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inside:

2

• How To Plan for the

Unexpected
• Bernanke Drops By Bank
Commissioners’ Meeting

3

4

• Ask These

Questions about
Bank Liquidity

5

• Fed Foreclosure

Forums Talk
Solutions

6

• How Will Fannie

and Freddie
Operate in the
Future?

• Central Banker Online

Compares Present Bank
Failures with 1980s Collapses
• Senior Bankers:
Ask the Fed

Winter 2008

News and Views for Eighth District Bankers

Gloomy Times Continue at District Banks

Michelle Neely is an economist at the Federal Reserve
Bank of St. Louis.

Not a Pretty Picture1
3rd Q 2007

2nd Q 2008

3rd Q 2008

Return on average assets2

District Banks

1.06%

0.81%

0.67%

Peer Banks

1.18

0.61

0.45

District Banks

3.91

3.79

3.79

Peer Banks

4.02

3.83

3.83

District Banks

0.23

0.52

0.60

Peer Banks

0.25

0.71

0.76

District Banks

1.02

1.53

1.68

Peer Banks

1.00

1.92

2.19

Net interest margin

Loan Loss Provision Ratio

Nonperforming loans Ratio

3

SOURCE: Reports of Condition and Income for Insured Commercial Banks
1
2

3

Banks with assets of more than $15 billion have been excluded from the analysis.
All earnings ratios are annualized and use year-to-date average assets or average earning
assets in the denominator.
Nonperforming loans are those 90 days or more past due or in nonaccrual status.

1

I

n response to tight credit markets and a
still-weakening economy, earnings and asset
quality at Eighth District and U.S. peer banks
continued their descent in the third quarter.
In the District, return on average assets (ROA)
declined another 14 basis points in the third quarter
to 0.67 percent. ROA was down 39 basis points
from its year-ago level. (See adjoining table.) U.S.
peer banks (banks with average assets of less than
$15 billion) fared even worse, with ROA declining
to 0.45 percent in the third quarter compared with
1.18 percent one year ago.
The decline in ROA in the third quarter was
due to a slight increase in net noninterest expense
and a more substantial increase in loan loss provisions. The trend in earnings components was
similar at U.S. peer banks. Once again, the
average net interest margin (NIM) stayed flat at
3.79 percent at District banks. Loan loss provisions (LLP) as a percent of average assets hit 0.60
percent at District banks and 0.76 percent at U.S.
peer banks.
The LLP ratio has almost tripled at District
banks and has more than tripled at peer banks
over the past year. The coverage ratio (the loan
loss reserve as a percentage of nonperforming
loans) has sunk over the same time period at both
sets of banks. At the end of the third quarter,
District banks had just 84 cents reserved for every
dollar of nonperforming loans compared with
$1.28 reserved one year ago.
Increases in loan loss provisions and declines in
coverage ratios can be traced to continued deterioration in asset quality at District and U.S. peer
banks. The ratio of nonperforming loans to total
loans rose to 1.68 percent at District banks and
2.19 percent at peer banks in the third quarter.
In the District, increases in nonperforming real
estate loans—especially construction and land
development (CLD) loans—and commercial and

industrial loans drove the uptick in the composite nonperforming loan ratios. Almost 5 percent
of District banks’ outstanding CLD loans were
nonperforming at the end of the third quarter,
compared with less than 2 percent one year ago.
At U.S. peer banks, the decline in quality is even
more pronounced, with almost 7 percent of outstanding CLD loans in nonperforming status.
Despite the bleak picture painted by the earnings and asset quality numbers, District banks
remain on average well-capitalized. At the end
of the third quarter, just three banks (out of 707)
failed to meet one of the regulatory capital minimums. District banks averaged a leverage ratio of
9.07 percent. n

www.stlouisfed.org

By Michelle Neely

Feditorial
How To Plan for the Unexpected
By Julie Stackhouse, senior vice president, Banking Supervision and Regulation

B

efore the disruptions in financial markets,
“planning for the unexpected” was typically
described as contingency planning for disaster recovery. In today’s uncertain environment,
planning for the unexpected involves a different
contingency: alternative sources of liquidity.
One source of potential liquidity for banks is the
Federal Reserve discount window. For smaller
banks, the Fed’s primary credit program (a Fed
discount window lending program) has become
attractive. Loans under this program are available
for up to 90 days and are priced at the primary
credit rate—currently, the federal funds rate plus
25 basis points. Other banks may be interested
in the Term Auction Facility (TAF). Under this
program, auctions are announced and funds made
available through a bidding process, similar to the
process used in Treasury auctions.
For both of these facilities, the institution must
be in generally sound financial condition, have
filed legal documents with the Federal Reserve
and pledged acceptable collateral. Details can be
found on the Fed’s discount window web site at
www.frbdiscountwindow.org.
Banks that are not eligible for participation in
the TAF have special liquidity planning challenges.
Contingency liquidity sources may not be as

reliable as expected. For example, when an institution is designated as “undercapitalized” for prompt
corrective purposes, it must seek a waiver from
the FDIC for the acceptance, renewal or rollover
of brokered deposits. (See Prompt Corrective Action
at www.stlouisfed.org/publications/cb/2008/c/
pages/views.html.) Moreover, the effective yield
on deposits may be subject to interest rate restrictions. (See Part 337.6(b)(3)(ii) of the FDIC’s Rules
and Regulations.) Funding arrangements may also
be reduced, or the lender may request the pledge of
additional collateral.
Therefore, contingency liquidity planning should
consider funding concentrations. Concentrations
might include a large reliance on uninsured deposits, dependency on a few large depositors or a single
lender, or large blocks of funds maturing near the
same point in time.
Contingent liabilities should also be considered,
such as unfunded loan commitments and letters of
credit. Rapid changes in contingent liabilities can
result in a quick drain on liquidity when sources of
liquidity are no longer available.
Reviewing your bank’s liquidity position with
your board of directors is a good idea. Plan for the
unexpected—be comfortable that your sources are
available should conditions unexpectedly change. n

Bernanke Drops By Bank Commissioners’ Meeting

www.stlouisfed.org

Shown are, from left: Arkansas Commissioner Candice
Franks, Senior Vice President Julie Stackhouse,
Tennessee Commissioner Greg Gonzales, Kentucky
Commissioner Charles Vice, Chairman Ben Bernanke,
Missouri Commissioner Eric McClure, President Jim
Bullard, Mississippi Commissioner John Allison, Illinois
Commissioner Jorge Solis and Indiana Commissioner
Judith Ripley.

2

Julie Stackhouse, senior vice president of the
St. Louis Fed’s Banking Supervision and Regulation division, hosted the Eighth District’s seven
state bank commissioners and their deputies at
a Sept. 11 meeting at the St. Louis Fed. The
commissioners also met Fed Chairman Ben Bernanke and St. Louis Fed President Jim Bullard
and discussed the state of the economy.

Ask These Questions about Bank Liquidity
How do I think about the liquidity risk of insured highcost CDs and brokered deposits?
When an institution is designated “undercapitalized” for prompt corrective action purposes, it
must receive a waiver from the FDIC to accept,
renew or roll brokered funds. Moreover, the rate
paid on deposits may not exceed 75 basis points
over the local market rate. This creates an important stress scenario that cannot be overlooked.

By Tim Bosch and Gary Corner

T

he current financial environment has
drawn bankers’ attention to an often forgotten component of the CAMELS rating:
the “L” component, liquidity. Management of
liquidity has become a challenge for many banks
experiencing asset quality issues. In some cases,
the inability to cover maturing deposit outflows
can cause a bank to fail.
Locally generated FDIC-insured deposits have
Can I count on Federal Home Loan Bank advances as a
historically been a stable source of funds for banks.
contingency liquidity source?
Unfortunately, over the past decade stable core
When a borrower’s financial condition begins to
deposits have declined as a percentage of most
deteriorate, any lender may take steps to reduce a
banks’ liabilities. Banks now rely on many other
possible loss on the loan, such as require additional
sources of funds that are not as stable, includcollateral, reduce the available line or call the
ing high-rate deposits, Federal Home Loan Bank
loan. If you rely significantly on FHLB advances,
advances, fed funds purchases and brokered deposits.
consider a reduction in the line as another scenario
If your bank depends significantly on noncore
to test.
deposit funding, then it is important to “stress test”
liquidity and contingency liquidity
Should I consider the discount window
sources. Here are a few commonin my liquidity contingency planning?
sense questions to get started:
This is a simplified analysis. Find
Setting up a borrowing relationship and pledging collateral to
a
downloadable
version
with
30-,
What is a good way to measure liquidity?
the discount window is a sensible
60an
180-day
increments
at
Your liquidity position is best esticomponent of a contingency
www.stlouisfed.org/publications/
mated as a flow of funds over mulliquidity plan. Discount wincb/2008/d.
tiple time periods. In other words,
dow credit is then available when
measure expected cash inflows and
unexpected events occur. Note,
Time Horizon
outflows in near-, medium- and
however, that federal law limits the
Sources of liquidity
longer-term periods. A simplified
Federal Reserve’s ability to provide
Loan collections and maturities
analysis might include elements in
discount window credit to underInvestment collections and maturities
the adjoining list.
New deposits generated
capitalized and critically underThis analysis can be conducted
Other sources
capitalized institutions.
under multiple scenarios, ranging
Uses of Liquidity
from normal operations to broad,
Loan originations
Your bank regulator expects you
systemic disruptions. The point of
Deposit maturities
to adopt a well-thought out policy
Scheduled Investment/asset purchases
stress scenarios is to identify liquidity
and implement commensurate
Federal funds purchased maturities
vulnerabilities and to identify appropractices to control liquidity risk.
Repurchase agreement maturities
priate contingency funding sources
Having a realistic, tested, continFHLB borrowing maturities
well in advance of the need.
gency funding plan is essential to
Estimated borrowing capacity
Available federal funds purchased capacity
Available repurchase agreement capacity
Available FHLB capacity
Available FRB discount window capacity
Available other lines/borrowing capacity
Total Estimated Borrowing Capacity
Total Change in Cash
Beginning Cash
Ending Cash
Other Unencumbered,
Readily Marketable Assets

weather today’s volatile financial
environment. n

Tim Bosch is a vice president of the
Banking Supervision and Regulation
division and Gary Corner is a senior
examiner at the St. Louis Fed.
3

Total Change in Liquidity

www.stlouisfed.org

How many and what type scenarios
should be completed?
This depends on your liquidity risk
profile. At a minimum, we suggest
two scenarios: a normal state and
one with your bank undergoing a
specific stress state. If your bank is
exposed to significant asset quality
issues, we suggest more scenarios.
As discussed later, liquidity sources
that are dependable in good times
often disappear when the balance
sheet becomes distressed.

FRB discount window maturities
Other borrowing maturities

Foreclosure Forums Present Solutions

M

give realistic expectations for all parties
concerning scarce funding resources,

•

alleviate foreclosures so that properties
don’t become REO (real estate owned)
or lead to evictions,

•

develop mutually agreeable plans for
vacant property, and

•

bring all parties to the table.

The short takeaway from the forums is that
each municipality needs a good, localized plan.
Youngstown, Ohio, Mayor Jay Williams, who spoke
at the final forum Oct. 20 in Washington, D.C.,
said smart citywide planning is critical. As with
many forum speakers, Williams talked about how
to use the $3.92 billion Neighborhood Stabilization
Program money allocated by HUD (Department of
Housing and Urban Development) in September.
While the money is welcome, Williams cautioned
that during hard economic times, some people
think that any investment is good investment.
“There must be a good plan because resources
invested in needy but ill-prepared cities will result
in disaster. We have to maintain a pragmatic
approach of what we can actually do and when,”
Williams said. “Using a peanut-butter strategy,
where resources are spread thin, will typically fail
to achieve measurable successes.”
A place at the table. Good planning should
include all parties. Bankers, servicers and lenders
can and should definitely play a role in community revitalization, said Faith Schwartz, executive
director of the nationwide HOPE NOW Alliance.
“There needs to be a bridge between servicers
and locals to get a grip on these unprecedented
volumes and understand each other,” Schwartz
said at the final forum. Mary Tingerthal of the
Housing Partnership Network agreed. “It’s apparent that nonprofits alone won’t solve this,” Tingerthal said at the Washington, D.C., forum. “Even

•

HSBC Bank USA: “Your Home Counts”
pilot REO disposition program. See www.
stlouisfed.org/RRRseries/event2/Event2_
Dallis.pdf.

•

Living Cities: weak-market programs in
Cleveland and Detroit. See www.stlouisfed.
org/RRRseries/event4/Event4_Novotny.pdf.

•

Genesee County (Michigan) Land
Bank: vacant property disposition program. See www.stlouisfed.org/RRRseries/
event5/Event5_kildee.pdf.

See www.stlouisfed.org/RRRseries for forum
notes and PDF files of the presentations. For more
on foreclosures, see the Foreclosure Resource
Center at www.stlouisfed.org/foreclosure. n

4

•

though it’s sometimes tough for an angry mayor or
nonprofit to call a servicer to talk about a specific
property, it’s necessary to try to understand the
situation from the servicer’s point of view.”
That’s something Jack Bailey can appreciate.
As a mortgage officer with Heartland Bank in
Chesterfield, Mo., Bailey needs to produce. From
the bank’s perspective, he’s an originator who
closes loans. “But it’s critical that we plug into
what’s going on beyond what we’re doing,” says
Bailey, who attended the St. Louis forum, held
Sept. 24-25. “The concentrations of foreclosures
and vacant properties are quite dramatic—and it’s
incumbent upon us as individuals and organizations to do something.
“One thing that can help, though, is remembering that every loan—good or bad—is unique, and
every issue is a one-on-one situation,” Bailey says.
Using the tools already at hand—such as offering
an FHA loan instead of a prime loan—can help.
Cynthia Jordan, business development representative at Southwest Bank in St. Louis, also attended
the St. Louis forum and saw some opportunity.
“The forum gave us new ideas and strategies to
add to what we are already doing as a community
or looking at putting in place,” said Jordan, whose
bank has a foreclosure task force.
What next? If you’re wondering what you
can do next, check out what some of the following organizations are doing. (Links go to forum
presentations.)

www.stlouisfed.org

any cities across the nation had already
been struggling with their own problems
when the foreclosure crisis hit. The
foreclosure crisis wiped out decades of neighborhood stabilization progress in a matter of months,
according to Alan Mallach, nonresident senior fellow at The Brookings Institution.
Mallach was one of several hundred participants
from community groups, the private sector, various levels of government, and the Federal Reserve
System who gathered for a series of foreclosure
forums this summer and fall across the country. Some of the common themes that developed
include the need to:

How Will Fannie and Freddie
Operate in the Future?

T

he U.S. mortgage market has gone through
enormous change during the past few years. Fannie
Mae and Freddie Mac, two giant
government-sponsored enterprises
(GSEs), have been at the center
of much of this upheaval. Today,
Fannie and Freddie are in an
unprecedented and paradoxical
position. They dominate mortgage lending to an extent never
seen before, yet the firms themselves lie in financial ruin. How
will Fannie and Freddie operate in
the future?
Fannie, Freddie and the
financial crisis. Fannie Mae
(Federal National Mortgage Association) and Freddie Mac (Federal
Home Mortgage Loan Corp.)
dominated the mortgage market
early in the decade, with almost
$2.5 trillion of mortgages underwritten to their credit standards—
so-called prime conventional/
conforming mortgages—during
the peak year of 2003. This
accounted for 62 percent of
all mortgage loans made that
year. The surge since early 2007
occurred because other mortgage
lenders were contracting or exiting
the market altogether. Moreover, Congress increased the loan
amounts that Fannie and Freddie could purchase—that is, the
conforming-loan limit was raised,
creating the new category of “conforming jumbo loans.”
Despite their commanding
market presence, Fannie Mae
and Freddie Mac collapsed into
government conservatorship on
Sept. 7, 2008, a form of suspended

animation in which holders of the GSEs’ common and
preferred stock were virtually wiped out. But the mortgage operations continued uninterrupted, and all the debt
and mortgage-backed securities that the firms issued were
guaranteed by the federal government.
How did we get here? Despite many advantages,
including an expectation by many market participants
that the federal government would not let them fail,
Fannie and Freddie badly misjudged the risks involved in
mortgage lending. The GSEs and many other mortgage
lenders essentially (and foolishly) had assumed that house
prices could not decline significantly across the entire
country at the same time. Once this began to happen
after 2006, the rate of default and the losses lenders suffered on each default began to increase sharply. The initial
spike in defaults appeared in subprime mortgages, but, by
mid-2008, it had become clear that near-prime and even
prime mortgage portfolios were suffering loss rates many
times higher than previously expected. Because they
held so little capital against unexpected losses, Fannie and
Freddie—by far the largest mortgage funders and guarantors in the market—had became insolvent.
The future of Fannie and Freddie. Many people
are asking how Fannie and Freddie will operate in the
future. No one really knows because the fates of Fannie
and Freddie lie with a future Congress. Federal lawmakers
must decide whether, and how, to rehabilitate and reform
the GSEs.
There are at least four distinct options under consideration. Will we go back to the traditional GSE model, in
which the federal government provided numerous financial and competitive advantages to the firms while private
shareholders provided equity capital and expected competitive returns on their stock? Will we, instead, liquidate the
GSEs’ operations and allow the private sector to fill the
void created by the disappearance of Fannie and Freddie?
Or will we effectively nationalize the former GSEs, operating them much like the Federal Housing Administration
(FHA) and Ginnie Mae? Or will the GSEs’ huge portfolios be carved up into many small mortgage lenders that are
privatized separately with no federal-government preferences or guarantees?
The ultimate decisions on Fannie’s and Freddie’s fates
are sure to be hard-fought politically. Whatever political choices are made, the technical and legal obstacles to a
smooth transition likely will be formidable. Yet, the future
of mortgage lending in the United States depends critically
on how the fates of Fannie and Freddie are resolved. n

www.stlouisfed.org

William R. Emmons is an officer and economist
with the Banking Supervision and Regulation
division at the Federal Reserve Bank of St. Louis.

5

By William R. Emmons

Central Banker Online Compares
Present Bank Failures with
Collapses during the 1980s
Check out this issue’s online-only content at
www.stlouisfed.org/cb, including the following:
•

Failures of banks, thrifts and other
key financial institutions set a
record in 2008

•

St. Louis Fed President Jim Bullard
discusses systemic risk

•

Fed examines what the data say about
crime rates relative to a community’s
desirability

•

Treasury offers new Treasury
Covered Bond Framework

•

Major Federal Reserve
action reports gathered at new site

•

Reg Z fee-based trigger increase
takes effect Jan. 1

•

Reg R entity compliance outlines bank
broker exceptions

•

Fed outlines Treasury early ACH/
check deliveries

Senior Bankers:
Ask the Fed
The St. Louis Fed recently began a call-in program
for senior officers of state-member banks and bank
holding companies.
Titled Ask the Fed, the monthly call-in program features
representatives of the Fed’s Banking Supervision and Regulation division taking your questions following a briefing on a
pertinent financial or regulatory topic.
Potential topics include economic updates, liquidity issues,
loan losses and causes of financial challenges.
At the present time, the program is by invitation only. If
you are a senior officer of a state-member bank or bank holding company and did not receive an e-mail or postcard invitation, contact the St. Louis Fed’s Pat Pahl at 314-444-8858 or
patrick.pahl@stls.frb.org.

FIRST-CLASS
US POSTAGE
PAID
PERMIT NO 444
ST LOUIS, MO
P.O. Box 442
St. Louis, Mo. 63166-0442
Editor
Scott Kelly
314-444-8593
scott.b.kelly@stls.frb.org
Central Banker is published
quarterly by the Public Affairs
department of the Federal
Reserve Bank of St. Louis.
Views expressed are not
necessarily official opinions
of the Federal Reserve
System or the Federal Reserve
Bank of St. Louis.

CENTRAL BANKER | WINTER 2008
https://www.stlouisfed.org/publications/central-banker/winter-2008/bank-thrift-and-other-key-financial-institution-failures-setignominious-standard-in-2008

Views: Bank, Thrift and Other Key Financial
Institution Failures Set Ignominious Standard in
2008
William R. Emmons , Andrew P. Meyer
Although the most banks and thrifts have failed during 2008 since 1994, the number of failed institutions is
minuscule compared with the number of failures that occurred during the 1980s and early 1990s. (See Figure
1, and the FDIC’s failed-bank list for the latest failures.) In the peak year of 1989, there were 534 failures,
including 206 banks and 328 thrifts. And even those turbulent years pale in significance when compared with
the early 1930s, when more than 1,000 banks failed each year between 1930 and 1933. Indeed, the 4,000
banks that were “suspended” during the single year of 1933 exceed the total number of insured banks and
thrifts that have failed since then (less than 3,600).
Yet, 2008 is setting an ignominious standard in another way. The total assets of the 14 banks and three thrifts
that had failed by Oct. 24 total about $350 billion, more than in any previous year. The bulk of this total is
represented by the assets of Washington Mutual’s two thrifts ($307 billion) and IndyMac ($31 billion). These
failures, however, are not the first of large banks or thrifts. (See Figure 2.) Adjusting for inflation, the previous
peak year for the asset values of bank and thrift failures was in 1989, at $250 billion.
Even more significant are the banks that came very close to failing but were acquired by another bank with
government assistance, and the non-depository financial institutions that collapsed or were given special
government assistance. Measured by total assets at the parent- or holding-company level at the end of last
year, there have been seven major U.S. financial institutions so far that failed, were rescued or were given
“open-bank assistance” by the Federal Reserve and/or the Federal Deposit Insurance Corporation (FDIC), or
used the Treasury’s Capital Purchase Program to avoid failure. (See table.) In several cases, the total assets
measurement seriously understates the scope of their operations and their importance to the financial system.
The largest of these institutions was AIG, a global insurance and financial-services company with more than $1
trillion of assets. Six of the seven financial institutions were larger than the largest depository institution ever to
fail, Washington Mutual.
If we add the 17 bank and thrift failures during 2008 to these seven major firms that collapsed or were rescued
with government assistance, the value of total assets of financial failures (or virtual failures) this year exceeds
$5 trillion—which we estimate may be greater than the total assets of all previous financial failures in the
history of the United States.
Moreover, these figures do not reflect the full extent of government intervention into the financial system this
year. The Federal Reserve and the federal government have expanded direct lending to a wide range of
financial firms through the Fed’s discount window and by providing liquidity backstops for money-market
mutual funds and commercial-paper markets. In sum, 2008 sets an unfortunate standard for financial failures
and government intervention into financial markets—one we all hope will never be repeated or exceeded.

Figure 1

Bank Suspensions (1921-1933) and Bank and Thrift Failures (1934
to Present)

SOURCES: Milton Friedman and Anna Schwartz, A Monetary History of the United States (1963) for 19211933, FDIC (2008) for 1934-2008. Note that present-day failures can barely be seen in this chart in
comparison to the previous ones.

Figure 2

Assets in Bank and Thrift Failures (Billions of 2008 Dollars) 1980
to Present

SOURCE: FDIC

Table

Major Financial Firms That Failed, Were Rescued by the Federal
Reserve or the Federal Government, Were Acquired With
Extraordinary Federal Assistance, or Were Acquired in
Connection with the Treasury’s Capital Purchase Program During
2008 (through Oct. 24)

Name

Type of institution

Holding-company assets
at end of 2007 financial
year (billions of dollars)

AIG

Insurance company/financial conglomerate

$1,061

Fannie Mae

Government-sponsored enterprise

883

Wachovia*

Financial holding company/commercial bank

783

Freddie Mac

Government-sponsored enterprise

764

Lehman Brothers

Securities firm/investment bank

660

Bear Stearns

Securities firm/investment bank

395

National City**

Financial holding company/commercial bank

150

Total assets

$4,696

SOURCE: Company financial statements.
* Government-assisted takeover by Citigroup was withdrawn in favor of takeover by Wells Fargo.
** Takeover by PNC Corp. was assisted by the Treasury’s Capital Purchase Program.

ABOUT THE AUTHORS
William R. Emmons
Bill Emmons is an assistant vice president and economist in the
Supervision Division at the Federal Reserve Bank of St. Louis.

Andrew P. Meyer
Andrew Meyer is a senior economist at the Federal Reserve Bank of
St. Louis.

CENTRAL BANKER | WINTER 2008
https://www.stlouisfed.org/publications/central-banker/winter-2008/st-louis-fed-president-jim-bullard-discusses-systemic-risk

Views: St. Louis Fed President Jim Bullard
Discusses Systemic Risk
Systemic risk can be a tricky term to define, but it’s one that is getting much attention following the recent
shake-ups in our economy, St. Louis Fed President Jim Bullard said Oct. 2 in a speech to faculty members and
graduate students in economics at Indiana University—Bloomington.
“Systemic risk is often associated with incomplete information,” Bullard said. “In the case of a banking system,
systemic risk can arise when a bank’s depositors—even relatively sophisticated depositors, such as other
banks—become unsure about the condition of the bank in which they hold their funds.” (Read the full text or
watch a video of the speech. Bullard’s remarks start about 11 minutes into the clip.)
Greater supervision of financial firms, Federal Reserve oversight of the payments and settlement system, and
creation of an orderly framework to liquidate investment banks and other securities firms might decrease
systemic risk, Bullard said. No firm, though, should be considered too big or too connected to fail because of
systemic concerns, he said.
“Bailouts are expensive—not just because they commit taxpayer funds, but because they can encourage
behavior that increases subsequent systemic risk,” Bullard said. “A firm that expects government protection if
its investments go awry may take bigger gambles than a firm that expects no protection.”
For more from Bullard, see his speeches and “Worry Less about Systemic Risk, More about Inflation” in the
October 2008 Regional Economist.

CENTRAL BANKER | WINTER 2008
https://www.stlouisfed.org/publications/central-banker/winter-2008/fed-research-examines-poverty-concentrations-in-america

Views: Fed Research Examines Poverty
Concentrations in America
Concentrated poverty in America—those pockets of dense, crippling poverty exemplified by photos coming out
of New Orleans after Hurricane Katrina—is the focus of new research from the Federal Reserve.
The report, The Enduring Challenge of Concentrated Poverty: Case Studies from Communities Across the
U.S., highlights themes that are common in all of the low-income communities that were studied: lack of
human capital development, high unemployment and inadequate housing. However, concentrated poverty
occurs in varying social and economic contexts and the need for tailored strategies to tackle the problem is
clear, according to the report.
The Federal Reserve collaborated with the Brookings Institution’s Metropolitan Policy Program to study the
issue. While concentrations of poor people living in poor neighborhoods have been observed in large cities,
concentrated poverty also exists in smaller cities, immigrant gateways, suburban municipalities and rural
counties. The resulting report contains case studies, undertaken by the Federal Reserve System’s Community
Affairs Offices, of 16 high-poverty communities.
One of the case studies focuses on Holmes County, Miss., located in the Federal Reserve’s Eighth District.
With a poverty rate that stood at more than 41 percent in 2000, Holmes County is both geographically and
economically isolated.
While the communities were diverse, four common factors emerged: poverty became concentrated over time,
and decades of disinvestments are difficult to turn around; residents are often isolated from the larger
community, and local organizations lack the resources to meet the community needs; many of these
neighborhoods experienced significant demographic changes, such as an increase in immigrant households, a
rise in single-parent families, or both; and, these communities exist in both weak and strong regional
economies.
High-poverty communities included in the report are: Albany, Ga.; Atlantic City, N.J.; Austin, Texas; Blackfeet
Reservation, Montana; Cleveland, Ohio; El Paso, Texas; Fresno, Calif.; Greenville, N.C.; Holmes County,
Miss.; Martin County, Ky.; McDowell County, W.Va.; McKinley County, N.M.; Miami, Fla.; Milwaukee, Wis.;
Rochester, N.Y.; and Springfield, Mass. The report’s findings will help the Federal Reserve in its ongoing work
with community development partnerships in these areas.
Read the full report. Single copies of the publication are free from: Publications, Mail Stop 127, Federal
Reserve Board, 20th and C Streets, N.W., Washington, DC 20551; or by calling 202-452-3245.

CENTRAL BANKER | WINTER 2008
https://www.stlouisfed.org/publications/central-banker/winter-2008/new-fed-study-examines-crime-rates-at-the-city-level

Views: New Fed Study Examines Crime Rates at
the City Level
Whether a community is perceived as a desirable place to live and visit is determined, in part, by its crime
rates. Naturally, crime rates are important to a community’s economic success and have been the topic of
numerous academic studies. Most of these have used data at the county, state or national level to explore
long-term relationships between economic conditions and crime and between deterrence and crime.
A new study from the Federal Reserve Bank of St. Louis, Local Crime and Local Business Cycles, narrows the
data down to the city level and looks at whether economic conditions and deterrence affect the short-term
growth rates of seven major crimes: murder, rape, assault, robbery, burglary, larceny and motor vehicle theft.
Authors Tom Garrett, St. Louis Fed economist, and Lesli S. Ott, senior research associate, zero in on monthly
data for 23 large cities in the United States, including St. Louis, Memphis, Little Rock and Louisville.
Overall, Garrett and Ott found little evidence that changes in a city’s economic conditions or its number of
arrests significantly affected short-term crime rates. This suggests that short-run changes in economic
conditions do not induce individuals to commit crimes. That being said, the authors did find that short-term
economic changes in some of the cities influenced crimes against property. “This likely reflects the fact that
nonviolent property crimes are more likely to result in financial gain than violent crimes,” the study says.
The authors also found strong evidence that law enforcement reallocates its resources in response to
increases in crime, especially those that are more visible to businesses and tourists, such as robbery, vehicle
theft and assault.
Finally, the study revealed that relationships between economic conditions and crime and between deterrence
and crime are not likely to be the same across cities or regions. This suggests that, to implement effective
public policy at the local level, it is important to conduct local analyses, using more disaggregated data.
The report is available at www.stlouisfed.org/community. For a print copy, call the Fed’s Cynthia Davis at 314444-8761. Garrett is making presentations on the report in the Eighth District. The next meeting is Dec. 9 in
Memphis.

CENTRAL BANKER | WINTER 2008
https://www.stlouisfed.org/publications/central-banker/winter-2008/more-term-auction-facility-funds-available-to-discountwindow-borrowers

Tools: More Term Auction Facility Funds Available
to Discount Window Borrowers
To address the disruptions in the financial markets, the Federal Reserve has enhanced its funding support for
financial institutions, including expansion of the Term Auction Facility (TAF).
On Oct. 6, the Board of Governors announced that the sizes of both 28-day and 84-day TAF auctions would be
boosted to $150 billion each. These increases will eventually bring the amounts outstanding under the regular
TAF program to $600 billion. In addition, forward TAF auctions were conducted in November to extend credit
over year-end. The size of these auctions totaled $150 billion each, so that $900 billion of TAF credit will
potentially be outstanding over year-end.
For further information regarding TAF auctions, contact our discount window staff at 314-444-8444 or toll-free
at 866-666-8316 or visit the Federal Reserve discount window web site.

CENTRAL BANKER | WINTER 2008
https://www.stlouisfed.org/publications/central-banker/winter-2008/treasury-can-authorize-early-redemption-and-ach-filesdelivery

Tools: Treasury Can Authorize Early Redemption
and ACH Files Delivery
In late August and early September, the U.S. Department of the Treasury took unusual efforts to ensure that
individuals in areas affected by hurricanes Gustav and Ike were able to receive their federal benefit payments
early.
The postal service delivered checks early in areas affected by evacuation orders, and ACH files were delivered
early to financial institutions in those areas. In addition, financial institutions in affected areas also were
authorized to redeem EE and I savings bonds less than one year old presented from September 2008 through
November 2008.
Treasury hoped to ensure that those facing hardships from the hurricanes did not face the additional hardship
of being unable to access their funds when they were needed.
Announcements of this nature can be found at www.frbservices.org under the Treasury Services heading.

CENTRAL BANKER | WINTER 2008
https://www.stlouisfed.org/publications/central-banker/winter-2008/use-these-guidelines-if-youre-interested-in-using-coveredbonds

Tools: Use These Guidelines if You're Interested in
Using Covered Bonds
During the summer, the U.S. Treasury and Fed introduced the covered bond framework to encourage
additional sources of financing within the mortgage market and strengthen financial institutions.
A covered bond is a secured debt instrument that provides funding to a depository institution, collateralized by
high-quality mortgage loans that remain on the issuer’s balance sheet. The Treasury, Federal Reserve, FDIC,
the Office of the Comptroller of the Currency, the Office of Thrift Supervision and the Securities and Exchange
Commission collaborated to create a best practices guide for covered bonds.
See the press releases if you’re interested in beginning a covered bond program at your institution. Also see
Fed Gov. Kevin Warsh’s remarks on the covered bond framework.

CENTRAL BANKER | WINTER 2008
https://www.stlouisfed.org/publications/central-banker/winter-2008/follow-major-federal-reserve-actions

Tools: Follow Major Federal Reserve Actions
The Fed now pays interest on depository institutions' required and excess reserve balances; there is now a
Commercial Paper Funding Facility; the Fed lends billions of dollars to AIG—but not Lehman Brothers; and
Freddie Mac and Fannie Mae are now in conservator status.
Are you keeping it all straight?
With major Federal Reserve actions, economic decisions and related events coming in a flurry since late
summer, the Board of Governors created a comprehensive web page encompassing all of the news and
decisions. Here, you’ll find links to press releases, Federal Register notices, relevant speeches and
congressional testimony, and other related information. Materials are organized by date.

CENTRAL BANKER | WINTER 2008
https://www.stlouisfed.org/publications/central-banker/winter-2008/regulatory-roundup

Regulatory Roundup
The following are regulatory changes of note that bankers should keep in mind:

Reg Z Fee-Based Trigger Increase Takes Effect Jan. 1
Effective Jan. 1, the dollar amount of the fee-based trigger under the truth in Lending Act (Regulation Z) will
increase to $583.
This adjustment does not affect the new rules that the Board adopted in July 2008 for higher-priced mortgage
loans, the coverage of which are determined using a different rate-based trigger.
The Home Ownership and Equity Protection Act of 1994 restricts credit terms, such as balloon payments, and
requires additional disclosures when total points and fees that the consumer pays exceed either the fee-based
trigger or 8 percent of the total loan amount, whichever is larger.

Bank Broker Exceptions Outlined in Reg R Entity Compliance
If your institution is engaging in broker-related activities, see the Fed’s Small Entity Compliance Guide issued
earlier this year.
The guide is issued under Regulation R, which implements certain key exceptions for banks from the term
“broker” The exceptions include:
certain third-party networking arrangements,
trust and fiduciary activities,
deposit “sweep” activities, and
custody and safekeeping activities.
Any bank that wants to rely on one of these exceptions or exemptions to the definition of broker should review
and understand the terms, limits and conditions to the particular exception or exemption.