Broad-based credit growth outpacing nominal economic growth. Although driven by housing credit, consumer and corporate credit is also rising. And that includes investment, as the CNB noted. But here we run into a classic macroprudential policy dilemma. Since it is clear that, on the one hand, investment loans are needed to increase the economy's potential (or maintain it) or to reduce structural problems, to which the CNB's other capital buffer associated with systemic risks responds.
The CNB argues for decreasing risk weights and lower loan loss provisioning ratios, also due to the low share of problem assets. Since the lower risk level is also part of the stronger profitability of the banking sector, the CNB has probably decided to lock in some of the bank profits in the form of a higher CCyB. Its higher level will be supported by a higher estimate of expected losses, as the CBN expects the 12-month default rate in the corporate sector to rise, probably due to the aforementioned higher debt ratio and a decline in profits in the economy due to higher wage growth. This reflects lower productivity growth. Clearly, this issue has wider implications for economic policy. Unfortunately, however, it is more in the area of regulatory and stabilisation policy, but not so much in structural economic policy.
In addition to the higher phase of the financial cycle, I think the harsher stress test in the Financial Stability Report and the change in fiscal policy and its impact on the financial sector have contributed to this view. First things first.
(1) The adverse economic scenario (with about a 15% decline in economic output over three years) sends the banking sector into an across-the-board loss in one year, whereas previous scenarios did not foresee an across-the-board loss. However, we will not have the details of the scenario until 22 June.
- Bank capital adequacy would fall below 16% from 23% at the start of the test
- Half of the sector would use the entire CCyB, part of the SyRB and some banks would break other non-releasable capital buffers
2. The link between the fiscal and banking sectors poses an additional risk in a deterioration of the fiscal position. The CNB argues that there is a risk of additional vulnerability of the financial system with the current high share of government bonds on banks' balance sheets (around 15% or 20% after excluding repo operations at the CNB). The dominance of banks in holding Czech government bonds (around 43% of total holdings) also plays a role.
3. Growing dynamics in investment funds (but government retail bonds are likely to fit here). The CNB has done sensitivity scenarios of a shift of deposits from banks to investment funds (but government retail bonds also fit here, although the CNB has not mentioned them). This shift (quantification of which is likely to be in the Financial Stability Report) would reduce banks' interest profits and hence capital adequacy by 0.2 pp.
Although the CNB has left the systemic risk buffer (SyRB) unchanged at 0.5%, the CNB warns that it is prepared to increase it in the event of an escalation of geopolitical risks. The issue of the sectoral systemic buffer was not mentioned in the discussion, given the buoyant mortgage market, as it was earlier (we will see more in the minutes of the 22 June meeting). In the sensitivity scenario, the CNB assumes that a further shock to energy prices would reduce the capital ratio by 0.2 pp.
In contrast, the CNB is prepared to dissolve both buffers if risks materialize into bank credit losses.
The CBN also provided its view on the mortgage market and does not expect a blanket reintroduction of DTI and DSTI requirements. For now, it is waiting because of the obscuring effect of data frontloading on so-called investment mortgages. However, it does not believe that current developments should lead to a blanket reintroduction of DTI and DSTI requirements. One argument is that the aforementioned frontloading is driven by mortgages to wealthier households, whereas the current LTV requirements for non-investment mortgages are only exceeded in 1.5% of cases (vs. the 5% exemption). The CNB assumes that 6% house price growth would be more neutral for the real estate market . Thus, for mortgage loans, the CNB has left the measure unchanged, i.e. 70% LTV and 7x DTI for so-called investment mortgages, 80 and 90% LTV for conventional mortgages with the across-the-board DSTI and DTI requirements turned off.
We will analyse the decision further after the release of further information from the CNB, on 5 June for the justification of the CCyB increase and on 22 June when the full Financial Stability Report is released.