Provision of a general nature III/2022

of 15 September 2022

on setting the countercyclical capital buffer rate for the Czech Republic No. III/2022

Pursuant to Article 12o(5) of Act No. 21/1992 Coll., on Banks, as amended by Act No. 375/2015 Coll., (hereinafter referred to as the “Act on Banks”) and Article 8al(5) of Act No. 87/1995 Coll., on Credit Unions and Certain Related Measures and on the Amendment of Czech National Council Act No. 586/1992 Coll., on Income Taxes, as amended, as amended by Act No. 375/2015 Coll. (hereinafter referred to as the “Act on Credit Unions”), the Czech National Bank as a competent administrative body hereby issues the following provision of a general nature:

1. Pursuant to Article 12o(3) of the Act on Banks and Article 8al(3) of the Act on Credit Unions, the countercyclical capital buffer rate for the Czech Republic shall be set at 2.50% of the total risk exposure amount pursuant to Article 92(3) of Regulation (EU) No. 575/2013 of the European Parliament and of the Council.
2. Banks and credit unions shall apply the rate referred to in point I for the purposes of calculating the combined buffer requirement as from 1 October 2023.

Justification

1. Pursuant to Article 12o(3) of the Act on Banks and Article 8al(3) of the Act on Credit Unions, the Czech National Bank (hereinafter referred to as the “CNB”) shall set the countercyclical capital buffer rate for the Czech Republic, taking into account the countercyclical capital buffer guide calculated pursuant to Article 12o(1) and (2) of the Act on Banks and Article 8al(1) and (2) of the Act on Credit Unions, the recommendations issued by the European Systemic Risk Board (hereinafter referred to as the “ESRB”) and indicators which may imply growth in systemic risk.
2. Pursuant to Article 12o(1) of the Act on Banks, Article 8al(1) of the Act on Credit Unions and Article 9al(1) of the Capital Market Undertakings Act, the calculation of the buffer guide is based on the deviation of the credit-to-GDP ratio from its long-term trend – the credit-to-GDP gap. The credit-to-GDP ratio was 85.8% and the relevant deviation from the long-term trend -6.0 percentage points in 2022 Q1.^[1] This value pursuant to Article 12o(1) of the Act on Banks and Article 8al(1) of the Act on Credit Unions corresponds to a benchmark countercyclical capital buffer rate of 0%. The additional gap,^[2] which is based on the ESRB Recommendation (section B, Article 2) and better reflects the specificities of the Czech economy, was 2.3 percentage points in 2022 Q1 and implies a benchmark rate of 0.25%.
3. In reaction to the ESRB recommendation, the CNB has repeatedly emphasised in its publications (particularly the Financial Stability Report) that it does not regard the size of the gaps referred to in paragraph 2 as a reliable guide for determining the position of the domestic economy in the financial cycle and setting the rate. The CNB prefers an approach based on a comprehensive assessment of indicators identifying growth in systemic risks under Article 12o(3) of the Act on Banks and Article 8al(3) of the Act on Credit Unions.^[3]
4. The value of the financial cycle indicator (FCI) increased in year-on-year comparison in 2022 Q1 but recorded a decline in quarter-on-quarter terms due to a drop in the correlation between the individual manifestations of the financial cycle. However, the theoretical FCI value (abstracting from the strength of the correlation) increased further due to a high volume of new housing loans and related growth in property prices and was the highest since 2009. The strong property price growth accompanied by growth in interest rates on house purchase loans led to a rise in the estimated overvaluation of apartment prices for the median household to above 40%. According to the CNB’s estimate, the overvaluation of investment apartments also exceeded 40% and was the highest in history. The growth in property prices and new loans to households for house purchase started to show signs of slowing in the first half of 2022. However, this has so far been reflected in the total growth of the stock of loans to only a limited extent. The year-on-year growth in loans in the main credit segments remained above average from both the medium and long-term perspective.^[4] This thus led to a continued build-up of cyclical risks in the banking sector’s balance sheet despite considerably slower taking on of new risks. Exceptionally low provisioning and a drop in the ratio of provisions to total loans meanwhile indicate that the banking sector may be insufficiently prudent in assessing the accumulated risks. Lowered risk weights in the loan portfolios of banks applying the IRB approach also remain a source of systemic risk. A deterioration in risk parameters as a result of significantly adverse cyclical effects would lead to a rise in risk weights and indirectly also in the capital requirement in absolute terms. This rise, coupled with unexpected cyclical credit losses, should also be covered by the countercyclical capital buffer. The capital needed to cover the fall in the capital ratio as a result of the potential cyclical rise in risk weights amounts to around CZK 38.9 billion according to the CNB’s estimates and, together with the volume of unexpected cyclical credit losses of CZK 20.5 billion, implies a need for additional capital of CZK 59.4 billion. This need would be fully covered by a countercyclical buffer rate of 2.25%. However, the escalation of the Russia–Ukraine conflict and the increased geopolitical and economic uncertainty associated with future developments is creating potential for faster and more substantial materialisation of cyclical risks than the baseline estimate assumes. For these reasons, the CNB is applying a higher degree of prudence in its approach to setting the buffer rate.
5. Based on the above assessment, and taking into account the potential consequences of Russia’s aggression towards Ukraine on the extent and speed of materialisation of cyclical risks, the CNB Bank Board has decided to set the countercyclical capital buffer rate at 2.50%, which is the level necessary to ensure that the banking sector is resilient to these risks. Should the economic situation worsen significantly and significant unexpected credit losses form in the domestic banking sector, the CNB is ready to lower the buffer rate or release the buffer fully in order to support banks’ ability to provide credit to the real economy without interruption.
6. Pursuant to Article 12x(1) of the Act on Bank and Article 8au(1) of the Act on Credit Unions, this provision of a general nature is announced only in a manner facilitating remote access and takes effect on the day of its publication.

Effect

This Provision shall take effect on 15 September 2022.

This provision of a general nature was published on 15 September 2022.

^[1] In accordance with ESRB Recommendation 2014/1 (Recommendation of the European Systemic Risk Board of 18 June 2014 on guidance for setting countercyclical buffer rates), total credit means the value of all loans provided to the private sector (non-financial corporations, households and non-profit institutions serving households) plus the volume of bonds issued by the domestic private sector. The time series of 1995 Q1–2022 Q1 and the Hodrick-Prescott filter with a smoothing parameter (λ) of 400,000 are used to calculate the long-term trend of the credit-to-GDP ratio.

^[2] The additional gap – the expansionary credit gap – is calculated as the difference between the current ratio of bank loans to gross value added of the private non-financial sector and the minimum level of this ratio achieved in the past eight quarters.

^[3] The methodological framework of the Czech National Bank for setting the countercyclical buffer rate is presented in the document The CNB’s approach to setting the countercyclical capital buffer.

^[4] The annual growth rates of bank loans provided to households for house purchase and for consumption were 10.6% and 9.3% respectively in June 2022. Bank loans to non-financial corporations increased by 9.8% year on year in June 2022.