Leverage in nonbank financial intermediation

Talking to Jack Farley from the Monetary Matters podcast, FSB Secretary General John Schindler breaks down the complexities of nonbank leverage and explains what regulators are doing about it, focusing on the FSB recommendations issued in July 2025.

FSB Annual Financial Report: 2024-25

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This report contains the audited financial statements of the FSB for the 12-month period from 1 April 2024 to 31 March 2025. It also provides details on the FSB governance arrangements and its transparency and accountability mechanisms.

A detailed explanation of the activities undertaken to implement the mandate and tasks of the FSB is provided in the FSB’s Annual Report, which is published separately.

Report of the auditor to FSB Plenary on the financial statements 2024-2025

FSB Regional Consultative Group for the Commonwealth of Independent States meets in Dilijan

The Financial Stability Board (FSB) Regional Consultative Group for the Commonwealth of Independent States (RCG CIS) met on 25 July in Dilijan. The meeting was hosted by the Central Bank of Armenia, whose Deputy Governor, Armen Nurbekyan, co-chairs the Group.

This was the Group’s first meeting since 2021. Members received an update on the FSB’s work programme and explored ways to support its initiatives, with a particular focus on the G20 Roadmap to enhance cross-border payments and the FSB’s Global Regulatory Framework for Crypto-asset Activities.

Members also discussed crisis preparedness, resolution planning, and strategies to promote cross-border cooperation and information sharing within the region during crises.

Andrew Bailey sets his priorities as FSB Chair

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  • In his first letter to G20 Finance Ministers and Central Bank Governors as FSB Chair, Andrew Bailey stresses the importance of international coordination on financial regulation against the backdrop of geopolitical tensions.
  • Mr Bailey highlights his priorities for the FSB, namely enhancing surveillance capabilities, addressing key risks to financial stability, and strengthening the effectiveness of the FSB.
  • He also presents the latest report on the FSB’s climate roadmap, which sets out for the G20 that the focus of the FSB climate work in the medium term will be international coordination, information sharing, and strengthening the analysis of the potential for climate-related financial vulnerabilities.

The Financial Stability Board (FSB) today published a letter from its Chair, Andrew Bailey, to G20 Finance Ministers and Central Bank Governors ahead of their meeting on 17-18 July.

In his first letter as FSB Chair, Mr Bailey calls for continued global cooperation and engagement, particularly against the backdrop of geopolitical tensions and rising fragmentation risk.

Mr Bailey outlines his priorities for the FSB, notably:

  • Enhancing surveillance capabilities: the FSB and national authorities’ assessment tools and surveillance capabilities must adapt to the evolving financial system to detect vulnerabilities and allow a targeted, evidence-based response to risks. As part of this, the FSB is to set out concisely – and publish – its assessments of vulnerabilities.
  • Addressing key risks to financial stability: alongside giving more focus to existing initiatives such as the G20 cross-border payments roadmap, the FSB will: (i) support robust implementation of agreed policies on Nonbank Financial Intermediation (NBFI); (ii) explore vulnerabilities from the growing role of private finance; (iii) assess the increasing role of stablecoins for payment and settlement purposes.
  • Strengthening the effectiveness of the FSB: the G20 Implementation Monitoring Review will be the starting point for considering possible improvements in the FSB effectiveness, not just with regard to the implementation of agreed standards, but also in other areas such as communicating with stakeholders outside of its membership.

The letter covers three reports the FSB is delivering to the G20: (i) the FSB’s policy recommendations to address financial stability risks created by leverage in nonbank financial intermediation, (ii) a workplan to address challenges related to nonbank data – both of which were published last week; and (iii) a report updating on work conducted under the FSB Climate roadmap and outlining the FSB’s medium-term approach to potential climate-related financial risks, delivered together with the Chair’s letter.

Notes to editors

The FSB coordinates at the international level the work of national financial authorities and international standard-setting bodies and develops and promotes the implementation of effective regulatory, supervisory, and other financial sector policies in the interest of financial stability. It brings together national authorities responsible for financial stability in 24 countries and jurisdictions, international financial institutions, sector-specific international groupings of regulators and supervisors, and committees of central bank experts. The FSB also conducts outreach with approximately 70 other jurisdictions through its six Regional Consultative Groups.

The FSB is chaired by Andrew Bailey, Governor of the Bank of England. The FSB Secretariat is located in Basel, Switzerland and hosted by the Bank for International Settlements.

FSB Chair’s letter to G20 Finance Ministers and Central Bank Governors: July 2025

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New FSB Chair Andrew Bailey tells G20 in Durban that international coordination is more important than ever.

This letter was submitted to G20 Finance Ministers and Central Bank Governors (FMCBG) ahead of the G20’s meeting on 17-18 July 2025.

Having taken up the role of FSB Chair on 1 July 2025, Andrew Bailey sets his priorities for the FSB, notably:

  • Enhancing surveillance capabilities;
  • Addressing key risks to financial stability;
  • Strengthening the effectiveness of the FSB.

The letter advises the G20 of the full range of FSB activities, which includes work to improve the data used by authorities to monitor vulnerabilities, promoting better cross border payment services, analysing potential climate-related impacts on the financial system and tackling the destabilising impacts that leverage can have on the financial system.

The letter underlines the need to remain vigilant to the risk of disruptive market moves as uncertainty continues to weigh on growth expectations. Mr Bailey calls for continued global cooperation and engagement against the backdrop of geopolitical tensions and rising fragmentation risk, and expresses his commitment to upholding the FSB’s mission and strengthen the resilience of the global financial system.

FSB Roadmap for Addressing Financial Risks from Climate Change: 2025 update

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This report to the G20 emphasises the importance of comprehensive, reliable, granular, consistent and comparable information on climate-related financial risks

This report was delivered to the July 2025 meeting of G20 Finance Ministers and Central Bank Governors. It provides a factual update on the work undertaken by the FSB, standard-setting bodies and other international organisations in the four areas identified by the 2021 Roadmap for Addressing Climate-related Financial Risks: firms’ disclosures; data; vulnerabilities analysis; and regulatory and supervisory practices and tools.

At the request of the South African G20 Presidency, the report also provides an outline of the FSB’s medium-term approach to potential climate-related financial risks, identifying the following areas for FSB work: coordination of international efforts, information sharing, vulnerabilities analysis, external engagement.  As part of their annual work programme discussions, FSB members will continue to evaluate how the analysis of topics, such as physical risks and gaps in insurance coverage, may contribute to a better understanding of financial stability risks.

FSB Chair’s speech at the launch event for the FSB’s final report on leverage in nonbank financial intermediation (NBFI)

Opening remarks by the Chair of the FSB, Andrew Bailey, at the launch event for the leverage in NBFI report, hosted by the Bank of England, 9 July 2025

The views expressed in these remarks are those of the speaker in his role as Chair of the FSB and do not necessarily reflect those of the FSB or its members.

It is a great pleasure to host the launch event for the Financial Stability Board’s NBFI leverage report at the Bank of England, in my capacity as Chair of the FSB. This report is the latest example of the FSB’s vital role in our global financial system: bringing together the expertise of policymakers across the world to enhance financial stability.

Before I begin, I must extend my sincere thanks to my predecessor, Klaas Knot, for his exceptional leadership as FSB Chair during a term beset by shocks and uncertainty. Klaas took on this role during the Covid pandemic, when authorities still working to safeguard the financial system against the vulnerabilities revealed during the Global Financial Crisis (GFC) had to work quicky – and together – to manage an unprecedented global shock.  His dedication was instrumental in ensuring a globally coordinated response, based on the principle – one of several agreed early on by the FSB membership – not to roll back reforms or compromise the objectives of existing international standards. That response spanned numerous areas of the FSB’s work, from banking reforms to crypto regulation, from assessing financial stability impacts of climate to operational resilience. It also included a significant programme of work focused on non-banks.

I will focus on non-banks.

Today, we are publishing recommendations for managing risks related to non-bank leverage. We have the co-chairs of the working group Cornelia Holthausen and Sarah Pritchard to thank for their outstanding leadership in overseeing the production of these recommendations.

Non-bank leverage is very much in focus for regulators and policymakers. And rightly so. Over the past decade, we’ve seen significant changes in the structure of markets, and the increasing role of non-banks. While leverage can bring benefits, we’ve seen repeatedly how excessive and poorly managed leverage can threaten financial stability.

I will also offer my view on what we as policymakers—and the FSB as an institution—need to do to ensure we have the right tools to stay one step ahead in a fast-changing financial landscape.

How did we get to the publication of this NBFI leverage report today?

Over the past 10 to 15 years, the structure of financial markets has changed significantly. After the GFC, there was a deliberate shift to move riskier activities out of the banking sector. This made sense: certain forms of risk-taking are not well-suited to back deposits – doing so could endanger depositors’ funds. These activities are better supported by investment capital, and therefore more appropriately housed in non-banks.

As a result, the non-bank sector has grown substantially. Today, it accounts for around half of global financial system assets. Investment fund assets have expanded globally from roughly $21 trillion in 2008 to $52 trillion in 2023.

This shift has not only changed the size of this sector; it has reshaped how the financial system functions. Much of the activity in core financial markets, and the associated vulnerabilities, now reside outside the banking system. Reliance on non-banks for credit intermediation and liquidity provision has increased. At the same time, business models have become more complex, global, and interconnected—and in some cases, less transparent to regulators and the market.

If not properly managed, these features can lead to sharp spikes in liquidity demand that can outpace supply, procyclicality, fire sales, and sudden jumps to illiquidity. The growing interconnectedness and correlated activity among diverse market participants mean that stress in one part of the system can quickly propagate to others.

To be clear, these changes are not inherently negative. They bring important benefits, like more efficient markets, better price discovery, and broader access to finance for the real economy. But they introduce vulnerabilities – like concentrated, correlated, often opaque positions that cascade through the system to core markets and core institutions – that must be carefully managed to ensure the stability required to support growth and innovation, even under stress.

We saw these vulnerabilities crystalise in 2020. During the onset of the Covid pandemic, global financial markets experienced severe stress in an episode commonly known as the “dash for cash”. The non-bank sector exhibited significant vulnerabilities and signs of a liquidity crisis.

We saw significant outflows from money market and open-ended funds. For example, non-government money market funds saw outflows of 11% to 25%, depending on type and currency. US corporate bond funds experienced weekly outflows of around 5% of assets under management—$109 billion—until central banks stepped in.

We saw the rapid redistribution of liquidity due to margin calls and material dislocations in key government bond markets. The spike in demand for the most liquid and safe assets led to a decoupling between the price of US Treasuries and their futures.

We saw the role that leverage could play in amplifying stress. Hedge funds were forced to unwind $90 billion of their so-called “basis trade” positions as they became largely loss making, contributing to extreme illiquidity in government bond markets.

Public authorities had to intervene in unprecedented ways to prevent further market dysfunction and strain on the real economy.

Since then, we’ve seen further stress episodes highlighting non-bank vulnerabilities. For example: the failure of Archegos, volatility in commodities markets following Russia’s invasion of Ukraine and in UK government bond markets during the LDI crisis, and stress in US Treasury markets in March 2023. In some cases, major public interventions were required to prevent broader economic fallout. In others, we had near misses – including in April this year.

In response to the dash for cash in 2020, the FSB – under Randy Quarles’ leadership – developed a multi-year work programme to assess and address vulnerabilities in the NBFI sector. The goals were clear: reduce excessive spikes in liquidity demand, enhance the resilience of liquidity supply during stress, and improve risk monitoring and preparedness among authorities and market participants.

Developing a policy response to vulnerabilities identified under this work programme has rightly been a priority for the FSB, and for me, as Chair of the FSB’s Standing Committee on Supervisory and Regulatory Cooperation. The case for these priorities has only strengthened as each new stress has hit.

Five years into this programme, we are seeing real progress.

In response to severe liquidity mismatches in money market funds and limited use of liquidity management tools in open-ended funds, the FSB published a new policy framework for MMFs and revised its OEF recommendations in collaboration with IOSCO.

The FSB, BCBS, CPMI, and IOSCO have also issued policies, best practices, and recommendations to improve margining practices and strengthen market participants’ preparedness to meet margin calls.

These are significant achievements.

But, they mean little if jurisdictions do not implement them. As time passes and memories of past crises fade, so does the urgency to implement reforms. But we would be misleading ourselves and the public if we thought these issues have been solved, simply because they haven’t flared up recently. Relying on the past not repeating itself is not a strategy. The global financial system requires sustained vigilance and intervention.    

The NBFI Leverage Report published today marks another major policy reform.

It presents nine policy recommendations to address financial stability vulnerabilities from leverage in non-banks, particularly those in core markets and those arising through interlinkages between leveraged nonbanks and systemically important financial institutions. It provides authorities with a comprehensive toolkit to put in place a domestic framework to identify and monitor financial stability vulnerabilities from NBFI leverage and to take steps to design and calibrate policy measures, or combinations of measures, to contain NBFI leverage where it may give rise to those financial stability risks.

And the report could not be timelier.

Hedge funds and other leveraged investors are growing their positions in sovereign bond markets. This is a global phenomenon, driven in part by increased issuance and changes in investor demand.

In the US, hedge fund exposure to Treasury markets has grown rapidly and now stands at $1.8 trillion long and $1.4 trillion short—close to record highs. In Canada, hedge funds now account for roughly 40% of auction value in Canadian sovereign markets. In the euro area, hedge funds are increasing their derivatives exposures. In the UK, hedge fund net repo borrowing is at its highest since data collection began in 2016, with seven funds accounting for 90% of that.

The growth of leveraged strategies, along with concentration, and crowded positions in certain markets, is concerning. These trends can amplify shocks and impact liquidity. The global nature of leveraged NBFIs and their interconnection with financial markets means that shocks in one jurisdiction can easily spill over to another.

Implementing the report’s recommendations is therefore critical. The recommendations have been designed to allow for flexibility in terms of implementation. That said, international cooperation and coordination in policy design and implementation are essential given the high cross-border interconnection and potential for spill-over risks.

I said I would come back to what we as policy makers must do to ensure we have the right tools to stay one step ahead in a changing world.

Two challenges stand out.

First, in today’s uncertain environment, strengthening our ability to anticipate and assess vulnerabilities is more important than ever. Surveillance enables us not only to identify risks but to respond with targeted, evidence-based action. The FSB, with its unique cross-border vantage point, has a vital role to play in facilitating global financial stability surveillance. So both the FSB and national authorities must have robust, forward-looking toolkits to identify existing and emerging vulnerabilities across the financial system that allow us to take steps to mitigate them before they crystalise and propagate through the financial system. And showing the results of our surveillance can help participants better manage their risks too. The financial system has evolved significantly, and our assessment tools must evolve with it. 

Data are one area where we are already leveraging international cooperation to make progress. A key obstacle to better surveillance is the persistent lack of timely, risk-focused data in non-banks, particularly around leverage, concentration, correlation, and crowded trades in core markets.

This is not a domestic issue. In some jurisdictions data gaps stem from the cross-border nature of sovereign bond markets and the absence of comprehensive data covering all market participants. So the FSB has launched a Task Force to address these data gaps and enable authorities to better identify vulnerabilities in financial markets.

Second, we must ensure that the policies we’ve agreed at the international level are fully and effectively implemented domestically.

This is especially important in a world where attitudes toward regulation are shifting, and growth is a priority. I want to underscore that sustainable growth requires a resilient financial system – there is no trade-off between financial stability and growth.

Effective implementation is essential to strengthening the stability of the financial system—especially in today’s uncertain and fragmented global environment. It enables a level playing field on which cross-border firms can operate, helping to guard against regulatory arbitrage and market fragmentation which can arise when reforms are applied inconsistently across jurisdictions.

International coordination is therefore critical—not just in designing and calibrating reforms, but in putting them into practice. While some progress has been made, implementation has been slow in some areas. For other NBFI reforms, it is still early days.

During my term as Chair, I will focus on driving progress in both of these areas.

Leverage in Nonbank Financial Intermediation: Final report

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Leverage in NBFI can be an important amplifier of stress. If not properly managed, it can create risks to financial stability.

This report addresses financial stability risks created by nonbank financial intermediation (NBFI) leverage, focusing on two key areas:

  1. risks that may arise in financial markets that are critical to the functioning of the financial system and the real economy;
  2. risks that may arise through interlinkages between leveraged nonbanks and systemically important financial institutions that act as leverage providers. 

Building on the policy steps already taken by authorities and the work done by the standard-setting bodies (SSBs), the report sets out an integrated approach for addressing NBFI leverage risks. Authorities are recommended to:

  • select, design and calibrate policy measures, or combinations of measures, that address the financial stability risks identified in a flexible, targeted and proportionate way.
  • have a domestic framework in place to identify and monitor financial stability risks created by NBFI leverage in an effective, frequent, timely and proportionate manner;

The recommendations reflect public feedback received on a consultative version of the report, which the FSB published in December 2024. They are structured around the following areas:

  • risk identification and monitoring (Recommendations 1-3);
  • addressing NBFI leverage in core financial markets (Recommendations 4-5);
  • counterparty credit risk management (Recommendations 6-7);
  • addressing incongruencies in regulatory treatment (Recommendation 8);
  • cross-border cooperation (Recommendation 9)

The report concludes with a set of general principles to help guide authorities in selecting, designing, and calibrating policy measures.

International cooperation on the implementation of the policy measures is critical to mitigate cross-border spillovers and avoid regulatory arbitrage. The FSB and SSBs will undertake further work to support and assist authorities in applying the recommendations.

FSB Recommendations to address the financial stability risks from leverage in NBFI

The FSB recommendations set out an integrated approach, according to which authorities should identify financial stability risks created by NBFI leverage and have appropriate policy measures in place to address the risks that they identify.

Recommendations relate to risk identification and monitoring. Authorities should:

  1. Have a domestic framework to identify and monitor in an effective, frequent, timely, and proportionate manner, the financial stability risks created by NBFI leverage.
  2. Assess and seek to address data challenges in their domestic risk identification and monitoring framework, and collaborate, where appropriate, with foreign authorities to reduce those challenges that may hinder effective cross-border risk identification and monitoring, including by promoting better data and information sharing.
  3. Review the granularity, frequency, and timeliness of existing public disclosures and determine the degree to which additional or enhanced disclosures should be provided to the public.

Recommendations relate to NBFI leverage in core financial markets. Authorities should:

  1. Take steps to address the financial stability risks created by NBFI leverage that they identify in their core financial markets.
  2. Consider those measures that are most appropriate to address the risks that they identify, including both activity- and entity-based measures, as well as concentration-related measures. In doing so, authorities should conduct appropriate analysis when selecting, designing and calibrating policy measures, to mitigate any unintended consequences.

Recommendations relate to counterparty credit risk management. Authorities should:

  1. Ensure the timely and thorough implementation of the BCBS’s guidelines on counterparty credit risk for bank leverage providers, which represent an important element of a comprehensive policy response to financial stability risks created by NBFI leverage.
  2. Review the adequacy of existing counterparty disclosure practices made privately between leveraged nonbanks and leverage providers and consider developing, in partnership with industry, mechanisms, standards and/or guidelines to enhance the effectiveness of these disclosure practices. 

In instances where various forms of NBFI leverage provision are subject to incongruent regulatory treatments which may result in regulatory arbitrage that can increase financial stability risks. Authorities should:

  1. determine whether and how to address the identified incongruences, having regard to the treatment of similar situations in other jurisdictions.

The last recommendation emphasises the importance of cross-border cooperation. Authorities should:

  1.  engage proactively with their peers to facilitate coordinated crisis and/or policy responses, to the extent legally and operationally feasible.

FSB Workplan to Address Nonbank Data Challenges

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Addressing data challenges is vital to the success of the FSB work programme aimed at building resilience in nonbank financial intermediation.

Taking forward the FSB’s work programme to enhance the monitoring of vulnerabilities in the nonbank sectors and to develop policy recommendations to address the associated financial stability risks depends heavily on reliable data.

In the course of its work, the FSB has identified several data challenges that have hindered the effective assessment of nonbank sector vulnerabilities by authorities.

Given the complexity and importance of ongoing data challenges, the FSB has set up a small, high-level task force: the Nonbank Data Task Force (NDTF). The NDTF, which is chaired by Andrew Bailey, Governor of the Bank of England and FSB Chair, has three objectives:

  1. Improve the ability of FSB member authorities to identify and assess vulnerabilities stemming from nonbank sectors.
  2. Improve the ability of authorities to assess and calibrate policies that could be used to mitigate financial stability vulnerabilities that stem from nonbank sectors.
  3. Explore whether and how authorities could share information (including data) when such sharing could be used to mitigate significant threats to financial stability.
NDTF Workplan

To test how much progress can be made in addressing various nonbank data challenges, the FSB has decided to conduct a test case on “leveraged trading strategies in sovereign bond markets”.

This report, delivered at the request of the G20, presents a plan for how the work on nonbank data challenges will be structured. The FSB intends to finalise a report on the selected test case by mid-2026, which should include ways to address data challenges. Based on the findings and insights from the work of the test case, the FSB will determine whether further work should be undertaken in other areas.