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Opinions are divided whether or not a Greek debt restructuring would undermine the financial stability of the euro area. Decision makers have therefore preferred to commit tax payers’ money but recent electoral outcomes show the limits to such a strategy. This column argues that the ESRB should make an assessment of the systemic implications of a Greek debt restructuring. First, the ESRB is the institution with the best access to data needed to undertake such as assessment. Second, it has the legal mandate and obligation to warn about and mitigate systemic risk. In the absence of a warning, EU decision makers should move ahead with restructuring if necessary as it would not jeopardize the financial stability of the euro area.

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With the continuing deterioration of Greek public debt, the debate about restructuring has become heated. Among the most vocal opponents of a restructuring, ECB’s board member Bini Smaghi has argued that a restructuring would severely undermine the stability of the Greek banking system and euro area financial stability as a whole. He may be right. Others, however, have pointed to the low exposure of German and French banks to Greek debt. Even the Greek banking system could be restructured and be taken over by foreign banks. Moreover, they dismiss the idea that a restructuring would lead to contagion beyond the countries that are already under EU/IMF assistance. Hence they argue that a sovereign restructuring is manageable and would not be comparable to a second “Lehman Brothers”.

Given this uncertainty in the assessment of what a restructuring of debt with private sector involvement means, European decision makers have so far erred on the side of caution, preferring to commit significant amounts of tax payers’ money. However, the election success of the True Finns has shown that such a policy has limits. We therefore urgently need a thorough assessment of the systemic implications of a Greek debt restructuring.

The ESRB is the institution uniquely placed to make such an assessment. First, it has probably the best access to the kind of data needed to make such an assessment. The ECB - providing a large part of the infrastructure of the ESRB - knows which banks use Greek bonds as collateral for the open market operations and should therefore have a good picture of exposure to Greek bonds. The ECB should also have fairly detailed information on the interbank market, from which contagion across banks can be assessed. Last but not least, the ESRB has the legal authority to request data from the national and European supervisors needed for such an assessment.  The assessment would obviously have to take into account the possible contagion effects.

Second, the ESRB is the European institution with the legal mandate to warn and provide recommendations to prevent or mitigate systemic risk. In fact, according to the Regulation, once the ESRB detects risk which “could seriously jeopardize the orderly functioning” of the Union’s financial system, it “should promptly inform the Council of the situation.” A warning from the ESRB that a Greek debt restructuring undermines the stability of the financial system of the EU would enjoy great credibility since its General Board includes among its members central bank governors, national supervisors and the chairs of the European Supervisory Authorities. To further increase the credibility of the warning, the ESRB could choose to publish its warning. Publication would also help convincing voters that a bail-out is in their own best interest if, indeed, a systemic risk exists.

Conversely, in the absence of a warning from the ESRB, EU decision makers as well as voters should rightly assume that a restructuring would not constitute a systemic risk and would not undermine the financial stability of the euro area. They could then confidently move to the task of involving the private sector in the restructuring.

How likely is it that the ESRB would deviate from the current opinion of the ECB? The ESRB is of course dominated by central bankers and might therefore be similarly risk averse as the ECB. However, in the ESRB all 27 central bank governors are present. Already now, one can see substantial differences in the assessment of some of the central banks of the euro zone. As regards the central banks outside the euro area, little is known to date as regards their opinion on the issue. Moreover, one should not underestimate the importance of the other members of the board, including the non-voting members, who will voice their opinion.

At the end of the day, the decision will crucially depend on how convincing the analysis prepared by the ESRB staff will be.  Different degrees of risk aversion will only play a role if the analysis does not allow for a clear decision. In that case, the ESRB may opt to be risk averse, not least because it will fear to lose a reputation as a young institution.

The second half of 2011 would be the right time to undertake the assessment. Greece was put under the program as it was feared that without it the financial stability of the euro area could be jeopardized and it was assumed that Greece would remain solvent. Greece will have to return to the market on a large scale in 2012. If the market refuses to provide finance at conditions compatible with sustainability, Greece will either need a new program or it will need to reduce its debt burden through a restructuring. Clearly, a decision will have to be made earlier to avoid further risks. A clear communication strategy would help mitigate short-term risks. It could be clearly stated that the restructuring would not take place during the current year.  Moreover, markets could be reminded that the current Greek program includes 10bn Euros that would be readily available to support the banking system during the assessment phase. Finally, European policy makers will need to make an effort to explain how the restructuring would be done in practice, not least to avoid contagion. It is time to act for the ESRB.