Regulating and Monitoring Investment Risk: Application of the OECD Guidelines Juan Yermo Financial...

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Regulating and Regulating and Monitoring Investment Monitoring Investment Risk: Risk: Application of the OECD Application of the OECD Guidelines Guidelines Juan Yermo Juan Yermo Financial Affairs Division Financial Affairs Division OECD OECD

Transcript of Regulating and Monitoring Investment Risk: Application of the OECD Guidelines Juan Yermo Financial...

Page 1: Regulating and Monitoring Investment Risk: Application of the OECD Guidelines Juan Yermo Financial Affairs Division OECD.

Regulating and Monitoring Regulating and Monitoring Investment Risk: Investment Risk:

Application of the OECD GuidelinesApplication of the OECD Guidelines

Juan YermoJuan YermoFinancial Affairs DivisionFinancial Affairs Division

OECDOECD

Page 2: Regulating and Monitoring Investment Risk: Application of the OECD Guidelines Juan Yermo Financial Affairs Division OECD.

What do we mean by investment risk?What do we mean by investment risk?

What is the time horizon?

Is there a liability (commitment, guarantee or target benefit)?

Who is the risk bearer?

Choice of risk measure will depend on these factors

Page 3: Regulating and Monitoring Investment Risk: Application of the OECD Guidelines Juan Yermo Financial Affairs Division OECD.

Main risk measuresMain risk measures

Overall risk measures• Volatility (standard deviation)• Beta (market correlation)

Downside risk measures• Expected shortfall / expected tail loss• Stress test• Value-at-Risk

Downside risk more relevant for DC pensions because of benefit target

Page 4: Regulating and Monitoring Investment Risk: Application of the OECD Guidelines Juan Yermo Financial Affairs Division OECD.

Investment risk in DC pensionsInvestment risk in DC pensions

Long-term horizon, terminal wealth matters most

Consumption matching requirement after retirement

Some relevance of investment outcomes up until retirement

Expected shortfall from targeted replacement rate

Page 5: Regulating and Monitoring Investment Risk: Application of the OECD Guidelines Juan Yermo Financial Affairs Division OECD.

Drawbacks of VaR as a risk measure Drawbacks of VaR as a risk measure in DC pensionsin DC pensions

Short-term horizon (one day/month)

It does not tell us anything about losses below VaR limit

It does not tell us anything about the portfolio’s exposure to annuity rate risk

To be useful for beneficiaries, VaR needs to be integrated into

replacement rate model

Page 6: Regulating and Monitoring Investment Risk: Application of the OECD Guidelines Juan Yermo Financial Affairs Division OECD.

Regulating investment riskRegulating investment risk

Directly:• Setting ceilings on risk measures

Indirectly:• Setting ceilings on portfolio allocations

Self-regulation:• Prudent person rule

Regulatory approach depends critically on extent of market and regulator

knowledge, competition, and redress

Page 7: Regulating and Monitoring Investment Risk: Application of the OECD Guidelines Juan Yermo Financial Affairs Division OECD.

Drawbacks of quantitative rulesDrawbacks of quantitative rules

Optimal asset allocation is a moving target

Difficult to change (often set in law)

Does not ensure diversification within limits

Quantitative risk control measures can achieve same goals without

these drawbacks

Page 8: Regulating and Monitoring Investment Risk: Application of the OECD Guidelines Juan Yermo Financial Affairs Division OECD.

Recent reforms to quantitative rulesRecent reforms to quantitative rules SharesShares

• Belgium: 65% - no limit (2002)Belgium: 65% - no limit (2002)• Czech Rep.: 25% - no limit (2004)Czech Rep.: 25% - no limit (2004)• Denmark: 50% - 70% (2001)Denmark: 50% - 70% (2001)• Mexico: 0% - 15% (2005)Mexico: 0% - 15% (2005)• Portugal: 50% - 55% (2002)Portugal: 50% - 55% (2002)• Spain: 10% - 30% for unlisted (2003)Spain: 10% - 30% for unlisted (2003)

Foreign investmentForeign investment• Japan: 30% - no limit (1999)Japan: 30% - no limit (1999)• Canada: 30% - no limit (2005)Canada: 30% - no limit (2005)• Denmark: 5% - 10% for non-OECD (2005)Denmark: 5% - 10% for non-OECD (2005)• Mexico: 0% - 20% (2005)Mexico: 0% - 20% (2005)• Germany: no limit for Germany: no limit for PensionsfondsPensionsfonds (2002) (2002)• Korea: 20% - 30% (2003)Korea: 20% - 30% (2003)

Page 9: Regulating and Monitoring Investment Risk: Application of the OECD Guidelines Juan Yermo Financial Affairs Division OECD.

Limits on sharesLimits on shares0% 10% 20% 30% 40% 50% 60% 70% 80%

Australia

Austria

Belgium

Canada

Czech Rep.

Denmark

Finland

Germany

Greece

Hungary

Iceland

Ireland

Italy

Japan

Mexico

Netherlands

New Zealand

Norway

Poland

Portugal

Slovak Rep.

Spain

Sweden

Switzerland

Turkey

UK

United States

No limit

No limit

No limit

No limit

No limit

No limit

No limitNo limit

No limit

No limit

No limit

No limit

No limit

No limit

Page 10: Regulating and Monitoring Investment Risk: Application of the OECD Guidelines Juan Yermo Financial Affairs Division OECD.

Limits on foreign investment Limits on foreign investment 0% 10% 20% 30% 40% 50% 60% 70% 80%

Australia

Austria *

Belgium

Canada

Czech Rep. *

Denmark *

Finland *

Germany

Greece*

Hungary *

Iceland

Ireland

Italy *

Japan

Mexico

Netherlands

New Zealand

Norway

Poland

Portugal *

Slovak Rep.

Spain

Sweden

Switzerland

Turkey

UK

United States

No limit

No limit

No limit

No limit OECD countries

No limit

Subject to 20% ratio

No limit

No limit

No limit

No limit

No limit

No limit

No limit

No limit

No limit

No limit

No limit OECD countries

No limit in EU and EEA countries

No limit OECD countries

No limit OECD countries

No limit OECD countries

Page 11: Regulating and Monitoring Investment Risk: Application of the OECD Guidelines Juan Yermo Financial Affairs Division OECD.

The debate on foreign investmentThe debate on foreign investment

For: seven countries with largest For: seven countries with largest capitalisation account for more than 80% of capitalisation account for more than 80% of the world’s equity portfolio (OECD more the world’s equity portfolio (OECD more than 90%)than 90%)

Against: difficulty of hedging exchange rate Against: difficulty of hedging exchange rate risk over long horizon, impact of capital risk over long horizon, impact of capital outflows on exchange rate and BoP.outflows on exchange rate and BoP.

Trade-off diversification benefits and Trade-off diversification benefits and macroeconomic effects of foreign macroeconomic effects of foreign investmentinvestment

A gradual approach to relaxing the foreign investment limit seems judicious for emerging markets

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””Prudent” quantitative limitsPrudent” quantitative limits

Limits on % of portfolio invested in individual securities or issuers

Limits on ownership concentration (if direct control not desirable)

Limits on % of portfolio invested in non-transparent/illiquid instruments

But can be left to self-regulation via the “prudent person rule”

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OECD Guidelines on Pension Fund OECD Guidelines on Pension Fund Investment ManagementInvestment Management

Requires prudent person; allows some quantitative limits (e.g. self-investment)

Includes “expert knowledge”, “duty of loyalty” and “due diligence”

Written investment policy and risk control process

Market value preferable