speeches · May 17, 2018
Regional President Speech
Loretta J. Mester · President
A Practical Viewpoint on Financial System Resiliency and Monetary Policy
Loretta J. Mester
President and Chief Executive Officer
Federal Reserve Bank of Cleveland
Third Annual ECB Macroprudential Policy and Research Conference
European Central Bank
Frankfurt, Germany
May 18, 2018
1
Introduction
I thank the European Central Bank for inviting me to participate in this conference on macroprudential
policy and research. The work being undertaken at the ECB, other central banks, and universities has
increased our knowledge and understanding about the interlinkages between the macroeconomy and
financial systems. It has been nine years since the financial crisis, and the global economy has improved
substantially over that time. In the U.S., the economy is near both of our monetary policy goals of
maximum employment and price stability, and the outlook is one of the most favorable we have seen in a
long time. As we move further from the crisis, one lesson can never be lost: the importance of
maintaining a resilient financial system for a healthy economy. Today, I’ll spend my time discussing
monetary policy and macroprudential policy from the practical perspective of a U.S. monetary
policymaker. Research informs our policy decisions, but at the end of the day, decisions have to be made
in a world that doesn’t match our models and without full information. Research can be elegant, practice
rarely is, but when we are setting policy, effectiveness is what we strive for. Before I continue, I should
note that the views I’ll present are my own and not necessarily those of the Federal Reserve System or my
colleagues on the Federal Open Market Committee.
U.S. Financial System Regulation and Macroprudential Tools
It is an understatement to say that the U.S. financial system’s regulatory structure is complex. A wide
variety of institutions offer financial services in the U.S. Banks, a category that includes commercial
banks, savings and loans, and credit unions, provide only about a third of the credit in the nation. Other
providers include insurance companies; mutual funds; pension funds; government-sponsored enterprises,
including Fannie Mae and Freddie Mac, which issue mortgage-backed securities; and other nonbanks,
including broker-dealers, finance companies, and mortgage real estate investment trusts.1
1 See Fischer (2014).
2
At the federal level, there are multiple financial regulators, including the Federal Reserve, the Federal
Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency, the National Credit
Union Association, the U.S. Treasury, the Securities and Exchange Commission, the Commodity Futures
Trading Commission, the Consumer Financial Protection Bureau, and the Federal Housing Finance
Agency. There are financial system regulators at the state level as well. In many cases, the regulatory
authority of these agencies is defined by type of institution rather than by financial instrument.
The 2008 financial crisis exposed gaps in the regulatory and supervisory architecture in the U.S., which
contributed to a build-up in financial imbalances and systemic risk. The Dodd-Frank Act, signed into law
in 2010, established provisions aimed at reducing the probability of another financial crisis and reducing
the costs on the rest of the economy when a shock hits the financial system. It directed the regulatory
agencies to augment their traditional microprudential approach, which focused on the safety and
soundness of individual institutions, with a macroprudential approach, which encouraged assessing the
risk across institutions. Dodd-Frank also created a new body, the Financial Stability Oversight Council
(FSOC), to promote coordination and information sharing across the financial system regulators. An
important power of the FSOC is its ability to designate nonbanks as systemically important, bringing
them under more banking-type supervision and regulation. The Board of Governors of the Federal
Reserve System has the responsibility for supervising systemically important financial institutions,
including these FSOC-designated nonbank financial companies, large bank holding companies, and the
U.S. operations of certain foreign banking organizations.
This complex system of institutions and regulators complicates risk monitoring and the ability to tailor
regulations and supervisory oversight to potential risks to the financial system. But there are ongoing
efforts in the U.S. to do so, and the Federal Reserve has developed a framework for systematically
tracking financial stability risks. Before I describe the framework, let me spend a few minutes on why the
3
FOMC regularly reviews financial stability, even though financial stability is not an explicit part of the
FOMC’s monetary policy mandate.
Financial Stability and Monetary Policy
Financial stability matters to the FOMC for several reasons. First, monetary policy affects the real
economy by affecting financial conditions. When financial markets are disrupted, as they were during the
financial crisis, the transmission of monetary policy to the economy can also be disrupted. Second, the
goals of monetary policy and financial stability are interconnected. Indeed, the FOMC’s statement on its
monetary policy strategy says that the FOMC’s monetary policy decisions “reflect its longer-run goals, its
medium-term outlook, and its assessments of the balance of risks, including risks to the financial system
that could impede the attainment of the Committee’s goals.”2 Financial stability is a necessary but not
sufficient condition for macroeconomic stability. On the other side of the coin, macroeconomic stability
is an important contributor to financial stability, and well-formulated and well-communicated monetary
policy supports financial stability.
A third reason monetary policymakers need to consider financial stability is that the financial crisis
changed how monetary policy is implemented. From a practical standpoint, monetary policymakers have
to be more attuned to developments in financial markets and institutions than they once were. The actions
taken to address the financial crisis and Great Recession increased the size and changed the composition
of the Fed’s balance sheet. The Fed is now transacting with a broader set of financial institutions, so
policymakers have to have a more complete understanding of the plumbing in financial markets.
2 See FOMC (2018).
4
The Fed’s Framework for Monitoring Financial Stability
The basic framework used by Federal Reserve staff to monitor financial stability risks recognizes the
complex nature of the financial system in the U.S., with its mix of bank-based and market-based finance
and its multiplicity of regulatory and supervisory bodies.3 The framework tracks a standard set of
financial system vulnerabilities that could amplify and propagate shocks. It monitors these vulnerabilities
using a set of indicators on various financial activities in four categories: asset valuation pressures
(reflecting the price of risk and risk appetites among investors), leverage, maturity and liquidity
transformation, and interconnectedness and complexity.4 Some of these vulnerabilities, like leverage,
vary over the business and financial cycles; others, like complexity, are more structural in nature,
reflecting the design of markets and intermediaries. The vulnerabilities are assessed across four sectors of
the economy: the banking sector; the nonbank financial sector, including capital markets, nonbanks, and
shadow banks; the nonfinancial business sector; and the household sector. Tools like heat maps and data-
visualization techniques aid in tracking changes in vulnerabilities over time.5 Assessments of individual
vulnerabilities are then combined to get an assessment of the overall vulnerability of the U.S. financial
system. Recognizing the global interconnectedness of financial systems, the Fed staff has also developed
tools to assess foreign financial stability.6
Four times a year, the staff uses this framework to brief the FOMC, and an evaluation of developments
related to financial stability is now a regular section in the Board of Governors’ monetary policy report to
Congress.7
3 See Adrian, Covitz, and Liang (2013, 2015).
4 Important research on the propagation and amplification of shocks throughout the financial system includes
Kiyotaki and Moore (1997), Brunnermeier and Sannikov (2014), and Gorton and Ordoñez (2014).
5 See Aikman, et al. (2015a, 2015b).
6 For example, see FOMC (2017), page 5.
7 See Board of Governors (2018a).
5
Macroprudential Policy and Monetary Policy
Although the FOMC regularly discusses financial system stability, the financial system regulators,
including the Federal Reserve Board of Governors (a group that is distinct from the FOMC), have
responsibility for maintaining and enhancing the structural resilience of the financial system. In the U.S.,
structural resilience is promoted by requiring higher levels and quality of capital (including a minimum
non-risk-based leverage ratio, as well as risk-based capital standards); conducting stress tests; imposing
liquidity standards; developing effective resolution methods for systemically important banks and
nonbank financial institutions; requiring large banks to submit living will resolution plans; and
implementing reforms to improve the stability of certain nonbank markets.8 Financial regulators are also
focused on working with the industry to enhance strategies to improve the cyber resiliency of the financial
sector, as cybersecurity risk is a continuing threat to financial stability.
In contrast to the structural tools, compared to other countries, the U.S. has fewer countercyclical tools
that can be varied with the perceived level of vulnerabilities in the financial system. However, the stress
tests can be used as a countercyclical tool to the extent that the vulnerabilities of concern can be built into
the stress scenarios. For example, this year’s adverse stress scenario includes deep declines in corporate
bond and real estate prices.9 Another cyclical tool available in the U.S. is the countercyclical capital
buffer (CCyB), which can be imposed on internationally active banks. The Federal Reserve Board has
indicated that it will use this tool only when systemic vulnerabilities are “meaningfully above normal”
and that, when using the tool, it intends to increase the buffer gradually.10 The Board anticipates giving
8 The Securities and Exchange Commission implemented revisions to the regulations governing money market
mutual funds in 2014 and 2016 to reduce the chance of investor runs on these funds. In 2009, the G20 countries
agreed that standardized over-the-counter derivatives contracts should be cleared by central counterparties. There
are limits to interday credit exposures in the tri-party repo market.
9 See Board of Governors of the Federal Reserve System (2018b).
10 See Board of Governors of the Federal Reserve System (2016). Other countries have used limits on loan-to-value
ratios and debt-to-income ratios that vary over the cycle and are targeted to particular sectors like housing or
household credit to control leverage. See Liang (2013) and Fischer (2014).
6
banking organizations 12 months before an increase would become effective.11 The U.S. has not had
much experience with this tool. It has yet to set a positive countercyclical capital buffer, even though
countercyclical policy calls for building up buffers during good times so that they are available during bad
times. And the lead times needed to use this tool likely make it less effective at addressing vulnerabilities
that may rapidly develop or may be detected only after they have had time to develop. So focusing on
increasing the resiliency of the financial system’s structure across the business and financial cycles seems
well-founded. And from a practical viewpoint, even if, in theory, using countercyclical tools might be
preferred, their limits suggest we need to at least contemplate using monetary policy to address financial
stability in some cases.
Indeed, the limits to the macroprudential tools were illuminated in a tabletop exercise in which I
participated with some other Federal Reserve Bank presidents.12 The exercise involved a hypothetical
scenario in which commercial real estate prices were rising sharply but the economy was at full
employment and inflation was somewhat below goal. The objective of the exercise was for policymakers
to use available macroprudential tools and possibly monetary policy to reduce the risk posed to financial
stability by the commercial real estate boom while fostering the Fed’s monetary policy goals.
Implementation challenges included having to coordinate across multiple regulators or, in some cases, to
follow legally required administrative procedures like public comment periods, which delay application
of the tools. Such delays could make the tools ineffective or even cause them to exacerbate the situation
rather than shore up the financial system. Another limitation was that some tools applied only to
regulated banking firms, which could result in risks shifting to other parts of the financial system. I came
away from the exercise more convinced of the need to focus on the structural resilience of the financial
system across the business and financial cycles.
11 See Board of Governors of the Federal Reserve System (2017).
12 See Adrian, et al. (2015).
7
Whether monetary policy should be used to address financial stability risks, such as sharply rising credit
growth, is still an open question.13 The benefits depend on the extent to which monetary policy would be
effective at stemming financial imbalances, thereby lowering the probability of a financial crisis or
limiting the effects of the crisis, and whether or not there are macroprudential tools that could be used
instead. Any benefits of attempting to use monetary policy to stem financial imbalances would need to be
weighed against the cost of slowing the economy and increasing the volatility of output and of inflation.14
Let me now turn to the practical question of how the decisions about financial stability policy and
monetary policy might effectively be organized, and then end with some conclusions.
The Governance of Financial Stability Policy
I argued earlier that the goals of monetary policy and financial stability policy are complementary over
the longer run. But the policies do interact, and at times, there can be short-run trade-offs between
monetary policy actions taken to support macroeconomic stability and financial stability. For example, an
extended period of very low interest rates aimed at returning the macroeconomy to health might also
generate financial imbalances and pose potential risks to financial stability by spurring investors to search
for yield. Or a tightening of macroprudential policy to address financial stability risks could result in
tighter financial conditions more generally, thereby increasing the likelihood that a monetary policy
response would be needed to promote macroeconomic stability.
13 Borio, et al. (2018) argue that monetary policy should be more attentive to the financial cycle. Svensson (2017)
argues against “leaning against the wind.” International Monetary Fund (2015) and Smets (2014) review the
literature on the use of monetary policy for financial stability.
14 An interesting paper by Gourio, Kashyap, and Sim (2017) shows that the cost-benefit analysis depends on the
nature of the shocks hitting the economy and the severity of the financial crisis. In the case of only demand and
productivity shocks, having monetary policy focus only on macroeconomic stability also limits the probability of a
financial crisis. But when there are financial shocks and when a financial crisis would have a large negative impact
on the economy, using monetary policy to limit credit growth would increase welfare, even though it would mean
higher volatility of output and inflation.
8
In many countries, responsibility for monetary policy and responsibility for financial stability policy are
handled by two different committees, which, in some cases, have some members in common.15 Canada’s
financial sector regulator is not part of the central bank, but the Bank of Canada assesses financial system
vulnerabilities and risks and publishes this assessment twice a year.16 In Sweden, the financial stability
authority is not part of the central bank, but the central bank publishes a financial stability report and its
governor sits on the financial stability council, an advisory board. The ECB is somewhat different, with
responsibility for both monetary policy and macroprudential policy ultimately resting with the ECB
Governing Council.
The U.K. has a two-committee structure housed within the Bank of England. The monetary policy and
financial policy committees are independent, but they also share members, which allows for good
communication and information sharing between the two committees. One example of coordination came
in August 2013 when the Bank of England’s Monetary Policy Committee initiated forward guidance that
it would hold interest rates low and consider additional asset purchases at least until the unemployment
rate had fallen to 7 percent.17 But it also said that a condition that would vacate this guidance would be if
the Bank of England’s Financial Policy Committee found that the stance of monetary policy was
threatening financial stability in a way that couldn’t be contained by the available macroprudential tools.
In the U.S., financial system complexity means that we don’t have a single authority that oversees
financial stability. While the Financial Stability Oversight Council (FSOC) has the ability to designate
firms as systemically important financial institutions and, therefore, subject to enhanced regulation by the
15 Kohn (2015) discusses the benefits of what he calls this two-committee approach.
16 See Bank of Canada (2017).
17 Kohn (2014) discusses this example, and see Bank of England (2013).
9
Fed, the FSOC does not have the authority to take actions to mitigate emerging risks. Instead, it can
make recommendations to the regulatory agencies and to Congress, which can then decide to act or not.18
But all is not lost. With its oversight of systemically important financial institutions, the Board of
Governors plays an important role in setting macroprudential policy in the U.S. The Board also
constitutes part of the FOMC, so that there is a potential for some coordination between macroprudential
policy and monetary policy or, at the very least, good communication and information sharing. In some
sense, the U.S. has a two-committee set-up and one could imagine a relationship between the FOMC and
the Board of Governors similar to that between the two policy committees in the U.K.
In the U.S., housing both committees within the central bank has an important governance benefit. By
design, the FOMC’s monetary policy decisions are independent from short-run political considerations,
with appropriate accountability to elected officials and the public. Similarly, it is also important that
policymakers have some independence in setting macroprudential policy.19 There will be times when
tools have to be used well before there are clear signs of instability. This might be difficult to explain,
and there may be various interests that would prefer the tools not be invoked in seemingly good times.
This means that macroprudential policymakers should be communicating with the public to improve the
public’s understanding of how financial stability risks are being monitored, what tools are available to
promote financial resilience, and the rationale for macroprudential policy decisions. Systematic and
transparent application of financial stability policy would seem to be as important as it is in the conduct of
monetary policy. Still, we are a distance away from being able to articulate a clear strategy and a set of
principles to guide decisions about the circumstances under which monetary policy should be used as a
tool for financial stability and when we should rely upon macroprudential tools.
18 Kohn (2014) compares and contrasts the financial stability structure in the U.S. with that in the U.K.
19 Kohn (2014) discusses the importance of the financial stability authority being able to pursue its goals
independent of short-run political considerations even when the actions taken aren’t popular.
10
Conclusions
Let me conclude with three points I take away from this practical viewpoint on financial resilience and
monetary policy in the U.S.
First, given some of the limitations on macroprudential tools and the complexity of financial system
regulation, ensuring the structural resilience of the financial system throughout the cycle is the first line of
defense in promoting financial stability. Higher levels and quality of capital, liquidity standards, stress
tests, living wills, and effective resolution methods for systemically important bank and nonbank financial
institutions are all important tools for improving resilience. In my view, we should set standards for the
structural resilience tools somewhat higher than they would be if we had more experience with and
confidence in the countercyclical tools. I support efforts to better align regulation and supervisory
oversight with where the potential system risks lie, including proposals to make regulation less
burdensome on community banks in the U.S. However, I think it would be a mistake to unwind the steps
taken since the financial crisis that have led to a more resilient financial system. I would like to see how
the new settings perform throughout the cycle before making major changes.
Second, monetary policymakers need to monitor the resiliency of the financial system and be cognizant of
the interlinkages between monetary policy, financial imbalances, and financial stability risks. In a
situation of rising financial stability risks, while using macroprudential tools might be preferred, we have
had little experience with these tools. If they proved to be inadequate and financial stability risks
continued to grow, monetary policy should be on the table as a possible defense. Note that, in this case,
the blurring between financial stability goals and monetary policy goals would be high: if we assessed the
risks to financial stability to be sufficiently great, achieving our dual mandate monetary policy goals
would also be in jeopardy over the medium run.
11
Third, it will be important for the FOMC and Board of Governors to make progress toward a systematic
strategy for handling the interactions between monetary policy and financial stability, including the
appropriate use of monetary policy to counteract financial imbalances, and to communicate this strategy
to the public. There are two concrete steps the Federal Reserve can take now. The Fed can continue to
hold tabletop exercises designed to illuminate the interactions between macroprudential policy and
monetary policy. These scenario exercises can help clarify policymakers’ views on the appropriate use of
each type of policy and help the Federal Reserve develop a systematic strategy for dealing with the
interactions between the policies. In addition, similar to other central banks, the Fed can develop and
publish a financial stability report, which discusses the Fed’s assessment of financial system
vulnerabilities. This report could also provide more context for the Board’s decisions about the
countercyclical capital buffer and any regulatory guidance aimed at mitigating emerging risks.
In summary, I believe the steps taken since the financial crisis have made the financial system more
resilient. Today, systemically important financial institutions have higher capital and liquidity buffers
and better risk-management systems. However, we cannot take greater resiliency for granted. If, as many
economists predict, the new normal is a world with lower equilibrium interest rates, then the interactions
between monetary policy and financial stability are likely to remain center stage. It’s important that we
come to some clarity about how we will use all of our policy tools to promote a healthy macroeconomy
and resilient financial system.
12
References
Adrian, Tobias, Patrick de Fontnouvelle, Emily Yang, and Andrei Zlate, “Macroprudential Policy: Case
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30, 2015, revised December 2015.
(https://www.bostonfed.org/publications/risk-and-policy-analysis/2015/macroprudential-policy-case-
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Adrian, Tobias, Daniel Covitz, and Nellie Liang, “Financial Stability Monitoring,” Finance and
Economics Discussion Series (FEDS) paper 2013-21, Divisions of Research and Statistics and
Monetary Affairs, Federal Reserve Board, March 2013.
(https://www.federalreserve.gov/pubs/feds/2013/201321/201321pap.pdf)
Adrian, Tobias, Daniel Covitz, and Nellie Liang, “Financial Stability Monitoring,” Annual Review of
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(http://www.annualreviews.org/doi/10.1146/annurev-financial-111914-042008)
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13
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14
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Cite this document
APA
Loretta J. Mester (2018, May 17). Regional President Speech. Speeches, Federal Reserve. https://whenthefedspeaks.com/doc/regional_speeche_20180518_loretta_j_mester
BibTeX
@misc{wtfs_regional_speeche_20180518_loretta_j_mester,
author = {Loretta J. Mester},
title = {Regional President Speech},
year = {2018},
month = {May},
howpublished = {Speeches, Federal Reserve},
url = {https://whenthefedspeaks.com/doc/regional_speeche_20180518_loretta_j_mester},
note = {Retrieved via When the Fed Speaks corpus}
}