Showing posts with label Lender Of Last Resort. Show all posts
Showing posts with label Lender Of Last Resort. Show all posts

Saturday, May 9, 2009

tie ourselves in knots” to make the systemic-risk regulator any agency but the Fed, because it’s the “lender of last resort

TO BE NOTED: From Bloomberg:

"Obama Administration Said to Favor Fed as Systemic Risk Agency

By Robert Schmidt

May 9 (Bloomberg) -- The Obama administration is likely to support giving the Federal Reserve the power to oversee financial companies that could pose a danger to the banking system, said participants in a White House meeting yesterday.

Treasury Secretary Timothy Geithner, a former Federal Reserve Bank of New York president, told representatives of the trade groups representing securities firms, hedge funds and banks that a single supervisor needs the authority over the biggest financial firms.

While the Fed was first favored to take the job, since a proposal by former Treasury Secretary Henry Paulson last year, lawmakers and some regulators have shifted away from that view. Federal Deposit Insurance Corp. Chairman Sheila Bair and Securities and Exchange Commission Chairman Mary Schapiro this week recommended that a council of regulators assume the role.

The divergence of views suggests that it will take months before any agreement on how to overhaul U.S. financial regulation in the aftermath of the worst credit crisis since the 1930s.

“There are going to be a number of regulators with oars in the water” over various parts of the banking system, Alan Blinder, a professor of economics at Princeton University and former Fed vice chairman, said in an interview with Bloomberg Television. Still, “we would have to tie ourselves in knots” to make the systemic-risk regulator any agency but the Fed, because it’s the “lender of last resort,” he said.

The SEC is best placed to oversee hedge funds, Blinder said.

Industry Groups

Representatives of the Securities Industry and Financial Markets Association, International Swaps and Derivatives Association and Chamber of Commerce were among those who attended yesterday’s meeting. Geithner dropped by the hour-long gathering in the Roosevelt Room, the people said on condition of anonymity.

The gathering was run by Diana Farrell of the National Economic Council and Pat Parkinson, a Fed staffer on detail to the Treasury, participants said. After Geithner left the meeting, Parkison told the attendees that the Fed would likely be the agency to supervise firms that are found to be too big to fail, they said.

“Geithner believes that we need a single independent regulator with responsibility for systemically important firms and critical payment and settlement systems,” Treasury spokesman Andrew Williams wrote in an e-mailed response to questions. “He does see a role, however, for a council to coordinate among the various regulators.”

‘Council’ of Agencies

Bair, in a May 7 speech at a Chicago conference, proposed a “Systemic Risk Council” that has “a mandate to monitor developments throughout the financial system, and the authority to take action to mitigate systemic risk.”

Schapiro said yesterday at an Investment Company Institute conference in Washington that she’s “inclined” to support Bair’s proposal.

“I have long been concerned about excessive concentration of power, which really means excessive concentration of a point of view in a single regulator,” Schapiro said.

Senate Banking Committee Chairman Christopher Dodd said in a May 6 hearing that “It is my preference that authority not lie in any one body; we cannot afford to replace Citi-sized financial institutions with Citi-sized regulators,” referring to Citigroup Inc., one of the largest U.S. financial firms.

In March, Geithner proposed creating a systemic risk regulator though he didn’t identify which agency should have those duties. President Barack Obama has said he wants to sign legislation overhauling financial rules by the end of the year.

Popular anger over the taxpayer-financed rescues of American International Group Inc., Bear Stearns Cos. and other firms has spurred Congress and the White House to push for regulatory changes that may become the most sweeping since the 1930s.

To contact the reporter on this story: Robert Schmidt in Washington at rschmidt5@bloomberg.net."

Thursday, December 25, 2008

"That's just the sort of thing that troubled Bagehot almost a century and a half ago"

I've wanted to do this post for some time, and today seemed a good time. First, George Selgin in the Pittsburgh Tribune-Review:

"Bagehot was right

By George Selgin

Sunday, October 19, 2008

Who can forget the end of "Planet of the Apes" when Charlton Heston, kneeling before the half-buried remains of the Statue of Liberty, slams his fists into the sand and cries, "You maniacs! You blew it up! Ah, damn you ... damn you all to hell!"( I CAN'T )

Now imagine the same scene, but with a half-buried Morgan Stanley building standing in for Miss Liberty and a time-traveling Walter Bagehot playing the lead and you've got the perfect Hollywood dramatization of the real-life tragedy that, with luck, is having its denouement on Wall Street.

Bagehot? The great Victorian man of letters, best remembered today as the second and most celebrated editor of the British magazine The Economist, wasn't exactly a hunk. But he certainly could have delivered those futile last lines with real conviction, for he was among the first to recognize the vast destructive potential of that newfangled weapon of Victorian finance: the modern central bank. ( TRUE )

Bagehot first alerted readers to this potential and offered his suggestions for containing it in an article that appeared in The Economist after the great panic and credit crisis of 1866. That panic witnessed the spectacular collapse of Overend, Gurney & Co., which had long been Great Britain's premier investment house.

Bagehot understood that, during such panics, the Bank of England alone commanded the confidence needed to serve other financial firms as a "lender of last resort."( TRUE ) But as Bagehot put it later in his book "Lombard Street: A Description of the Money Market" (1873), the bank's "faltering way" -- its arbitrary and inconsistent use of its unique lending powers -- tended only to make things worse.( TRUE. WE'VE SEEN THE RESULTS OURSELVES )

"The public," Bagehot wrote, "is never sure what policy will be adopted at the most important moment: it is not sure what amount of advance will be made. ... And until we have on this point a clear understanding with the Bank of England, both our ability to avoid crises and our terror at crises will always be greater than they would otherwise be."( TRUE. THIS IS WHAT HAS BEEN HAPPENING, WHICH I CALL AN OVERREACTION OF FEAR AND AVERSION TO RISK BEYOND THE FUNDAMENTALS )

The ultimate source of trouble, Bagehot believed, was the very existence of the Bank of England and the special privileges it enjoyed. But because nothing save a revolution seemed likely to do away with the "Old Lady of Threadneedle Street," as it was called, Bagehot's preferred, practical solution was for the bank expressly to commit itself to lending freely during crises, though on good collateral only, and at "penalty" rates. ( ALL STILL TRUE )

The restrictive provisions were supposed to limit aid to otherwise solvent firms panic had rendered illiquid. ( THAT'S IT )

Bagehot's recommendation has since become a sort of master precept of central banking -- albeit one that's mainly honored in the breach by central bankers. ( TRY NEVER )

To be fair to today's central bankers, there's never been much agreement on how to apply Bagehot's rule in practice. Just what do "good collateral" and "penalty rates" mean in times like these? ( WE'D BETTER FIGURE IT OUT )

While no one might precisely be able to define good collateral -- and one can debate whether the rate at which banks offer to lend unsecured funds to other banks, known as the London Interbank Offered Rate, or LIBOR rate, plus 8 percent constitutes a "penalty" rate -- who even pretends that recent central bank lending has been based on good collateral? ( NOT ME. EXHIBIT ONE: TARP )

But rescuing insolvent firms is the least of it. The real damage comes from the Treasury's utter lack of any consistent last-resort lending rule. The recently enacted financial institutions bailout bill does little to clarify this. ( TRUE )

That's just the sort of thing that troubled Bagehot almost a century and a half ago, when central banks were still in their swaddling clothes. Yet central bankers and governments still don't get it, despite the lip service they pay to this great thinker from our past. ( TRUE )

George Selgin is a research fellow at The Independent Institute (www.independent.org) and a professor of free market thought at West Virginia University."

Fine. You can immediately see the relevance of Bagehot, and roughly from where I get my Bagehot's Principles. Here again, some of Bagehot's Principles:

1) If the Fed exists, it will be the Lender Of Last resort, and that has to be taken in to account in real world Political Economy. It should lend freely in a crisis to solvent banks.

2) The rules for LOLR( from here on down this includes any government guarantee ) intervention should be clear, public, and followed, otherwise Moral Hazard is ineffective. All guarantees must be explicit.

3) The terms must be onerous.

4) The LOLR should get something valuable in return.

Here are a few others:

5) The taxpayer's interests should come first.

6) Moral Hazard needs to be constantly applied by quickly liquidating problem banks in normal times.

7) Any entity receiving a guarantee will have to be supervised or regulated effectively, and violations should be quickly and severely punished.

8) There is no doubt that any entity receiving a LOLR guarantee will need to be more conservative in its practices in order to limit the liability of the taxpayer.

9) There should be a class of financial concerns that can act more freely, but they should not receive LOLR guarantees. They will be strictly supervised or regulated though, and are subject to laws against fraud, etc.

Now, a different point of view from one of my favorite writers:

"
Walter Bagehot Was Wrong
By JAMES GRANT, Grant's Financial Publishing Inc. | June 19, 2008
http://www.nysun.com/opinion/walter-bagehot-was-wrong/80283/

The governor of the Central Bank of Luxembourg raised some eyebrows when he questioned the integrity of the fast-growing balance sheet of the European Central Bank. Yves Mersch, a member of the ECB's governing council as well as the Ben Bernanke of the Grand Duchy of Luxembourg, raised the issue at a gathering of the International Capital Market Association in Vienna two weeks ago.

(The Granger Collection, New York / Copyright � The Granger Collection, New York / The Granger Collection)">

The Granger Collection, New York / Copyright � The Granger Collection, New York / The Granger Collection

BAGEHOT

Insofar as a currency derives its strength from the balance sheet of the issuing central bank, the euro is unsound and becoming more so, as Mr. Mersch did not quite say. We, however, will say it for him. In fact, we will say the same for most of the leading monetary brands, that of the United States not excluded. The mortgage mess is the immediate cause of the new debasement( PRINTING MONEY ). A long-held article of central banking dogma is the remote cause.

Mr. Mersch landed on the front page of the Financial Times by acknowledging that the ECB is accepting a dubious kind of mortgage collateral( TRUE ) in exchange for loans to the world's liquidity-parched financial institutions. In so many words, Mr. Mersch charged that the commercial banks are gaming the central bank, a situation he called of "high concern." Reading Mr. Mersch, we thought of Thomson Hankey.

Mr. Mersch has the look of a comer in world central-banking councils. Hankey, though he served a term as governor of the Bank of England in 1851 and 1852, is known today, if at all, as a sparring partner of the great Victorian Walter Bagehot (say "Badge-oat"). It was Bagehot who laid down the law that, in a credit crisis, a central bank should lend freely against good collateral at a high rate of interest. Hankey emphatically disagreed, and he answered Bagehot in a little book titled, "The Principles of Banking," first published in 1867 in the wake of the famous Overend Gurney run, the one to which the 2007 Northern Rock panic is sometimes compared.

Way back then, the Bank of England was an investor-owned institution conducting a conventional, for-profit commercial banking business. It had but one avowed public purpose, and that was to manage the workings of the international gold standard. It stood ready to exchange currency for gold coin, and gold coin for currency, at the statutory rate of �3.17s.9d. to the ounce, or �3.89 in metric terms, no questions asked.

Lender of Last Resort

For Bagehot, the Bank of England was no ordinary deposit-taking institution but the lender, or liquidity provider, of last resort. Actually, Sir Francis Baring had anticipated Bagehot in that judgment. In the crisis year of 1797, Baring had fixed the Bank with the name, "le dernier resort." Neither Bagehot nor Baring seemed to anticipate that, before many hundreds of years would pass, the Bank � indeed, many central banks � would become, so to speak, "le premier resort." ( VERY TRUE. THAT'S WHAT WE HAVE NOW )Anyone with good collateral should expect to find accommodation at the Bank's discount window at a suitably high penalty rate( ONEROUS ), Bagehot said. What passed for good banking collateral in the mid-19th century were bills of exchange, i.e., short-dated, self-liquidating IOUs. Mortgages, inherently illiquid, were inadmissible. Hankey liked to quote a relative of his, one C. Poulett Thomson, on the art of banking. It wasn't very hard, said Thomson, as long as the banker "would only learn the difference between a Mortgage and a Bill of Exchange."

By now, a busy reader of Grant's Interest Rate Observer might be wondering why the editor is reaching back to 1867 for actionable ideas on the 21st-century monetary situation. Medical science has made a certain amount of progress since Dr. Strickland's Pile Remedy, Constitution Life Syrup, and Webster's Vegetable Hair Invigorator represented state-of-the-art therapeutics. Neither has monetary economics stood still � has it?

You be the judge. Hankey, in a losing cause, marshaled two principal arguments against the Bagehot doctrine. No. 1, moral hazard: Let profit-maximizing people come to believe that the Bank of England will bail them out, and they themselves will take the risks, and pile on the leverage, that will require them to be bailed out( I BELIEVE THAT THIS IS THE MAIN CAUSE OF OUR CURRENT CRISIS ). No. 2, simple fairness: If Britain's banking interest can claim a right to the accommodation of the Bank of England, why shouldn't the shipping interest, the construction interest, the railroads, "and, last of all, the much-maligned agricultural interest," do the same? Shouldn't all economic actors "be equally entitled to benefit by any favors for which the public have a right to look from such an institution as the Bank of England( NO. THEY CAN PETITION THE GOVERNMENT )?"

At this writing, the Federal Reserve, the ECB, and the Bank of England are taking extraordinary measures to accommodate the demand for liquidity from the institutions that couldn't seem "to learn the difference between a Mortgage and a Bill of Exchange," or between a triple-A corporate bond and a triple-A mortgage, which is a slightly different kind of confusion( TRUE. BUT I CONTEND THAT THEY DID REALLY KNOW THAT THEY WERE DOING ).

To bail out these slow learners( I DISAGREE. THEY UNDERSTOOD THE SYSTEM. EXHIBIT ONE: THE CURRENT BAILOUT ), the central banks are lending government securities against the inherently illiquid mortgage collateral that never had a place on the balance sheet of a properly run monetary institution in the first place( I AGREE. WE DON'T NEED GLASS TO UNDERSTAND GOOD BANKING ). In fact, in Hankey's day, it was a breach of good form( WE NEED MORE OF IT CHUM ) for a central bank even to acquire government securities (the preferred assets were commercial loans, foreign exchange, and gold). How far the world has come: Gold, the most liquid of monetary assets, today is officially demonetized, whereas mortgages, the least liquid of banking assets, are now � all of a sudden, because there seems to be no choice � being embraced, or, at least, tolerated. Certainly, they are being monetized ( BUT GOLD COULD BE AS WELL ).

"Ready money," writes Hankey in a passage on liquidity that seems to speak directly to the post-Bear Stearns world of 2008, "is a most valuable thing, and cannot from its very essence bear interest; every one is therefore constantly endeavoring to make it profitable and at the same time to retain its use as ready money, which is simply impossible( YOU CAN HAVE SHORT TERMS, AND LOANS TO TIDE YOU OVER ). Turn it into whatever shape you please, it can never be made into more real capital than is due to its own intrinsic value, and it is the constant attempt to perform this miracle which leads to all sorts of confusion with respect to credit. The Bank of England has long been expected to assist in performing this miracle; and it is the attempt to force the Bank to do so which has led to the greater number of the difficulties which have occurred on every occasion of monetary panics during the last twenty years."

History Chooses Bagehot

So Hankey would have every banker, trader, merchant, and speculator watch out for himself, proceed with prudence, not overreach, not overborrow, and � above all � not depend on the Bank of England for emergency accommodation if he got into a jam( GOOD LUCK. I DON'T SEE THIS FOR BANKS, BUT I DO SEE IT FOR OTHER FINANCIAL CONCERNS. PERHAPS WE DO NEED GLASS TO PUT THIS DIFFERENCE INTO LAW. ALSO, STRICTLY SPEAKING, BAGEHOT DIDN'T DISAGREE WITH THIS. I AM A TIMID BELIEVER IN CENTRAL BANKS AND THE LSOR CONCEPT )About 150 years later, Northern Rock and the Bank of England are both arms of the British government (the Bank joined the public sector in 1946). The Bank has just rolled out its Special Liquidity Scheme to exchange the government's gilts for the private sector's mortgages, and the gold price, expressed in sterling, stands at �468.2 an ounce, up from �3.89 in Hankey's time. From 1867 to date, the annual rate of debasement( I THINK GRANT LIKES THIS TERM'S MORAL CONNOTATIONS ), sterling against gold, comes to 3.3%.

Hankey's ideas did not go down to defeat for no reason. The gold standard was as hard as it was clean. When the price level fell, as it did in the final quarter of the 19th century, it just fell. No gold-standard central bank resisted the trend with newly created credit (as every major central bank does, or would do, today). A certain kind of person � Grant's knows the type � takes it to be a good thing that, under the monetary arrangements of Hankey's day, no monetary policy committee fixed interest rates or sized up the money supply or regulated the price level or supervised a return to macroeconomic equilibrium when imbalances appeared. Rather, as Hankey observed, interest rates moved and macroeconomic adjustments took place, more or less spontaneously. No government commanded them. ( THEORETICALLY, I AGREE. BUT'S IT'S NOT POSSIBLE )

To judge by all that has happened since the gold standard bit the dust, we would have to say that the people have registered their collective preference for the comforting sight of a Bernanke or a Mersch at the helm of a central bank. There is something pleasing to many, or to most, about a government functionary taking responsibility for interest rates( THEY DON'T TRUST BANKERS. CAN YOU BLAME THEM ? ), the price level and/or the labor market, whether or not that individual can actually make the magic demanded of him (we are sure he or she cannot).

Nowadays, the consensus of belief has it that America fills the bill of a "market-based system," whereas Europe is closer to a "bank-based system." But the truth is that the worldwide mortgage mess has pushed America away from markets and Europe away from banks. Both systems are moving closer to a state of government or central-bank control. And both the dollar and the euro are, therefore, moving even further away from an orthodox notion of soundness (not that either was within hailing distance of it before the credit clouds rolled in last summer)( WE'VE A HYBRID SYSTEM. IT'S SIMPLY REBALANCING ITSELF IN WAYS THAT WE DON'T APPROVE OF. BUT WE'LL SURVIVE ).

A Grand Comeuppance

In the United States this election year, the galloping socialization( NOT TRUE ) of the mortgage market proceeds with hardly a peep of discussion, let alone protest. Thus, mortgage originations by the government-sponsored enterprises reached 81% of overall originations in the fourth quarter of 2007, up from 37% in the second quarter of 2006. In the first quarter of this year, Fannie copped a 50% share of originations, double its take in calendar 2006. But in comparison to the biggest GSE, Fannie and Freddie might as well be standing still.

In Boston, before a Mortgage Bankers Association audience on May 6, the chairman of the Federal Housing Finance Board, Ronald Rosenfeld, noted that the Federal Home Loan Banks, which his agency supervises, are closing in on $1 trillion in outstanding loans, or "advances" ($925 billion currently are outstanding, up by $300 billion since last June). "The FHLBs," Reuters reported of Mr. Rosenfeld's remarks, "are facing increased risk due to the concentration of loans to big financial institutions that recently 'decided to become very involved in the FHLB system,' Mr. Rosenfeld said. Those banks include Countrywide, Washington Mutual Inc.( THOSE TWO AREN'T GOOD NAMES ) and Wells Fargo & Co., he said. The top borrowers of the FHLB system account for 37% of all advances, he said. 'That's an astonishing number, and an astonishing amount of concentration,' he said. ( A BAD IDEA )

"The FHLBs can continue to provide money for their commercial bank members as long as demand persists in the market for agency debt." Foreign central banks can't seem to get their fill( THEY DID GET THEIR FILL OF AGENCIES ). In the 12 months through March, according to a recent Home Loan Bank slide show, central banks took down 40% of the system's debt issuance. Russia's central bank has shown a particularly hearty appetite for the GSEs' emissions: 21% of Russian monetary reserves are parked in the obligations of Fannie, Freddie, and the Home Loan Banks, according to a May 19 Bloomberg report.

Taking an evolutionary view of present-day monetary disturbances, we see a kind of grand comeuppance( WE'VE HAD IT ). Embracing Bagehot and rejecting Hankey, central bankers have pushed aside the classical doctrines of liquidity. In the way that financial ideas seem always to be carried to an extreme( TRUE ), they have pushed too hard. Under their noses, the global credit apparatus froze up, and now it falls to them to thaw it out. A measure of the difficulty of that work is the huge volume of lending that the Bank of England and the ECB, especially, have chosen to undertake; over the past 12 months, the balance sheets of the ECB and the Bank of England have grown by 21% and 19.4%, respectively. (In comparison, the Fed is a model of restraint.)

In his critique of the Bagehot doctrine, Hankey understandably failed to foresee how the financial engineers of the future would respond to the opportunities presented to them by ambulance-chasing central banks of the 21st century. According to the Financial Times, investment bankers the world over are bundling up mortgages to deposit in the special liquidity facilities created by the ECB and the Bank of England. "The Bank of England," the paper reported on May 16, "recently created a facility for UK banks to access funding for mortgages and the Financial Times has learnt that almost �90 billion ($175 billion) worth of bonds are being created to be placed there � almost twice the �50 billion initially expected when the scheme was launched only three weeks ago. ...

"Investment bankers who work in securitization," the FT went on, "say that their main business is structuring bonds that are eligible for ECB liquidity operations. Some analysts have concerns about whether the bonds being created will ever be saleable if markets recover( YES )."

We believe that more analysts ought to be concerned about the risk that these monetary exertions will result in a new cycle of currency debasement. For ourselves, we expect it. A brilliant man was Walter Bagehot, but Hankey had the foresight."

I would say that Bagehot was more realistic. However, the solution to our crisis is to return to Bagehot, with Hankey's views as our conscience. Again, Grant doesn't give Bagehot his due. I'm not so sure that he would have disagreed with Hankey but for Bagehot's Principle:

If the B of E exists, then it will be the LOLR, and that real life fact needs to be taken into account in your policies.

Since the B of E exists, Bagehot is really the person we must turn to.

This article and more can be found at Grant's Interest Rate Observer, grantspub.com. � 2008 Grant's Financial Publishing Inc., all rights reserved.

Monday, December 22, 2008

"that the central bank should lend to illiquid but solvent banks, at a penalty rate, and against collateral deemed to be good under normal times."

Xavier Freixas and Bruno M. Parigi consider the concept of the Lender Of Last Resort on Vox:

"
This column argues that the financial crisis of 2007 and 2008 redefines the functions of the lender of last resort, placing it at the intersection of monetary policy, supervision and regulation of the banking industry, and the organisation of the interbank market.

Since the creation of the first central banks in the 19th century, the existence of a lender of last resort (LOLR) has been a key issue for the structure of the banking industry. Banks finance opaque assets with a long maturity with short-lived liabilities – a combination that is vulnerable to sudden loss of confidence ( A BANK RUN ). To avoid avoidable disasters when confidence evaporates, the classical view (Thornton 1802 and Bagehot 1873) is that the central bank should lend to illiquid but solvent banks, at a penalty rate( ONEROUS ), and against collateral deemed to be good under normal times( YES ).

With the development of well-functioning financial markets, this view has been considered obsolete( IT IS ? ). Goodfriend and King (1988) in particular argue that the central bank should just provide liquidity to the market and leave to banks the task of allocating credit and monitoring debtors. This view, however, assumes that interbank markets work perfectly and in particular are not plagued by asymmetric information – but that is one of the main reasons why banks exist. The problem with asymmetric information is that liquidity shocks affecting banks might be undistinguishable from solvency shocks, thus making it impossible to distinguish between illiquid and insolvent banks( TRUE ) (Goodhart 1987 and Freixas, Parigi and Rochet 2004).

LOLR and bank closure policy

LOLR is thus connected with the efficient bank closure policy and, more generally, with the costs of bank failures and of the safety net. In cases of illiquidity, the LOLR is channelling liquidity and improving the efficiency of the monetary policy framework( TRUE ). In insolvency cases, the LOLR acts as part of a safety net and thus is directly related to the overall regulatory framework( TRUE ).

Clearly, the design of an optimal LOLR mechanism has to take into account both the banking regulation context and the monetary framework that is intended to cope not only with inflation but also with the management of aggregate liquidity ( YES ).

These issues are compounded by the fact that financially fragile intermediaries are exposed to the threat of systemic risk. Systemic risk may arise from the existence of a network of financial contracts from several types of operations: the payment system, the interbank market, and the market for derivatives. The tremendous growth of these operations recent decades has increased the interconnections among financial intermediaries and among countries. This has greatly augmented the potential for contagion( TRUE ) (Allen and Gale 2000 and Freixas, Parigi and Rochet 2000).

The panic of 2008 and subprime crisis of 2007

The panic of 2008, originating with the subprime crisis of 2007, offers key insights into systemic risk and illustrates vividly the new role of a lender of last resort.

Years of accommodating monetary policy( LOW INTEREST RATES ), regulatory arbitrage to save capital( SEEKING INVESTMENT WITH LOWER CAPITAL STANDARDS ), and waves of financial innovations( CDSs, CDOs, etc. ) – which by definition tend to escape traditional prudential regulation( TRUE ) – have created the conditions( I'LL ACCEPT CONDITIONS, BUT NO MORE ) for slack credit standards and rating agencies that fail to call for adequate risk premia( BUT THEY TOOK ADVANTAGE OF THE CONDITIONS FREELY ).

The opacity of the assets of the banks and of the financial vehicles they created to hold mortgages resulted in a dramatic and sudden reappraisal of risk premia( FEAR AND AVERSION TO RISK, AND THE ACCOMPANYING FLIGHT TO SAFETY ). As with a thin market typical of the Akerlof lemons problem (Freixas and Jorge 2007), financial intermediaries have become reluctant to lend to each other if not for very short maturities. The fear that the interbank market might not work well and might fail to recycle the emergency liquidity provided by the central banks around the world in various and coordinated ways has induced banks to choose the rational equilibrium strategy of hoarding some of the extra liquidity instead of recycling it to the banks in deficit.

The resulting equilibrium closely resembles the gridlock described by Freixas, Parigi and Rochet (2000), where the fear that a debtor bank will not honour its obligations induces the depositors of the creditor bank to withdraw deposits, thus triggering the liquidation of assets in a chain reaction. This is the modern form of a “bank run” – financial intermediaries refuse to renew credit lines to other intermediaries, thus threatening the very survival of the system( TRUE. IT IS LIKE A BANK RUN. THAT'S ESSENTIALLY WHAT THE FLIGHT TO SAFETY IS ).

Liquidity in a non-functioning interbank market

Clearly channelling emergency liquidity assistance through the interbank market will not work if the interbank market is not functioning properly. Thus, to limit the systemic feedbacks of the sudden deleveraging of financial institutions, the Fed has taken the unprecedented steps of both increasing the list of collateral eligible for central bank lending and extending emergency liquidity assistance to investment banks, government sponsored entities, money market mutual funds, and a large insurance company (AIG). Preventing a complete meltdown of the financial system has required the central bank to guarantee (and accept potential losses) that most if not all claims on financial institutions will be fulfilled( THAT'S IT. GUARANTEE ).
The panic of 2008 has showed that it would be erroneous to adopt a narrow definition of the LOLR, stating that its role should be limited to the funding of illiquid but solvent depository institutions, while capital injections should be the Treasury’s responsibility( TRUE ). This would lead to a very simplistic analysis of the LOLR’s functions, as the complex decisions would be either ignored or handed over to the Treasury. Such a narrow view of the lender of last resort would create an artificial separation between lending by the lender of last resort at no risk and the closure or bail-out decision by the Treasury. In fact, the recent crisis has proved that the lender of last resort cannot deny support to a systemic, too-big-to-fail financial institution in need( BINGO! AND THE MARKET AND INVESTORS BELIEVED THAT AND HAVE BEEN ACTING UNDER THAT PRESUMPTION ).
To understand the interventions of the lender of last resort in the current crisis, the view of its role has to be a broad one encompassing the closure or bail-out decision defining the lender of last resort as an agency that has the faculty to extend credit to a financial institution unable to secure funds through the regular circuit.

LOLR policy as part of the banking safety net

Once we establish that the lender of last resort policy has to be part of the overall banking safety net, the interdependence of the different components of this safety net becomes clear.

  • First, the existence of a deposit insurance( FDIC ) system limits the social cost of a bank’s bankruptcy, and therefore, reduces the instances where a LOLR intervention will be required. ( TRUE )
  • Second, capital regulation( REQUIRING HIGHER CAPITAL ) reduces the probability of a bank in default being effectively insolvent, and so has a similar role in limiting the costly intervention of the LOLR.( TRUE)
  • Third, the procedures to bail-out or liquidate a bank, determined by the legal and enforcement framework will determine the cost-benefit analysis of a LOLR intervention( WE WISH ).

Adopting a perspective of an all-embracing safety net does not mean that the safety net has to be the responsibility of a unique agent. Often several regulatory agencies interact, because different functions related to the well functioning of the safety net are allocated to different agents( OK ).

It is quite reasonable to separate monetary policy from banking regulation, and the separation of the deposit insurance company from the central bank makes the cost of deposit insurance more transparent. Also, the national jurisdiction of regulation makes cross-border banking a joint responsibility for the home and host regulatory agencies, an issue of particular concern for the banking regulatory authorities in the EU.

Lessons for the LOLR’s role

  • First, we have witnessed how an additional aggregate liquidity injection is not a sufficiently powerful instrument to solve the crisis. ( TRUE )

The illiquidity of financial institutions around the world is, in fact, directly linked not only to their solvency but also to asset prices.

  • Second, central banks around the world have been much more flexible in providing support to the banking industry than initially expected( I DON'T AGREE ).

In other words, that central bank cannot credibly commit to a bail-out policy( YES IT CAN ). Indeed, the arguments regarding the bail-out of banks only if their closure could have a systemic impact (too-big-to-fail), that were intended for an individual bank facing financial distress were soon discarded in favour of a more realistic approach.

The case of Northern Rock, certainly not a systemic bank, illustrates this point. Its liquidation in such a fragile banking environment would have triggered a domino effect with contagion from one institution to another. From that perspective the lesson is that when facing a systemic crisis, the LOLR has to take into account also the “too-many-to-fail” issue, and consider how it will treat all banks that are in a similar position( TRUE ).

  • A third point is that, in a systemic crisis, the safety net is extended to non-bank institutions. ( TRUE )

This may be the result of financial innovation. Yet, because AIG had been issuing credit default swaps, its bankruptcy would have affected the fragility of the banking industry by leading to losses and a lower capital.

  • Fourth, regulators around the world have a mandate to protect the interests of their national investors. ( COME ON )

The international coordination of regulators, and in particular, the European coordination has been helpless when faced with the real cost of the Icelandic crisis. So, the theoretical models of non-cooperative behaviour( YEP ) are the ones to cope ex-ante with the burden-sharing issue."

Truthfully speaking, countries have been pursuing a beggar thy neighbor policy right from the start. A good article, but of limited scope.

Editor’s note: This article draws in part on the work Freixas and Parigi (2008).

References

Allen, F. and Gale, D. (2000). Financial Contagion, Journal of Political Economy, 108, 1-33
Bagehot, W. (1873). Lombard Street: A Description of the Money Market. London: H.S. King
Freixas, X. and Jorge, J. (2007). The role of Interbank Markets in Monetary Policy: A model with rationing, Journal of Money, Credit and Banking, forthcoming.
Freixas, X. and Parigi, B.M. (2008) “Lender of last resort and bank closure policy” CESifo working paper 2286, April 2008
Freixas, X., Parigi, B.M. and Rochet, J-C. (2000). Systemic Risk, Interbank Relations and Liquidity Provision by the Central Bank, Journal of Money, Credit and Banking August, 32, Part 2, 611-638
Freixas, X., Parigi, B.M. and Rochet, J-C. (2004). The Lender of Last Resort: A 21st Century Approach, Journal of the European Economic Association, 2, 1085-1115
Goodfriend, M. and King, R. (1988). Financial Deregulation Monetary Policy and Central Banking, in W. Haraf and Kushmeider, R. M. (eds.) Restructuring Banking and Financial Services in America, AEI Studies, 481, Lanham, Md.: UPA
Goodhart, C. A. E. (1987). Why do Banks need a Central Bank?, Oxford Economic Papers, 39, 75-89
Thornton, H. (1802). An Enquiry into the Nature and Effects of the Paper Credit of Great Britain, London: Hatchard

Thursday, December 18, 2008

“If their goal is to not take a loss on these assets, they should be hiring independent analysts.”

I can't feel good about this. From Bloomberg:

"By Alison Fitzgerald

Dec. 18 (Bloomberg) -- Federal Reserve Chairman Ben S. Bernanke is basing hundreds of billions in emergency lending on credit ratings from companies that gave AAA grades to toxic securities.( Come On )

The Fed has purchased $308.5 billion in commercial paper and lent $631.8 billion under eight credit programs, most of which require appraisals of short-term debt and loan collateral by “major nationally recognized statistical ratings organizations.” That, in effect, means Moody’s Investors Service, Standard & Poor’s and Fitch Ratings ( THE THREE STOOGES ).

It is foolhardy ( TRY INSANE ) to rely on the three New York-based companies, said Keith Allman, chief executive officer of Enstruct Corp., which trains investors in financial modeling and asset valuation. The major raters issued top marks to $3.2 trillion in subprime mortgage-backed securities at the root of the financial crisis.

“They’re outsourcing the credit assessment to a group of people whose recent performance has been unbelievably( TRY BEYOND COMPREHENSION UNLESS BASED ON COLLUSION AND CONFLICT OF INTEREST ) bad,” said Allman, the New York-based author of three books on structured finance and a former vice president in Citigroup Inc.’s securitized markets unit. “If their goal is to not take a loss on these assets, they should be hiring independent analysts ( YOU THINK? ).”

Rating companies are hired by debt issuers to analyze the quality of securities and the likelihood the borrowings will be repaid. Lenders demand higher interest when a rating is low ( I SURE AS HELL WOULD ). If the Fed is relying on unrealistic valuations, it may be charging too little and taking on greater risk than it intends ( REALLY? ), said Donald van Deventer, CEO of Honolulu-based Kamakura Corp., which provides financial software and consulting.

‘Favored Arbiters’

It’s impossible to gauge the analysis of debt in the Fed programs because the bank won’t reveal whom it’s lending to or the assets accepted as collateral( THAT'S A DISGRACE ).

Bloomberg News requested details under the U.S. Freedom of Information Act and filed a federal lawsuit Nov. 7 seeking to force disclosure. In its Dec. 8 response to the lawsuit, the central bank said it was allowed to withhold information about trade secrets and commercial information.( KUDOS TO BLOOMBERG )

Fitch and Moody’s declined to comment specifically on the Fed’s use of their evaluations ( WE'RE BUSY ).

Fed reliance on major rating companies is an important part of “restoring confidence( GAME ASPECT ) in the financial markets,” said Chris Atkins, an S&P spokesman ( BS MERCHANT ).

S&P and Moody’s said in statements e-mailed to Bloomberg that they had taken steps to improve the transparency ( CAN ANYONE VERIFY THIS? ) of their ratings systems. Fitch CEO Stephen Joynt told a Congressional hearing on Oct. 22 that the company has become more conservative( YOU KNOW, THEY COULD EVEN BE TOO CONSERVATIVE NOW BECAUSE THEY'RE TRYING TO RESTORE THEIR TARNISHED REPUTATIONS ) in its ratings.

Retaining Flexibility

Now is the time to end the trio’s “official status as the government’s favored arbiters of credit quality,” said Michael Aronstein, chief investment strategist for New York-based Oscar Gruss & Son Inc., a closely held broker and dealer( ACTUALLY, THE TIME WAS YEARS AGO, BUT I'LL ACCEPT TODAY ).

“From my perspective, their assessments are not worth any more than any other form of advertising,” Aronstein said.( AN EXCELLENT POINT )

The Fed is confident it’s limiting the risks( THAT WORKS FOR ME. NOT ), said Andrew Williams, a spokesman for the Federal Reserve Bank of New York.

“Reserve banks are never obligated to lend,” Williams said. “We retain flexibility( INCOHERENCE ) to decline an issuer if we do not feel secured to our satisfaction or otherwise comfortable with the credit.”

The Fed’s main goal in the rescue programs is to stabilize the banking system and get credit markets working again( RELYING ON IDIOTS SHOULD HELP ), Bernanke said in a December 1 speech to the Greater Austin Chamber of Commerce in Texas.

‘Last Resort’ Lender

The emergency loans are “consistent with the central bank’s traditional role as the liquidity provider of last resort,” he said.

“It should be emphasized that the loans that we make to banks and primary dealers through our standing facilities are both overcollateralized and made with recourse to the borrowing firm, which serves to minimize the Federal Reserve’s exposure to credit risk,” Bernanke said.( I CUT BERNANKE TOO MUCH SLACK )

A senior Fed official told a conference call with reporters on Dec. 16 that the central bank is considering buying lower- rated securities in some of its lending programs to further boost liquidity( GET JAMES GRANT OR WILLIAM GROSS TO DO IT ).

The central bank is discussing with two independent analysis companies, Egan-Jones Ratings of Haverford, Pennsylvania, and Realpoint LLC of Horsham, Pennsylvania, how it might use their services, according to their CEOs. Williams said he couldn’t confirm the talks.( YES PLEASE )

‘Dominant Ratings Agencies’

Policy makers should take the opportunity to spearhead a change in the system by elevating the independents( I AGREE ), said Alex Pollock, a resident fellow at the American Enterprise Institute in Washington.

Unlike the top three, they are paid by investors who subscribe to their services, rather than by businesses whose products they rate( NO CONFLICT OF INTEREST. HEY, THERE'S AN IDEA ). That makes them less likely to grade securities favorably( OH YEH ), Pollock said.

“Why would you limit this to the dominant ratings agencies that helped get us into this situation?” he said.( IF I WERE AN IDIOT OR GRANTING FAVORS )

While the Fed can look at appraisals from any of 10 companies certified by the Securities and Exchange Commission, the three biggest rate ( "RATE" ) the vast majority of instruments.

The Fed also requires that the ratings be publicly available through third parties such as Bloomberg LP, owner of Bloomberg News, which provides assessments from seven certified companies, including Moody’s, S&P and Fitch.

Investment Grade

S&P, a unit of McGraw-Hill Cos. with 8,500 employees, last year rated 93.6 percent of the $707 billion of U.S. non-agency mortgage-backed securities. Moody’s, which employs 3,000, graded 80.2 percent and Fitch, with a payroll of about 2,100, judged 47.3 percent.

The fourth-busiest rater, DBRS Ltd. of Toronto, analyzed 6.8 percent, according to the newsletter Inside MBS & ABS based in Bethesda, Maryland.

Egan-Jones’s ratings for Bear Stearns Cos., which the Fed propped up with emergency funding in March, and on Lehman Brothers Holdings Inc., which filed for bankruptcy in September, were consistently lower than those from the major companies( I WONDER WHY ), according to Sean Egan, president of the service. Egan-Jones has 19 employees( WHO ARE DOING THEIR JOB ).

While Moody’s and S&P classified Lehman debt as A1 and A, respectively, Egan-Jones placed the bank several grades lower, at BBB, as early as May.

A Matrix

Under the emergency programs, the Fed is buying commercial paper that carries at least the equivalent of an A-1 rating, the second-highest for short-term credit. It is lending to banks that can post collateral the major raters deem to be investment grade, or eligible for bank investment. The central bank can reject collateral or commercial paper if it has doubts about creditworthiness or value.

In addition, policy makers reduce the risk of losing money on a declining asset by loaning as little as 75 percent of the market value. They value some securities according to a matrix and use outside firms to appraise the rest, Williams said. The Fed then cuts that figure by as much as 25 percent before lending, according to its Web site.

General Electric Co., Korea Development Bank and Morgan Stanley are among companies that have said they signed up for the commercial paper program.

GMAC LLC, the largest lender to General Motors Corp. car dealers, said in October that it was granted access to the commercial paper facility through its New Center Asset Trust unit. The unit’s paper earned top ratings of P-1 from Moody’s and F1+ from Fitch, though GMAC itself is rated 11 levels below investment grade by Moody’s. S&P on Dec. 5 put the New Center Asset Trust on watch for a possible downgrade.

‘Imprudent’ Lending

Former executives of the three major raters told a House Oversight and Government Reform Committee hearing Oct. 22 that they had relied on outdated models to maximize profits ( COME ON. THEY USED MODELS THAT MADE THEM A LOT OF MONEY ).

Originators of mortgage-backed and asset-backed securities and collateralized debt obligations “typically chose the agency with the lowest standards, engendering a race to the bottom in terms of rating quality,” ( RATINGS SHOPPING ) Jerome Fons, a former managing director of credit policy at Moody’s, testified.

The U.S. Department of Housing and Urban Development said Dec. 4 that it would investigate a Nov. 18 complaint by the National Community Reinvestment Coalition, a Washington-based advocate for affordable housing. Moody’s and Fitch made “public misrepresentations” about the soundness of subprime securities that led to “imprudent” mortgage lending, the coalition said( THIS IS WHAT WE SHOULD BE DOING ).

No Discussions

Senator Carl Levin, a Michigan Democrat and chairman of the Permanent Subcommittee on Investigations, is conducting a “preliminary inquiry”( WHICH WILL GO NOWHERE AND TAKE FOREVER ) into the companies’ role in the financial crisis, he said Dec. 5.

The SEC voted Dec. 3 to bar ratings services from discussing compensation with bankers seeking assessments and to limit gifts to their employees from the underwriters( THIS IS COMMON SENSE ).

From 2002 to 2007, Moody’s and S&P provided top ratings on debt pools that included $3.2 trillion( HOW MUCH? ) of loans to homebuyers with low credit scores and undocumented incomes( THIS NEEDS TO BE INVESTIGATED. IT'S A VIOLATION OF LENDING 101 ), according to data compiled by Bloomberg.

$997.1 Billion

As subprime borrowers defaulted, the companies downgraded more than three-quarters of the structured investment securities known as CDOs that had been rated AAA.

Writedowns and losses on that debt incurred by banks, brokers, insurers and Fannie Mae and Freddie Mac totaled $997.1 billion( UNREAL. OFF A TRILLION DOLLARS AND STILL IN BUSINESS ) worldwide, Bloomberg data show.

The central bank wants to stabilize financial markets and mitigate the effects of the recession, as well as “support the functioning of credit markets,” Bernanke said Dec. 1 in a speech in Austin, Texas. He didn’t address the credit rating system ( THEY ADDRESS HIM ).

The Bloomberg lawsuit is Bloomberg LP v. Board of Governors of the Federal Reserve System, 08-CV-9595, U.S. District Court, Southern District of New York (Manhattan).

Tuesday, December 9, 2008

"That's awfully close to my view of why Congress might reconsider investing in Chrysler given Cerberus's unwillingness to act."

Paul Kedrosky makes a good point, as per usual:

"I like this excerpt from a letter just-disclosed from Fed chair Ben Bernanke to Congress. He is essentially saying that the Fed isn't the lender of last resort in the economy, Congress is.

The Federal Reserve would be extremely reluctant to extend credit where Congress has actively considered providing assistance but, after due consideration, has decided not to act.

[via FT]

Funny he should say that, of course. That's awfully close to my view of why Congress might reconsider investing in Chrysler given Cerberus's unwillingness to act."

Here's my comment:

This is a good point, and I often get comments when I say "the lender of last resort" about the taxpayers being the lenders of last resort.

Of course, strictly speaking, the taxpayers and then congress are the people that fund the Fed. It would be nice to think that we're lending the government money, and, if we buy bonds, I guess that we are, but we are supposedly paying for services rendered by government to and for us, so we don't expect to get most of our taxes back in cash with interest.

However, by the "Lender Of Last Resort" ,we should now clearly understand that government will undoubtedly intervene in financial crises, so that it might be a good idea to talk about what that guarantee really entails and means.

Sunday, November 2, 2008

"Can a Lender of Last Resort Stabilize Financial Markets? Lessons from the Founding of the Fed (NBER) "

Via Paul Kedrosky, this interesting article:

"Can a Lender of Last Resort Stabilize Financial Markets? Lessons from the Founding of the Fed

Asaf Bernstein, Eric Hughson, Marc D. Weidenmier

NBER Working Paper No. 14422
Issued in October 2008
NBER Program(s): DAE ME

---- Abstract -----

We use the founding of the Federal Reserve as a historical experiment to provide some insight into whether a lender of last resort can stabilize financial markets. Following the Panic of 1907, Congress passed two measures that established a lender of last resort in the United States: (1) the Aldrich-Vreeland Act of 1908 which authorized certain banks to issue emergency currency during a financial crisis and (2) the Federal Reserve Act of 1913 which established a central bank. We employ a new identification strategy to isolate the effects of the introduction of a lender of last resort from other macroeconomic shocks. We compare the standard deviation of stock returns and short-term interest rates over time across the months of September and October, the two months of the year when financial markets were most vulnerable to a crash because of financial stringency from the harvest season, with the rest of the year during the period 1870-1925. Stock volatility in the post-1907 period (June 1908-1925) was more than 40 percent lower in the months of September and October compared to the period (1870- May 1908). We also find that the volatility of the call loan rate declined nearly 70 percent in September and October following the monetary regime change."


I'm not going to pay for it, instead I'm going to try and get it at my library. It does sound interesting.