This should lead us to reflect on how we can increase the macroprudential space available, thereby extending the capacity to mitigate the effects of future crises, both those originating in macrofinancial disequilibria that are endogenous in the economy and those arising from factors exogenous to the financial sector. Some national authorities, in countries such as the United Kingdom, have added flexibility to the implementation of the original CCyB framework developed by the BCBS to require the accumulation of a countercyclical capital buffer in the absence of warnings about systemic imbalances based on the credit-to-GDP gap metric. It would suffice for the economy not to be in a recessionary environment to call for a positive CCyB that can be released when any shock leading GDP to stand below its potential should materialise. Events surrounding the COVID-19 shock, from a source completely external to the financial system, have demonstrated the goodness of this approach in the use of the CCyB. This discussion has a bearing on other matters, such as the optimum level of capital that banks should maintain, and the most suitable composition of this capital: structural requirements versus cyclical/releasable requirements, microprudential requirements versus macroprudential requirements, and discretionality versus rules. It is, therefore, a complex discussion requiring detailed analyses well-grounded in empirical and theoretical evidence. Second, I would like to stress that we must also reflect in the coming years on the development of macroprudential policy for the so-called “non-bank segment” of the financial system, i.e. in the area of securities markets and insurance companies.
In any event, the Banco de España has in fact indicated that it will not activate this instrument for a long period of time, at least not until the main effects of the crisis have been absorbed. With this approach it is sought to eliminate banks’ potential uncertainty as to when to build up capital buffers, which might discourage their provision of credit to the private sector. 7  For a detailed summary of country-by-country macroprudential measures, see Box 3.1 of the Spring 2020 Financial Stability Report and the article by Anguren, Gutiérrez de Rozas et al. (2020). 16  We can draw lessons from our experience of the crisis on the usefulness of some of the indicators used for the activation of macroprudential tools. This is the case of the credit-toGDP gap. After the pandemic broke, this indicator increased significantly and has held at values of over 2 percentage points (pp), which is the warning threshold on the basis of which the Basel framework recommends activating the CCyB. However, it should be borne in mind that this increase in the credit-to-GDP gap has been largely due to the very stimulus policies for the economy applied by the authorities and, above all, to the adverse impact on GDP of the COVID-19 shock. Hence, in situations such as the present, the Basel framework itself acknowledges that it is necessary to complement the information provided by the indicators habitually used in upturns with other indicators offering information on the degree of materialisation of systemic tensions.