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If Regulators Are Going to Model Systemic Risk, They Should Publish the Model

Supervisors are making consequential claims about contagion channels on the basis of work nobody outside the building can check.

Senior Policy Editor1 min read

Financial stability boards have spent two years producing assessments of digital asset contagion risk. The conclusions are cited in consultation papers, quoted in speeches, and increasingly used to justify capital treatment. The underlying models are almost never published.

This is not a demand for source code. It is a request for the assumptions: which exposures are treated as correlated, what haircut is applied to stablecoin reserves under stress, and how a bank's indirect exposure through a custodian is counted.

Central banks publish stress test methodologies for the banking book precisely because the credibility of the exercise depends on it. Applying a lower standard here suggests either that the work would not survive scrutiny or that the conclusions preceded it.

Industry has an obvious self-interest in making this argument, which is why it should be made carefully and without exaggeration. The point is not that supervisors are wrong. It is that on present evidence nobody can tell.

This column reflects the author's views and is labelled Opinion under MyBunnyFarm's editorial policy.

  • regulation
  • opinion
  • systemic risk
  • transparency

About the author

Julian Thorne Julian Thorne leads MyBunnyFarm's coverage of financial regulation, central bank digital currency programmes and cross-border enforcement. He has covered European financial rulemaking for eleven years, including the full passage of MiCA, and reads consultation papers so readers do not have to.

Senior Policy Editor · Brussels, Belgium · More from Julian Thorne

Corrections to this report: corrections desk. Nothing in this article is investment advice.

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