ISWGNA Task Force on FISIM Status Report OECD Working Party on Trade in Goods and Services Paris, November 2011 Contact: nadim.ahmad@oecd.org A simple world Loans matched to deposits Assuming no credit-default risk • Matched-maturity approach = single reference rate approach 120 100 80 Loans 60 Deposits 40 20 0 1 2 3 4 A slightly more complicated world Loans = deposits but not matched 300 250 200 Loans 150 Deposits 100 50 0 1 2 3 4 • (assuming margin rate is the same for all maturities) Matchedmaturity approach is unchanged. • But FISIM higher with single reference rate approach. • Liquidity transformation services? Background • Task Force created in late 2010. • Partly in relation to 2008 SNA research agenda: – The SNA recommends that FISIM should be calculated with respect to a reference rate that contains no service element and reflects the risk and maturity structure of deposits and loans. Different reference rates may be needed for domestic and foreign financial institutions. The assumption behind the FISIM approach is that it is the service element, and not the interest flows, that reflect varying degrees of risk, with riskier clients paying a higher service charge. This assumption has been queried and is being investigated. • But also partly in response to volatile (including negative) and difficult to interpret FISIM series in wake of recent financial crisis Terms of Reference • Two meetings: March and July 2011 (merged with European Task Force) with following ToR: 1. How does the composition of the services that FISIM covers—particularly risk management and liquidity transformation—affect the selection of the reference rate and the price and volume breakdown of FISIM. 2. What should be the financial instrument and unit scope of FISIM 3. What are the connections between the recommendations on implementation of FISIM and the definition of income. Short-term clarification questions • How can FISIM be made consistent in international trade? • Liquidity transformation, a service or not? • Credit-default risk? Compensation for riskmitigation/purchased insurance or a distributive flow (analogous to insurance). • What are the implications for the price and volume measures of FISIM? International Trade • FISIM should be calculated by at least two groups of currencies (national and foreign currency). • But recognition that data availability across countries is sparse and, so, there may be a need for international coordination to better estimate the imports/exports of FISIM through counterparty data. Liquidity Transformation • #6.158 of 2008 SNA explicitly recognises that financial intermediation services include liquidity transformation. • SNA refers to FISIM as being: (RR – RD).D (Deposits) + (RL –RR).L (Loans) • However, there is a view that liquidity transformation is a non-productive activity related to risk-bearing services, and, so, should be excluded from FISIM. • Matched-Maturity method removes term-premium So, e.g. FISIM on Loans = Σ (RtL –RRt).Lt Two interesting points Ignoring credit-default risk • Matched maturity approach = single reference rate approach if the maturity structure and size of loans and deposits is the same. But deposit/loan FISIM varies. So, extending the range of instruments on which FISIM could be calculated probably closes the gap. • And total FISIM using a single reference rate is the same irrespective of the reference rate chosen if total deposits = total loans. Liquidity Transformation • Many countries use inter-bank lending rate for RR, which proved troublesome during the crisis, creating volatility and negative component estimates of FISIM. Matched maturity rates should provide greater stability. But the Task Force has tentatively concluded that the removal of LT would result in implausibly low estimates of FISIM. • One key argument for a matched approach related to the view that the VA of firms should be indifferent to their means of financing (corporate bond versus a loan – where the term premium for the former is interest but with a loan it is FISIM). But the TF felt this assumed an equivalence between bonds and loans that did not hold, and did not negate the inclusion of LT but rather raised the question about the instrument and institutional scope of FISIM. • The TF also recognised that in removing LT from FISIM it would by default arise in SNA interest; changing the definition, Liquidity Transformation • However. • The TF recognised that, in practice, the use of single reference rate based on short-term maturities had proved problematic. – All other things being equal, does it make sense for the split of FISIM services provided by a bank to depositors and borrowers to change (potentially significantly), from one day to the next, in line with changes in the interbank lending rate, if the bank changes none of the terms and conditions to borrowers or savers and requires no additional funding itself from one day to the next? And so affect GDP? – All other things equal, why should changes in the interbank lending rate necessarily mean differing price movements in FISIM prices for deposits and FISIM prices for borrowers, when the bank's actual costs of production have, to all extents and purposes, remained unchanged? • And so the TF have tentatively concluded that the reference rate may be better estimated if it reflects a mix (average) of underlying rates for deposits and loans with different maturities. • The TF also considered and still is a ‘Cost of funds’ approach, which defines the reference rate for an institution based on its interest costs including the implicit costs of its own funds. Liquidity Transformation • Action:- To test the following: – Single reference rate using inter-bank lending rates. – Reference rate calculated using the midpoint of interest rates on deposits and interest rates on loans. – Average reference rate (weighted by the stocks of short-term and long-term loans and deposits) calculated using different rates for the short-term and long-term reference rates. – Matching reference rates using different rates for short-term and long-term deposits and loans Credit-default risk • The majority of the TF (so far) have concluded that credit-default risk should be removed from FISIM and treated in an analogous way to non-life insurance services. • Estimates could be derived using information on CDS, write-offs, provisions. This is currently being tested using an approach developed by Eurostat. Once these results have been completed the TF will review its position, vis-a-vis the feasibility of removing creditdefault risk. • A secondary issue concerns the accounting treatment of bad debt write-offs. The insurance analogy would mean that households receive a transfer from banks i.r.o of write-offs, increasing saving. Price and Volumes • Direct output approach has merit but is a complex task requiring very detailed data. • Task Force expressed a preference for direct deflation methods using a general price index for deflating stocks of loans and deposits. • However it was emphasised that the calculation of volume estimates needed to be made by type (maturity) of loan and deposit as the margin varied by maturity. Next steps • Preliminary report with TF. • Tests are being conducted by European countries (except the matched-maturity approach) both for reference rate and creditdefault risk. • ISWGNA TF members conducting similar tests for reference rate. • ABS and BEA volunteered to investigate cost of funds approach. • Assessment of returns, and subsequent next steps, to be conducted in Q1 2012.