Treasury and the Fed should agree promptly to cooperate according to the above principles so that the Fed can act preemptively, flexibly, aggressively

TO BE NOTED:

"CENTRAL BANKING IN THE CREDIT TURMOIL:
AN ASSESSMENT OF FEDERAL RESERVE PRACTICE
Marvin Goodfriend1
Carnegie Mellon University
And
National Bureau of Economic Research
May 2009
1 Professor of Economics, Chairman of the Gailliot Center for Public Policy, Tepper School of Business.
The paper was prepared for a presentation at the Bank of Japan 2009 International Conference: Financial
System and Monetary Policy Implementation, May 27-8, 2009, Institute for International and Economic
Studies, Bank of Japan, Tokyo, and a presentation at the Conference on “Monetary-Fiscal Policy
Interactions, Expectations, and Dynamics in the Current Economic Crisis,” May 22-3, 2009, Princeton
University, Princeton, New Jersey.
1
Introduction
The credit market turmoil and severe contraction of economic activity
have challenged central banks around the world as never before. Central
banks increased the stock of aggregate bank reserves enormously, and
brought targeted short-term interest rates to (near) zero in many countries.
For instance, the Federal Reserve increased the stock of bank reserves in the
United States from under 10 billion dollars in August 2007 to around 800
billion dollars in April 2009 as the federal funds rate approached zero.
Central bank lending expanded greatly to facilitate credit flows. For
instance, Federal Reserve loans to depository institutions stand at over 400
billion dollars at the end of April 2009. Previously, the most expansive,
prolonged Fed lending was a loan of roughly 5 billion dollars to Continental
Illinois Bank from May 1984 until February 1985.2 Since the turmoil began
in 2007 the Fed extended its credit well beyond depository institutions. Most
significantly, the Fed purchased around 400 billion dollars of mortgagebacked
securities guaranteed by Fannie Mae, Freddie Mac, and Ginnie Mae.
And the Fed extended over 200 billion dollars of loans to a special purpose
vehicle created to purchase commercial paper.3
Still farther afield, the Fed extended credit to three limited liability
companies in conjunction with efforts to stabilize institutions that it deemed
to be critically important. In mid-March 2008 the Fed agreed to extend
roughly 29 billion dollars to Maiden Lane I LLC so that it could acquire a
variety of mortgage obligations, derivatives, and hedging products to
facilitate the acquisition of Bear Stearns by JP Morgan Chase. Maiden Lane
II and III LLC were both created to restructure the Fed’s lending to AIG in
the aftermath of its financial support of AIG in September 2008. Together,
the Fed lent Maiden Lane II and III roughly 50 billion dollars to purchase,
respectively, residential mortgage-backed securities from AIG, and multisector
collateralized debt obligations on which AIG has written credit
default swap contracts.4
All together, the Fed grew its balance sheet from around 900 billion
dollars in mid-2007 to over 2 trillion dollars as of April 2009. The Fed did
so while reducing its purchases of US Treasury securities from over 800
billion to 550 billion dollars. The Fed funded its enormous increase in
lending with over 250 billion dollars from the sale of Treasury securities,
2 For a brief period following 9/11, fed lending to banks rose above 30 billion dollars. Fed credits
referenced here and in the text are overnight loans.
3 See Federal Reserve Statistical Release H.4.1 “Factors Affecting Reserve Balances,” April 30, 2009.
4 See the Appendix to the Federal Reserve’s Monetary Policy Report to Congress, February 24, 2009.
2
plus around 800 billion dollars growth of bank reserves, and around 300
billion dollars of additional deposits provided by the Treasury, for a grand
total of over 1.3 trillion of Fed lending as of April 2009.
The extraordinary scale and scope of the policy actions undertaken by
the Fed and other central banks to stabilize the banking system, to facilitate
non-bank credit flows, and to act against the contraction of employment and
output presents a unique opportunity to reconsider the nature of central
banking. The Fed and other central banks around the world have undergone
a stress test of their own, a test that is still very much in progress. Yet
enough time has passed to take stock, not so much to evaluate the timing,
magnitude, and effectiveness of particular extraordinary actions, but to
observe how central banks put their various powers to work in extraordinary
circumstances, and to use those observations to rethink central banking more
generally.
Our reconsideration begins by classifying core central banking
initiatives as monetary policy, credit policy, or interest rate policy. Monetary
policy refers to open market operations that expand or contract highpowered
money (bank reserves and currency) by buying or selling Treasury
securities. Credit policy shifts the composition of the central bank balance
sheet, holding high-powered money fixed, from Treasuries to credit to the
private sector or other government entities in the form of loans or securities
purchases. Interest rate policy involves adjusting interest paid on bank
reserves to influence the level of short-term interest rates.
This three-fold taxonomy did not matter much in the past. For
instance, until the recent credit turmoil the Fed’s credit policy played a
relatively minor role, the Fed could not pay interest on reserves, and
monetary policy was utilized to target the federal funds rate. However, the
taxonomy is useful in the current context for a number of reasons. For
instance, it will allow us to appreciate the potential for monetary policy
alone to stimulate economic activity at the zero bound on interest rate policy.
And it will allow us to understand how interest on reserves will enable
interest rate policy to exit from the zero bound, regardless of the size of the
Fed’s balance sheet.
Monetary, credit, and interest rate policy involve fiscal policy in
important but different ways. We will see that monetary policy needs more
support than is usually granted from the fiscal authorizes to be effective at
the zero bound, in part because interest on reserves needs fiscal support to
assure its effectiveness in exiting from the zero bound. And credit policy
owes its effectiveness to the fact that it is fiscal policy pursued by a central
bank. One of the main points of this essay is that because credit policy is
3
fiscal policy, central bank independence is incompatible over time with all
but limited, temporary last resort lending to depository institutions.
The essay presents a framework for rethinking central banking in light
of the extraordinary developments in the credit turmoil—near zero interest
rates, the huge expansion of bank reserves, the unprecedented expansion of
the scale and scope of central bank lending. The contention is that one must
understand central banking in terms of its essence—the independent
authority to manage monetary policy, (limited) credit policy, and interest
rate policy—and build an institutional framework to preserve that
independence so that central banks can make their greatest possible
contribution to stabilization policy.
With that in mind, the balance of the essay proceeds as follows.
Section 1 details the taxonomy to be employed in the remainder of the essay.
Section 2 outlines the fiscal dimensions of monetary, credit, and interest rate
policies. Section 3 explains how monetary policy can stimulate economic
activity at the zero bound, and how interest on reserves could allow interest
rate policy to exit the zero bound. Section 4 reviews the fiscal policy
dimensions of five actual Federal Reserve initiatives in the credit turmoil—
the Term Auction Facility, lending to facilitate the acquisition of Bear
Stearns by JP Morgan Chase, Fed support for AIG, emergency authority to
pay interest on reserves, and the joint statement by the Treasury and the Fed
on the role of the Fed in preserving financial and monetary stability. Section
5 proposes a set of principles to clarify the boundary between the Treasury
and Fed in an “Accord for Federal Reserve Credit Policy” along the lines of
the famous 1951 “Fed-Treasury Accord on Monetary Policy.”
1. Monetary Policy, Credit Policy, and Interest Rate Policy
Monetary policy refers to central bank policy actions that change the
stock of high-powered money, i.e., currency plus bank reserves. A central
bank can add reserves to the banking system or supply currency to the public
by purchasing securities; it can drain reserves or currency by selling
securities. The Fed’s power to determine the stock of high-powered money
has enabled it to manage the federal funds rate and to pursue interest rate
policy as directed by the Federal Open Market Committee. At the start of the
credit turmoil in the summer of 2007, the Fed had on its balance sheet
roughly 850 billion dollars of securities obtained in the course of supplying
the economy with currency and bank reserves.
To avoid carrying credit risk on its balance sheet, ordinarily the Fed
satisfied virtually all of its asset acquisition needs in support of monetary
4
policy by purchasing Treasury securities and those securities deemed to have
the explicit backing of the Treasury, an acquisition policy known as
“Treasuries only.”5 A pure monetary policy action is one in which the Fed
either injects newly-created reserves into the banking system by buying
Treasury securities or drains reserves from the banking system by selling
Treasury securities. The Fed returns to the Treasury all but a small fraction
of the interest on the Treasury securities that it holds; the remainder is
utilized to pay its operating expenses. Fed interest payments to the Treasury
in 2006 were around 30 billion dollars. Given the huge volume of Treasury
debt outstanding and likely to remain outstanding, the Fed could manage
monetary policy indefinitely without abandoning “Treasuries only.”
Things changed recently with the Fed’s aggressive use of credit policy
to deal with the turmoil in credit markets. The Fed takes a pure credit policy
action as distinct from a monetary policy action by shifting the composition
or size of its portfolio of assets, holding high-powered money fixed. For
example, the first large-scale credit policy actions undertaken by the Fed in
early 2008 involved lending to banks funds acquired by selling Treasury
securities from its portfolio, with no effect on high-powered money or on the
size of its balance sheet.
To date, the Fed has extended over 1.3 trillion dollars of credit to
banks and non-bank financial institutions, to special purpose entities to
finance the acquisition of commercial paper, and to purchase mortgagebacked
securities. The Fed financed around 800 billion dollars of its massive
extension of credit with newly-created bank reserves. In this sense, one can
say that 800 billion dollars of its unprecedented credit initiative was a
combination monetary and credit policy. An additional 250 billion dollars
of credit extended by the Fed, funded by the sale of a like amount of
Treasury securities, was pure credit policy. The remaining 300 billion
dollars of credit extended by the Fed utilized a like amount of new Treasury
deposits. Since the Treasury financed those deposits by issuing debt, this
portion of Fed asset acquisition was pure credit policy, too.
The Fed acquired the authority to pay interest on reserves in the
autumn of 2008. It has utilized interest on reserves since then to free interest
rate policy from monetary policy. This interest-on-reserves regime works as
follows. The Fed buys enough securities with newly-created bank reserves to
drive the federal funds rate down to the zero bound.6 Simultaneously, the
Fed pays interest on reserves at the intended (overnight) federal funds rate,
5 Most Treasuries have been purchased outright, but a small fraction is held under repurchase agreements
for liquidity purposes.
6 Goodfriend (2002), and Keister, Martin, and McAndrews (2008).
5
say 2%. Banks don’t lend federal funds below 2% since they earn 2%
overnight by holding reserves at the Fed. The overnight federal funds rate
would not trade much above 2% either, as long as the Fed nearly satiates the
market for reserves.
Evidence from the 1930s, the last time interest rate policy hit the zero
bound in the United States, indicates that short-term interest rates fell to
around 25 basis points once excess reserves rose above 10 percent of
deposits.7 In other words, the reserves market was nearly satiated with a
relatively modest volume of reserves. The Fed would be free to expand
bank reserves beyond that threshold for reasons other than targeting the
federal funds rate. In other words, an interest-on-reserves regime would
allow the Fed to pursue monetary policy independently of interest rate policy.
Of course, Fed credit policy funded with Treasury deposits or with sales of
Treasury securities from the Fed’s portfolio could be pursued independently
of both interest rate policy and monetary policy.
2. Fiscal Aspects of Monetary, Credit, and Interest Rate Policy
For a given payment of interest on reserves, at zero or otherwise, pure
monetary policy involves fiscal policy in two ways. First, monetary policy
influences the spread between the federal funds rate and interest paid on
reserves by varying the marginal liquidity services yield on reserves. For
instance, by draining reserves from the banking system the central bank
raises the marginal liquidity services yield, which requires a higher interest
opportunity cost of holding reserves in equilibrium, and hence a higher
spread between the federal funds rate and interest paid on reserves. In effect,
monetary policy raises the federal funds rate relative to interest paid on
reserves by increasing the scarcity of reserves which, in turn, taxes reserves
by paying below market interest on reserves.
Second, the Fed collects the tax as interest on the Treasury securities
that it purchases in the process of supplying bank reserves and non-interest
bearing currency. Treasury securities so purchased are “retired” from the
government’s point of view, since the Fed returns to the Treasury interest
paid on these securities. The monetized Treasury securities represent the
seigniorage from the creation of high-powered money. Importantly, by
adhering to a “Treasuries only” asset acquisition policy, the Fed passes all
the tax revenue from monetary policy through to the Treasury.
7 Morrison (1966), page 44.
6
Fed credit initiatives described above employ fiscal policy to improve
flows in credit markets. When the Fed substitutes credit to the private sector
or another government entity for a Treasury security in its portfolio, the Fed
can no longer return to the Treasury the interest it had received on the
Treasury security that it held. In other words, when the Fed sells a Treasury
security to make a loan, it’s as if the Treasury issued new debt to finance the
loan. Credit policy executed by the Fed is really debt-financed fiscal policy.
Fed loans may perform well, throwing off interest payments by a margin
appropriate for the risk above interest paid by the Treasury to fund the loan.
Nevertheless, Fed credit policy is risky, and inherently involves contentious
questions of fiscal policy.
Fed credit policy “works” by exploiting the creditworthiness of the
government to acquire funds at a riskless rate of interest in order to make
those funds available to financial institutions and other borrowers that
otherwise would have to pay a much higher risk premium to borrow, if they
can borrow at all under the circumstances. Collateralized Fed credit policy is
risky not only because the borrower might default, but also because the
collateral might prove to be worth less than the loan in the event of a
borrower default. In effect, Fed credit policy works by interposing the US
Treasury between lenders and borrowers in order to improve credit flows. In
doing so, however, the Fed essentially makes a fiscal policy decision to put
taxpayer funds at risk. In the event of a default, if the collateral is unable to
be sold at a price sufficient to restore the initial value of Treasury securities
on the Fed’s balance sheet that was used to fund the credit initiative, then the
flow of Fed remittances to the Treasury will be smaller after the loan is
unwound. The Treasury will have to make up the shortfall somehow, namely,
by lowering expenditures, raising current taxes, or borrowing more and
raising future taxes to finance the increased interest on the floating debt or to
retire the debt.
Even Fed lending that is collateralized fully and subject to a negligible
risk of loss exposes taxpayers to losses if the borrower fails subsequently.
For instance, Fed emergency lending (that finances the withdrawal of
uninsured claimants of a financial institution that fails subsequently) strips
that institution of collateral that would otherwise be available to cover the
cost of insured deposits or other government guarantees. Thus, even if the
Fed succeeds in lending only against good collateral so as not to take
appreciable credit risk itself, last resort lending to depositories and
emergency credit extended to other financial institutions that have federal
guarantees have the capacity to impose significant losses on taxpayers.
7
The interest-on-reserves regime utilizes a fiscal policy instrument
granted to the central bank, the authority to pay interest on reserves, to
improve the efficiency of interest rate policy and free monetary policy to
pursue other objectives. The interest-on-reserves regime would nearly
eliminate the tax on reserves. An abundance of costless, safe reserves would
displace costly and risky private credit in the payments system. The savings
would be passed to interest on bank deposits, inducing the public to
substitute money balances for shopping time in making transactions. The
availability of low opportunity-cost bank reserves would enable the central
bank to limit the extension of its own credit in support of the payments
system. Moreover, by eliminating the tax on reserves, the interest-onreserves
regime would secure the central bank’s control of short-term
interest rates, since banks would no longer have an incentive to substitute
away from central bank reserves in the provision of transactions services.
As indicated above, the advantages of the interest-on-reserves regime
could be achieved at a relatively low threshold of aggregate reserves to
deposits. At that minimum, the central bank would likely have little problem
financing the payment of interest on reserves out of interest earned on its
securities in as much as all but a relatively small portion of its securities will
have been purchased with non-interest bearing currency. Moreover, the
interest-on-reserves regime could be run in conjunction with pure monetary
policy, that is, with a “Treasuries only” asset acquisition policy.
Switching to the interest-on-reserves regime would have two effects
on the government’s revenue from money creation. There would be a loss of
transfers to the government associated with interest paid to banks on
preexisting reserve balances. However, interest paid on the increase in
reserves would be self-financing on average over time since interest rate
spreads between longer-term Treasuries and overnight deposits at the central
bank should normally exhibit term premia reflected in the Treasury yield
curve. In fact, the interest-on-reserves regime would likely yield a net
increase in seigniorage over time, since preexisting reserve balances are so
small.
3. Monetary Policy at the Zero Bound and Interest on Reserves
in the Exit Strategy
Monetary policy expansion at the zero bound can be effective if the
public is confident that the central bank will expand bank reserves by as
much and for as long as needed to act against the downturn. The credibility
of aggressive monetary stimulus, however, depends on the public’s belief
8
that the central bank is confident of its independence to exit promptly and
aggressively from the zero bound if need be to contain inflation.( NB DON ) This section
explains the leverage that monetary policy can utilize to stimulate economic
activity at the zero bound, and the leverage that interest on reserves can exert
to exit from the zero bound, regardless of the size of the central bank’s
balance sheet.
Monetary Policy at the Zero Bound on Interest Rate Policy
To appreciate the power of monetary policy to stimulate economic
activity at the zero bound, we must distinguish between narrow and broad
liquidity services. Narrow liquidity services are provided by the medium of
exchange allowing banks and the public to economize on transactions costs.
When short-term nominal interest rates are near zero, there is little
opportunity cost of holding currency, bank reserves, and transactions
deposits. Banks and the public enlarge their holdings of transactions
balances, and the demand for narrow liquidity services of money is nearly
satiated.
The demand for broad liquidity services is evident in the large stock
of time deposits and certificates of deposit, money market mutual fund
shares, and short-term government securities willingly and routinely held by
the public in relation to consumption and income in the United States, even
though the short-term real rate of interest on such financial assets has
averaged around 1 to 2 percent.8 For instance, in 2005 the US public held
around one year’s GDP, then about 12.5 trillion dollars, in M3 plus shortterm
Treasuries.
Broad liquidity services are not exhausted when the interbank interest
rate hits the zero bound. In fact, the hallmark of the credit turmoil has been
the “flight to safety,”( NB DON ) an increased demand to hold wealth in such financial
assets.
The demand for broad liquidity provides the leverage for monetary
policy to stimulate the economy even after the interbank interest rate hits the
zero bound.9 At the zero bound, high-powered money and short-term
Treasury securities provide identical (broad) liquidity services because
narrow liquidity services are satiated. Hence, to exert monetary (as distinct
from credit) policy stimulus at the zero bound, a central bank must inject
reserves by purchasing illiquid assets such as long-term Treasury bonds.
8 Campbell (1999), page 1233.
9 This following draws on Goodfriend (2000).
9
Increasing the stock of broadly liquid financial assets acts on a number of
margins to stimulate economic activity at the zero bound.
First, expanding the stock of broad money brings down the “marginal
broad liquidity services yield” and activates the portfolio rebalancing
channel. An injection of broad liquidity that drives down its implicit yield
induces banks and the public to hold assets that are less liquid but have a
higher explicit rate of return. Equilibrium prices of nonmonetary assets are
bid up to restore the required return differential. Second, higher asset prices
raise collateral values and the net worth of households and firms, and
thereby help bring elevated credit spreads back down. Higher asset prices
and reduced credit spreads, in turn, stimulate desired consumption out of
current income and help revive investment.
Third, the public might utilize reserves injected into the economy to
repay bank loans. In this case, the injection of reserves would not act directly
to increase the stock of broad liquidity. But the reserve injection would be
expansionary nevertheless, in addition to enabling the public to pay off bank
loans without shrinking the aggregate money stock. The reserve injection
would increase the ratio of reserves to deposits; and it would free up banking
resources that had been engaged in managing and monitoring the loans that
were paid off. Both effects would reduce the equilibrium external finance
premium and encourage the extension of new loans by reducing riskweighted
assets and improving risk-weighted capital ratios, and by making
available organizational banking resources to manage new lending. Not only
would the banking system be better positioned to extend loans to those still
in need of credit, in so doing it would expand the stock of aggregate bank
deposits and broad liquidity.
Two additional implementation problems would have to be overcome
to make monetary stimulus effective at the zero bound. Ordinarily, relatively
small changes in bank reserves suffice to manage interest rate policy. We
saw above, however, that monetary policy exerts its stimulus through a large
“monetary aggregate” at the zero bound. Hence, a large, sustained increase
in bank reserves in the trillions of dollars likely is necessary for monetary
policy stimulus to have much effect through the three broad-liquidity
channels of monetary transmission outlined above. Moreover, the
effectiveness of even such a large expansion of bank reserves against the
contraction would depend on the public’s belief in the central bank’s
willingness to expand reserves by as much and for as long as needed to act
against the contraction. The required expansion of bank reserves would be
credible only if the public also believed that the central bank could exit the
10
zero bound on interest rate policy promptly and aggressively if need be to
act against inflation, regardless of the size of its balance sheet.
Interest on Reserves in the Exit Strategy
In principle, the authority to pay interest on reserves obtained in the
fall of 2008 should give the Fed the operational independence to raise the
federal funds rate against inflation if the economy turns up sharply or if
inflation or inflation expectations begin to rise—even with trillions of
dollars of bank reserves on its balance sheet financing long term Treasuries
and credit programs that cannot be unwound promptly.
However, credible operational independence for the Fed to exit the
zero bound also needs the support of financial independence. The question
is: can the Fed be sure to have sufficient interest income to finance
independently whatever interest must be paid on reserves as the economy
emerges from the zero bound, or might the Fed need additional fiscal
support from the Treasury? This question should be addressed even though
nearly 1 trillion dollars of non-interest bearing currency provides the Fed
with a large cushion of net interest income.
Financial independence need not be a problem if the Fed manages
stabilization policy well in the current turmoil so as to maintain long term
Treasury rates in the vicinity of a sustainable 5 percent yield, a 3 percent real
yield plus a 2 percent inflation premium consistent with the Fed’s apparent
inflation target.10 If short rates remain below long rates as interest rate policy
exits from the zero bound so that the yield curve remains upward sloping,
then Fed net interest income could remain comfortably positive.
However, a cash flow problem could arise if the Fed is either
insufficiently preemptive against deflation or insufficiently preemptive
against inflation. If the Fed acts too slowly against deflation, it could suffer
negative cash flow problems as interest rates normalize if it bought long
bonds to act against the contraction and deflation after long rates had fallen
well below their steady state levels. If the Fed acts too slowly against
inflation, negative cash flow problems could arise if the Fed has to raise
interest on reserves far above long term interest rates to stabilize inflation.(NB DON )
To make fully credible the Fed’s operational independence to use
interest on reserves to exit the zero bound, the Treasury should guarantee the
Fed’s financial independence to pay interest on reserves. This the Treasury
could do by allowing the Fed to retain net interest income to build up
10 Board of Governors of the Federal Reserve System (2009), page 39.
11
“surplus capital.” The Fed would hold its cushion of surplus capital in short
term Treasury securities to be sold if need be to offset a negative cash flow
problem. By allowing the Fed to build up capital this way, the Treasury
would be undertaking a fiscal policy action to utilize tax revenue to buy back
short term government debt. Debt in the Fed capital account would be retired
from the Treasury’s point of view because the Fed would return the interest
to the Treasury. Under this arrangement, however, the Fed would have the
independence to sell the short term Treasuries in its capital account to help
finance interest on reserves, and any other operational expenses, if that were
to become necessary.
4. Fiscal Aspects of Five Federal Reserve Initiatives
This section describes five Fed initiatives in the credit turmoil: the
Term Auction Facility, lending to facilitate the acquisition of Bear Stearns
by JP Morgan Chase, Fed support for AIG, emergency authority to pay
interest on reserves, and the joint statement by the Treasury and the Fed on
the role of the Fed in preserving financial and monetary stability. The
descriptions highlight the role that fiscal policy plays in each of these
initiatives, and how at times the fiscal aspects of these initiatives created
problems for the Fed and for the effectiveness of its interventions to stabilize
the economy.
The Term Auction Facility
In December 2007, the Fed approved the establishment of the Term
Auction Facility (TAF) under which the Fed auctions term loans against a
wide variety of collateral to depository institutions judged to be in sound
condition.11 Since January 2009 the minimum bid rate has been interest paid
on reserves. TAF loans are provided for 28- and 84-day terms. Roughly 400
billion dollars of TAF loans were outstanding in April 2009.
In the taxonomy of this paper, the TAF program was established as a
pure credit policy in as much as the Fed financed TAF loans with funds
acquired by selling Treasury securities from its portfolio, with no effect on
aggregate bank reserves.
The TAF worked as follows. The credit turmoil was marked by an
unprecedented elevation in rates at which banks could borrow in the federal
funds market. Banks recognized a substantial credit risk in lending to each
11 Armantier, Olivier, Sandy Krieger, and James McAndrews (2008).
12
other given that federal funds lending is generally unsecured. Even if
collateral were taken, the ability to liquidate it could be impaired severely in
a widespread default. These factors reflected the substantial broad-liquidity
premium on reserve balances at the Fed. Banks reacted by shortening the
maturity at which they were willing to lend, and charging a substantial term
premium for interbank lending at longer horizons such as one and three
months. Bank positions in the federal funds market can be highly persistent.
For instance, big banks tend to be borrowers of federal funds and smaller
banks lenders. When the credit turmoil hit, those banks that were persistent
borrowers of federal funds endured a sharp persistent jump in their funding
costs.
Persistent borrowers of federal funds would bid most aggressively for
TAF term credit. By substituting TAF credit for more expensive federal
funds borrowed they could lower their borrowing costs. Persistent lenders of
federal funds in the interbank market could sell their excess reserves to the
Fed in exchange for Treasury securities sold by the Fed to fund its TAF
loans.
Since the TAF program had no effect on total bank reserves, and little
if any effect on the balance of supply and demand in the federal funds
market, and little effect on the creditworthiness of borrowing banks, it
should not have been expected to have much sustained effect on the
marginal federal funds rate paid by persistent interbank borrowers. The Fed
says that the TAF program was designed to increase the access of depository
institutions to funding in order to support the ability of such institutions to
meet the credit needs of their customers.12 Whether or not the TAF program
has had much effect on the marginal federal funds rate, the TAF program
can be understood to have reduced funding costs of those banks caught with
a persistent short-term funding shortfall.
Understood this way, the TAF program provides infra-marginal relief
on funding costs for persistent borrowers of federal funds. To the extent that
interest the Fed earns on TAF credit exceeds interest on the Treasury
securities sold to fund it, and TAF credit is virtually riskless for the Fed
because it has a secure collateral interest if the borrowing bank fails, the
TAF may provide that relief at little cost to the Fed.
It cannot be said, however, that the TAF provides interest savings to
banks at little risk to the taxpayer. As discussed in Section 2 above, even
Fed lending that is collateralized fully exposes taxpayers to losses if the
borrower fails subsequently. If TAF credit finances uninsured or unsecured
12 Board of Governors of the Federal Reserve System (2009), page 47.
13
lenders to a bank that fails while the loan is outstanding, then the TAF will
have stripped the bank of collateral that would be available otherwise to
cover the cost of insured deposits or other government guarantees. Thus, the
Fed must be careful when extending one to three month term credit through
the TAF to make sure that bank receiving TAF credit will remain solvent
over the term of the loan.
Lending to Facilitate the Acquisition of Bear Stearns
by JP Morgan Chase
In mid-March 2008 Bear Stearns was pushed to the brink of failure
after losing the confidence of investors and its access to short-term funding.
The Fed judged that a disorderly failure of Bear Stearns would have
threatened overall financial stability, and after talking with the Treasury and
SEC, the Fed determined that it would invoke emergency authority to
provide special financing to facilitate the acquisition of Bear Stearns by JP
Morgan Chase. 13 In June, when the acquisition was completed, the Fed
extended roughly 29 billion dollars to the limited liability company Maiden
Lane I, which was formed to facilitate the transaction by acquiring a variety
of mortgage obligations, derivatives, and hedging products from Bear
Stearns.
The point of this discussion is not to question the Fed’s decision to
provide financial support for the acquisition of Bear Stearns by JP Morgan
Chase. What matters for our purposes is that the Fed’s financial support
went well beyond ordinary lending to depository institutions.( NB DON ) Institutions
ordinarily eligible to borrow at the Fed discount window are depositories
that hold balances at the Fed. Investment banks were not in this group.
Hence, the Fed had to invoke emergency powers to lend in support of the
acquisition.
As a central bank the Fed usually provides loans against good
collateral to institutions deemed to be in sound financial condition( NB DON ). The Fed
went beyond these two conditions in this case. It lent to a limited liability
company Maiden Lane I formed for the purpose of acquiring certain assets
of Bear Stearns. Maiden Lane I was funded by a 29 billion dollar loan from
the Fed and a 1 billion dollar loan from JP Morgan Chase. The first 1 billion
dollar loss was to be borne by JPMC, any further loss up to 29 billion was to
be borne by the Fed. And any realized gains beyond the 30 billion initial
financing, which could occur because of revaluing the underlying assets,
13 See Geithner (2008).
14
would accrue to the Fed. This arrangement meant that the Fed had all of the
upside of the asset valuations and all but a small fraction of the downside by
lending to Maiden Lane I. In effect, the Fed “purchased” the assets( NB DON ), a variety
of risky mortgage obligations, derivatives, and hedging products acquired
from Bear Stearns.
The Fed financed its loan to Maiden Lane I with funds from the sale
of Treasury securities. Hence, in terms of the terminology presented in this
paper, the loan to Maiden Lane I was a pure credit policy which, in turn,
amounted to a debt-financed fiscal policy purchase of a pool of risky private
financial assets. The Fed effectively acknowledged this in two ways. First,
the Fed brought Maiden Lane onto its balance sheet and recognized
implicitly that its loan to Maiden Lane amounted to a purchase of the assets
in Maiden Lane.14 Second, the Fed received a letter from the Treasury saying
“if any loss arises out of the special facility extended by the FRBNY to
JPMCB, the loss will be treated by the FRBNY as an expense that may
reduce the net earnings transferred by the FRBNY to the Treasury general
fund.”15
In April 2008, Paul Volcker described the Fed’s lending to facilitate
the acquisition of Bear Stearns by JP Morgan Chase as follows:
Simply stated, the bright new financial system—for all its talented
participants, for all its rich rewards—has failed the test of the market
place( NB DON ). To meet the challenge, the Federal Reserve judged it necessary
to take actions that extend to the very edge of its lawful and implied
powers, transcending certain long embedded central banking
principles and practices. The extension of lending directly to nonbanking
financial institutions—while under the authority of nominally
“temporary” emergency powers—will surely be interpreted as an
implied promise of similar actions in times of future turmoil( NB DON ). What
appears to be in substance a direct transfer of mortgage and mortgagebacked
securities of questionable pedigree from an investment bank to
the Federal Reserve seems to test the time honored central bank
mantra in time of crisis—“lend freely at high rates against good
collateral”( NB DON BAGEHOT )—to the point of no return.16
14 See Board of Governors of the Federal Reserve System statistical release H.4.1 from July 3 and
September 10, 2008, and 1A Memorandum Items, September 10, 2008.
15 Paulson (2008).
16 Volcker (2008), page 2.
15
In retrospect, Volcker’s remarks can be seen as a kind of “life
preserver” thrown to the Fed. Without judging whether the Fed’s actions
were called for under the circumstances, but describing the Fed as having
acted at the “very edge of its lawful and implied powers,” Volcker’s remarks
could have prompted the Fed back in April to get the Treasury and Congress
to appropriate financial resources to stabilize the financial system, should
those resources be needed as the credit turmoil ran its course. Instead, the
fiscal authorities were not then so involved, and the Fed remained exposed
to having its balance sheet utilized as an “off budget” arm of fiscal policy.
Federal Reserve Support for AIG
Events surrounding the deterioration of financial conditions in the
autumn of 2008 illustrate the consequences of allowing the Fed’s balance
sheet to be the front line of fiscal support for the financial system. On
September 7 the Treasury and the Federal Housing Finance Agency
announced they would place Fannie Mae and Freddie Mac into
conservatorship. Shortly thereafter, Lehman Brothers came under pressure
as short-term secured funding was withdrawn from the investment bank, and
Lehman filed for bankruptcy on Monday, September 15th. The financial
condition of American International Group (AIG), a large, complex
insurance conglomerate, also deteriorated rapidly and on Tuesday,
September 16th with the full support of the Treasury, the Fed announced an
85 billion dollar loan to AIG to support the firm whose failure it judged
would have significant adverse effects on the economy. A full-scale
financial panic developed on Wednesday, September 17th after a major
money market mutual fund “broke the buck” prompting widespread
withdrawals from prime money funds and forcing the liquidation of their
commercial paper holdings. The “flight to safety” pushed the 3-month
Treasury bill yield to zero on September 17th.( NB DON )
The Fed’s financial support for AIG was criticized immediately by
some important members of Congress as a questionable commitment of
taxpayer funds, in effect, a “bridge too far.”17 At that point, and in light of
the ongoing panic in financial markets, Fed Chairman Bernanke had little
choice but to call Treasury Secretary Paulson and tell him that the Fed had
been stretched to its limits and couldn’t do anymore. Although Paulson
apparently had been resisting such a move for months, Bernanke said it was
17 Blackstone and Yoest (2008), and Andrews, de la Merced, and Walsh (2008).
16
time for the Treasury secretary to go to Congress to seek funds and authority
for a broader rescue of the financial system.18
On Thursday eve, September 18th, Paulson and Bernanke made their
case to the congressional leadership—that the Congress should authorize a
large expenditure of public funds to help stabilize the financial system. By
that weekend, Congress and Paulson had agreed on the outlines of the700
billion dollar Troubled Asset Relief Program (TARP).19
The problem was that in order to get Congress to appropriate the
funds, Bernanke then had to argue that otherwise the US economy was at
risk of a severe contraction, if not another Great Depression. When the
House of Representatives rejected the initial TARP bill on Tuesday,
September 30th, stocks plunged.20 To overcome resistance to funding the
TARP program, Bernanke continued to argue that the legislation was needed
to prevent a severe contraction. By the time the legislation passed on Friday,
October 3rd, the public was thoroughly frightened. Equity markets in the
United States fell by over 30 percent in the four weeks to October 10th. Risk
spreads rose dramatically throughout the credit markets as never before in
the credit turmoil. High-yield corporate bond spreads over comparable offthe-
run Treasuries spiked briefly to 16 percentage points and remained
above 10 percentage points, well above their previous peak in the credit
turmoil of 6 percentage points.
Getting the fiscal authorities to appropriate the TARP funds proved
catastrophic. The political fighting involved in persuading Congress to
authorize funding for TARP, in conjunction with other aspects of the ad hoc
fiscal response to the financial turmoil, precipitated the collapse of
confidence that gave rise to the severe contraction of spending and
employment in the fourth quarter of 2008 that we continue to endure.
Emergency Authority to Pay Interest on Reserves
The Financial Services Regulatory Relief Act of 2006 gave the Fed
the authority starting in October 2011 to pay interest on reserves for the first
time in its history. In May 2008 Bernanke asked that Congress give the Fed
immediate authority to pay interest on reserves. Using authority granted
under the Emergency Economic Stabilization Act of 2008, the Fed
announced on October 6 that it would begin paying interest on required and
excess reserve balances. The payment of interest on reserves was intended to
18 See the Wall Street Journal article written by Hilsenrath, Solomon, and Paletta (2008).
19 The Economist (2008).
20 See the headline in the New York Times September 30, 2008.
17
assist in maintaining the federal funds rate close to the target set by the
FOMC by creating a floor under interbank market rates. Initially, the rate
paid on excess reserves was set as a spread below the targeted federal funds
rate. Later, with the federal funds rate trading consistently below the target
rate, the spreads were eliminated. Interest on reserves helped set a floor
under the federal funds rate as the Fed created nearly a trillion dollars of
reserves to help finance its credit initiatives in the fourth quarter of 2008.
Interest on reserves became less important when the federal funds rate target
was reduced to ¼ percent in mid-December.
Nevertheless, the Fed’s authority to pay interest on reserves is timely
and valuable because, in principle, it gives the Fed the operational capacity
to exit credibly from the zero bound without first drawing down the stock of
bank reserves. Unfortunately, in practice, the fact that the federal funds rate
has fallen somewhat below the rate of interest paid on reserves indicates that
some financial institutions holding balances at the Fed that trade in federal
funds market are not authorized to receive interest on those balances. The
Fed should act promptly to secure the power of interest on reserves to exit
the zero bound by seeking additional legislation if necessary so that (1) all
institutions with balances at the Fed eligible to trade federal funds can
receive interest that the Fed pays on reserves, and (2) the Fed can retain
interest income to build up surplus capital sufficient to finance the payment
of interest on reserves in addition to its operating expenses, as needed.
Joint Statement by the Treasury and the Fed on Preserving Financial and
Monetary Stability
The joint statement issued on March 23, 2009 by the Department of
the Treasury and the Federal Reserve “The Role of the Federal Reserve in
Preserving Financial and Monetary Stability” indicates that the authorities
recognize that overall financial policy is well-served by clarifying the
relationship between the Treasury and the Fed.21 The two institutions agree
1) to cooperate in preventing and managing financial crises, 2) that the Fed
alone is responsible for monetary policy and that its monetary policy
independence is critical for the long-term economic welfare of the nation, 3)
that the Fed should use all its tools in cooperation with the Treasury and
other agencies to improve the functioning of credit markets, help prevent the
failure of systemically important institutions, and to foster financial stability,
21 Jeffrey Lacker and Charles Plosser, presidents of the Federal Reserve Banks of Richmond and
Philadelpha, respectively, recently called for clarifying the relationship between the Fed and the Treasury.
See Lacker (2009) and Plosser (2009).
18
4) that the Fed’s lender-of-last resort responsibilities involve lending against
collateral, secured to the satisfaction of the responsible Federal Reserve
Bank, 5) that the Fed should improve financial conditions broadly and not
aim to allocate credit narrowly, 6) that government decisions to allocate
credit are the province of the fiscal authorities, 7) that the use of the Fed’s
balance sheet in the pursuit of financial stability should not compromise its
independence on monetary policy, 8) that the Treasury should help the Fed
seek legislative action to provide additional tools to sterilize the effects of its
lending or security purchases on the supply of bank reserves, 9) that the two
institutions will work with Congress to develop a regime to allow the
government to address at an early stage the failure of a systemically
important financial institution within a framework that spells out the roles of
the Fed and other government agencies, 10) that the Treasury will remove
from the Fed balance sheet the three Maiden Lane facilities.
The joint statement has much to recommend it. It establishes the
principle that the boundary between the Fed and the Treasury must be
managed carefully so the two institutions can operate productively in
managing financial stability. It reasserts the importance of the Fed’s
independence on monetary policy. And it implicitly recognizes the fiscal
nature of the Maiden Lane facilities and the Treasury’s responsibility for
them.
Nevertheless, the March 23rd joint statement does not specify clearly
the principles that one should use to clarify the boundary of responsibilities
between the two institutions. It is on this last point that the present essay
hopes to contribute by distinguishing among monetary, credit, and interest
rate policy.
5. An Accord for Federal Reserve Credit Policy
The 1951 “Accord” between the United States Treasury and the
Federal Reserve was one of the most dramatic events in US financial history.
The Accord ended an arrangement dating from World War II in which the
Fed agreed to use its monetary policy powers to keep interest rates low to
help finance the war effort. The Truman Treasury urged that the agreement
be extended to keep interest rates low in order to hold down the cost of the
huge Federal government debt accumulated during the war. Fed officials
argued that keeping interest rates low would require inflationary money
growth that would destabilize the economy and ultimately fail.22
22 See Hetzel (2001), and Stein (1969).
19
The so-called Accord was only one paragraph, but it famously
reasserted the principle of Fed independence so that monetary policy might
serve exclusively to stabilize inflation and the macroeconomic activity.
The Fed has long executed credit policy in addition to monetary
policy, usually as “lender of last resort” to depository institutions. Credit
policy is also subject to misuse for fiscal policy purposes. However, as long
as Fed lending was relatively modest and temporary and confined to
depository institutions deemed solvent, and the Fed took good collateral
against its loans, the potential for fiscal misuse was limited by today’s
standards.23 So although the Fed has long needed an “Accord” for its credit
policy, a credit accord did not seem to be a pressing matter.24
The enormous expansion of Fed lending today—in scale, in reach
beyond depository institutions, and in acceptable collateral—demands an
accord for Fed credit policy to supplement the accord on monetary policy. A
credit accord should set guidelines for Fed credit policy so that pressure to
misuse Fed credit policy for fiscal purposes does not undermine the Fed’s
independence and impair the central bank’s power to stabilize financial
markets, inflation, and macroeconomic activity.
Federal Reserve Independence
The 1951 Accord restored the Fed’s instrument independence after the
wartime interest rate peg. Thereafter, the Fed utilized monetary policy to
manage the federal funds rate to achieve its macroeconomic objectives.
Congress early on recognized that the Fed needed financial independence in
order to conduct monetary policy effectively. The Fed is exempted from the
congressional appropriations process in order to keep the political system
from abusing its money-creating powers. The central bank funds its
operations from interest earnings on its portfolio of securities. The Fed was
given wide latitude regarding the size and composition of its balance sheet to
enable it to react quickly and independently to unanticipated short-run
developments in the economy. In the early 1980s under the strong,
independent leadership of Paul Volcker the Fed succeeded in establishing
low inflation as the nominal anchor for monetary policy. Thus, Fed
independence is today the institutional foundation for effective monetary
policy.
23 Schwartz (1992).
24 Goodfriend (1994).
20
Asset Acquisitions Should Sustain Federal Reserve Independence25
Congress bestowed financial independence on the Fed only because it
is essential for the Fed to do its job effectively. A healthy democracy
requires full public disclosure and discussion of the expenditure of public
funds. The congressional appropriations process enables Congress to
evaluate competing budgetary programs and to establish priorities for the
allocation of public resources. Hence, the Fed—precisely because it is
exempted from the appropriations process—should avoid, to the fullest
extent possible, taking actions that can properly be regarded as within the
province of fiscal policy and the fiscal authorities.
When the Fed purchases Treasury securities, it lends to the Treasury.
Doing so leaves all the fiscal decisions to Congress and the Treasury and
hence does not infringe on their fiscal policy prerogatives. Pure monetary
policy as described above—the acquisition of Treasury securities with newly
created bank reserves—respects the integrity of fiscal policy fully.
Federal Reserve credit policy as described above is another matter
entirely, because all financial securities other than Treasuries carry some
credit risk and all lending involves the Fed in potentially controversial
disputes regarding credit allocation. When the Fed extends credit to private
or other public entities, it is allocating credit to particular borrowers, and
therefore taking a fiscal action and invading the territory of the fiscal
authorities. As discussed in Section 2 above, and again with respect to the
TAF, even fully collateralized lending that is riskless for the Fed may expose
taxpayers to losses if the borrower fails subsequently. Fed credit that
finances the exit of uninsured or unsecured lenders to a financial institution
that fails while the loan is outstanding will have stripped the bank of
collateral that could otherwise be available to cover the cost of insured
deposits or other government guarantees.
It is important to appreciate the difficulties to which the Fed exposes
itself in the pursuit of credit policy initiatives that go beyond traditional last
resort lending to depository institutions. The Fed must decide how widely to
expand its lending reach. Lending farther afield creates “an implied promise
of similar actions in times of future turmoil,” as Volcker put it, which the
Fed may then be inclined to accommodate.26 Fed involvement in one credit
class can drain lending from nearby credit channels. The Fed must determine
the relative pricing of its loans based on risk and collateral. The Fed must be
25 This section draws directly from Broaddus and Goodfriend (2001).
26 Goodfriend and Lacker (1999) discuss this “limited commitment” problem in detail.
21
accountable for its credit allocations and the returns or losses on its loans or
security purchases. The public deserves transparency on Fed credit
extensions beyond ordinary lending to depository institutions. Yet,
congressional oversight opens the door to political interference in the Fed’s
lending choices. The Fed is exposed to congressional pressure to exploit the
central bank’s off-budget status to circumvent the appropriations process.
Finally, the Fed and the government must cooperate on banking,
financial, and payments system policy matters. This interdependence
exposes the Fed to political pressure to make undesirable concessions with
respect to its credit policy initiatives in return for support on other matters.
Worse, the Fed could be pressured to make concessions on monetary policy
to deflect pressure regarding credit policy.
Accord Principles for Federal Reserve Credit Policy
The above reasoning suggests that the following principles should
serve as the basis for a comprehensive Credit Policy Accord between the
Treasury and the Federal Reserve. To repeat, Congress bestows Fed
independence only because it is necessary for the Fed to do its job
effectively. Hence, the Fed should perform only those functions that must be
carried out in an independent central bank. The main idea is to preserve the
Fed’s independence to act flexibly and aggressively with monetary and
interest rate policy, and (limited) credit policy so that the Fed can maximize
its contribution to price stability, financial market stability, and
macroeconomic stability.
Principle 1: As a long run matter, a significant, sustained expansion of
Fed credit initiatives beyond, ordinary, temporary last resort lending to
depository institutions is incompatible with Fed independence. The Fed
should adhere to a “Treasuries only” asset acquisition policy except for
occasional and limited discount window lending to depository institutions
deemed to be solvent.
Principle 2: The Treasury and the Fed should agree to cooperate, as
soon as the current credit turmoil allows, to shrink the central bank’s lending
reach by letting Fed credit programs run off or by moving them from the
Fed’s balance sheet to be managed elsewhere. Any further expansion of Fed
credit programs in the current turmoil should be undertaken by agreement
with the Treasury to minimize the risk of committing to a course of action
that proves subsequently to be ill-advised.
22
Principle 3: The Fed has employed monetary policy in the service of
credit policy in the current emergency by creating around 800 billion dollars
of bank reserves to finance its credit initiatives, with the possibility of more
to come before the credit turmoil ends. The Treasury and the Fed should
cooperate to guarantee that the use of monetary policy for the fiscal purpose
of funding credit policy does not undermine price stability.
Principle 4: To strengthen the nation’s commitment to price stability,
the Treasury and the Fed should agree on a low long run inflation objective.
Anchoring inflation expectations will improve the effectiveness of monetary
policy and hold down the inflation premium in long-term Treasury bond
rates.
Principle 5: The Treasury should help the Fed, by seeking
congressional legislation if necessary, to secure the capacity of interest on
reserves to provide a fully credible exit strategy from the zero bound on
interest rate policy, regardless of the Fed’s credit policy commitments or the
size of its balance sheet. Specifically, the fiscal authorities should support
interest rate policy by (1) allowing every institution that holds balances at
the Fed and trades in the federal funds market to receive the rate of interest
that the Fed pays on the reserves of depository institutions, and (2) allowing
the Fed to retain interest income to build up surplus capital enough to
finance the payment of interest on reserves and any operating expenses in
the event of adverse cash flow problems.
Principle 6: The credibility and effectiveness of monetary policy to act
aggressively against deflation at the zero bound requires that the Fed and the
public are both confident that interest rate policy can exit the zero bound
promptly and aggressively against inflation if need be, whatever the Fed’s
credit policy commitments. The Treasury and the Fed should agree promptly
to cooperate according to the above principles so that the Fed can act
preemptively, flexibly, and aggressively against either rising inflation or a
deepening contraction and deflation, if either demands Fed action.
23
References
Andrews, A. L., M. J. de la Merced, and M. W. Walsh, “Fed’s $85 Billion
Loan Rescues Insurer, The New York Times, September 17, 2008, page 1.
Armantier, O., S. Krieger, and J. McAndrews, “The Term Auction Facility,”
Current Issues in Economics and Finance, Federal Reserve Bank of New
York (July 2008), pp. 1-9.
Blackstone, B. and P. Yoest, “Bailouts Turn Up Heat on Fed Chief,” The
Wall Street Journal.com, September 18, 2008
Board of Governors of the Federal Reserve System, Monetary Policy Report
to Congress, February 24, 2009.
Broaddus, J. A. and M. Goodfriend, “What Assets Should the Federal
Reserve Buy?” Federal Reserve Bank of Richmond Economic Quarterly
(Winter 2001), pp. 7-22.
Campbell, J.Y., A.W. Lo, and A.C. MacKinlay, The Econometrics of
Financial Markets, Princeton: Princeton University Press, 1997.
Geithner, T., “Actions by the New York Fed in Response to Liquidity
Pressures in Financial Markets” (Testimony), Federal Reserve Bank of New
York, April 3, 2008.
Goodfriend, M. “Interest on Reserves and Monetary Policy,” Federal
Reserve Bank of New York Policy Review, (May 2002), pp. 77-84.
___________, “Overcoming the Zero Bound on Interest Rate Policy,”
Journal of Money, Credit, and Banking, Vol. 32, No.4, Part 2 (November
2000), pp. 1007-1035.
___________, “Why We Need an Accord for Federal Reserve Credit
Policy,” Journal of Money, Credit, and Banking (August 1994), pp. 572-80.
Goodfriend, M. and J. Lacker, “Limited Commitment and Central Bank
Lending,” Federal Reserve Bank of Richmond Economic Quarterly, ( Fall
1999), pp. 1-27.
24
Economist, “America’s Bail-out Plan: The Doctors’ Bill,” September 25,
2008
Hetzel, R. “The Treasury-Fed Accord: A New Narrative Account,” Federal
Reserve Bank of Richmond Economic Quarterly, (Winter 2001), pp. 33-64.
Hilsenrath, J., D. Solomon, and D. Paletta, “Crisis Mode: Paulson, Bernanke
Strained for Consensus in Bailout,” The Wall Street Journal.com, November
10, 2008.
Keister, T., A. Martin, and J. McAndrews, “Divorcing Money from
Monetary Policy,” Federal Reserve Bank of New York Policy Review
(September 2008), pp. 41-56.
Lacker, J., “Government Lending and Monetary Policy (speech),” Federal
Reserve Bank of Richmond, March 2, 2009
Morrison, G., Liquidity Preferences of Commercial Banks, Chicago:
University of Chicago Press, 1966.
Paulson, H., Letter to Timothy Geithner, March 17, 2008.
Plosser, C., “Ensuring Sound Monetary Policy in the Aftermath of the Crisis
(speech), “ Federal Reserve Bank of Philadelphia, February 27, 2009
Schwartz, A. “The Misuse of the Fed’s Discount Window,” Federal Reserve
Bank of St. Louis Economic Review (September/October 1992), pp. 58-69.
Stein, H. “The Liberation of Monetary Policy,” in The Fiscal Revolution in
America, Chicago: University of Chicago Press, 1969, pp. 241-80.
Volcker, P., “Remarks by Paul Volcker at a Luncheon of the Economic Club
of New York,” April 8, 2008."