I have no doubt that, in these two days, both supervisors and financial stability policy-makers will have a constructive and enriching dialogue with academia on macroprudential policy. Macroprudential institutional framework in Spain: the creation of AMCESFI The timing of the conference is particularly important for us, since our new macroprudential institutional arrangements have just been set up. In early 2019 the Spanish Macroprudential Authority – Financial Stability Board (AMCESFI by its Spanish acronym) was created. Its main goal will be to contribute to the promotion of coordination and the exchange of information on financial stability issues among the Banco de España, the Ministry of Economy and Enterprise, the Spanish National Securities Market Commission and the Directorate-General of Insurance and Pension Funds. Such an institution provides Spain with a structure similar to that of other EU Member States, in line with the recommendations issued by the European Systemic Risk Board and the IMF. In parallel, the supervision of the financial system was reinforced, extending the range of macroprudential tools available to the sectoral supervisory authorities, which remain individually responsible for deciding when they should be activated. In particular, the Banco de España is now empowered to require banking institutions to establish countercyclical capital buffers by credit segment, limits on concentration in relation to economic activity sectors, and limits and conditions when underwriting new loans (in terms of loan-to-value, loan-to-income and debt service-to-income, and also the maturity, the currency in which the operation is denominated and whether the interest rate is fixed or variable, among others).
In addition, as this buffer is demanded on all exposures, nothing guarantees that its release will affect the provision of credit in a specific jurisdiction. The other instrument in the macroprudential policy-maker’s toolkit to address non-cyclical risks is the systemic risk buffer. Here, we welcome the European initiative to allow its application to sectoral credit portfolios, thus providing it with more flexibility. Finally, let me also stress that, for the moment, the bulk of macroprudential tools affect banks exclusively. While banks continue to account for most financial intermediation, they are losing relevance and could do so even more in the future. This can give rise to regulatory arbitrage and undermine the effectiveness of macroprudential tools. The Spanish case is to some extent innovative5, as similar borrower-based tools to those granted to the Banco de España were given to the financial markets authority (CNMV) and the insurance supervisor for their own sectors. Thus, one of the tests for the Spanish macroprudential institutional setting will be whether it is able to achieve enough coordination across authorities to maximise the effectiveness of the macroprudential toolkit. In any event, we should bear in mind that global financial integration can also have similar effects to the domestic development of the non-bank financial sector, with banking and non-banking entities operating in different jurisdictions. Especially in this last area, major steps have been taken (with reciprocity agreements); but there is still ample room for improvement. I am sure we will be able to address these challenges in future editions of this conference.