Published in the Hill Times, May 25, 2015
As Canadians, we pride ourselves on how well our financial regulations coped with the 2008 financial crisis. Given this attitude, it’s not surprising that Canadian policymakers have avoided a major overhaul to our regulations in response.
Yet we need to make sure that this pride in our system does not lead to complacency. Rather than just looking backwards to how the Canadian financial system performed in the last crisis, we also need to look forwards and recognize how much the global economy is changing.
In order to manage an uncertain economy, someone needs to be able to look at the system as a whole: to connect the dots that link regulations governing consumer credit, mortgages, interest rates, big, small and “shadow” banking institutions.
Those changes take two key forms. First, the economy has become much more uncertain since the crisis. And second, a number of other countries have raised the bar for financial regulation. If Canadians don’t catch up with these two major shifts, we may well find ourselves in trouble.
Whether we look at the International Monetary Fund’s latest Global Financial Stability Report, or the Bank of Canada’s recent Financial System Review, it is clear that both the global and national economies have become increasingly uncertain. That uncertainty defines some of the most important aspects of our economy, whether we look at the likely medium-term impact of the decline in oil prices, the potential for a hard landing in an overheated housing market, or the possibility that Canadians will wake up one day and realize that their household debt level is unsustainable.
This environment of profound uncertainty poses serious policy challenges.
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In the good old days of the so-called “Great Moderation” from the mid-1980s to the financial crisis, policymakers were able to focus on what Donald Rumsfeld famously described as “known unknowns”—the kinds of risks to which policymakers could assign definite probabilities. Today, we are faced instead with a great deal of “unknown unknowns”—the kinds of uncertainty that resists formal modeling, as Bank of Canada Governor, Stephen Poloz noted in a recent paper.
How should we regulate financial markets in the face of this kind of uncertainty? Very carefully. As it becomes increasingly difficult to predict what kinds of complex risks the economy might face, we need to err on the side of caution.
As good Canadians we might assume that we already have some of the most cautious financial regulations around. Yet this is no longer the case.
Yes, Canada has implemented the capital adequacy standards set out in the Basel III accord very quickly. Yet our government has treated those requirements as the gold standard, when they were designed to be a bare minimum. On the other hand, the United Kingdom and the United States are in the process of implementing more demanding standards, including adopting higher and stricter leverage ratios. While Canada was one of the only countries with a leverage ratio requirement before the crisis, we now starting to look relatively lax.
- Jacqueline Best, What Counts as Policy Failure–And Why It Matters
- Stephanie Silverman, At Any Cost: The Injustice of the ‘4 and 4 Rule’ in Canada
Even more striking is the fact that Canada, unlike every other major country, has no central body responsible for coordinating efforts to manage systemic risk. The Canadian regulatory universe is fragmented, with important pieces of the regulatory puzzle managed by half a dozen agencies plus a multitude of provincial authorities. The Bank of Canada does an admirable job of identifying potential sources of systemic risk, but they have few tools for acting on them.
Canadian authorities have engaged in macroprudential regulation in recent years—most notably through their efforts to cool the housing market down. Yet, as a recent IMF report points out, those efforts have unintentionally encouraged those who no longer qualify for prime mortgages into the under-regulated world of “shadow lending,” potentially increasing systemic risk. In order to manage an uncertain economy, someone needs to be able to look at the system as a whole: to connect the dots that link regulations governing consumer credit, mortgages, interest rates, big, small and “shadow” banking institutions.
What about the usual financial sector response that more regulation will cost Canadian financial institutions, and thus the economy, more generally? We should have learned by now that the cost of another crisis would be much greater still. Given the triple threat of uncertain oil prices, a volatile housing market and rising consumer debt, another crisis would likely hit us harder than the last one. It’s worth being well prepared for that kind of risk.