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Stress Testing




Universal Banking Solution System Integration Consulting Business Process Outsourcing
Introduction                                            •   little consideration was given to system-wide
One of the major outcomes of the Credit Crunch              outcomes of tests and particularly the adverse
has been that banks, regulators and the whole               effects that could arise from the behaviour of
financial market have had to question the validity          other firms in markets or via the real economy
and even usefulness of some standard risk                   in response to those stresses.
management systems. Why was it that so many             In addition standards were observed to be
institutions were overextended in the credit            below acceptable practice, with some institutions
boom up until the summer of 2007 and why                having insufficient holdings of liquid assets.
weren’t risk controls flashing appropriate              In addition the age old problem, of banks
warning signs? Given that very few early                cutting corners by funding their portfolios of
warning signals were triggered, what can be             illiquid asset with short-term liabilities. And
done to improve our risk management systems             equally important far too many institutions had
in the future?                                          insufficient detailed information in their cash-flow
                                                        projections and frequently lacked rigorous liquidity
This state of affairs has caused regulators, often
                                                        contingency plans.
pressed by politicians who have had to calm
voters concerns, to look for additional new             Now it is all change – over the past year
approaches for measuring and managing                   the regulators have devised a much more
financial risk. Clearly there is no magic bullet        comprehensive regime – will it work? For bank
that can warn for every eventuality but equally         treasurers this new stress testing regime really
relying on ever more sophisticated manipulation         means liquidity risk (though of course it can
of data from the past doesn’t always seem to            equally be deployed to assess credit exposures,
work. One area that almost immediately attracted        market risk and operational risk). What are the
the regulators was increasing the use of stress         challenges? How can the best approaches be
testing – this in many ways is not a new idea           employed, what new skills are needed, will there
but perhaps more sophisticated approaches               be software requirements and what exactly do
could be used to plug some of the gaps in the           the regulators expect?
existing risk systems? Certainly the Turner             Liquidity Risk Drivers
Review (which examined the causes of the credit
                                                        Starting with regulatory demands, the key change
crunch, the impact on the financial sector and
                                                        has been to identify ten Liquidity Risk Drivers,
possible remedies for the future) in London took
                                                        and critically banks have to demonstrate how
this view and this has been embraced by the
                                                        these are incorporated into two specific types of
major regulators around the globe. Whilst some
                                                        scenario; these being the idiosyncratic scenario
stress testing had been conducted in the past
                                                        plans and the market wide scenario plans. The
it had been rather limited in its scope and
                                                        idiosyncratic plans test for a liquidity event at
had clearly not helped in identifying problems
                                                        the individual institution, and the market wide
for many major banks during the unfolding
                                                        plan is to see how an overall market event
credit crisis.
                                                        would impact an institution’s liquidity. The idea is
To quote the FSA in London (whose thinking is in        that from these scenarios banks can model their
line with the major regulators)                         liquidity buffers and then have to demonstrate
                                                        that such buffers are in place and meet the
Deficient stress testing was identified as one of the
                                                        continuous requirements regarding their liquidity,
failures that contributed to the current financial
                                                        and credit worthiness (in broad terms these
crisis in the following ways:
                                                        buffers have to be cash, balances at central
•   Firms devoted insufficient resources to stress      banks and government securities issued by
    testing before the crisis;                          major countries as listed by the regulators).

•   Firms and regulators failed to test against         These plans also come with both quantitive and
    sufficiently extreme macroeconomic                  qualitive assessments. Naturally enough the
    outcomes; and                                       former is well suited for developing appropriate




                                                                                               Stress Testing
software but the latter takes banks into the            •   External funding sources will have to be
possibly unfamiliar territory of scenario planning.         continuously available to all the bank’s
Here judgements and methodologies are much                  internal risk and pricing applications.
more fluid and a different management approach
is needed. This will need new skills for many
bankers – and it may well be that staff are             All of this means that connectivity to markets
recruited from other sectors (e.g. the Oil              where the assets in question are traded or valued
Industry, Chemicals and Pharmaceuticals) where          is even more critical than currently. Pricing and
such planning techniques are well understood            valuation data has to be captured and updated
and established.                                        on a continuous basis – and across what may be
                                                        a plethora of existing legacy systems. Of course
There are also spin off business effects from           much of this work is already done, but now it will
this new liquidity framework. With a much closer        be under very intense scrutiny with the threat of
focus on liquidity and crucially its true cost,         punishing restrictions and controls imposed by
there will now be strong incentives for firms           regulators if they feel a bank has not done its
to correctly price liquidity across business            homework properly.
units. This will help strengthen the commercial         Finally the real issue surrounding stress testing
viability of many firms as previously profitable        is not just about data, systems and accurate
transactions and positions may be rather less           liquidity provision and pricing – it is about senior
attractive when liquidity costs are truly accounted     management’s ability to create and control the
for – so weaker deals are more likely to be rejected.   complex systems required. This is no mean
                                                        undertaking – the challenges range from new
Another area that this regime will shed light on
                                                        specialist systems and IT upgrades, through to
is the often complex liquidity issues regarding
                                                        even better data and also how to blend in the
cross border relationships within firms, the
                                                        “soft” tools such as scenario planning and
regulators now expect stress tests to examine
                                                        reverse stress testing routines.
any effects of poor liquidity across borders and
jurisdictions. This has been shown by the               Future Challenges
collapse of Lehman Brothers to be an area full
of potential problems, some of which could              Clearly the advent of more sophisticated stress
prove disastrous if proper liquidity buffers and        testing is a positive step – here are some of the
contingencies are not in place.                         major challenges and issues that could well
                                                        emerge in this area in the future:
Action Time for Banks
All of the above generates a huge amount of             •   Stress testing is not the new panacea and
work for the banks; consider the following issues           has to be used in careful conjunction with
firms will need data and systems for:                       other tools. The key message is that stress
•   Calculating the cost of funding across                  testing (and the so called reverse method)
    different markets, aggregating the data and             are complements to existing tools. It
    integrating internal systems to correctly               also presupposes a great deal of data
    apportion those costs.                                  integration across multiple locations and
•   Accurate and timely data to create correct              timeframes – these are significant business
    risk-adjusted valuations for balance sheet              and IT challenges.
    items – and to be able to calculate liquidity
    buffers on a continuous basis.                      •   However “reverse” stress testing may prove
                                                            to be a disappointment to regulators – it is
•   Banks will have to be able to monitor                   hard to believe institutions will devote more
    accurately their cost of capital over multiple          than the minimum regulatory requirement on
    time periods.                                           planning their own funeral.




                                                                                               Stress Testing
•   It is easy to make bad mistakes in scenario      Further Reading
    planning – care and the use of tried and
    tested methods from other industries will        For those interested in understanding how the
    be needed. It may well be that financial         wider topics of futures planning and scenarios
    institutions (and perhaps the regulators)        are conducted in other industries take a look at:
    will need to draw on planning talent from        The Art of the Long View – Planning for the Future
    entirely new sectors so that they get the most   in an Uncertain World by Peter Schwartz
    from the process.
                                                     The Living Company by Arie de Gues
•   Stress Testing is not just another compliance
    issue – if managed correctly it can help
    improve the business going forward. It is
    also not a one off exercise – building a
    dynamic and continuous scenario planning
    process is the secret to getting the most
    from the process.




                                                                                          Stress Testing

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Stress Testing

  • 1. Stress Testing Universal Banking Solution System Integration Consulting Business Process Outsourcing
  • 2. Introduction • little consideration was given to system-wide One of the major outcomes of the Credit Crunch outcomes of tests and particularly the adverse has been that banks, regulators and the whole effects that could arise from the behaviour of financial market have had to question the validity other firms in markets or via the real economy and even usefulness of some standard risk in response to those stresses. management systems. Why was it that so many In addition standards were observed to be institutions were overextended in the credit below acceptable practice, with some institutions boom up until the summer of 2007 and why having insufficient holdings of liquid assets. weren’t risk controls flashing appropriate In addition the age old problem, of banks warning signs? Given that very few early cutting corners by funding their portfolios of warning signals were triggered, what can be illiquid asset with short-term liabilities. And done to improve our risk management systems equally important far too many institutions had in the future? insufficient detailed information in their cash-flow projections and frequently lacked rigorous liquidity This state of affairs has caused regulators, often contingency plans. pressed by politicians who have had to calm voters concerns, to look for additional new Now it is all change – over the past year approaches for measuring and managing the regulators have devised a much more financial risk. Clearly there is no magic bullet comprehensive regime – will it work? For bank that can warn for every eventuality but equally treasurers this new stress testing regime really relying on ever more sophisticated manipulation means liquidity risk (though of course it can of data from the past doesn’t always seem to equally be deployed to assess credit exposures, work. One area that almost immediately attracted market risk and operational risk). What are the the regulators was increasing the use of stress challenges? How can the best approaches be testing – this in many ways is not a new idea employed, what new skills are needed, will there but perhaps more sophisticated approaches be software requirements and what exactly do could be used to plug some of the gaps in the the regulators expect? existing risk systems? Certainly the Turner Liquidity Risk Drivers Review (which examined the causes of the credit Starting with regulatory demands, the key change crunch, the impact on the financial sector and has been to identify ten Liquidity Risk Drivers, possible remedies for the future) in London took and critically banks have to demonstrate how this view and this has been embraced by the these are incorporated into two specific types of major regulators around the globe. Whilst some scenario; these being the idiosyncratic scenario stress testing had been conducted in the past plans and the market wide scenario plans. The it had been rather limited in its scope and idiosyncratic plans test for a liquidity event at had clearly not helped in identifying problems the individual institution, and the market wide for many major banks during the unfolding plan is to see how an overall market event credit crisis. would impact an institution’s liquidity. The idea is To quote the FSA in London (whose thinking is in that from these scenarios banks can model their line with the major regulators) liquidity buffers and then have to demonstrate that such buffers are in place and meet the Deficient stress testing was identified as one of the continuous requirements regarding their liquidity, failures that contributed to the current financial and credit worthiness (in broad terms these crisis in the following ways: buffers have to be cash, balances at central • Firms devoted insufficient resources to stress banks and government securities issued by testing before the crisis; major countries as listed by the regulators). • Firms and regulators failed to test against These plans also come with both quantitive and sufficiently extreme macroeconomic qualitive assessments. Naturally enough the outcomes; and former is well suited for developing appropriate Stress Testing
  • 3. software but the latter takes banks into the • External funding sources will have to be possibly unfamiliar territory of scenario planning. continuously available to all the bank’s Here judgements and methodologies are much internal risk and pricing applications. more fluid and a different management approach is needed. This will need new skills for many bankers – and it may well be that staff are All of this means that connectivity to markets recruited from other sectors (e.g. the Oil where the assets in question are traded or valued Industry, Chemicals and Pharmaceuticals) where is even more critical than currently. Pricing and such planning techniques are well understood valuation data has to be captured and updated and established. on a continuous basis – and across what may be a plethora of existing legacy systems. Of course There are also spin off business effects from much of this work is already done, but now it will this new liquidity framework. With a much closer be under very intense scrutiny with the threat of focus on liquidity and crucially its true cost, punishing restrictions and controls imposed by there will now be strong incentives for firms regulators if they feel a bank has not done its to correctly price liquidity across business homework properly. units. This will help strengthen the commercial Finally the real issue surrounding stress testing viability of many firms as previously profitable is not just about data, systems and accurate transactions and positions may be rather less liquidity provision and pricing – it is about senior attractive when liquidity costs are truly accounted management’s ability to create and control the for – so weaker deals are more likely to be rejected. complex systems required. This is no mean undertaking – the challenges range from new Another area that this regime will shed light on specialist systems and IT upgrades, through to is the often complex liquidity issues regarding even better data and also how to blend in the cross border relationships within firms, the “soft” tools such as scenario planning and regulators now expect stress tests to examine reverse stress testing routines. any effects of poor liquidity across borders and jurisdictions. This has been shown by the Future Challenges collapse of Lehman Brothers to be an area full of potential problems, some of which could Clearly the advent of more sophisticated stress prove disastrous if proper liquidity buffers and testing is a positive step – here are some of the contingencies are not in place. major challenges and issues that could well emerge in this area in the future: Action Time for Banks All of the above generates a huge amount of • Stress testing is not the new panacea and work for the banks; consider the following issues has to be used in careful conjunction with firms will need data and systems for: other tools. The key message is that stress • Calculating the cost of funding across testing (and the so called reverse method) different markets, aggregating the data and are complements to existing tools. It integrating internal systems to correctly also presupposes a great deal of data apportion those costs. integration across multiple locations and • Accurate and timely data to create correct timeframes – these are significant business risk-adjusted valuations for balance sheet and IT challenges. items – and to be able to calculate liquidity buffers on a continuous basis. • However “reverse” stress testing may prove to be a disappointment to regulators – it is • Banks will have to be able to monitor hard to believe institutions will devote more accurately their cost of capital over multiple than the minimum regulatory requirement on time periods. planning their own funeral. Stress Testing
  • 4. It is easy to make bad mistakes in scenario Further Reading planning – care and the use of tried and tested methods from other industries will For those interested in understanding how the be needed. It may well be that financial wider topics of futures planning and scenarios institutions (and perhaps the regulators) are conducted in other industries take a look at: will need to draw on planning talent from The Art of the Long View – Planning for the Future entirely new sectors so that they get the most in an Uncertain World by Peter Schwartz from the process. The Living Company by Arie de Gues • Stress Testing is not just another compliance issue – if managed correctly it can help improve the business going forward. It is also not a one off exercise – building a dynamic and continuous scenario planning process is the secret to getting the most from the process. Stress Testing