Ádám Banai1,2, Edina Berlinger3, Barbara Dömötör3. 1. Executive Directorate for Monetary Policy Instruments and Foreign Reserve Management, National Bank of Hungary, Budapest, Hungary. 2. MNB Institute, John von Neumann University, Kecskemét, Hungary. 3. Department of Finance, Corvinus University of Budapest, Budapest, Hungary.
Abstract
We investigate the problem of interest rate risk transforming into default risk of adjustable-rate mortgage loans in the EU. Bank regulation is strikingly not neutral in this aspect, it explicitly favors short-duration adjustable-rate loans over long-duration fixed-rate loans in the framework of the gap management. This asymmetry in the regulation creates perverse incentives both for banks and households, which can lead to aggressive risk-taking, over-indebtedness of unhedged households, high procyclicality of mortgage markets, and increased systemic risks. We present a stress test model to quantify potential losses stemming from this specific risk from the perspective of lender institutions. We estimate the average extra capital that is needed to cover the additional risk of adjustable-rate mortgage loans in the EU to be 0.53% of the value of the total mortgage portfolio and 1.97% of the value of the adjustable-rate mortgage portfolio. We propose introducing a stress test model as a new mandatory element into banks' risk management framework.
We investigate the problem of interest rate risk transforming into default risk of adjustable-rate mortgage loans in the EU. Bank regulation is strikingly not neutral in this aspect, it explicitly favors short-duration adjustable-rate loans over long-duration fixed-rate loans in the framework of the gap management. This asymmetry in the regulation creates perverse incentives both for banks and households, which can lead to aggressive risk-taking, over-indebtedness of unhedged households, high procyclicality of mortgage markets, and increased systemic risks. We present a stress test model to quantify potential losses stemming from this specific risk from the perspective of lender institutions. We estimate the average extra capital that is needed to cover the additional risk of adjustable-rate mortgage loans in the EU to be 0.53% of the value of the total mortgage portfolio and 1.97% of the value of the adjustable-rate mortgage portfolio. We propose introducing a stress test model as a new mandatory element into banks' risk management framework.
Foreign exchange (FX) lending for households or other unhedged borrowers has been
widely discussed in the literature. In this context, Eichengreen et al. [1] called indebtedness in
foreign currency the original sin. Several authors concluded that FX debts of
unhedged borrowers may threaten financial stability, worsen the effectiveness of the
monetary policy, and lead to severe social crises [2-4]. Transferring unmanageable risks to
households is contrary to the basic principles of sustainable finance [5].The risk of adjustable-rate mortgages (ARMs) for the household sector has been
subject to much lower attention in the literature although it is similar to FX
lending in several aspects. A huge and mainly underestimated market risk (changes in
interest rates or FX rates) can easily turn into credit risk and lead to significant
credit losses in mortgage markets. There are different channels through which
interest rate risk may increase the delinquency rate of mortgages. As Doms et al.
[6] showed in their paper
for the US market during the Great Financial Crisis (GFC), rising interest rates led
to mass defaults of subprime mortgages due to higher installments. Higher
installments worsen the ability to pay mortgages but also have a negative effect on
willingness-to-pay since higher rates may decrease the potential appreciation of
house prices. Pennington‐Cross and Ho [7] also found that default probabilities
increase dramatically in the case of low or negative home equity. From this
perspective, widespread ARMs—similarly to widespread FX lending—may also narrow down
the room for maneuver of monetary policy since any interest rate decision can have
serious consequences for financial stability and social cohesion. This is especially
true in today’s environment, where after many years of zero rates, central banks
started to tighten monetary conditions. Although the ECB and the FED are still
waiting, sooner or later they will start raising interest rates. Many central banks
of smaller EU countries are already in their hiking cycle.Our paper fills out a research gap from several aspects. First, we contribute to the
literature on the choice between adjustable-rate (ARM) versus fixed-rate (FRM)
mortgages by investigating an important effect on the supply side that has not been
discussed so far, namely banks’ capital regulation. We show that capital adequacy
regulations are distorting towards ARM lending. Second, we propose a specific stress
test supplement to the Basel regulations which would make capital calculations
neutral from the ARM-FRM perspective. Our recommendation builds on the literature of
credit and market risk management, especially the modeling of wrong-way risks.
Finally, we elaborate on a stress test methodology by which we quantify the extra
default risks and the corresponding extra capital need of ARMs relative to FRMs for
the EU banking sector. Our empirical study draws attention to the significant
unhedged household exposure in many European countries.Borrowers find ARM loans more attractive if the yield curve is increasing (so most of
the time) as they focus on short term cost minimization while underestimating the
future interest rate risk [8-11]. Berlinger
[12] argued that the
calculation method of APRC misleads the borrowers and strengthens their myopic view.
Several authors found that personal traits and psychological effects also play a
role in borrowers’ choice [13-15], while
Albertazzi et al. [16] and
Gathergood and Weber [17]
emphasized the effects of education and financial literacy. The product
characteristics are more complicated in the case of ARMs as compared to FRMs since
installments are not a linear function of interest rates [18]. The National Bank of Hungary [19] found that customers do not
understand the risks of variable-rate mortgages as an overwhelming majority of
borrowers could not answer what would happen with the installment after a rate hike.
Therefore, with ARM loans, a large amount of interest rate risk is transferred from
professional banks to non-professional households that can hardly calculate, hedge,
or manage it. After a decade of a low interest rate environment, it has become
increasingly important to get prepared for the potential broader scale of
defaults.Moench et al. [20] and Zocchi
[10] pointed out that the
share of ARM loans depends heavily on supply-side factors, as well, most importantly
the availability of securitization and state guarantee programs for the banks. Foà
et al. [21] documented that
banks hit by shocks (related to the deposit base, long term funding, or
securitization) tend to lend ARMs; and this can be effectuated through different
channels such as the pricing of loan products and distorted advice to borrowers. In
connection with this research line, we draw attention to another significant aspect:
the risk regulation of banks. Financial regulation prescribes the measurement of the
sensitivity of the bank’s economic capital to an interest rate change by calculating
the duration of assets and liabilities and the duration gap reflecting the
asset-liability mismatch of the institution. As loans provided by a bank usually
have a longer tenor than the maturity of the deposits, banks can reduce the duration
gap, hence capital requirements by providing ARM loans with shorter interest rate
periods, thereby reducing their exposure to market risk.While the optimal mortgage contract is not a straightforward issue either at an
individual or social level [22,23], empirical
studies found that ARM loans have significantly higher credit and systemic risk than
FRM loans [6,7,24]. Campbell and Cocco [24] modeled mortgage markets including the
potential effects of interest rate hikes. According to their results, default rates
are the highest for ARMs originated at low interest rates. This mechanism was
confirmed by the empirical default rates of the US mortgage market. Moreover, ARM
loans defaulted significantly more frequently in the 2000s, too, in a period of
decreasing interest rates, which can be explained by the fact that ARMs attract
borrowers with the highest income risk. Gaudêncio et al. [25] found the same relation between ARM loans
and default probability in EU countries.In the case of ARM loans, market risk (a rise in interest rates) can easily translate
into credit risk (a rise in default rates). Financial regulation, however, does not
handle this interconnection properly as according to the classical silo-based
approach, different risk types are measured and managed separately. Risk assessment
improved after the GFC in many aspects, and the regulation called for banks to
assess all types of unexpected and expected losses insufficiently covered by
provisions [26]. It also
addresses the interconnection of credit and market risks by introducing the concept
of wrong-way risk deriving from the positive correlation between the probability of
default and market variables (defined as general wrong-way risk); however, in
practice, it is applied only to derivative transactions. The regulation also
highlights the importance of stress testing that aims to identify potential losses
and liquidity needs under adverse circumstances [27], but no mandatory stress scenarios are
prescribed to capture interactions between market and credit risks.In this paper, we propose a stress test model to measure the extra risk arising from
ARM lending in the EU banking sector. We estimate the default risk hidden in ARM
loans quantifying the potential losses on ARMs stemming from a hypothetical rate
hike (2%). We find that at the EU level, on average, the potential loss due to this
specific risk can be 0.53% of the total value of the mortgage portfolio, which is
1.97% for the ARM loan portfolio under a realistic scenario; but results are highly
sensitive to the assumptions and parameter settings.The paper follows the following structure: The next session describes the regulation
of market and credit risks; then, we present the stress test model calibrated to the
banking sectors of EU countries; finally, we summarize our main findings and
conclusions.
2. Risk management of ARM loans
Originally, financial regulation required banks to quantify their credit risk, market
risk, and operational risk separately. The minimum capital requirement was
calculated by simply adding up the capital requirements of the different risk types.
The need for integrated measurement of market and credit risk appeared around 2010.
Bunn et al. [28] showed that
since income is an important determinant of both corporate and household probability
of default (PD), macroeconomic variables affecting income gearing (payment-to-income
ratio) have credit loss consequences as well. Alessandri and Drehmann [29] and Drehmann et al. [30] modeled the risk of a
hypothetical banking book under different stress scenarios incorporating the
dependency of credit risk on interest rate shocks. They concluded that the
interaction is significant between interest rate risk and credit risk, so neglecting
this effect would lead to an underestimation of risks. Kupiec [31] derived a model in which a common Gaussian
factor impacts migration-style credit risk as well as market risk. In this model,
the portfolio’s future value was calculated using a Monte Carlo simulation and he
found that due to the complex effects, an integrated model can give higher or lower
results than the sum of the parts. Kretzschmar et al. [32] suggested an integrated economic
scenario-based model where the price changes of the bank’s assets were driven by
common macroeconomic factors. They showed that implementing an integrated risk model
can help to avoid the undercapitalization of banks. Therefore, if the banking
portfolio is simultaneously affected by market risk and credit risk factors, an
integrated risk assessment is needed for the prudent operation. Breuer et al. [33] also showed an example of
foreign currency loans where the integrated risk capital was significantly larger
than the sum of the capital calculated for market and credit risks separately at all
significance levels.A new element in the Basel regulation is the concept of wrong-way risk which captures
the risk deriving from the fact that the parameters of the loss distribution are not
independent of each other. BCBS [27] distinguishes two subcategories: general and specific wrong-way
risks. A general wrong-way risk arises when the probability of default of
counterparties is positively correlated with general market risk factors; while
specific wrong-way risk refers to the situation when the exposure to a particular
counterparty positively correlates with the probability of default of the
counterparty due to the nature of the transactions with the partner. The regulation
requires banks to increase the credit value adjustment for financial derivatives due
to the specific wrong-way risk and to conduct stress tests to measure the effect of
the changes in the risk factors or in their correlations. However, there is no
explicit method or scenario to be used for the wrong-way risk reporting for credit
portfolios.In practice, market risk can translate into credit risk also in the case of mortgage
portfolios. A change in the interest rate, which is a kind of market risk,
influences the economic value by repricing the bank’s assets and liabilities. The
change of the economic value depends on the extent of the actual yield change and
the duration gap of the institution. Simultaneously, the payments of the ARMs will
also be recalculated, so the payment-to-income ratio of the borrowers will change.
The probability of default has a strong connection to mortgage income gearing. In
the Bank of England’s model, a 1% change in the mortgage income gearing caused a 0.3
percentage point change in the arrears rate [28]. Balás et al. [34] analyzed the factors affecting the
probability of default (PD) empirically and they found a strong relationship, too. A
change of 1 percentage point in the payment-to-income ratio caused a 0.76 percentage
point increase in the default rate. A sudden jump in the PD may lead to a hike in
the rate of non-performing loans; however, it also implies an increase in the
capital requirement of the whole loan portfolio as a higher PD causes an increase in
the worst-case default rate.The Basel regulation does not explicitly address the additional credit risk of ARM
loans, hence, depending on the local banking and regulatory practices, this specific
risk might be entirely or partly neglected. Banks’ ARM risks can be managed by
prescribing stricter eligibility criteria for ARM loans (e.g., lower
payment-to-income (PTI) or loan-to-value (LTV) ratios at issuance), establishing
extra provisions, and providing extra capital in the framework of the internal
capital adequacy assessment process (ICAAP). Corresponding to the last point, we
propose a stress test methodology designed specifically to capture the interaction
between the interest rate risk and default risk of ARM loans.In the following section, we present a stress model to quantify the potential extra
capital need of the European banks at a country level. A similar method could be
used at a bank level as well. Applying a stress test like this and calculating the
capital requirement accordingly may counterbalance the incentives to hedge the
duration gap by offering ARM loans.
3. Stress model
To estimate the additional credit risk of ARM loans (relative to FRM loans) in the
European banking sector, we use data of the European Mortgage Federation (EMF)
published in Hypostat [35] on
the developments in the housing and mortgage markets in Europe and beyond with a
special focus on the differences in interest rates, maturities, portfolio values,
and shares of ARM loans.According to the regulation on prudent banking, all relevant risks should be modeled,
measured, mitigated, and monitored. For the expected losses, banks establish
provisions and make price adjustments, while for the unexpected losses (difference
between the expected loss and some downside risk threshold), they provide capital
[27].In the case of ARM loans, too, the additional default risk can be decomposed into
expected and unexpected parts. Using the expected change in interest rates, we can
estimate the expected loss that should be reflected in the provisions and in the
pricing of ARM products. However, in the low-rate environment we live in, the
expected rise in interest rates (calculated on a historical basis) is close to zero
even for a longer time horizon, so the expected ARM-specific default loss can be
considered zero. In contrast, in practice as inflation expectations are increasing
in all countries and some central banks already made their first tightening steps,
we must prepare for large interest rate hikes too.In this section, we develop a specific stress test model to quantify the additional
default risk and the corresponding additional capital need if a bank lends ARM
(instead of FRM), ceteris paribus.A stress test is a semi-quantitative method of risk analysis, which means analyzing
the effects of possible outcomes without assigning probabilities to these outcomes.
Fully quantitative methods, on the other hand, rely on a complete probability
distribution, so all possible outcomes and their associated probabilities should be
determined first, and then some risk measures (Value-at-Risk, VaR; Expected
Shortfall, ES; etc.) can be calculated [36,37].Stress test methodology fits better our research than fully quantitative methods for
several reasons. First, in this way, we do not have to forecast future changes in
the interest rates, hence, we don’t have to model their stochastic processes. This
is an advantage because currently, there is a great deal of uncertainty in
forecasting interest rates; past interest rates cannot be projected into the future
due to, for example, large regime changes (impacts of the Covid crisis, crisis
management, inflation, etc.). In our stress test, we assume a severe but still
possible change in the interest rates and quantify its effect, but we do not need to
specify the probability of this event. The only requirement is that the assumed
stress scenario (the change in the interest rate) should be realistic. Second,
according to the GFC-induced new regulatory recommendations, more emphasis should be
put on stress testing rather than on the mechanistic application of quantitative
(VaR, ES) models [38,39]. These latter quantitative
models rely inevitably on historical data, hence, are backward-looking. In contrast,
stress testing, if properly done, can be more forward looking, and risk management
should be concerned with the future. Financial regulators highly recommend stress
testing also because it supports internal and external communication and facilitates
risk mitigation or contingency planning [39]. Third, the stress test methodology suits
well the framework of the Internal Capital Adequacy Assessment Process (ICAAP) in
the second pillar of banking risk management. Stress test tools have been
specifically developed to look at how negative scenarios affect the underlying
factors that ensure safe operation and to assess the shock-resilience of
institutions, hence their contribution to the systemic risk [40]. For banks, the classic regulatory and
supervisory requirement is to have the right amount of capital to ensure the
repayment of liabilities even in a stress event. Standardized liquidity and capital
rules are also rooted in a stress test logic. Moreover, stress tests are widespread
in other industries as well when analyzing fundamental risks.The logic of the proposed stress test model is the following:
where Δr is the assumed change in the interest
rates in an extreme but plausible stress scenario over a holding period of 1 year;
is the percentage change in the mortgage
repayment; ΔPD is the increase in the probability of default
relative to the base case (with no change in the interest rate level), and
ΔCR is the additional capital need of ARM loans relative to FRM
loans.The definition of a stress event for a single market variable or for the whole market
is not straightforward [41].
Here, in line with the Basel stress methodology [27], the assumed extreme change in the interest
rate Δr is 2%. This is consistent also with the EBA guideline where
the macro-financial stress scenario is considered with an increase of 2.5% in the
interest rates over 3 years [42].According to Berlinger [12],
the repayment of ARM loans changes in line with the change in the interest rate, and
the interest rate sensitivity equals the modified duration D* of a
similar but FRM loan:We aggregate all residential loans for a country and characterize them with the
typical interest rate r, typical maturity at issuance
M, the total amount of outstanding mortgage loans
V, and share of ARM loans a. We assume, for
the sake of simplicity, that for a given country, parameters r,
M, and a are the same for each year cohort
y (loans issued in year y); and due to the
lack of year-specific data, the nominal values of new loans are also supposed to be
the same over time. So, we assume stationary year cohorts in all relevant aspects.
Therefore, the interest rate sensitivity of the total outstanding mortgage portfolio
D* in (2) is given by
where D and
w are the duration and the
relative weight of the yth year cohort’s portfolio, respectively.
We calculate the duration of a similar but fixed mortgage portfolio for each year
cohort D as
where T is the remaining maturity.Relative weights are defined as
where, V is the present value of the outstanding
loan portfolio, and indices refer to the year of issuance. We model only one
repayment per year, which simplifies calculations without the loss of generality:
where AF(r,
T) is the annuity factor
depending on interest rate r and remaining maturity
T. As year cohorts are stationary,
initial loan amount L, initial maturity M, and,
hence, initial repayment C remain the same in each cohort:Once we calculated the increase in the repayments using (2), we estimate the corresponding increase in the
probability of default PD. We assume a sigmoid PD
function, which is consistent with the probit model widely used for modeling default
losses, the KMV method [43],
and the results of the agent-based simulation model of Campbell and Cocco [24] as well:In (9),
N stands for a cumulative normal distribution function with a
mean μ and a standard deviation σ. Parameters
μ and σ are latent variables depending on the
characteristics of the ARM portfolio. The mean μ reflects the
average riskiness of the borrowers (how much they are indebted relative to their
income on average), and σ reflects the heterogeneity of borrowers
in terms of their riskiness. We calibrate our PD function (9) to the
PD function estimated by Balás et al. [34, Chart 2] for
borrowers with average income indebted in home currency in the Hungarian mortgage
market assuming an initial payment-to-income ratio of 30%. Given that Balás et al.
[34] analyzed real-life
microdata, their PD function can be considered as a realistic
estimation. Minimizing the sum of squares of the differences, we get
μ = 0.79 and σ = 0.52 (Fig 1).
Fig 1
Probability of default in the function of the percentage change in
mortgage payments.
Fig 1 presents the empirical PD function in function of the
percentage change in the repayment C based on [34] and the calibrated
PD curve we use in the stress test. The two curves are
very close to each other.
Probability of default in the function of the percentage change in
mortgage payments.
Fig 1 presents the empirical PD function in function of the
percentage change in the repayment C based on [34] and the calibrated
PD curve we use in the stress test. The two curves are
very close to each other.Using a sigmoid PD function, we implicitly assume that at an
individual level, there is a threshold in the loan repayments which triggers
default. So, also at a portfolio level, there can be a sharp transition from a
regime of few defaults to many defaults as required loan repayments increase, hence
PD is not linear in either at an individual or an aggregate level.
Clearly, PD is highly dependent on parameters μ
and σ. In our analysis, first, we take the calibrated parameters
(μ = 0.79 and σ = 0.52) as a basis and
estimate default losses accordingly. Later, we run a sensitivity analysis for these
model parameters.When calculating the additional capital need for ARM loans ΔCR, we
use the following formula:
where EAD is the exposure at default which equals
the present value of the mortgage portfolio affected by the increase of the interest
rate, and LGD is the loss given default (in percentage),
ΔPD stands for the change in the PD relative to the base case
() Note that ΔCR is the
additional capital need designated to cover the ARM-specific additional credit risk
due to the potential increase of interest rates.Country-level mortgage portfolios in the EU are built up from loans of different
interest rate adjustment periods. Loans with an extremely short interest rate period
(up to 1 year) are considered as ARMs, while for the rest, interest rates are
supposed to be fixed for the whole maturity (FRM). Thus, our estimation for the
additional capital need can be considered as a lower bound. To quantify the effect
of increased PDs, we consider only ARM loans (up to 1 year);
therefore, EAD is calculated asUsing (2), (9), (10), and (11), the additional
capital need ΔCR for a country isTo have comparable values across different countries, we divide ΔCR
by the total value of the mortgage portfolio V or the value of the
ARM portfolio V∙a.Having no access to country-specific loss given default ratios LGD
for mortgage portfolios, we set it uniformly at 35%—the lowest possible value
suggested by the EU’s Capital Requirement Regulation (CRR) [44] for exposures with eligible
collaterals.Relying on our stress methodology (12) and the database of Hypostat [35], we estimate the ratios of
the additional capital need for each member of the EU (the UK included) in November
2020. Table 1 presents the
input data.
Table 1
Characteristics of mortgage markets in EU countries UK included),
November 2020.
Country
Typical mortgage rate
Typical maturity
Total outstanding residential loans
Share of ARM loans
r
M
V
a
(%)
(year)
(M euro)
(%)
Austria
1.6
27
119,775
43.67
Belgium
1.8
20
263,419
6.36
Bulgaria
3.3
20
6,384
99.01
Croatia
3
25
7,720
13.32
Cyprus
2.1
22
8,605
93.22
Czechia
2.6
25
48,658
18.40
Denmark
0.7
30
258,799
33.40
Estonia
2.5
30
8,119
89.88
Finland
0.7
25
100,354
93.30
France
1.3
20
1,078,000
0.00
Germany
1.5
25
1,530,434
11.00
Greece
3.1
25
52,707
83.92
Hungary
4.9
15
13,715
49.00
Ireland
2.9
25
81,637
78.60
Italy
1.4
22
382,583
29.36
Latvia
2.7
20
4,177
95.78
Lithuania
2.4
30
8,411
98.39
Luxembourg
1.4
27
35,633
38.95
Malta
2.6
25
6,071
44.41
Netherland
2.3
30
722,672
18.72
Poland
4.3
30
108,382
100.00
Portugal
1.2
33
93,846
71.75
Romania
2.5
30
16,999
77.00
Slovakia
1.4
25
31,001
1.71
Slovenia
2.4
20
6,587
52.76
Spain
2
25
487,561
35.64
Sweden
1.5
40
422,742
67.00
UK
1.8
25
1,708,134
31.60
Source: Hypostat [35].
Source: Hypostat [35].We can see in Table 1 that EU
countries are highly different in terms of mortgage rate r,
maturity M, the total value of mortgage portfolios
V, and share of ARM loans a.Table 2 presents the output of
our stress test, assuming an upward parallel shift in mortgage rates of
Δr = 2% and using the calibrated PD
function.
Table 2
Results of stress testing for EU countries (UK included), November
2020.
Country
Interest rate sensitivity of ARM loans
Percentage change in payment
Exposure at default (M euro)
Change in the probability of default
Additional capital requirement (M euro)
Relative additional capital requirement (to the
total portfolio)
Relative additional capital requirement (to the
ARM portfolio)
1.6%Remark: Here, Δr = 2%, μ = 0.79, σ = 0.52, and LGD = 0.35.The additional capital need relative to the total value of the mortgage portfolio
ΔCR/V ranges from 0–0.1% (Belgium, France, and Slovakia) to
2.0% (Lithuania, Sweden); the weighted average is 0.53%. Differences are due to many
factors, most importantly, the differences in the shares of adjustable-rate loans,
see Fig 2.
Fig 2
Additional capital need relative to the total portfolio value ΔCR/V in EU
countries, November 2020.
The additional capital need depends mostly on the share of ARM loans. Due to
other parameters (interest rates, maturities, etc.), some countries might be
above or below the trendline.
Additional capital need relative to the total portfolio value ΔCR/V in EU
countries, November 2020.
The additional capital need depends mostly on the share of ARM loans. Due to
other parameters (interest rates, maturities, etc.), some countries might be
above or below the trendline.To highlight the effects of other differentiating factors such as maturity and
interest rate, we can relate the additional capital need to the value of the ARM
portfolio ΔCR/Va. Fig
3 presents a bar chart with EU countries arranged according to this
ratio.
Fig 3
Additional capital need relative to the ARM portfolio value ΔCR/Va in EU
countries November 2020.
Except for France (where ARM loans with extremely short interest periods do
not exist), the additional capital need relative to the value of the ARM
portfolio is between 1.0% (Hungary) and 2.9% (Sweden); the average is 1.97%.
Differences can be explained mainly by the maturity, which is typically 15
years for Hungary and 40 years for Sweden.
Additional capital need relative to the ARM portfolio value ΔCR/Va in EU
countries November 2020.
Except for France (where ARM loans with extremely short interest periods do
not exist), the additional capital need relative to the value of the ARM
portfolio is between 1.0% (Hungary) and 2.9% (Sweden); the average is 1.97%.
Differences can be explained mainly by the maturity, which is typically 15
years for Hungary and 40 years for Sweden.Clearly, these results are strongly dependent on the assumptions, especially on the
potential change in the mortgage rate Δr and the parameters of the
PD function (μ and σ). With
Δr = 2%, μ = 0.79, and σ =
0.52, the average additional capital need at an EU level is 0.53% of the value of
the total mortgage portfolio (ΔCR/V = 0.53%) and 1.97% of the value
of the total ARM portfolio (ΔCR/Va = 1.97%). Figs 4 and 5 present how the first ratio
ΔCR/V changes with parameters Δr,
μ, and σ.
Fig 4
Additional capital need of ARM loans at EU Level as a function of Δr and
µ.
Fig 5
Additional capital need of ARM loans at EU level as a function of Δr and
σ.
Figs 4 and 5 demonstrate
that the calculation of the additional capital need is highly sensitive to
the assumed change in the interest (Δr), parameters related
to the average riskiness of the mortgage portfolio (µ), and
inequality of borrowers in their riskiness (σ). If loss
given default LGD differs from our assumptions (0.35), the
ARM-specific additional capital will change proportionally.
Additional capital need of ARM loans at EU level as a function of Δr and
σ.
Figs 4 and 5 demonstrate
that the calculation of the additional capital need is highly sensitive to
the assumed change in the interest (Δr), parameters related
to the average riskiness of the mortgage portfolio (µ), and
inequality of borrowers in their riskiness (σ). If loss
given default LGD differs from our assumptions (0.35), the
ARM-specific additional capital will change proportionally.Our calculations have some limitations. Most of all, we do not have granulated data
on the composition of the loan portfolios related to maturities, interest rates,
loan amounts, etc.; therefore, we use averages and make simplifying assumptions
(like the homogeneity of year cohorts). Furthermore, we do not know the exact shape
of the PD and LGD functions that can vary across banks, countries, and times; thus,
our estimations are highly uncertain. Note, however, that we significantly
underestimate the ARM-specific extra default risk and the corresponding capital need
in the EU banking sector as we overlook ARM loans with interest rate periods of
longer than 1 year.
4. Conclusions
We focus on the interest rate risk transforming into default risk in the case of ARM
loans in the EU banking sector. Although we can witness some convergence in the last
decade, there is still surprisingly large heterogeneity in mortgage conditions
across the EU [35], which can
be attributed to different economic and social conditions, institutions, histories,
cultures, etc. In some countries such as Belgium, France, Germany, and Slovakia, ARM
loans with an extreme short interest period (up to 1 year) are not widespread at
all; hence, the ARM-specific risk is marginal. At the other end of the scale,
however, we find countries where aggressive ARM lending is the business standard.
The share of ARM loans is the highest in Bulgaria (99%), Cyprus (93%), Finland
(93%), Latvia (96%), Lithuania (98%), and Poland (100%).Bank regulation is strikingly not neutral in this aspect, as it explicitly favors
short-duration adjustable-rate loans over long-duration fixed-rate loans in the
framework of gap management. Market risks and credit risks are handled separately,
and there are no direct prescriptions to quantify interactions between the two. This
asymmetry in the regulation creates perverse incentives both for banks and
households, which can lead to aggressive risk-taking, over-indebtedness of unhedged
households, high procyclicality of mortgage markets, and increased systemic
risks.As capital regulation has become highly complex and contains different stress testing
requirements, it may change from bank to bank how they are prepared for losses
stemming from the additional credit risk of ARM loans. In any case, as we learned
from FX lending, it is difficult to manage the default risk of unhedged borrowers
who are not even aware of the risks they are bearing.We propose a stress test model to estimate potential losses stemming from the
specific ARM risk from the lender institution’s perspective. We would like to
highlight that although adjustable-rate products seem cheaper and, thus, more
attractive for both borrowers and lenders, they can result in higher potential
losses. We estimate the average additional capital that is needed to cover the extra
ARM credit risk in the EU to be 0.53% of the value of the total mortgage portfolio
(the maximal value is 2.0% in Lithuania) and 1.97% of the value of the ARM portfolio
(the maximal value is 2.92% in Sweden).One may think that banks effectively take account of the relationship between macro
factors (like inflation) and mortgage defaults when estimating worst-case defaults
using advanced default risk models under the first pillar of the Basel regulation.
However, as long as ARM and FRM loans are not differentiated in these models,
ARM-specific extra risk will not get measured either explicitly or implicitly.Some banks may model ARM-specific risks under the second pillar of the Basel
regulation, the Internal Capital Adequacy Assessment Process (ICAAP), and they may
apply an extra multiplier when calculating the regulatory capital if they are
heavily involved in ARM lending. However, according to the present regulation, there
are no guarantees for this.In some countries, ARM lending is marginal due to historical, cultural, or
institutional reasons; for example, in countries with fewer ARM loans, mortgage
portfolios might be safer, so our calibrated PD function may overestimate the
corresponding default risk. When developing a tailor-made stress test, parameters
can be adjusted to the local conditions taking advantage of the more granulated
data.To some extent, ARM loans may provide an inherent natural hedge against inflation
risk, as when inflation rises, interest rates, wages, and collateral values are
expected to rise in the longer run. However, correlations are not perfect and there
can be significant time lags (which may take years), so, this hedge is far from
being perfect [24,25]. Due to the time lag,
increasing installments after the rate hike and the inflation of living costs may
shock households at the same time. Thus, ARM-specific risks must be properly modeled
and measured to ensure a prudent operation.We can see from the sensitivity analysis that the outputs of the model are highly
sensitive to the parameter setting; therefore, the model risk is high. At a
portfolio level, however, model risk can be marginal if banks carefully design their
own stress methodology and exploit the granulated information they possess in
relation to their mortgage portfolio. Our analysis suggests that the upside risk of
the capital need can be significant in some countries, so it is advisable to change
the structure of the banking book toward fixed-rate contracts.In many cases, banks have no direct interest in changing their business model and
moving toward fixed-rate products. Therefore, we recommend additional regulatory
measures, for example, under the second pillar of the Basel regulation, in the ICAAP
framework, ARM-specific stress tests focusing precisely on the additional ARM risk
should be prescribed. This new supplement would perfectly fit the framework of
stress testing already present in the regulation and would significantly contribute
to the relevance, completeness, unbiasedness, and consistency of risk management
systems.The macroprudential policy also gives different opportunities to incentivize banks
toward fixed-rate lending. The Hungarian National Bank, for example, effectively
directed mortgage lending from ARM to FRM by setting stricter eligibility rules for
ARM loans (lower PTI and LTV ratios are allowed) and by providing interest rate
swaps to make FRM lending more attractive for the banks. As a result, almost 100
percent of newly disbursed loans are fixed [45]. A Systemic Risk Buffer (SRB) may also be a
good tool to reflect more on the different risks of mortgages with different
fixation. SRB might be applied for ARMs especially if the probability of increasing
rates is high.An important further research topic can be the effect of adjustable-rate loans on
SMEs and the lender banks. Adjustable rates may have a similar effect on SMEs as
they have on households since they don’t have the deep knowledge to understand the
risks and there are no relevant instruments to hedge. It is especially true for
smaller, young firms which would like to fund their long-term investments. This
consideration at SMEs is reflected by the popularity of the fixed-rate Funding for
Growth Scheme in Hungary [45]. The literature also shows the potential negative effect of indebtedness
on growth [46], so not only
the choice between adjustable and fixed rate is important but the choice between
loan and equity.