Showing posts with label Bernanke Speech. Show all posts
Showing posts with label Bernanke Speech. Show all posts

Tuesday, June 9, 2009

Monetary ease lowers interest rates in the short run but raises them in the long run

TO BE FILED:

"Remarks by Governor Ben S. Bernanke
At the Federal Reserve Bank of Dallas Conference on the Legacy of Milton and Rose Friedman's Free to Choose, Dallas, Texas
October 24, 2003

It is an honor and a pleasure to have this opportunity, on the anniversary of Milton and Rose Friedman's popular classic, Free to Choose, to speak on Milton Friedman's monetary framework and his contributions to the theory and practice of monetary policy. About a year ago, I also had the honor, at a conference at the University of Chicago in honor of Milton's ninetieth birthday, to discuss the contribution of Friedman's classic work with Anna Schwartz, A Monetary History of the United States (Bernanke, 2002). I mention this earlier talk not only to indicate that I am ready and willing to praise Friedman's contributions wherever and whenever anyone will give me a venue, but also because of the critical influence of A Monetary History on both Friedman's own thought and on the views of a generation of monetary policymakers.

In their Monetary History, Friedman and Schwartz reviewed nearly a century of American monetary experience in painstaking detail, providing an historical analysis that demonstrated the importance of monetary forces in the economy far more convincingly than any purely theoretical or even econometric analysis could ever do. Friedman's close attention to the lessons of history for economic policy is an aspect of his approach to economics that I greatly admire. Milton has never been a big fan of government licensing of professionals, but maybe he would make an exception in the case of monetary policymakers. With an appropriately designed licensing examination, focused heavily on the fine details of the Monetary History, perhaps we could ensure that policymakers had at least some of the appreciation of the lessons of history that always informed Milton Friedman's views on monetary policy.

Today I will pass over Friedman's contributions to our knowledge of monetary history and focus instead on how his ideas have influenced our understanding both of how monetary policy works and how it should be used. That is, I will discuss both the positive and the normative implications of Friedman's thought. The usual disclaimer applies, that is, I speak for myself and not necessarily for my colleagues at the Federal Reserve.

In preparing this talk, I encountered the following problem. Friedman's monetary framework has been so influential that, in its broad outlines at least, it has nearly become identical with modern monetary theory and practice. I am reminded of the student first exposed to Shakespeare who complained to the professor: "I don't see what's so great about him. He was hardly original at all. All he did was string together a bunch of well-known quotations." The same issue arises when one assesses Friedman's contributions. His thinking has so permeated modern macroeconomics that the worst pitfall in reading him today is to fail to appreciate the originality and even revolutionary character of his ideas, in relation to the dominant views at the time that he formulated them.

To illustrate, I begin with the descriptive or positive side of Friedman's work on monetary policy. Here is a short summary of Friedman's own list of eleven key monetarist propositions, as put forth in the conclusion to his 1970 (note well that date) lecture, "The Counter-Revolution in Monetary Theory." These propositions are a reasonable description, I believe, of Friedman's basic views on how money affects the economy. Here they are (in my summary of slightly more detailed language in the original):

  1. There is a consistent though not precise relationship between the rate of growth of money and the rate of growth of nominal income.
  2. That relationship is not obvious, however, because there is a lag between money growth and nominal income growth, a lag that itself can be variable.
  3. On average, however, the lag between money growth and nominal income growth is six to nine months.
  4. The change in the rate of nominal income growth shows up first in output and hardly at all in prices.
  5. However, with a further lag of six to nine months, the effects of money growth show up in prices.
  6. Again, the empirical relationship is far from perfect.
  7. Although money growth can affect output in the short run, in the long run output is determined strictly by real factors, such as enterprise and thrift.
  8. Inflation is always a monetary phenomenon, in the sense that it can be produced only by money growth more rapid than output. However, there are many possible sources of money growth.
  9. The inflationary impact of government spending depends on its financing.
  10. Monetary expansion works by affecting prices of all assets, not just the short-term interest rate.
  11. Monetary ease lowers interest rates in the short run but raises them in the long run.
Let me emphasize again that these propositions reflected Friedman's view as of some thirty-five years ago. At the time, they were far from being the conventional wisdom, as suggested by the term "Counter-Revolution" in the essay's title. What do we make of these propositions today?

First, the empirical description of the dynamic effects of money on the economy given in the first six propositions would be viewed by most policymakers and economists today as being, as the British would put it, "spot on." As a minor illustration of this point, in my own academic research I contributed to a large modern econometric literature that has used vector autoregression and other types of time series models to try to quantify how monetary policy affects the economy. The economic dynamics estimated by these methods correspond very closely to those outlined in Friedman's propositions.

These methods confirm that a monetary expansion (for example) leads with a lag of one to two quarters to an increase in nominal income. Perhaps more importantly, as Friedman emphasized, the responses of the quantity and price components of nominal income have distinctly different timing. In particular, as Friedman told us, a monetary expansion has its more immediate effects on real variables such as output, consumption, and investment, with the bulk of these effects occurring over two to three quarters. (I was going to say, as Friedman first told us, but perhaps the credit for that should go to David Hume. Milton's work is, after all, part of a long and great tradition of classical monetary analysis.) These real effects tend to dissipate over time, however, so that at a horizon of twelve to eighteen months the effects of a monetary expansion or contraction are felt primarily on the rate of inflation. The same patterns have been found in empirical studies for virtually all countries, not only by vector autoregression analysis but by more structural methods as well. They are reflected in essentially all contemporary econometric models used for forecasting and policy analysis, such as the FRBUS model at the Federal Reserve. The lag between monetary policy changes and the inflation response is the reason that modern inflation-targeting central banks, such as the Bank of England, set a horizon of up to two years for achieving their inflation objectives.

Thus Friedman's description of the economic dynamics set in train by a monetary expansion or contraction, summarized in his first six propositions, has been largely validated by modern research. What about the other propositions? Friedman's seventh point, that money affects real outcomes in the short run but that in the long run output is determined entirely by real factors, such as enterprise and thrift, is of particular importance for both theory and policy. The proposition that money has no real effects in the long run, referred to as the principle of long-run neutrality, is universally accepted today by monetary economists. When Friedman wrote, however, the conventional view held that monetary policy could be used to affect real outcomes--for example, to lower the rate of unemployment--for an indefinite period. The idea that monetary policy had long-run effects--or, in technical language, that the Phillips curve relationship between inflation and unemployment could be exploited in the long run--proved not only wrong but quite harmful. Attempts to exploit the Phillips curve tradeoff, which persisted despite Friedman's warnings in his 1968 presidential address to the American Economic Association, contributed significantly to the Great Inflation of the 1970s--after the Great Depression, the second most serious monetary policy mistake of the twentieth century.

The diagnosis of inflation in Friedman's eighth proposition, also controversial when he wrote, is likewise widely accepted today. Of course, as we all know, Friedman noted the close connection between inflation and money growth, though carefully acknowledging that excessive money growth could have many causes. As Milton and Rose discussed in Chapter 9 of the 1980 edition of Free to Choose, popular views in the 1960s and 1970s (and even the views of some Federal Reserve officials) held that inflation could arise from a variety of non-monetary sources, including the power of unions and corporations and the greediness of oil-producing countries. An unfortunate implication of these views, whose deficiencies were revealed by bitter experience under President Nixon, was that wage-price controls and other administrative measures could successfully address inflation. We understand today that the Great Inflation would simply not have been possible without the excessively expansionist monetary policies of the late 1960s and 1970s.

Some of Friedman's descriptive propositions remain the subject of active research. For example, much research has investigated both theoretically and empirically the interactions of fiscal policy, monetary policy, and inflation. Friedman's view that fiscal deficits are inflationary only if they result in money creation, his ninth proposition, remains broadly accepted, but work by scholars such as Thomas Sargent, Neil Wallace, and Michael Woodford has shown that these links can be subtle. For example, Sargent and Wallace's "unpleasant monetarist arithmetic" suggested that a near-term tightening of monetary policy, by making the long-term fiscal situation less tenable, could (in principle at least) lead to inflation, because the public will anticipate that the fiscal deficit must be financed eventually by money creation. More recently, Woodford's fiscal theory of the price level suggests that nonsustainable fiscal policies can drive inflation, even if the central bank resists monetization. Following Woodford, Olivier Blanchard has recently argued that tight money policies in Brazil, by raising the government's financing costs and thus worsening the fiscal situation, might have had inflationary consequences. Although this subsequent work has refined our understanding of the relationship between monetary and fiscal policy, these analyses are not inconsistent with the spirit of monetarist propositions, which place the blame for inflation on overissuance of nominal government liabilities.

Another area of pressing current interest derives from Friedman's tenth proposition, that monetary policy works by affecting all asset prices, not just the short-term interest rate. This classical monetarist view of the monetary transmission process has become highly relevant in Japan, for example, where the short-term interest rate has reached zero, forcing the Bank of Japan to use so-called quantitative easing methods. The idea behind quantitative easing is that increases in the money stock will raise asset prices and stimulate the economy, even after the point that the short-term nominal interest rate has reached zero. There is some evidence that quantitative easing has beneficial effects (including evidence drawn from the Great Depression by Chris Hanes and others), but the magnitude of these effects remains an open and hotly debated question.

The only aspect of Friedman's 1970 framework that does not fit entirely with the current conventional wisdom is the monetarists' use of money growth as the primary indicator or measure of the stance of monetary policy. Clearly, monetary policy works in the first instance by affecting the supply of bank reserves and the monetary base. However, in the financially complex world we live in, money growth rates can be substantially affected by a range of factors unrelated to monetary policy per se, including such things as mortgage refinancing activity (in the short run) and the pace of financial innovation (in the long run). Hence, it would not be safe to conclude (for example) that the recent decline in M2 is indicative of a tight-money policy by the Fed.

The imperfect reliability of money growth as an indicator of monetary policy is unfortunate, because we don't really have anything satisfactory to replace it. As emphasized by Friedman (in his eleventh proposition) and by Allan Meltzer, nominal interest rates are not good indicators of the stance of policy, as a high nominal interest rate can indicate either monetary tightness or ease, depending on the state of inflation expectations. Indeed, confusing low nominal interest rates with monetary ease was the source of major problems in the 1930s, and it has perhaps been a problem in Japan in recent years as well. The real short-term interest rate, another candidate measure of policy stance, is also imperfect, because it mixes monetary and real influences, such as the rate of productivity growth. In addition, the value of specific policy indicators can be affected by the nature of the operating regime employed by the central bank, as shown for example in empirical work of mine with Ilian Mihov.

The absence of a clear and straightforward measure of monetary ease or tightness is a major problem in practice. How can we know, for example, whether policy is "neutral" or excessively "activist"? I will return to this issue shortly.

Besides describing the effects of money on the economy, Friedman also made recommendations for monetary policy--the normative part of his framework. I will discuss just three of the most important of these.

First, Friedman has emphasized the Hippocratic principle for monetary policy: "First, do no harm." Chapter 9 of Free to Choose contains a famous quote of John Stuart Mill, as follows: "Like many other kinds of machinery, (money) only exerts a distinct and independent influence of its own when it gets out of order." On this quote, Milton and Rose commented: "Perfectly true, as a description of the role of money, provided we recognize that society possesses hardly any other contrivance that can do more damage when it gets out of order."

Friedman's emphasis on avoiding monetary disruptions arose, like many of his other ideas, from his study of U.S. monetary history. He had observed that, in many episodes, the actions of the monetary authorities, despite possibly good intentions, actively destabilized the economy. The leading case, of course, was the Great Depression, or as Friedman and Schwartz called it, the Great Contraction, in which the Fed's tightening in the late 1920s and (most importantly) its failure to prevent the bank failures of the early 1930s were a major cause of the massive decline in money, prices, and output. It is likely that Friedman's study of the Depression led him to look for means, such as his proposal for constant money growth, to ensure that the monetary machine did not get out of order. I hope, though of course I cannot be certain, that two decades of relative monetary stability have not led contemporary central bankers to forget the basic Hippocratic principle.

A second normative recommendation, worth recalling here, was Friedman's preference for floating rather than fixed exchange rates. At times, at least in popular writing, Friedman rationalized this position as following from free market principles. This argument is a bit disingenuous, I think, as a fixed nominal exchange rate is just one method of anchoring the aggregate price level and is perfectly consistent with free adjustment of the relative prices of goods and services. In a more serious vein, Friedman understood that, in a world in which monetary policymakers put domestic economic stability above balance of payments considerations, a fixed exchange rate system is likely to be unstable during periods of economic stress. He saw that this was the case during the 1930s, when the world was on a modified gold standard called the gold exchange standard, and it was likewise the case under the postwar Bretton Woods system. To reconcile a fixed exchange rate and an emphasis on domestic stability, policymakers must impose capital controls or restrictions on trade, which have undesirable effects on economic efficiency.

If policymakers' first priority is stability of the domestic economy, Friedman reasoned, then why not adopt a system--namely, flexible exchange rates--that provides the necessary monetary independence without restrictions on the flow of capital or goods? When Friedman wrote about fixed and flexible exchange rates, a switch from the Bretton Woods fixed-exchange-rate system to a floating-rate system seemed quite unlikely. In this, as in many other matters, he was prescient, as the major currencies have now been successfully floating since the breakup of the Bretton Woods system in the early 1970s.

These two recommendations have had major effects on institutional design and policy practice. However, in my view, the most fundamental policy recommendation put forth by Milton Friedman is the injunction to policymakers to provide a stable monetary background for the economy. I take this to be a stronger statement than the Hippocratic injunction to avoid major disasters; rather, there is a positive argument here that monetary stability actively promotes efficiency and growth. (Hence Friedman's suggestion that the long-run Phillips curve, rather than vertical, might be positively sloped.) Also implicit in Friedman's focus on nominal stability is the view that central banks should avoid excessively ambitious attempts to manage the real economy, which in practice may exacerbate both nominal and real volatility. In Friedman's classic 1960 work, A Program for Monetary Stability, he suggested that monetary stability might be attained by literally keeping money stable: that is, by fixing the rate of growth of a specific monetary aggregate and forswearing the use of monetary policy to "fine-tune" the economy.

Do contemporary monetary policymakers provide the nominal stability recommended by Friedman? The answer to this question is not entirely straightforward. As I discussed earlier, for reasons of financial innovation and institutional change, the rate of money growth does not seem to be an adequate measure of the stance of monetary policy, and hence a stable monetary background for the economy cannot necessarily be identified with stable money growth. Nor are there other instruments of monetary policy whose behavior can be used unambiguously to judge this issue, as I have already noted. In particular, the fact that the Federal Reserve and other central banks actively manipulate their instrument interest rates is not necessarily inconsistent with their providing a stable monetary background, as that manipulation might be necessary to offset shocks that would otherwise endanger nominal stability.

Ultimately, it appears, one can check to see if an economy has a stable monetary background only by looking at macroeconomic indicators such as nominal GDP growth and inflation. On this criterion it appears that modern central bankers have taken Milton Friedman's advice to heart. Over the past two decades, inflation has fallen sharply and stabilized around the world, not only in the industrialized nations but in emerging-market economies and in even the poorest developing nations. Some central banks, so-called inflation targeters, have set explicit, quantitative targets for inflation; but all central banks, certainly including the Federal Reserve, have emphasized the importance of achieving and maintaining price stability. On the issue of inflation control, Friedman may be judged to have been a bit too pessimistic; his concerns that central banks would have neither the technical ability nor the correct incentives to control inflation led him to recommend his money-growth rule, for which a central bank could certainly be held accountable. Evidently, however, determined central banks can stabilize inflation directly, at least they have been able to do so thus far.

However, on the benefits of monetary stability, or as I would prefer to say, nominal stability, Friedman was not wrong. Many theories popular even today might lead one to conclude that increased stability in inflation could be purchased only at the cost of reduced stability in output and employment. In fact, over the past two decades, increased inflation stability has been associated with marked increases in the stability of output and employment as well, both in the United States and elsewhere.

It has been argued that a lower incidence of exogenous shocks explains these favorable developments, and that may be part of the story. But I believe that there is an important causal relationship as well. For example, low and stable inflation has not only promoted growth and productivity, but it has also reduced the sensitivity of the economy to shocks. One important mechanism has been the anchoring of inflation expectations. When the public is confident that the central bank will maintain low and stable inflation, shocks such as sharp increases in oil prices or large exchange rate movements tend to have at most transitory price-level effects and do not result in sustained inflationary surges. In contrast, when inflation expectations are poorly anchored, as was the case in the 1970s, shocks of these types can destabilize inflation expectations, increasing the inflationary impact and leading to greater volatility in both inflation and output.

In summary, one can hardly overstate the influence of Friedman's monetary framework on contemporary monetary theory and practice. He identified the key empirical facts and he provided us with broad policy recommendations, notably the emphasis on nominal stability, that have served us well. For these contributions, both policymakers and the public owe Milton Friedman an enormous debt."

Wednesday, June 3, 2009

he wants to push fiscal sustainability issues clearly away from the Fed’s domain and back where they belong, with Congress and the administration

From Alphaville:

"
El-Erian: Bernanke and the “new normal”

Pimco’s Mohamed El-Erian kindly provided FT.com with a snap commentary on Ben Bernanke’s congressional testimony on Wednesday.

Extract:

The bottom line is that we should come away from Mr Bernanke’s testimony with at least two conclusions: the chairman seems more cautious about the growth outlook when compared with other recent public statements; and he wants to push fiscal sustainability issues clearly away from the Fed’s domain and back where they belong, with Congress and the administration.

Related links:
Why Bernanke is right to be worried
- FT
Bernanke calls for action on deficits
- FT

Me:

Don the libertarian Democrat Jun 3 22:48
The import of Bernanke's statement is not what El-Erian says. That's what he and William Gross seem to believe. Instead, Bernanke is saying that QE or CE and the Stimulus are working, and reinforcing each other. The fact that we have low short term rates and rising longer term rates is how it's supposed to work. It's even a net positive to have the hyperventilating on hyperinflation, since it signals that we will have some inflation going forward. We need the perception of some inflation going forward for QE or CE to work.

Of course, down the road, inflation will be the worry, not, thankfully, deflation. Dealing with the issue will involve three possibilities:
1) Default
2) Printing Money Excessively
3) Having Congress deal with tax increases, spending cuts, selling assets, etc.
Clearly, he would like to see 3 be the answer going forward. Many of us do. Bernanke and Geithner are both saying the right things. Namely, it's really up to Congress to deal with this problem going forward. It's not a big economic conundrum, but it is a big political problem. That's what Bernanke actually said.

If you receive no post from Bernanke denying my theory, you can infer his implicit, if not explicit, agreement with my interpretation.

From the FT:

"Why Bernanke is right to be worried

By Mohamed El-Erian

Published: June 3 2009 17:21 | Last updated: June 3 2009 17:21

Fed chairman Ben Bernanke’s congressional testimony on Wednesday warrants careful attention by market participants – this at a time when policy measures play an unusually large role in determining both absolute and relative values in many markets.

In his prepared written remarks, Mr Bernanke correctly points to the ongoing healing in critical elements of the financial markets, including inter-bank and commercial paper transactions. He also notes the improved functioning of the corporate credit market which has enabled many companies to raise needed and precautionary capital.

Yet, the most interesting aspects of his testimony are elsewhere. They relate to his more nuanced outlook about the economy and his attempt to place fiscal issues in their proper place.

Mr Bernanke acknowledges that, despite the ”green shoots”, there are still question mark over which components of demand will kick into gear once the cyclical inventory pick-up runs its course, as it will inevitably do so over the next few months. Indeed, the chairman notes that ”businesses remain very cautious and continue to reduce their workforces and capital investments.”

Concerns about a sustainable recovery are not limited to the dynamics of the immediate cyclical recovery. Mr Bernanke also notes that ”even after a recovery gets under way, the rate of growth of real economic activity is likely to remain below its longer-run potential for a while, implying that the current slack in resource utilisation will increase further.”

Yet he stops short of addressing what, increasingly, will be on many people’s minds going forward. Specifically, the longer-term question goes well beyond the notion of a prolonged period of below-potential growth. The level of potential growth itself is likely to decline. Indeed, this is a central element of what we, at Pimco, call the ”new normal”.

When it comes to fiscal issues, the chairman is not timid about worrying about longer-term questions – and rightly so. He is explicit about the need for greater clarity on how fiscal sustainability will be restored after this period of emergency policy actions.

Mr Bernanke states that ”even as we take steps to address the recession and threats to financial stability, maintaining the confidence of the financial markets requires that we, as a nation, begin planning now for the restoration of fiscal balance. Prompt attention to questions of fiscal sustainability is particularly critical because of the coming budgetary and economic challenges associated with the retirement of the baby-boom generation and continued increases in medical costs.”

He does not stop here. He goes on to warn that ”near-term challenges must not be allowed to hinder timely consideration of the steps needed to address fiscal imbalances. Unless we demonstrate a strong commitment to fiscal sustainability in the longer term, we will have neither financial stability nor healthy economic growth.”

These are strong words, and appropriately so given the worrisome fiscal outlook facing the US. By necessity, Mr Bernanke will increasingly be in the business of countering monetisation and inflation concerns.

Indeed, the markets have already fired a couple of clear warning shots in the last couple of weeks, as illustrated by recent moves in US bonds and the dollar.

The chairman’s challenges on this count are neither easy nor amenable to quick solutions. Moreover, as markets increasingly look into the underlying factors, as inevitably they will, they will recognise the difficulty that the government faces in credibly committing to the needed primary fiscal adjustment in the absence of high economic growth.

The bottom line is that we should come away from Mr Bernanke’s testimony with at least two conclusions: the chairman seems more cautious about the growth outlook when compared with other recent public statements; and he wants to push fiscal sustainability issues clearly away from the Fed’s domain and back where they belong, with Congress and the administration. He is correct on both counts. He would have been justified on Wednesday in being even more forceful; and he mostly probably will be in the next few months.

The writer is chief executive and co-chief investment officer of Pimco. His book ‘When Markets Collide: Investment Strategies for the Age of Global Economic Change’ won the 2008 FT/Goldman Sachs Business Book of the Year



Still, it’s a little disconcerting to see the Fed chairman talk so freely about fiscal policy

From Reuters:

"
Felix Salmon

nonrival, nonexcludable

June 3rd, 2009

Bernanke’s fiscal focus

Posted by: Felix Salmon
Tags: fiscal and monetary policy

Ben Bernanke’s testimony to Congress today starts with 7 paragraphs on general economic conditions, continues with five more paragraphs on the state of the financial sector, and then has six important paragraphs on fiscal policy. Finally, at the end, he spends one paragraph talking about what the Fed is doing in terms of monetary policy and quantitative easing.

This is reasonable enough: after having hit the zero bound, there’s not much which can be said about monetary policy, and fiscal policy is going to be the main driver of America’s standing in the international financial markets going forwards. What’s more, for the past couple of years the Fed has been working hand-in-glove with Treasury: the distinction between fiscal and monetary policy, and the independence of the central bank, have gone by the wayside (quite properly, I might add, contra Angela Merkel) in a time of crisis.

Still, it’s a little disconcerting to see the Fed chairman talk so freely about fiscal policy: now we’ve reached this point, it’s going to be hard to stop him talking this way, even after the crisis is over. And the distinction between the Fed chairman and the Treasury secretary is a useful one, which really should be maintained.

Update: James Pethokoukis, for one, seems to think that the Fed’s actions are divorced from the Obama administration’s economic policy. It’s not clear why.

Me:
“These increases appear to reflect concerns about large federal deficits but also other causes, including greater optimism about the economic outlook, a reversal of flight-to-quality flows, and technical factors related to the hedging of mortgage holdings.”

This means that he agrees that the policy of QE and a Stimulus are working. He’s right. Here’s how it works:

From my point of view, this is how you want QE to work against Debt-Deflation, which is a panic phenomenon.
1) Low Short Term Interest Rates, as a disincentive to buy guaranteed assets, and an incentive to buy stocks and corporate bonds. This attacks the Fear and Aversion to Risk.
2) Rising Longer Term Interest Rates, which signal an end to Deflationary Fears, and are an incentive for Longer Term Investing.As well, as you say, the Spread often ( which is as exact as this gets ) signals a recovery.

Now, what’s interesting, is that I take it that this is what Bernanke and Geithner have been arguing, although not necessarily saying it the way I do. And, in fact, it seems to be working, which , again, is about as good as it gets, since none of us know the future.

Yet, as obvious as this is to me, others have been puzzled by this line of reasoning. I, on the other hand, do not understand the point of having interest rates move in tandem, insofar as incentives are concerned.

I understand the idea of rising interest rates being a problem, but the Fed has other means of addressing mortgages, in coordination with other parts of the government. However, I am not for keeping interest rates of mortgages artificially low at all, but certainly feel that this policy should now end. We need to see a plausible bottom on housing prices, without the perception of government still keeping housing prices artificially high.

Of course, Inflation will be the issue going forward, but I prefer that to a Debt-Deflationary Spiral. Call me silly, I guess.

The stimulus:
Tax Cuts as incentives against the Fear and Aversion to Risk.
Infrastructure Spending showing long term confidence in the future.
Current spending, to battle the Savings Spree, also an aspect of the Fear and Aversion to Risk.

These measures are working, combined with a Government Guarantee backing the entire process. As Brad De Long has pointed out, this was the position of Frank Knight, Jacob Viner, Henry Simons, and Irving Fisher, during the Great Depression. It was called the Chicago Plan, I believe. It argued that a Stimulus and QE reinforce each other. They were correct. That’s what we’re seeing.

Nick Rowe wonders how we can tell which of the plans matter more, the Stimulus or QE. We can’t. All we can say is that it seems to be working. That’s as good as it gets.

I believe that this is Bernanke and Geithner’s view. I also believe that Geithner’s view, that we should have guaranteed everything at the outset of the crisis, was correct, and, quite frankly, helps him in dealing with China, because that is China’s position.

Perhaps people who disagree with this could list criteria that they would accept for showing that QE and the Stimulus are working or not. Otherwise, they’re merely stating the obvious, which is that it’s deucedly hard to disentangle the causal factors in this mess. As Wittgenstein says:

“At the end of reasons comes persuasion.”

Today, Martin Wolf argues much the same view, I hope, since I’ve just said that he does. As long as he’s making sense, I don’t care what Bernanke talks about.

- Posted by Don the libertarian Democrat

“Later George panics when a small fire breaks out and he rushes away, pushing down children, senior citizens, and the clown in the process. He tries to justify his behavior by saying how he acted bravely, like a “leader.”

This is the US. In a panic, niceties like the freedom of the Fed will be tossed aside without regret or remorse. Call it “The Costanza Response”.

- Posted by Don the libertarian Democrat

Monday, May 11, 2009

banking system's return to health with a sharply diminished reliance on government capital

TO BE NOTED:

"
Chairman Ben S. Bernanke

At the Federal Reserve Bank of Atlanta 2009 Financial Markets Conference, Jekyll Island, Georgia

May 11, 2009

The Supervisory Capital Assessment Program

My remarks this evening will focus on the Supervisory Capital Assessment Program, popularly known as the banking stress test. The federal bank regulatory agencies began the assessment program in late February and concluded their review with the release of the results just last Thursday. This initiative involved an unprecedented, simultaneous supervisory review of the 19 largest bank holding companies in the United States. Its objective was to ensure that these institutions have sufficient financial strength to absorb losses and to remain strongly capitalized, even in an economic environment more severe than currently anticipated. A well-capitalized banking system is essential for the revival of the credit flows that will underpin a sustainable economic recovery.

Objectives of Supervisory Capital Assessment Program
As you know, the abrupt end of the credit boom in 2007 has had widespread financial and economic ramifications, including a sharp slowdown in global economic activity and the imposition of substantial losses on banks and other financial institutions. Economic and financial weaknesses have fed on each other, as a declining economy has exacerbated credit losses and the resulting pressure on banks and other financial institutions has constrained the availability of new credit.

A number of significant steps have been taken to restore confidence in the nation's financial institutions, including a substantial expansion of guarantees for bank liabilities by the Federal Deposit Insurance Corporation (FDIC), injections of capital by the Treasury in many institutions both large and small, and Federal Reserve programs to provide liquidity to financial institutions and support the normalization of key credit markets. These efforts averted serious threats to global financial stability last fall and have contributed to gradual improvement in key credit markets, though many markets remain stressed.

These steps, however, did not fully address market concerns over the depletion of bank capital caused by write-downs and increased reserving for potential losses. At the beginning of this episode, bank losses were focused in a few asset classes, such as subprime mortgages and certain complex credit products. Today, following the significant weakening in the global economy that began last fall, concerns have shifted to more-traditional credit risks, including rising delinquencies on prime as well as subprime mortgages, unpaid credit card and auto loans, worsening conditions in commercial real estate markets, and increased rates of corporate bankruptcy.

The loss of confidence we have seen in some banking institutions has arisen not only because market participants expect the future loss rates on many banking assets to be high, but because they also perceive the range of uncertainty surrounding estimated loss rates as being unusually wide. The capital assessment program was designed to reduce this uncertainty by conducting a stringent, forward-looking assessment of prospective losses at major banking organizations. The objective was to identify the extent to which each of the 19 firms is vulnerable today to a weaker-than-expected economy in the future, and to measure how much of an additional capital buffer, if any, each firm would need to establish now to withstand the potential losses in more-adverse economic conditions.

To make this assessment, we began by stipulating a hypothetical, adverse economic scenario, under which growth, unemployment, and house-price outcomes were assumed to be more unfavorable than those implied by the consensus of private-sector forecasters. Using this hypothetical adverse scenario, examiners were asked to estimate the range of possible losses that our largest and most important banking organizations could experience over the next two to three years, as well as the resources, such as earnings and reserves, that those organizations would have available to offset those losses. It is important to note that this was not a solvency test. After including capital previously provided by the Treasury, all of these banking organizations currently have capital well in excess of the minimum stated capital requirements of the supervisors. Instead, the purpose of the exercise was to determine the size of the capital cushion that each organization would need to remain well capitalized and still be able to lend--even in an economic scenario more severe than expected.

We have now learned through this process that, if the economy were to track the more adverse scenario, additional losses at the 19 firms during 2009 and 2010 could total about $600 billion. After taking account of potential resources to absorb those losses, including expected revenues, reserves, and existing capital cushions, we determined that 10 of the 19 institutions will require, collectively, common or contingent common equity of $185 billion to ensure adequate capital cushions. Of this amount, the equivalent of $110 billion has already been raised or is contractually committed to be in place, or to a lesser degree reflects first-quarter pre-provision earnings above those assumed in the initial supervisory estimates. Consequently, the remaining common equity buffer that must be raised is $75 billion. The firms that are determined to need an additional capital buffer will have 30 days to develop a capital plan to be approved by their supervisors and six months to implement that plan. We have strongly encouraged institutions requiring additional capital to obtain it through private means, including, for example, new equity issues, conversions, exchange offers, or sales of businesses or other assets. To ensure that all of these firms can build the needed capital cushions, however, the Treasury has made a firm commitment to provide contingent common equity, in the form of mandatory convertible preferred stock, as a bridge to obtaining private capital in the future. Banking organizations will also have the option to exchange their existing preferred stock, issued under Treasury's earlier Capital Purchase Program, for the new contingent common equity. The Treasury has indicated that it expects that any such exchange will be either accompanied or preceded by new capital raises or the conversion of private capital securities into common equity.

Process and Methodology
To properly understand the results of the capital assessment program, it is helpful to understand the process that produced the results. All U.S.-owned bank holding companies with year-end 2008 assets exceeding $100 billion were required to participate in the program. These 19 firms collectively hold two-thirds of the assets and more than one-half of the loans in the U.S. banking system, supporting a very significant portion of credit intermediation in the United States. The assessment process can perhaps best be characterized as a simultaneous examination of 19 large bank holding companies that addressed all major categories of assets as well as revenue expectations.

The assessment was a resource-intensive undertaking, involving extraordinary efforts by more than 150 examiners and analysts from the Federal Reserve, the Office of the Comptroller of the Currency (OCC), and the FDIC. These staff members conducted a detailed, firm-specific analysis over a 10-week period. Their efforts were aided by access to data and management available only to bank supervisors. The supervisors also incorporated statistical tools and quantitative models in their evaluation of each firm's data to facilitate comparative analysis across the 19 firms.

The analysis was a comprehensive one, which included an exhaustive review of loan portfolios, investment securities, trading positions, and off-balance sheet commitments. Typically, supervisory examinations focus on individual business lines or asset classes at a single firm. In this case, we simultaneously reviewed all of the major portfolios and business lines at each of the 19 firms, making unprecedented efforts to achieve methodological consistency across firms, portfolios, and supervisors.

Through it all, we tried to be as transparent as possible. The assumptions, processes, and results of the capital assessment program have been communicated in detail, taking into account legitimate supervisory and firm confidentiality concerns. We released a white paper on April 24 describing the process and methodology.1 On May 6, we provided more information on the measures used to size the required capital buffer, as well as a preview of the information that would be disclosed.2 The final release of results, this past Thursday, May 7, included the supervisory-determined indicative loss rates that were used in evaluating firm submissions, and, most importantly, aggregate and firm-specific estimates for losses, loss rates, resources to absorb losses, and the resulting capital buffer needs.3

Finally, as I have noted, the assessment was forward-looking. To project losses and offsetting resources two to three years in the future under the adverse scenario, we analyzed the historical relationships of losses and earnings to macroeconomic conditions and other determinants, and we dug deeply into cross-firm differences in portfolio compositions and vulnerabilities.

The process began in earnest in early March when each firm submitted its estimate of losses and earnings over a two-year scenario, under two alternative assumed paths for the U.S. economy. The baseline scenario reflected the consensus expectation for the economy among professional forecasters as of February 2009, and the more adverse scenario incorporated the possibility that the recession could be more severe than the consensus expectation and that house prices could fall even more sharply.

Although we began the process by asking the firms to submit their own estimates of expected losses and revenues, we by no means accepted these submissions uncritically. Senior supervisors and on-site examiners evaluated the firms' estimates to identify methodological weaknesses, missing information, over-optimistic assumptions, and other problems. Examiners had detailed conversations with bank managers, which led to numerous corrections to and modifications of the firms' submissions, including sensitivity analyses based on alternative assumptions.

As a second step, supervisors made judgmental adjustments to the firms' loss and revenue estimates. This process used both firm-specific and comparative analyses. For example, supervisors sometimes disagreed with the technical assumptions underlying a firm's loss forecast. In these cases, they adjusted the loss rates based on sensitivity analyses performed by the firm, results from other firms, and the supervisors' own expert judgments.

Third, the supervisors' judgmental assessments were supplemented by objective, model-based estimates for losses and revenues that could be applied on a consistent basis across firms. For example, we used statistical models to estimate residential mortgage losses at firms based on loan data submitted by the firms as part of the exercise. Each participating institution was asked to supply detailed information, in a standardized format, about the composition of its residential real estate portfolios, including breakdowns by type of product, loan-to-value ratio, FICO score, year of origination, and so on. These data allowed supervisors to consistently estimate potential future losses across firms using a variety of independently constructed models. Some of these models were already in use to monitor risk as part of the ongoing supervisory oversight process, while others were developed or refined specifically for the capital assessment exercise.

Similarly, to assess firms' revenue projections for 2009 and 2010, the agencies examined the components of expected revenue in detail, compared the projections to historical results, and cross-checked the underlying assumptions with projections of portfolio growth, funding costs, and the like. The agencies also used more-formal statistical analyses to develop firm-by-firm forecasts that would reflect the historical relationship between revenues and macroeconomic conditions, thereby enabling them to assess which components were less likely to be sustainable in a weaker economy. Information from all of these sources was incorporated into the final revenue projections. Finally, the supervisors systematically incorporated all of these inputs into loss, revenue, and reserve estimates for each institution.

Determining the Size of the Capital Buffer
A key question in this assessment was the appropriate size of the capital buffers that these firms would be required to hold, as well as the quality of those buffers. Recall that our analysis of the firms' financial conditions focused not on current capital levels alone but also on how capital levels might evolve over a two-year horizon, assuming a more adverse economic environment than currently anticipated. In other words, the assessment was not a forecast of expected outcomes but rather a "what-if" exercise, intended to help supervisors gauge the capital buffers needed to keep banks well capitalized and able to lend across a range of economic scenarios.

In judging the needed buffer, we understood that no single measure of capital adequacy is universally accepted or would guarantee a return of market confidence. Fortunately, our existing capital framework is well understood and addresses the key concerns that have been voiced by the market. Under our existing standards, banks are considered "well capitalized" with Tier 1 capital at 6 percent of risk-weighted assets. Using that benchmark in the context of bank holding companies, we sized the capital buffer so that each of the 19 companies would be expected to meet that threshold at year-end 2010 if the losses and revenues implied by the adverse case were realized.

In addition, common equity ratios in various guises are viewed by stockholders, bondholders, and counterparties as key measures of solvency, because common equity provides superior loss absorption and greater financial flexibility than other forms of capital. Because of these attributes of common equity, our bank holding company capital rules require that voting common stockholders' equity make up the dominant portion of Tier 1 capital elements. In the context of the assessment program, we have structured the required capital buffer to ensure that, under the adverse scenario, each of the 19 firms would have a minimum 4 percent Tier 1 Common ratio at year-end 2010. (Tier 1 Common is simply common equity subject to the same deductions from capital as are required when determining Tier 1 capital--for example, deducting goodwill.) Importantly, the "6-4" metric used to size the appropriate capital buffer does not represent a new capital standard and is not expected necessarily to be maintained on an ongoing basis. Going forward, with the required initial buffer in place, supervisors will work with banks and bank holding companies to ensure that capital levels are appropriate for the level of risk in banks' portfolios and in the economic environment.

Evaluating the Results
Projecting credit losses in an uncertain economic environment is difficult, to say the least, but the intensive, painstaking nature of this process gives us confidence in our results. In particular, we believe that our estimates of needed capital buffers are appropriately conservative. Notably, a comparison to historical loss rates shows that the loss estimates we obtained significantly exceed those experienced in past recessions. The estimated two-year cumulative losses on total loans under the more adverse scenario averaged 9.1 percent across the 19 participating bank holding companies. This two-year rate is higher than any two-year period dating back to 1920, including the historical peak loss years of the 1930s. In particular, estimated loss rates for mortgage and consumer credit are high, reflecting the combination of high unemployment and steep declines in house prices that were specified in the more adverse scenario.

Still, it is useful to know whether our estimates are consistent with what has been found by others. Two studies released within the last few weeks essentially bracketed the supervisory estimate. The International Monetary Fund estimated lifetime losses that would imply a loan loss rate for U.S. banking firms of about 8 percent in a stressed scenario.4 One of the major rating agencies estimated an annual loan loss rate of about 4-3/4 percent in a stress scenario for the next two years.5 More broadly, our informal survey of the results of a considerable number of private-sector studies and analyst reports published over the past several months generally placed our projected loss rates for key portfolios near the midpoints of the ranges of these independent estimates.

When making comparisons, it should be kept in mind that studies differed in the ways that losses were estimated and reported. Four particular sources of differences are notable.

First, studies differed in the time frames over which losses were calculated. Some outside reports included cumulative losses from the beginning of the financial crisis in mid-2007, and others included projections of losses over the lifetimes of currently held loans and securities. Our estimates are for potential losses in 2009 and 2010 and, indirectly, for 2011, through the estimate of the end-2010 loan loss reserve. Our estimates do not include the sizable losses that have already been recognized by the 19 banks--about $325 billion of loans and securities in the last six months of 2007 and in 2008--because they are already reflected in the firms' balance sheets. Moreover, while we exclude losses beyond 2011, this limit would only be material for sizing the capital buffer if those losses were expected to substantially exceed pre-provision earnings after 2011, an outcome that we do not expect.

Second, a few private-sector estimates implicitly or explicitly assumed mark-to-market or liquidation prices for loans, which effectively incorporate a substantial liquidity discount in today's market. However, because banks are portfolio lenders with core deposit funding and the ability to hold loans to maturity, our estimated valuations are based on projected cash flow credit losses related to a borrower's failure to meet its obligation, not a liquidation value.

Third, some private-sector studies may not have taken into account the markdowns in asset valuations that occurred in the context of acquisitions of other firms. In particular, in the course of acquisitions by the 19 bank holding companies in 2008, the value of troubled loans was written down by almost $65 billion.6 These potential losses should only be realized once and thus are excluded from our estimates of prospective losses for 2009 and 2010. Of course, we took full account of these writedowns in our sizing of required capital buffers.

Fourth, in contrast to some outside estimates, estimated losses for the capital assessment program are for the 19 firms, not the entire banking system. Moreover, numerous adjustments were necessary to reflect particular facts and circumstances at these firms. That level of analysis simply has not been done--nor could it be done--by outside observers without the level of access available to supervisors.

Despite the care and rigor of this process, I would be the first to acknowledge that any loss forecast is inherently uncertain. The assessment program did not address some risks that institutions still need to consider in their own internal stress tests, such as operational, liquidity, and reputational risks. For all 19 firms, and particularly those with trading and investment banking businesses, those risks are important and will need to be monitored by both the firms and the supervisors. Ideally, the stress tests used in the assessment program should be part of a broader palette of internal stress tests conducted by firms; indeed, we do not intend that the capital assessments should be taken as all that those firms need to do.

A principal goal of the capital assessment process is to help increase confidence in the banking system. In particular, if it helps reduce uncertainty among investors regarding future losses and capital needs, and thereby improves the banking system's access to private capital, one of the key objectives of the program will have been achieved. It will be some time before we can evaluate the success of the program on this criterion. However, the initial indications are encouraging. Each of the 10 banks requiring an additional capital buffer has pledged to have the necessary buffer in place by the November 9 deadline. Many of the banks are well ahead in finding private-sector options for increasing their common equity, and several have announced plans for new equity issues. In another positive sign, several have announced plans to issue long-term debt not guaranteed by the FDIC.

Lessons from the Assessment Program for the Supervisory Process
We've learned important lessons in the capital assessment process that will inform our supervisory efforts in the future. Notably, the process of comprehensively evaluating 19 major firms represented an important step forward in consolidated supervision, as it gave us insights into the challenges posed in understanding risks and exposures across complex organizations.

The cross-firm aspects of the assessment program were also instructive from a supervisory point of view. As I have mentioned, unlike traditional examinations focused on individual banks, the assessment process specifically incorporated cross-firm and aggregate analyses of a set of firms that constitute a majority of the banking system. This approach allowed a broader analysis of risks than is possible within the traditional supervisory focus on individual institutions. Supervisors evaluated loss rates for similar portfolios using consistent data and metrics, allowing them to identify outliers and more effectively evaluate the quality of individual firm estimates. The process was an iterative one, with both the firms and supervisors conducting sensitivity analyses around key assumptions.

The federal bank regulators--the Federal Reserve, OCC, and FDIC--cooperated extensively throughout this process, from the design to the implementation. In addition, within each agency, many resources across a range of skills were brought to bear. For example, quantitative experts supported examiners by incorporating statistical tools to facilitate benchmarking across institutions and to develop consistent loss estimates.

We learned from this effort that it is not a simple matter to simultaneously evaluate the consolidated risks for two-thirds of the assets in the U.S. banking system, using a common forward-looking framework and common metrics. But it was an enlightening exercise that will improve the toolkit we use to help ensure the safety and soundness not just of individual firms, but of the financial system more broadly.


Conclusion
In summary, the Supervisory Capital Assessment Program is an important element of broader and ongoing efforts by the Federal Reserve, other federal bank regulators, and the Treasury to ensure that our banking system has sufficient resources to navigate a challenging economic downturn. A collateral benefit is that many lessons of the exercise can be used to improve our supervisory processes. In particular, the supervisory capital assessment has demonstrated the benefits of using cross-firm, cross-portfolio information and the simultaneous review of a number of major firms to develop a more complete and fine-grained view of the health of the banking system.

Whether the objectives of the assessment program were achieved will only be known over time. We hope that in two or three years we will be able to reflect on the banking system's return to health with a sharply diminished reliance on government capital. More immediately, we hope and expect that the public and investors will take considerable comfort from the fact that our largest financial institutions have been evaluated in a comprehensive and rigorous fashion; and that they will, as a consequence, be required to have a capital buffer adequate to weather future losses and to supply needed credit to our economy--even if the economic downturn is more severe than is currently anticipated.


Footnotes

1. See Board of Governors of the Federal Reserve System (2009), "The Supervisory Capital Assessment Program: Design and Implementation (287 KB PDF)," white paper (Washington: Board of Governors, April 24). Return to text

2. See Board of Governors of the Federal Reserve System (2009), "Joint Statement by Secretary of the Treasury Timothy F. Geithner, Chairman of the Board of Governors of the Federal Reserve System Ben S. Bernanke, Chairman of the Federal Deposit Insurance Corporation Sheila Bair, and Comptroller of the Currency John C. Dugan: The Treasury Capital Assistance Program and the Supervisory Capital Assessment Program," joint press release, May 6. Return to text

3. See Board of Governors of the Federal Reserve System (2009), The Supervisory Capital Assessment Program: Overview of Results (333 KB PDF) (Washington: Board of Governors, May 7). Return to text

4. International Monetary Fund (2009), Global Financial Stability Report: Responding to the Financial Crisis and Measuring Systemic Risks Leaving the Board (Washington: IMF, April). Return to text

5. Standard and Poor (2009), "What Stress Tests Reveal about U.S. Banks Capital Needs," May 1. Return to text

6. Purchase accounting adjustments were recognized for Capital One Financial Corporation, JPMorgan Chase & Co., PNC Financial Services Group, Inc., and Wells Fargo & Company. Return to text"

Friday, April 17, 2009

Many of the poor underwriting practices in the subprime market were also potentially unfair and deceptive to consumers.

TO BE NOTED: From the Fed:

"
Chairman Ben S. Bernanke

At the Federal Reserve System's Sixth Biennial Community Affairs Research Conference, Washington, D.C.

April 17, 2009

Financial Innovation and Consumer Protection

The concept of financial innovation, it seems, has fallen on hard times. Subprime mortgage loans, credit default swaps, structured investment vehicles, and other more-recently developed financial products have become emblematic of our present financial crisis. Indeed, innovation, once held up as the solution, is now more often than not perceived as the problem. I think that perception goes too far, and innovation, at its best, has been and will continue to be a tool for making our financial system more efficient and more inclusive. But, as we have seen only too clearly during the past two years, innovation that is inappropriately implemented can be positively harmful. In short, it would be unwise to try to stop financial innovation, but we must be more alert to its risks and the need to manage those risks properly.

My remarks today will focus on the consumer protection issues raised by financial innovation. First, though, I want to say how pleased I am to join you for the sixth biennial Federal Reserve System Community Affairs Research Conference. We all want to see our communities grow and thrive, especially those that have been traditionally underserved. But the people in this room know as well as anyone that, when it comes to consumer protection and community development, good intentions are not enough. Hard-won knowledge, as exemplified by the empirical work presented here during the past two days, is required. I applaud your diligent and tough-minded research in analyzing what works and what doesn't. Only with such knowledge can efforts to spread prosperity more widely become increasingly effective.

Sources of Financial Innovation
Where does financial innovation come from? In the United States in recent decades, three particularly important sources of innovation have been financial deregulation, public policies toward credit markets, and broader technological change. I'll talk briefly about each of these sources.

The process of financial deregulation began in earnest in the 1970s, a period when stringent regulations limited competition and the range of product offerings in the markets for consumer credit. For example, Regulation Q, which capped interest rates on deposits, hampered the ability of depository institutions to attract funding and thus to extend credit. Restrictions on branching were a particularly significant constraint, as they limited the size of the market that individual depository institutions could service and thus their scope to reduce costs through economies of scale.1 The lifting of these regulations, especially branching restrictions, allowed the development of national banking networks. With national networks, the fixed costs of product innovation could be spread over larger markets, making the development and marketing of new products more profitable.

Many public policy decisions have affected the evolution of financial products and lending practices. One particularly important example was the Community Reinvestment Act of 1977 (CRA), which induced lenders to find ways to extend credit and provide services in low- and moderate-income neighborhoods. Another important set of policies was the government's support for the development of secondary mortgage markets, particularly through the government-sponsored enterprises, Fannie Mae and Freddie Mac. Secondary mortgage markets were rudimentary and thin in the 1970s; indeed, the Federal Reserve's Flow of Funds accounts do not even record private securitization activity until the early 1980s. As secondary mortgage markets--an important innovation in themselves--grew, they gave lenders both greater access to funding and better ability to diversify, providing further impetus to expansion into new markets and new products.

On the technological front, advances in information technology made possible the low-cost collection, processing, and dissemination of household and business financial data, functions that were once highly localized and, by today's standards, inefficiently managed.2 As credit reporting advanced, models for credit scoring gradually emerged, allowing for ever-faster evaluation of creditworthiness, identification of prospective borrowers, and management of existing accounts.

All these developments had their positive aspects, including for people in low- and moderate-income communities. Prior to the introduction of the CRA, as you know, many of these communities had limited access to mortgages and other forms of consumer credit. Subsequent innovations in financial products and services, processes, and technology helped at least some underserved consumers more fully enter the financial mainstream, save money, invest, and build wealth, and homeownership rates rose significantly.

Yet with hindsight, we can see that something went wrong in recent years, as evidenced by the currently high rates of mortgage delinquency and foreclosure, especially in minority and lower-income neighborhoods. Indeed, we have come almost full circle, with credit availability increasingly restricted for low- and moderate-income borrowers. And the damage from this turn in the credit cycle--in terms of lost wealth, lost homes, and blemished credit histories--is likely to be long-lasting. One would be forgiven for concluding that the assumed benefits of financial innovation are not all they were cracked up to be.

A number of factors explain the recent credit boom and bust, including problems stemming from financial innovation. From a consumer protection point of view, a particular concern has been the sharp increase in the complexity of the financial products offered to consumers, complexity which has been a side effect of innovation but which also has in many cases been associated with reduced transparency and clarity in the products being offered. I will illustrate the issue in the context of some familiar forms of consumer credit: credit cards, mortgages, and overdraft protection.

Credit Cards, Mortgages, and Overdrafts: Some Instructive Examples
The credit card is an example of financial innovation driven by technological advance, including improvements in communications, data management, and credit scoring. When the first general-purpose credit card was issued in 1952, it represented a way to make small loans more quickly and at a lower cost than the closed-end installment loans offered by retailers and finance companies at the time. Moreover, this form of credit doubled as a means of payment. Card issuers benefited by spreading fixed costs over multiple advances of credit, over larger customer bases, across geographic areas, and among many merchants.3 From the consumer's perspective, credit cards provided convenience, facilitated recordkeeping, and offered security from loss (by theft, for example).4 Their use gradually expanded among American families, rising to 43 percent in 1983 and to 70 percent by 2007. Among lower-income families, usage increased from 11 percent in 1983 to 37 percent in 2007.5

Mortgage markets saw similar product innovations. For example, in the early 1990s, automated underwriting systems helped open new opportunities for underserved consumers to obtain traditional forms of mortgage credit. This innovation was followed by an expansion of lending to borrowers perceived to have high credit risk, which became known as the subprime market. Lenders developed new techniques for using credit information to determine underwriting standards, set interest rates, and manage their risks. As I have already mentioned, the ongoing growth and development of the secondary mortgage market reinforced the effect of these innovations, giving mortgage lenders greater access to the capital markets, lowering transaction costs, and spreading risk more broadly. Subprime lending rose dramatically from 5 percent of total mortgage originations in 1994 to about 20 percent in 2005 and 2006.6

Innovation thus laid the groundwork for the expansion of credit card and mortgage lending that has taken place over the past 15 years or so, as well as some other forms of credit like auto loans. However, while innovation often brought consumers improved access to credit, it also brought increased complexity and an array of choices that consumers have often found difficult to evaluate properly.

Take the case of credit cards. In the early days, a card may have allowed the user to make purchases or obtain cash advances, with a single, unchanging annual percentage rate, or APR, applied to each feature. Card fees were typically limited to an annual fee, a charge for cash advances, and perhaps fees for making a late payment or exceeding the credit limit. In contrast, today's more-complex products offer balance transfers and treat different classes of purchases and cash advances as different features, each with its own APR. In addition, interest rates adjust much more frequently than they once did, and the array of fees charged for various features, requirements, or services has grown.

More-complex plans may benefit some consumers; for example, pricing that varies according to consumers' credit risk and preferences for certain services may improve access to credit and allow for more-customized products. Growing complexity, however, has increased the probability that even the most diligent consumers will not understand or notice key terms that affect a plan's cost in important ways. When complexity reaches the point of reducing transparency, it impedes competition and leads consumers to make poor choices. And, in some cases, complexity simply serves to disguise practices that are unfair and deceptive.

Mortgage products have likewise become much more complex. Moreover, in recent years, the increased complexity has sometimes interacted with weakened incentives for good underwriting, to the detriment of the borrower. The practice of securitization, notwithstanding its benefits, appears to have been one source of the decline in underwriting standards during the recent episode. Depending on the terms of the sale, originators who sold mortgage loans passed much of the risk--including the risks of poor underwriting--on to investors. Compensation structures for originators also caused problems in some cases. For example, some incentive schemes linked originator revenue to particular loan features and to volume rather than to the quality of the loan. Complexity made the problem worse, as the wide array of specialized products made consumer choices more difficult. For example, some originators offered what were once niche products--such as interest-only mortgages or no-documentation loans--to a wider group of consumers. And, we have learned, loan features matter. Some studies of mortgage lending outcomes, after controlling for borrower characteristics, have found elevated levels of default associated with certain loan features, including adjustable rates and prepayment penalties, as well as with certain origination channels, including broker originations.7 Although these results are not conclusive, they suggest that complexity may diminish consumers' ability to identify products appropriate to their circumstances.

The vulnerabilities created by misaligned incentives and product complexity in the mortgage market were largely disguised so long as home prices continued to appreciate, allowing troubled borrowers to refinance or sell their properties. Once housing prices began to flatten and then decline, however, the problems became apparent. Mortgage delinquencies and foreclosure starts for subprime mortgages increased dramatically beginning in 2006 and spread to near-prime (alt-A) loans soon thereafter. By the fourth quarter of 2008, the percentages of loans 60 days past due, 90 days or more past due, and in foreclosure were at record highs.8

Credit cards and mortgages are not the only product classes for which innovation has been associated with increased complexity and reduced transparency. I will cite one more example: overdraft protection.

Historically, financial institutions used their discretion to determine whether to pay checks that would overdraw a consumer's account. In recent years, institutions automated that process with predetermined thresholds.

Although institutions usually charged the same amount when they paid an overdraft as when they returned the check unpaid, many consumers appreciated this service because it saved them from additional merchant fees and the embarrassment of a bounced check. However, technological innovations allowed institutions to extend the service, often without consumers' understanding or approval, to non-check transactions such as ATM withdrawals and debit card transactions. As a result, consumers who used their debit cards at point-of-sale terminals to make retail purchases, for instance, could inadvertently incur hundreds of dollars in overdraft fees for small purchases. In response to this problem, the Board last December proposed regulatory changes that would give consumers a meaningful choice regarding the payment of these kinds of overdraft fees, and we expect to issue a final rule later this year.

Protecting Consumers in an Era of Innovation and Complexity
In light of this experience, how should policymakers ensure that consumers are protected without stifling innovation that improves product choice and expands access to sustainable credit? The first line of defense undoubtedly is a well-informed consumer. The Federal Reserve System has a long-standing commitment to promoting financial literacy, and we devote considerable resources to helping consumers educate themselves about their financial options.9 Consumers who know what questions to ask are considerably better able to find the financial products and services that are right for them.

The capacity of any consumer, including the best informed, to make good choices among financial products is enhanced by clear and well-organized disclosures. The Board has a number of responsibilities and authorities with respect to consumer disclosures, responsibilities we take very seriously. In the past year or so, the Board has developed extensive new disclosures for a variety of financial products, most notably credit cards, and we are currently in the midst of a major overhaul of mortgage disclosures.

In designing new disclosures, we have increased our use of consumer testing. The process of exploring how consumers process information and come to understand--or sometimes misunderstand--important features of financial products has proven eye-opening. We have used what we learned from consumer testing to make our required disclosures better. For example, our recently released rules on credit card disclosures require certain key terms to be included in a conspicuous table provided at account opening; we took this route because our field testing indicated that consumers were often already familiar with and able to interpret such tables on applications and solicitations, but that they were unlikely to read densely written account agreements.

We have also learned from consumer testing, however, that not even the best disclosures are always adequate. According to our testing, some aspects of increasingly complex products simply cannot be adequately understood or evaluated by most consumers, no matter how clear the disclosure. In those cases, direct regulation, including the prohibition of certain practices, may be the only way to provide appropriate protections. An example that came up in our recent rulemaking was the allocation of payments by credit card issuers. As creditors began offering different interest rates for purchases, cash advances, and balance transfers, they were also able to increase their revenues through their policies for allocating consumer payments. For example, a consumer might be charged 12 percent on purchases but 20 percent for cash advances. Under the old rules, if the consumer made a payment greater than the minimum required payment, most creditors would apply the payment to the purchase balance, the portion with the lower rate, thus extending the period that the consumer would be paying the higher rate. Under these circumstances, the consumer is effectively prevented from paying off the cash advance balance unless the purchase balance is first paid in full.

In an attempt to help consumers understand this practice and its implications, the Federal Reserve Board twice designed model disclosures that were intended to inform consumers about payment allocation. But extensive testing indicated that, when asked to review and interpret our best attempts at clear disclosures, many consumers did not demonstrate an understanding of payment allocation practices sufficient to make informed decisions. In light of the apparent inadequacy of disclosures alone in this case, and because the methods of payment allocation used by creditors were clearly structured to produce the maximum cost to the consumer, last year we put rules in place that will limit the discretion of creditors to allocate consumers' payments made above the minimum amount required. We banned so-called double-cycle billing--in which a bank calculates interest based not only on the current balance, but also on the prior month's balance--on similar grounds; we found from testing that the complexity of this billing method served only to reduce transparency to the consumer without producing any reasonable benefit. These actions were part of the most comprehensive change to credit card regulations ever adopted by the Board.

Similar issues have arisen in the mortgage arena. Many of the poor underwriting practices in the subprime market were also potentially unfair and deceptive to consumers. For example, the failure to include an escrow account for homeowners' insurance and property taxes in many cases led borrowers to underestimate the costs of homeownership. In this case, allowing greater optionality--which we usually think of as a benefit--had the adverse effects of increasing complexity and reducing transparency. Restricting this practice was one of the new protections in the residential mortgage market that the Board established in a comprehensive set of rules released in July. Banning or limiting certain underwriting practices, which the new rules do for the entire mortgage market, also helps to address the incentive problems I discussed earlier. For institutions that we supervise, these incentive issues can also be addressed by requiring that lenders set up compensation plans for originators that induce behavior consistent with safety and soundness.

Where does all this leave us? It seems clear that the difficulty of managing financial innovation in the period leading up to the crisis was underestimated, and not just in the case of consumer lending. For example, complexity and lack of transparency have been a problem for certain innovative products aimed at investors, such as some structured credit products.

Conclusion
I don't think anyone wants to go back to the 1970s. Financial innovation has improved access to credit, reduced costs, and increased choice. We should not attempt to impose restrictions on credit providers so onerous that they prevent the development of new products and services in the future.

That said, the recent experience has shown some ways in which financial innovation can misfire. Regulation should not prevent innovation, rather it should ensure that innovations are sufficiently transparent and understandable to allow consumer choice to drive good market outcomes. We should be wary of complexity whose principal effect is to make the product or service more difficult to understand by its intended audience. Other questions about proposed innovations should be raised: For instance, how will the innovative product or practice perform under stressed financial conditions? What effects will the innovation have on the ability and willingness of the lender to make loans that are well underwritten and serve the needs of the borrower? These questions about innovation are relevant for safety-and-soundness supervision as well as for consumer protection.

In sum, the challenge faced by regulators is to strike the right balance: to strive for the highest standards of consumer protection without eliminating the beneficial effects of responsible innovation on consumer choice and access to credit. Our goal should be a financial system in which innovation leads to higher levels of economic welfare for people and communities at all income levels.


Footnotes

1. For a listing of these rules, see Dean F. Amel and Daniel G. Keane (1986), "State Laws Affecting Commercial Bank Branching, Multibank Holding Company Expansion and Interstate Banking," Issues in Bank Regulation, vol. 10, no. 2 (Autumn), pp.30-40. Research indicates that non-interest expenses, wages, and loan losses all declined following the lifting of branching restrictions leading to lower loan prices. Also, the lifting of geographic restrictions lead to larger and more diversified banking institutions. See Randall S. Kroszner and Philip E. Strahan (forthcoming), "Regulation and Deregulation of the U.S. Banking Industry: Causes, Consequences, and Implications for the Future," in Nancy Rose, ed., Economics of Regulation, NBER Conference Volume. Return to text

2. Board of Governors of the Federal Reserve System (2007), Report to the Congress on Credit Scoring and Its Effects on the Availability and Affordability of Credit, (Washington: Board of Governors, August). Return to text

3. Dagobert L. Brito and Peter R. Hartley (1995), "Consumer Rationality and Credit Cards," Leaving the Board Journal of Political Economy, vol. 103 (April), pp. 400-33. Return to text

4. Board of Governors of the Federal Reserve (2006), Report to the Congress on Practices of the Consumer Credit Industry in Soliciting and Extending Credit and their Effects on Consumer Debt and Insolvency (Washington: Board of Governors, June). Return to text

5. See note 4, Report to the Congress on Practices of the Consumer Credit Industry, table 6; and Board of Governors of the Federal Reserve System (2007), 2007 Survey of Consumer Finances, Board of Governors. Return to text

6. See Chris Mayer and Karen Pence (2008), "Subprime Mortgages: What, Where, and to Whom?" Finance and Economics Discussion Series 2008-29 (Washington: Board of Governors of the Federal Reserve System, June); and Inside Mortgage Finance (2007), The 2007 Mortgage Market Statistical Annual vol. 1; The Primary Market (Bethesda, Md.: Inside Mortgage Finance Publications). Return to text

7. Lei Ding, Roberto Quercia, Wei Li, and Janneke Ratcliffe (2008), "Risky Borrowers or Risky Mortgages: Disaggregating Effects Using Propensity Score Models," Leaving the Board Working Paper (Chapel Hill, N.C.: UNC Center for Community Capital). See also Elizabeth Laderman and Carolina Reid (2009), "CRA Lending During the Subprime Meltdown (470 KB PDF)," in Revisiting the CRA: Perspectives on the Future of the Community Reinvestment Act, pp. 115-33 (San Francisco: Federal Reserve Bank of San Francisco, February). Other studies do not find evidence of consistent harm from stemming from certain practices or products. See, for example, Morgan J. Rose (2008), "Predatory Lending Practices and Subprime Foreclosures: Distinguishing Impacts by Loan Category," Leaving the Board Journal of Economics and Business, vol. 60 (January-February), pp. 13-32; and Christopher L. Foote, Kristopher Gerardi, Lorenz Goette, and Paul S. Willen (2008), "Just the Facts: An Initial Analysis of Subprime's Role in the Housing Crisis," Leaving the Board Journal of Housing Economics, vol. 17 (December), pp. 291-305. Return to text

8. Mortgage Bankers Association (2009), National Delinquency Survey, MBA, March. Return to text

9. See, for instance, materials on the Consumer Information portion of the Federal Reserve's website. Return to text"

Tuesday, April 14, 2009

its failure could have triggered a 1930s-style global financial and economic meltdown, with catastrophic implications for production, incomes,and jobs

TO BE NOTED: From the Fed:

Chairman Ben S. Bernanke
At the Morehouse College, Atlanta, Georgia
April 14, 2009

Four Questions about the Financial Crisis

I am pleased to have the privilege of speaking today to the students and faculty of Morehouse College, the only all-male historically black institution of higher learning in the United States. It is sufficient to note that Martin Luther King, Jr., was a graduate of Morehouse. Yet a roster of distinguished alumni that also includes former Atlanta Mayor Maynard Jackson, former U.S. Surgeon General David Satcher, and filmmaker Spike Lee testifies to the success of your stated mission of "producing academically superior, morally conscious leaders for the conditions and issues of today."

My remarks today will focus on the ongoing turmoil in financial markets and its consequence, the global economic recession. The financial crisis, the worst since the Great Depression, has severely affected the cost and availability of credit to both households and businesses. Credit is the lifeblood of market economies, and the damage to our economy resulting from the constraints on the flow of credit has already been extensive. With recent job losses exceeding half a million per month, this year's college graduates are facing the toughest labor market in 25 years. In the communities in which you and I grew up, many families are trying to cope with lost employment and depleted savings or are facing foreclosure on their homes. Firms have shut factories and cancelled construction projects. States and municipalities are scrambling to find the funding to provide critical services. And although we naturally tend to be most aware of conditions in the United States, we should not overlook the impact that the crisis is having virtually everywhere in the world, particularly on many citizens of countries that struggle economically even when the global economy is doing well.

In the midst of all of these concerns, many Americans have recently celebrated Easter or Passover. As you may know, a highlight of the traditional Passover meal occurs when the youngest child asks four questions, the answers to which tell the history of the Jews when they were slaves in Egypt and during their exodus to the Promised Land. In the spirit of the holiday, today I will pose and answer four important questions about the financial crisis. Of course, my answers will have to be brief, but we will have more time for additional questions at the conclusion of my prepared remarks.

How Did We Get Here?
The first question I would like to address is: How did we get here? What caused our financial and economic system to break down to the extent it has? Not surprisingly, the answer to this question is complex, and experts disagree on how much weight to give various explanations. In my view, however, to tell the story fully--and, in particular, to understand its international scope--we need to consider how global patterns of saving and investment have evolved over the past decade or more, and how those changes affected credit markets in the United States and some other countries.

At the most basic level, the role of banks and other financial institutions is to take the savings generated by households and businesses and put them to use by making loans and investments. For example, financial institutions use the funds they receive from savers to provide loans that help families buy homes or allow businesses to finance inventories and payrolls. Financial markets, such as the stock and bond markets, perform a similar function, as when a firm raises funds for a new factory by selling a bond directly to investors. When the financial system is working as it should, it allocates funds both prudently (that is, with proper attention to risk) and efficiently (to the most productive uses).

Importantly, in our global financial system, saving need not be generated in the country in which it is put to work but can come from foreign as well as domestic sources. In the past 10 to 15 years, the United States and some other industrial countries have been the recipients of a great deal of foreign saving. Much of this foreign saving came from fast-growing emerging market countries in Asia and other places where consumption has lagged behind rising incomes, as well as from oil-exporting nations that could not profitably invest all their revenue at home and thus looked abroad for investment opportunities. Indeed, the net inflow of foreign saving to the United States, which was about 1-1/2 percent of our national output in 1995, reached about 6 percent of national output in 2006, an amount equal to about $825 billion in today's dollars.

Saving inflows from abroad can be beneficial if the country that receives those inflows invests them well( NB DON ). Unfortunately, that was not always the case in the United States and some other countries. Financial institutions reacted to the surplus of available funds by competing aggressively for borrowers, and, in the years leading up to the crisis, credit to both households and businesses became relatively cheap and easy to obtain. One important consequence was a housing boom in the United States, a boom that was fueled in large part by a rapid expansion of mortgage lending. Unfortunately, much of this lending was poorly done( NB DON ), involving, for example, little or no down payment by the borrower or insufficient consideration by the lender of the borrower's ability to make the monthly payments. Lenders may have become careless because they, like many people at the time, expected that house prices would continue to rise--thereby allowing borrowers to build up equity in their homes--and that credit would remain easily available, so that borrowers would be able to refinance if necessary. Regulators did not do enough to prevent poor lending, in part because many of the worst loans were made by firms subject to little or no federal regulation.

Mortgage markets were not the only ones caught up in the credit boom. The large flows of global saving into the United States drove down the returns available on many traditional long-term investments, such as Treasury bonds, leading investors to search for alternatives. To satisfy the enormous demand for investments both perceived as safe and promising higher returns, the financial industry designed securities that combined many individual loans in complex, hard-to-understand ways. These new securities later proved to involve substantial risks--risks that neither the investors nor the firms that designed the securities adequately understood at the outset.

The credit boom began to unravel in early 2007 when problems surfaced with subprime mortgages( NB DON )--mortgages offered to less-creditworthy borrowers--and house prices in parts of the country began to fall. Mortgage delinquencies and defaults rose, and the downturn in house prices intensified, trends that continue today. Investors, stunned by losses on assets they had believed to be safe, began to pull back from a wide range of credit markets, and financial institutions--reeling from severe losses on mortgages and other loans--cut back their lending. The crisis deepened last September, when the failure or near-failure of several major financial firms caused many financial and credit markets to freeze up. Stock prices fell sharply as investors lost confidence in the financial sector and became gloomy about economic prospects. Declining stock values, a teetering financial system, and difficulties in obtaining credit triggered a remarkably rapid and deep contraction in global economic activity and employment, a contraction that has persisted through the first months of 2009. Both the ongoing financial crisis and economic contraction have posed major challenges to economic policymakers.

What Is the Fed Doing to Address the Situation?
Those challenges bring me to my second question: What has the Federal Reserve been doing to address the economic and financial crisis?

The Fed's mandate from the Congress is to promote maximum sustainable employment and stable prices. In addition, the Fed is expected to contribute to financial stability by acting to contain financial disruptions and prevent their spread outside of the financial sector. Thus, we have been serving as a first responder to the crisis.

The Fed's basic policy tool for influencing economic activity and inflation is its ability to control very short-term interest rates--specifically, the federal funds rate, which is the rate that banks pay each other for overnight loans. Lower interest rates can be used to stimulate private-sector borrowing and spending at times like the present when the economy is suffering from a lack of demand. In September 2007, shortly after the turbulence in financial markets began and signs of economic weakness started to appear, the Federal Open Market Committee (FOMC), the body that determines the Federal Reserve's monetary policy, began to aggressively reduce the federal funds rate. By the spring of 2008, we had cut that interest rate from 5-1/4 percent to 2 percent, a highly proactive policy that helped to cushion the economy from some of the effects of the financial turmoil. But, as I mentioned a moment ago, the intensification of the financial crisis in the fall of 2008 led to a further significant deterioration in the economic outlook. The FOMC responded with additional interest rate cuts, and since December, our policy interest rate has been essentially zero. In addition, the FOMC has made clear that it expects economic conditions to warrant holding the federal funds rate low for an extended period.

However, given the ongoing problems in credit markets, conventional monetary policy alone is not adequate to provide all the support that the economy needs. The Fed has therefore taken a number of steps to help the economy by unclogging the flow of credit to households and businesses. In doing so, we have demonstrated that the Fed's toolkit remains potent, even though the federal funds rate is close to zero and thus cannot be reduced further.

We have taken a wide range of actions to help restore the flow of credit, of which I will only mention a few of the most important. One set of actions involves making short-term loans to banks and other financial institutions. Banks and other financial intermediaries normally make longer-term commitments--such as residential mortgages and business loans--yet rely on funding that may be relatively short-term, such as customer deposits that can be withdrawn at any time. To have the confidence to commit to longer-term loans and investments, banks must be sure that they will have ample access to funding when necessary. To give this assurance to banks, the Federal Reserve has made clear that it will provide short-term credit to sound financial institutions as needed. Indeed, serving as a lender of last resort to financial institutions is a method that central banks have used for centuries to try to calm financial crises.( NB DON )

To underscore our commitment to providing short-term funding to banks when they need it, we have lowered the interest rate we charge for short-term loans and extended the term of the loans to up to three months. We have also begun to auction funds to financial institutions, thereby allowing the interest rate paid to depend on the level of demand. Importantly, this lending is extremely safe from the point of view of both the Fed and the taxpayer. Not only is our lending short-term and restricted to healthy institutions, but we require that the borrowers pledge, as security, collateral whose value exceeds the amount we are lending. The Fed's lending to financial institutions has helped to ease conditions in a number of key financial markets, reduced important benchmark interest rates (such as the London interbank offered rate, or Libor, to which payments on some mortgages and other types of loans are tied), and increased the willingness of banks to make credit available.

A second strategy the Fed has employed is to use targeted lending to help free up critical credit markets outside of the banking system. A good example of targeted lending is our efforts in the commercial paper market. Commercial paper is a form of short-term debt issued by a variety of businesses to finance their operations; paychecks and payments to suppliers can depend on it. Among the largest investors in commercial paper are money market mutual funds. At the peak of the crisis last fall, many people who had invested in money market mutual funds lost confidence in those funds and withdrew their money( NB DON ); this loss of funding forced money market mutual funds to reduce their own investments, which in turn caused serious problems in the commercial paper market. Through a series of lending programs, and in coordination with steps taken by the Treasury, the Federal Reserve helped restore confidence in both money market mutual funds and the commercial paper market. Over time, withdrawals from money market mutual funds have been replaced by modest net inflows, and borrowers in the commercial paper market have seen significant improvements in the cost and availability of funding.

More recently, the Federal Reserve has also initiated a lending program, with the cooperation of the Treasury, designed to free up the flow of credit to households and small businesses. Among the forms of credit on which the program is currently focused are auto loans, credit card loans, student loans, and loans guaranteed by the Small Business Administration. We are currently reviewing other types of credit for possible inclusion in this program. In all cases, we will be taking the appropriate measures to minimize the risk of loss to the Federal Reserve.

Restoring stability to the market for housing and home mortgages has been a particular area of concern. To address this problem, the Fed has employed a third type of policy tool--namely, buying securities in the open market. The FOMC has approved purchases of well over $1 trillion this year of mortgage-related securities guaranteed by the government-sponsored mortgage companies, Fannie Mae and Freddie Mac. Buying mortgage-related securities helps to drive down the interest rates that consumers pay on mortgages, and, indeed, the rate on a traditional 30-year fixed-rate mortgage has recently fallen to less than 5 percent, the lowest level since the 1940s. Certainly, the housing market remains depressed, but lower interest rates and house prices are making houses more affordable. For example, two years ago, when mortgage rates were higher than 6percent, payments on a mortgage covering 80 percent of the cost of a $215,000 home would have been more than $1,000 per month; today, the price of that same house may have fallen to $170,000, and, at today's mortgage interest rates, the monthly payment would be about $700. Lower mortgage rates are also helping some homeowners refinance their mortgages to reduce their monthly payments.

The Federal Reserve will continue to take the necessary steps to unclog the credit markets and strengthen the economy. We will also continue to work closely with other agencies, such as the Treasury and the Federal Deposit Insurance Corporation (FDIC), each of which has also taken a variety of actions to help stabilize financial markets, as well as with other central banks around the world.

Does the Fed's Aggressive Response Risk Inflation Down the Road?
The multifaceted policy response that I've described has been aggressive. I am confident that such a proactive policy response is well justified by the serious ongoing problems in financial markets and the economy. However, some have raised the third question I will address: Could the Fed's aggressive actions to stabilize the economy today lead to an inflation problem down the road?

I mentioned earlier that the Fed's mandate from the Congress is to foster price stability as well as maximum sustainable employment. The FOMC treats its obligation to ensure price stability extremely seriously. Price stability supports healthy economic growth, for example, by making it easier for households and businesses to plan for the future. In practice, price stability does not require that inflation be literally zero; indeed, although inflation can certainly be too high, it can also be too low. Experience suggests that inflation rates that are close to zero or even negative (corresponding to deflation, or falling prices) can at times be associated with poor economic performance. Cases in point include the United States in the 1930s and the more recent experience of Japan. In their latest quarterly projections of the economy, most members of the FOMC indicated that they would like to see an annual inflation rate of about 2 percent in the longer term. Right now, because of the weakness in economic conditions here and around the world, inflation has been running less than that, and our best forecast is that inflation will remain quite low for some time. Thus, the Fed's proactive policy approach is not at all inconsistent with the goal of price stability in the medium term.

Although inflation seems set to be low for a while, the time will come when the economy has begun to strengthen, financial markets are healing, and the demand for goods and services, which is currently very weak, begins to increase again. At that point, the liquidity that the Fed has put into the system could begin to pose an inflationary threat unless the FOMC acts to remove some of that liquidity and raise the federal funds rate. We have a number of effective tools that will allow us to drain excess liquidity and begin to raise rates at the appropriate time; that said, unwinding or scaling down some of our special lending programs will almost certainly have to be part of our strategy for reducing policy stimulus once the recovery is under way.

We are thinking carefully about these issues; indeed, they have occupied a significant portion of recent FOMC meetings. I can assure you that monetary policy makers are fully committed to acting as needed to withdraw on a timely basis the extraordinary support now being provided to the economy, and we are confident in our ability to do so. To be sure, decisions about when and how quickly to proceed will require a careful balancing of the risk of withdrawing support before the recovery is firmly established versus the risk of allowing inflation to rise above its preferred level in the medium term. However, this delicate balancing of risks is a challenge that central banks face in the early stages of every economic recovery. I believe that we are well equipped to make those judgments appropriately. In addition, when the time comes, our ability to clearly communicate our policy goals and our assessment of the outlook will be crucial to minimizing public uncertainty about our policy decisions.

Why Did the Fed and the Treasury Act to Prevent the Bankruptcy of Some Major Financial Firms?
The final question is as difficult as it is important: Why did the Fed and the Treasury act to prevent the bankruptcy of some major financial firms, such as the investment bank Bear Stearns and the insurance company American International Group, or AIG? We must answer that question not only because the decisions have been controversial, but also because it bears on the steps we need to take as a country if we are to avert a repetition of the crisis.

As a general rule, my strong preference is that any firm that cannot meet its obligations should bear the consequences of the marketplace. But recent circumstances have been truly extraordinary. Consider the situation on September 16 of last year, when the insurance conglomerate AIG faced pressures that threatened to force it imminently into bankruptcy. At that time, the strains in the global financial system were unprecedented and extreme, and the confidence of financial market participants in the system was rapidly eroding. The investment bank Lehman Brothers had filed for bankruptcy the day before, and the mortgage giants Fannie Mae and Freddie Mac, after suffering losses that threatened their solvency, had effectively been taken over by the government just two weeks earlier. As waves of panic and fear washed over the markets, the Fed and the Treasury became very concerned about the stability of a number of other major financial firms.

Large, complex financial institutions tend to be highly interconnected with other firms and markets, and AIG was more interconnected than most. For example, AIG had insured many billions of dollars of loans and securities held by banks around the world, and its failure would have rendered those insurance contracts worthless, imposing large losses on the global banking system. In addition, banks had extended more than $50 billion in credit to the company, much of which would have been lost. Many other serious consequences would have followed from a default by AIG: Insurance policyholders would have faced considerable uncertainty about the status of their policies; state and local governments, which had lent more than $10 billion to AIG, would have suffered losses; workers whose 401(k) plans had purchased $40 billion of insurance from AIG against the risk of loss would have seen that insurance disappear; and holders of AIG's substantial quantities of commercial paper would have also borne serious losses.

But much more important, the disorderly failure of AIG would have put at risk not only the company's own customers and creditors but the entire global financial system. Historical experience shows that, once begun, a financial panic can spread rapidly and unpredictably( NB DON ); indeed, the failure of Lehman Brothers a day earlier, which the Fed and the Treasury unsuccessfully tried to prevent, resulted in the freezing up of a wide range of credit markets, with extremely serious consequences for the world economy. The financial and economic risks posed by a collapse of AIG would have been at least as great as those created by the demise of Lehman. In the case of AIG, financial market participants were keenly aware that many major financial institutions around the world were insured by or had lent funds to the company. The company's failure would thus likely have led to a further sharp decline in confidence in the global banking system and possibly to the collapse of other major financial institutions. At best, the consequences of AIG's failure would have been a significant intensification of an already severe financial crisis and a further worsening of economic conditions. Conceivably, its failure could have triggered a 1930s-style global financial and economic meltdown, with catastrophic implications for production, incomes, and jobs. ( NB DON )

The Federal Reserve and the Treasury agreed that in the environment then prevailing, AIG's failure would have posed unacceptable risks for the global financial system and for our economy. Accordingly, the Federal Reserve, with the full support of the Treasury, made a loan to AIG to prevent its failure. The loan imposed tough terms; in addition, senior management was replaced, and shareholders lost almost all of their investments. However, because the firm avoided a declaration of bankruptcy, creditors of AIG were protected.

In my view, preventing the failure of AIG was the best of the very bad options available, but it nevertheless involved major costs, including financial risks to the taxpayer. The American people also quite correctly see as unfair that AIG was saved from bankruptcy because of the dangers to the system that its failure would have posed, even as many other companies, including nonfinancial and smaller financial firms, have not received the same treatment. Allowing AIG to at least partly avoid the discipline of the marketplace also sets a bad precedent.

For these reasons, it is essential that we make changes to the financial rules of the game to prevent a similar episode from occurring in the future. First, we must ensure that all types of financial institutions, especially large and interconnected ones like AIG, receive strong and effective government oversight. AIG's regulatory oversight was limited, which allowed it to take dangerous risks largely out of sight of federal regulators.

Second, the AIG experience demonstrates that federal regulators urgently need a new set of procedures for dealing with a complex, systemically important financial institution on the brink of failure. Such rules already exists for banks: If a bank approaches insolvency, the FDIC is empowered to intervene as needed to protect depositors, sell the bank's assets, and take any necessary steps to prevent broader consequences to the financial system. However, for an insurance conglomerate like AIG, or for a large financial holding company that owns many subsidiary companies, these rules do not apply. Among other things, a good system for resolving nonbank financial institutions would allow federal regulators to unwind a failing company in ways that minimize disruptions in financial markets. An effective regime would also provide the authorities greater latitude to negotiate with creditors and to modify contracts entered into by the company, including contracts that set bonuses and other compensation for management. More generally, we need significant reforms to financial regulation and financial practices that will reduce the risk of future financial crises like the one we are currently experiencing. The Federal Reserve strongly supports such reform efforts.

Conclusion
The current crisis has been one of the most difficult financial and economic episodes in modern history. Recently we have seen tentative signs that the sharp decline in economic activity may be slowing, for example, in data on home sales, homebuilding, and consumer spending, including sales of new motor vehicles. A leveling out of economic activity is the first step toward recovery. To be sure, we will not have a sustainable recovery without a stabilization of our financial system and credit markets. We are making progress on that front as well, and the Federal Reserve is committed to working to restore financial stability as a necessary step toward full economic recovery.

I am fundamentally optimistic about our economy. Among its many intrinsic strengths are universities and colleges like Morehouse, which help talented students gain not only a command of a body of knowledge but also the capacity to think creatively and independently. Institutions like this one train the professionals, entrepreneurs, and leaders who will shape our economy in the future. Today's economic conditions are difficult, but the foundations of our economy are strong, and we face no problems that cannot be overcome with insight, patience, and persistence. The Federal Reserve will certainly do its part to help restore prosperity and opportunity to our economy."