another.
Connections between markets and financial institutions
increased and became more complex internationally ahead of
the crisis, partly as a result of growth in cross-border
investment in asset-backed securities and related products and
greater sourcing by banks of funding from overseas.
(6)
When
(1) The size and interconnectedness of the UK financial sector make it a powerful
originator, transmitter, and potential dampener of global shocks. The United Kingdom
agglomerates core international financial functions making it a key node in funding
liquidity and balance sheet hedging, providing buoyancy to global markets and acting
as a key channel transmitting shocks or stabilizing measures, see International
Monetary Fund (2011).
(2) See European Systemic Risk Board (2011).
(3) See Remit and recommendations for the Financial Policy Committee April 2013,
available at www.bankofengland.co.uk/financialstability/Pages/fpc/remit.aspx.
(4) See Bailey, Breeden and Stevens (2012).
(5) See Murphy and Senior (2013).
(6) Parkinson and Speight (2003) describe the increased reliance of UK banks on overseas
wholesale funding. Recent developments in cross-border credit are discussed by
Hills and Hoggarth (2013).
194 Quarterly Bulletin 2013 Q3
the crisis broke inadequate disclosure meant there was
widespread uncertainty about those institutions across the
globe that were exposed directly or indirectly to
sub-prime assets, such as loans extended to borrowers that are
more likely to have difficulties meeting repayments. Given the
poor capitalisation of many banks and shadow banks this, in
turn, led to a breakdown in the functioning of interbank
markets as financial institutions began to lose confidence in
the resilience of their counterparties.
Risks relating to the distribution of risk
A second dimension of risk to systemic resilience is the
distribution of risk within the financial system. Risk may be
concentrated in specific parts of the system, for example in
large financial institutions with a significant footprint in
financial markets, or at critical infrastructure providers, such
as central counterparties.
(1)
As a result, the resilience of
the system as a whole depends on the strength of these
entities.
Cyclical systemic risks
A third dimension to systemic risk relates to the cyclical
build-up of debt or leverage. After an extended period of
stability, financial firms, households and companies may take
decisions to lend or borrow that make sense while economic
conditions remain benign but, collectively, entail fragility
across the system as a whole. A sudden economic slowdown
can then lead to unexpected and widespread losses. The scale
of losses across the system, and wider economic impact, may
be amplified if lenders have insufficient capacity to absorb
losses and as a result rein back on new activity.
The crystallisation of systemic risks following a large build-up
of debt has been evident in previous financial booms and busts
such as those in the United States, Scandinavia and Japan in
the 1980s and 1990s. In the United Kingdom in the run-up to
the recent crisis, balance sheets of financial institutions
expanded rapidly relative to their capital base.
(2)
This can be
seen in the increase in reported leverage of UK banks shown in
Chart 1, defined as total assets including, for example, the
stock of outstanding loans to capital, which can absorb
losses on those loans.
(3)
Similar developments were seen in
other financial systems. Rising asset prices and a progressive
easing in access to finance went hand in hand. But as the crisis
unfolded conditions reversed rapidly. For example, in the
run-up to the crisis, as house prices rose, UK households were
able to obtain mortgages at higher loan to value and loan to
income ratios, but then terms tightened sharply as conditions
deteriorated. In financial markets, the cost of accessing
finance, as indicated by initial margin or haircut requirements
the collateral required to back borrowing fell ahead of the
crisis, but then rose sharply when the crisis hit. This had the
effect of amplifying the falls in asset prices and activity in
some markets and spreading problems across the financial
system.
Banks also took on more liquidity risk by financing an ever
higher share of their loans which are typically extended over
a long term with short-term wholesale funding, including via
shadow banks. Maturity transformation based on the
provision of monetary services is a valuable service to the
economy, allowing savers to have ready access to their
deposits and borrowers to take out loans for extended periods.
But excessive maturity transformation also makes banks and
shadow banks prone to the risk of runs. That can mean that
they need to sell assets at depressed market prices in order to
meet redemptions as they fall due, which can further
undermine resilience. In the run-up to the crisis, UK banks, in
common with their international counterparts, had reduced
their holdings of liquid assets and, at the same time, had
become more reliant on unstable sources of short-term
funding, in particular from wholesale markets.
The combination of highly indebted borrowers, opaque capital
markets and dangerously thin capital and liquidity positions
across banks and shadow banks left the global financial system
highly vulnerable to shocks. By the summer of 2007, an
unusual pick up in defaults on mortgages to borrowers with
poor credit records in the United States had led to the
widespread closing of wholesale markets used by banks and
others across the globe to finance residential and commercial
Chart 1 UK banks reported leverage multiples
0
10
20
30
40
50
60
70
1980 86 92 98 2004 10
Multiple
Weighted average Basel III denition
(b)(c)

Range
Interquartile range
Weighted average
(a)
Sources: PRA supervisory data, published accounts and Bank calculations.
(a) The weighted average and ranges shown are based on a simple leverage multiple defined as
total assets based on banks published accounts to shareholders claims (note a discontinuity
due to introduction of IFRS accounting standards in 2005, which tends to increase leverage
multiples thereafter). Data exclude Northern Rock/Virgin Money from 2008. The last data
point in this series is at end-2011.
(b) The Basel III leverage multiple, from end-2011 onwards, is calculated as aggregate leverage
ratio exposure, according to the proposed Basel III definition, over aggregate peer group Tier 1
capital. However, Tier 1 capital includes some grandfathered instruments which will
no longer be eligible after the full transition to Basel III in 2019. The Basel III sample includes
Barclays, Co-operative Bank, HSBC, Lloyds Banking Group, Nationwide, Royal Bank of
Scotland, and Santander UK. Last data point is June 2013.
(c) The Basel III leverage multiple series does not include adjustments to capital as discussed by
the FPC and PRA earlier this year.
(1) See Nixon and Rehlon (2013).
(2) For a primer on bank capital as a buffer to absorb losses, see Farag, Harland and
Nixon (2013) on pages 20115 of this edition of the Bulletin.
(3) The weighted average simple leverage multiple (shown in orange) differs from the
Basel III multiple (shown in red) due to the latter using a narrower definition of
capital, a Basel III definition of exposures and a different sample of banks.
Topical articles Macroprudential policy at the Bank of England 195
mortgage lending. As these sources of funding dried up, banks
liquidity came under pressure, with some forced to make fire
sales of assets to meet redemptions. Investors were uncertain
whose difficulties were fundamental. As credit conditions
tightened and economic activity slowed, asset prices fell and
defaults rose. Eventually the spotlight turned to whether
banks were adequately capitalised. As confidence withered,
liquidity seized up. Lacking adequate resolution regimes, the
authorities ended up matching liquidity support with taxpayer
solvency support.
Powers of the FPC
One way that the FPC can mitigate threats to the resilience of
the financial system is by raising awareness of systemic risks
among financial market participants. The FPC is required to
publish a Financial Stability Report twice a year which must
identify key threats to the stability of the UK financial system.
At times, simply warning about risks may be sufficient to
catalyse action within the private sector to reduce
vulnerabilities. But experience from before the crisis showed
that warnings alone are not always enough.
(1)
The new legislation gives the FPC two main types of power:
Recommendations and Directions. EU law provides the
overarching framework within which the FPC can use these
powers. For banks, two key elements of EU legislation are the
Capital Requirements Regulation and the Capital
Requirements Directive IV, which are due to come into force in
January 2014. While the EU regulation is directly applicable or
maximum harmonised meaning that it restricts the scope
for national variation in regulatory rules some national
flexibility is permitted. For example, in addition to the
countercyclical buffer, a range of other tools are identified
within a so-called macroprudential carve out and can be set
at a national level. For tools within that carve out, if the
relevant national authority considers it needs to take action, it
must notify various EU bodies of that fact and submit evidence
and reasoning for taking the proposed measure. Once that
process is complete, and provided the proposed action is not
rejected by the European Council based on opinions of the
other EU bodies, the measure can be introduced.
In seeking to meet its objectives, the FPC is not allowed to take
actions that would in its view be likely to have a significant
adverse effect on the capacity of the financial sector to
contribute to the growth of the economy in the medium or
long term. It must also consider whether any adverse effects
of its actions on financial institutions or activities are
proportionate to the benefits. Generally, the FPC must also
explain its reasons for taking action and provide, where
practicable, an estimate of the costs and benefits that would
arise from compliance. It must also, so far as is possible while
complying with its objectives, seek to avoid prejudicing the
PRA and FCAs respective objectives.
Powers of Recommendation
Under its power of Recommendation the FPC can ask the PRA
and FCA to take measures to mitigate risks. Such
Recommendations can cover any aspect of the activities of the
regulators but cannot relate to a specified individual regulated
entity. The FPC can also make Recommendations to the PRA
and FCA on a comply or explain basis in which case, the
regulators are required to act as soon as reasonably practical.
If one of these regulators were to decide not to implement a
Recommendation, it must explain the reasons for not doing so.
The FPC can also make Recommendations to other bodies,
though not on a comply or explain basis, so there is not a
statutory obligation on the recipient to respond. For example,
it could issue a Recommendation to the Bank of England in
relation to the provision of liquidity to financial institutions
(but not to a particular financial institution) or with regard to
its oversight of payments systems, settlement systems and
clearing houses. The FPC can also make Recommendations to
other bodies, for example to the Financial Reporting Council or
industry representative bodies, such as the British Bankers
Association.
The FPC can give Recommendations to HM Treasury, including
over the scope of activities regulated under the Financial
Markets and Services Act 2000. Developments in the structure
of the financial system can leave regulatory rules out of date.
For example, financial market participants can find ways to
avoid regulatory rules, which may lead to risks shifting into
new, hitherto unregulated areas. The job of microprudential
bodies is to focus on risks to specific regulated institutions.
The FPC can look more broadly at the emergence of risks
across the system as it evolves and recommend changes to
regulation that are needed to maintain stability. That could
include a change to the regulatory perimeter including the
division between regulated and unregulated activities as well
as the split of responsibilities between the FCA and PRA.
Powers of Direction
The FPC has a distinct set of powers to give Directions to the
PRA and FCA to deploy specific macroprudential tools that are
prescribed by HM Treasury, and approved by Parliament, for
these purposes. To date, HM Treasury has given the FPC a
power of Direction over sectoral capital requirements (SCRs).
The FPC will also be given a power to set the countercyclical
capital buffer (CCB) under new EU legislation.
(2)
For each of its powers of Direction, the FPC must prepare,
publish and maintain a written statement of the general policy
that it proposes to follow in relation to the exercise of its
(1) The limits of warnings alone are discussed in a speech by Mervyn King, see
King (2009).
(2) The countercyclical buffer is part of the Basel III reforms implemented in EU law via
the Capital Requirements Directive IV and Regulation (CRD IV/CRR), which also
include capital conservation and systemic risk buffers.
196 Quarterly Bulletin 2013 Q3
powers. The interim FPC published a draft policy statement
relating to these two prospective Direction powers over capital
requirements in January 2013.
(1)
This will be updated and
reissued by the statutory FPC.
The Government has also stated its intention to provide the
FPC with a Direction power over a time-varying leverage ratio
tool, although this will come into effect no earlier than 2018
and subject to a review in 2017 to assess progress on
international standards. The FPC can at any time make a
Recommendation to HM Treasury for its consideration if the
Committee believes it needs an additional power of Direction.
Countercyclical capital buffers and sectoral capital
requirements
The CCB and SCR tools both focus on banks capital buffers.
The more a bank uses capital such as equity to finance
itself, the more it is able to absorb unexpected losses on its
assets, without failing or needing to scale back on new
lending.
(2)
As risks evolve over the cycle, varying the settings of
these tools and, therefore, banks overall capital
requirements can reduce the chances of financial crises
emerging by making banks better able to cope with
unexpected losses.
(3)
The CCB tool will allow the FPC to change capital
requirements above normal microprudential standards in
relation to all loans and exposures of banks to borrowers in the
United Kingdom. Authorities abroad will also determine
whether banks are required to have a CCB against foreign
exposures.
The SCR tool is more targeted and allows the FPC to change
capital requirements on exposures to specific sectors judged to
pose a risk to the system as a whole. The FPC is able to adjust
SCRs for banks exposures to three broad sectors, namely
residential property (including mortgages), commercial
property and other parts of the financial sector. In addition,
SCRs can be adjusted at a more granular level, for example on
mortgages with high loan to value or loan to income ratios at
origination. The CCB and SCR tools can be applied to all
UK-incorporated banks, building societies and large investment
firms (for example, broker-dealers).
The use of these tools can improve the ability of the financial
system to withstand shocks. When the FPC judges that
current and future threats to financial stability are low, the
CCB applied to UK exposures and SCRs will be set to zero. In
this case, banks will need to meet simply their normal,
microprudential capital requirements. When threats to
stability emerge, the FPC can raise the CCB or SCRs, requiring
banks to have a larger capital buffer which can then be used to
absorb unexpected losses when the cycle turns.
The tools may also affect the resilience of the financial system
indirectly through effects on the price and availability of credit.
These effects are likely to vary over time and according to the
state of the economy.
(4)
For example, in periods where there
are concerns about the strength of financial institutions, both
resilience and lending can be supported by recommending that
banks raise capital. For those banks that are perceived by the
market to be inadequately capitalised, official action to
increase their equity capital will boost resilience and that is
likely to reduce the cost of their funding, which will tend to
improve credit availability.
In an environment where market participants perceive risks to
the financial system to be small, banks may be able to borrow
at a rate that is relatively insensitive to how much capital they
have. In that case, if the FPC were to judge that the risks to
overall financial stability were greater than believed by the
market and hence instigated an increase in capital
requirements, banks cost of funding may rise. This might lead
to a tightening in credit conditions facing households,
companies and financial intermediaries, helping to arrest the
build-up of vulnerabilities created by an overextension of credit
and thereby boost banks resilience.
When threats to resilience are judged to have receded and
banks capital buffers are judged to be more than sufficient to
absorb future unexpected losses in the event of stressed
economic or financial conditions, previously accumulated
macroprudential capital buffers (the CCB or SCRs) might be
reduced.
Other FPC responsibilities
In addition to using its powers of Recommendation and
Direction, the FPC can influence financial system resilience by
giving advice. It is consulted on a range of issues by other
bodies. For example, the Banks Court of Directors is required
to consult the FPC on the Banks overall financial stability
strategy. The Bank also seeks the views of the FPC on
developments in its Sterling Monetary Framework under a
protocol agreed in May 2013.
(5)
In April 2013, the Chancellor
announced a Help to Buy scheme that will run for three years.
Should the Government be considering an extension of the
scheme at that time, the FPC would be asked for advice on the
impact on systemic risks.
The Monetary Policy Committee (MPC) is also seeking the
advice of the FPC as part of its new framework for forward
guidance. The FPC is asked to alert the MPC if the stance of
monetary policy poses a significant threat to financial stability
(1) See Bank of England (2013a).
(2) Note that in addition to unexpected losses, banks also expect some degree of losses
to crystallise on loans (which will vary depending on the type of loan, credit rating of
the borrower, and so on). Banks lending practices should account for these expected
losses, for example via the price of new lending and provisions. See, for example,
Button, Pezzini and Rossiter (2010).
(3) This section draws on The Financial Policy Committees powers to supplement capital
requirements, see Bank of England (2013a).
(4) See Tucker (2013).
(5) See Bank of England (2013b).
Topical articles Macroprudential policy at the Bank of England 197
that cannot be contained by the substantial range of
mitigating policy actions available to the FPC, the FCA and the
PRA in a way consistent with their objectives. More broadly,
in its remits to the MPC and FPC, HM Treasury asked the
Committees to explain how they consider the policies of
each other in discharging their responsibilities.
(1)
Policy co-ordination is a central feature of the new
arrangements, and one of the reasons for overlapping
memberships of the FPC with other policy bodies (Figure 1).
The FPC is also required to have regard to the
United Kingdoms international obligations. To that end, it
expects to co-operate closely with overseas macroprudential
bodies, including the ESRB. Proposed new EU legislation sets
out formal co-ordination arrangements on the CCB within
the European Economic Area: overseas regulators will apply
the CCB chosen by the FPC to their banks UK exposures,
while the relevant overseas regulators will normally set the
CCB in relation to UK banks overseas exposures. SCRs will be
subject to different co-ordination arrangements under the
EU legislation.
How do FPC rounds work?
The composition of the FPC and its location in the central bank
means it is able to draw on a diverse experience and a wide
range of information in detecting and assessing threats to
financial stability.
The FPC has ten voting members: the Governor (who chairs
the FPC); the Deputy Governors for Financial Stability,
Monetary Policy and Prudential Regulation; the Executive
Director of the Bank of England for Financial Stability; the
Chief Executive Officer of the FCA; and four external members
(Figure 1). In addition, a representative of HM Treasury is a
non-voting member of the FPC. The FPC therefore has direct
insights from MPC members into developments in the
macroeconomy and in its interaction with the financial system.
Membership from the microprudential regulators the PRA
and FCA ensures that supervisory intelligence relevant to
financial stability is brought into the FPCs discussions.
External members add to the diversity of experience and
information available to the FPC. The Banks Executive
Director for Markets routinely attends FPC meetings so as to
offer insights on financial markets.
The processes supporting the FPC, including the format of
meetings in which members discuss risks to stability and
possible policy responses, are likely to evolve over time. But
experience over the past two years of the interim FPC can
provide some insights on the broad shape of regular rounds.
The FPC has a pre-announced quarterly schedule, with the
dates of formal policy meetings, published on the Banks
website.
(2)
A typical quarterly cycle contains four elements:
briefing on financial system developments;
focused discussions of key issues germane to UK financial
stability and potential areas for macroprudential policy
interventions;
a policy meeting, culminating in decisions about
macroprudential policy, for example to make Directions
and/or Recommendations; and
communication of the policy decision, including via the FPC
Record and, twice a year, the Financial Stability Report (FSR).
The Committee is supported in these areas by a broad range of
staff. A dedicated FPC Secretariat, housed within the Bank, is
responsible for co-ordinating the wide-ranging inputs to the
FPC, as well as supporting the Committees outputs, including
some of its public communications. Figure 2 sets out the cycle
for a typical quarterly FPC round. The various components of
the process are described in more detail below.
Briefing
Briefing papers produced by staff, including analytical work
and market and supervisory intelligence, are circulated to the
FPC throughout each quarter. Some papers are requested
directly by the FPC, while others are provided on the initiative
of staff. The information covers a very broad spectrum of
issues and varies in detail depending on the topic.
At one extreme, the Committee receives short, factual updates
on breaking news: for example, latest developments in
vulnerable euro-area economies. At the other extreme the FPC
MPC
Executive Director for
Monetary Analysis
Executive Director for Markets
(b)

Four external members
HM Treasury observer
Governor
Deputy Governor for
Financial Stability

Deputy Governor for
Monetary Policy
PRA Board
Four non-executives
Deputy Governor for
Prudential Regulation
Chief Executive of
the FCA
FPC
Executive Director for
Financial Stability
Four external members
HM Treasury
representative
(c)
Figure 1 Membership of Bank of England policy committees
(a)
(a) Members shown in red are not part of the Banks Executive Team.
(b) The Executive Director for Markets will also routinely attend FPC meetings.
(c) Non-voting member of the FPC.
(1) See Remit for the Monetary Policy Committee, March 2013, available at
www.gov.uk/government/uploads/system/uploads/attachment_data/file/221566/
chx_letter_to_boe_monetary_policy_framework_200313.pdf and Remit and
recommendations for the Financial Policy Committee April 2013, available at
www.gov.uk/government/uploads/system/uploads/attachment_data/file/207473/
remit_fpc_290413.pdf.
(2) See www.bankofengland.co.uk/financialstability/Pages/fpc/meetings/default.aspx.
198 Quarterly Bulletin 2013 Q3
may receive in-depth reports, for example on loan forbearance
by banks. The most common form of briefing tends to be short
notes that examine recent economic or financial developments
and use analytical techniques or intelligence to answer specific
questions. For example, what are the key risks to UK financial
stability arising from emerging market economies? Or to what
extent is there evidence of exuberance and excessive search
for yield in financial markets?
A substantial proportion of the analytical support for the FPCs
activities comes from staff in the Banks Financial Stability
Directorate. Market intelligence, supervisory insights and
analysis from staff in other parts of the Bank and FCA, and on
occasion HM Treasury, are also critical inputs into the FPCs
activities. The Banks market intelligence (MI) is drawn from an
extensive, growing, and internationally diverse contact base
including banks, dealers, brokers, asset managers, pension
funds, insurance companies, hedge funds, private equity funds
and infrastructure providers. It covers a wide range of markets,
from vanilla instruments such as gilts, equities, commodities,
bonds and repo through to complex derivative products. It
helps the FPC to understand better the qualitative behavioural
patterns that underlie quantitative movements in financial
variables and to spot new developments or risks that might
introduce potential vulnerabilities into parts of the financial
system.
Supervisory intelligence and other briefing are provided by
staff from the PRA and the FCA. This allows the Committee to
draw together granular supervisory insights to form a better
understanding of developments across the system as a whole.
A focal point for the quarterly FPC briefings is a set of
presentations by senior Bank (including PRA) and FCA staff on
key developments. Agendas vary from briefing to briefing, but
typically include:
a summary of MI from the Banks Markets Directorate (for
example, risks arising from the search for yield);
presentations by the Banks Financial Stability Directorate on
domestic and international macroeconomic and capital
market risks (for example, risks of spillovers from stress in
parts of the euro area, or signs of emerging threats to
stability from beyond the regulatory boundary), resilience of
the financial system (for example, risks from weak UK bank
profitability) and non-cyclical issues affecting system
resilience (such as banks risk-weight methodologies or
risk management practices at central counterparties); and
a summary of supervisory intelligence from the PRA (for
example, themes from banks capital and liquidity planning);
and
a summary of key issues from the FCA (for example, on
developments in relevant products, markets or among firms
regulated by the FCA).
As part of this briefing, the FPC will consider a wide range of
information, alongside economic and financial indicators. No
single set of indicators can ever provide a perfect guide to
systemic risks, or to appropriate policy responses, due to the
complexity of financial interlinkages, the tendency for the
financial system to evolve over time and time lags before risks
become apparent. The FPC also monitors a specific set of
indicators as a core input to the use of the CCB and SCR.
These include measures relating to the size and composition of
balance sheets within the financial system and among
borrowers, and information on terms and conditions in
financial markets. They are published in each FSR and on the
Banks website.
(1)
The FPC sees attractions in synthesising information from a
broad range of indicators via a stress-testing framework that
can explore the resilience of the financial system in various
adverse scenarios. To that end, it has asked the Bank, including
the PRA, to develop a framework for regular stress testing of
the UK banking system. Results from proposed future
stress-test exercises will be discussed by the FPC.
There is some overlap between the briefing received by the
FPC and the MPC. As noted above, FPC members who sit on
the MPC are able to incorporate the insights that have been
(1) See, for example, the June 2013 Financial Stability Report, available at
www.bankofengland.co.uk/publications/Documents/fsr/2013/fsrfull1306.pdf.
Figure 2 A typical FPC quarterly cycle
Brieng
Analysis and research from Bank
economists about risks to nancial
stability
Market intelligence from the Banks
network of nancial market contacts
Supervisory intelligence and analysis
from the PRA and FCA
Assessment of the impact of existing
FPC policies
FPC issues meetings
FPC assesses and discusses the major
risks to UK nancial stability
Discussion of potential macroprudential
policy actions that might be required
Communication
Policy set out in FPC statement/FSR
and communicated to addressees of
Recommendations and/or Directions
Details of FPC deliberations set out in
the FPC Record
FSR sets out assessment of, and outlook
for, the nancial system
Analysis promulgated including via the
Banks Agents and market contacts
FPC policy meeting
FPC discusses and decides any
macroprudential policy measures
FPC reviews the setting of Direction
instruments (CCB and SCR)
FPC reviews the status of existing
policies
Topical articles Macroprudential policy at the Bank of England 199
provided to them as monetary policy makers into
macroprudential policy discussions. In addition, analysis on
issues such as credit conditions, the banking system and
financial market developments is produced jointly by staff
across the Bank, and circulated to both Committees.
Furthermore, FPC members have the opportunity to observe
the monthly briefing session held for the MPC, and vice versa.
PRA Board independent members can also attend these two
briefing meetings.
Issues discussions
Issues discussions are an opportunity for the Committee
to assess the major risks to UK financial stability and discuss
in more detail key areas of concern. Staff prepare briefing
and analysis to support FPC discussion of potential
macroprudential policy responses. The Committee also
considers a range of issues relevant to its statutory
responsibilities, including the effect of potential policy
interventions on resilience and the economy. These
deliberations guide staff in preparing any further material
to support the Committees subsequent policy decisions.
The FPC is updated by staff, or members of the Committee, on
progress in implementing previously issued policy decisions.
Policy meeting
New macroprudential policy measures that may be required to
mitigate risks to financial stability are discussed and, where
appropriate, agreed by the FPC at the policy meeting. Aside
from FPC members, only a few Bank staff are present,
including a Secretariat with responsibility for producing the
Record of the discussion.
The legislation sets out that the Chair of the FPC the
Governor or, if the Governor is not present, the Banks Deputy
Governor for Financial Stability should seek to ensure that
macroprudential policy decisions of the FPC on new
Recommendations or Directions are reached by consensus
wherever possible. Where that is not possible a vote is taken
by the Committee.
At the policy meeting, the FPC also reviews formally the status
of previous policy Recommendations or Directions. The
Committee assesses actions taken in response, and decides
whether to withdraw the policy measure if it has been
successfully implemented or is no longer required to mitigate
risks to UK financial stability or to retain it as being in
progress.
Where it judges that disclosure is against the public interest,
the FPC is able under section 9V of the Act, to delay disclosure
and make private Recommendations. But the Committee is
required to review any private Recommendations that it may
have made previously, and to consider whether publication is
still against the public interest.
Accountability
The FPC policy decision, including any new Directions and/or
Recommendations that have been agreed, are communicated
to those to whom the action falls for example, the PRA or
FCA. The policy decision is communicated to the public in
either a short statement typically released a week after the
policy meeting in the first and third quarters of the year
or in the FSR in Q2 and Q4.
Under the Act, the FSR must include: the FPCs view of the
stability of the UK financial system at the time of the Reports
preparation; an assessment of the developments that have
influenced the current position of the UK financial system; the
strengths and weaknesses of the UK financial system; risks to
the stability of the UK financial system; and the Committees
view of the outlook for the stability of the UK financial system.
It also reports the Committees view of progress against
previous Recommendations and Directions, as well as
reporting any new policy actions taken to reduce and mitigate
risks to stability. The FSR is prepared by the FPC, with a draft
produced by Bank staff. The FPC provides comments and
formally agrees the text at a special meeting prior to
publication.
The key messages and policy actions in the FSR are conveyed
to a wide audience. A press conference is held when the FSR is
published. Participants in financial markets including the
Banks network of market intelligence contacts are also
informed of policy decisions when the FSR is published. FPC
members and other Bank staff hold regular meetings with
financial market participants where FPC decisions are
discussed. The Banks network of Agents across the
United Kingdom is able to promulgate and discuss messages
with business contacts, often supported by FPC members or
other Bank staff.
A formal Record of the policy meeting is published at present
around a fortnight after the corresponding meeting. It must
specify any decisions taken at the meeting and must set out, in
relation to each decision, a summary of the Committees
deliberations.
(1)
FPC members also appear regularly before Members of
Parliament at Treasury Committee hearings, where they are
required to explain their assessment of risks and policy actions.
The Treasury Committee has also held appointment hearings
for members.
The procedures followed by the FPC are kept under review by a
committee of the Court of Directors of the Bank, the Oversight
Committee established under the Act. It may appoint persons
(1) Although, as previously discussed, the Act gives the FPC the right to delay disclosure
of private Recommendations where it judges immediate publication to be against the
public interest.
200 Quarterly Bulletin 2013 Q3
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to conduct specific performance reviews, which would be
published unless the Banks Court judges that publication at a
particular time is against the public interest.
Conclusion
In the period leading up to the crisis insufficient attention was
paid to tackling risks and vulnerabilities across the financial
system as a whole. The FPC fills that gap by identifying,
monitoring and, crucially, taking action to remove or reduce
systemic risks to the resilience of the financial system. This
article has described the objectives and powers of the FPC. It
has also provided an overview of some of the processes
currently supporting the Committee.