A. Principle 1: Willingness to Act

6. The 2013 FSAP recommended that a dedicated macroprudential council be established. The IMF identifies the assignment of a macroprudential mandate to a body or committee as a key element of frameworks that deliver “willingness to act” (IMF, 2014 ¶79). To that end, the macroprudential council proposed by the FSAP would have had the power to recommend actions to responsible agencies on a “comply-or-explain” basis. The FSAP further recommended a stronger role for the Bank of Korea (BOK), and in particular that it should provide regular assessments of systemic risk to the proposed council, along with proposals for policy action where appropriate (IMF, 2014a ¶80).

7. The authorities have maintained a multi-agency system where key macroprudential responsibilities are shared. A high-level summary of the responsibilities falling to the principal agencies involved in macroprudential oversight and policy appears in Table 2, with an accompanying schematic in Figure 1. These responsibilities are broadly unchanged since the last FSAP. The main actors are:

• The Financial Services Commission (FSC)—the financial regulatory agency of the Korean government, with broad supervisory powers.

• The Financial Supervisory Service (FSS) —responsible for on-going supervision of financial institutions and markets.

• The Bank of Korea (BOK)—the independent central bank, responsible for price stability, financial stability, and emergency liquidity assistance, and has power to conduct bank examinations. It conducts foreign exchange operations in consultation with the MOEF.

• The Ministry of Economy and Finance (MOEF)—overall authority over foreign exchange policy, including FX-related macroprudential measures the foreign exchange stabilization fund (ESF).

Korea: Institutional Schematic

Citation: IMF Staff Country Reports 2020, 277; 10.5089/9781513557014.002.A001

Source: IMF and country authorities.

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Korea: Institutional Schematic

Citation: IMF Staff Country Reports 2020, 277; 10.5089/9781513557014.002.A001

Source: IMF and country authorities.

• Download Figure
• Download figure as PowerPoint slide

Korea: Institutional Schematic

Citation: IMF Staff Country Reports 2020, 277; 10.5089/9781513557014.002.A001

Source: IMF and country authorities.

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• Download figure as PowerPoint slide

This Technical Note will not be specifically concerned with the operations of the KDIC or SFC.

8. The legal mandates of the principal agencies include a financial stability objective. The alignment of objectives in a multi-agency framework can be useful where it encourages cooperation (IMF 2014a, ¶88). In Korea, the FSC and FSS share a common legal mandate to ‘promote the stability of financial markets’, while the BOK’s legal mandate requires it to ‘pay attention to financial stability’.⁵ In addition, the MOEF oversees measures relating to stability risks arising from foreign exchange markets directly, as part of general government policy. In this context it should be noted that a potential drawback of an overlap between mandates is that it may risk obscuring who is ultimately responsible and accountable for financial stability, and that that may lead necessary actions to be delayed.

9. Financial stability is not the sole primary objective of any agency in Korea. Financial stability is one primary objective amongst others set for the FSC/FSS and BOK. As a result, at times a trade-off between objectives may arise. Where trade-offs are present, tensions both within and between agencies on the direction of policy will need to be resolved. That process of resolution may help policymakers to internalize the spillovers of policy actions in one policy domain onto the objectives of another domain (for example, between micro- and macroprudential policies). But it may also make decisions harder to reach, and harder to communicate, reinforcing inaction bias.⁶

10. Formal macroprudential powers rest with the government-appointed FSC. FSC commissioners are the ultimate decision-takers for most measures relating to regulated financial institutions. This includes decisions relating to macroprudential measures, but also decisions in many other spheres of financial supervision and regulation. The FSC commissioners meet on a regular basis. The commissioners comprise the FSC Chairperson and Vice Chairperson, the Vice Minister of the MOEF, the President of the KDIC, the Senior Deputy Governor of the BOK, the Governor of the FSS, and two financial experts and one business representative recommended by the FSC Chairperson and the Chairperson of the Korea Chambers of Commerce and Industry, respectively.⁷ The FSC Chairperson is a government appointee, who in turn nominates the FSC Vice Chairperson, and the Governor of the FSS. The commissioners are appointed for a term of three years (renewable once) and cannot be dismissed except on serious grounds.⁸ However, since March 2013 there have been four FSC Chairmen.⁹ The relatively rapid rate of turnover has allowed the government ample opportunity to decide or influence key financial leadership roles since 2013.

11. The inter-agency Macroeconomic and Finance Meeting (MEFM) serves as the central forum for financial stability matters. Along with the FSC meeting, the MEFM is the most important element of Korea’s macroprudential policymaking framework. It is intended to foster ‘close cooperation’ between Korea’s main macroeconomic and financial agencies in several areas: (i) Analysis and monitoring of macroeconomic and financial developments; (ii) Foreign exchange market monitoring and policy; (iii) Other elements affecting the economy, recently including global monetary policy, trade, and geopolitical developments. ¹⁰

12. The MEFM exists within the MOEF and is chaired and run by government officials. The MEFM is a deputy-level body that brings together the First Vice Minister of Finance (who acts as chair), the Vice Chairperson of the FSC, the Senior Deputy Governor of the BOK, the first senior Deputy Governor of the FSS, and President of the KDIC.¹¹ The MEFM is explicitly created within the MOEF, and the body’s supporting secretariat—which is responsible for setting meeting agendas, and composing post-meeting communications—is based in the MOEF. The MEFM is established by Presidential Decree, and under the most recent of these will run until 2020.¹² Multiple channels of involvement therefore exist between the government and the MEFM. IMF guidance recognizes political influence as a risk factor for delays in macroprudential action and can compromise the independence of participating agencies (IMF, 2014a, ¶82). But it also acknowledges that the involvement of government in macroprudential policy can be beneficial when changes in legislation are required, or when fiscal measures are called for to mitigate systemic risks (IMF, 2014a, ¶81).

13. Experience shows the Korean authorities are willing to act on identified risks, but formal safeguards for independent decision-making are lacking. The authorities involved in macroprudential oversight and mitigation policies in Korea have been active in developing responses to some developing risks. In the past three years, most activity has been focused on measures to curb risks from the household sector (discussed in further detail below, ¶61). Many of the measures introduced have had potential to be politically sensitive, as they have aimed to curb the ability of borrowers to obtain credit secured against real estate. In other jurisdictions, such measures are more common where an agency independent of government takes the lead in policymaking, precisely for this reason.¹³ The demonstrated willingness to act in this area supports the view that the framework is operating in a healthy manner. But it does not follow that equal willingness exists in all domains. And looking further back, the authorities have at times made macroprudential policy decisions on shakier grounds (see ¶46).¹⁴ The macroprudential framework does not have formal protections that might prevent policy from being diverted away from its primary responsibility to limit systemic risk in future.

B. Principle 2: Ability to Act

14. The ability to act is underpinned by the broad regulatory powers granted to the FSC. The FSC exercises macroprudential power via its ability to issue regulations that are binding on a broad range of regulated entities (so-called ‘hard powers’; IMF 2014a, ¶87). For example, the FSC has the power to designate banks or bank holding companies as D-SIBs; it can set loan standards for residential mortgages; and it can set various capital standards for banks and insurers. The FSC also has the power to recommend actions (so-called ‘soft powers’), for example in the area of corporate restructuring.¹⁵ The Financial Supervisory Service (FSS), the integrated supervisor, is responsible for implementation and enforcement. The presence of a strong central authority ensures that actions can be taken when required.

15. Ability to act also depends on the capacity within the agencies. Some capacity to support macroprudential oversight activity exists in designated teams within each agency. The BOK has a financial stability department with a staff of around 100 under a Deputy Governor, and the FSS has a dedicated department and specialized teams for macroprudential supervision. The FSC also employs teams for macroprudential policy, as well as teams specializing on issues including housing, banks, and non-banks. However, some teams are assigned wide-ranging briefs that, given resource constraints, give rise to challenges in supporting the macroprudential policy process.

16. Although the MEFM lacks formal powers (including semi-hard powers), in practice its proposals are enacted by the relevant decision-making bodies. The decree that establishes the MEFM describes its functions as deliberation and consultation, which resembles the functions given to Sweden’s Financial Stability Council.¹⁶ At the same time, and somewhat in opposition to the notion of a consultative body, the decree describes its decision-making procedure.¹⁷ However, the decree does so without specifying any powers that the MEFM may have (for example, the ‘semi-hard’ power to make recommendations to competent agencies on a comply-or-explain basis). However, decisions on FX measures have often been taken at the MEFM—for example, the adoption of LCR-FX regulations (¶80). Discussions at the MEFM on the use of borrower-based measures on households (¶61) have also produced policies that were effectively decided, and later taken up by the FSC commissioners.

C. Principle 3: Effective Coordination and Cooperation

17. Cooperation is facilitated by the relevant laws and MOUs. The set of overlapping responsibilities in the Korean system place a premium on effective mechanisms for coordination and cooperation between agencies. Any agency may request materials from a sister institution, under a presumption that requests will be granted (FSC Act, Art. 65). Further, the government is obliged to consult with the MPB when formulating important money and credit policies (BOK Act, Art. 93). Otherwise confidential regulatory information held by the FSS is shared with the BOK on the basis of a MOU, and in addition the BOK can request a joint bank examination with the FSS. In practice, however, sharing of information is not seamless, and no cross-agency committee for the oversight of data sharing presently exists to review independently-made decisions. For overseas cooperation, the FSC and FSS have signed MOUs for the exchange of financial information with forty-eight institutions in twenty-six out of the thirty-four overseas jurisdictions in which Korean financial companies are active—including banks, insurers, asset managers, and credit-specialized finance companies—as well as with two international organizations (as of end-2018).

18. Topic-focused meetings enhance working-level coordination and cooperation. While the MEFM (¶11) is a meeting of senior officials, the Macroprudential Analysis Council (MAC) holds staff-level meetings. The council was introduced in March 2019 to improve channels of communication between the main official agencies, and to bring in the views of researchers and experts outside the official sector. So far, MAC risk discussions have included in repo markets, insurers’ foreign exchange hedging, and project finance loans. Where potential systemic risks are identified, matters can be elevated to the MEFM for discussion. Meanwhile, the Household Debt Management Council, constituted of subject experts from across the main agencies, has been an important forum for information-sharing and cooperation preceding the recent strengthening of borrower-based measures. Finally, the BOK’s Financial Stability Forum is another opportunity for outsiders to provide perspective and challenge to institutional views.

D. Recommendations

19. The MEFM (or a body empowered for the equivalent purpose) should be assigned macroprudential oversight as its sole primary objective. To avoid the difficulties mentioned under ¶9, clear priority should be given to a financial stability objective by establishing one body as a focal point for macroprudential (system-wide) oversight. The term macroprudential oversight is intended to mean the assessment of systemic risks, and consideration of measures to mitigate those risks. The intention of this recommendation is to:

• Bring clarity to the institutional setting in which macroprudential policy is decided, thereby strengthening the processes for decision making and enhancing accountability.

• Ensure that the goal of safeguarding financial stability cannot be subordinated to other objectives, thereby limiting the extent to which macroprudential powers can be exercised in the absence of systemic risk considerations.

20. The macroprudential oversight objective should specify the interlocking intermediate objectives that ensure financial stability (IMF, 2014a, ¶3), namely to:

• Build resilience to shocks, for example by moderating the leverage available to borrowers and financial institutions and encouraging them to maintain buffers of high-quality loss absorbing capital.

• Contain the build-up of vulnerabilities over time, for example due to excessive credit growth and maturity mis-match.

• Mitigate structural vulnerabilities, for example due to interconnectedness.

21. The macroprudential oversight objective may be combined with secondary objectives—that is, goals that should be pursued subject to ensuring financial stability (IMF, 2014a, ¶83)—but such objectives, if any, should not be too wide-ranging.

The most obvious choice for a responsible body within the legal framework currently in force in Korea is the MEFM.

• The decree establishing the MEFM already comes close to giving the body an objective to ensure financial stability, albeit an insufficiently explicit one.

• In the system as it stands, the MEFM is the focal point for discussion of systemic risk and the formulation of policy options, and moreover matters of macroprudential policy are effectively decided at its meetings.

• Under a revised arrangement, the MEFM would continue to offer on-the-record recommendations for macroprudential actions to the FSC Meeting.

22. Note that the recommendation need not entail any reassignment of formal powers within the system, nor any new legal powers to be granted, should such steps not be desired.¹⁸ However, it would be desirable to strengthen the MEFM by placing it on a statutory basis and by ensuring that its composition is appropriate to its mandate.

23. The recommendation pertains to macroprudential policy and should not be understood to impinge on the ability of competent agencies to deploy crisis management tools, such as BOK provision of emergency liquidity assistance, or KDIC use of the deposit insurance fund, which is a separate issue.

24. Giving one body a sole primary financial stability mandate might have implications for the laws governing other institutions, which should be carefully considered. For example, whether other agencies should be assigned secondary financial stability objectives or whether co-equal financial stability objectives should be retained.

A. The Role of Communications

25. Successful macroprudential policy requires a supporting communication strategy. The strategy sets out the goals of communication, and the means to achieve them. Communications in the area of financial stability policy are challenging (Stankova, 2019): The financial system is complex; deals fundamentally with uncertain and contingent events; and is the domain of distinct but overlapping policy responses (for example, between micro- and macroprudential regulators). An overriding goal for any strategy is to ensure the objectives of financial stability policy are understood by stakeholders. Clear statements of policy intentions improve the effectiveness of macroprudential measures, both on activation and on release (IMF, 2014a, ¶50). And successful communication increases an authority’s reputation for predictable, consistent policymaking (CGFS, 2016).

26. Financial stability messages are sent on multiple channels. The ability of the legislature and the public to hold agencies to account is aided by the publication of the minutes of key financial stability meetings. However, the proliferation of forums in which financial stability is discussed complicates the task of understanding policy, and of ensuring accountability. Multiple communication channels are employed by the various agencies charged with financial stability: In-depth systemic risk analysis is published by the BOK in its twice-yearly FSR;¹⁹ In addition, its Monetary Policy Board publishes minutes of its quarterly Financial Stability Meetings; Summaries of the inter-agency Macroeconomic and Finance Meeting are published by the MOEF-based secretariat after each meeting (at least quarterly); and the MOEF announces decisions on FX regulations. Yet other macroprudential decisions are announced via FSC press release.

27. Financial stability messages need a dedicated channel. A further complication is that within the many channels mentioned above, some are used to send messages on other topics too. For example, minutes of FSC commissioners’ meetings cover a broad range of micro- and macroprudential issues;²⁰ the MEFM covers a broad range of macroeconomic policy issues, albeit with a focus on financial vulnerabilities; and financial stability issues often crop up in monetary policy communications. Combining financial stability messages alongside other—conceptually distinct—issues, rather than devoting a specific ‘channel’ to them (as with the FSR) can obscure their content or weaken their impact.

28. Financial stability messages are targeted towards experts. Because the channels used for communication are monitored mostly by the specialized media and experts in industry and academia, and as the messages are often very detailed and technical, official messages are unlikely to reach beyond their traditional consumers.²¹ Although recent editions of the FSR were widely reported by the Korean press (79 stories appeared across print, broadcast, and online media following the June, 2019 edition), even amongst the financial institutions consulted during the FSAP few if any proved able to identify the key elements of the authorities’ policy strategy (beyond ‘cooling the housing market’). And despite a consistent message sent by the authorities in recent times that household debt was unlikely to cause a systemic risk, precisely that risk has consistently featured near the top of those named by respondents to the BOK’s Systemic Risk Survey.²²

29. Accountability may be hampered by opaque decision-making structures. At present, much of the decision-making process is invisible to those outside government. In part, this is because responsibilities are widely divided or shared between a number of agencies, meaning that relevant information is dispersed. It is also because the MEFM and its role in the policy process is not well known.

B. Recommendations

30. The authorities should undertake a thorough review of their financial stability communication strategy with the aim of improving transparency. The review should seek to bring Korea to the forefront of financial stability communication practice by considering the stakeholders that need to be reached by financial stability messages; the channels through which messages should be sent; and the design of messages with comprehensibility, priority, and accountability in mind.

• The authorities should consider broadening the group of stakeholders that financial stability communications reach. Support for the policy framework would be aided by helping the general public relate to and act on financial stability messages. Introducing layers of messaging is one means to achieve this.

• Each agency involved in financial stability communications should have clearly delineated areas of responsibility under a revised strategy. Rationalizing the number of channels used and ensuring that dedicated channels are prioritized should work best. The body with sole primary responsibility for macroprudential oversight would naturally take the lead in communicating policy actions.

• Communications should also bear in mind the need to link risk assessments to mitigating policy actions. Linking vulnerabilities to specific policy actions builds understanding of those measures amongst private sector actors. Information on the macroprudential measures in force at any given time, along with a summary of the risks being targeted by each measure, and an assessment of the progress made towards the goal of mitigating those risks should be readily available. It would be desirable if the body assigned the sole primary responsibility for macroprudential oversight were to own the process by which such information is collated and disclosed.

• The review should consider the appropriate level of disclosure for meetings that discuss, recommend, or decide financial stability policy actions. It is not necessarily desirable for detailed minutes of such meetings, or draft policy recommendations, to be disclosed. Neither is it desirable for the record of such meetings to be entirely or effectively withheld from public scrutiny. The timing and content of disclosure should aim to foster accountability and guide private sector expectations.

• Availability of documents in translation. Consideration might be given to increasing the availability of English translations of key documents, beyond the FSR.

A. Approach to Risk Monitoring

31. The authorities undertake wide-ranging risk monitoring activities. The FSC, FSS, MOEF, and BOK all undertake monitoring activities. The perimeter for monitoring is set broadly to capture banks, nonbank depository institutions, other financial companies, public guarantee institutions, and others. High-frequency monitoring of markets is mostly overseen by the FSC and FSS. The BOK has teams with very good analytical capacities, and is the principal agency charged with communicating risk assessments to stakeholders. The BOK Act requires it to conduct financial stability assessments and to publish a biannual Financial Stability Report (see ¶42). The Bank’s FSR is underpinned by a wealth of data and analysis covering credit and asset markets, financial institutions, capital flows, and financial market infrastructure, amassed by the Bank’s Financial Stability Department. Cooperation and coordination with risk assessments produced by the FSC and FSS is supported by the processes described above (see ¶17–18).

32. The process supporting the BOK’s analysis of financial institutions is systematic and well-developed. A ‘desk-based’ analysis track and a ‘bank examination’ track run in parallel. The first of these works around the FSR cycle, and has a broad institutional scope: (i) the bank and non-bank teams look across their respective sectors to assess asset management, asset soundness, and profitability; (ii) where vulnerabilities are found in institutions’ business lines, there is internal reporting and in-depth follow-up analysis; and (iii) when necessary, matters are elevated to the Financial Stability Meeting of the MPB. The second track is on an annual cycle, and has been mostly focused on larger banks.²³ It can take one of two forms: individual bank-focused; or sectoral, with a macroprudential focus. For the sectoral review, BOK examiners take the same issues to multiple banks. The main issues for sectoral reviews are approved by the MPB, and in recent years have included SOHO lending, household debt, and corporate loans. The risk analysis developed by Bank teams may be published in the FSR, often as in-depth topical issue boxes, some recent examples of which are summarized in Table 3.

33. Early warning systems covering a broad spectrum of financial risks are in use. The BOK publishes a ‘financial stability index’ (FSI) in its FSR (e.g. June 2019, p. 3), the purpose of which is to provide a headline signal of build-ups in systemic risk. The index has threshold values of ‘warning’ and ‘crisis’ and was calibrated on a very broad range of indicators.²⁴ Second, the FSS has put in place an early warning system for individual institutions that are subject to its supervision. The system provides a model-based assessment of the likelihood of capital shortfalls at individual institutions on a quarterly basis.²⁵ Several types of assessment follow: first, individual institutions that are found to be at risk are referred for examination; second, individual institution results are aggregated to perform industry-level solvency analyses. The FSC operates an early warning system for financial crises based on the signaling approach of Kaminsky and others (1998), information from which feeds into their monthly risk assessment. Finally, the MOEF operates a similar early warning system for key external sector variables, including the exchange rate and portfolio flows.

34. Sophisticated quantitative risk indicators draw on financial market data and are appropriately supplemented by qualitative information. Quantitative risk monitoring using market-based measures of systemic risk and interconnectedness are a useful way to keep abreast of information on the largest financial institutions that is ‘in the market’ outside of regular reporting windows. The BOK has implemented a suite of such models, including widely used CoVaR and SRISK approaches.²⁶ Qualitative information complements quantitative analysis. Twice a year, the BOK conducts a Systemic Risk Survey that covers close to one hundred employees and executives of domestic financial institutions, financial sector associations, research institutes, and foreign money managers. Qualitative monitoring is bolstered by interactions with relevant experts and market participants, including via the MAC.

35. Stress-testing is an important component of forward-looking risk assessment. Stress tests differ from other forms of risk assessment because they are explicitly based on prospective stress scenarios, in addition to the current state of the economy and current asset valuations. They therefore form an important component of the overall financial stability judgement. The BOK and FSS conduct annual joint stress tests, in addition to each agency’s own individually-run tests. The scenario used in the joint solvency stress testing exercise is developed using inputs from teams across the BOK, and the baseline scenario for the test is consistent with the forecast used by the BOK MPB in its monetary policy deliberations. The BOK has capacity for top-down solvency and liquidity tests, while the FSS conducts both top-down and bottom-up tests that could feed into their supervisory activities.²⁷

36. A suite of analytical models has been developed to support stress testing. The Systemic Risk Assessment Model for Macroprudential Policy (2012); the Non-bank Financial Institution Stress Test Model (2019), which covers insurance companies, credit cooperatives, savings banks, securities firms, and credit-specialized finance companies;²⁸ and the Extensive Stress Test Model (2019), which integrates banks and non-banks.²⁹ This model incorporates a contagion module which analyzes spill-overs from losses incurred by a financial institution to other institutions across all financial sectors. The FSS developed the Stress Test for Assessing Resilience and Stability of the Financial System (STARS) in 2017, to aid its macroprudential supervision efforts. STARS includes a suite of models that capture contagion and macro-feedback effects developed with the BOK. Results from the BOK stress tests are published in the FSR, and those from joint BOK/FSS tests are shared with the MEFM. For recommendations relating to stress testing, see the accompanying Technical Note on Stress Testing.

37. Availability of data is generally very good, although some gaps remain. A licensed public credit registry, the Korea Credit Information Service (KCIS), records and manages information on household and business loans.³⁰ Access to the credit registry makes possible a very granular analysis of the financial state of debtors and supports policy implementation. Some gaps remain in the area of non-financial corporate businesses’ financial exposures, which is relevant to solvency stress-testing. A second is related to the growth of FinTech, and in particular to peer-to-peer (P2P) lending. There has been rapid growth in P2P lending in Korea, but little information exists on the creditor base, the risks that they assume, or the extent to which borrowers have used P2P platforms to circumvent macroprudential measures that apply elsewhere in the system.³¹ However, legislation requiring P2P platforms to disclose more of their financial information may improve oversight is expected to be enacted.³² In particular, P2P lenders will in future be required to submit information to a credit agency to be used by banks to comply with DSR regulations (see ¶63).

B. Recommendations

38. An interagency team should be established to synthesize, prioritize, and direct regular assessments to the MEFM. The purpose of this recommendation is to ensure that the inter-agency system of risk monitoring is effective in (a) bringing together the analysis of separate agencies, (b) prioritizing identified risks, and (c) delivering warnings targeted to the responsible parties. Achieving these three goals will enhance the policy impact of risk assessment work.

The BOK is well-suited for this role as it already undertakes many of the necessary activities under existing legal reporting requirements, and already has supporting processes (such as quarterly financial stability meetings) in place. The new elements in this recommendation are:

• Prioritization: the principal macroprudential vulnerabilities identified by risk assessment should be clearly prioritized based on the likelihood that they will be the source of a systemic event, and their potential systemic impact. Identifying amplifying factors can aid understanding of the transmission channels associated with the crystallization of a particular macroprudential risk, and bolster the rationale for macroprudential policy actions.

• Designated recipient: the synthesized and prioritized risk assessment, along with warnings (if any), are to be directed to the body with sole primary responsibility for macroprudential policy.

In undertaking this task, the BOK will make use of existing mechanisms for working-level coordination and cooperation, such as those described under ¶17-¶18. This recommendation, along with the recommendation on monetary and macroprudential policy coordination in ¶47, below, would help to strengthen the capacity of the BOK to influence policy in ways that lead to effective macroprudential measures to mitigate financial stability risks.

A. Sources of Policy Interactions

39. Monetary policy impacts incentives for risk-taking, leverage, and liquidity creation. Monetary policy has the potential to affect financial stability through multiple channels (IMF, 2013; Box 2). For example, there is good evidence to suggest that low interest rates can induce banks to grant riskier loans (Dell’Ariccia and others, 2017). For the financial system beyond banks, the level of short-term rates is a notable driver both of leverage (Adrian and Shin, 2008), and of risk-taking by liability-driven investors, the so-called ‘search for yield’ (Becker and Ivashina, 2015). Studies often find that the extent of this risk-taking behavior depends on lenders’ underlying balance sheet strength (Jiménez and others, 2014). That type of dependence highlights the importance of coordination between prudential and monetary policies to ensure financial stability.³³

40. The overall effect of monetary policy on the likelihood of financial crises is small. Although monetary policy can encourage behavior that feeds financial vulnerabilities, its contribution to financial crises is indirect and, as a quantitative matter, thought to be relatively minor. The available evidence suggests that the nexus of credit growth and asset price spirals responds little to interest rates, so significant reductions in crisis probabilities would require substantial hikes in interest rates (Adrian and others, 2018).³⁴ A prolonged period in which monetary policy is kept tighter than warranted by broader economic conditions risks an undershoot of the central bank’s objectives for inflation and growth, damaging its credibility. This has led many economists to conclude that the costs of using monetary policy alone to deal with systemic vulnerabilities substantially outweigh the benefits (Svensson, 2017). However, this remains an actively-debated topic, and these conclusions are necessarily tentative.

41. Macroprudential policy should be used first to mitigate financial stability risks but is not omnipotent. When risks are sector-specific, or structural rather than time-varying, monetary policy would be an especially blunt tool to deal with them. Where targeted supervisory tools are available that avoid collateral damage to the broader economy, those are likely to be preferred.³⁵ However, prudential tools are subject to limitations due to leakages, potential inaction bias and political economy constraints, uncertainty over their transmission, and because forms of risk-taking may evolve faster than regulations do. Moreover, some vulnerabilities may be immune to effective remedy using macroprudential tools—for example, deeply negative term premiums in bond markets (Shin, 2015)—although such tools can help build resilience. Such arguments primarily reinforce the need for macroprudential frameworks to be strengthened. But they also point to the need for monetary policymakers to remain vigilant to financial stability risks, and to be ready to “lend a hand” if that is required (IMF, 2013; ¶38). Such assistance is particularly important when financial conditions undergo a material tightening that threatens financial stability. Monetary policy action might also be called for to offset the side-effects of some macroprudential actions, where these have an impact on aggregate demand.³⁶

42. The Bank of Korea has financial stability responsibilities but owns no direct macroprudential policy tools. The Bank of Korea Act (2011) instructs it to pursue price stability while ‘paying attention’ to financial stability.³⁷ In the absence of direct macroprudential powers, the Monetary Policy Board (MPB) discharges its financial stability responsibilities in two ways.³⁸ The first is through its financial stability monitoring activities. The Board is briefed four times a year on financial stability matters and signs off on the analysis and recommendations in the Financial Stability Report.³⁹ The second is via its monetary policy strategy. The Board’s “General Principles of Monetary Operation” set out how the goal of financial stability is incorporated into its flexible inflation targeting framework.⁴⁰ The principles stress the need for cooperation between monetary and macroprudential policy functions, and acknowledge that monetary policy action may be required to manage the trade-off that arises when financial imbalances have not been adequately contained by macroprudential measures.

43. The Monetary Policy Board must judge when the incentives for risk-taking are being contained by current macroprudential measures, and when they are not. In cases where the MPB perceives the trade-off between its objectives to be unfavorable, two actions may be taken. The first is to communicate the need for a strengthening of macroprudential policies—for example through its FSR—and to influence the macroprudential policy process through its participation in cross-agency forums. Two examples of such actions are detailed in the following paragraphs. However, because macroprudential policies are often complex and can be slow to enact, in the interim it may be desirable for the policy horizon to be extended—that is, for inflation to be brought back to target more slowly than would otherwise be the case—to avoid worsening financial imbalances.⁴¹ The second, and more troublesome, possibility is that the fundamental limits on the ability of macroprudential policy tools to contain risks have been reached. Under those circumstances, monetary policy may be used to some degree to compensate—although the tradeoffs involved are unlikely to be attractive (IMF, 2013, ¶39; IMF, 2014a, ¶76; Mester, 2017).

44. The BOK has multiple and partly overlapping roles as monetary policymaker, FX risk monitor, FX market agent, and key participant in the formulation of FX macroprudential measures through its seat on the MEFM. The combination of functions performed by the BOK in this policy domain act to enhance the effectiveness of both monetary and financial stability aspect of its mandate. Korea maintains a freely floating exchange rate (IMF, 2018), and is amongst the most open of the advanced economies. Its trade is also highly exposed to fluctuations in the US dollar exchange rate.⁴² Under these circumstances, recent research suggests that financial conditions in the US are likely to be an important source of external shocks for Korea, as well as a potential source of financial instability (Rey, 2016). To contain the risks that might arise when interest rate differentials between the Korean won and the US dollar become sizeable, the authorities have put CFM/MPMs in place that dull incentives to accumulate short-term foreign exchange liabilities (see ¶80–82, below). These measures attenuate the influence of the global financial cycle on domestic monetary policy.

45. The BOK has used its influence to strengthen macroprudential housing measures, helping to assuage debt concerns following recent monetary easing. The BOK cut its base rate twice in 2019, in response to weak growth and below-target inflation. A key concern for policymakers and observers of the Korean economy has been the possibility that easier monetary conditions could fuel renewed acceleration in household borrowing.⁴³ But as early as June 2016, the BOK was indicating the need to enhance the debt service capacity of borrowers.⁴⁴ BOK analysis underpinned its push—including at the MEFM—for strengthening the macroprudential framework through the introduction of DSR limits.⁴⁵ In this case, pre-emptive action on macroprudential policy has opened up some space for monetary policy to act towards its price stability objective; but tradeoffs remain, and the Board has continued to discuss the risks posed by household lending growth and rising real estate prices.⁴⁶

46. Premature easing of macroprudential policy can complicate the task of monetary policy. An instructive counterpoint to recent experience is provided by the decision to relax macroprudential housing measures in 2014 amid a slowing economy. At the time, household loan growth was accelerating; Seoul property prices were up, and apartment vacancies were down.⁴⁷ That constellation of factors would not normally warrant an easing of policy. Nevertheless, the government announced a stimulus package that included measures to ‘normalize’ the housing market through a relaxation of LTV and DTI limits, as well as various technical adjustments to boost housing demand (MOSF, 2014).⁴⁸ That decision has been the subject of criticism by some observers, in part because it had the undesirable effects of worsening the macro-financial trade-off at a time when easier monetary policy was needed, and because it gave the appearance of short-termism (Kim, 2019).⁴⁹ Using macroprudential tools to manage aggregate demand is likely to overburden them, and should be avoided (IMF, 2014b, ¶84).

B. Recommendations

47. The formal mechanisms for coordination between monetary and macroprudential policies should be strengthened. To minimize the likelihood of undesirable trade-offs between monetary and macroprudential policy objectives, a mechanism is required to better internalize the spillovers between decisions in the distinct policy domains. This recommendation has two important elements:

• In enacting macroprudential policy decisions, the responsible agencies should show that due regard has been given to the dual responsibilities of the BOK.

• When the MPB judges that systemic risk concerns place a material constraint on their ability to achieve their price stability objective, formal notification should be given to the body responsible for macroprudential oversight.

The formal notification will be grounded in a risk assessment, which would naturally emanate from the BOK’s activities under ¶38, and (optionally) a recommendation that specific policy actions be undertaken.⁵⁰

• If the assessment is accompanied by suggestions for mitigating actions, which would presumably be developed using the same inter-agency channels detailed in ¶18.

Note that the decision to place formal notifications in the public domain is a separate issue, but also that partial disclosure may be preferable to none (¶30). In implementing this recommendation, the independence of the Bank of Korea in the conduct of monetary policy shall be taken as absolute.

48. The BOK should enhance its capacity to quantify the macro-financial trade-off, and to model the effects of macroprudential policy actions over the policy horizon. Central bank models have increasingly come to reflect the importance of financial factors both as amplifiers of shocks, and as a potential source of disturbances to the broader economy (Lindé, 2018). Analysis of the trade-off policymakers must manage requires a structural model, and an appropriate assumption about how policy is set.⁵¹ The BOK’s structural macroeconomic model (BOKDSGE) could be developed to include a richer set of financial markets, financial assets (in particular, housing), and financial institutions such as banks.⁵² Developing such a tool would assist policymakers in their efforts to balance their macroeconomic and financial stabilization goals when setting monetary policy.

A. Broad-Based Vulnerabilities

49. Overall credit conditions are accommodative, but few indicators point to exuberance. Financial conditions in mid-2019, as constructed using the methodology set out in IMF (2017b), were close to historical averages after several years in easy territory (Figure 2). Perhaps driven by easy credit conditions, the ratio of total non-financial private sector debt to GDP has reached an elevated level—to stand close to 189 percent—and core debt (debt of the non-financial sector owed to banks) stands at 131 percent of GDP, which is high in international comparison (similar to Malaysia, Sweden). But although the trend has been upward, an accelerating trend is not in evidence; indeed, the credit-to-GDP gap is close to zero (Figure 2). Overall credit growth slowed to around 5 percent for households (as of 2019 Q1), a level the government judges to be sustainable over the longer term. Overall corporate credit growth stands a little under 7 percent, about double the average rate for recent years. Real estate prices remain high particularly in the capital area, where some valuations may be stretched (Part B of this section). The funding arrangements of the core system appear solid, with banks exceeding their LCR and NSFR requirements, and having little exposure to foreign exchange (Part D of this section). And despite the weak external environment, the economy continues to run a current account surplus.

Korea: Broad Financial Indicators and Bank Capital Buffers

Citation: IMF Staff Country Reports 2020, 277; 10.5089/9781513557014.002.A001

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Korea: Broad Financial Indicators and Bank Capital Buffers

Citation: IMF Staff Country Reports 2020, 277; 10.5089/9781513557014.002.A001

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Korea: Broad Financial Indicators and Bank Capital Buffers

Citation: IMF Staff Country Reports 2020, 277; 10.5089/9781513557014.002.A001

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50. Korea has implemented the countercyclical capital buffer framework, but has yet to ever raise it above zero. The CCyB is intended to mitigate the likelihood of crises resulting from pro-cyclical movements in broad-based vulnerabilities. Korea’s CCyB is currently set to zero.⁵³ In past advanced economy cycles, easy credit conditions during up-swings have facilitated build-ups in leverage, rapid credit growth, and inflated asset prices. All of these are known to be risk factors for financial crises and deeper-than-average recessions. In addition, it may attenuate cyclical build-ups in credit exposures. The CCyB has been widely implemented, but to date fewer than a score of countries have ever set a positive buffer. An advantage of maintaining a positive buffer, even in a normal risk environment, is the possibility of releasing it (reducing the buffer requirement) in the event of stress. Such actions help to reduce pro-cyclicality by giving banks balance sheet space when constraints would otherwise be binding.

51. The authorities employ a range of indicators when considering the appropriate CCyB setting. Assessing the state of the financial cycle in real time is not straightforward, and in practice no single indicator is likely to provide a reliable guide. As a result, multiple indicators are typically considered. Further, although quantitative indicators can provide a guide to policymakers, it is important that they retain discretion when making decisions. In Korea, the FSS provides recommendations for the CCyB setting to the FSC on a quarterly basis.⁵⁴ (The BOK provides its own, separate, assessment.) Its recommendation is based on an assessment of vulnerabilities, and an assessment of resilience. On vulnerabilities, a single main indicator—the credit-to-GDP gap—and five ancillary indicators, shown in Table 4, are used. The indicators aim to pick up accelerations in overall credit, household debt, house prices, non-core funding, and foreign currency debt. Comparing indicator values to an alert threshold produces a signal that guides the overall recommendation. On resilience, capital adequacy and asset quality are assessed. Where indicators are below their thresholds, and overall resilience is deemed sufficiently high, a zero buffer is recommended.

52. The current approach to assessing the state of the credit cycle has a number of limitations. These fall into the following categories:

• Some indicators should be related to the incidence of banking system problems. To be effective, the CCyB should be activated in the up-swing of a credit cycle that has the potential to lead to a crisis. The chosen set of indicators may, or not, be systematically related to such events. However, the authorities have developed a number of early warning models that could already provide useful model-based input to the decision. An alternative to threshold-based EWMs is a binary classification model for crisis events.

• The scope of indicators should be sufficiently broad. At present, all indicators are quantity- (rather than price-) based. That makes it hard to pick up mis-pricing of risks (for example, compressed lending spreads). In general, it is desirable to define a set of risk buckets that encompasses all the relevant risk categories, and to select indicators within those. We note (without endorsement) that the core indicator set for the countercyclical buffer published by the Bank of England contains 18 indicators in three categories: non-bank balance sheet stretch; conditions and terms in markets; and bank balance sheet stretch. And the ECB’s core indicator set includes the categories: credit developments; property price over-valuation; external imbalances; private sector debt burdens; and the mis-pricing of risk. A detailed list of potential indicators is discussed in IMF (2014b, ¶7-¶14 and Table 1), along with information on CCyB frameworks in other jurisdictions (Table 2).

• Computing ‘gaps’ using the HP filter has problems. It has long been known that serious issues of interpretation attend the use of the HP filter, as the transformations it performs on the underlying data introduces spurious dynamic relations (Hamilton, 2018).⁵⁵ Practitioners have noted the downward bias to the credit-to-GDP gap following credit booms, and the undesirable increases that result from business cycle downturns. Criticism extends to the one-sided filter; although it avoids the ‘end of sample’ problem, others remain. Alternative methods of detrending that have a firmer statistical basis are available (Harvey, 1990; Hamilton, 2018). It is noteworthy that most countries that have activated the CCyB have a negative credit-to-GDP gap, and that amongst the jurisdictions with a zero buffer are a significant number whose credit ‘gap’ are well into positive territory (Figure 2).⁵⁶

53. The authorities have yet to set out how the CCyB will be used. There is an increased recognition that macroprudential policy should be guided by a strategy that set out how risks map into actions, and how the results of actions are assessed (see ¶97).⁵⁷ The CCyB is a useful place to trial such a strategy, as it is reviewed on a quarterly basis, and requires a holistic approach that encompasses broad categories of vulnerabilities. In many jurisdictions, the quarterly review round for the CCyB provides a useful focus for macroprudential risk assessment since the need to reach a decision spurs structured monitoring activity. Making clear in advance when the buffer will be released—a crucial phase of counter-cyclical policy—should help to reassure banks that they do not need to hold ‘buffers-on-buffers’.

54. More balanced arguments for a positive CCyB setting could be made. The costs and benefits of using the CCyB are not fully set out in the advice given to policymakers. Potential costs include potential spillovers to the real economy, and these should be quantified. Research suggests that such costs can be minimized by appropriate coordination between monetary and macroprudential policies (Meeks, 2017). The potential benefit of activating the CCyB in a period of still-easy financial conditions would be that ‘insurance’ (in the form of additional capital) can be purchased cheaply against the broad-based vulnerabilities created by the prolonged build-up of household indebtedness, and the banking system’s sizeable exposure to real estate. Finally, there are circumstances under which microprudential and macroprudential objectives are in apparent conflict, and as a consequence there are risks to entrusting a microprudential supervisor with primary responsibility for making CCyB recommendations.

55. Other broad-based tools include a limit on the leverage ratio and forward-looking provisioning. Estimates of the risk attending banks’ exposures are uncertain and vary depending on whether standardized or IRB schemes are used to compute them. They may also fail to account for risks that fall outside historical experience—or experience recent enough for good data to be available for modeling—and they may become inaccurate when changes occur in the structure of the financial system, financial products, or financial regulation itself.⁵⁸ For these reasons, an unweighted leverage ratio provides a useful back-up to the standard risk-weighted capital ratio. Because it does not seek to account for the relative riskiness of different exposures, it protects banks against errors of miscategorization, where assets are assessed as low risk when they are not; as well as errors of commission. Leverage limits disincentivize banks from responding to tighter risk-based capital requirements by shifting out of high-risk weight assets (for example, SME loans in the denominator of the ratio) rather than raising additional capital (the numerator). Finally, IFRS9 was introduced for Korean banks in 2018, and so are required to make provisions on the basis of expected losses rather than realized impairments. As discussed elsewhere, Korean banks are also active sellers of NPLs to AMCs.

B. Vulnerabilities from Housing and the Household Sector

56. Elevated household indebtedness is viewed as a potential vulnerability. Respondents to the BOK’s Systemic Risk Survey have consistently placed the ‘household debt problem’ or ‘housing market instability’ amongst their top five financial system risk factors.⁵⁹ The FSAP has identified concerns associated with pockets of at-risk debt owed by liquidity-constrained households, rollover risks associated with Korea’s unique rental system (jeonse), and the potential for medium-term stress amongst older age cohorts as Korea undergoes a demographic transition. Fear of crises related to real-estate are well-founded. The Nordic banking crises of the early 1990s saw GDP decline at rates of almost 5 percent year-on-year in Sweden, and more than 6 percent in Finland.⁶⁰ And taken across advanced economies as a whole, Jordà and others (2016) report that the aftermath of mortgage booms are marked by deeper recessions and slower recoveries than others. Rapid expansion in other forms of household lending can also lead to trouble. Between 1999 and 2002, Korea’s credit card lending boom saw a tripling of cards in issue, and a quintupling of outstanding balances (Kang and Ma, 2009). The crisis that followed in 2003 saw heavy losses for banks and card issuers, and negative spillovers to the real economy and asset prices.

57. Loans secured against housing collateral account for more than half of the assets of Korea’s nationwide banks. Korean lenders’ exposure to mortgages is systemically significant.⁶¹ Mortgage loans account for around a third of the assets held by domestic banks. Amongst the domestic banks, nationwide banks—the most significant grouping in terms of assets, accounting for 52 percent of the total banking system in 2018, or 83 percent of GDP—have the highest share, at around two-fifths of their total assets. In addition to mortgages, banks also make loans secured against jeonse (leasehold) deposits. Those deposits are a sizeable proportion of the value of the property being leased—67 percent on average, or 74 percent for apartments.⁶² Loans amount to some KRW100tn, or a little over 10 percent of the size of domestic banks’ mortgage book—but are partly guaranteed, and so carry zero risk weight.⁶³ Finally, the past several years has seen rapid growth in SME lending to real estate leasing businesses. Loans to this segment, which include loans to sole proprietors or SOHOs—frequently residential landlords incorporated as small businesses— amounted to a tenth of domestic bank total assets in 2018.

58. Household lending is also important amongst some non-banks. Some ODIs are very exposed to households. For example, mutual credit cooperatives had exposures to households of around KRW300tn in 2018, around 70 percent of their total assets. Historically, ODI lenders—which have a different capital adequacy regime—applied lower lending standards to their household loans than did the domestic banks. On the other hand, household lending by life insurance companies, which comprises just 3 percent of those companies’ total assets, has typically been on conservative terms.⁶⁴ New entrants to the lending business—such as the internet-only banks—have focused on growing their consumer credit businesses, and have issued very few mortgages.⁶⁵

59. Korea has not seen a real estate bust since 1997. Nationwide nominal prices have not undergone any significant decline since the Asian financial crisis. But in real terms, year-on-year price growth has been close to or below zero since the end of 2016. Figure 2 shows the rate of inflation-adjusted apartment price trends across three regional groups, along with the whole-country aggregate.⁶⁶ It is notable that real-terms price declines have largely been driven by developments outside of the capital city area. In the three capital-area regions of Seoul, Incheon, and Gyeonggi-do, prices have mostly grown above the rate of inflation. Price growth in the capital area is only weakly correlated with that in other regions of the country (see Appendix I Table 1).

60. The capital area real estate market is at greatest risk of over-valuation. The capital area is the center of the real estate market in Korea. It produces half of national GDP and contains half the country’s population. The median apartment price in Southern Seoul (the premier market within the capital city area) is three times the national median, and eight times the price in the cheapest region (Gyeongsangbuk-do), according to data from Kookmin Bank. Unsurprisingly, affordability in Seoul is very low (Figure 3). The unique pressures on the center market has made prices there more volatile, and more prone to speculative activity—evinced through widespread demand for multiple properties, and high rates of turnover—than is the case in other areas of the country.⁶⁷ Indeed, model-based valuation measures suggest that Seoul prices are somewhat above their equilibrium level (Figure 3).⁶⁸ But they are well below in non-metropolitan areas, and cities outside Seoul, in part due to the long-term structural changes affecting industrial cities such as Ulsan.⁶⁹

Korea: Real Estate Valuations

Citation: IMF Staff Country Reports 2020, 277; 10.5089/9781513557014.002.A001

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Korea: Real Estate Valuations

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Korea: Real Estate Valuations

Citation: IMF Staff Country Reports 2020, 277; 10.5089/9781513557014.002.A001

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61. Macroprudential tools have been deployed to mitigate systemic vulnerabilities from the household sector. The systemic significance of household sector lending, and particularly of lending secured against real estate, has necessitated the deployment of a wide range of policy tools. The strong pull of the capital area real estate market has meant that policy measures have often been targeted there, with measures differentiated down to the level of individual districts (si, gun, and gu). Although borrower-based measures have received most attention, tax measures and even price caps have also been deployed.⁷⁰ The strong incentives that appear drive households’ acquisition of real estate assets in Korea are likely to mean that sustained policy action is likely to remain appropriate, if the pro-cyclical effects of excess household credit are to be avoided. However, the authorities should be mindful that further tightening of borrower-based measures may not be as effective as past actions, and that unintended side-effects may emerge (Alam and others, 2019). That suggests a need for careful monitoring of the net benefits of future policy actions in this domain.

62. Policy measures have been aimed principally at limiting the ability of borrowers to take on excess leverage. The Korean authorities introduced borrower-based measures in 2002, starting with a cap on the maximum loan-to-value (LTV) ratio. Limits on the maximum repayments-to-income ratio for mortgages (a DTI cap) followed.⁷¹ The limits that are currently in place are set conservatively—as low as 40 percent in speculation-prone metropolitan markets, with yet lower limits for owners of multiple homes. For comparison, LTV limits in Croatia (another early adopter of borrower-based measures) are 75 percent; in Finland above 90 percent; and in Indonesia 75 percent. Limits in Bulgaria, Hong Kong SAR, and Singapore are comparably tight.⁷²

63. Recent measures have aimed to further strengthened borrowers’ ability to repay loans.

• Loan underwriting standards have been tightened. As part of the measures introduced in October 2017, the FSC announced stricter standards for calculating DTI ratios.⁷³ These included eliminating anomalies in the treatment of existing debt for those taking second mortgages and improving documentation of income. Stricter income checks were also announced for cooperatives in June 2017.

• Borrowers have been incentivized to take safer mortgages. Policy measures aim to encourage borrowers to take out fixed interest rate amortizing loans, for example by easing LTV limits for such mortgages. Such loans carry a lower risk of becoming distressed in the event that interest rates rise, or property prices decline. The stock of outstanding mortgages at fixed rates increased from less than 10 percent of all mortgages in 2011 to 45 percent in 2018. The share of amortizing mortgages followed a similar pattern, and stood at a little over 50 percent in 2018.

• Measures introduced to take account of overall household indebtedness. When the availability of mortgage credit is limited, incentives may be created for households to obtain other secured or unsecured loans. Growth in unsecured lending can in turn raise the share of households vulnerable to increased debt service burdens should adverse shocks materialize. To gain better traction on risks from rising overall household indebtedness, the authorities introduced rules that restrict new lending at high-DSRs. These were fully implemented for banks in October 2018 and appear to have caused growth in non-mortgage lending to slow to close to zero in 2019Q1, as well as achieving a material reduction in the riskiest high-DSR lending (Table 6).⁷⁴

A summary of selected macroprudential housing actions appears in Table 5.

64. Regulatory leakage to non-bank lenders is minimized by alignment in LTV and DTI rules. Creating a level playing field for different categories of lender helps to remove incentives for borrowers to migrate towards lower-quality lenders when regulations are tightened. Historically, borrower-based measures were calibrated to be somewhat looser for NBDIs and finance companies than for banks and insurance companies. For example, when LTV limits were first introduced for savings banks, mutuals, and finance companies in 2005, the maximum possible was 80 percent for long-term loans secured on apartments in speculative zones, compared to 40 percent for banks. However, LTV and DTI rates were unified at 70 percent and 60 percent (respectively) for all lenders in 2014 as part of a package of measures to simplify regulations.⁷⁵ Since 2017, LTV and DTI limits have been differentiated once again, but only by region and not by institutional form. Some banks welcomed this regulatory alignment, reporting that it had improved their ability to compete for borrowers. By contrast, DSR targets are different for non-banks, reflecting their diverse borrower base and variety of loan types.

65. Tighter macroprudential measures crimped house price appreciation and lessened the risk of sharp house price corrections. Although affecting real estate prices is not a primary goal of LTV and DTI measures, research has shown that tighter measures have cooled the housing market (Box 1). Recently, there has also been interest in understanding how such policies may also affect downside risks in real house prices, rather than simply their effect on the average price (IMF, 2019b). This new approach, known as housing at risk (HaR) can shed light on how macroprudential measures map into household sector vulnerabilities and financial stability, and so is more closely linked to the underlying objective of the measures. HaR measures the magnitude of house price declines that occur with a given probability.⁷⁶ Figure 4 shows how the unconditional distribution of year-on-year real apartment prices is affected by a 10ppt tightening in both the LTV and DTI ratios.

Korea: The Effect of Tighter Macroprudential Measures on the Distribution of Real Apartment Price Growth

Citation: IMF Staff Country Reports 2020, 277; 10.5089/9781513557014.002.A001

Note: Panels show the probability density functions for the year-on-year growth in real apartment prices in Seoul (right) and for Korea as a whole (left). Bottom axis = annual percent change in real apartment prices, one year ahead. Baseline = the estimated unconditional distribution. Macropru = the baseline plus the estimated effect of a 10 point tightening in LTV and DTI limits. Estimation sample runs 1992Q4–2019Q1. Source: IMF calculations.

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Korea: The Effect of Tighter Macroprudential Measures on the Distribution of Real Apartment Price Growth

Citation: IMF Staff Country Reports 2020, 277; 10.5089/9781513557014.002.A001

Note: Panels show the probability density functions for the year-on-year growth in real apartment prices in Seoul (right) and for Korea as a whole (left). Bottom axis = annual percent change in real apartment prices, one year ahead. Baseline = the estimated unconditional distribution. Macropru = the baseline plus the estimated effect of a 10 point tightening in LTV and DTI limits. Estimation sample runs 1992Q4–2019Q1. Source: IMF calculations.

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Korea: The Effect of Tighter Macroprudential Measures on the Distribution of Real Apartment Price Growth

Citation: IMF Staff Country Reports 2020, 277; 10.5089/9781513557014.002.A001

Note: Panels show the probability density functions for the year-on-year growth in real apartment prices in Seoul (right) and for Korea as a whole (left). Bottom axis = annual percent change in real apartment prices, one year ahead. Baseline = the estimated unconditional distribution. Macropru = the baseline plus the estimated effect of a 10 point tightening in LTV and DTI limits. Estimation sample runs 1992Q4–2019Q1. Source: IMF calculations.

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66. In the case of the nation as a whole (left panel), tighter policy appears to damp down the likelihood of rapid appreciations; the probability of seeing a rise in prices greater than 5 percent (in real terms) goes from 21 percent in the baseline to 16 percent when macroprudential measures are tightened. But for Seoul, where macroprudential policies were applied most frequently, there are notable effects on downside risks too: In the baseline, there is a one-in-twenty chance of prices falling by 7.5 percent over the course of a year; when policy is tightened, the corresponding decline is only 6.6 percent (put differently, the 5 percent HaR or the 5^th percentile of the distribution of house prices goes from -7.5 percent to -6.6 percent). These findings show that Korea’s borrower-based macroprudential measures can be thought of as an effective risk management policy. But at the same time, real-terms declines in prices cannot be ruled out.

67. A sectoral countercyclical buffer for household exposures would complement existing measures and add flexibility to respond to changing risks. Borrower-based measures improve the resilience of household balance sheets. The purpose of a SCCyB is to do the same for banks, in the context of slowing growth in household exposures but a sizeable stock of past loans. The SCCyB requires banks to build up a capital buffer on a demarcated segment of exposures deemed to pose risks beyond those accounted for by Pillar I rules (see BCBS, 2019a). A SCCyB on household exposures has been proposed by the FSS, and the FSC is reviewing plans to introduce it.⁷⁷ The authorities already impose higher risk weights on some categories of household exposure, which means more capital must be held against them, but these weights are time-invariant. By contrast, the SCCyB would allow capital to be built up and released as risks from the household sector wax and wane over the credit cycle, and when risks crystalize. An ancillary effect of the SCCyB might be to slow the pace of household lending, with possible knock-on effects for housing valuations. However, affecting credit growth and house prices is not its primary purpose.⁷⁸

68. The SCCyB brings a number of potential benefits, including enhancing resilience to a targeted set of risks, providing a releasable buffer in the event risks crystalize, and complementing borrower-based measures. The key benefits are as follows:

• To enhance or maintain banks’ resilience to sector-specific risks. The primary purpose of the CCyB, and its sectoral counterpart, is to generate a capital cushion that can be used in the event that unanticipated losses occur. This cushion will allow banks to support valuable economic activity through continued lending, even in the event of a sector-specific shock.

• To provide a targeted and efficient capital-based tool. The SCCyB is targeted to specific lending segments, and affects the relative cost of lending to different borrower types. The effect of a positive SCCyB can therefore be to make lending to a targeted segment less attractive. Relative to the CCyB, which has a uniform impact on all exposures, the SCCyB may therefore be a more efficient means of containing sectoral imbalances. Moreover, early decisions on activation and release would potentially be more straightforward than in the case of the CCyB.

• To provide a releasable buffer in the event of stress. Under some circumstances it may be desirable to release the SCCyB. IMF (2014b, ¶21-¶25) suggests that countercyclical capital-based tools should be released in an incipient crisis, but that measures should be taken to ensure that banks use the released capital to absorb losses, rather than distributing via dividends or otherwise.

• To complement borrower-based macroprudential measures. Tools such as maximum LTV ratios act to enhance the resilience of borrower balance sheets. They tend to curtail the current demand for housing credit as they require households to take actions that may include accumulating additional financial resources or purchasing lower value properties. These channels of transmission are likely to complement measures that on the margin affect the cost to financial institutions of extending household credit, such as the SCCyB.

• Improved policy mix. Alam and others (2019) show that, in the case of LTV limits, tightening borrower-based measures can lead to declining benefits, and rising costs. An active (non-zero) SCCyB may also allow the use of some borrower-based tools to be scaled back, resulting in a better policy mix.

To date, only Switzerland and Spain have introduced SCCyB frameworks, and only Switzerland has used the buffer (Jahn and Pirovano, 2019).

C. Vulnerabilities from the Corporate Sector

69. The indebtedness of Korean corporates is above the G20 average. Total non-financial corporate credit stands at around 100 percent of GDP, roughly unchanged from 2013 (see Figure 5). This level is about 4ppt higher than the G20 aggregate, and 6ppt higher than the advanced economy aggregate reported by the BIS. For comparison, this level of indebtedness is comparable to that of Japan, Portugal, and Chile. On the other hand, it is far lower than in France (152 percent), Sweden (160 percent), or Ireland (202 percent).⁷⁹ Of the total debt owed by corporates in Korea, KRW843tn (46 percent) was due to banks (as of 2019-Q1), with the remainder being capital market funding.⁸⁰ Banks have very low levels of foreign exchange denominated loans, and regulations often require asset-liability matching (natural hedges) where longer-term loans are made (see also Part D of this section).

Korea: Corporate Indebtedness

Citation: IMF Staff Country Reports 2020, 277; 10.5089/9781513557014.002.A001

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Korea: Corporate Indebtedness

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Korea: Corporate Indebtedness

Citation: IMF Staff Country Reports 2020, 277; 10.5089/9781513557014.002.A001

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70. Most bank lending to non-financial corporates is directed to SMEs. Large corporates are by-and-large cash rich, and able to tap local and global capital markets where funding needs arise. Direct lending to large corporates therefore makes up only around one fifth of banks’ overall corporate book, around KRW160tn. Indirect funding via corporate bond holdings is negligible. Most lending—some KRW700tn (20 percent of system assets)—goes instead to SMEs. Korean SMEs are able to borrow on relatively favorable terms. The spread between average SME loan rates and that of large firms has been less than 0.5 percent for the past five years, which is low in international comparison (OECD, 2019; latest available figures are for 2017). However, low spreads may also reflect conservative lending practices.⁸¹ NPL rates on bank balance sheets are low, in part because of Korea’s comprehensive corporate restructuring provisions, and the existence of asset management companies specialized in bad loan recovery.⁸² Most of the recent slow-down in SME lending growth can be attributed to stricter rules on SOHO loans related to real estate leasing businesses (discussed in Part A of this Section).

71. Government supports SMEs in a variety of ways. Around 10 percent of total SME lending is backed by a government loan guarantee, and a little under 1 percent is made directly from government (OECD, 2019). The Korean government also directs spending worth 3 percent of GDP towards SMEs, through procurement and subsidies (Tierno, 2019). In addition to this direct support, Korea also has five specialized banks whose role is to provide funding to industry, three of which are government-controlled.⁸³ These banks are a significant source of SME funding—for example, some four-fifths of IBK’s loans were made to SMEs in 2018.

72. Risks to the core banking system from exposure to corporates appear to be contained under stress. The principal near-term risk to SMEs is posed by their direct exposure to export markets affected by the ongoing US-China trade tensions; and indirect exposures to larger firms that are also being impacted. The results of the FSAP solvency stress tests show that across the banking system as a whole, SME exposures imply loss rates that exceed their portfolio shares, particularly for the regional banks. This indicates the heightened vulnerability of SMEs under the scenario considered. That said, losses are not sufficient to drive the system to insolvency. But that conclusion should be taken with caution to the extent that the exercise may not fully capture the knock-on effects of a large firm failing onto the SME sector. The health of the specialized lenders is also key to supporting SME credit, which amounted to a third of their loan books as of end-2018. The capitalization of specialized banks is therefore an important factor for maintaining the supply of credit to SMEs. In that context, it should be noted that the specialized banks’ regulatory capital ratios are somewhat below those of nationwide banks, and that their capital depletion is more sizeable under the adverse scenario considered in the FSAP’s solvency stress test than that of nationwide and regional banks. But overall, the combined effects of government’s direct and indirect involvement in the SME sector, forward-looking provisioning, and the framework for recovering loans are together likely to help avoid excessive pro-cyclical contractions in credit if negative shocks occur.

73. Regulators have recently issued new rules on loan-to-deposit ratios designed to incentive corporate lending by banks. The authorities appear to wish banks to rebalance their loan portfolios away from households and towards corporate borrowers—the majority of which are SMEs as outlined above. To do this, they have announced that the flat 100 percent LTD ratio, which was applied across exposures, will be replaced by differential weights to household and corporate exposures. Specifically, starting in 2020 the LTD ratio will be calculated with a weight of 115 percent for household lending, versus 85 percent for corporates.⁸⁴ If banks start out with equal exposures to the two sectors, which is approximately the case at present, no immediate changes would be necessary. However, under some circumstances banks may have an incentive to issue more corporate loans than household loans. For example, if the aggregate demand for deposits is highly price inelastic, so that banks as a whole would struggle to increase their deposit funding, the tighter requirement could place a brake on household credit growth. For that to occur, the LTD requirement would have to be binding—which is not certain, given that banks are also subject to the NSFR.

74. The change in LTD rules is of dubious value and should be revisited. The purpose of macroprudential tools is to increase the resilience of borrowers and lenders to shocks, thereby mitigating procyclicality in the financial system. As a by-product, they may often cause private agents to alter their mix of exposures. However, if policymakers wish to achieve sectoral rebalancing of credit as an end in itself, independent of systemic risk concerns, macroprudential tools should not be used. Indeed, even capital-based prudential tools appear to have little impact on SME lending (FSB, 2019). In the present case, perceived risks in corporate lending could be dealt with by changing risk weights on SME lending—or more likely, through microprudential actions aimed at bolstering the capital positions of the weaker specialized banks. If instead risks are thought to lie primarily with high levels of household exposures, then were the authorities to implement the SCCyB on household exposures, there would likely be a natural re-balancing of bank exposures towards SME loans as a result. Changing exposure weights for the LTD ratio is unlikely to have a material effect on SME lending, and may have unintended consequences in situations of liquidity stress, given the already complex set of liquidity regulations that they face.

D. Liquidity and Foreign Exchange-Related Vulnerabilities

75. A principal source of systemic liquidity risk is over-reliance on non-core funding. Core funding at banks, coming from domestic deposits, grows in line with the fundamentals of household wealth and the economic cycle. In small and financially open economies, non-core funding— especially from foreign wholesale sources—is driven in large part by global risk appetite.⁸⁵ The pro-cyclical nature of foreign liabilities at domestic banks exposes them to capital flow reversals, which can result in the crystallization of systemic risks, for example from asset fire sales and liquidity hoarding (Shleifer and Vishny, 2011). Such risks are the fundamental justification for mitigating macroprudential policy actions.⁸⁶

76. Korea experienced foreign currency liquidity shortages during the Asian financial crisis. The 1997–98 crisis saw severe liquidity problems emerge amongst Korean banks, which had borrowed heavily abroad to fund loans to domestic conglomerates. For example, in 1996 the ratio of foreign liabilities to assets to BIS reporting banks was 332 percent (Corsetti and others, 1999, Table 28), and much of this borrowing was short-term. Banks were heavily exposed to rollover risk, which crystalized as losses on loans to the troubled corporate sector mounted.⁸⁷

77. Difficulties re-emerged during the 2008 Global Financial Crisis. In the decade following the Asian crisis, reforms were made to financial regulation, and the balance sheets of Korean banks were materially strengthened. But Korea’s highly export-oriented economy generated a significant structural demand for foreign exchange hedges, which themselves became a source of systemic risk.⁸⁸ And the won-dollar carry trade led to large-scale and short-term dollar borrowing, particularly by branches of foreign banks. When global banks scrambled for liquidity after the collapse of a US investment bank in March 2008, the won-dollar swap market experienced severe dislocation, with deviations from covered interest parity (CIP) in excess of 1,000 bps.⁸⁹ There were sizable outflows of foreign exchange from domestic banks and foreign branches, as well as large-scale intervention by the Korean government and central bank.⁹⁰ A swap line with the Federal Reserve, which was in place until 2010, gave the BOK access to US dollar funding and—along with similar arrangements with the People’s Bank of China and the Bank of Japan—helped to ease pressures in the swap and forward markets.

78. Foreign exchange market developments are closely watched by the authorities. Korea’s adverse experiences with foreign exchange stress have shaped an official approach to the markets that is highly sensitive to incipient pressure. Monitoring of developments in the foreign exchange markets is carried out by the MOEF and BOK, with the MEFM serving as the principal venue for information exchange and policy discussion. The MEFM has been convened as often as twice a week during the period of global trade tensions that intensified during 2019. The MEFM takes the lead on formulating measures to counteract emerging foreign exchange risks, while implementation rests with the BOK and supervisory authorities.

79. A portfolio of policy measures has been introduced to limit systemic risks. A summary of the policy measures, along with the institutional forms they cover, appears in Table 7.⁹¹ Some measures, such as the limits on net open positions and forward positions, are common in many jurisdictions. A LAR ratio limit differentiated by foreign currency, first introduced in 1997, was aimed at reducing foreign exchange mismatch. Shortcomings revealed in FX regulations in 2008 led to complementary measures being introduced to achieve greater coverage of potential vulnerabilities, including the derivatives cap and the macroprudential stability levy (MSL) discussed below, as well as modifications to liquidity rules.⁹² The LAR-FX was superseded by the LCR-FX for large domestic banks in 2017. It was maintained for insurers and other non-banks, small domestic banks, and KEXIM, to which the LCR-FX does not apply.⁹³ In addition to the measures listed in Table 7, certain fiscal measures have at times been used to influence capital flows—notably exemptions for capital gains and interest earned on foreign investors’ bond portfolios between May 2009 and January 2011 (Hwang, 2017, Table 1).

80. An LCR differentiated by foreign currency helps address short-term liquidity risks. Korea has adopted the LCR-FX as a requirement (not simply a monitoring tool) alongside the Basel III LCR requirement. Both measures came fully into force in 2019. The LCR-FX requirement serves the macroprudential purpose of improving the resilience of the banking system in the event of shocks to funding liquidity in foreign currencies. Domestic commercial banks with FX liabilities above a threshold amount, and specialized banks (such as IBK) must hold a stock of high-quality liquid assets in foreign currency sufficient to cover a 30-day net cash outflow. The floor is set slightly lower than its local currency equivalent (80 percent vs. 100 percent). The following institutions are excluded from the LCR-FX: (i) KEXIM, (ii) foreign bank branches, and (iii) banks with foreign-currency denominated debt below USD 0.5bn, or with a foreign currency-denominated debt to total debt ratio of less than 5 percent.

81. Net derivative positions are limited to a multiple of bank capital. The measure requires banks to hold costly capital against net FX derivative positions, which acts to shrink the arbitrage profits that can be earned (for example) through won-dollar swap transactions (Hwang, 2017).⁹⁴ It also has the effect of improving banks’ resilience to FX shocks. The limit was introduced in 2010, adjusted in 2011 (tighter), 2013 (tighter), and 2016 (looser) in response to swings in global liquidity (Figure 6). The limit is set at a higher ratio to capital (that is, looser) for foreign branches, whose business models are different from domestic banks—requiring them to take overall larger positions—and who have greater access to foreign exchange via global parent banks.

Korea: FX and Liquidity Metrics

Citation: IMF Staff Country Reports 2020, 277; 10.5089/9781513557014.002.A001

Source: Updated from Hwang (2017), courtesy of Bank of Korea.

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Korea: FX and Liquidity Metrics

Citation: IMF Staff Country Reports 2020, 277; 10.5089/9781513557014.002.A001

Source: Updated from Hwang (2017), courtesy of Bank of Korea.

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Korea: FX and Liquidity Metrics

Citation: IMF Staff Country Reports 2020, 277; 10.5089/9781513557014.002.A001

Source: Updated from Hwang (2017), courtesy of Bank of Korea.

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82. The macroprudential stability levy acts as a tax on activities that may give rise to systemic risks. Introduced in 2011, the levy aims to discourage risky foreign exchange exposures, especially those involving excessive short-term maturity mismatches on financial institution balance sheets. It does so by applying a flat fee of 10 basis points on non-deposit foreign exchange denominated liabilities with remaining maturity of a year or less. Hahm and others (2012) identify three desirable properties of the levy: (1) it acts directly on the identified source of systemic vulnerability; (2) as the ‘tax base’ of the levy varies over the cycle, it acts as an automatic stabilizer; and (3) it acts on financial vulnerability without impacting banks’ core intermediation function. Price-based measures, such as the levy, can be a useful complement quantity-based liquidity ratios and exposure limits. An important aspect of the levy’s design is that proceeds from it feed into a ring-fenced account of the ESF, to be used to support FX liquidity in times of stress.

83. The portfolio of enacted policy measures has been successful in extending the maturity of external debt and reducing maturity mismatches. Given the incentives for risk-taking in foreign exchange markets, the potential for circumventing restrictions, and the risks that can crystalize, putting in place several complementary measures is likely to bring benefits.⁹⁵ The tools deployed by Korea have different design features and transmission mechanisms and combine price- measures (such as the MSL) with quantity-based backstops (such as the LCR-FX). Quantitative studies of Korea’s FX policies indicate that they have broadly achieved their intended effects. For example, Choi (2014) attributes sizeable reductions in short-term external borrowing to the suite of measures introduced after 2011, while finding virtually no reductions in longer-term borrowing. In their bank-level study, Cho and Hahm (2014) report that the macroprudential levy reduced non-core liability ratios by close to 10 percentage points. Kim and Lee (2017) argue that the policies have curbed FX market vulnerabilities, with the levy having been particularly effective at limiting foreign borrowings of domestic banks. Hwang (2017) reports that tighter derivative limits curtailed the volatility of banks’ FX liabilities, especially amongst foreign branches; and that overall, banks have remained well inside the prudential limits set for derivative exposures (Figure 6).

84. The FX services that the financial system offers to the real economy are not unduly restricted. The effect of the measures introduced has been to raise the cost of providing services that entail systemic risks—for example, those that produce foreign exchange maturity mismatches. The measures do not entail any form of residency-based discrimination. In assessing the overall appropriateness of the policy measures that the authorities have introduced, it is therefore important to bear in mind that their intent is not to prohibit economically valuable financial sector activity.

E. Non-bank and Structural Vulnerabilities

85. Financial sector structure may give rise to ‘cross-sectional’ risk. Structural aspects of the financial system—its concentration, the balance of different types of institution, the extent of interconnections between institutions, institutions’ opacity and complexity—give rise to risks that are primarily ‘cross-sectional’, in the sense that they do not show marked cyclical variation (although of course, structures can and do change over time). In addition, there may be macroprudential risks that derive from the real economy that are not captured by Pillar I capital requirements. (Korea does not currently impose Pillar II requirements on banks.) An example of the latter is the common exposures to real estate shared by Korea’s banks (¶57).

86. The Korean financial system is modestly concentrated. Concentration in the banking system is one indication of the systemic risk posed by individual institutions. Looking across developed countries using the World Bank’s Global Financial Development database, the Korean system is relatively less concentrated than most. By their definition (based on the size of the three largest banks relative to the system), Korea ranks similarly to Japan and the UK, and well below countries such as Singapore and Finland. But in an absolute sense, Korea’s system is dominated by a few large entities. The largest four nationwide banks plus the largest two specialized banks account for 60 percent of system assets. Around 90 percent of system assets are held inside one of thirteen financial conglomerates (with or without holding group structures). Korea also has an active and growing non-bank financial sector. The number of investment companies stood at 501 in 2018 (from 315 in 2013), and the number of credit-specialized finance companies stood at 105 (from 76 in 2013).⁹⁶

87. Systemically important banks must hold additional capital buffers. The purpose of the D-SIB buffer is to protect the domestic economy from the impact that the distress or failure of a bank would cause. The FSC designated four financial groups (Shinhan FG, Hana FG, KB FG, NongHyup FG), their subsidiary banks, and Woori Bank as DSIBs for 2019. Although size is not the only criteria for D-SIB designation, the D-SIB list does cover the top five banks by size.⁹⁷ D-SIBs must meet a risk-weighted common equity tier 1 capital ratio that is 1ppt higher than other banks. The extent of the financial linkages between firms (’interconnectedness’) is one determinant of an institution’s systemic importance.

88. Network-based contagion analysis reveals the systemic importance of financial sectors. The FSAP has simulated the financial system using data on bilateral exposures between 64 individual entities. The analysis shows that, as expected, the nationwide banks are systemically significant, in the sense that failure of that sector would cause sizeable direct losses in other sectors, particularly investment firms (whose capital would be fully depleted).⁹⁸ However, the specialized banks are, as a group, about as systemic as the nationwide banks, and their default could significantly deplete the capital of the core banking system. Some banks appear to be vulnerable to the failure of investment firms.

89. Structural risks need to be carefully assessed. The existence of risks may indicate the need for additional capital to protect banks. The principal sources of structural risk appear to be as follows.

• Concentration of real estate exposures. Although real estate lending standards are in general set prudently, the exposures that individual institutions have to the market are very highly correlated. Were problems to materialize in real estate markets, attempts to unwind correlated positions would be likely to place banks, guarantee funds, and AMCs under stress.

• Opaqueness and complexity. When key aspects of the financial system are obscured due to opaque organizational structures or the inherent complexity of financial transactions, risks can develop which markets cannot price and regulators cannot mitigate. For example, the regime currently governing oversight of financial conglomerates, particularly non-holding groups (which include Samsung, Hanwha, and Kyobo), may not allow supervisors sufficient insight into the risks that businesses are running.⁹⁹ And the pursuit of returns in a low interest rate environment has seen rapid growth in complex financial products such as equity-linked securities, which may imply step-in or reputational risks for issuers.

• Structural changes due to FinTech. The FSAP’s solvency stress test has highlighted the potential for greater competition due to the entry of new technology platforms to weaken the core banking system’s resilience to stress. Should banks find that more intense competition impairs their ability to generate earnings, capital buffers may need to be widened in order that they remain resilient through periods of stress.

• Interconnectedness between banks and other financial companies. Spillovers between regulated and unregulated entities, and between banks and other financial institutions, are an important source of systemic risk. The ongoing monitoring of such connections is challenging, and although systems are in place (see ¶34), the financial network may evolve faster than can be reasonably tracked.

• Geographic concentration. Regional banks exposures are clearly concentrated in particular geographic regions. But even the nationwide banks may find themselves effectively concentrated due to the size and economic pull of the capital area.

F. Recommendations

90. The foregoing analysis of has highlighted the broad range of macroprudential tools deployed by the authorities. It has also highlighted the willingness of the authorities to develop the toolkit to meet evolving risks. The following recommendations are aimed towards ensuring that existing tools are deployed in a consistent and predictable fashion, and at closing the gaps in coverage that might remain.