Establish Risk Measurement Approach

Quantifying the financial impact of physical and transition risk is critical to evaluating a portfolio’s potential exposure. From a mortgage loan perspective, loan-level and portfolio-level analyses provide both standalone and marginal views of risk.

Translating hazard risk into a view of financial loss on a mortgage instrument can be accomplished within traditional mortgage model estimations using 1) a combination of property-specific damage estimates from natural hazard and climate risk models, and 2) formulated macroeconomic scenarios guided by academic research and regulatory impacts. And because chronic effects can affect how acute risks manifest, a more nuanced view of how acute risks and chronic risks relate to one another is necessary to answer questions about financial risk.

Mortgage investors can better understand natural hazard risk measures by taking a page from how property insurers account for it. For example, the worst-case “tail loss” potential of a given portfolio is often put in context of the type of events that are at the tail of risk for the industry as a whole – in other words, a 1-in-100-year loss to the portfolio versus a loss to portfolio for a 1-in-100-year industry event. Extending this view to mortgages entails considering the type of events that could occur over the average life of a loan.

To address chronic and transition risk, selecting appropriate macroeconomic scenarios also provides a financial view of the possible impact on a mortgage portfolio. These scenarios may be grounded in published climate projections, asset-specific data collection, or different scenario narratives outlining how these risks could manifest locally.

Defining a Risk Appetite Framework

Inventorying the complete range of potential climate-related risks provides structure and organization around which risks have the largest or most severe impact and creates a framework for ranking them by appropriate criteria. A risk appetite and limit framework defines the type and quantity of natural catastrophe and climate change risk that an enterprise is willing to hold in relation to equity, assets, and other financial exposure measures at a selected probability of occurrence.  The operational usefulness of these frameworks are enhanced when defining the appetite and limits in reference to the risk measures the company selects in addition to straight notional values.

The loss exposure for a particular risk will drive operations differently across business lines based on risk preferences. From the viewpoint of mortgage activities, these operations include origination, servicing, structuring, and pricing. For instance, it may be undesirable to have more than $100 million of asset valuation at risk across the enterprise and apportion that limit to business units based upon the return of the asset in relation to the risk generated from business activity. In this way, the organization has a quantitative way for balancing business goals with risk management goals.

The framework can also target appropriate remediation and hedging strategies in light of the risk priorities. Selecting a remediation strategy requires risk reporting and monitoring across different lines of business and a knowledge of the cost and benefits attributed to physical and transition risks.

Incorporate Findings into Risk Governance

Entities can adapt policies, processes, and responsibilities in the existing ERM framework based on their quantified, prioritized, and articulated risk. This could come in the form of changes to stakeholder reporting from internal management committees, board, and board committees to external financial, investor, public, and regulatory reporting.

Because regulatory requirements and industry best practices are still being formed, it is important to continuously monitor these and ensure that policies align with evolving guidance.

Monitor and Manage Risk Within Risk Appetite and Limits

Implementation of an ERM framework with considerations for natural catastrophe and climate risk may appear different across different lines of businesses and risk management processes. For this reason, it is important that dashboards, reporting frameworks, and exposure control processes be designed to fit in with current reporting within individual lines of businesses.

A practical first step is to establish monitoring specifically to detect adverse selections issues—i.e., ensuring that you are not acquiring a book of business with disproportionately high levels of climate risk or one that adds risk to areas of existing exposure within your portfolio. The object is to manage the portfolio, so risk remains within the agreed appetite and limit framework.  This type of monitoring will become increasingly critical as other market participants start to incorporate climate risk into their own asset screening and pricing decisions. Firms that fail to monitor for climate risk will ultimately be the firms that bear it.

All of this ultimately comes down to identifying natural catastrophe and climate risks, quantifying them through property and loan-specific modeling and scenarios, ranking the risks along different criteria, and tailoring reporting to different operations in the enterprise with an eye for changing regulatory requirements and risk governance policies. An enterprise view is needed given climate risks correlate across multiple asset classes, and where it is determined that differences in risk tolerance are desired, the framework described provides a coherent and quantitative basis for differences.  Successfully negotiating these elements is more easily described than actually carried out, particularly in large financial institutions consisting of businesses with widely divergent risk tolerances.  But we appear to be reaching a point where further deferral is no longer an option. The time to begin planning and implementing these frameworks is now.