Author Archives: Dirk Niepelt

Border Adjustment Tax

On VoxEU, Mary Amiti, Emmanuel Farhi, Gita Gopinath, and Oleg Itskhoki discuss a border adjustment tax and its consequences.

… a border adjustment tax … would make export sales deductible from the corporate tax base, while expenditure on imported goods would not be deductible … Therefore, if the border adjustment extends to all imports and exports, it is akin to a combination of a uniform import tariff and an export subsidy on all international trade …

… it would limit the incentives for profit shifting across countries by means of transfer pricing towards lower tax jurisdictions … the border adjustment tax is a destination-based tax, linking the tax jurisdiction to the location of consumption, rather than the location of production.

Under certain circumstances … the border adjustment tax has no effects on economic outcomes … Lerner (1936) symmetry [implies] … that a uniform tariff on all imports is equivalent to a uniform tax of the same magnitude on all exports. As a corollary … a combination of a uniform import tariff and an export subsidy of the same magnitude … [has] no effect on imports, exports and other economic outcomes … results in an increase in the home relative wage and domestic cost of production by the amount of the tariff. … the relative cost of domestic production increases proportionally with the cost of imports, as well as with the subsidy to exports, leaving no relative price affected, nor the real wage. … As a result, tax policies that feature a border adjustment, such as the value added tax (VAT), do not have to systematically promote or demote trade.

Amiti, Farhi, Gopinath, and Itskhoki discuss several conditions for neutrality:

  • Flexible wages. If wages are sticky, a nominal exchange rate appreciation may partly substitute.
  • Uniformity of the border adjustment tax. This condition would likely not be met. Exchange rate fluctuations thus would affect some sectors more than others. And imports by non-incorporated businesses would be favored.
  • Foreign currency denomination of gross foreign assets and liabilities. (Not met, see below.)
  • Unexpected, permanent policy change, to prevent anticipation effects and currency appreciation before the fact.
  • Unchanged monetary policy stance, also in other countries, in spite of the exchange rate shock. This condition would likely not be met.

If the conditions for neutrality are met the border adjustment tax generates no international transfer. The fiscal implications depend on the sign of the trade balance. A home country exchange rate appreciation (that keeps relative trade prices and flows unchanged) generates a lump-sum transfer from households to the public sector when households hold net external assets which they use to pay for imports. When households have net external debt and thus, export on net, then the fiscal implications are reversed.

Since the US has currently a negative net foreign asset position, the US must run a cumulative trade surplus in the future. … the overall transfer would be away from the government budget and towards the private sector …

When some gross positions are denominated in domestic currency an appreciation transfers wealth internationally.

Since for the United States, the foreign assets are mostly in foreign currency, while foreign liabilities are almost entirely in dollars, this would generate a massive transfer to the rest of the world and a capital loss for the US of the order of magnitude of 10% of the US annual GDP or more.

US imports and exports are predominantly invoiced in dollars. With sticky pricing a border adjustment tax would raise the relative cost of imported inputs and consumer prices.

US exports … will likely fall together with US imports in the short run, with no clear effect on the trade balance. As trade prices adjust over time, both imports and exports will recover, resulting in a neutral long-run effect of the border adjustment tax on trade.

“Die Vollgeld-Initiative und eine Alternative (The Swiss Sovereign Money Initiative, and an Alternative),” SNB, 2017

In: Thomas Moser, Carlos Lenz, Marcel Savioz and Dirk Niepelt, editorial committee, Monetary Economic Issues Today, Festschrift in Honour of Ernst Baltensperger, Swiss National Bank/Orell Füssli, Zürich, June 2017. PDF of draft.

The sovereign money initiative (Vollgeldinitiative) seeks to gain greater control over the money and credit supply, to increase financial stability and to achieve a fairer distribution of seigniorage income. The initiative’s suggested approach – a ban on active money creation – is inefficient and may even prove ineffective, as it fails to address the core problems. A variant of the initiative, which would allow the public access to electronic central bank money on a voluntary basis, would offer greater benefit at lower cost.

“Monetary Economic Issues Today,” Orell Füssli, 2017

Festschrift in Honour of Ernst Baltensperger, Swiss National Bank/Orell Füssli, Zürich, June 2017, with Thomas Moser, Carlos Lenz, and Marcel Savioz, editorial committee. Publisher’s website.

From the publisher’s website:

»Eine Welt ohne ein gut funktionierendes Zahlungssystem, ohne Geld- und andere Wertaufbewahrungsanlagen, ohne zuverlässige Recheneinheit, das wäre eine Welt mit einem viel tieferen Wohlstandsniveau,in der wir nicht mehr leben möchten.«
Ernst Baltensperger

Ursachen und Folgen der Finanzkrise sind komplex. Zentralbanken und Regulatoren sahen sich gezwungen, in vielerlei Hinsicht unbekanntes Terrain zu betreten. Die ökonomische Forschung wurde mit vielen neuen, oft grundlegenden Fragen zum Finanzsystem und zur Wirtschaftspolitik konfrontiert und ringt bis heute um Antworten.

Diese Festschrift gibt zehn Jahre nach dem Ausbruch der Finanzkrise einen Einblick in die Fragen, mit denen sich die monetäre Ökonomie heute befasst. Sie wird von der Schweizerischen Nationalbank zum 75. Geburtstag von Ernst Baltensperger – einem international renommierten Experten der Geldpolitik und Geldtheorie – herausgegeben.

Elektronisches Geld, unkonventionelle Geldpolitik, negative Zinsen – mit welchen Fragen befasst sich die Wirtschaftswissenschaft heute, und welche Antworten liefert sie?

27 Beiträge von Experten der Makro-, Geld-, Banken und Finanzmarktökonomie für ein besseres Verständnis der Zusammenhänge und Strukturen.

Die kurze und allgemein verständlichen Texte sind für den interessierten Laien – auf Deutsch, Französisch oder Englisch verfasst.

“Sovereign Bond Prices, Haircuts, and Maturity,” IMF, 2017

IMF Working Paper 17/119, May 2017, with Tamon Asonuma and Romain Ranciere. PDF.

Rejecting a common assumption in the sovereign debt literature, we document that creditor losses (“haircuts”) during sovereign restructuring episodes are asymmetric across debt instruments. We code a comprehensive dataset on instrument-specific haircuts for 28 debt restructurings with private creditors in 1999–2015 and find that haircuts on shorter-term debt are larger than those on debt of longer maturity. In a standard asset pricing model, we show that increasing short-run default risk in the run-up to a restructuring episode can explain the stylized fact. The data confirms the predicted relation between perceived default risk, bond prices, and haircuts by maturity.

Legal Tender

Dave Birch blogs about the concept of legal tender: a means to discharge debt.

… you cannot force a retailer to accept legal tender or indeed any other form of tender. If, however, you buy something from them and there is no contractual barrier to the use of any form of tender, and you offer legal tender in payment, and they refuse it, then they cannot enforce the debt in court. That’s what legal tender means: it’s about discharging debts. If you incur a debt you can discharge it with legal tender, but you cannot be forced to incur the debt in the first place …

 

Monte dei Paschi Bail-X

The Economist reports about plans for Monte dei Paschi’s future:

… retail investors in the bank’s junior bonds, many of them ordinary customers. European state-aid rules say that they should lose their money along with shareholders. Technically, they will. In fact, to preserve their savings and avoid a political outcry, they will be deemed to have been “mis-sold” the bonds: they will receive shares which will in turn be swapped for new, safer bonds.

Italy has to come up with a restructuring plan, likely to involve job losses and branch closures, for the commission’s approval. (The ECB must also certify the bank’s solvency.) Bosses’ pay will be capped at ten times the staff average. And Monte dei Paschi must sell its sofferenze, the worst category of non-performing exposures, which in March amounted to 24% of all its loans. A state guarantee will cover senior tranches of these securitised debts. Atlante 2, a fund backed by Italian financial institutions, and others are negotiating with the bank over more junior slices.

Sources of Low Real Interest Rates

In a (December 2015) Bank of England Staff Working Paper, Lukasz Rachel and Thomas Smith dissect the global decline in long-term real interest rates over the last thirty years.

A summary of their executive summary:

  • Market measures of long-term risk-free real interest rates have declined by around 450bps.
  • Absent signs of overheating this suggests that the global neutral rate fell.
  • Expected trend growth as well as other factors affecting desired savings and investment determine the neutral rate.
  • Global growth was fairly steady before the crisis but may (be expected to) fall after the financial crisis. Recently, slower labor supply (demographics) and productivity growth may account for a 100bps decline in the real rate.
  • Desired savings rose, due to demographics (90bps), higher within country inequality (45bps), and higher savings rates in emerging markets following the Asian crisis (25bps).
  • Desired investment fell, due to a lower relative price of capital goods (50bps) and less public investment (20bps).
  • The spread between the return on capital and the risk-free rate rose (70bps).
  • These trends look likely to persist and the “global neutral real rate may settle at or slightly below 1% over the medium- to long-run”.

From page 2 of the paper:
Untitled

See also the summary by James Hamilton; the White House CEA report; and the 17th Geneva report.

ECB Collateral Framework

In an ECB occasional paper, Ulrich Bindseil, Marco Corsi, Benjamin Sahel, and Ad Visser review the European Central Banks’s collateral framework.

From the executive summary, on misconceptions:

… differences e.g. with interbank repo markets: first, central banks are not subject to liquidity risk in the way “normal” market participants are, and can therefore accept less liquid collateral. Second, as the central bank has a zero default probability in its domestic market operations, collateral providers are willing to accept severe haircuts to obtain credit. …

According to the authors the ECB is the most transparent central bank when it comes to its collateral framework. But the latter is also complicated:

However, it is true that the ESCF is relatively broad in terms of the scope of eligible collateral and rather complicated. This is inevitable because of the diversity of financial institutions and markets in the euro area.

The Swiss Phillips Curve

On VoxEU, Stefan Gerlach reviews the case for tilting Phillips curves in Switzerland.

Previous research had suggested that the Swiss Phillips curve had steepened in the second half of the 20th century. Gerlach estimates a Phillips curve model that includes lagged inflation, an output gap measure, and a measure of import price inflation. His model suggests several structural breaks:

The first structural break occurs in 1936-37. The estimated Phillips curves indicate that inflation became much more inertial, as evidenced by the fact that the parameter on lagged inflation more than doubled.

The second break occurs in 1970-71 … While the sensitivity of inflation to the output gap essentially doubles, other parameters are broadly unchanged. This impies that the Phillips curve steepened sharply in the 1970s.

The third break occurs in 1993-94 … The parameter on the output gap falls to zero and becomes insignificant. The parameter on lagged inflation also falls sharply and loses significance. This implies that between 1994 and 2015 inflation in Switzerland was insensitive to the output gap and displayed little persistence, and seems to have fluctuated only in response to changes in import prices.

Orderly Liquidation Authority vs. Financial Institutions Bankruptcy Act

On the Brookings blog, Aaron Klein discusses the Orderly Liquidation Authority that was introduced with the Dodd-Frank Act.

Dodd-Frank extended the FDIC’s authority to resolve failed institutions beyond commercial banks to include the entire bank holding company and all firms designated as Systemically Important Financial Institutions (SIFIs). Thus, if a large, complex financial institution were to fail, the FDIC would have authority to resolve the entire institution, both the commercial bank and the rest of it.

The FDIC needs access to cash to operate these firms while they go through resolution.  Title II of Dodd-Frank created a new fund, the Orderly Liquidation Authority (OLA), to be funded by complex, large institutions and non-bank SIFIs. Unlike the DIF which is pre-funded, OLA is funded only after a failure. The Treasury lends the FDIC money to resolve the institution. If there is a net cost, the FDIC then recoups the money spent by imposing a fee on surviving large, complex financial institutions. In order to invoke the OLA, the FDIC needs the agreement of the Federal Reserve Board of Governors (by a 2/3 majority) and the Treasury Secretary, who is required to consult with the President.

… The FDIC has created a detailed plan on how it would resolve these types of institutions under a scenario called ‘single point of entry’ (SPOE). Under SPOE, the FDIC is appointed as receiver of the top-level holding company, allowing all of its subsidiaries (the commercial bank, investment bank, broker-dealer, insurer, etc.)  to continue operations. The FDIC would then establish a bridge financial company to which the FDIC would transfer the assets and some of the old firms liabilities. The new company would be capitalized by converting a pre-arranged class of debt, which is structured to convert into equity. With equity and limited liabilities, the new firm should be able to access financial markets to fund operations. However, if markets are frozen or otherwise inaccessible, the FDIC could use OLA to lend to the new company.

Klein mentions three criticisms against OLA:

  • It fosters moral hazard.
  • It gives too much discretion to the FDIC.
  • Regular bankruptcy is better. That’s why there is bi-partisan support for “The Financial Institutions Bankruptcy Act of 2017” (“chapter 14”).

 

Government Debt with State Contingent Coupons

On VoxEU, Myrvin Anthony, Narcissa Balta, Tom Best, Sanaa Nadeem, and Eriko Togo discuss the history of government debt with state contingent coupons and offer some lessons.

  • In the mid-19th century, the Confederate states issued cotton-linked bonds
  • In the late 1970s, Mexico issued oil-linked bonds
  • In the 2000s, Turkey issued revenue-indexed bonds
  • Since 2014, Uruguay issues nominal wage-issued bonds
  • Some other examples (figure taken from the column):
  • Obviously, confidence in data quality and thus, quality of institutions is important for the success of such issues.

State contingent securities also have been used in debt restructurings:

The first use of state contingent bonds in debt restructurings occurred in the Brady deals from 1989-97, which allowed commercial banks’ claims on debtor countries to be exchanged for tradable instruments, allowing the banks to clean up their balance sheets. Many of these instruments included ‘value recovery rights’, which envisaged additional debt payments in circumstances where the debtor country’s economic or terms of trade conditions improved substantially … Oil exporters generally linked the payments to oil prices, while other countries linked either to GDP or measures of the terms of trade. Many of the Brady instruments subsequently made significant ongoing upside payments (e.g. Bosnia and Venezuela), while in some cases sovereigns chose to repurchase the instruments as it became clear that upside payments would be triggered (e.g. Mexico, and Bulgaria in the mid-2000s).

More recently, ‘upside’ GDP-warrants have featured as part of the package of bonds issued to creditors in each of the three major restructurings of the past decade: Argentina (2005 and 2010), Greece (2012), and Ukraine (2015). In the case of Grenada (2015), the restructuring deal included instruments with both upside and downside features (Table 2).

Inflation linked bonds have been successful:

Inflation-linked bonds have a long history, dating back to a 1780 issuance by the State of Massachusetts … More recently, they emerged in Latin America in the 1950s and 1960s, in an environment of very high domestic inflation, and the UK became the first advanced economy to issue inflation-linked bonds in 1981. … the global stock of government inflation-linked bonds had grown to around USD 3 trillion by 2015 … Despite this recent growth, inflation-linked debt still accounts for a relatively small share of sovereign debt portfolios in most countries …

Related VoxEU column on policy implications.

Initial Coin Offerings and the Pecking Order

On Alphaville, Izabella Kaminska comments on the pecking order induced by initial coin offerings (ICOs).

All of this raises an important point about actual shareholder rights within these structures. Say a legally-incorporated institution with actual shareholders dishes out an uncapped amount of tokens promising a share of revenues or dividends via the ICO process. Do shareholders’ rights to those revenue/dividends trump rights of the token holders? And if so, how does that square with the way risk is distributed through these systems? As Unseth notes, more often than not, it’s the token holders taking the bulk of the early concept risk, yet the inferiority of their ranking relative to shareholders kind of sees the latter receiving a free lunch.

Tax Evasion and Wealth Inequality

The Economist reports about a study by Annette Alstadsæter, Niels Johannesen and Gabriel Zucman who matched leaked information from Swiss banks and Panamanian shell companies with Scandinavian wealth records. Their findings:

  • Tax evasion is progressive. The average / top 1% / top 0.01% Scandinavian household paid 3% / 10% / 30% fewer taxes than it should.
  • Accordingly, estimates of wealth inequality (based on tax data) likely underestimate the degree of inequality.

Governments Adopt the Blockchain, To Improve Efficiency and Build Trust

The Economist reports about government initiatives aimed at using blockchain technology in the public sector.

  • Possible uses include land registries, identity-management systems, health-care records, or elections.
  • Proponents expect the technology to improve efficiency and transparency and foster trust.
  • Adoption requires significant investments.
  • According to a survey “nine in ten government organisations say they plan to invest in blockchain technology to help manage financial transactions, assets, contracts and regulatory compliance by next year.”
  • Sweden tests a blockchain-based land registry; Dubai’s government wants to completely shift to blockchain technology by 2020; Estonia stores health records and protects its shared government systems using blockchain-like technolog; Georgia’s land registry uses blockchain technology and has processed 160,000 transactions; Ukraine wants to become “one of the world’s leading blockchain nations,” not least to build trust between government and citizens.

Single Resolution Board and Banco Popular Bailin

In the FT, Martin Arnold, Tobias Buck, and Rachel Sanderson discuss the significance of the Banco Popular bailin.

The Single Resolution Board was created at the start of 2015 as a pan-European authority for dealing with failing banks. Since then however, the institution has remained almost entirely untested. Now with Banco Popular it has shown its teeth at last. The SRB, chaired by Elke Koenig, acted swiftly after it was informed by the European Central Bank that Popular was “failing or likely to fail” on Tuesday. It imposed heavy losses on shareholders and junior bondholders before transferring Popular’s remaining equity to Santander for only €1. The move is an unprecedented step as it imposes losses for the first time on holders of alternative tier one (AT1) securities — the riskiest bonds in a bank’s capital structure that are designed to absorb losses in a crisis.

On Publishing and Cost Benefit Analysis

On his blog, Gilles Saint-Paul comments on the publication process in economics.

Of course I was wrong in all accounts. The publication process in economics is not a publication process, it is a validation process by which we acquire a certain rank in a certain pecking order. Submitting a paper to a journal has nothing to do with research dissemination, it is far more similar to taking an exam or participating in a sports competition. The actual dissemination takes place mostly orally, in seminars and conferences; these seminars and conferences are also important validation events, because they allow authors to signal some of their characteristics that may influence their position in the pecking order, while not being easy to infer from their papers.

Now, when you take an exam as a student, you are graded by your professor, not by a fellow student – who would be a competitor if this exam is actually a contest. …

Yet this is the way our own profession is organized. Each submission is “peer reviewed’, that is, it has to be accepted by anonymous referees who happen to be participating in the same beauty contest as the author(s), most often in the same subcategory. At a minimum, as believers of cost-benefit analysis, we should consider that the journal editors and referees themselves perform a cost-benefit analysis when deciding whether or not to publish a paper. I must say that if I apply such a theory to explain my own experience with acceptances and rejections, I easily get an R2 of 80 %.

UBS Business Solutions AG

In the NZZ, Hansueli Schöchli reports about further steps by UBS, the Swiss bank, to prepare for the next financial crisis. In the future, a legally independent service unit—UBS Business Solutions AG—provides other business units with critical internal services, including payments, trading systems as well as legal services. A “Master Service Agreement” specifies that the service unit remains operative even if other business units fail.

Die UBS vollzieht nun einen weiteren Schritt. Sie überträgt dieser Tage die konzerninternen Dienstleistungen für das Schweizer Geschäft in die rechtlich selbständige Dienstleistungseinheit UBS Business Solutions AG. Übertragen werden damit im Inland rund 8000 Mitarbeiter. Weltweit soll diese Service-Einheit bis Ende Jahr etwa 18 000 Beschäftigte umfassen. Zu den betroffenen internen Dienstleistungen zählen unter anderem Informatik, Zahlungsverkehr, Handelssysteme, Risikomanagement, Rechtsdienst, Personal und Marketing. Hauptzweck der Übung: Auch wenn Teile des Konzerns in den Konkurs schlittern, sollen kritische Dienstleistungen weiterhin sichergestellt sein. «Dies ist eine Lehre aus der Pleite von Lehman», sagt Markus Ronner, Chef Notfallplanung bei der UBS.

Ein globales «Master Service Agreement» regelt die Service-Lieferungen gegenüber gut 130 UBS-Gesellschaften. Nebst Preisen und Qualitätserfordernissen ist dabei auch geregelt, dass die Service-Einheit im Fall des Konkurses eines Konzernteils ihre Dienstleistungen gegen Bezahlung noch mindestens zwei Jahre lang weiterführen muss. Wenn interne Kunden zahlungsunfähig werden, muss die Service-Gesellschaft genügend Liquidität haben, um in einer Übergangszeit ihre Dienste aufrechterhalten zu können; die Rede ist von sechs Monaten als Referenzmarke.

Marvin Goodfriend, the Fed’s Board of Governors, and Negative Rates

In the FT, Sam Fleming and Demetri Sevastopulo report that the White House considers Marvin Goodfriend for the Federal Reserve’s Board of Governors.

He has criticised the Fed’s crisis-era balance sheet expansion, saying the central bank should generally not purchase mortgage-backed securities, and has advocated the use of monetary policy rules to guide policy, as has Mr Quarles. …

At the same time, however, Mr Goodfriend has been willing to contemplate the use of deeply negative rates to stimulate growth — something that the Fed has thus far not embarked upon. In 1999 he wrote that negative rates were a feasible option, years before central banks started actually experimenting with them.

To implement negative rates while preserving cash, Goodfriend has advocated a flexible exchange rate between deposits and cash. On Alphaville, Matthew Klein quotes from a recent paper of Goodfriend’s:

The zero bound encumbrance on interest rate policy could be eliminated completely and expeditiously by discontinuing the central bank defense of the par deposit price of paper currency. … the central bank would no longer let the outstanding stock of paper currency vary elastically to accommodate the deposit demand for paper currency at par. …

The reason to abandon the pegged par deposit price of paper currency is analogous to the … reasons for abandoning the gold standard and fixed exchange rate: it is to let fluctuations in the deposit demand for paper currency be reflected in the deposit price of paper currency so as not to destabilize the general price level … the flexible deposit price of paper currency would behave as it actually did when the payment of paper currency for deposits was restricted in the United States during the banking crises of 1873, 1893, and 1907.

MIT vs Trump, Contd.

In an open letter, MIT President Rafael Reif writes (from the opening paragraph):

Yesterday, the White House took the position that the Paris climate agreement – a landmark effort to combat global warming by reducing greenhouse gas emissions – was a bad deal for America. Other nations have made clear that the deal is not open to renegotiation. And unfortunately, there is no negotiating with the scientific facts.

In March, Reif questioned planned federal spending cuts. And in January, he condemned Trump’s immigration restrictions.

The SNB’s Currency Interventions

On the FT’s Alphaville blog, Matthew Klein reviews Swiss monetary policy over the last years and its effect on the real economy. He concludes that

it seems the SNB’s relentless accumulation of foreign assets has been pointless — at best. More likely, the behaviour qualifies as predatory mercantilism at the expense of the rest of the world, especially Switzerland’s hard-hit neighbours.

Smart Ponzi Games in the Blockchain

On the FT’s Alphaville blog, Izabella Kaminska points to a paper by Italian academics arguing that the Ethereum technology tends to incubate Ponzi schemes.

The uniqueness of the “smart Ponzi” is its capacity to protect the identity of the initiator but also its ability to persist even after being exposed. Since contracts are unmodifiable and thus unstoppable there is no central authority to terminate the execution of the scheme or force the initiator to refund victims. What’s more, the inability to shut it down means victims can be led to believe the scheme will last forever.

Does Decentralized Intermediation Add Value?

On the FT’s Alphaville blog, Izabella Kaminska questions the value of decentralization (and thus, blockchain technology) in intermediation.

Decentralisation is, in almost all cases, not an efficiency. To the contrary, it’s a cost that adds complexity and creates an unnecessary burden for both users and operators unless centralised layers are added on top of it — defying the whole point. …

At the end of the day, there are only two groups of people prepared to go to costly lengths to decentralise a service which is already available (in what is often a much higher quality form) in a centralised or conventional hierarchal state. One group is criminals and fraudsters. The other is ideologues and cultists. …

It’s not privacy, because a centralised system can be encrypted just as much as a blockchain-based one.

Effects of Climate Change for Switzerland

In the NZZ, Christian Speicher summarizes expected consequences of climate change for Switzerland by 2050–2060.

  • Mean temperatures exceed the 1980–2009 average by 1.6–2.9 degrees Celsius.
  • The temperature increase is more pronounced in Summer than in Winter. But ski resorts below 2000m are no longer competitive.
  • Less precipitation in Summer, maybe more in Winter.
  • More extreme weather events.
  • Increased need for water storage and conservation.

 

Brexit and Third-Country Treaties

In the FT, Paul McClean reports that according to FT estimates and as a consequence of Brexit, the UK will have to negotiate more than 700 treaties with third countries. More than 160 countries need to be dealt with; Switzerland, the US and Norway stand out.

Some negotiations have to be concluded very soon:

… the EU-US Open Skies accord for airlines, were agreed when the forces of liberalisation were at their peak. The political mood has hardened considerably since then. … The timing is tight. The US needs to know the UK’s arrangements with the EU before it can commit, and that may not be clear until late 2018. … “It is not as if you can wait until March 2019 to see what the regime will be. You probably need clarity by the early summer or spring of 2018.”