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Working Paper
The Failure of supervisory stress testing: Fannie Mae, Freddie Mac, and OFHEO
In the aftermath of the global financial crisis, policymakers in the United States and elsewhere have adopted stress testing as a central tool for supervising large, complex, financial institutions and promoting financial stability. Although supervisory stress testing may confer substantial benefits, such tests are vulnerable to model risk. This paper studies the risk-based capital stress test conducted by the Office of Federal Housing Enterprise Oversight (OFHEO) for Fannie Mae and Freddie Mac, the two government-sponsored enterprises (GSEs) that are central to the U.S. housing finance ...
Working Paper
The failure of supervisory stress testing: Fannie Mae, Freddie Mac, and OFHEO
Stress testing has recently become a critical risk management and capital planning tool for large financial institutions and their supervisors around the world. However, the one prior U.S. experience tying stress test results to capital requirements was a spectacular failure: the Office of Federal Housing Enterprise Oversight's (OFHEO) risk-based capital stress test for Fannie Mae and Freddie Mac. We study a key component of OFHEO's model?30-year fixed-rate mortgage performance?and find two key problems. First, OFHEO had left the model specification and associated parameters static for the ...
Working Paper
CECL Implementation and Model Risk in Uncertain Times: An Application to Consumer Finance
I examine the challenges of economic forecasting and model misspecification errors confronted by financial institutions implementing the novel current expected credit loss (CECL) allowance methodology and its impact on model risk and bias in CECL projections. We document the increased sensitivity to model and macroeconomic forecasting error of the CECL framework with respect to the incurred loss framework that it replaces. An empirical application illustrates how to leverage simple machine learning (ML) strategies and statistical principles in the design of a nimble and flexible CECL modeling ...
Working Paper
The Impact of the Current Expected Credit Loss Standard (CECL) on the Timing and Comparability of Reserves
The new forward-looking credit loss provisioning standard, CECL, is intended to promote proactive provisioning as loan loss reserves can be conditioned on expectations of the economic cycle. We study the degree to which one modeling decision?expectations about the path of future house prices ? affects the size and timing of provisions for first-lien residential mortgage portfolios. While we find that provisions are generally less pro-cyclical compared to the current incurred loss standard, CECL may complicate the comparability of provisions across banks and time. Market participants will need ...