Reserve Bank DTIs and the cost of crises

I was late getting round to reading the whole of the Reserve Bank’s consultation document, that backs its bid to persuade the Minister of Finance to agree to authorise them (at some future time) to impose debt to income limits on banks’ mortgage lending.   I’d heard from some people who’d read it that it wasn’t very good, but even so I was surprised how weak the document making the Bank’s case is.  This post isn’t a substantive response to the body of the document, which will probably come in a few posts over the month or so until submissions close.  Today I wanted to focus on just one assumption they make.

The Minister of Finance insisted that the Reserve Bank include a cost-benefit analysis in the consultation document, and one that was a bit more than the usual Reserve Bank effort (an unweighted list of unquantified pros and cons).    It is hard to do so when they aren’t wanting to impose the control right now, but they made a valiant effort.   The value in these things is not in the precise bottom line number (inevitably wrong), but in forcing regulators to spell out their assumptions.

In their cost-benefit analysis, the Reserve Bank assumes that a DTI type instrument can reduce –  by a third –  the risk of a financial crisis.    And they assume that (a) financial crises are really expensive (lost GDP) and (b) that in addition to reducing the probability of a financial crises, a DTI instrument can reduce –  by a quarter –  the severity (again, lost GDP) of such a crisis.      If all three assumptions aren’t correct –  if, say, a DTI instrument could reduce the probability but not the cost, or vice versa, or if a plausible crisis wasn’t as costly as the Bank assumed –  the expected net benefits shown in the paper would simply evaporate.

So how costly are financial crises (especially one concentrated in developments around housing) in moderately well-governed market economies which (a) have their own monetary policy, and (b) haven’t run up against hard fiscal constraints?    The Reserve Bank assumes a cumulative loss of 20 per cent (of a single year’s GDP) –  and they describe that as “conservative”, meaning towards the lower end of a plausible range.

The honest answer is that we don’t really know.   The relevant historical sample (of such crises) is exceptionally small.     And even when a financial crisis happens, it is hard to disentangle the contribution of the financial crisis itself from adjustments that would have happened anyway.

Of course, there is the United States in the last decade –  the case that grabbed everyone’s attention at the time.   Plenty of writers since have described it as ‘the worst financial crisis since the Great Depression” –  in some respects (narrow financial system stresses) one could mount an argument that the recent episode was worse.    The Reserve Bank constantly like to invoke Ireland, but while that case study might be useful for some purposes, it isn’t for this one.   Ireland gave up its own monetary policy when it joined the euro, and so had little or no scope for any stabilising macro policy when the crisis hit.

So lets have a look at how things unfolded in the United States.     They had a nasty recession but they weren’t alone in that.  So one benchmark might be to look at how the US relative to, say, other moderately well-governed floating exchange rate countries, and especially ones that had lots of housing debt and house price inflation but didn’t have a domestic financial crisis.   Australia, New Zealand, Canada, and Norway seemed like a nice subset of such countries.

This chart uses IMF WEO annual data. It shows real GDP per capita for the US normalised to 100 in 2007, the last year before the recession (and before the financial crisis itself intensified).   And it shows the average for the four rising house price non-financial crisis countries on the same basis.

US vs NZ Can etc

Sure enough, the US recession was deeper than that in the average of these other four floating exchange rate countries which –  despite the debt and run-up in house prices –  avoided both housing busts and financial crises.      But the cumulative gap between the two lines (ie adding up the differences across the nine years) is just under 10 per cent, which isn’t even quite half of the “conservative” assumption the Reserve Bank is using.

Of course, even among these four countries there are some quite different experiences: Australia didn’t have a real GDP recession at all, and Norway still hasn’t regained the level of per capita income they had in 2007.  That is why it helps to average across a range of non-crisis countries.

Is it a fair test?   If anything, I think the simple difference between the two lines errs towards overstating the costs of the US financial crisis.  After all, the US ran into the effective lower bound on nominal interest rates.  Standard Taylor-rule prescriptions would have had the Fed cut interest rates a lot more than the 500 basis points they did cut by (a nice chart I have in front of me from the Boston Fed illustrates that in the previous six easing cycles the Fed had cut by an average of more like 800 basis points).    And the US went into the crisis with much less fiscal leeway than our fairly unindebted comparative sample.   And, as it happens, each of the four comparators benefited from average terms of trade in the years since 2007 that were higher than those in the previous half decade or so.    By contrast, the terms of trade for the US have been weaker than they were in the pre-crisis years.

Of course, if I compared Iceland with the four non-crisis countries, I could come out with a number that exceeds the Reserve Bank’s 20 per cent loss estimate.   But the Icelandic crisis (a) wasn’t concentrated on housing, (b) was an order of magnitude more severe (in its own financial system) than the US one, and (c) the Icelandic government ran into severe policy constraints, including exhausting their capacity to borrow.    It is an important case study, but it isn’t the sort of crisis we should be thinking about in contemplating the possible use of DTI controls here.   Arguably, even the US experience is only somewhat enlightening given that an oversupply of houses was a significant element in the US experience.   An oversupply of houses might be fine thing here one day, but it seems unlikely to be an issue here or in other Anglo countries while tight land-use restrictions are in place.  But that is an issue –  not touched on in the Reserve Bank paper – for another day.

If a reasonable “cost of crisis” were, say, a third lower than then Reserve Bank assumes then, on their assumptions about everything else, there are no net benefits from a DTI instrument.

Thoughts prompted by the FSR

I had only a limited number of specific comments to make on the details of the Reserve Bank’s Financial Stability Report released yesterday.  But it is the last such report for the outgoing Governor Graeme Wheeler, and that itself prompts a few other thoughts.

The Bank continues to tout the line that monetary policy in much of the world is “very accommodative” –  relative to what benchmark is never clear –  and yesterday they claimed that

“a sustained period of very accommodative monetary policy has supported the long-awaited recovery in global economic activity”

That seems questionable on multiple counts.  First, the recovery or growth phase has been underway since at least 2009/10.  There have been setbacks and what felt a little like “growth pauses”, and the overall experience has been pretty underwhelming.  But there also isn’t really much sign of that changing for the better.

And since what the Bank calls “very accommodative monetary policy” has been concentrated in the advanced economies, one obvious place to look for upbeat news might be investment spending.  Lower interest rates, all else equal, make investment today more attractive than otherwise.   But here is the IMF data –  and the IMF is the Bank’s standard reference point for comment on the wider world – for investment as a share of GDP in advanced economies.

investment imf

The latest actual data –  for 2016 –  are still below the cyclical lows in the early 2000s.  And if investment isn’t picking up strongly, neither is the IMF picking a slump in savings rates to support an acceleration of demand.

Across the advanced world, there just isn’t much consistent sign of anything very different in the next few years than we’ve had in the past few.  That suggests interest rates are low for a good –  if not fully-explained –  reason, rather than just that monetary policy is “very accommodative”.

At one level, the terminology doesn’t matter very much, but coming from a central bank offering insights on financial stability, it doesn’t suggest that they really have a good sense of what is going on.   They might be in good company on that score, but it isn’t exactly reasssuring.  If you don’t have a good “model”, the prognostications might not be of much value.

I also found it rather surprising that there was almost nothing in the Financial Stability Report  – the major statutory document on financial stability issues, including the Bank’s conduct of its various regulatory responsibilities – on the recently-released report on New Zealand under the IMF’s financial sector assessment programme (FSAP).   It was a major independent report, which seems to have also involved a substantial commitment of resources by the New Zealand authorities (including the Reserve Bank), in some areas it reached conclusions quite different from current policy, and yet it is barely mentioned in the Bank’s own review.  It isn’t because they didn’t have time –  the papers were released to the public three weeks ago, and the Bank will have had them well before that.  Perhaps it isn’t yet time for a definitive responses to all the points, and some of the issues the FSAP reports raise are really for the government rather than the Bank to decide, but…the silence was deafening.   Perhaps the Bank thought the IMF report really wasn’t much use at all, and was simply being polite?   (I would have some sympathy for such a view, and will before long have my own post on some aspects of the report.)

And there was something a little odd in the box the Bank included on “Vulnerability of owner-occupiers to higher mortgage rates“, clearly softening us up for the consultation paper on debt to income ratios.  They argue that

New Zealand is particularly vulnerable to a sharp rise in mortgage rates as the banking system funds a large proportion of its mortgage credit from offshore wholesale markets. The cost of this funding can increase sharply if there is an unexpected increase in global interest rates or a change in investor risk appetite, and banks are likely to pass on the higher funding costs to customers through higher mortgage rates.


But mostly this is just untrue.  The Reserve Bank sets the OCR in New Zealand based on overall inflation pressures in New Zealand.  If funding spreads rise –  as they did in 2008/09 –  and domestic inflation pressures don’t the Reserve Bank can easily offset most or all of the potential impact on retail interest rates by lowering the OCR.    That is what happened in 2008/09.

Of course, retail interest rates can rise, quite materially.  As the Bank points out, new floating mortgages rose from “around 7 per cent to over 10 per cent between early 2004 and 2007”.  Of course, as we used to stress at the time, fixed mortgage rates rose nowhere near that much.  But, more importantly, interest rates here didn’t rise because foreign rates were rising, but because the economy was cyclically strong, unemployment was low and falling, and wage and price inflation were increasing.  Wages rose roughly 20 per cent in that period.

It is fine and good for the Reserve Bank to do these sorts of stress-testing exercises, looking at what happens if interest rates rise to 7 per cent, or 9 per cent.  But in any realistic assessment, those sorts of substantial increases are only remotely likely if the economy is doing really cyclically well.  If jobs are readily available and wages are rising, not many people will be under that much stress even if interest rates rise quite a lot.  And those that are should quite readily be able to sell their house and move on.  It might be painful for them, but it simply isn’t a financial stability event.

There was some good news in the report.  Previous stress tests conducted by the Reserve Bank with the major banks have used very severe adverse macroeconomic shocks (in some respects –  notably the critical unemployment assumptions –  beyond anything ever seen in a modern floating exchange rate country).  Banks came through those tests largely unscathed.  So this time, the Bank did something a bit different.

The most recent regulator-led exercise was a ‘reverse’ stress test completed in late 2016. This test required the largest four New Zealand banks to determine the most plausible scenario that would lead to a breach of a minimum capital requirement. The results highlight that severe risks would need to materialise before this would occur, beyond the sustained macroeconomic downturn assumed in a typical stress test.

It was another way of reaching the same conclusion the previous tests pointed to: our major banks appear to be strong, and well-managed.   The Reserve Bank is quite explicit that the regulatory regime is not a “zero-failure” one –  in a market economy, firms will fail sometimes, and that includes banks  – but with the sorts of loans the banks had on their books late last year, the latest stress test suggests (again) that it would take something almost inconceivable for one of them to fail.

Which does leave one wondering, again, quite what all the fuss has been about in the last few years, with successive rounds of LVR controls, and the forthcoming consultative document in which the Bank tries to persuade us (and more importantly the Minister of Finance) that it should be able to impose debt-to-income limits too.      When it discusses the world economy, the Bank is quite fond of invoking concerns about “policy uncertainty”, but what certainty and stability has it provided in the markets/institutions it regulates in recent years?  And to what end has all the uncertainty been?

The Bank likes to claim that its successive interventions have ‘improved the resilience of the banking system”.  In fact, they offer us no evidence on that score.   No doubt, as their data show, the number and value of high LVR loans on the books of banks have both fallen.   But high LVR loans require banks to hold higher amounts of capital, and loans that are just below some regulatory threshold, supplemented perhaps by other forms of credit (eg family support), may be only very slightly (if at all) less risky than the loans the banks would have made in an unconstrained world.     The Bank’s claim would be more convincing if (a) they directly addressed the clear and simple point that lower risk lending also lowers the amount of capital banks have to hold (so that the risks might be lower, but so are the buffers if things do turn bad), and (b) if they ever addressed the question of what banks do instead of the high LVR housing lending they are now largely barred from.  Banks’ own risk-appetite probably hasn’t changed, and neither (probably) have the return expectations of their shareholders, so have they pursued other types of risk.   FSR after FSR the Bank never engages with this fairly straightforward point.  It also never engages with the question of how direct controls, frequently revisited, better advance the efficiency of the financial system than indirect mechanisms (primarily the capital requirements for banks, which don’t interpose government regulators directly between banks and their customers).

Perhaps there are good and convincing responses to these sorts of points.  The Wheeler Bank has never even attempted to provide them.

I’m also uneasy about the Bank’s treatment of the housing market.  They have a long list of various factors that play a part at various times in influencing house prices.  I’m pleased that they quite openly state the obvious point –  well, it should be obvious if we didn’t have business think tanks and government-funded researchers arguing that opposite –  that when housing and urban land supply is less than fully elastic, strong net migration inflows can and do boost house prices.

But, for an organisation that has chosen to intervene repeatedly, and which weighs in every six months with an assessment of the risks around the stock of housing lending, they don’t seem to have anything very authoritative to offer.      They have never once noted that land use restrictions –  not just here, but in a variety of similar countries –  could make urban land prices permanently higher.    Without major changes to those laws, other interventions –  taxes, LVR restrictions, government housebuilding programmes, and even immigration restrictions –  will typically only make a modest difference for a relatively short period of time.   And there are no natural market forces that will undo those restrictions –  they aren’t like a temporary credit bubble.     When bank lending standards deteriorate rapidly, there is good reason for people who have lent to banks (and for the regulators) to worry.  When governments enable pernicious land use restrictions, there are plenty of reasons for many to worry – notably the young, who might struggle to ever get a place of their own – but it isn’t much of an issue for financial stability regulators (in that climate, higher gross credit is mostly just an endogenous response).  And yet, for all their interventions, the Reserve Bank has never been able to give us an authoritative story (“model”) on what role the various possible explanatory factors are playing now, and have played over the last 25 years.

I can imagine that the Reserve Bank is uneasy about wading into what can be a rather political debate. I can understand that.  But if you are a government agency actively intervening in a market –  itself a highly “political” choice, favouring some groups of potential buyers over others – you have an obligation to show us your robust supporting analysis.  The Reserve Bank simply hasn’t done so thus far.  Perhaps the robust cost-benefit analysis in the forthcoming consultative document will be different?

And, years on, there is still no robust analysis or research suggesting that the Reserve Bank has thought hard about what the important differences might be between countries where banks’ domestic loan books got into serious trouble and those where they did not?  In 2008/09 for example, New Zealand, Australia, Canada and the UK saw quite different things than the United States and Ireland did (and even those two latter experiences were themselves quite different). It seems like a pretty elementary line of inquiry –  and we do, as taxpayers, pay for a lot of researchers at the Reserve Bank –  but there has been just nothing.  In the meantime, people who are regulated out of credit markets pay the price.

If the Bank doesn’t know the answers to these sorts of questions, perhaps they need to be rather more agnostic about the outlook and the case for their own direct policy interventions in the market.  Focus on stress tests and capital requirements, and eschew direct interventions which have little economic foundation, and are arguably ultra vires anyway.

These are now mostly challenges for the new Governor.  Both Graeme Wheeler and his deputy (and Head of Financial Stability) Grant Spencer are leaving shortly –  Wheeler in September, and Spencer next March.  I hope the new guard takes more seriously some of these issues.  If they do, writing FSRs will be harder, but there would be a great deal more value in the resulting documents even if, in many cases, the resulting analysis leaves as many questions as answers.  That might simply reflect the limits of what we know about the world (and housing markets, housing finance, and banking risk).

Earlier in the year, the Minister of Finance intervened and instructed the Board of the Reserve Bank to stop their search for candidates for a new permanent Governor, and instead to recommend a candidate to be a temporary (acting) Governor.   Doing so avoided trespassing on conventions which restrain governments from making major permanent appointments which would take effect around the time of general elections.  Deputy Governor, Grant Spencer, was –  with what still looks like little secure legal basis –  appointed acting Governor for six months, allowing whichever government takes office after the election to make the appointment of a permanent new Governor.

You might have thought –  I did –  that such a temporary appointment was designed to leave the new government free, and also not to tie the hands of the new Governor.  An acting Governor would make the decisions that really had to be made, keep a steady hand on the tiller, and otherwise leave substantive decisions until a permanent appointee was in place next year.

But it seems that Graeme Wheeler, and the Reserve Bank’s Board –  the latter perhaps still smarting at having to end their earlier search process – didn’t quite see it that way.

With Spencer stepping up to acting Governor, and then retiring when that term ends, there was going to be a vacancy in his substantive roles.  There were two of those.  One was the fulltime day job as Head of Financial Stability (a role in which three departmental heads report to him, covering financial markets and financial stability/supervision.  And the second was the statutory position of Deputy Chief Executive.

A month or so ago, there was a press release from the Reserve Bank filling both positions.    The other current Deputy Governor, Geoff Bascand, was to transfer from his current role (oversight of the operations and admin sides of the Bank) to become Head of Financial Stability, and he was also promoted to become Deputy Chief Executive.  In addition, a search process would get underway straightaway to fill Bascand’s role (adverts have subsequently appeared, and applications have already closed).

Frankly it all seems rather odd.  For a start, even though Bascand has no background in banking, financial markets, or the regulation of those activities, there was no sign that any sort of competitive or contestible process was undertaken before he was appointed Head of Financial Stability.

But it also looks like an attempt to box in the new Governor, whoever he or she may be.  Sure, it is common for a chief executive to inherit a senior management team –  although often enough that is a prompt for a (often disruptive) restructuring etc to allow the new person to shape his or her own team.  Moreover, the qualities one might want in other members of the top team surely depend, at least in part, on the skills, experience, and other qualities of the person at the top.    A more obvious (and common elsewhere) solution would have been to have appointed an acting Head of Financial Stability and then let the new Governor make his or her own choice about the sort of structure and people they want in the roles.  For example, it might be fine to have a macroeconomist as Head of Financial Stability  –  key point of contact with senior people in the financial sector and other regulatory agencies –  if the new Governor has a strong banking background.  If not, it might be a lot more problematic, especially given how large and prominent the Reserve Bank’s regulatory role now is.   (Of course, if Bascand himself becomes Governor, that issue solves itself.)

These points are more important than usual given that talk of statutory reform of Reserve Bank decisionmaking is in the air.  Labour and the Greens are committed to change, and the government has had Iain Rennie looking at the issue.  Again, depending how those matters are resolved (including those around the Bank’s financial regulatory powers), it could easily influence the sort of person one wants in key senior management roles.   (That includes the Assistant Governor position they are filling now.  For all Graeme Wheeler’s talk of the key role of the Governing Committee in making key policy decisions in the Bank, the advert for that position, had hardly any mention of monetary policy and, from memory, none at all of financial regulation.  In many respects that makes a lot of sense –  while the Governor in law actually makes those decisions –  but perhaps not if the Act was to be changed to make a holder of this position a statutory decisionmaker on major areas of public policy.)

And then, of course, there is question of whether all of this was even lawful.   In the Reserve Bank Act,  the role of deputy chief executive is filled by the Board on the recommendation of the Governor.  But there is no vacancy in the role of deputy chief executive while Graeme Wheeler is Governor.  And, even though the press release was worded as coming from both Wheeler and Spencer, the Act does not talk of an acting Governor being able to recommend a deputy chief executive appointment.  Perhaps it is a small issue, but details matter, and the law matters.

All else equal, I happen to think that Geoff Bascand would normally be a sensible appointment for deputy chief executive.    I’m less convinced he is right for the role of Head of Financial Stability, and generally think he would be better-suited (despite his fling with LUCI) for the role of Head of Economics (a role which should have become much more important as the Governor has had to focus increasingly on the Bank’s various regulatory roles).

There is a public sector culture of generalist managers.  I’m not sure it serves particularly well.  Of course, Grant Spencer also had a background in macroeconomics but had also served as the Bank’s Head of Financial Markets, and then had almost 10 years in various relatively senior roles at ANZ in New Zealand and Australia.   It wasn’t doing credit –  perhaps the essence of banking –  but it was much more of an exposure than Bascand has had (and the Head of Financial Stability job is itself much bigger than it was when Spencer was first appointed to it).  Sure, Bascand has sat around the internal committees on regulatory issues for the last three or four years, but it really isn’t that much depth of involvement.  And I say this even though, when I also sat on those committees, Bascand’s was often more willing to challenge and questions the interventionist inclinations of staff than many of his colleagues were.  I welcomed that.

Perhaps he is the single best person in the country (or abroad) for the role.  And there is something to be said, in high-performing organisations, for promoting from within.  But the appointment has an uncomfortable feel about it, including the dimensions of Wheeler either trying to box in his successors, or give Bascand another leg up in the succession stakes.

And there is also the uncomfortable fact that, for someone soon to be charged with oversight and regulation of much of our financial system –  regulating in the interests of the wider economy, not that of the banks –  Bascand doesn’t exactly have a spotless track record.   Defensive behaviour and an attempt to close down issues, rather than open them up, seems to be his style.  There was his attempt to tar the whistleblower –  me –  last year when I alerted the Bank to what turned out to be a leak of an OCR decision and a systematic weakness in their processes.  There was the seeming inability to distinguish between his (and others) role as trustee and as Bank employee –  particular worrying to the Bank I’d have thought if a financial sector employee had a similar cavalier attitude.  There was the attempt to close down, without substantive inquiry, significant complaints from a member of the Reserve Bank superannuation fund, only to find later that a breach of the law had occurred (and various other –  still ongoing – issues identified), for which breach trustees later had to apologise to members.  And, meetings with fellow regulators might be interesting, given that there is an outstanding complaint with the Financial Markets Authority –  regulatory body responsible for superannuation schemes –  around the decisions and processes adopted by the superannuation scheme trustees under Geoff’s chairmanship.

I know we don’t have depositor protection as one of the statutory elements in New Zealand’s banking regulation, but whether as a depositor or citizen I’m not sure this sort of track record would fill me with confidence in Bascand’s ability to lead financial regulatory functions, with the drive and willingness to leave no stone unturned that, in some circumstances would surely be required.  Bankers will often be keen to close things down quickly, and paper over problems.  The last thing we need is officials who will be content, or perhaps even complicit, in letting that happen.    At very least, this was a decision the new Governor should have been left to make.


On Graeme Wheeler

Morning Report had invited me on this morning to talk about Graeme Wheeler, the change of governor, prospects for a permanent successor etc.  The death of Steve Sumner apparently changed their schedule so that interview didn’t happen, but I’d already jotted down some notes as to what I might say, so I thought I’d use them here.  Wheeler, of course, still has seven months in office, and we’ll see his next Monetary Policy Statement tomorrow.

When Graeme Wheeler was first appointed as Governor, there was generally a fairly positive reaction.  I shared that view.  Until quite late in the process, I’d assumed that Grant Spencer was the favourite for the role –  after all, successful organisations tend to promote from within, and a capable insider should always have an advantage, being constantly visible to the Board.  And so when Graeme was appointed, my initial reaction was “well, he must have been a very strong candidate to have beaten the capable internal deputy”.    And it was well known at the time that Bill English and John Key had been keen to have Wheeler back in New Zealand –  there had been well-sourced talk that the Minister had wanted him as Secretary to the Treasury, something apparently stymied by SSC bureaucracy.

With hindsight, one can only conclude that the Bank’s Board –  the key players in the appointment of the Governor –  just didn’t do a very good job in evaluating the candidates. Perhaps that shouldn’t be surprising –  mostly behind the scenes people themselves, they don’t have much experience in appointing someone to a position with as much visibilty and probably more untrammelled power than most Cabinet ministers.  There are suggestions that Board members were rather too easily swayed by big names Wheeler had produced as referees, and by his international connections (coming just a few years after the international financial crisis) rather than looking hard at the qualities required to do the Reserve Bank Governor job well.    Since many of the Board members then are still on the Board now, one can only hope they’ve learned from their experience.

I think Wheeler has done a poor job as Governor, both in the specific decisions he has made, and in the processes and procedures and style he has adopted.   For most of the time, he seems to have been aided and abetted –  or at least sheltered –  by the Board, who are actually paid as the public’s agents, not as associates and defenders of the Governor.

And it is not as if times have been unusually hard for him.  We haven’t had a recession in New Zealand and there has been no major flare-up of international financial stresses during his term (so far).  The terms of trade moved around a bit, but not much more so than usual.  There was no domestic financial crisis, no major domestic fiscal stresses, no change of government, and the major natural disasters of the last decade (the Canterbury earthquakes) had all happened by the time the Governor took office.   Sure, what is going on globally is a little hard to fully make sense of, but whereas most other advanced country central banks had by 2012 largely reached the limits of conventional monetary policy (interest rates very close to zero) that has not yet been a constraint here.

The Reserve Bank’s primary function –  according to the Act –  is monetary policy.  Graeme came into office with a new PTA that he was comfortable with –  in particular, with an explicit focus for the first time, on the 2 per cent midpoint of the inflation target range.  And yet over his 4.5 years in office, annual headline inflation has averaged not 2 per cent but 0.8 per cent.  Falling oil prices played a part in that, but CPI ex petrol has averaged not 2 per cent, but 1.1 per cent.  The Governor’s preferred measure of core inflation –  the sectoral factor model measure –  has averaged not 2 per cent, but 1.35 per cent.  All sorts of one-off factors that the Governor can’t be really be held accountable for influence inflation rates –  thus cuts in ACC levies have held down headline inflation in the last couple of years, while large increases in tobacco taxes have artificially boosted headline inflation throughout the Governor’s term.

There are a lot of comfortable commentators inclined to treat these inflation outcomes as a matter of indifference –  so what they imply, after all low inflation is better than high inflation.    But persistently low inflation over several years –  and especially when it doesn’t arise from surprisingly good productivity outcomes – almost invariably comes at a cost –  lost output, and lost employment.  And that has almost certainly been the case over the last few years.   Throughout the Governor’s term, the unemployment rate has been reasonably materially above estimates of the non-inflationary or “natural” level –  these days thought to be around 4 per cent.  The Governor’s choices affected the lives and options of real people –  and years lost out of employment simply can’t be got back.

My standard here isn’t one of perfection.  Central banks, engaged in active discretionary monetary policy of the sort now common around the world, will inevitably make mistakes.  Central banks try to operate on the basis of forecasts, and yet no one  –  least of all them  – knows the future.  So in evaluating the Governor, we need to look at the specific circumstances, and at the willingness to acknowledge and learn from mistakes.  Here, Graeme Wheeler doesn’t score well.

Before he came to office, the Reserve Bank had already once misjudged the need for a tightening cycle to commence, and had had to reverse itself.  At the time –  2010/11 –  they had some company internationally, and there was a fairly widespread expectation that interest rates would need to return to “normal” fairly soon.  That wasn’t the case by the end of 2013, when the Governor was not just talking about tentatively beginning a tightening cycle, but confidently asserting that interest rates would need to rise by 200 basis points.   He –  and his machinery of advisers –  simply got that one wrong.  Fortunately, they never raised the OCR by 200 basis points, but it was 18 months before they even started to reverse themselves –  and even now, to my knowledge, they have never acknowledged having made a mistake.  In so doing, they’ve unnecessarily exaggerated both interest rate and exchange rate variability, all the while leaving unemployment unnecessarily high.   Good managers and leaders recognise that human beings make mistakes, but they expect those who make them to acknowledge and learn from them.  Graeme Wheeler failed that test.

The other big part of the Reserve Bank’s policy responsibilities is the regulation of key elements of the financial system, to promote the soundness and efficiency of the system.  Graeme made that a much more prominent part of the Bank’s role with his enthusiasm for successive waves of LVR controls.   The Reserve Bank has no policy responsibility for the housing market, or for house prices, only for the soundness and the efficiency of the financial system.    And yet I see a leading commentator criticising the Governor for not doing the impossible:

Wheeler should have earlier called out the Prime Minister and Finance Minister on their tardiness in developing policy responses to counter the house price bubble. But he was late to the party.

Notably, the bank was also tardy in its own policy responses, thus earning itself a rebuke from then Prime Minister John Key, who rather cynically tried to take the focus off a Government that was running immigration hot for its own ends.

A more adept governor should have been able to persuade the politicians that slowing the boom was a job for both the politicians and the central bank. And that it was necessary for NZ’s long-run stability.

Quite how Graeme Wheeler was supposed to have changed the mind of the government on reforming supply – when no one else, in New Zealand or in many Western countries, has succeeded in doing that –  is a bit of mystery.  I have pretty high expectations of a Reserve Bank Governor, but that seems like a Mission Impossible task.  It is not that reform couldn’t be done, but against a Prime Minister determined to present high and rising house prices as a mark of success, a central bank Governor, with no detailed background in the area, no real research to back him, and no particular mandate wasn’t likely to succeed.  After all, our housing supply and land use laws have created problems, interacting with immigration policy, for 25 years, and Alan Bollard and Don Brash had made no inroads either.

As for the Bank being “tardy”, hardly.  When Graeme Wheeler took office, no one in the Reserve Bank had been keen on direct LVR controls –  they were a clear fourth preference, when assessed against the Bank’s responsibility for financial system soundness and efficiency.    But Graeme rushed such restrictions into place, at times surprising even his own senior managers, with no tolerance for any debate or dissent (there was no substantive discussion of the merits of the measures at the key relevant internal committee).  If you think LVR limits were a good thing, the last thing you can accuse Graeme of was being tardy.  I think they were ill-conceived, sold on a false promise (about how temporary they would be), are still poorly-researched, and have spawned one new set of controls (and odd exemptions) after another.  And, unsurprisingly, the real housing market issues –  mostly about land supply, not finance –  haven’t been dealt with.  Wheeler liked to fancy himself as a shrewd political player, and yet if there is a valid criticism of him in this particular area it is as much that he eased the pressure on politicians by rushing to do something/anything, at time when there was a growing sense that “something must be done”.  The appropriate response to “something must be done” is not “so anyone should do anything”.    And it remains concerning that despite Wheeler’s penchant for increased use of direct controls –  harking back to earlier decades –  there has been little or no serious analytical or research engagement with the issues around the efficiency of the financial system, and the way in which direct controls can undermine efficiency, and in the process favour insiders over outsiders, the well-connected and well-resourced over the more marginal, and so on.  The experience of the US over 2008/09 –  where Wheeler lived at the time –  always seemed to loom large, and never once has the Bank answered my challenge to consider the similarities and differences between the US and New Zealand, or to look at the experiences of countries (many of them including New Zealand) that didn’t have domestic financial crises in 2008/09 despite large house price booms.

Effective communication is a big part of what the central bank governor should be expected to do, and the more so in New Zealand where (a) all the statutory power rests with the Governor personally, and (b) where the Bank has such wide-ranging powers, and is not just responsible for monetary policy.  And yet during the Wheeler years, the Bank hasn’t done well on that score either.    The number of on-the-record speeches the Governor has made has dwindled, and those he does give don’t typically compare favourably –  in terms of quality, depth and insight –  with those of his peers in other countries.   There have been specific communications stuff-ups (speeches inconsistent with subsequent action etc), although I’m reluctant to be too harsh on those –  most central banks end up with some of those problems in one form or another, at some time or another.  But it is also a matter of accountability:   Wheeler has been very reluctant to grant serious media interviews (none at all to the main TV current affairs programmes, and only belatedly the occasional soft-soap interview to the Herald) in a way that is quite extraordinary for someone personally wielding so much power.  A Cabinet minister wouldn’t get away with it.  And in his press conferences, the Governor has often come across as embattled, defensive and weary.    Despite his past senior roles, he had no background in the public limelight, and clearly wasn’t comfortable with it.  But that was a significant part of what made him, at least with hindsight, the wrong person for the job.

Neither in my time at the Bank –  around half his term, involved in most of key policy committees –  nor subsequently have I seen any sign in the Governor of wanting to foster a climate of debate and explorations of ideas and alternative options.  I mentioned the LVR controls already, but they weren’t the only example.  In my own experience, one small example lodged in my brain.  One day a few years ago Graeme was down in a meeting in the Economics Department and there was a bit of a low key discussion about alternative policy approaches etc: the death glare I received for even mentioning, hypothetically, nominal income targeting was a pretty clear message, not just seen by me, that what the Governor wanted was support for his position, and answers to his detailed questions, not alternative perspectives or debate, no matter how non-urgent the issues were.  People respond to incentives.  In a area so rife with uncertainty as monetary policy, it is very dangerous approach.  The same goes for the ability to deal with external criticism –  a capable and intellectually confident Governor would recognise the value in alternative perspectives and relish the prospect of engaging with the alternative ideas.  Doing so is part of how people come to have confidence in the Governor.  But there has been none of that with Wheeler –  if anything he seemed to become unreasonably rattled by disagreement (his active effort to tar the messenger who drew to his attention the OCR leak last year was a sad example of that –  made worse by the cover he received for it from his Board).

I could go on, but won’t at length.  The Governor has been highly obstructive in his approach to the Official Information Act –  we still don’t have access to papers relating to the 2012 PTA for example –  and has done nothing to advance transparency around the Bank’s medium-term spending plans.  Nothing appears to have been done to prepare for the likelihood that the near-zero bound will become an issue here in the next recession.  The refusal of the Governor to engage with serious evidence of past misconduct around staff superannuation policy is a blight.  And despite the large team of researchers and analysts the Governor commands, there has been little good policy-relevant research published in the last few years, particularly in the areas of financial system regulation and macro and financial stability.  Sadly, the Reserve Bank has been living off reputational capital for some considerable time now, and one of the challenges for a new Governor should be turning that around and lifting the quality of the Bank’s outputs and its senior people.

As I’ve noted before, I give the Governor a small amount of credit for his recognition that the single decisionmaker model is past its use-by date, and should be reformed.  A committee of his own apppointees –  his two deputy governors and one assistant governor, all answerable to him – is not the right answer, but at least he was willing to start addressing the issue, unlike his predecessor.  Responsibility for the Reserve Bank governance model rests mostly with the Minister of Finance and the Treasury, but the Governor sought to get approval for legislative changes and failed.  That reflects poorly on him  –  our current model is so out of step with how countries do things and how government agencies are structured –  and is partly a reflection of his own fixation on a technocratic model, and partly of the loss of trust he incurred with the Minister and the Treasury (including around the financial regulation powers).  The Bank should have been able, by a flow of good research and analysis, to have helped shape a public debate on the appropriate future governance model.  But it failed to do that –  and now still refuses to release any of the background papers from that long-completed work programme undertaken at taxpayers’ expense (and this time, extraordinarily, they have managed to get Ombudsman cover for their refusal).

Quite who will be the next Governor is anyone’s guess.  If I had to put money on it, I’d assume it would come down to a choice between Geoff Bascand and Adrian Orr –  both of whom have their own weaknesses –  but there are other possible candidates both here and (New Zealanders) abroad.  Even though the Bank’s Board have all been appointed by the current government and have the key role in determining who will be the next Governor, quite a bit could still turn on the outcome of the election and what changes, if any, they might want to make to the Act.  In my view, whoever wins the election should focus quite quickly on sketching out a plan for governance reforms, and should look to appoint a person who will be able to carry those through and help the Bank adapt, and perform well, under a new model, under which the Governor personally would have a vital role, but a much less dominant personal role in determining monetary and bank regulatory policy.

Doing so now isn’t a reflection on Graeme Wheeler –  as perhaps it might have been seen as a year or two ago –  just a recognition that times, and the institution and its challenges, have changed,  While so much power rests with the Governor personally, it is important to appoint someone with some reasonable credibility in the subject areas the Bank is responsible for –  an effective deputy can do much of the day-to-day management of what isn’t a very large or complex organisations –  but if the new government, of whatever stripe, is seriously willing to move to a committee-based model (the more conventional approach) then the requirements for a Governor would be rather different.   Change management skills would be a key component, as part of revitalising the Bank and shaping a position for a strong chief executive who can support the decisionmakers –  rather than being both the principal decisionmaker, and the one who controls all the flow of paper, him or herself.  It might be a little more akin to the important role a Secretary to the Treasury plays in leading his organisation as advisers to the Minister of Finance.

Stress tests and credit availability

It is 3 January, a public holiday, the heart of summer (notionally at least –  it is actually cool and wet in Wellington), and something of a low ebb in local news and analysis.  But bright and early this morning, I did a radio interview on the Reserve Bank’s stress tests of the major banks.

The request was apparently prompted by a Stuff article, itself prompted by a recent new Reserve Bank animated video explaining stress tests.    The article, rightly, pointed out that following a very severe recession and significant credit losses for banks it was likely that banks’ lending standards would be somewhat tighter than they would have been in the previous boom.  That might even affect some of those hoping to take advantage of lower asset prices.

The stress tests themselves aren’t new.  They were done in late 2015, and were written up in the Reserve Bank’s Financial Stability Report last May.   I wrote about those results at the time.  In that stress test the Reserve Bank, quite appropriately, looked at how banks would cope if they were faced with a very severe recession and a very sharp fall in asset prices.  Stress tests are useless unless they use very demanding shocks.   These were. In the stress test, the unemployment rate rose to around 13 per cent and stayed there for some time.  For housing loan books it is the combination of unemployment and falling house prices that creates the scope for large loan losses –  either strand alone isn’t enough.  In fact, the increase in the unemployment rate was larger than anything experienced in any advanced economy with its own monetary policy in the 70 years since the end of World War Two.  And house prices were assumed to fall by 40 per cent generally, and by 55 per cent in Auckland –  about as large as any falls anywhere.

The banks emerged from these very demanding stress tests intact.  It wasn’t even a close run thing.  Capital ratios dropped, but mostly because the risk weights applied to banks’ outstanding loans increased  (a 50 per cent initial LVR loan looks riskier after house prices fall by 40 per cent).  The actual loan losses weren’t large enough to offset bank’s other operational earnings, so that the actual dollar value of banking system capital was not reduced.  This is the Reserve Bank’s chart of losses.


Total losses, over four years, were around 4 per cent of assets.  As the Bank observed

The cumulative hit to profits averaged around 4 percent of initial assets (figure C1), which is a similar outcome to phase 2 of the full regulator-led exercise conducted in late 2014. About 30 percent of total losses were related to mortgage lending, with half of this due to the Auckland property market. SME and rural lending accounted for most of the remainder of financial system losses. Loss rates for mortgage lending were around 2 percent, significantly lower than the 5 percent loss rate observed for most other sectors.

Faced with such very demanding economic circumstances, banks could be expected to become more cautious about lending.  That is what generally happens in economic downturns.    Banks –  like others in the economy –  find that things hadn’t turned out as they expected, and aren’t sure what will happen next, or how long the downturn will last for.  Central banks don’t know either.

In this sort of climate banks are typically keen to conserve capital –  it isn’t necessarily easy to raise more capital, and shareholders are a bit uneasy.  On the other hand, banks stay in business by lending and borrowing, and being known to be reasonably willing to extend credit.    As I noted in my earlier post, lower asset prices (houses and farms) tend to result in a lower stock of credit over time just through the normal process of turnover.  What was a million dollar house might now be a half million dollar house, and a new purchaser will typically need a lot less credit to facilitate the transaction than the previous million dollar purchaser would have.  That process takes time, but it is fairly inexorable.  Combine it with the lower turnover that is typical during recessions and there is likely to be a lot less new credit going out the door, even without credit standards tightening.  Business credit demand also tends to fall away sharply during recessions –  demand for new investment projects dries up, and that is particularly marked in sectors like commercial property (where empirical evidence suggests banks are particularly prone to taking losses).

But I’m sceptical of the notion that even in the sort of recession dealt with in the Reserve Bank’s stress tests credit conditions for home buyers would tighten much.  There are really three reasons for that.  The first  –  unique to current circumstances –  is that credit conditions for home buyers are already quite (inappropriately) tight as a result of the Reserve Bank’s successive waves of LVR controls.  That is a very different climate than existed in previous booms (here or abroad).  Those controls would typically be expected to be lifted in any downturn.  The second reason is that, as the Bank’s results above show, even in a scenario of this sort loan losses on the housing loan books are not large –  not trivial by any means, by not of the sort of scale that is likely to take banks by surprise if such a shakeout ever occurs.   Servicing capacity remains a vitally important factor and any young couple with a secure income would be unlikely to find it that difficult to secure a 70 or 80 per cent LVR loan to purchase a first home.  Banks, after all, will often be keen to replace extremely highly indebted borrowers (eg investment property borrowers with negative equity) with less indebted owner occupiers with decades of home ownership in front of them.

The third reason is history.  Take, for example, the banking crisis of the late 1980s and early 1990s, which was much more damaging that the stress test results in the recent Reserve Bank exercise.  Several major banks were severely adversely affected, and the BNZ would have failed were it not for the government bailout.  And yet through that period-  late 80s and early 90s –  banks’ housing credit stock grew quite rapidly.  Even though the unemployment rate was high and rising –  not to 13 per cent –  and interest rates were still quite high, banks recognised that housing loans were generally relatively lower risk exposures.  To be sure, the stock of housing credit was much lower then than it is now –  and there was still some reintermediation (from non-banks to banks) going on, so I wouldn’t expect a repeat, but it is a reason not to be too worried about the availability of credit to house purchasers with reasonable deposits even in the aftermath of a very nasty recession and a sharp fall in house prices.  Even good projects advanced by property developers would probably struggle to get credit  –  as happened after 2007/08 –  but existing suburban houses are likely to be a very different proposition than new commercial developments, or even new fringe residential subdivisions.   (One caveat to that might be if governments were to intervene, in response to a sharp fall in house prices, and impair the value or certainty of banks’ security interests in residential mortgages –  but that isn’t an element in the Reserve Bank stress test.)

As a reminder, the stress test scenarios are very demanding.  The Reserve Bank likes to suggest that the scenarios don’t fully account for the second round effects of tighter credit conditions after the initial shakeout, but the scenario is so severe –  more so, say, than the US experience in 2008/09 – that we can largely set that concern to one side.     Based on the lending standards our banks were adopting in 2015 –  when the stress tests were done –  our banks look to be able to withstand all but the very worst imaginable economic shocks, and to be able to emerge still providing finance to reasonable projects, perhaps especially mortgages on existing residential properties.  Indeed, credit conditions for potential mortgage borrowers might be little or no worse than they are now, given the direct interference in that market through the waves of LVR restrictions.

The Stuff article appeared to be driven by the idea that those hoping to take advantage of a future fall in house prices might be out of luck, as the credit might not be available to do so.    For the potential first home buyer considering waiting for a future shakeout that seems a misplaced concern (although it might not be for someone wanting to buy say 20 properties at once).

The bigger question, of course, is what might trigger a really sharp fall in New Zealand real and nominal house prices.  I don’t think there is any evidence that what has happened here is, primarily, some sort of speculative bubble.  Mostly it is a consequence of the land use restrictions, exacerbated by the rapid immigration-policy fuelled population growth.  As we saw in 2008/09, recessions and reversals in immigration numbers can prompt a temporary fall in nominal house prices.  But without far-reaching reforms in land use regulation, perhaps supported by permanent material changes in target immigration levels, it is difficult to be optimistic that the sustained halving in house prices, that might re-establish more reasonable levels of affordability, is in prospect.

Debt to income limits: some questions

One of the jobs of the new Minister of Finance will be to decide whether or not to accept the Governor of the Reserve Bank’s request to add some sort of debt-to-income limit tool to the list of direct regulatory interventions that the government gives the Reserve Bank political cover to use.  It does this under the Memorandum of Understanding on (so-called) macroprudential tools.  I phrase things in that slightly awkward way because Parliament has delegated so much power to the Reserve Bank –  probably without fully realising the import of several legislative changes over the years –  that one unelected official, the Governor, does not actually need approval of the Minister of Finance, or of Parliament, to impose such intrusive direct controls.

To give some credit to the outgoing Minister of Finance, the Memorandum of Understanding framework, while legally non-binding, does more or less ensure that the current Governor would not use such a regulatory intervention without at least the political cover provided by allowing the inclusion of a debt-to-income limit on the list of approved tools.  Longer-term, reform of the governance and regulatory powers of the Bank should include making decisions on the application of such controls formally a matter for the Minister of Finance, on the recommendation of the Reserve Bank.

The Reserve Bank has been at pains to claim that their successive waves of LVR controls have improved the resilience of the banking system.  That claim is less well-founded than they would like people to believe.  For example, shifting a large group of borrowers from say 81 per cent LVR mortgages to, say, 79 per cent LVR mortgages won’t make any material difference to the expected losses a bank might face in a severe downturn, but might actually modestly reduce the ability of a bank to withstand those losses (since loans with less than an 80 per cent LVR typically have lower risk weights).   This risk is one my former colleague Ian Harrison has drawn attention to.  In addition, the Bank has never presented any sort of analysis, not even impressionistic in nature, of what banks are doing instead of making high LVR housing mortgages.  If their risk appetites haven’t changed, and the capital invested in the business hasn’t changed, the risks are likely to be developing somewhere else, perhaps somewhere rather less visible, on banks’ books.  There are also ongoing questions about the evidence base behind the regulatory discrimination against those borrowing to buy a house for residental rental purposes.  Before giving his imprimatur to the possibility of further Reserve Bank regulatory interventions, the new Minister of Finance might reasonably ask some harder questions about what has already been done.  He might also ask some questions about when the drift towards ever more direct intervention –  initially sold as quite temporary back in 2013 –  might end.

Before approving the addition of any sort of debt to income limit tool to the approved list, it would also be worth the Minister insisting that the Bank’s background papers get public scrutiny.  No doubt Treasury gets to see them and Treasury has had some serious questions in the past about proposed Bank interventions.  But since the Governor says there is no urgency about using a debt to income tool, there can be no good grounds for not putting the background material out for wider scrutiny now, before the Minister makes his decision, not sometime –  if ever –  afterwards, when (with luck) the OIA finally gets the papers out of the Bank.

In particular, it would be good to see a careful assessment of the empirical evidence the Bank is using in support of its case for a DTI limit, on both soundness and efficiency dimensions (both important in the Reserve Bank Act).  Along those lines, there was an interesting post out earlier this week on the blog of Richard Green a professor (in housing, real estater economics etc) at the University of Southern California.

In that post, he reports some interesting empirical work on a sample of 281000 fixed-rate mortgages purchased by Freddie Mac, one of the US quasi-government “agencies”, in 2004.  He runs a regression model across two-thirds of these mortgages, using a range of variables to model the probability of subsequent default, including through the largest shakeout in the US housing market in many decades.  His DTI term is not actually the ratio of debt to income, but the ratio of debt service to income, but clearly the two will be highly correlated, especially for these relatively high quality mortgages (ones that met US agency standards –  “qualifying”), looking at all the mortgages across the same period of time.

The equation results are in Green’s post.

Note that while DTI is significant, it is not particularly important as a predictor of default.  To place this in context, note that a cash-out refinance is 5.2 percentage points more likely to default than a purchase money loan, while a 10 percentage point change in DTI will produce a 1.3 percent increase the probability of default.

To be clear, increasing the total service burden from, say, 40 per cent of income to 50 per cent of income –  a huge increase – produced a 1.3 per cent increase in the (always quite low) probability of default.

One reason he notes is measurement

First, while DTI is a predictor of mortgage default, it is a fairly weak predictor.  The reason is that it tends to be measured badly, for a variety of reasons.  For instance, suppose someone applying for a loan has salary income and non-salary income.  If the salary income is sufficient to obtain a mortgage, both the borrower and the lender have incentives not to report the more difficult to document non-salary income.  The borrower’s income will thus be understated, the DTI will be overstated, and the variable’s measurement contaminated.

More generally, and in the US context

The Consumer Financial Protection Board has deemed mortgages with DTIs above 43 percent to not be “qualified.”  This means lenders making these loans do not have a safe-harbor for proving that the loans meet an ability to repay standard.  Fannie and Freddie are for now exempt from this rule, but they have generally not been willing to originate loans with DTIs in excess of 45 percent.  This basically means that no matter the loan-applicant’s score arising from a regression model predicting default, if her DTI is above 45 percent, she will not get a loan.

This is not only analytically incoherent, it means that high quality borrowers are failing to get loans, and that the mix of loans being originated is worse in quality than it otherwise would be.  That’s because a well-specified regression will do a better job sorting borrowers more likely to default than a heuristic such as a DTI limit.

He tests this by applying his model to the one third of the sample of loans held back in the initial estimation.

To make the point, I run the following comparison using my holdout sample: the default rate observed if we use the DTI cut-off rule vs a rule that ranks borrowers based on default likelihood.  If we used the DTI rule, we would have made loans to 91185 borrowers within the holdout sample, and observed a default rate of 14.0 percent.  If we use the regression based rule…… we get an observed default rate of 10.0 percent.  One could obviously loosen up on the regression rule, give more borrowers access to credit, and still have better loan performance.  

And extending the point

Let’s do one more exercise, and impose the DTI rule on top of the regression rule I used above.  The number of borrowers getting loans drops to 73133 (or about 20 percent), while the default rate drops by .7 percent relative to the model alone.  That means an awful lot of borrowers are rejected in exchange for a modest improvement in default.  If one used the model alone to reduce the number of approved loans by 20 percent, one would improve default performance by 1.4 percent relative to the 10 percent baseline.  In short, whether the goal is access to credit, or loan performance (or, ideally, both), regression based underwriting just works far better than DTI overlays.  

The current focus in the US isn’t on responding to a house price boom, but on access to finance (in a market still dominated by the government).  But the sorts of questions posed by these sorts of results are just as relevant here as they might be in a US context.  Perhaps here too, high debt to income borrowers might generally be better quality borrowers?     How confident can the Reserve Bank be that an actual debt to income limit –  as distinct from a pure hypothetical –  will actually improve the resilience of banks –  not just on the housing book, but overall?  And even if there is some improvement in resilience, at what cost –  recall the statutory efficiency mandate –  in terms of access to credit would that gain come at?

Perhaps there are good answers to all these sorts of questions.  Perhaps the Reserve Bank has access to other careful studies that produce different, and robust, results.  But these are the sorts of questions the new Minister of Finance, and the public, should be asking in response to the Governor’s request for political imprimatur for adding another tool to his kit of potential interventions.     And, more broadly, how confident can we be of any sustained gains from such interventions, as compared to the sure increases in resilience that would result from either higher risk weights on housing loans more generally, or higher overall capital requirements for banks (and non-banks regulated by the Reserve Bank)?


A submission to the Reserve Bank’s faux consultation

A bit under three weeks ago the Reserve Bank announced a proposal for a further, substantial, extension of its LVR controls on banks’ mortgage lending  It is formally a proposal, subject to a consultative process, but it is all done in such a mad rush that it is difficult for anyone to take the “consultation” process seriously.  Late last year, the Bank announced that it would be allowing substantial consultative periods, and on this occasion they have offered no argument or evidence for why it is so urgent that such a short time is allowed for consultation and the preparation of submissions.  Presumably it is just the impatience –  backed by very little analysis – of the Governor –  much the same impatience that means this is now the third attempt in three years to get LVR controls “right”.  What was worse was the instruction to banks to simply fall into line now.  We live in a country supposedly governed by the rule of law, not the whims of men.  And until the proper consultative process has been completed, and the Governor has had regard to all the submissions, what he is proposing (a) is not law, and (b) cannot be counted on as ever being so.  But just to write that is to explain why it is hard to take the consultative process seriously.

I have  written and lodged a submission.  It was a fairly rushed job, but I’m out of commission for the next couple of days and needed to get it in this evening.

Submission to RBNZ consultation on further extension of LVR limits Aug 2016

This is the heart of the conclusion of my submission

In substance, the proposal if adopted will further undermine the efficiency of the financial system, while doing little or nothing to reduce any threats to financial stability (risks which, on your own stress tests are already very low). Indeed, there is a risk that such direct controls could increase, albeit modestly, the risk of serious financial system stresses because it will reduce the volume of capital held against bank mortgage books.    Over time, the growing use of direct controls risks progressively undermining the willingness and ability of banks to do their credit risk assessments, and to compete with each other in doing so,  rewarding going along with the Bank’s assessment of risks, while gaming the rules at the margin wherever possible. 

Since the Bank offers us no reason to think that its own assessment of credit risks –  in the aggregate or at a more disaggregated level –  is superior to that of the market, and since our banks actually came through a much larger housing and credit boom largely unscathed, there is little basis for us to prefer the Bank’s judgement.  And it has offered nothing to suggest how much its planned intervention might affect the probability or severity of any crisis. 

Over-reliance on a very slender base of international evidence, and a failure to think hard about the distinctiveness of New Zealand (from, say, the Irish or US experience) or to make the attempt to gather and analyse New Zealand loss experiences should give citizens little reason to have any confidence in what the Bank is proposing,   Even if investor loans were to prove slightly riskier, all else equal, than owner-occupier loans, the scale of the differentiation in the rules for the two types of lending suggests the Bank is driven at least as much by tilting the playing field against investors and in favour of first-home buyers as by its statutory responsibilities to use its powers in the interests of financial system soundness and efficiency.  If so –  and I hope there is nothing to that suspicion –  it would have involved the Bank stepping well beyond its responsibilities (with little ability for citizens to hold it to account if it did so).

There isn’t much to like in the consultative document.  The empirical evidence they now rely on is two studies undertaken by a central bank (the Irish one) which had already decided to have a regulatory distinction between investor loans and owner-occupier loans.  One of those studies is claimed to examine the UK experience –  in fact, it looks as the loan books in the UK of the three (failed) Irish banks, not necessarily a representative sample of UK experience.  I’m open to the possibility that investor loans are slightly riskier than owner-occupier ones, but have simply not yet been presented with any compelling evidence.  And the Bank has still made no effort to look at the experience in New Zealand, where the post-2008 reductions in house prices in some regions were not dissimilar to the UK experience, where unemployment rates lingered high, and where in some cities nominal house prices stayed well below previous peaks for a prolonged period. Obviously, New Zealand data reflecting New Zealand banking practice, New Zealand law, and New Zealand cultural norms would be more persuasive than the experience of the Irish banks (and even those research papers have some real problems).

The proposed controls differentiate between investor loans and owner-occupier ones to a huge extent.  Implicit in these proposed new rules is the view that loans to an owner-occupier with an 80 per cent LVR are less risky – not just as risky –  as loans to investors with a 60 per cent LVR.   Nothing in the data they’ve presented warrants that sort of differentiation, and it looks like a bit of covert redistributive policy: regardless of the riskiness of the respective loans, make things harder for investors and help out the first home buyers (even though those young buyers might be getting in right near a peak).  That simply isn’t the Bank’s job.  It is charged with financial system soundness and efficiency: it pays lip service at best to the efficiency issues (and the way its controls will progressively undermine competitive credit allocation decisions) and its own stress tests say that the financial stability risks are slight.  And why should regulatory policy be prohibiting a young person in, say, Wanganui getting into the rental property market with an LVR above 60 per cent.  Direct controls lead to arbitrary boundaries, absurd outcomes, and/or ever-increasing regulatory complexity.  That was part of the reason why we deregulated markets, and relied more extensively on indirect instruments, in the 1980s. it remains a good model –  and served New Zealand well through the boom and bust of the last decade, when our banks came through largely unscathed.

A key feature missing from the consultative document is any recognition that to the extent that the controls reduce high LVR lending, they will also reduce the amount of capital banks need to hold against their mortgage books. The Bank argues that the proposals will reduce the risk of financial crisis, but they show no sign of having thought much about the implications of the reduction in required capital.  If the capital requirements for high LVR loans were too low in the first place, that might be one thing. But our risk weights on housing loans are among the highest anywhere, and the Bank went through a consultative process not that long ago to increase those risk weights on high LVR lending.  And as part of what the controls will do is push a pile of lending to just below the respective ceilings –  there will be a lot of 59.9 per cent investor loans , even though a 59.9 per cent loan is little less risky than, say, a 60.1 per cent loan.  Capital requirements are likely to fall further as a result, even if the underlying risks haven’t changed much.   It would be unfortunate if measures ostensibly designed to reduce financial system risk actually modestly increased those risks, by reducing the capital buffers banks have to hold.

I don’t suppose submissions will make any difference to the Bank, but time (not much time, if they plan to have the restrictions in effect from 1 September) will tell.

Readers will recall that a couple of weeks ago the ANZ’s local head, David Hisco, called for the controls to be much more constraining than what the Bank is proposing. As I noted, there was nothing to stop ANZ restraining its lending accordingly.  But I do hope the ANZ will now pro-actively release its submission to the consultation so that we can see if Hisco’s submission on regulatory policy aligned at all with the rhetoric in his newspaper article.

I have lodged an Official Information Act request for all the submissions the Bank receives.  If past practice prevails they will eventually release those of entities other than banks, while claiming that the Reserve Bank Act prohibits the release of the bank submissions. I discussed this curious interpretation of section 105 of the Act the other day.  It cries out for a short amendment to the Reserve Bank Act to make it clear that all submissions on new regulatory proposals of this sort are covered by the Official Information Act.  That, of course, would be just a start on the sort of extensive reforms of the governance of the Reserve Bank that are needed.



Reserve Bank on housing – still all over the place

As I was writing this, the Reserve Bank’s latest set of regulatory interventions and controls were announced.  I haven’t yet read that document but from the press release I would make just three observations:

  1. The flip-flops continue.  After easing the LVR restrictions for non-investors outside Auckland last year, they now plan to totally reverse that change.  As a reminder, when these controls were first introduced three years ago, they were all supposed to be “temporary”.  So, I suppose, were the exchange controls, introduced in 1938 and lifted in 1984,
  2. The consultation process is a joke.  Not long ago, as part of their regulatory stocktake, the Bank indicated that it intended to put in place materially longer consultative periods for its proposed regulatory initiatives (typically six to ten weeks).  But in today’s announcement they are allowing only three weeks for submissions on the new “proposals” to be made, and then plan to implement the changes three weeks after that.  Only 10 days ago they were talking languidly of “a measure that could potentially be introduced by the end of the year”.   There is no real consultation going on, simply jumping through what they must regard as the bare minimum of legal hoops they must be seen to comply with.  And they will, no doubt, continue to refuse to publish most of the submissions.  It is, frankly, a travesty of democracy –  and the nature of what is going on is well-illustrated by the Governor’s statement that “We expect banks to observe the spirit of the new restrictions in the lead-up to the new policy taking effect.”  Citizens –  even banks –  are required to obey the law, not the wishes and whims of officials, elected or otherwise.   None will do so of course –  they are all too scared to challenge the Reserve Bank in public – but it would be interesting if a bank were to seek a judicial review of what is going on here.
  3. The policy remains as incoherent as ever, in that the LVR restrictions will not apply to loans for new house building, even though the risks of losses are materially higher on new buildings  –  often on the peripheries of towns/cities – than on existing ones.

I was away when Grant Spencer’s 7 July speech on housing was released, and although I glanced through it then on my phone, last night was the first time I had sat down and read it carefully.  It was really quite disappointing.

I say that not primarily because I disagree with Spencer on many points –  although I do.  But reasonable people can interpret the same data and experiences in different ways.  What concerns me is that the Reserve Bank still doesn’t seem to have a disciplined framework for thinking about housing markets here or abroad, or about its role in respect of the efficiency of the financial system,  and simply doesn’t back up its claims with much analysis or research at all.

Grant Spencer gave a speech on housing in April 2015, shortly after I started this blog.  At the time I was quite critical of that speech (here and here), and rereading those comments this morning I could easily simply repeat most of them now.  They apply as much to the latest speech as to the one given 15 months ago.  Back then I concluded:

Without more detailed and extensive analysis, it is still difficult to escape the conclusion that the Reserve Bank’s approach to housing is being shaped more by impressions of the US last decade than by robust in-depth analysis of the sorts of specific risks the New Zealand economy and, in particular, New Zealand banks and the New Zealand financial system face.

That still seems to be the case.

Of course, not everything can be covered in a single speech.  But good speeches by authoritative senior central bankers  typically draw on analysis and research undertaken in their own institution and elsewhere.  But Spencer’s speech has no references to any other Reserve Bank research and analysis (other than his own April 2015 speech) and in fact no significant references to anyone else’s research or analysis either –  whether to support his case, or respond to alternative perspectives.

And even though Spencer is the Deputy Governor with explicit responsibility for the Bank’s financial stability functions, nowhere does he even mention the Bank’s stress tests.  Perhaps he disagrees with the assumptions that were used in doing the stress tests –  but if so, he should have had them changed –  or perhaps the results are simply uncomfortable given that he knew his boss was champing at the bit to impose yet more controls.  But it should be seen as simply unacceptable for a major speech on housing from the central bank’s financial stability Deputy Governor to not even engage with the stress test results.

There is also nothing in the speech on how the Bank thinks about the implications of its ever-growing web of controls for the efficiency of the financial system –  an explicit (and equal) part of the Bank’s financial regulatory responsibilities.  In his latest letter of expectation to the Bank, released a few days ago, the Minister of Finance indicated to the Governor that he expected the Bank to produce analysis on how the stability and efficiency goals were being balanced.  Four months on from when that letter was written, there is nothing at all in Spencer’s speech.

The Reserve Bank has explicit statutory responsibility for monetary policy, and for financial regulation to promote the soundness and efficiency of the financial system.  It has no statutory responsibility for the housing market, or house prices per se.  And it certainly has no responsibility for tax policy, immigration policy, land use regulatory policy, fiscal policy, policy around Urban Development Authorities, and so on.  And yet in the speech, Spencer weighs in on all of them.

That is not good practice generally, and particularly not in this case where the Bank’s comments seem to be based on no supporting analysis at all.  Central banks are given quite considerable power in specific and limited areas, but continued support for central bank independence (whether in monetary policy or financial regulatory policy) depends in part on a sense that (a) the central bank is a technocratic, limited, institution that doesn’t involve itself in other partisan or politically contentious issues, and (b) that when on very rare occasions the central bank might weigh in on matters outside its direct ambit, it does so backed by very sound research and analysis.  Since central banks often have considerable research capacity, at times such research might be able to shed useful light on some of these wider issues.  But neither of those criteria are met with the material in this speech.

I happen to agree with the Deputy Governor that the government should be reviewing immigration policy –  which is itself quite a change of stance from the Governor’s view on immigration only a few months ago –  but I don’t think it is a matter on which the Reserve Bank should be expressing a view.  And in particular, it should not be expressing such views without the supporting research and analysis.  There appears to be none behind these comments.

Much the same might be said for the government’s recent announcement of a Housing Infrastructure Fund –  the $1000m fund under which the government on behalf of the rest of us will lend interest-free to councils in high population growth areas.  The Deputy Governor opines that this will “help to relieve an important constraint”, except that (a) he references no analysis in support of this claim, which is perhaps not surprising as (b) no one has yet  seen the details of the fund, which appeared to many to be more about getting a weekend’s headlines rather than making a very material difference to the housing situation (recall that it is a $25m per annum interest subsidy, which doesn’t seem likely to make very difference to anything that matters to a macro-focused agency).

Similar comments could be made about the Deputy Governor’s views on taxes or Urban Development Authorities (compulsory acquisition wasn’t explicitly mentioned, but I assume he is probably sympathetic).  It is tempting to lodge an OIA request asking for copies of the analysis the Bank used in support of each of these policy preferences, but it is easy enough to guess how little there would be.  After all, Spencer has form.  In his speech last year, he advocated introducing a capital gains tax.  When I asked for the analysis etc in support of that proposal –  and was pretty sure there was none, as I’d left the Bank only a couple of weeks earlier and had previously written any material the Bank had on CGTs – it boiled down to a single brief email.   It really isn’t good enough.

I could go on.  The Bank has still produced no analysis that looks  carefully at the international experience of the last decade, including considering the countries where house prices did fall sharply and, as importantly, those where they did not.  Instead, they cherry-pick a couple of countries with bad experiences, and don’t ever stop to analyse the similarities and differences between those countries and their policy interventions and the New Zealand situation.  They have still produced nothing explaining why they think the risks are now so much greater than in 2007, even though the banks’ buffers are bigger, and any mood of exuberant optimism is much more attenuated.  While I was still at the Bank I used to pose that latter question to Grant, and never got a serious attempt at a response.

The Bank also continues to anguish about the low level of global interest rates –  the same attitude that has continued to leave them (and the Governor specifically) too reluctant to simply do their main job and keep inflation near-target.  But even there, what they have to offer is unconvincing.  We are told that low real interest rates are “a worldwide phenomenon linked to post-GFC caution”, with no mention of the weak underlying productivity growth and demographics pressures that are at play.  In other words, they treat low interest rates as some exogenous event, rather than something that is an endogenous response to the apparently poor fundamentals, here and abroad.  Partly as a result we get anguishing about low interest rates driving up house prices, rather than a considered reflection on what it is that means interest rates in New Zealand need to be as low –  or lower –  than they are.  For example, real per capita income growth is much less than it was.

Related to this, they simply ignore how not-very-widespread any serious housing market stresses really are.  If low real interest rates were a major factor in the overall house price story we might reasonably have expected to see real house prices well above where they were at the end of the last boom.  After all, at the end of that boom the OCR was 8.25 per cent, and today it is 2.25 per cent.  Inflation expectations have fallen of course, but real interest rates are a lot lower than they were.

House prices not so much.  I downloaded the QV house price index data.   On the QV numbers, house prices nationwide have risen 18.5 per cent since the peak in 2007.   But the CPI has risen 18.1 per cent over that period. In other words, in real terms nationwide house prices are barely changed from where they were in 2007, despite the sharp fall in real interest rates –  and the boom that peaked in 2007 was much bigger credit event than what we have seen so far, and didn’t end in banking system stresses.

In fact, plenty of places in New Zealand have real house prices today materially lower in real terms (and sometimes in nominal terms) than they were in 2007.  Here is an illustrative chart from the QV data

qv house prices since 2007 peak

Of course, the overall level of house (and urban land) prices in New Zealand remains far too high –  far higher, relative to incomes, than in the vast swathes of the US with well-functioning housing supply markets –  but in terms of the last decade or so, what we have had in mostly an Auckland boom.  It is a very big boom in Auckland – as one might expect when unexpectedly rapid population growth collides with land use restrictions – and Auckland is a big place in a New Zealand context, but it is hardly a nationwide phenomenon.    There is some spillover from Auckland to places like Hamilton, and the earthquake related pressures put, probably temporary, pressures on prices in Christchurch and surrounds. But vast swathes of the country –  including our now second largest city –  have seen no real house price inflation over almost a decade, or in some cases really quite substantial falls.  There are plenty of smaller TLAs that I haven’t shown individually –  and almost all of them have had falling real prices –  but they are included in the overall New Zealand number.

One would know nothing of this from reading the Spencer speech.  And quite why the Bank considers it appropriate to have tight controls on access to housing finance in Gisborne, Wanganui and Invercargill remains a mystery –  perhaps the new consultative document will shed some light, but I rather doubt it.

The citizens of New Zealand deserve (a lot) better from the Reserve Bank –  and frankly, from those charged with holding it to account.  Of course –  since the housing problems are primarily a responsibility of the government –  we also deserve a lot better from the government.  Sadly, the Reserve Bank continues to take responsibility on itself for something it is not charged with, and then does not back up its claims with the standard of analysis and research that we have a right to expect.  Far-reaching reforms are needed –  different governance structures, reformed legislation, and different people across the top ranks of the Bank.