We would have been attentive to the opacity around the ABS market; and to the cliff effects stemming from mechanistic reliance on rating agency ratings by banks, investors and regulatory regimes. And, finally, I trust that we would have been more exacting in following up the early-2000s’ G10/Financial Stability Forum report on the difficulties of resolving Large Complex Financial Institutions. Some of those interventions would have addressed long-standing structural faultlines in the global financial system. Others, perhaps more speculatively, would have been contingent on cyclical conditions. For example, a respectable macroprudential authority would ideally have tightened banks’ capital requirements against exposures to property and to shadow banking. Perhaps more compellingly, I think a macroprudential authority equipped with powers to do things would at least have asked whether the system was sufficiently resilient given a pervasive sense, from the market itself, that risk was underpriced. BIS central bankers’ speeches  7  Lo and behold, the sphere of influence of the FPC will come via both “structural” and “cyclical” instruments.7 Once the legislation is in place, the FPC will be able to make Recommendations, on a “comply or explain” basis, to the Prudential Regulation Authority and to the Financial Conduct Authority (the planned securities markets-cum-consumer regulator) on their rules and policies. And the FPC will also be able to Direct the microregulators to take certain kinds of action, to be set out in secondary legislation; that is so that our Parliament decides the spheres in which the microregulators will be obliged to follow the FPC’s lead.
Or the incentives, here in the USA, for Government Sponsored Enterprises such as Fannie and Freddie – massive players in global capital markets and so with a significance stretching beyond your borders – to take on more risk in lending to poorer households. Or for banks to badge illiquid ABS tranches as trading positions in order to benefit from much lower Trading Book capital requirements. Or for banks to move credit portfolios to off-balance sheet vehicles supported by liquidity lines against which no regulatory capital had to be held. I could go on and on. The microeconomics of finance matters hugely to stability. The faultlines of the system are sometimes obscure. And a macroprudential authority needs, therefore, to be attentive to the complex ways in which the different parts of the financial system interact, generating leverage and liquidity risk. Threats may often be buried in the complex details of the system – subprime CDO2, conduits and SIVs etc in the latest crisis; investment trust cross holdings in the 1920s – but the task is to make the connections without getting lost in the trees. Which brings me from scene setting to the real world of the new UK framework. The UK’s new Financial Policy Committee Who we are The FPC exists. We will hold our first formal policy meeting in June. We are a Committee of eleven.