medium · FRM Part 2 Operational Risk

A regulator is debating between using the Credit-to-GDP gap or a 'Credit Growth' metric as the primary CCyB guide.

What is a key advantage of the Gap over the Growth metric?

  1. The Gap is a point-in-time (PIT) leverage snapshot, whereas the Growth metric is inherently a through-the-cycle (TTC), backward-smoothed indicator by design.
  2. The Gap deliberately ignores shadow banking flows entirely, which greatly simplifies data collection burdens for regulators lacking granular reporting.
  3. The Gap is easier and faster to calculate since it skips the need for an HP filter or any long historical trend estimation step.
  4. The Gap normalizes credit levels by the size of the economy, preventing a high-growth but low-leverage economy from triggering the buffer prematurely.

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