IMF Publishes Report on the 2018 Article IV Consultation with Germany
IMF published its staff report under the 2018 Article IV consultation with Germany. Directors noted that profitability in the bank and life insurance sectors remains low and that restructuring efforts must be accelerated to durably strengthen resilience and reduce risks. They stressed the importance of continued supervisory attention to progress in implementing restructuring plans and reducing interest rate risk in banking and insurance.
The staff report highlights that completion of Basel III, as well as other recent regulatory changes, may have important implications for large German banks. After a long period of favorable economic conditions, banks’ internal risk models may underestimate risk-weights. The introduction of the 72.5% output floor is aimed to limit the effects of sharp re-assessments of risks on bank capital. As the use of internal models is more pervasive in large banks, this measure will affect mostly this group. In addition, the report highlighted that the Markets in Financial Instruments Directive (MiFiD II), which came into force in January 2018, aims to increase transparency and efficiency in financial trading, but may also add regulatory compliance costs in the larger banks. Furthermore, the 2017 minimum requirement for own funds and eligible liabilities (MREL) policy of EU sets targets that are binding only for larger/more complex banks in the Single Resolution Board remit, while smaller and medium-size institutions are not yet affected. Few banks are expected to face funding shortfalls to meet MREL target and subordination requirements are facilitated by recent changes to the German Banking Act.
In the banking sector, the regulatory capital ratio has increased, but the cost-to-income ratio and leverage remain high. Risk-weighted capital stood at comfortable levels, supported by favorable macroeconomic conditions and declining risk-weighted asset density, and is improving for all categories, except large banks. Non-performing loans (NPLs) continue to decline and provisioning for impaired shipping loans is leveling off. As noted in the 2016 Financial Sector Assessment Program (FSAP), international experience suggests that macro-prudential tools should be deployed early to be most effective. It is therefore important that the macro-prudential framework is sufficiently nimble such that instruments can be utilized preventively to avoid the build-up of vulnerabilities. The macro-prudential toolkit should be strengthened. New tools—loan to value (LTV) caps and amortization requirements—were legally created in 2017, a welcome development. However, income-based instruments, such as the debt-to-income ratio and the debt-service-to income ratio, are not included in the legislation. These tools, which can help prevent an excessive build-up of debt by households when house prices are rising rapidly, should be added.
Large German banks continue to underperform relative to the European peers. To keep up with cost-reduction targets, the German global systemically important bank (G-SIB) presented an updated restructuring strategy to refocus activities in Europe and reduce personnel costs by shrinking its investment banking business. Overall, the financial market stress is assessed to be low, capital buffers in the banking and life insurance sectors are deemed comfortable. Nevertheless, accelerating restructuring, restoring profitability, and reducing interest rate risk remain the key priorities in the banking and life insurance sectors. Continued supervisory attention to interest rate risk and implementation of restructuring plans, including through Pillar 2 measures, remains essential. The report also reveals that low interest rates and the introduction of Solvency II are forcing some restructuring in the life insurance sector. Solvency ratios, according to Solvency II, have improved overall, alongside the increase in long-term yields, since late 2016. However, a majority (nearly 70%) of life insurers rely on transitional measures to calculate their solvency capital requirement. As was noted in the Bundesbank’s 2017 Financial Stability Report, 14 life insurers would not meet the Solvency II minimum requirement as of end of 2016 without transition measures.
Related Link: Staff Report
Keywords: Europe, Germany, Banking, Insurance, Securities, Solvency II, Basel III, MiFID II, NPLs, Restructuring, IMF
Featured Experts

María Cañamero
Skilled market researcher; growth strategist; successful go-to-market campaign developer

Adam Koursaris
Asset and liability management expert; capable modeler; risk and capital specialist

Pierre-Etienne Chabanel
Brings expertise in technology and software solutions around banking regulation, whether deployed on-premises or in the cloud.
Previous Article
FSB Issues Second Consultation on UPI Governance ArrangementsRelated Articles
EC Adopts Financial Reporting Changes Arising from Benchmark Reforms
EC published Regulation 2021/25 that addresses amendments related to the financial reporting consequences of replacement of the existing interest rate benchmarks with alternative reference rates.
BIS Bulletin Examines Key Elements of Policy Response to Cyber Risk
BIS published a bulletin, or a note, that examines the cyber threat landscape in the context of the pandemic and discusses policies to reduce risks to financial stability.
HMT Updates List of Post-Brexit Equivalence Decisions in UK
HM Treasury, also known as HMT, has updated the table containing the list of the equivalence decisions that came into effect in UK at the end of the transition period of its withdrawal from EU.
EBA Issues Erratum for Technical Package on Reporting Framework 3.0
EBA published an erratum for technical package on phase 1 of the reporting framework 3.0.
APRA Publishes FAQ on Measurement of Credit Risk Weighted Assets
APRA updated a frequently asked question (FAQ), for authorized deposit-taking institutions, on the measurement of credit risk weighted assets.
EBA Publishes Risk Dashboard for Third Quarter of 2020
EBA published the quarterly risk dashboard, along with the results of the Risk Assessment Questionnaire survey among 60 banks and 15 market analysts.
ECB Analysis Shows Privacy as Biggest Concern in Use of Digital Euro
ECB concluded the public consultation on the introduction of a digital euro in EU.
ECB Finalizes Guide on Supervisory Approach to Bank Consolidation
ECB published a guide that sets out the supervisory approach to consolidation in the banking sector.
SRB Chair Outlines Work Priorities for 2021
The SRB Chair Elke König published an article setting out work priorities for 2021.
FDIC Selects Companies to Compete in Final Phase of Tech Sprint
FDIC has selected 11 technology companies—including BearingPoint, Fed Reporter, Inc, and S&P Global Market Intelligence, LLC—for inclusion in the third and final phase of the rapid prototyping competition.