ifo Schnelldienst 16/2018, August 23, 2018. PDF.
Central bankers often argue that CBDC would increase the risk of bank runs. On his blog, JP Koning rejects this notion. After all, he retorts, during a confidence crisis bank customers would no longer have to queue to withdraw cash; lender of last resort support would be provided much more quickly; and “large” cash holders would continue to shift funds into treasury bills, not into CBDC.
The general criticism here is that during a crisis, households and businesses will desperately shift their deposits into the ultimate risk-free asset: central bank money. Presumably when deposits were only redeemable in banknotes (as is currently the case) and one had to trudge to an ATM to get them, this afforded people time for sober contemplation, thus rendering runs less damaging. But if small depositors can withdraw money from their accounts while in their pajamas, this makes banks more susceptible to sudden shifts in sentiment, goes the Carney critique.
I don’t buy it. … even in jurisdictions without deposit insurance, I still don’t think that shifts into digital currency in times of stress would exceed shifts into banknotes. A bank will quickly run out of banknotes during a panic as it meets client redemption requests, and will have to make arrangements with the central bank to get more cash. Thanks to the logistics of shipping cash, refilling the ATMs and tellers will take time. In the meantime a highly visible lineup will grow in front of the bank, exacerbating the original panic. Now imagine a world with digital currency. In the event of a panic, customer redemption requests will be instantaneously granted by the bank facing the run. But that same speed also works in favor of the bank, since a request to the central bank for a top-up of digital currency could be filled in just a few seconds. Since all depositors gets what they want when they want, no lineups are created. And so the viral nature of the panic is reduced.
But what about large depositors like corporations and the rich … ? During a crisis, won’t these sophisticated actors be more likely to pull uninsured funds from a bank, which have a small possibility of failure, and put them into risk-free central bank digital currency?
I disagree. In a traditional economy where banknotes circulate, CFOs and the rich don’t generally flee into paper money during a crisis, but into short-term t-bills. Paper money and t-bills are government-issued and thus have the same risk profile, t-bills having the advantage of paying positive interest whereas banknotes are barren. The rush out of deposits into t-bills is a digital one, since it only requires a few clicks of the button to effect. Likewise, in an economy where digital currency circulates, CFOs are unlikely to convert deposits into barren digital currency during stress, but will shift into t-bills. The upshot is that banks are not more susceptible to large deposit shifts thanks to the introduction of digital currency—they always were susceptible to digital bank runs thanks to the presence of short-term government debt.
Of course, depending on the type of CBDC, central banks might also choose to pay negative interest on CBDC in order to depress demand for it.
In a CEPR discussion paper, Òscar Jordà, Björn Richter, Moritz Schularick, and Alan M. Taylor suggest that higher bank capital ratios help stabilize the financial system ex post but not ex ante, and that illiquidity breeds fragility.
Abstract of their paper:
Higher capital ratios are unlikely to prevent a financial crisis. This is empirically true both for the entire history of advanced economies between 1870 and 2013 and for the post-WW2 period, and holds both within and between countries. We reach this startling conclusion using newly collected data on the liability side of banks’ balance sheets in 17 countries. A solvency indicator, the capital ratio has no value as a crisis predictor; but we find that liquidity indicators such as the loan-to-deposit ratio and the share of non-deposit funding do signal financial fragility, although they add little predictive power relative to that of credit growth on the asset side of the balance sheet. However, higher capital buffers have social benefits in terms of macro-stability: recoveries from financial crisis recessions are much quicker with higher bank capital.
On his blog, John Cochrane reports about a Hoover panel including him, Charles Plosser, and John Taylor.
Cochrane focuses on the liability side. He favors a large quantity of (possibly interest bearing) reserves for financial stability reasons. Plosser focuses on the asset side and is worried about credit allocation by the Fed, for political economy reasons. Taylor favors a small balance sheet. Cochrane also talks about reserves for everyone, but issued by the Treasury.
In a BIS working paper (January 2015), Bengt Holmstrom summarizes some of the implications of the research on information insensitive debt. He cautions against moves to increase transparency in debt markets and defends the shadow banking system. He explains why opacity and information insensitivity are valuable and argues that debt-on-debt arrangements are (privately) optimal.
It all started with pawn shops:
The beauty lies in the fact that collateralised lending obviates the need to discover the exact price of the collateral. …
Today’s repo markets … are close cousins of pawn brokering with similar risks for the parties involved. … the buyer of the asset (the lender) bears the risk that the seller (the borrower) will not have the money to repurchase the asset and just like the pawnbroker, has to sell the asset in the market instead. The seller bears the risk that the buyer of the asset may have rehypothecated (reused) the posted collateral and cannot deliver it back on the termination date. … the risk that a pawnbroker may sell or lose the pawn was a big issue in ancient times and could explain why the Chinese pawnbrokers were Buddhist monks. …
People often assume that liquidity requires transparency, but this is a misunderstanding. What is required for liquidity is symmetric information about the payoff of the security that is being traded so that adverse selection does not impair the market. …
… stock markets are in almost all respects different from money markets …: risk-sharing versus liquidity provision, price discovery versus no price discovery, information-sensitive versus insensitive, transparent versus opaque, large versus small investments in information, anonymous versus bilateral, small unit trades versus large unit trades. … money markets operate under much greater urgency than stock markets. There is generally very little to lose if one stays out of the stock market for a day or longer. This is one reason the volume of trade is very volatile in stock markets. In money markets the volume of trade is very stable, because it could be disastrous if, for instance, overnight debt would not be rolled over each day. …
… debt-on-debt is optimal … . It is optimal to buy debt as collateral to insure against liquidity shocks tomorrow and it is optimal to issue debt against that collateral tomorrow. In fact, repeating the process over time is optimal, too, so debt is in a very robust sense the best possible collateral. This provides a strong reason for using debt as collateral in the shadow banking system. …
Panics always involve debt. Panics happen when information insensitive debt (or banks) turns into information-sensitive debt.
I was asked to play devil’s advocate in a debate about “secular stagnation.” Here we go:
Alvin Hansen, the “American Keynes” predicted the end of US growth in the late 1930s—just before the economy started to boom because of America’s entry into WWII. Soon, nobody talked about “secular stagnation” any more.
75 years later, Larry Summers has revived the argument. Many academics have reacted skeptically; at the 2015 ASSA meetings, Greg Mankiw predicted that nobody would talk about secular stagnation any more a year later. But he was wrong; at least in policy circles, people still discuss and worry about secular stagnation. As we do tonight.
In his 2014 article, Summers does not offer a definition of “secular stagnation,” in fact the article barely mentions the term. But Summers tries to offer a unifying perspective on pressing policy questions. The precise elements of this perspective change from one piece in the secular stagnation debate to the other.
Summers (2014) emphasizes a conflict between growth and financial stability: He argues that before the crisis, growth was built on shaky foundations that resulted in financial instability; and after the crisis, projections of potential output were revised downwards.
Summers frames this conflict in terms of shifts in the supply of savings on the one hand and investment demand on the other, which are reflected in lower real interest rates.
He identifies multiple factors underlying these shifts:
- The legacy of excessive leverage
- Lower population growth
- Redistribution to households with a higher propensity to save
- Cheaper capital goods
- Lower after tax returns due to low inflation
- Global demand for CB reserves
- Later added: Lower productivity growth
- Risk aversion which creates a wedge between lending and borrowing rates
All this, Summers argues, is aggravated by the fact that nominal interest rates are constrained by the ZLB, and that low rate policies induce risk seeking and Ponzi games—that is, new financial instability—by investors.
I am not convinced by the diagnosis. First, I feel uncomfortable with “secular” theories of “lack of aggregate demand.” I guess I believe in some variant of Says’ law; I agree that the massive surge of CB reserves is relevant in this context but even this cannot rationalize “secular” demand failure (presumably, the surge will stop and may even be reversed or prices will adjust).
Second, I disagree on population growth. We have two workhorse models in dynamic macroeconomics, the Ramsey growth model and the overlapping generations model. In the former, population growth does not affect the long-term real interest rate (R = gamma^sigma / beta). In the latter, population growth can have an effect by changing factor prices; but in this model the real interest rate is unrelated to the economy’s growth rate.
Third, productivity growth clearly is relevant. Gordon would support the view that the outlook is bleak on that front, others would disagree and predict the opposite. We will know only in a few decades.
Fourth, domestic factors cannot be the dominant explanation. With open financial markets, global factors shape savings and interest rates.
Fifth, real interest rates have trended downward for thirty years, including in decades when no one worried about “demand shortfalls.” (Nominal rates trended downward too, but that is easy to explain.) But it is true that historically, low real rates tend to coincide with low labor productivity growth. Over the last years, low real rates have gone hand in hand with a stock market boom; this suggests financial frictions or increased risk aversion.
There are competing narratives of what is going on. For example, Kenneth Rogoff argues that we are experiencing the usual deleveraging process of a debt supercycle; in Rogoff’s view, the secular stagnation hypothesis does not attribute sufficient importance to the financial crisis. Bob Hall has identified an interesting structural break: Since 2000, households and in particular, the teenagers and young adults in those households supply less labor (they play video games instead).
Summers discusses three policy strategies in his 2014 article:
- Wait and see (he associates this with Japan)
- Policies that lower nominal interest rates to stimulate demand; Summers mentions various risks associated with this strategy, related to bubbles, redistribution, or zombie banks
- Fiscal and other stimulus policies: Fiscal austerity only if it strongly fosters confidence; regulatory and tax reform; export promotion, trade agreements, and beggar thy neighbor policies; and public investment
I am not convinced by the medicine either. In general, I miss a clear argument for why policy needs to respond. We might be very disappointed about slower future growth. But this does not imply that governments should intervene. The relevant questions are whether we identify market failures; whether governments can improve the outcome (or whether they introduce additional failures); and whether it’s worth it. And this must be asked against the background that some of the trends described before may reverse sooner than later. For example, aggregate savings propensities are likely to fall when baby boomers start to dis-save, and Chinese savings have started to ebb.
More specifically, the Japanese approach over the last decades strikes me as following the third, stimulus strategy favored by Summers rather than the first, wait and see strategy that he dislikes. So we should discount this argument. (In any case, Japan might be a bad example since its per capita growth is not that low.) I agree that I don’t see much scope on the monetary policy side. Monetary policy also has the problem that interest rate changes have income in addition to substitution effects, and that it has lost effectiveness, both fundamentally and in terms of public perceptions. I believe that our views on monetary policy transmission will dramatically change in the next ten years (think for example about the discussion on Neo-Fisherianism). The interesting thing about Summers’ third, stimulus strategy is that it is much less demand focused than conventional wisdom would have it (think of regulation and taxes and confidence to some extent as well).
Finally, the argument for public investment as the instrument of choice is much weaker than Summers suggests. One can think of a situation where private investment is held back for various reasons and as a consequence, interest rates are low and public investment is “cheap.” Nevertheless, the optimal policy response need not be to invest; it could be preferable to eliminate the friction on private investment. For example, with excessively tight borrowing constraints, tax cuts for private investors could be appropriate. If we believe that demographics is the problem then investment could be counter productive as well (dynamic inefficiency in the OLG context). And public investment as an instrument for stimulus is problematic for politico-economic reasons. Low interest rates do not imply that debt is “for free.” It indicates that the supply of risk-free savings is ample, for example because markets are very concerned about tail risks.
Lawrence H. Summers (2014), “U.S. Economic Prospects: Secular Stagnation, Hysteresis, and the Zero Lower Bound,” Business Economics 49(2), 65—73.
In BPEA, Natasha Sarin and Larry Summers argue that bank stock has not:
… we find that financial market information provides little support for the view that major institutions are significantly safer than they were before the crisis and some support for the notion that risks have actually increased. …
… financial markets may have underestimated risk prior to the crisis … Yet we believe that the main reason for our findings is that regulatory measures that have increased safety have been offset by a dramatic decline in the franchise value of major financial institutions, caused at least in part by these new regulations.
This table is taken from their paper:
However, their finding need not be as bad as it sounds. After all, bank regulators intended to insulate taxpayers against bank failure and to render the financial system more shock proof, not bank equity.
On his blog, Ben Bernanke discusses the merits of the Fed’s strategy to slowly reduce the size of its balance sheet to pre crisis levels. Bernanke (with reference to a paper by Robin Greenwood, Samuel Hanson and Jeremy Stein) suggests that this strategy should be reconsidered:
First, the large balance sheet provides lots of safe and liquid assets for financial markets. This might strengthen financial stability. (DN: In my view, there are also reasons to expect the opposite.)
Second, a larger balance sheet can help improve the workings of the monetary transmission mechanism, in particular if non-banks can deposit funds at the Fed. Currently, the Fed accepts funds from private-sector institutional lenders such as money market funds, through the overnight reverse repurchase program (RRP). (DN: I agree. As I have argued elsewhere, access to central bank balance sheets should be broadened.)
Third, with a large balance sheet and thus, large bank reserve holdings to start with, it could be easier to avoid “stigma” in the next financial crisis when banks need to borrow cash from the Fed but prefer not to in order not to signal weakness. (DN: Like the first, this third argument emphasizes banks’ needs. In my view, monetary policy should not emphasize these needs too much because it is far from clear whether bank incentives are sufficiently aligned with the interests of society at large.)
Bernanke also discusses the reasons why the Fed does want to reduce the balance sheet size.
First, in a financial panic, programs like the RRP could result in market participants depositing more and more funds at the Fed until the interbank market would be drained of liquidity. But these programs could be capped.
Second, a large balance sheet increases the risk of large fiscal losses for the Fed and thus, the public sector. Losses could trigger a legislative response and undermine the Fed’s policy independence. But these risks could be kept in check if the Fed invested in government paper that constitutes a close substitute to cash, such as three year government debt. (DN: But why, then, shouldn’t financial market participants hold three year government debt rather than reserves at the Fed? Because cash is much more liquid than government debt … But what does this mean?)
Jonathan McMillan proposes a systemic solvency rule which stipulates that
[t]he value of the real assets of a company has to be greater than or equal to the value of the company’s liabilities in the worst financial state. (p. 147)
That is, the financial assets of a company have to be financed by equity. This reminds of Kotlikoff’s limited purpose banking, see here and here. McMillan (who is actually two persons, a banker and a journalist) argues that Kotlikoff’s proposal
is a step in the right direction to address the boundary problem, [but] it creates an overwhelming public authority [that monopolizes monitoring]. Moreover, it does not solve the boundary problem. Limited purpose banking requires the regulator to differentiate between financial and nonfinancial companies. … Finding clear legal criteria to categorize a company as financial is impossible. (p. 140)
In the FT, Jim Brunsden reports that the European Commission’s 2013 proposal to install a financial transactions tax has not made much progress. At least nine countries have to sign up.
The report highlights that key differences remain on how to craft exemptions from the tax, including the problem of how to shield transactions in other non-participating EU countries such as Britain. Other splits concern how to protect market-making activities by banks, and also what carveouts should apply for derivatives that are used by traders to hedge risk when they buy sovereign debt.
In his blog, John Cochrane points to SoFi, a FinTech company, as proof that banking services can be delivered by institutions without the traditional characteristics of a bank.
SoFi finances loans by selling equity. The loans are securitized and the cash is reinvested in loans. As John points out:
- A “bank” (in the economic, not legal sense) can finance loans, raising money essentially all from equity and no conventional debt. And it can offer competitive borrowing rates — the supposedly too-high “cost of equity” is illusory.
- There is no necessary link between the business of taking and servicing deposits and that of making loans. Banks need not (try to) “transform” maturity or risk.
- To the extent that the bank wants to boost up the risk and return of its equity, it can do so by securitizing loans rather than by borrowing. (Securitized loans are not leverage — there is no promise of your money back when you want it. Investors bear any losses immediately and without recourse.)
- Equity-financed banking can emerge without new regulations, or a big new Policy Initiative. It’s enough to have relief from old regulations (“FDIC-free”).
- Since it makes no fixed-value promises, this structure is essentially run free and can’t cause or contribute to a financial crisis.
Liz Marshall, Sabrina Pellerin, and John Walter of the Richmond Fed estimate that in December 2014, 61% of financial sector liabilities in the US were protected by explicit (35%) or implicit (26%) government guarantees.
In the FT, Richard Milne reports about Marvin Goodfriend and Mervin King’s “Review of the Riksbank’s Monetary Policy 2010–2015.” The report criticizes monetary policy decisions after but not before 2011. It recommends a core inflation target, organizational changes and the possibility to suspend the inflation target.
In his FT blog, Larry Summers argues for a “quite radical” change in government debt-management. He proposes several lessons:
- “Debt management is too important to leave to Federal debt managers and certainly to leave to the dealer community. … when interest rates are near zero, it has direct implications for monetary and fiscal policy and economic performance … and … financial stability.”
- “… it is fairly crazy for the Fed and Treasury, which are supposed to serve the national interest, to pursue diametrically opposed debt-management policies. This is what has happened in recent years, with the Fed seeking to shorten outstanding maturities and the Treasury seeking to term them out.”
- “Standard discussions of quantitative easing … are intellectually incoherent. It is the total impact of government activities on the stock of debt that the public must hold that should impact on financial markets.”
- In the US, “the quantity of long-term debt that the markets had to absorb in recent years was well above, rather than below, normal. This suggests that if QE was important in reducing rates or raising asset values it was because of signalling effects … not because of the direct effect of Fed purchases.”
- “The standard mantra that federal debt-management policies should seek to minimise government borrowing costs is … wrong and incomplete. … it is risk-adjusted expected costs that should be considered. … it is hard to see why the effects of debt policies on levels of demand and on financial stability should be ignored.”
- “The tax-smoothing aspect, which is central to academic theories of debt policy, is of trivial significance.”
- Rather than providing opportunities for carry trade, “[t]reasury should reverse the trend towards terming out the debt. Issuing shorter term debt would also help meet private demands for liquid short-term instruments without encouraging risky structures such as banks engaged in maturity transformation.”
- “Institutional mechanisms should be found to insure that in the future the Fed and Treasury are not pushing debt durations in opposite directions.”
In a Federal Reserve Bank of New York staff report, Rodney Garratt, Antoine Martin, James McAndrews and Ed Nosal argue in favor of “Segregated Balance Accounts” (SBAs):
SBAs are accounts that a bank or depository institution (DI) could establish at its Federal Reserve Bank using funds borrowed from a lender. … the funds deposited in an SBA would be fully segregated from the other assets of the bank … only the lender of the funds could initiate a transfer out of an SBA; consequently, the borrowing bank could not use the reserves that fund an SBA for any purpose other than paying back the lender. … the loan made by the lender to the bank would be collateralized by the reserve balances in the SBA account.
The authors argue that SBAs could foster competition in money markets and
help strengthen the floor on overnight interest rates that is created by the payment of interest on excess reserves.
The proposal is related to topics I discussed in previous blog posts:
- Narrow banking proposals.
- Reserves for Everyone—Towards a New Monetary Regime.
- Reserves for Everyone—Towards a New Monetary Regime, Vox.
- Notenbankgeld für Alle?, NZZ.
- Sovereign Money in Iceland?
- Reserves for All.
James McAndrews of the Federal Reserve Bank of New York doubts the merits of negative interest rates. He lists the following types of complications:
- Legal and operational frictions
- Economic frictions
- Pass-through to market rates, and retail v. wholesale
- Effects of negative rates on the health of financial intermediaries
- Signal of deflation
- Public acceptance
In the eleventh chapter of “Across the Great Divide: New Perspectives on the Financial Crisis,” Darrell Duffie argues that central clearing parties administering tri-party repurchase agreements cannot be resolved under current bankruptcy law, including recent provisions under the Dodd-Frank act. He argues that
a financial institution should not operate key financial market infrastructure backed by the same capital that supports much more discretionary forms of risk-taking, such as speculative trading or general lending.
In the ninth chapter of “Across the Great Divide: New Perspectives on the Financial Crisis,” Martin Baily and Douglas Elliott argue that significant progress has been made in safeguarding financial stability:
- Due to higher bank capital requirements, the FDIC can intervene before equity is wiped out.
- Liquidity requirements work in the same direction and render fire sales less likely.
- Easier resolution of distressed financial institutions helps to shield taxpayers when a bank fails.
- Better macro prudential oversight helps to manage systemic risks.
The authors discuss these dimensions in much detail.
In the seventh chapter of “Across the Great Divide: New Perspectives on the Financial Crisis,” Peter Fisher argues that the Fed’s mandate should be reviewed:
- The Fed did not address leverage early enough. In the future, monetary policy should weigh financial stability objectives more strongly—at the cost of employment and inflation objectives.
- Moral hazard should be addressed before, not during the crisis.
- “Since the end of the financial crisis, the Fed is making the mistake of conceiving of its mandate over too short—and too narrow—a horizon. This permits the Fed to avoid articulating the difficult intertemporal trade-offs that it is making.”
- The Fed’s mandate is not crystal clear and has been interpreted differently over the years. In light of the new experiences, it should be clarified or adjusted.
A Hoover Press book edited by Martin Baily and John Taylor collects articles about the financial crisis. The contributions in “Across the Great Divide: New Perspectives on the Financial Crisis” include (with links to PDF files):
- Introduction, Martin Neil Baily and John B. Taylor
- Chapter 1: How Efforts to Avoid Past Mistakes Created New Ones: Some Lessons from the Causes and Consequences of the Recent Financial Crisis, Sheila C. Bair and Ricardo R. Delfin
- Chapter 2: Low Equilibrium, Real Rates, Financial Crisis, and Secular Stagnation, Lawrence H. Summers
- Chapter 3: Causes of the Financial Crisis and the Slow Recovery: A Ten-Year Perspective, John B. Taylor
- Chapter 4: Rethinking Macro: Reassessing Micro-foundations, Kevin M. Warsh
- Chapter 5: The Federal Reserve Policy, Before, During, and After the Fall, Alan S. Blinder
- Chapter 6: The Federal Reserve’s Role: Actions Before, During, and After the 2008 Panic in the Historical Context of the Great Contraction, Michael D. Bordo
- Chapter 7: Mistakes Made and Lesson (Being) Learned: Implications for the Fed’s Mandate, Peter R. Fisher
- Chapter 8: A Slow Recovery with Low Inflation, Allan H. Meltzer
- Chapter 9: How Is the System Safer? What More Is Needed?, Martin Neil Baily and Douglas J. Elliot
- Chapter 10: Toward a Run-free Financial System, John H. Cochrane
- Chapter 11: Financial Market Infrastructure: Too Important to Fail, Darrell Duffie
- Chapter 12: “Too Big to Fail” from an Economic Perspective, Steve Strongin
- Chapter 13: Framing the TBTF Problem: The Path to a Solution, Randall D. Guynn
- Chapter 14: Designing a Better Bankruptcy Resolution, Kenneth E. Scott
- Chapter 15: Single Point of Entry and the Bankruptcy Alternative, David A. Skeel Jr.
- Chapter 16: We Need Chapter 14—And We Need Title II, Michael S. Helfer
- Remarks on Key Issues Facing Financial Institutions, Paul Saltzman
- Concluding Remarks, George P. Shultz
- Summary of the Commentary, Simon Hilpert
Larry Summers explains his secular stagnation hypothesis in Vox: If the full employment real rate of interest (FERIR) is low and so is inflation, full employment may be out of reach. Price rigidities may amplify the effect if they induce expectations of falling prices. In addition, low interest rates tend to undermine financial stability, by fostering an aggressive search for yield and Ponzi schemes. Several factors suggest that the FERIR has been falling. Summers proposes to operate under a higher inflation rate target and to spend more on public investment.
Philip Stafford and Tracy Alloway report in the FT that under the stewardship of the International Swaps and Derivatives Association, large banks
have agreed to give up their rights to immediately end derivatives contracts with crisis-hit rivals after global regulators pressed for an industry cross-border agreement to stop counterparties terminating deals with troubled institutions.
The agreement covers 90% of the OTC derivatives market. Incentives to live up to it are weak; not amending one’s contracts with counter parties amounts to the dominant strategy in a prisoners’ dilemma situation. Moreover, institutional investors may have fiduciary duties to end their contracts if a counter party defaults so attaining the cooperative equilibrium may not be possible without legal changes.
DN: But if the initiative succeeds, could it undermine the effective seniority status of derivatives?
Joint with CEPR, the Study Center Gerzensee organised a conference on law and economics. The program can be viewed here and papers can be downloaded from CEPR’s website. The focus session on bank resolution featured contributions by
- Patrick Bolton and Jeffrey Gordon (paper)
- Martin Hellwig (paper, slides)
- Mathias Dewatripont (slides)
- Gerard Hertig
- Wolf-Georg Ringe (paper)
- Paul Tucker (paper)
In his talk, Jeff Gordon explained how Dodd-Frank extends the FDIC’s resolution technology from the 1930s to “non-banks” that engage in banking business. Dodd-Frank establishes an “Orderly Liquidation Authority” and in title II a “Single Point of Entry” by putting a holding company (topco) into receivership. The objective is to minimise disruption costs for large institutions, to preserve the going-concern value of the company and to avoid collateral damage. Single point of entry also helps resolve cross-border issues. No comparable institutional framework is available in the EU. In the crisis, US authorities implemented ad-hoc alternatives to bankruptcy: Mergers (which require the approval of shareholders and therefore make it hard to wipe out the target’s shareholders) worked for Bear Stearns (JPMorgan Chase, Maiden Lane, Fed) but not for Lehman Brothers (Barclays, Fed) because the UK authorities refused to waive Barclays shareholder approval, fearing fiscal implications. Recapitalisation with third party funds (Fed) in the case of AIG also required shareholder approval and protected creditors and counter-party claims.
Patrick Bolton cautioned that the rules for the topco are still not clear and discussed alternatives to Dodd-Frank in the bankruptcy code. He emphasised the role of qualified financial contracts and debtor-in-possession interventions.
Martin Hellwig argued that the government rescue of Hypo Real Estate reflected the political will to help influential creditors rather than systemic importance. He questioned the viability of single-point-of-entry arrangements in cross-border resolution, pointing to lack of trust among national regulators. He questioned whether internationally active banks can ever be resolved in an efficient manner and asked whether, in that light, they are socially valuable.
Mathias Dewatripont warned that excessive emphasis on bail-in arrangements can undermine financial stability, for example by having the expectation of a small haircut applied to senior debt tranches trigger a run on all senior debt. To avoid such an outcome, he favoured a clearly identified seniority structure with a significant balance-sheet share of “bail-inable” liabilities. He questioned the usefulness of higher capital requirements, arguing that “prompt corrective action” is politically infeasible unless the equity ratio has fallen below a very low value, 2 percent say.
Wolf-Georg Ringe favoured holding-company structures with sufficient “bail-inable” debt.
Paul Tucker discussed potential problems with the holding-company/single-point-of-entry strategy, related to centralised operations (IT). He raised the issue of accountability and the potential lack thereof if companies are resolved by regulators rather than judges, and he wondered whether national regulators can commit to collaborate across borders if need be. He favoured “bail-inable” debt over equity because the former gives incentives to monitor without the incentive to speculate on the upside.
Gerard Hertig warned that regulatory incentives lead to bank mergers rather than resolution, in particular because authorities tend to be more lenient in crisis times. He argued that because of deposit insurance, resolution worked well in Japan until recently.
Patrick Bolton argued that cocos are badly designed as their triggers are too low and they refer to accounting equity. Instead, he favoured reverse convertible bonds that can be converted by the issuer.
Oliver Hart argued that resolution has the advantage over cocos that the management gets replaced.
Many panelists voiced scepticism towards narrow banking proposals. They feared that control over the money supply might turn into control over credit, referring to the discussion in the US during the 1930s.