Should stress test models be country specific? Why UK banks would fail the 2014 tests based on Spanish models. Burkhard Heppe, Open Source Investor Services B.V. (OSIS) [email protected], 17 December 2014, Version 0.1 1 Abstract We explore whether results form recent supervisory stress tests across Europe reflect a level playing field where local supervisors approved broadly consistent models. Did banks take advantage of different regulatory regimes making stress test results and capital ratios hard to compare across countries? We find that banks use widely different sensitivities to macroeconomic variables like GDP, house price changes and the unemployment rate in the recently published EU-wide stress test conducted by the European Banking Authority (EBA) and the European Central Bank (ECB). Based on the detailed and unprecedented disclosure of EBA we estimate implied macro sensitivities for a large number of bank, country and exposure class combinations and find significant differences between countries and banks. We find that UK or German banks use smaller sensitivity parameters on average compared to the more conservative parameters used by the beleaguered Italian or Spanish banks. We look at historical performance data in different countries to check whether the observed differences may be justified. As a robustness check for the recent stress test, we estimate the credit impairments of UK and German banks using the more conservative parameters that we estimated for Spain or Italy. We estimate that the four major UK banks would have failed the EBA stress test (and also the more stringent Bank of England stress test) using Spanish average sensitivity parameters indicating that the playing field may not have been level. 2 Introduction The recent financial crisis that started in 2008 has been felt all over Europe, but the relative magnitude of the impact in terms of asset price declines (especially for real estate), unemployment rates and loss of output has varied widely with southern European countries suffering more and northern countries like Germany, the UK or Scandinavia suffering less. The burst of the house building bubble in Spain and Ireland resulted in large increases in unemployment that persist to this day whereas the recession of 2009 was short lived in Germany achieving a balanced federal budget in 2014 and UK house price indices have recently hit all time highs. Moreover, credit risk indicators like the nonperforming loan (NPL) ratio 1 have increased several fold in Spain and Ireland since 2009 whereas they have been quite stable in Germany and the UK. Hence, it appears that credit dynamics are indeed highly country specific. Based on the data recently disclosed by EBA for the 2014 EU-wide stress test we estimate simple stress testing models and their key sensitivities to macro economic variables. We find that UK or German banks use much smaller sensitivity parameters on average compared to the more conservative parameters used by Italian or Spanish banks. Using publicly available aggregate measures of credit risk we then investigate whether the observed model discrepancies between large European economies can be justified. As noted before (Heppe 2014b), there is an important analogy between macro sensitivities and the asset correlation parameter in the Basel II capital requirements for which Basel prescribes the same parameters across all countries. Correlation and macro sensitivity parameters are hard to estimate unless long historical time series are available spanning several economic cycles. In practice for the bottom up approach that was followed by EBA, such data are rarely available resulting in uncertain model parameters. The annual Pillar 3 reports for many banks include some information about the length of historical data available to estimate regulatory stress test models. From looking at a small sample of Pillar 3 reports we can see that banks in many instances have less than 10 years of data available potentially resulting in models with a high degree of uncertainty. In light of this, we argue that a complementary and transparent top down approach with consistent and perhaps more homogenous model assumptions across countries and banks could be useful to achieve a more level playing field for banks across Europe. First, we provide a brief overview about the academic literature on stress testing credit risk in multiple countries. Second, we summarize our analysis of the EBA EU-wide stress test data and the estimation of implied macro sensitivities. Third, we compare macro sensitivities for a number European countries and banks. Fourth, to benchmark the implied models from the EBA data, we estimate country specific stress test models for the UK and Spain against longer histories of aggregated credit performance measures. Fourth, we estimate credit impairments for banks using more homogenous model parameters across countries. In particular, we calculate the CET1 ratio for some UK and German banks using more conservative macro sensitivities similar to the ones used in the EBA stress test in Italy and Spain. While the publicly available loan performance data suggest some differences between countries, we recommend that banks should also be required to conduct their stress tests with more homogeneous top down assumptions for a more level playing field in Europe. 3 Literature review Several studies have shown that credit performance indicators vary with the economic cycle with higher defaults and losses being correlated with rising unemployment or falling GDP or residential real estate prices (e.g. Hirtle et al. 2014 for the US and Henry Kok 2013 for Europe). Most research on credit stress testing focuses on exposures in a single country and central banks regularly publish country specific credit risk analysis and macro stress test results in their financial stability reports (Čihák 2012). Cross-country comparisons of stress 2 test models are rare. Published stress test models designed to fit individual countries vary in their econometric specification and in terms of the choice of macro variables used, which makes a cross-country comparison impossible without access to the underlying data. Jakubik Schmieder (2008) compare credit stress testing models in Germany and the Czech Republic and investigate both the corporate sector and the household sector. They find that credit risk for corporates can be modeled based on similar macroeconomic variables for both countries, despite fundamental differences in the default rate time series patterns. In contrast, Simons Rowles (2009) find that a top down stress test model for Dutch corporate credit risk does not work well in Austria. From a practitioners view, Van Gestel (2014) claims good global performance of simple econometric models for corporate defaults based on GDP growth as a sole explanatory variable, however, without providing specific evidence. Beck et al. (2014) study the nonperforming loan (NPL) ratio across 75 countries over one decade using panel models with country fixed effects and pooled macro sensitivities. In other words, while the authors allow for the baseline NPL ratio to vary by country (i.e. there is a country specific intercept in each regression), the panel models estimates one sensitivity parameter for GDP and one parameter for the lending rate applicable to all countries in addition to other macro risk factors. The authors do not state whether non-pooled country-specific models would have been statistically preferable. Focusing on rating scores for corporate borrowers in 32 European and 3 non-European jurisdictions, Altman et al. (2014) shows that a simple score model based on four financial ratios performs reasonably well across all jurisdictions. This is surprising as most practitioners and researchers would approach credit risk modeling on a country-by-country basis claiming improved accuracy over a global model. Altman and co-workers do make the point that the model fit and predictive performance can be improved by adding country specific risk factors, but looking at their results the solid performance of a simple score model is more striking than the incremental performance gains from additional country-specific model complexity. The complexity of bank risk management and regulation has been critized by Haldane (2013) who suggested that overly complex regulations could be gamed by insiders making banks less robust. Bank risk managers may be overwhelmed by the tens of thousand of model parameters in use at large international banks with significant model risk and risk of overfitting. The US FED stress test program has recently been criticized by Dowd (2014) who argued for less complexity but also for less prescriptive stress test models. If all banks have to manage to the risk assessment of one regulator or one set of models this would fuel the build up of systemic risk. This aspect is also mentioned in the recent publication by the Bank of England (2014) for the UK variant stress test. 4 Empirical stress test models To set the scene and to justify our choice of models, we note that the well-known Basel Vasicek model underying the calculation of risk-weighted assets can be interpreted as simple model for the PD PIT as follows. 3 ( P DitP IT Φ−1 (P DiT T C ) √ =Φ − 1 − ρi √ ρi ft 1 − ρi ) Here, Φ denotes the cumulative distribution function of the standard normal distribution with inverse Φ−1 , t is the time index measured in years and i is the index for an individual borrower or a homogeneous cohort of borrowers. A homogeneous cohort could consist of all borrower with the same through-the-cycle P DT T C , corporate borrowers in the same industry segment or in the same country or those sharing all these characteristics together (e.g. a BBBrated UK utility). Kupiec (2009) noted that this model shares some important characteristics of historical default data, but quantitatively does not fit corporate bond data well. He writes the model as a linear panel regression model in the probit-transformed dependent variable yit = Φ−1 (P DitP IT ) yit = ai + bi ft + ϵit . The parameter ai is called a fixed effect and ft a random effect. As the random effect is the same for all cohorts (no index i), different cohorts are correlated with each other causing systematic undiversifiable risk to the lender. The panel model can now be estimated with different assumption for the model coefficients. A frequently used pooled model with fixed effects would leave the ai cohort-specific, but would estimate the same parameter b for all cohorts. In the Basel framework, the asset correlation ρ and hence b is prescribed to be the same for each retail asset class (e.g. ρ = 0.15 for residential mortgages and ρ = 0.04 for qualifying revolving retail exposures) and does not vary by bank or country. In other words, a Spanish bank has to hold the same amount of capital against their residential mortgages as a German or UK banks, if the loans share the same P DT T C and loss-given-default (LGD) parameter. The asset correlation for corporate loans is prescribed as a function of the P DT T C , but does not vary by country or industrial sector. These assumptions in Basel were made for simplicity and the empirical support for the assumed asset correlation values and the PD-dependency of corporate asset correlations is generally weak. By comparison, top down stress testing models are often formulated as linear panel models or time series models for the P DitP IT possibly after a suitable transformation like the probit transformation above. The key difference to the Basel model is two-fold. First, analysts often use the time lagged dependent variable in the regression for an improved fit of the data. Second, rather than using a latent random effect ft , analysts use one or more observable macroeconomic variables like the annual growth in GDP or the unemployment rate to capture the systematic risk resulting from the macro environment. The macro variables can appear contemporaneously at time t or with a time lag t-1, t-2, … , reflecting the expectation that changes in the macroeconomic environment take time to be reflected in the loan performance statistics. In statistical terms, such a stress test model (also called satellite model) is specified as an auto-regressive distributed lag model. For one macro variable using no and one time lag only, the model can be written as yit = β0i + β1i yt−1 + β2i xt + β3i xt−1 + ϵit , 4 where β0i are constant intercepts, β1i are the auto-regression coefficients, xt is an observable macro economic variable, and ϵit is the random error term. The model coefficients β2i and β3i drive the sensitivity of the performance measure to the macro variable xt and we will simply refer to these parameters as the macro sensitivities. Comparing the Basel model with the satellite model makes it clear that the satellite model approximates the latent random effect of the Basel model with observable macro variables and the lagged dependent variable. In the following we also consider a simplified version of the satellite model which is more similar to the Basel model and drop the auto-regressive term in the dependent and independent variables yit = β0i + β1i xt + ϵit . While an auto-regressive specification often fits the historical data better, especially if monthly or quarterly data are available, for a three year forecast based on annual data, the auto-regressive model has the undesirable feature of slowing down the response to changes in the macro environment. We restrict ourselves to a small number of variables for which explicit macro scenarios have been published: the annual growth in GDP, the unemployment, and house prices and interest rates which are all common choices in credit modelling. In principle there are a large number of macro variables that could be used and some will be more predictive for the loan performance measure than others. A number of statistical variable selection methods have been applied to stress testing modeös of US mortgages (Heppe 2014a). For exposures secured by real estate for which banks report an average loan to value (LTV) ratio at year end 2013, we also calculate a stressed LTV based on updated indexed house price values. The models above can be estimated with frequentist methods using any commonly used statistical software. If data are scarce and time series short as is often the case in credit risk modeling, we prefer to estimate the models using a Bayesian approach to directly capture the uncertainty in the model parameters. Researchers from the ECB also advocate the benefits of the Bayesian approach (Henry Kok 2013 p20): “A Bayesian approach to modeling is particularly useful for modeling banks’ risk parameters to account for the inherent model uncertainty related to the fact that for many risk parameter variables, the data quality is often imperfect and the historical time-series are typically rather short.” For detailed examples of Bayesian model estimates using US and European credit data we refer to Heppe (2014a and 2014b). 5 Macro sensitivities calculated from the 2014 EUwide stress test We have published an interactive tool to analyze the EBA EU-wide stress test results free of charge on www.os-is.com. Users can explore the EBA data online with a wealth of information on credit risk. We estimate the point-in-time probability of default (PD PIT) assuming that banks adhere to the methodology of calculating impairments as prescribed by 5 EBA (EBA 2014b, OSIS manual 2014 on www.os-is.com). We obtain six PD PIT estimates for each year 2014, 2015, and 2016 in each the baseline and adverse scenario. We then regress the PD PIT with the macroeconomic scenarios applied by the banks in the stress test to arrive at simple models for the PD PIT in dependence of a small number of macro factors. While many results look reasonable, we do not know whether a bank adhered to the published methodology from EBA or to what extent the estimates were impacted by regulatory overwrite. We know that 23 banks had permission by EBA not to use the static balance sheet assumption. In those 23 cases, our estimates are likely to be inaccurate and we exclude then im the calculation of country averages. Figure 1 shows the estimated probit-transformed PD PIT for a number of banks lending to residential mortgage borrowers in the UK (EBA exposure class Retail - Secured by on real property). Figure 1: Estimated probit PD PIT of UK mortgages versus indexed LTV. The simple univariate probit model can be displayed as a trend line when plotting the probit PD PIT against the macro variable whereby the macro sensitivity equals the slope of the trend line. Big circles indicate that the p-value of the regression is less than 0.2 whereas small data points indicate lack of statistical significance. The trend lines appear to all have similar slopes and all models are significant. Deutsche Bank is not a high street lender in the UK, their PD PIT are much higher than those of the other banks shown which is probably due to a higher portion of non-conforming mortgages. The estimated PD PIT for Handelsbanken are small. HSBC and Barclays are not shown as their extremely small impairment rates give rise to negative PD PITs (cf. Figure 16 in Annex 1). In this graph, we include Lloyds despite the banks’ exemption from the static balance sheet assumptions. Figure 2 adds some banks with their residential mortgage exposure in Spain. It is obvious 6 Figure 2: Estimated probit PD PIT of UK and Spanish mortgages versus indexed LTV. that the macro sensitivity for the Spanish exposures are significantly higher. The difference exists for Spanish banks in the UK (e.g. Santander) and UK banks in Spain (e.g. Barclays). ING Spain being the exception with PD PIT even lower than in the UK (the two trend lines at the bottom of the graph). Perhaps surprisingly, the starting point PD PIT in the baseline 2014 scenario are quite similar across banks in both countries seen in the left part of the graph whereas the higher stresses in the adverse scenario are located on the right side of the graph corresponding to higher LTVs. If the baseline PD PIT were close to the throughthe-cycle PD PIT then the banks in Spain and the UK would be required to hold similar amounts of regulatory capital against the respective mortgage pools given the same asset correlation prescribed by Basel (and assuming similar LGD). Annex 1 provides more charts for comparing the risk weights and impairments between selected UK and Spanish banks. In contrast, the stress test results point to much higher defaults in an adverse scenario in Spain compared to the UK. The model differences persist if we use the annual change in unemployment rather than the indexed LTV (Figure 3) or if we consider non-real estate secured retail exposures (EBA exposure class Other Retail, Figure 4). A similar behaviour can be found for corporate exposures. For example, the exposure weighted average macro sensitivity for corporate loans versus the change in unemployment is 3.73% in Spain, 1.97% in Italy, but only 0.68% in the UK and 0.52% in Germany. For Other Retail exposures, the sensitivities to the change in unemployment are 2.63% (Spain), 3.23% (Italy), 0.15% (UK), and 0.80% (DE). 7 Figure 3: Estimated probit PD PIT of UK and Spanish mortgages versus annual change in unemployment rate. Figure 4: Estimated probit PD PIT of UK and Spanish Other Retail loans versus annual change in unemployment rate. 8 6 Analyzing nonperforming loan ratios across countries In this section and the remainder of this paper, we wish to assess whether the different model sensitivities apparently used by banks in Spain and in the UK for retail assets can be justified with historical data. There are very few public data sets that measure the credit performance of bank loans and span at least one full economic cycle across many countries. One such data set is the ratio of nonperforming loans to all loans reported by the Worldbank. However, contrary to Basel, which has a standard definition of default, there is no standardized definition of what constitutes a nonperforming loan across countries or banks. The advantage of the Wordbank data is that many countries are covered for the period 2000 to 2013 though the data are not broken down by asset class and thus combine retail and wholesale exposures. Figure 5 and 6 show the scatterplots for the probit NPL ratio versus the change in unemployment and GDP, respectively, for a number of countries (we download the data for NPLs and the macro variables via API from quandl.com). We note that no consistent picture emerges. Whereas Germany, Spain and Italy show similar sensitivities to the change in unemployment such dependency is not significant for the UK. Regarding GDP, Spain, Ireland and the US show a relatively large sensitivity, whereas the UK is significantly smaller and Germany is not significant. France does not show a significant sensitivity to either the change in GDP or unemployment. The example of France demonstrates that these short time series have to be interpreted with caution as the statistical error is large as indicated by the shaded areas. It is not plausible that a sharp rise in unemployment in France would not result in higher NPL ratios for French banks. The insignificant results reflect the relative stability of the last 13 years in France. Beck et al. (2014) consider a similar but broader NPL data set for 75 countries and find that GDP is most explanatory, but other variables like the lending interest rate are also significant. Note that the authors estimate a pooled model with fixed effects and do not estimate country specific sensitivities. We refrain from introducing more macro variables here, but simply repeat our warning that 13 annual data points provide little information to justify the estimation of country specific models. However, the data certainly suggest that pooling across countries may not be statistically preferable and further research with longer time series is required. 7 Analyzing historical data of UK and Spanish retail loans In this section, we look at longer historical data for UK and Spanish retail loans taken from recent financial stability reports. The published time series are also highly aggregated and only offer a rough proxy for the default rate. On the positive side, these data offer a longer view spanning several decades. In Spain, we look at the nonperforming loan ratio for secured and unsecured household loans as reported in the Spanish credit register and published in the recent financial stability report 9 Figure 5: Nonperforming loan ratio versus change in unemployment. Figure 6: Nonperforming loan ratio versus change in GDP. 10 of the Bank of Spain (2014). Data for Spanish and UK house price indices (HPI) are taken from the Bank for International Settlement. For ease of comparison we only report results where data are aggregated to an annual frequency. Figure 7 shows the fit and forecast of a Bayesian auto-regressive model of order one versus the historical change in Spanish house prices (i.e. no lag for the HPI variable). The forecasts for 2014-16 are shaded grey and we take the projected HPI changes from the adverse scenario of the 2014 EU-wide stress test for Spain. The Bayesian fan chart results from a Markov Chain Monte Carlo simulation (using the rjags package in R) and expresses the forecast uncertainty including the uncertainty in the model parameters. The usefulness of Bayesian fan charts for stress testing has recently been highlighted by Franta et al. (2014). The prior distributions for all parameters are assumed uninformed. The posterior distribution for the sensitivity to the annual change in the Spanish house price index is shown in Figure 8. The mean of the posterior macro sensitivity agrees well with the frequentist OLS estimate. Even with 30 years of data, the parameter is not sharply defined. Using less than 10 years of data, which banks often encounter in practice, results in even wider uncertainty distributions (for more Bayesian examples see Heppe 2014b). In the UK, we use the percentage of mortgage loans in arrears for more than six months as published in the financial stability report of the Bank of England and in the recent publication of stress test results (Bank of England 2014). The macro stress shown is the UK variant of the 2014 stress test. Figure 9 and 10 show the model fit and forecast and the posterior sensitivity to UK HPI. While the time series in the UK and Spain are quite different, the difference in the HPI sensitivities between the two countries is minor in stark contrast to the models used by the banks in the EU-wide stress test (cf. Figure 2). Similarly, for unsecured retail loans Figure 11 and 12 show the fit and forecast of the NPL ratio of unsecured household loans in Spain against the annual change in the unemployment rate whereas Figure 13 and 14 show write offs of unsecured retail loans in the UK against changes in unemployment. Again, the means of the posterior distributions of the sensitivity parameters differ only modestly especially in light of the displayed uncertainty. 8 Stress testing UK banks with Spanish models While we saw some weak evidence in the Worldbank NPL data that macro sensitivities may be significantly smaller in the UK compared to Spain, we do not find such evidence in our Bayesian analysis of Spanish and UK retail loans based on longer time series. The average macro sensitivities of banks in the UK and Germany are much lower than those used by banks in Spain and Italy. To gauge the importance of the macro sensitivities in the stress test results, we reclaculate the PD PITs for UK and German banks using the higher average sensitivities from Spain and Italy and vice versa. Surprisingly the effect of using more or less aggressive macro sensitivities seems to work mainly in one direction. While the CET 11 Figure 7: NPL ratio of secured loans to Spanish households. Figure 8: Posterior sensitivity to Spanish house price changes in autoregressive model of order one. 12 Figure 9: Arrears ratio of residential mortgage loans in the UK. Figure 10: Posterior sensitivity to UK house prices in autoregressive model of order one. 13 Figure 11: NPL ratio of unsecured retail loans in Spain. Figure 12: Posterior sensitivity to changes in unemployment rate (Spain. 14 Figure 13: Write offs for unsecured retail loans in the UK. Figure 14: Posterior sensitivity to changes in unemployment rate (UK). 15 1 ratios of Spanish and Italian banks increase the effect is modest and none of the failed banks in Spain and Italy would have passed the EU-wide stress test on the basis of the more benign model parameters. In contrast, the use of the more conservative Spanish sensitivities would have a dramatic impact on those big four UK banks which were subject to the EBA stress test and disclosure. Barclays and HSBC who comfortably passed the 2014 EBA and Bank of England tests both follow the static balance sheet assumption and both would fail the stress test by a significant margin. Even though we cannot calculate the PD PITs for Lloyds and RBS due to their exemption from the static balance sheet assumption it is reasonable to infer that those two would have failed the stress tests as well if the more conservative Spanish model parameter were imposed on them. We also recalculated the CET1 ratios for German banks using average Italian macro sensitivities and again find some material capital shortfalls with a further three banks failing the stress test in the adverse scenario. Detailed results of the capital calculation can be made available upon request. 9 Conclusions The answer to our initial question is negative whether we find a level playing field between banks in different European countries. Further research is required into the apparent inconsistency of assuming a homogeneous asset correlations in the calculation of risk weighted assets while allowing banks to use widely differing macro parameters in the stress testing models. What are the possible explanations for the apparent inconsistencies of having widely varying model parameters allowed in the stress test? First, while we think that our conclusions are robust, we cannot be sure that our calculated PD PITs are exactly those used by the banks as banks may have deviated from the published methodology of EBA. Second, as we have seen in the NPL data from the Worldbank in section 6, banks using different macro variables could come to different conclusions as the historical macroeconomic data do not always show the expected co-movements that underlie the specific stress scenarios imposed by EBA/ECB or the Bank of England in the adverse scenario. Third, statistical sampling errors are large and macro parameters are notoriously hard to determine with data of length found in practice and all econometric model parameters will be unstable over long enough time horizons. We recommend the Bayesian approach for model estimation as it includes the uncertainty of the parameters directly and we have shown the importance of such uncertainty for forecasting credit risk and stress testing. The Bayesian fan charts presented above clearly demonstrate the large forecast uncertainty which includes the uncertainty about the model parameters. While all stress tests to date seem to focus on point estimates (the 50% central white line in the forecast fan), we note that stress test predictions are not certain even if the macro scenario is assumed to be known with certainty. Bank stakeholders requiring a credibility of more than 50% will find material capital shortfalls at many institutions. The Bayesian framework has the additional advantage of allowing the use of informed priors to include 16 external information about model parameters in a statistically coherent manner. The EU-wide stress test provides an unprecedented level of disclosure with up to 12,000 data points per banks. While the EBA stress test has addressed many of the shortcomings of its predecessors, many practitioners still consider it more a ritual dance than a source of deep insight into the riskiness of the balance sheet. Here, we aim to demonstrate the value of this rich data set for a better understanding of credit risk even if further research is required to overcome the apparent inconsistencies in the models used by banks. This version of the paper was released shortly after the UK stress test results were announced by the Bank of England (2014). For the avoidance of doubt, we do not claim that our analysis shows that any particular UK (or German) bank should have failed the EBA or Bank of England stress tests. We do not claim that the models of UK banks are inadequate. We highlight that the apparent inconsistencies between different countries require further investigation. The purpose of stress tests is to complement the existing bank capital framework so one should not expect the same models or conclusions from both approaches. However, bottom up stress test procedures are still under development and the experience with the widely divergent calculations of risk weighted assets points towards a need for simple top down measures to complement the bank’s own calculations which have historically been intransparent to outsiders. The recent publication of stress test data provide unprecendented insight into the banks balance sheet, but the more information becomes available the more questions will be raised by outsiders. Providing answers that are broadly consistent across Europe will remain a formidable challenge for the years to come. 10 References • Altman, Iwanicz-Drozdowska, Laitinen, Suvas 2014, Distressed Firm and Bankruptcy prediction in an international context: a review and empirical analysis of Altman’s Z-Score Model. • Banco de Espana 2014, Financial stability report, November. • Bank of England 2014, Stress testing the UK banking system: 2014 results. • Beck, Jakubik, Piloiu 2013, Non-performing loans: What matters in addition to the economic cycle? ECB Working Paper No. 1515. • Čihák, Muñoz, Teh Sharifuddin, Tintchev 2012, Financial Stability Reports: What Are They Good For? IMF working paper. • Dowd 2014, Math Gone Mad. Regulatory Risk Modeling by the Federal Reserve, Cato Institute, No. 754. • EBA 2014a, Results of 2014 EU-wide stress test 17 • EBA 2014b, Methodological note EU-wide Stress Test 2014, Version 2.0 • Franta, Barunik, Horvath, Smidkova 2014, Are Bayesian Fan Charts Useful? The Effect of Zero Lower Bound and Evaluation of Financial Stability Stress Tests, Czech National Bank. • Haldane 2013, Containing Discretion in Bank Regulation, speech available on www.bankofengland.co.uk • Henry, Kok (Editors) 2013, A macro stress testing framework for assessing systemic risks in the banking sector. ECB Working Papers No. 152. • Heppe 2014a, Top down stress testing of US mortgages, www.os-is.com. • Heppe 2014b, Top down robustness check of the 2014 EBA Stress Test, www.os-is.com. • Hirtle, Kovner, Vickery, Bhanot 2014, The Capital and Loss Assessment under Stress Scenarios (CLASS) Model, Federal Reserve Bank of New York Staff Reports. • Jakubík, Schmieder 2008, Stress Testing Credit Risk: Comparison of the Czech Republic and Germany. • Kupiec 2009, How Well Does the Vasicek-Basel AIRB Model Fit the Data? Evidence from a Long Time Series of Corporate Credit Ratings Data. • Nkusu 2011, Nonperforming Loans and Macrofinancial Vulnerabilities in Advanced Economies, IMF Working Paper 11/161. • Simons, Rowles 2009, Macroeconomic Default Modeling and Stress Testing. De Nederlandsche Bank. • Van Gestel 2014, Credit stress testing, presentation. 11 Annex 1: Screenshots from OSIS LoanCracker regarding UK and Spanish banks 18 Figure 15: Risk weights of UK and Spanish residential mortgages (Source: EBA). Figure 16: Impairment rates of UK and Spanish residential mortgages in adverse scenario (Source: EBA). 19 Figure 17: Coverage ratios of default UK and Spanish residential mortgages in adverse scenario (Source: EBA). Figure 18: Calculated PD PIT of UK and Spanish residential mortgages in adverse scenario (Source: EBA, OSIS). 20
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