Financial market report
Financial Market Report
2
2013
Exceptionally large amount of bond financing by
Finnish companies
Stock of housing corporation loans more than tripled
Strong growth in nonperforming loans at euro area
Many euro area countries place restrictions on large
Financial Stability and Statistics
Contents
1 Financial intermediation
Banks' role in financing Finnish companies has diminished
Housing corporation loans from MFIs increasing strongly
2 Banks and insurance companies
Banks' non-performing loans increase in the euro area, decrease in
the United States
Bank's position relative to other banks explains contagion in the
European money markets
3 Securities markets
SEU's CSD Regulation strengthens the single market and
improves the rules for securities settlement
Stock of bonds issued by Finnish enterprises growing at a rapid
Project team
Bond and money market funds maintain their position in the
investment fund markets
4 Infrastructure
Several euro area countries already limit large cash payments
Contactless payment is changing the way we make card payments 22
Pertti Pylkkönen
5 Key regulatory and supervisory initiatives
Single Resolution Mechanism will protect taxpayers from costs of
Many European countries impose restrictions on banks' housing
The legislative basis for the use of macroprudential tools 25
New tools for the regulation of capital adequacy
Use of instruments that influence housing lending
Liquidity requirements
Kimmo Virolainen
List of charts
Päivi Heikkinen
Chart 1. Finnish corporate sector's self-financing ratio (gross savings/investment)
Chart 2. Finnish non-financial corporations' interest-bearing debt
Chart 3. Imputed interest margins on new corporate loans, by loan size
Chart 4. Outcome of the application for bank loans by SMEs
Chart 5. MFI lending to housing corporations in Finland
Chart 6. Housing starts in Finland, by type of financing, and housing corporations'
renovation costs
Chart 7. Imputed average margins on new drawdowns of MFI loans in Finland
Chart 8. Lending to housing corporations by general government and from abroad
Chart 9. Average return on equity (ROE) for large euro area banks and US banks
Chart 10. Developments in non-performing loans in the euro area and United States
Chart 11. Bonds issued by Finnish residents, outstanding amounts end-month
Chart 12. Bond issuance by Finnish non-financial corporations, gross (all currencies) 15
Chart 13. Fund capital by fund type and total net subscriptions
Chart 14. Finnish households' net investment in investment funds registered in
List of tables
Table 1. Maximum sizes of cash payments in selected EU countries, EUR
1 Financial intermediation
Banks' role in financing
the corporate sector reflects a relatively strong level of
internal financing in the sector as a whole.
Finnish companies has
Chart 1. Finnish corporate sector's self-financing
diminished
ratio (gross savings/investment)
Finnish corporate sector's self-financing ratio (gross savings/investment)
Eero Savolainen
Corporate finance in Finland and
elsewhere in the euro area is highly bank-
centred. In Finland, particularly large
non-financial corporations have recently
acquired financing via bond issues, and
Source: Statistics Finland.
growth in the stock of bank loans to non-
Corporate finance is bank-centred in Finland
financial corporations has come to a halt.
Financing conditions of small and
The Finnish corporate sector's interest-bearing debt
medium-sized enterprises have weakened
relative to the size of the economy has grown steadily.
to some extent, but are better than in the
At the end of March 2013, the debt amounted to 66%
euro area on average.
of GDP and totalled EUR 127 billion .2 The
largest providers of finance to non-financial
Viewed at the level of the national economy as a
corporations include domestic monetary financial
whole, there is no major need for external finance in
institutions (MFIs), in practice mainly deposit banks.
the Finnish corporate sector,1 as non-financial
Another important source of loan-based debt financing
corporations' internal financing has exceeded
is the rest of the world, chiefly foreign banks and other
investment for nearly 20 years. In national accounts
financial institutions.
terms, there is no need for external finance from
financial institutions and securities markets, as the
corporate sector's gross savings exceed gross fixed
capital formation. The corporate sector's self-financing
ratio has long been over 100. Admittedly,
in recent years, the ratio has been lower than in the
pre-crisis years. Although the situation of individual
non-financial corporations may even differ widely
from the average, the fairly high self-financing ratio of
Here direct investment loans in the balance of payments statistics
1 This article excludes housing corporations from the corporate
and domestic inter-company loans are not counted among the
corporate sector's interest-bearing debt.
Financial Stability and Statistics – Suomen Pankki Finlands Bank
increased . In particular, the smallest
Chart 2. Finnish non-financial corporations' interest-bearing debt
corporate loans have been affected by widening
Structure of Finnish non-financial corporations' interest-bearing debt
Loans from MFIsLoans from abroad (excl. direct investments)
margins. Nevertheless, loan rates for Finnish non-
Loans from other financial institutionsLoans from employment pension institutionsLoans from other general government entities
financial corporations are lower than in the euro area
Short-term debt securitiesLong-term debt securities
Loan margins for large non-financial corporations
have also widened, but relatively less than for smaller
enterprises. This is due, in part, to large companies'
access to a wider spectrum of funding sources, such as
bonds. Thus, larger companies have stronger
Sources: Statistics Finland and Bank of Finland.
negotiating power than smaller enterprises. Moreover,
Lending by employment pension institutions to non-
in making loan decisions, banks pay increasing
financial corporations began to grow rapidly in the
attention to the imputed capital requirements of loans,
latter half of 2008, in response to increased risks
which typically are lower in relative terms for large
relating to the availability of corporate finance.
companies than for small and medium-sized
Employment pension institutions' loan stock peaked
enterprises (SMEs).
above EUR 10 billion, compared to a pre-crisis level
of approximately EUR 4 billion. Although the loan
Chart 3. Imputed interest margins on new corporate loans, by loan size
stock of employment pension institutions has
Up to EUR 250,000
Over EUR 250,000 and up to EUR 1 million
Over EUR 1 million
subsequently declined, it is still markedly larger than
before the crisis. The total stock of lending to non-
financial corporations by other general government
entities (central and local governments) is somewhat
larger than that by employment pension institutions.
The biggest recent change in the structure of
corporate finance is the increasing importance of
market-based funding. Large non-financial
Source: Bank of Finland.
corporations, in particular, have issued more bonds
Financing situation of SMEs has deteriorated
than previously. By contrast, growth in bank loans has
but is still better than in the euro area on
slowed: in August 2013, the three-month moving
average of the annual growth rate of the corporate loan
stock (excl. housing corporations) was only 0.3%.
The financing situation of Finnish SMEs has
weakened to some extent. According to a survey
Interest margins on corporate loans have
conducted by the European Central Bank (ECB),3 the
increased
proportion of rejected loan applications has increased
MFIs have re-priced the risks inherent in corporate
since autumn 2011 . In the period October
loans. Imputed interest margins on new loan
2012 to March 2013, 11% of SMEs' bank loan
agreements to non-financial corporations have
3 Survey on the access to finance of SMEs in the euro area (SAFE).
Suomen Pankki Finlands Bank – Financial Stability and Statistics
applications were rejected. On the other hand, during
MFI statistics do not separately indicate the amount of
the same period, 79% of SMEs' loan applications were
loans taken out by SMEs. However, based on the
approved in full. This was the euro area's second
ECB's survey, it seems that developments in the SME
highest figure after Germany's and clearly higher than
loan stock have been subdued.
the euro area average.
More than half of Finnish SMEs have enough own
funds and internal sources of financing to render it
Chart 4. Outcome of the application for bank loans by SMEs
unnecessary to seek external financing. In addition,
SMEs' external financing needs have changed slightly.
Not acquired due to high interest
Demand for bank loans has already been on a
downward path for several years, while demand for
overdrafts and trade credits has increased.
Source: European Central Bank, Survey on the access to finance of SMEs in the euro area
Financial Stability and Statistics – Suomen Pankki Finlands Bank
Housing corporation loans About two fifths of MFI lending to housing
corporations is provided by Municipality Finance Plc4
from MFIs increasing
and the remaining three fifths mainly by deposit banks.
strongly
The share of deposit banks has declined markedly
since 2008, even as the stock of these loans has
Hanna Putkuri ja Kimmo Koskinen
Municipality Finance grants loans to housing
The stock of loans granted by Finnish
corporations controlled by local authorities and to
MFIs to housing corporations has grown
housing corporations designated as non-profits by the
significantly in the past ten years. MFIs
Housing Finance and Development Centre of Finland
grant housing corporations both non-
(ARA), a government agency operating under the
subsidised and state-guaranteed or
supervision of the Ministry of the Environment.6 Such
subsidised loans. By contrast, the stock of
loans may be interest-subsidy or privately financed
loans granted by the general government
loans, and may be used for construction, renovation or
directly to housing corporations is
acquisition of housing property.
contracting gradually, as new state-
According to the State Treasury, the volume of
subsidised housing loans (ARAVA loans)
state guarantees and the stock of loans with interest
are no longer provided.
subsidy were both upwards of EUR 8 billion in June
The stock of loans granted by Finnish MFIs to housing
2013.7 Municipality Finance is the most important
corporations has more than tripled in the past ten
intermediary for state-subsidised housing finance. The
years. In August 2013, these loans amounted to
above-mentioned housing corporations designated as
approximately EUR 17.3 billion, and the year-on-year
non-profits legally qualify for state subsidies and
loan stock growth was well over 15
guarantees. However, in the current environment of
low interest rates, interest subsidies are of no
Chart 5. MFI lending to housing corporations in Finland
MFI lending to housing corporations in Finland
Loan stock (left-hand scale)
Municipality Finance also provides financing for
Annual change in loan stock (right-hand scale)
debt restructuring. According to Municipality Finance,
demand for its loans has recently been driven by
4 At the end of 2012, the stock of loans granted by Municipality
Finance to housing corporations amounted to about EUR 6.4 billion
(Municipality Finance's Annual Report 2012).
Annual change is calculated from monthly changes in the stock, adjusted for revaluations
The data is based on the Statistics Finland outstanding credit
Source: Bank of Finland.
statistics discontinued at the end of 2012.
6 Significant housing corporations with non-profit status include eg
certain limited liability companies belonging to Avara, Sato, TA and
7 Includes subsidies and guarantees for rental and right-of-
occupancy housing.
Suomen Pankki Finlands Bank – Financial Stability and Statistics
customers' willingness to replace old ARAVA loans
Chart 7. Imputed average margins on new
by new market-based loans.
drawdowns of MFI loans in Finland
Imputed average margins on new drawdowns of MFI loans in Finland
Housing production and housing corporations'
Loans to non-financial corporationsHousing loans to householdsLoans to housing corporations
renovation costs have evolved fairly steadily in
Finland in recent years. Following the dip in 2008–
2009, housing starts have regained their average level
of the first post-millennium decade. The relative
importance of state-subsidised ARA production
increased strongly in 2009–2010, as privately financed
housing construction collapsed. The trend has
Source: Bank of Finland.
MFIs have increased their margins on new loans in
subsequently normalised
order to improve profitability and to better take
Chart 6. Housing starts in Finland, by type of financing, and housing corporations' renovation
account of credit risks in pricing. In recent years, the
long-sustained period of historically low Euribor rates
Housing starts in Finland, by type of financing, and housing corporations' renovation costs
Privately financed housing starts (left-hand scale)
and Euribor-tied lending rates has been the most
ARA housing starts (left-hand scale)Total housing starts (left-hand scale)Renovation by housing corporations, new statistics ( right-hand scale)
important factor eroding profitability in basic banking.
Renovation by housing corporations, old statistics (right-hand scale)
Banks have also cited more expensive funding and
anticipated costs for regulatory tightening as
justifications for the widening of loan margins.
Direct lending by the State contracts at an
even pace
Sources: Statistics Finland, ARA and Bank of Finland calculations.
The stock of loans granted by the general government
Margins on the increase, continued low level
directly to housing corporations is mainly composed of
of interest rates
ARAVA finance, ie loans granted for rental and right-
The average interest rate on the stock of loans granted
of-occupancy housing. No new ARAVA loans have
by MFIs to housing corporations remained at a
been provided since 2007; rather, state subsidies for
historically low level (1.65%) at the end of August
housing purposes are entirely channelled via interest
2013. The average interest rate on new drawdowns in
subsidies and guarantees on loans granted by MFIs.
August was 1.89%. The imputed interest margin8 on
The stock of loans granted by the general
new loans averaged 1.47 percentage points in August,
goverment directly to housing corporations peaked in
ie slightly less than for new housing loans to
2009, and has since been declining at an even pace
households and appreciably less than for new
. The stock of ARAVA loans managed by the
corporate loans . The average loan repayment
State Treasury amounted to about EUR 7.1 billion at
period is more than 20 years.
the end of June 2013.
8 Imputed loan margins are based on Bank of Finland calculations
and data on interest rates and volumes of new loan drawdowns at
different initial rate fixations.
Financial Stability and Statistics – Suomen Pankki Finlands Bank
Part of housing corporation loans are in practice
Chart 8. Lending to housing corporations by general government and from abroad
the responsibility of households. According to
Lending to housing corporations by general government and from abroad
Central government
Statistics Finland's estimate, the loan stock of housing
Employment pension institutions
Insurance corporations
Rest of the world
companies owned by households amounted to
approximately EUR 9.2 billion at the end of June
2013. In financial accounts within the national
accounts framework, these loans taken out for eg
financing renovations and repaid in the form of
maintenance charges are classified as household
Source: Statistics Finland.
debt.10 This calculation method, inter alia, improves
What are housing corporations?
the international comparability of the household debt-
to-income ratio.
In Statistics Finland's economic classification, housing
corporations are housing companies, housing co-
operatives, residential real estate companies, right-of-
occupancy associations and other housing
corporations. According to the Financial Supervisory
Authority (FIN-FSA), corporations engaged in renting
and management of own or leased real property
account for most of the loans granted by deposit banks
for real estate industry (a total of EUR 17.8 billion at
the end of June 2013). Such corporations typically
include housing companies and housing cooperatives
as well as housing corporations designated as non-
Most sectoral statistics on economic and financial
transactions include all housing corporations in the
corporate sector. For example, ECB statistics include
MFI loans to housing corporations in loans to the
corporate sector. In Finland, the relative impact of
housing corporations on growth in this sector's
aggregate loan stock has been of particular relevance
during the past 12 months, as the stock of loans to
non-financial corporations has barely grown.9 In other
euro area countries, housing corporations generally
play a minor role in this area.
9 The financing situation of non-financial corporations is discussed
10 Correspondingly, national accounts add imputed income from
in more detail in section 1.1.
housing property to households' disposable income.
Suomen Pankki Finlands Bank – Financial Stability and Statistics
2 Banks and insurance companies
Banks' non-performing
Chart 9. Average return on equity (ROE) for large euro area banks and US banks
loans increase in the euro
area, decrease in the United
Kimmo Koskinen, Mervi Toivanen
Banks' financial results have recently been
pronouncedly better in the United States
The sample of banks includes all FDIC-supervised institutions in the United States and about 60 large listed banks in the euro area.
Sources: FDIC and Reuters Datastream.
than in the euro area. The difference is
US banks' earnings were mainly driven by lower
largely explained by weaker economic
impairment losses and higher non-interest income. The
activity and strong increases in
growth in non-interest income was due, in particular,
impairment losses in the euro area. Losses
to increased profits from securities trading. By
of banks in Southern European countries,
contrast, net interest income contracted, as the low
in particular, have expanded significantly.
level of interest rates reduced banks' interest income.
US banks reported improved earnings for the
Banks' loan losses and impairments on loans have
second quarter of 2013. According to data from the
declined amid the recovering US economy. Banks
Federal Deposit Insurance Corporation (FDIC), a
recognised about USD 9 billion in impairment losses
supervisor of US banks, the aggregate earnings of US
for the second quarter of 2013, compared to a
banks grew by about 23% on the second quarter of
maximum of about USD 63 billion for a single quarter,
2012, to USD 42.2 billion.11 This was the fourth
reached in the last quarter of 2009. However, even
consecutive year in which earnings have improved.
though non-performing loans relative to the loan stock
In June 2013, nearly 54% of the banks reported an
have simultaneously been on a clear downward
improvement in year-on-year earnings, while only
trajectory, the volumes have remained higher than
8.2% cited a weakening. The banks' average return on
prior to the financial crisis that came to a head in 2008
equity (ROE) was 9.9%, compared to 8.7% a year
earlier Measured by return on assets12,
Some banks have already reported their earnings for
however, the banks' average earnings (1.17%)
the third quarter of 2013. Wells Fargo's earnings grew
remained below the average for 2000–2006 (1.27%).
on the previous quarter (April–June 2013), whereas
J.P. Morgan posted a loss owing to a substantial legal
charge relating to sub-prime mortgages. Loan losses
and impairments on loans reported by large banks
11 FDIC data cover 6,940 commercial and savings banks.
continued to decline quarter on quarter, and cost
Financial Stability and Statistics – Suomen Pankki Finlands Bank
cutting helped to reduce expenses. The low level of
slowly. At the same time, banks' own market funding,
interest rates and weak mortgage credit performance
notably in Southern European countries, has remained
still kept banks' interest income at low levels and
discernibly more expensive than in the period
eroded securities trading income.
preceding the financial crisis, causing banks' interest
The Tier 1 capital adequacy ratio of banks supervised
expenses to rise and contributing to declines in net
by the FDIC, which was 13.0% in the second quarter
interest income.
of 2013, has remained broadly unchanged since 2011.
Developments in non-interest income continue to
In 2009 and 2010, however, banks' capital levels were
diverge. On the one hand, subdued economic activity
bolstered significantly; at the end of 2008 the Tier 1
reduces banks' fee income. On the other hand,
capital ratio was 9.9%. The Tier 1 capital ratio of US
narrower interest rate differentials and favourable price
commercial banks, staying at 12.6% in the second
movements in the stock market have boosted bank
quarter of 2013, is slightly lower than that of the
profits from securities trading.
banking sector as a whole.
Impairments recognised on loans and securities
constitute the most important cause of euro area banks'
Chart 10. Developments in non-performing loans in the euro area and United States
poor profit performance. For example, at the end of
2012, banks in Spain recognised impairments of
almost EUR 50 billion on e.g. real estate sector loans.
Despite banks' increased impairment recognition,
growth in non-performing loans has not come to a halt,
but has instead clearly outpaced impairment
recognition. The growth in non-performing loans has
increased doubts about the banks' ability to cope with
Source: IMF.
future loan losses and about the adequacy of capital
The profitability of large
euro area banks13 remained
levels. To restore confidence, assessments of euro area
weak in the second quarter of 2013, although many
banks will be undertaken, in an effort to ensure the
banks managed to move into profit territory after the
consistency of valuation practices for bank balance
end of 2012. The weakness of the economy, increasing
sheet components and to review the capital adequacy.
impairment losses and the low level of interest rates
The most important of these initiatives is the Balance
continue to weigh on bank results. The weighted
Sheet Assessment to be conducted under the guidance
average of euro area banks' return on equity (ROE)
of the ECB within the framework of the Single
was 3.3% at the end of June 2013, after 4.5% a year
Supervisory Mechanism.
Tightening capital requirements, market pressures and
Banks' net interest income is burdened, in particular,
growing loan losses have forced banks to bolster their
by low interest rates and subdued credit demand.
capital positions. The average Tier 1 capital adequacy
Although euro area banks have widened margins on
ratio of large euro area banks was 12.1% in the second
new loans, margins on the aggregate loan stock expand
quarter of 2013, compared to 9.8% as late as at the end
13 Euro area banks include about 60 large listed banking groups
operating in euro area countries.
Suomen Pankki Finlands Bank – Financial Stability and Statistics
Bank's position relative to
model15 used in epidemiology. In the model, banks are
other banks explains
broken down in three categories: susceptible, infected
contagion in the European
or recovered. Contagion spreads across the network of
money markets
banks' financial linkages. If the capital buffers of a
susceptible bank are too small relative to its
Mervi Toivanen
receivables from the infected counterparty, negative
domino effects spill over from the infected bank to the
A research paper on contagion in the
susceptible bank. Contagion probability depends on
interbank money market shows that in
interbank exposures between the two banks, mistrust
2010 contagion negatively affected 40% of
European banks on average. A bank's
towards the infected bank and the size of the overall
central position in the interbank network
interbank market. The model is simulated with actual
is particularly important in explaining the
data on European banks.
level of contagion, while a bank's size is a
The results show that contagion affected on
considerably less significant explanatory
factor.
average 40% and 70% of European banks in 2010 and
2007, respectively. Country-level results in turn
Banks manage and level out their daily liquidity needs
suggest that banks from France, the United Kingdom,
in the interbank money market. Interbank exposures
Germany and Spain are the most contagious ones,
nevertheless create contagion channels through which
whereas Irish, Greek and Portuguese banks induce
the problems of one bank may spill over to other
only limited negative effects.
banks. Insolvency of an individual bank causes losses
Given the results, it is of interest to disentangle the
to the creditor bank, which, in turn, may lead to the
leading indicators determining the level of contagion.
creditor bank's inability to meet its own obligations.
This is analysed by cross-sectional panel estimations
Such spreading of problems is known as contagion.
where the level of contagion is explained by bank-
The most recent example of the spreading of
specific characteristics such as size, capital buffers and
uncertainty and counterparty risk aversion in the
indicators that depict the bank's position in the
financial markets is the financial crisis that started in
banking network. The results show that a bank's
the United States in 2008 and spread like a disease
position in the network is more important in
through the interbank network.
explaining contagion than its size or leverage. Bank
A very recent research paper14 assesses the
clustering, large interbank loans and a bank's
spreading of contagion and its possible negative
prominence in the interbank loan network are the key
effects in the European banking sector. The research
explanatory factors. The results support the view that,
proposes a novel approach for modelling contagion in
besides bank size, bank regulation should address
the interbank network by implementing the SIR
banks' position and significance in the money markets.
14 Mervi Toivanen (2013) Contagion in the interbank network: an
epidemiological approach. Bank of Finland's Discussion Paper series
The name of the model comes from the words susceptible -
(19/2013). See the Bank of Finland's website
infected - resistant (SIR).
Financial Stability and Statistics – Suomen Pankki Finlands Bank
3 Securities markets
SEU's CSD Regulation
securities transactions. In Finland, such services are
provided by the Finnish central securities depository,
strengthens the single
Euroclear Finland.
market and improves the
The proposed Regulation includes many important
rules for securities
reforms. The Regulation, which will be directly
binding on member states, will eg require market
settlement
participants to commit to settling securities
transactions two days after the trading day (T+2). At
Jenni Koskinen
the same time, the text emphasises the need to improve
settlement discipline in Europe and therefore direct
The EU's future CSD Regulation allows
measures to address settlement fails will be put in
authorised CSDs to provide services
throughout the EU. A new settlement
On the markets where the Euroclear group is
period (T+2) will soon be introduced on
involved in CSD activities, the aim is to introduce T+2
the equities market. Those settling later
settlement already earlier than required by the
will be subject to an effective sanctioning
Regulation. A shorter settlement cycle increases
operational efficiency and reduces counterparty risk.
The purpose of the EU regulation on central securities
Nearly all the European equities markets have thus far
depositories (CSD Regulation) currently being
applied the T+3 model. T+2 settlement is however
prepared is to harmonise EU-level requirements for
already common practice in foreign exchange
CSDs and for settlement of securities transactions and
thus enhance the safety of the completion of securities
One of the main objectives of the regulatory reform
transactions. The Regulation reduces the complexity of
is to give authorised CSDs the freedom to provide
post-trading caused by differences in national rules
services throughout the EU. Share issuers would also
and regulations. The aim is also to open CSD
be able to choose the place of issuance. As the borders
functions to competition and to lower the costs of
are opened, it is however necessary to carefully define
cross-border securities transactions. The proposed
the powers, responsibilities and cooperation of the
Regulation therefore also supports the introduction and
various authorities. The principle is that the competent
efficient use of the ECB's T2S platform16.
authority of the CSD's home country will grant
The proposal for a Regulation focuses essentially
authorisation to the CSD and will be responsible for its
on CSD functions relating to the settlement of
ongoing supervision and regular reviews, in
accordance with Level 2 regulations, which will
16 TARGET2-Securities (T2S) is a securities settlement platform
supplement the Regulation. The competent authorities
provided by euro area central banks, see
are required to cooperate with the relevant authorities,
Suomen Pankki Finlands Bank – Financial Stability and Statistics
eg central banks. Harmonised reporting is also
Regulation however recognises the model of direct
currently being developed in cooperation with the
ownership and the special role of the account
European Securities and Markets Authority (ESMA)
operators. The proposal has sparked debate also in
and national securities markets supervisors and central
Finland, particularly on the publicity of securities
ownership (see eg Kauppalehti, 2 Oct 2013, in Finnish
Finnish investors are currently required to keep
their holdings in book-entry registers maintained by
The details of the Regulation, which has undergone
Euroclear Finland. Securities are recorded in a book-
extensive preparations, are expected to be further
entry register on behalf of the shareholders, by a
honed in the EU's legislative process. The aim is to
account operators approved by the CSD. This clear
have the Regulation adopted during the current term of
and secure model of direct ownership is exceptional in
the European Parliament, ie in early 2014 at the latest.
Europe. In most EU countries the keeping of
ownership records is the responsibility of a bank
acting as counterparty to the CSD and as nominee
register to individual investors. The proposal for a
Financial Stability and Statistics – Suomen Pankki Finlands Bank
Stock of bonds issued by
Chart 11. Bonds issued by Finnish residents, outstan
tanding amounts at
Finnish enterprises
Central government
Financial corporations
growing at a rapid pace
Pertti Pylkkönen
The stock of bonds issued by Finnish
enterprises is growing at a rate of 30%,
and the group of issuers has become more
Sources: Financial Supervisory Authority and State Treasury.
diversified. After Spain, the growth rate
The stock of loans granted by banks to non-financial
for Finland is the second highest in
corporations has grown very slowly, and the share of
bank loans in the corporate sector's debt financing is
decreasing. Larger companies have diversified the
The total stock of bonds issued by Finnish residents is
acquisition of debt funding by increasing bond
currently growing at a faster rate than that for the
issuance. As a result of rapid growth of issuance,
aggregate of euro area residents. In August 2013, the
bonds already account for almost one fourth of non-
annual growth rate of the stock of bonds issued by
financial corporations' interest-bearing debt17.
Finnish financial corporations, enterprises and the
In August 2013, the volume of bonds issued by
central government in the Finnish and international
Finnish enterprises in the Finnish and international
markets was about 6%, while the corresponding
markets was 30% higher than in the previous year
growth rate for the euro area was just over 1%.
The stock of bonds issued by Finnish residents
totalled EUR 183 bn in August. The general
) (all currencies)
government and financial corporations each accounted
for over 40% of the stock, while the share of non-
financial corporations has already grown to 15%
Source: European Central Bank.
The range of issuers has become more diversified, but
only a few issuers have credit ratings. This has been
reflected eg in issued bonds' coupon interest rates. The
lowest coupon rates (investment grade corporate
17 See section 1.1. Banks' role in corporate finance has diminished.
Suomen Pankki Finlands Bank – Financial Stability and Statistics
bonds) have stood at 2.75% and the highest (non-
which approximately 85% was covered by the end of
investment grade corporate bonds) at over 12%.
September. The debt has been almost fully covered by
The stock of bonds issued by non-financial
long-term bonds, and at end-September short-term
corporations is also growing faster than the total bond
treasury bills accounted for less than 4% of the debt.
stock in other European countries. In August, the euro
The central government has sought to diversify its
area corporate bond market grew at an annual rate of
borrowing in the course of the year and has also issued
10%. The stock of corporate bonds has grown
bonds denominated in non-euro currencies under the
considerably faster in Finland than in the euro area on
Euro Medium Term Note (EMTN) programme.
average. At the end of August, Finnish corporate
According to the budget proposal, the central
bonds already accounted for almost 3% of total
government will acquire new debt financing of some
corporate bond issuance in the euro area, which is
EUR 7 bn in 2014. By the end of 2014, central
notably higher than eg Finland's share in the euro area
government debt will rise to almost EUR 100 bn19.
Finnish bonds mostly sold to international
The annual growth rate of the stock of bonds
investors
issued by Finnish financial corporations18 was 6% in
Finnish bond issuance has primarily been directed at
August. A considerable portion of bond funding is
either domestic or foreign institutional investors; sales
acquired in the wholesale market. Instruments sold to
to private investors have been fairly modest. Bonds
private customers consist mainly of various structured
held by Finnish households only account for a few
bonds. Smaller local banks have recently started to
percent of the total bond stock. However, the share is
strengthen their capital positions by issuing
slightly larger in practice since households invest in
debentures. However, the individual issue volumes are
bonds mainly via investment funds and voluntary unit-
fairly modest; only a few million euros. Bonds
directed at larger banks' wholesale markets have
linked insurance products.
The key domestic investors are insurance
mostly been covered (mortgage-backed bonds). At the
corporations and employee pension institutions, which
end of August, the stock of bonds issued by Finnish
hold almost a tenth of bonds issued by Finnish
financial corporations totalled EUR 75 bn, of which
residents. The insurance sector's domestic bond
covered bonds accounted for EUR 28 bn.
investment has recently been heavily concentrated on
In the euro area as a whole, the stock of bonds
the corporate bond market.
issued by financial corporations contracted in August
Foreign investors currently hold over 80% of the
2013 by about 8% from the year-earlier period.
stock of bonds issued by Finnish residents and about
Contraction of bank balance sheets and problems in
90% of the stock of bonds issued by the Finnish
real-estate markets in several countries are reflected in
central and local governments.
reduced funding from the markets.
Finland's central government (budgetary) debt
amounted to EUR 86.2 bn at end-September 2013. The
net borrowing requirement for 2013 is EUR 9.3 bn, of
18 Deposit banks, mortgage banks and Municipality Finance.
19 See www.statetreasury.fi
Financial Stability and Statistics – Suomen Pankki Finlands Bank
Bond and money market
Chart 13. Fund capital by fund type and total net subscriptions
funds maintain their
Net assets of funds by fund type and total net subscriptions
Real estate funds
Money market funds
position in the investment
Net subscriptions (RHS)
fund markets
Pertti Pylkkönen
The level of capital in investment funds
registered in Finland has continued to
Source: Bank of Finland.
Households' direct investment in investment funds
grow. Plans call for European regulation
of money market funds to be tightened in
accounted for 20% of total fund capital in August. In
order to mitigate the threat of systemic
addition to direct fund investments, households also
risk to the markets associated with money
indirectly place large sums in the investment fund
market funds.
markets, via individual life and pension insurance
products. Households are the largest holder group of
Fund capital has continued to grow in Finland
fund shares in the domestic investment fund markets:
At the end of August 2013, capital in investment funds
their total holdings comprise over a third of the total
registered in Finland totalled EUR 70.7 bn, up EUR 4
fund capital. There was a slight change in households'
bn on the start of the year. A substantial portion of the
financial wealth in January-August 2013, as
increase – about two thirds – is from new investment
households' net investment in investment funds
inflows. Despite the low level of interest rates, bond
totalled almost EUR 1 bn in the first half of 2013,
and money market funds have maintained their key
while their deposits contracted by EUR 1.3 bn
position in the investment fund markets; at the end of
August, half of total capital in Finnish investment
Life and non-life insurers' holdings in investment
funds was in bond funds. Money market funds, which
funds have increased strongly, particularly as a result
invest in short-term interest instruments, accounted for
of robust growth in life insurers' premium income
5% of total fund capital and equity funds for 37%.
from individual unit-linked life and pension insurance
Mixed funds' investor-attractiveness has gradually
products. A substantial part of funds invested in unit-
diminished, and their share of total fund capital is just
linked insurance products are redirected to investment
fund markets; at the end of August, life and non-life
Mixed funds have this year been the only funds in
insurers' total holdings in investment funds accounted
the largest-size category that have recorded negative
net subscriptions, in the amount of EUR 1.4 bn. New
The general government's (incl. employee pension
inflows to bond and money market funds totalled EUR
institutions) share in total investment fund capital has
2.8 bn in January-August, and equity funds attracted
stabilised at 10%.
Suomen Pankki Finlands Bank – Financial Stability and Statistics
market for AIFMs and a harmonised framework for
Chart 14. Finnish households' net investment in investment funds registered in Finland
their activities and supervision.
Finnish households' net investment in investment funds registered in Finland
The AIFM Directive regulates marketing of AIFs
to professional investors. The Government bill
proposes the marketing of AIFs in Finland also to non-
professional customers.
Legislation on money market funds (MMFs) is also
to be revised. In September 2013 the European
Parliament and the Council issued a proposal for a
Source: Bank of Finland.
regulation on MMFs with the aim to harmonise EU-
The share of foreign investment in Finnish investment
wide regulation in this field. The new regulation seeks
funds has edged down this year, but foreign
to mitigate systemic risk and the related threats arising
investment still accounts for over a fifth of the total
from MMFs in the financial markets. One such
fun capital. A significant portion of foreign investment
potential and systemically relevant risk is for a
came from Sweden.
massive exit from MMFs. The new regulation also
Finland's investment fund markets are highly
aims to reduce interlinkages between MMFs and
concentrated. The market share of the two biggest
management companies is about 50% and that of the
The proposal will introduce strict restrictions on
MMFs' investment ac
five biggest management companies is 75%. At the
tivities, eg restrictions on assets
end of August, there were 32 management companies
in which the funds can invest. MMFs will also be
operating in Finland, which managed 514 UCITS
prohibited from engaging in short selling of money
funds and special funds.
market instruments.
One of the focal points of the proposed regulation
Upcoming changes to regulation on
is more stringent rules on constant net asset value
investment funds
(CNAV) MMFs. The most important change is that, in
The Directive on alternative investment fund managers
order to prevent such exits, a CNAV MMF will be
(AIFMD Directive, 2011/61/EC) was adopted in June
required to hold a liquidity buffer amounting to at least
2011. The deadline for the implementation of the
3% of its total assets.
Directive was July 2013. In Finland, a Government
At the end of August 2013, there were 13 MMFs
bill concerning the legislative changes required by the
registered in Finland, and capital invested in them
Directive has been submitted to Parliament, and the
totalled EUR 3.7 bn. There are no CNAV MMFs
new provisions are scheduled to enter into force at the
operating in Finland.
turn of the year. The scope of the new legislation will
be extended eg to equity, real-estate, hedge and
commodity funds not covered by the UCITS Directive.
The AIFM Directive aims to provide for an internal
Financial Stability and Statistics – Suomen Pankki Finlands Bank
4 Infrastructure
Several euro area
Popularity of cash
countries already limit
In Central and particularly in Southern Europe,
large cash payments
cash is still the dominate retail payment instrument. In
Greece, ca 90% of the retail payments are cash
payments, the figure for Austria is ca 80%. Even in
Kari Takala
Germany as much as two-thirds of retail payments are
In the aftermath of the financial crisis,
cash payments. The share of card payments is however
several EU countries have limited the use
growing slowly but steadily in the euro area. In the
of cash for large payments, in order to
Nordic countries, the Netherlands and the United
curb the grey economy. Many countries
Kingdom, card payments already clearly dominate the
popular with tourists have more relaxed
retail payment market.
legislation on the use of cash by foreigners.
The large amounts of cash are not necessarily used
for payment but they may be kept as liquid cash assets
Many euro area countries have in recent years started
or used for storing wealth even for extended periods of
to limit large cash payments or have tightened the
time. This is reflected in the fact that, of the banknotes
restrictions on cash payments. The aim, inter alia, is to
issued in the euro area, 36% are of the two highest
prevent and curb the black and grey economy, money
laundering and terrorism financing.
The popularity of cash payments in Finland has
Another aim of the restrictions is to boost tax
been maintained by the easiness of cash ATM
revenues, which have shrunk as a result of the
withdrawals and the fact that consumers are not
financial crisis, by making cash payments electronic
usually charged directly for the cash withdrawals. At
and thus decreasing the cash payment-related
the checkout counter, cash has until recently been
opportunities for unreported sales. The use of cash
clearly the fastest payment method, and it still is, at
may enable unreported sales, because the payment
least for small payments involving coins.
transaction does not necessarily create a digital trace.
Temporary cash withdrawal limits have been in
This usually applies to private entrepreneurs who are
place recently at least at bank branches in Spain and
not part of a retail chain and industries where cash
Cyprus, to prevent deposit flight. In other countries,
payment is frequent. In some sectors, the use of cash
consumers and companies can withdraw cash from
also enables the payment of salaries and wages under
their current accounts and hold cash without
the table, ie without paying income tax.20
20 Payment of salaries and wages under the table usually requires
that the company also has a cash flow. Studies show that in the
Finnish construction sector, wages have been paid under the table.
account. Information on the impact of the new regulation is not yet
But since July 2013, it has been compulsory to pay wages on a bank
Suomen Pankki Finlands Bank – Financial Stability and Statistics
In the euro area, cash can be moved across borders
Cyprus and Estonia). Of the EU countries, Denmark,
freely, without cash declaration obligations. A person
Sweden and the United Kingdom also do not have
arriving from or leaving the EU's free trade area must
limits on cash payments. In these countries, accounting
however declare cash in amounts of EUR 10,000 or
software makes tax evasion more difficult for larger
more. The anti-money laundering directive applies to
companies, and cash payments are already declining.
cash payments of over EUR 15,000.21 In its proposal
In addition, there seems to be no empirical evidence on
for a for a new anti-money laundering directive, the
the impact of limits on cash payments in these
European Commission proposes that the directive be
applied to cash payments of EUR 7,500 or more.
Some EU countries (Finland, Estonia, the Czech
Cash is legal tender in the euro area, and therefore,
Republic and France) also have limits concerning the
as a rule, it should be impossible to refuse to accept
efficiency of cash payments. For example, a cash
cash. Finland, like some other euro area countries,
payment involving more than 50 coins need not be
emphasise the freedom of contract in legal praxis
accepted. In addition, retailers must inform customers
concerning payments. In Finland, customers should be
clearly at the checkout that they have limits on eg the
informed clearly about limits on the acceptance of cash
acceptance of banknotes larger than 50 euro. The ECB
payments, already before entering the store or by the
has thus far not issued any general guidelines on cash
checkout counter.
payment limits, but it has considered them to be
The current maximum for cash payments in the
subject to national decision making.
euro area varies between EUR 1,000 and 15,000
. The limits usually apply only to business
activities, as cash payments between private
individuals cannot be controlled. Some countries also
have limits on cash payments between companies. In
Finland, companies do not normally pay each other in
The forerunner in limiting cash payments is
France, where the maximum cash payment is EUR
3,000. Foreigners are however allowed to pay in cash
for purchases amounting to as much as EUR 15,000. A
similar practice facilitating purchases by tourists is
applied in Spain. Countries with significant tourism
revenue thus already have eased the limits on
maximum size of cash payments (France and Spain) or
do not have limits on the size of cash payments (Malta,
ages/Default.aspx
Financial Stability and Statistics – Suomen Pankki Finlands Bank
Table 1. Maximum sizes of cash payments in selected EU countries, EUR
Maximum for Maximum for
Cash payment can be refused, if the price is low relative to the offered banknote.
Obligation to declare sums of over EUR 15,000.
Foreigners have to show identification for purchases exceeding EUR 1,000.
Will be lowered to EUR 3,000 as of start of 2014. House purchase in cash prohibited as of the start of 2014.
Limits do not apply to purchases between consumers.
Limit applies only to consumer's responsibility for VAT if the trader does not pay his share of the tax.
The sum in euro corresponds to ca DKK 10,000.
Limit is EUR15,000 if the payment is not related to the payer's business.
Limit is defined as the sum of purchases in one day, if it is equivalent to CZK 350,000.
The following countries do not have limits on cash payments: Iceland, Slovenia, Malta, United Kingdom, Austria, Cyprus, Finland and SwedenLithuania and Estonia.
Suomen Pankki Finlands Bank – Financial Stability and Statistics
Contactless payment is
which he can continue making payments without a
changing the way we
The new payment method has raised discussion
make card payments
also in the media. Its safety has been questioned. On
the other hand, many would definitely like to start
Anne Nisén22
using contactless payment because of its convenience
and speed. The card companies managing the card
Quick and easy payment methods are
features seek to ensure safety of the cards by defining
gaining popularity. Consumers are already clearly what information can be read from the card
accustomed to paying for purchases by
with the NFC function. Payment without a PIN is a
card and invoices online. The latest
safer alternative, particularly if there is a high risk of
payment trends seem to be to contactless
the PIN and card getting into the wrong hands. The
and mobile payment.
contactless payment feature does not change the card
user's responsibilities for potential misuse of the card:
Banks operating in Finland are planning, and some
the customer is not responsible for misuse if he or she
have already added, the Near Field Communication
uses the card carefully, in accordance with the card
(NFC) feature to their payment cards. NFC enables the
terms and conditions.
payment of small purchases without a PIN, by passing
Banks are planning to automatically incorporate
the card close to the retailer's payment terminal. The
the contactless payment feature into cards upon
payment terminal must have an NFC function to
renewal and into new cards in connection with card
enable payment without a PIN. Finnish banks have
orders. In a supervisory letter sent to banks in June
decided to set the maximum for a contactless payment
2013, the Financial Supervisory Authority pointed out
the safety aspects of the NFC feature. The Financial
Contactless payments based on NFC utilise radio
Supervisory Authority requires that private customers
frequency identification (RFID) technology. A very
should be able to get, without extra charge, an
small transmitter placed in the card's chip enables the
alternative card without the NFC feature, if they so
payment terminal to read the card data required for the
wish. The banks are also required to inform their
payment. Mobile payment solutions are also changing
customers clearly about the new ways of using
and the NFC feature is expected to be added to mobile
payment cards, the terms and conditions, safety
payment in the coming years. Contactless payment
aspects, and what to do if they do not want to start
enables the payment of small purchases without a PIN.
using this new type of payment card.
Larger purchases will still require keying in the PIN.
The bank issuing the card can impose additional
restrictions on card usage, eg by setting a limit on the
number of contactless payments; when the limit is
exceeded, the customer must key in the PIN once, after
22 The author is employed by the Financial Supervisory Authority.
Financial Stability and Statistics – Suomen Pankki Finlands Bank
5 Key regulatory and supervisory
initiatives
Single Resolution
Mechanism. The Mechanism would be based largely
on the almost completed Recovery and Resolution
Mechanism will protect
Directive (RRD) for credit institutions and investment
taxpayers from costs of
firms, but would also include certain key new
banking crises
elements. The most difficult issues that will still have
to be resolved before introduction of the Mechanism
relate to the legal foundation of the Mechanism,
Jyrki Haajanen
decision-making procedures and funding.
The Single Resolution Mechanism must have a
The European Commission proposal for
solid legal foundation if significant powers (that
the Single Resolution Mechanism is
normally belong to national authorities) are to be
intended to come into effect at the
delegated to it. The Commission proposes as the legal
beginning of 2015. The proposal does,
foundation article 114 of the Treaty on the Functioning
however, contain a number of
controversial issues that will need to be
of the European Union, which deals with the
resolved before final decisions are taken.
harmonising of Member States' legislation. The
Prominent among these are the legal
suggestion is not entirely unproblematic, as in practice
foundation of the Mechanism, decision-
the proposal would mean powers (and responsibilities)
making procedures and funding.
under the RRD being transferred from national
authorities to an EU authority. In reality, the work of
In July 2013, the European Commission issued a
the Single Resolution Mechanism would often not
proposal for the Regulation on the Single Resolution
involve measures to harmonise legislation, but rather
Mechanism. This is part of the broader project for
the application of already harmonised powers to
European Banking Union, which also includes the
individual cases. In evaluating the adequacy of the
Single Supervisory Mechanism for banks and an
legal foundation, the final structure and decision-
integrated deposit guarantee scheme. In its proposal,
making procedures of the Single Resolution
the Commission suggests the establishment of a Single
Mechanism will be important.
Resolution Board for crisis resolution in respect of
Under the proposal, the Commission would take
failing European banks and a single Bank Resolution
the key decisions on resolution based on proposals
Fund to cover some of the costs of resolution.
from the Single Resolution Board (such as whether
Together with the Commission and the national
and when to place a bank into resolution and the scope
resolution authorities, the Single Resolution Board and
of use of resolution tools and the Fund). In accordance
Fund would constitute the EU's Single Resolution
with the Commission's decision, the Single Resolution
Suomen Pankki Finlands Bank – Financial Stability and Statistics
Board would draw up a resolution plan, in which the
Commission's proposal, new legislation governing
measures to be taken in resolving the crisis at the bank
bail-in would not come fully into effect until the
would be set out in detail. National resolution
beginning of 2018, although the Single Resolution
authorities would be in charge of executing the
Mechanism would already begin operation at the
resolution plan, but the Board would oversee
beginning of 2015. Postponement of the introduction
resolution and could, where necessary, directly address
of bail-in would cause a 3-year transition period during
executive orders to troubled banks. The Single
which the funding of resolution would have to be
Resolution Board would contain representatives from
resolved in some other credible manner.
the Commission, the ECB and Member States. As an
The Commission and Member States, and at a later
alternative to the key role of the Commission, a
stage also the European Parliament, are negotiating
formally and politically independent resolution
over the Regulation on the Single Resolution
authority with extensive, precisely defined powers has
Mechanism with the aim of securing its adoption
also been proposed.
before the spring 2014 European Parliament elections.
As part of the Single Resolution Mechanism, it is
The timetable is extremely tight and will require the
also proposed to create a Single Bank Resolution
speedy resolution of the many questions still
Fund. Over the next ten years, funds would be
gathered into the Fund equal to 1% of all bank
deposits covered by deposit guarantee (based on the
situation in 2011, the amount to be gathered in would
be approximately EUR 55 billion). Essentially, the
goal of the Fund would be to support the stability of
the financial system, not the operations of unviable
banks. The Single Bank Resolution Fund would
replace the national resolution funds of countries
participating in the Banking Union.
The Single Resolution Mechanism will be able to
function effectively only when it has sufficient funds
available to complete the resolution of troubled banks.
Both the RRD and the Single Resolution Mechanism
rest very strongly on the principle of creditor
responsibility (bail-in). This is accomplished by
covering a bank's losses initially with its own equity
capital (plus subordinated liabilities) and thereafter
converting a sufficient amount of creditors'
receivables into (new) equity so as to enable the new
bank formed out of the healthy components of the
troubled bank to have an adequate capital base. In the
Financial Stability and Statistics – Suomen Pankki Finlands Bank
Many European countries
(iii) macroprudential instruments potentially having an
effect via the terms and conditions and the availability
impose restrictions on
of housing loans and mortgage credit more broadly.
banks' housing lending
Our examination does not consider those instruments
that will be compulsorily included in Member States'
Jukka Vauhkonen
macroprudential toolkit via the EU's regulation of
capital adequacy, the requirement for counter-cyclical
EU countries have – contrary to the
capital buffers and the capital buffer requirement for
general view – a relatively large amount of
globally systemically important banks. We also leave
experience in using potential
out macroprudential instruments that could possibly be
macroprudential tools, even if the specific
targeted at infrastructure actors and financial
purpose for their use has not been to ward
institutions other than banks.
off systemic risks and strengthen the
stability of the financial system. Half of the 5.2.1
The legislative basis for the use
countries in the EU have imposed a loan-
of macroprudential tools
to-value cap on housing loans, if differently
defined and used for different purposes.
The purpose of most potential macroprudential tools is
Some countries also have experience with
to regulate banks' capital adequacy and liquidity,
the use of capital adequacy requirements
which for their part affect banks' ability to grant loans
for banks in excess of the EU's minimum
and enlarge their balance sheets, the terms of lending
and banks' resilience to crises and losses. The
requirements on banks in the EU in regard to capital
This article examines EU countries' experiences to
adequacy and liquidity are set out in the Capital
date with the use, for either micro- or macroprudential
Requirements Directive and Regulation (CRD
purposes, of regulatory instruments that are suitable
IV/CRR). The Capital Requirements Directive defines
for use as macroprudential tools. We also examine
centrally the type of macroprudential tools national
Member States' intentions in the immediate years
authorities have at their disposal and how their use can
ahead to adopt macroprudential tools within the scope
possibly be directed or coordinated at EU level.
of the EU's Capital Requirements Directive.
With CRD IV, all Member States will be required for
The macroprudential tools to be examined can be
the first time to introduce a standardised
divided into three groups: (i) banks' capital adequacy
macroprudential tool, a counter-cyclical capital buffer.
requirements; (ii) banks' liquidity requirements; and
The imposition of a counter-cyclical capital buffer will
23 By macroprudential tools we mean regulatory
gradually become possible in all euro area countries at
instruments for which the primary, publically
the latest by 2016–2019, in accordance with the
expressed objective is to reduce risks to the stability of
timetable for transition set out in CRD IV. Earlier
the financial system as a whole and strengthen the
financial system's risk-bearing capacity relative to
24 In 2016, Member States must be able, where
such collective risks.
necessary, to impose a counter-cyclical capital buffer
Suomen Pankki Finlands Bank – Financial Stability and Statistics
introduction is also permitted. Of countries outside the
Many other potential macroprudential tools, too,
EU, Switzerland has already introduced a buffer
are outwith the scope of the Directive. It does not
requirement. Norway, too, may activate a buffer in the
cover regulatory instruments that affect the terms and
conditions of lending, such as the imposition of a loan-
The Directive and Regulation also make provision
to-value cap on housing loans or a maximum debt-to-
for other macroprudential tools that will allow
income ratio for loan applicants. The use of such
regulation of the size of capital buffer required of
instruments will in future continue to be at the
banks. Nationally systemically important credit
discretion of national authorities.
institutions can have an O-SII buffer of a maximum
2% imposed on the basis of their systemic importance.
New tools for the regulation of
In addition, or alternatively, a country can impose on
capital adequacy
all or some of its credit institutions a systemic risk
The EU's new Capital Requirements Directive and
buffer requirement of, as a rule, a maximum 5%. The
requirement for a systemic risk buffer can be imposed
Regulation will change the range of instruments
for structural or macroprudential reasons, for example
available to Member States to tighten the capital
the banking sector's large size relative to the country's
requirements on their countries' banks. The Capital
economy as a whole.
Requirements Directive currently in force is based on
The Directive does not, however, oblige Member
the principle of minimum harmonisation: the Directive
States to include a systemic risk buffer requirement in
defines EU-level minimum common requirements,
the tools available to their authority with responsibility
from which Member States are free to differ in a
for macroprudential supervision. It is not yet apparent
stricter direction. In contrast, the new CRD IV will be
if this requirement will be made available to Finland's
based on maximum harmonisation, from which
macroprudential supervisory authority.
Member states may differ only in ways defined in the
The new quantitative liquidity standards included
text of the Directive.
in Basel III and EU rules – the Liquidity Coverage
Member States will in future have three ways in
Ratio (LCR) and the Net Stable Funding Ratio (NSFR)
which they can impose on some or all of their credit
– are essentially microprudential provisions. It is still
institutions (structural) capital requirements beyond
unclear to what extent they will in future be usable
the mandatory EU minimum: 1) an O-SII buffer
nationally as countercyclical or discretionary
requirement 2) a systemic risk buffer requirement or 3)
measures. Member States can, however, use other
a capital buffer requirement imposed on a single credit
liquidity requirements for either micro- or
institution by the banking supervisor on the basis of a
macroprudential purposes.
Pillar 2 assessment. Of these, the first two are new
instruments. Pillar 2 requirements have been in use
since the implementation of the Basel II capital of at most 0.625%. This level will be raised annually
framework. As well as institution-specific risk factors,
by 0.625 percentage points until 2019, when they must
use of a Pillar 2 requirement could in future also be
be able, where necessary, to impose a counter-cyclical
based on macroprudential reasons, such as the risks an
capital buffer of 2.5%.
Financial Stability and Statistics – Suomen Pankki Finlands Bank
individual institution poses to the financial system as a
has been used, in a number of very different ways.
There are major differences between European
Already prior to the financial crisis, some countries of
countries in respect of how ‘binding' the loan-to-value
Central and Eastern Europe (Croatia, Estonia) were
cap has been, and hence how much its use has
already using capital requirements that were stricter
restricted housing lending and affected its terms and
than the EU's minimum requirements. For example, in
Estonia the minimum capital requirement for banks
The effectiveness of a loan-to-value cap is
was raised from 8% to 10% as early as 1997.
influenced by, for example, its level, scope (applies to
As a consequence of the financial crisis, the minimum
all mortgage-backed loans, or just to some), how
capital requirements for banks were also tightened in
legally binding it is (recommendation or mandatory),
Greece, which imposed a 9% core capital requirement
the sanctions for a breach of the rules, and whether
(Core Tier 1) in March 2013. In Portugal, too, the core
unsecured top-up loans are allowed.
capital requirement for banks was increased. Slovakia
In Sweden, for example, the loan-to-value cap is
has in place a non-binding core capital
binding and is applied comprehensively to all
recommendation of 9%.
mortgage-backed loans. In some countries, however,
rules like loan-to-value caps are applied more
Use of instruments that
influence housing lending
In some countries, such as Finland, the loan-to-
value cap is a non-mandatory recommendation. In a
Authorities in European countries have made extensive
few countries (Poland, Romania and Hungary) the
use of regulatory instruments that restrict bank lending
loan-to-value cap applies only to housing loans
for the purchase of housing and other real estate. The
denominated in foreign currency.
use of these instruments has been motivated by both
European countries have not used loan-to-value
‘microprudential' and ‘macroprudential' objectives.
caps as a discretionary countercyclical tool; as a rule, it
The former include strengthening consumer protection
has been applied either as a fixed rule or at least as a
and the capital adequacy of banks, while the latter
rule with only rare exceptions. It is chiefly just certain
would be, for example, the objective of moderating the
Asian countries that have experience with using a
pace of growth in housing loans or rising house prices.
To date, microprudential objectives would appear to
Belgium, the United Kingdom, Italy, Latvia,
have been the more important motivation.
Lithuania, Portugal, Poland, France, Sweden,
Romania, Slovakia, Finland and Hungary. Experiences
Loan-to-value caps
with using a loan-to-value cap are examined in more
A loan-to-value cap has been the most commonly used
detail in Vauhkonen and Putkuri (2013) ‘Lamauttaako
regulatory instrument targeting lending to house
vai vakauttaako lainakatto Suomen asuntomarkkinat?'
purchasers.25 A loan-to-value cap can be used, and
[‘Would a loan-to-value cap stabilise or paralyse the
Finnish housing market?'] Kansantaloudellinen
25 Countries that have applied a loan-to-value cap in its aikakauskirja [Finnish Economic Journal], 109,
various forms include at least the Netherlands,
Suomen Pankki Finlands Bank – Financial Stability and Statistics
loan-to-value cap as a tool of active (macroprudential)
instruments has been primarily for microprudential
purposes. Many countries have in use similar
requirements for minimum levels of liquid assets to be
Other regulatory instruments applied to
held by banks to those envisaged for the forthcoming
housing lending
Liquidity Coverage Ratio.27 In a few countries, banks
Loan applicants' loan-to-income (LTI) ratio or debt-to-
are also required to have sufficient liquid assets
income (DTI) ratios have been used in many EU
denominated in foreign currency (Croatia, Sweden and
countries.26 In Finland, the Financial Supervisory
Hungary). Meanwhile, foreign subsidiaries of Austrian
Authority (FIN-FSA) has not issued direct
banks are required to have a sufficient level of funding
recommendations regarding the LTI/DTI or a
acquisition in their country of operation.
maximum debt service burden. FIN-FSA has,
In some non-euro-area countries, the requirements
however, urged banks operating in Finland to carry out
for banks' cash reserves can potentially be used as
a financial margin assessment for every new housing
macroprudential instruments (Croatia and Hungary).
loan applicant. Stress test calculations of a loan
Foreign-sourced or foreign-currency-denominated
applicant's debt-servicing capacity should be
funding has also had imposed upon it in individual
conducted at least for the highest level of interest rates
countries various cash reserve requirements (Croatia)
seen in the euro era (12-month Euribor at 6%) and for
or else is subject to more intensive supervision
a maximum repayment period of 25 years.
The housing loan risk weightings employed by
banks in their capital adequacy calculations can also be
raised for macroprudential reasons. Of the Nordic
countries, Sweden and Norway have raised their
housing loan risk weightings above the minimum
levels defined in the Capital Requirements Regulation.
Individual EU countries also have in place and
available for use other regulatory instruments to
influence housing lending. Examples include sectoral
capital requirements (United Kingdom), limits on
housing loan interest rates and on the duration of loans
(France) and dynamic loan loss reservations (Spain).
Liquidity requirements
EU countries have had no experience of the explicitly
macroprudential use of regulatory instruments that
influence banking liquidity; the use of such
27 Such countries include at least Belgium, Croatia,
26 These include at least the Netherlands, Belgium,
Poland, Portugal, France, Romania, Slovakia, Sweden,
France, Lithuania, Portugal and Poland.
Denmark and Hungary.
Financial Stability and Statistics – Suomen Pankki Finlands Bank
Source: http://vds14550-haaga-helia.jelastic.planeetta.net/sites/default/files/Kuvat-ja-liitteet/Koulutus/Hakeminen/fina_k2014_ennakko_financial_market_report.pdf
Significant Risks of Oral Why This Drug Class Should Not Be Included in a Preventive Care Mandate Rebecca Peck, M.D., C.C.D., and Charles W. Norris, M.D.* Dr. Rebecca Peck is a board-certified family physician, certified clinical densitometer, and Marquette Method NFP teacher. Dr. Peck may be
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