A Cautionary Lesson on ESG Ratings

Based on ESG ratings in isolation, Silicon Valley Bank appeared to be a sound choice of a more sustainable investment. It wasn't.

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KEY TAKEAWAYS:

--A leading data provider gave SVB a good overall ESG rating and an upper end score for governance--demonstrating the potential limitations of relying too much on single sources of outsourced, off-the-shelf ESG data.

--Increasingly, using ESG data blindly can be avoided. Insurers can supplement or cross-check rating scores with the expanding range of data available to validate and set ESG strategies.

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During the pandemic, Silicon Valley Bank (SVB) saw a huge increase in customer deposits, which nearly tripled from pre-pandemic levels. Some of these deposits were used to provide loans to other customers, but the bank also invested them in U.S. Treasury bonds and other bonds deemed high-quality by rating agencies.

When the Federal Reserve began raising interest rates, the U.S. yield curve shifted upward, putting downward pressure on the price of these bonds. Ordinarily, this in itself would not be an issue, as the bank doesn’t have to sell these lower-value assets at their new valuation, unless it requires liquidity to meet demand for withdrawals. Yet, that is exactly what happened with SVB: Customer withdrawals rose more than expected, and, to meet the need for liquidity, the bank had to sell these bonds at a significant loss.

SVB, in turn, announced that it would need to raise capital. Investors sold off the stock, and customers made a run on the bank for their deposits, trying to withdraw $42 billion on March 9. The following day, the Federal Deposit Insurance Corporation took over SVB’s assets. Similar concerns were raised with other banks, including Signature Bank in New York.

Green appearances can be deceptive

One less-reported aspect of its failure (including the sale of SVB's U.K. subsidiary to HSBC) is that it was well-rated from an environmental, social and governance (ESG) perspective. A leading data provider gave SVB a good overall ESG rating and an upper end score for governance.

What happened with SVB demonstrates the potential limitations of relying too much on single sources of outsourced, off-the-shelf ESG data. As important a source as third-party ESG ratings and scores are, SVB’s collapse shows that insurers must take greater ownership of the data on which they rely for setting a more sustainable investment strategy.

Beware ‘black boxes’

Currently, a lot of insurers that we speak to are still treating their third party ESG data as "black boxes," where they use the data provided without analyzing the methodology used to create the data. SVB was rated well because of its focus on creating initiatives to advance inclusion and opportunity in the innovation economy and its investments in clean energy solutions. SVB was seemingly a sound ESG diversification bet.

Increasingly, using ESG data blindly can be avoided. Insurers can supplement or cross-check rating scores with the expanding range of data available to validate and set ESG strategies. For insurers, there are clear parallels to the rationale for why and what the Prudential Regulation Authority and the Lloyd’s Market already expect with regard to validating the output of external models (e.g., economic scenario generators and CAT models). Stronger ESG investment controls will likely have capital management benefits in the future.

Ways forward could include using more than one data vendor to get different perspectives. This could also go hand in hand with developing an approach for a company sourcing their own data that more accurately aligns to their specific ESG beliefs, ambitions and targets, such as achieving net zero by a certain date, for example.

The fundamental goal should be to establish a sense check and validate primary data. Other avenues to explore could include periodic deep dives into specific sectors of investment interest to understand what’s driving overall portfolio scores.

See also: The Return of the Regulators

5 key takeaways

The main points for insurers to consider are:

  • Insurers should take greater ownership of data they’re using to inform investment decisions and manage ESG-related risks.
  • It’s also important for insurers to clearly articulate an ESG strategy for their business and create a clear link to how this will apply to their investment strategy, particularly with regard to the implications and potential trade-offs when using ESG data.
  • Insurers must validate and understand the ESG data they’re using, as opposed to relying on a black box approach. 
  • It is important for an insurer to perform due diligence on ESG data when they are using it to inform portfolio allocation decisions and for there to be greater oversight of how their asset managers are making stock selection decisions. Such due diligence might have brought to light some of the governance concerns relating to SVB. 
  • Insurers are increasingly seeking support on which validation approaches to consider when using third party ESG data and establishing governance processes around data used to inform strategic decisions.

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