The Effects of Model Assumptions
The Effects of Model Assumptions
The Effects of Model Assumptions
Since the European Central Bank (ECB) embarked on its current monetary policy
stance (negative interest rates, sovereign and corporate bond purchases), one question
has come up time and again: what effect does this accommodative stance have on
the profitability of banks in the euro area? Given that this issue is highly relevant for
monetary policy makers and bank supervisors, it has been discussed regularly by
the Oesterreichische Nationalbank (OeNB). Kerbl and Sigmund (2016) examine
the empirical relationship between low interest rates and net interest margins, sim-
ulating the asymmetric effect of negative interest rates on profitability. They show
that the low and negative interest rate environment adversely affects banks’ net in-
terest income (see e.g. also Drescher et al., 2016; Eggertsson et al., 2019; Genay
and Podjasek, 2014; Gros, 2018).
This effect is less evident with large banks, as shown by Kerbl and Sigmund
(2016), and is possibly explained by banks (partly) compensating for this by
(a) higher credit volumes, (b) higher credit risks or (c) higher interest rate risks.
The positive link between higher interest rate risks and a higher net interest margin
has been corroborated, among others, by Angbazo (1997) and Entrop et al. (2015;
see also the discussion in Bologna, 2018).
1
Oesterreichische Nationalbank, Financial Markets Analysis and Surveillance Division, stefan.kerbl@ oenb.at;
On-Site Supervision Division – Significant Institutions, boris.simunovic@ oenb.at; Supervisory Statistics, Models
and Credit Quality Assessment Division, andreas.wolf@ oenb.at. Opinions expressed by the authors of studies do not
necessarily reflect the official viewpoint of the Oesterreichische Nationalbank (OeNB) or of the Eurosystem. The
authors thank Pierluigi Bologna for his comments, which improved the overall readability and precision of the study.
Yet, when the interest rate risk as reported by banks is considered (see also
chart 2), then no increased interest rate risk is observable during the period of
accommodative monetary policy.
For this reason, OeNB bank examiners, when they started carrying out business
model-related on-site inspections at the end of 2017, focused, inter alia, on interest
rate risk. What they observed was that banks were engaging more and more in
maturity transformation due to its positive effect on net interest income. In other
words, banks were striving to compensate for the contracting net interest margin
by making longer-term investments (i.e. longer interest rate fixation periods),
which, according to the banks, also tied in with the customers’ demands. Never-
theless, the higher degree of maturity transformation was not reflected by an
increase in the risk reported.2 We assumed that the respective banks continuously
raised the (fictitious) interest rate fixation period of sight deposits and hereby offset
the longer interest rate fixation periods on the assets side. In this study, we con-
firm this hypothesis.
1 Interest rate risk – basic facts
According to classical finance theories (see e.g. Hicks, 1946), maturity transformation
is an integral part of the banking business: in other words, credit institutions extend
long-term finance (by granting long-term loans) and engage in short-term funding
(by taking in short-term or sight deposits). This denotes maturity transformation
from a liquidity perspective.
Another form is maturity transformation from the interest rate perspective.
Interest rate fixation periods may deviate from liquidity deadlines both on the assets
side (e.g. variable rate loans) and on the liabilities side (e.g. deposits with a floating rate).
A bank’s net interest income depends, inter alia, on the difference between the
risk-free interest rate applicable to assets and liabilities.3 With a “normal” upward
sloping yield curve, the long-term interest rates exceed the short-term interest
rates. Credit institutions earn a structural contribution if the interest rate fixation
period of their lending business is higher than that of their deposit business.
Chart 1 displays the yield curves in the euro area (for AAA-rated sovereigns)
from year-end 2007 to year-end 2018. For readability, we only show the yield
curve for every other year, with the exception of 2017 and 2018. We see that
(1) the yield curve was upward sloping during the whole period (least pronounced
in 2007), and that (2) especially after 2013, yields were substantially compressed
over the entire maturity range. The first observation implies that banks can increase
net interest income by means of maturity transformation, and the second – in
combination with depressed margins in times of low rates (see the literature section
above) – that banks have a stronger incentive to do so.
2
As explained in section 2, the interest rate risk statistics are part of a bank’s reported “asset, income and risk statement”
under statutory law. At the unconsolidated level, credit institutions submit quarterly reports in line with Annex
A3b of the Regulation on Asset, Income and Risk Statements; at the consolidated level, banking groups pursuant
to Article 59 and Article 59a Austrian Banking Act submit quarterly reports in line with Annex B3b and C3b of
the Regulation on Asset, Income and Risk Statements.
3
Another important driver is the margin contribution, which equals the difference between the credit institution’s
credit spread (margin contribution on the liabilities side) and its customers (margin contribution on the assets side).
The relationships are presented here in a simplified manner.
74 OESTERREICHISCHE NATIONALBANK
Quantifying interest rate risk and the effect of model assumptions behind sight deposits
Chart 1
There is no reward/return without
risk, which is why this type of maturity Yield curves in the euro area, 2007–2018
transformation carries interest rate Yield in %
risk: if interest rates increase along the 5.5
4
See e.g. European Banking Authority (EBA, 2018).
5
Apart from sight deposits, some employee pension claims fall into this category, but size-wise, such claims are
underrepresented in our case.
6
EBA (2015), para. 24(d).
7
EBA (2018), para. 115(o).
8
In the following, we do not consider trading book positions as capital charges apply to trading book interest rate risk.
9
That is, this measure approximates the present value change of the position in the event of a +/–200-basis-point parallel
shift of the yield curve. For the requirements for calculating more complex interest rate scenarios, see BCBS (2016).
76 OESTERREICHISCHE NATIONALBANK
Quantifying interest rate risk and the effect of model assumptions behind sight deposits
the interest rate on these NMDs unchanged. In turn, if the model estimates allocate
NMDs to buckets with long rate fixation periods, this mitigates the long-end asset
overhang that results from loans and bonds with contractually fixed repricing
dates. Unlike, for instance, internal ratings-based (IRB) models, which have to be
approved by the competent authority before they can be used, this modeling
approach is not subject to such supervisory approval. While the validation of the
assumptions may be challenged during relevant on-site inspections and the Austrian
Financial Market Authority (FMA) or the ECB may impose pertinent requirements
when following up on such inspections, there may be a significant time lag between
the implementation of a new model (and its calibration) and the acknowledgment of
the model by the supervisory authorities.
3 Objective
In this analysis, we aim to identify the extent to which banks took on more interest
rate risk over the past few years, which, ceteris paribus, increased interest income.
To this end, we draw on data reported by 482 (groups of) credit institutions10 and
adjust these data for the effect of model assumptions to compare the interest rate
risk over time and across banks.
The analysis is meant to shed light on the question whether maturity transformation
has been stepped up in the Austrian banking system since the beginning of the low
interest rate period. In addition, by employing the method introduced in the next
section, we also gain insights into the extent to which banks model sight deposits
in order to identify any outliers and model risks.
4 Methodology
To reach the desired level of comparability, it is first of all necessary to neutralize
the impact of the heterogeneous model assumptions behind sight deposits. Please
note that modeling heterogeneity does not necessarily have to be an indicator of
misquantification, since the economic interest rate sensitivity of sight deposits indeed
varies depending on the respective bank’s business model. An in-depth assessment
may only be carried out by way of an on-site inspection.
This notwithstanding, reporting data may be used to perform plausibility
checks on a bank’s model assumptions, especially for the purpose of peer group
comparisons. The bolder the model assumptions are, the higher is the model risk
of the respective bank. Model risk exists even in cases where the model assumptions
are justified and have been validated accordingly. Reliable validation coupled with
conservative model assumptions help reduce the resulting model risk11.
To ensure a level playing field for banks regarding these model assumptions,
we, for one thing, compute the IRR for all banks in the sample, using data reported
in the interest rate risk statistics. For another thing, we edit the data reported by
banks as follows: in line with their contractual maturity, we allocate NMDs to the
time bucket with the lowest rate fixation period (i.e. less than one month). This
represents the most conservative approach and the assumption of the shortest possible
10
To be precise, these data comprise all fully operating credit institutions at the highest level (i.e. consolidated in
the case of groups) as at end-2017.
11
For the provisions on how to consider these model risks, see EBA (2018) para.108(h,i).
fictitious rate fixation period.12 To keep it simple, we call the thus calculated change
in present value given an assumed interest rate change of 200 basis points under
level playing field assumptions “interest rate risk under level playing field assump-
tions” or IRR-LPF, to refer to the time series of the changes in the present value
calculated in this way.
In a second step, we compare the IRR-LPF with the reported IRR over time to
identify any trends. A rising IRR-LPF time series is indicative of a bank’s increased
maturity transformation. If the IRR-LPF time series rises more strongly than the
reported IRR, the bank is likely to progressively model NMDs.
Finally, we sort and rank the results. We deem those credit institutions “model
dependent” whose interest rate risk exceeds 20% of their own funds according to
the IRR-LPF, i.e. banks that do not exceed the regulatory limit only thanks to
model assumptions behind NMDs. In addition, we identify those institutions
whose model assumptions on the fictitious maturity of sight deposits are more
aggressive (longer duration) than the respective assumptions of the peer group.
5 Outcome for bank aggregates
Chart 2 shows the interest rate risk reported by Austrian banks. It is evident from this
chart that while small banks13 systematically increased their interest rate risk, neither
medium-sized banks nor large banks increased their interest rate risk as reported
in the interest rate risk statistics during the indicated period. For the r emainder of
this study, note that whenever we refer to bank aggregates (small, medium-sized
and large banks), we refer to an average bank representative of the given sample and
do not mean every individual bank classified as small, medium-sized or large.
Chart 2
1 Sep. 06 Sep. 08
0
Sep. 05 Sep. 06 Sep. 07 Sep. 08 Sep. 09 Sep. 10 Sep. 11 Sep. 12 Sep. 13 Sep. 14 Sep. 15 Sep. 16 Sep. 17 Sep. 18
Large banks Medium-sized banks Small banks
Source: Supervisory statistics, authors’ calculations.
12
In fact, this corresponds to the most conservative assumption under a +200-basis-point shift of the yield curve.
13
Small banks: total assets < EUR 1 billion; medium-sized banks: total assets < EUR 20 billion; large banks: total
assets ≥ EUR 20 billion. “Large banks” include all systemically important institutions according to Article 23c
Austrian Banking Act. For a further description of the data, see the subsequent sections.
78 OESTERREICHISCHE NATIONALBANK
Quantifying interest rate risk and the effect of model assumptions behind sight deposits
In the event of a +200-basis-point shift of the yield curve and based on the data
reported by banks, the present value of large Austrian banks’ own funds declines
by less than 2% as of September 2018.
Chart 3 compares the reported IRR with the computed IRR-LPF. Especially
large banks (total assets ≥ EUR 20 billion) show a notable rise in the IRR-LPF, i.e.
the interest rate risk under an assumed short rate fixation period for NMDs. This
strong increase in large banks’ exposure to interest rate risk has an impact on the
average of the entire banking sector given large banks’ weight. For medium-sized
banks, only a moderate increase is observed. In parallel to their IRR, small banks’
IRR-LPF went up in recent years.
Chart 3
Volume-weighted averages of the reported IRR and the IRR-LPF of four bank aggregates
All banks Large banks
Impact of 200-basis-point shift in % of own funds Impact of 200-basis-point shift in % of own funds
20.0 20.0
17.5 17.5
15.0 15.0
12.0 12.5
10.0 10.0
7.5 7.5
5.0 5.0
2.5 2.5
0.0 0.0
Sep. 06 Sep. 08 Sep. 10 Sep. 12 Sep. 14 Sep. 16 Sep. 18 Sep. 08 Sep. 10 Sep. 12 Sep. 14 Sep. 16 Sep. 18
9 10.5
8 9.0
7 7.5
6 6.0
5 4.5
4 3.0
3 1.5
2 0.0
1 –1.5
0 –3.0
Sep. 06 Sep. 08 Sep. 10 Sep. 12 Sep. 14 Sep. 16 Sep. 18 Sep. 06 Sep. 08 Sep. 10 Sep. 12 Sep. 14 Sep. 16 Sep. 18
Interest rate risk – level playing field (IRR-LPF) Interest rate risk – reported (IRR)
Source: Supervisory statistics, authors’ calculations.
Note: For large banks, the x-axis dates back to 2008 only in order to keep changes in the composition of the respective bank aggregates over time to a minimum. Please note that the
y-axis features different percentages in all four panels.
In contrast to small banks, large banks’ increased exposure to interest rate risk
is not reflected in the reported 200-basis-point shift (IRR, dark red line in chart 3)
but becomes evident only once the model assumptions, which change over time,
are neutralized (IRR-LPF). It is noteworthy that, compared with small banks,
large banks develop models considering interest rate fixation periods much more
frequently.
IRR reported by large banks invariably amounted to less than 5% of own funds;
in contrast, interest rate risk adjusted for model assumptions behind sight deposits
(IRR-LPF) came to around 19.8% of own funds. Under level playing field assumptions,
large banks’ exposure to interest rate risk is considerably higher than the reported
interest rate risk. One presumption is that large banks use the room for maneuver
they have in considering NMDs in interest rate risk calculations to keep the IRR to
be reported relatively low.
For better comparability across the banking aggregates, chart 4 shows the IRR-
LPF adjusted for assumptions behind sight deposits.
The rise in large banks’ interest rate risk coincides with the beginning of the
low interest rate period; it is also a manifestation of large Austrian banks’
stepped-up recourse to maturity transformation to fight off interest income erosion.
In a similar vein, albeit from a low starting level, medium-sized and small banks
also show a marked increase in interest rate risk since the beginning of the low
interest rate period, which reflects their attempt to maintain the net interest margin
by taking on more interest rate risk. Medium-sized banks started earlier to take on
interest rate risk and display a stronger reliance on model assumptions than large
banks but a larger model reliance than small banks, as reflected by the respective
differences in IRR and IRR-LPF in chart 3. Compared to small banks, medium-sized
banks have not extended their maturity transformation as monotonically as small
banks and not as drastically as large banks but still show a marked increase in the
IRR-LPF from 5% in 2011 to 9% toward the end of 2018.
In the following, we take a closer look at a case study that illustrates the magnitude
of this phenomenon. Before we do so, however, we mention one caveat: some
Chart 4
17.5
15.0
12.5
10.0
7.5
5.0
2.5
0.0
Sep. 06 Sep. 08 Sep. 10 Sep. 12 Sep. 14 Sep. 16 Sep. 18
Large banks Medium-sized banks Small banks
Source: Supervisory statistics, authors’ calculations.
80 OESTERREICHISCHE NATIONALBANK
Quantifying interest rate risk and the effect of model assumptions behind sight deposits
banks provide behavioral economic reasons for their model assumptions in the risk
management talks with bank supervisors. For instance, banks pointed out that,
amid the prevailing low interest rates, depositors hardly pay any attention to the
interest rate on their instruments. This is why not changing the interest rate on
deposits in tandem with the market would hardly have an impact on the deposit
volume. Moreover, banks allegedly dispose of data (but only for individual countries
in Central, Eastern and Southeastern Europe) that corroborate this hypothesis. It
remains to be seen, however, whether this reasoning still applies to a deposit market
that, driven by technological advances, is becoming ever more efficient.
6 Case study of a bank
For a case study, we chose an example bank in order to illustrate that implications
for financial stability would arise if several banks hypothetically followed an aggressive
interest rate risk strategy. These insights allow us to recommend specific general
policy action for safeguarding financial stability, which we present in the final section.
The example bank markedly increased its interest rate risk under level playing
field assumptions in 2014 (when the zero interest rate period began), while at the
same time reducing the interest rate risk reported in supervisory statistics. This
difference may be traceable to two factors: (1) a fictitious rate fixation period for
deposits in model assumptions which changes over time and (2) a rise in the deposit
volume (quantity effect).
The first effect, the change in the assumptions about the interest rate sensitivity
of sight deposits, is illustrated in chart 5. The chart shows the model assumptions
this bank applies to sight deposits as compared with the volume-weighted average
of all banks. At the beginning of 2018, the rate fixation period for sight deposits
was assumed to be more than 30 months by the example bank in its model assump-
tions. The longer this assumed rate fixation period is, the greater is the deviation
of the r eported IRR from the IRR-LPF. The analogous average across all banks,
and also of large banks, amounted to only about half that time. As to the example
bank’s assumptions, it is evident, on the one hand, that they were changed and, on
the other, that they reached elevated values (> 2.5 years) as early as in 2013.
Chart 5
30
25
20
15
10
5
Sep. 08 Sep. 10 Sep. 12 Sep. 14 Sep. 16 Sep. 18
Example bank All banks
Source: Supervisory statistics, authors‘ calculations.
Chart 6
The computations underlying the
Factors determining the difference second effect, the volume increase over
between the IRR-LPF and the reported time, are shown in chart 6. In the third
IRR, as of 2018Q3 quarter of 2018, the difference b etween
Impact of 200-basis-point shift in % of own funds
the IRR-LPF and the reported IRR
40
+11% +37%
3 4
amounts to about 37% of own funds.
This difference may be broken down as
30
follows: the difference between the LPF
+12% 2
model assumptions and the model as-
20
sumptions used by the example bank
+14% 1
for sight deposits at year-end 2011 ac-
10 counts for some 14 percentage points
(initial modeling effect). The effect of
0 changes to the model assumptions for
Source: Supervisory statistics, authors’ calculations. sight deposits between the fourth quar-
1
Difference between LPF and modeling sight deposits at year-end 2011.
2
Effect of changes to model assumptions between 2011Q4 and 2018Q3.
ter of 2011 and the third quarter of 2018
3
Increase in deposits since 2011Q4. equals some 12 percentage points
4
Total effect.
(time-changing model assumptions).
The increase in deposits recorded since
the fourth quarter of 2011 accounts for some 11 percentage points (quantity effect).
In addition to the calculated IRR-LPF and the reported IRR, chart 7 depicts
the interest rate risk had the bank under review not adjusted the distribution of
sight deposits over maturity buckets as of year-end 2011 (blue line). The difference
between the latter and the reported IRR demonstrates that the bank lowered its
reported interest rate risk by around 12% of own funds between the final quarter of
2011 and the third quarter of 2018 by changing the distribution across maturity
buckets (time-changing model assumptions).
If the bank had not adjusted the distribution of sight deposits across maturity
buckets as of year-end 2011, it would be exposed to interest rate risk of 14% instead
of 2% of own funds at the end of the third quarter 2018.
Chart 7
30
20
10
–10
–20
Sep. 08 Sep. 10 Sep. 12 Sep. 14 Sep. 16 Sep. 18
Distribution over maturity buckets constant as of year-end 2011 Interest rate risk – level playing field (IRR-LPF)
Interest rate risk – reported (IRR)
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Quantifying interest rate risk and the effect of model assumptions behind sight deposits
Reported IRR and IRR-LPF of the example bank and IRR of the
derivative positions
Impact of 200-basis-point shift in % of own funds
40
35
30
25
20
15
10
–5
–10
–20
Sep. 08 Sep. 10 Sep. 12 Sep. 14 Sep. 16 Sep. 18
Interest rate risk – derivatives only Interest rate risk – level playing field (IRR-LPF)
Interest rate risk – reported (IRR)
7 Summary
In this study, we show that Austrian banks in aggregate increased their interest
rate risk amid the low interest rate environment. The extent of such an increase
becomes evident when the interest rate risk reported by banks is harmonized over
time and across banks under conservative model assumptions for sight deposits
which we introduced to ensure a level playing field.
From our analysis, we draw the following policy recommendations. First, it is
important for supervisors to be aware of the general issue, namely that interest rate
risk might be hidden under model assumptions on sight deposits. Financial stability
experts should be knowledgeable about the general trend in interest rate risk and
banking supervisors need to question banks’ modeling assumptions and apply a
harmonized approach in the supervisory review and evaluation process under Pillar 2.
Second, we could imagine that, in comparison with other euro area banks,
Austrian banks are, generally speaking, not the only ones practicing interest rate
risk modeling. Hence, we argue that, from a financial stability perspective, it might
be worth taking a closer look at euro area banks’ modeling choices for capturing
depositor behavior. Third, we encourage further research to examine how much
banks benefit from taking on more interest rate risk.
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Quantifying interest rate risk and the effect of model assumptions behind sight deposits
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