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Spring 2009

Central

N e w s a n d V i e w s f o r E i g h t h D i s t r i ct B a n k e r s

F e at u r e d i n t h i s i s s u e : Growth in Noncore Funding | Collapse of the Shadow Banking System

How To Use the Fed’s Discount Window
Traditional and New, Temporary Lending Programs Fit Specific Needs
By Kim Nelson

I

n just a little over a year, the Federal Reserve’s discount window has
become a popular option for many
banks interested in temporary alternative funding sources.
If you’re thinking of tapping into a
temporary funding program for your
financial organization, here is a quick
review. The purpose of the discount
window is to act as a safety valve to
relieve pressures in the market for
reserves. Normally, the discount
window relieves temporary liquidity
strains for depository institutions and
the banking system; it is not intended
to provide longer-term funding (with
the exception of the very small seasonal credit program). However,
because of the significant stress in
the financial markets that started in
August 2007, the Fed’s Board of Governors expanded discount window credit
programs to provide longer-term
liquidity to the financial system.
The Fed introduced several temporary programs for banks first. These
included Term Primary Credit, which
makes funding available for 90 days,
and the Term Auction Facility, which
makes funding available for up to
84 days. These programs are available only to financial institutions that
are in “generally satisfactory” financial condition. The loans come with
essentially the same requirements as
a traditional discount window loan,

although loans exceeding 28 days
must have an excess margin of collateral for contingency short-term borrowing purposes.
After introducing the temporary
programs for banks, the Board of Governors in March 2008 began exercising
its authority under Section 13(3) of the
Federal Reserve Act, which allows the
Fed to extend credit to individuals,
partnerships and corporations during what the Board determines to be
“unusual and exigent circumstances.”
Generally, an “unusual and exigent
circumstance” presents risk of systemic insolvencies. No loans had been
made under this provision since the
Great Depression era of the 1930s.
The Fed established two Section 13(3)
programs to help with the resolution of
specific financial entities: Bear Stearns
and American Insurance Group (AIG).
Other Section 13(3) programs were
continued on Page 6

T h e F e d e r a l R e s e r v e B a n k o f St . L o u i s : C e n t r a l t o A m e r i c a ’ s Ec o n o m y ™

Central View
News and Views for Eighth District Bankers

Vol. 19 | No. 1
www.stlouisfed.org/cb
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.
To subscribe for free to Central Banker or any
St. Louis Fed publication, go online to
www.stlouisfed.org/publications/subscribe.
html. To subscribe by mail, send your name,
address, city, state and ZIP code to: Central
Banker, P.O. Box 442, St. Louis, MO 63166-0442.
The Eighth Federal Reserve District includes
all of Arkansas, eastern Missouri, southern
Illinois and Indiana, western Kentucky and
Tennessee, and northern Mississippi. The
Eighth District offices are in Little Rock,
Louisville, Memphis and St. Louis.

Looking for Regulatory Information
in Troubled Times?

We’re Here To Help
By Julie Stackhouse

A

t the St. Louis Fed, we’re committed to the goal of being the quality
regulatory agency in the Midwest.
One of the ways that we work toward
our goal is to provide quality information to banking organizations when it
is needed most. We offer a number of
programs for your participation:
• Ask the Fed. This one-hour monthly
conference call-in program provides
senior banking officials with critical information on recent financial
and regulatory developments. Topics since November 2008, when this
program began, have included origins
of the mortgage crisis, new developments in the federal funds market,
changes to the Fed’s payment system
risk policy and an economic update
by St. Louis Fed President Jim Bullard.

Julie Stackhouse is
senior vice president
of the St. Louis Fed’s
division of Banking
Supervision, Credit
and the Center for
Online Learning.

• Examiner advisory visits. By request, seasoned Fed
examiners will visit state member banks or bank holding
companies to discuss Bank Secrecy Act matters, loan-loss
reserve issues, flood insurance, fair lending, Home Mortgage Disclosure Act data submission and other matters.
These informal advisory visits are often beneficial to new
compliance officers and staff as a matter of introduction
and personalized training.
• Regulatory reports consultation. At your request, our
staff will conduct an on-site tuneup for your institution’s
regulatory reporting needs. Benefits include improved
report accuracy, access to in-person training, and in-depth
analysis and data verification.
• Fed officials’ visit. Periodically, Banking Supervision
officers will visit your area to meet with small groups of
senior officials from state member banks. This informal
forum has been well-received as a unique opportunity for
frank and informal discussion on matters that are most
important to you, such as regulatory burden.
• Visit to the St. Louis Fed. We invite you to come to our
offices and meet with me and other officials in our Banking Supervision function. This program is especially
beneficial for new executive officers who need a sound
understanding of regulatory operations.
We hope that you will take advantage of one or more of
these opportunities. To find out more, contact Patrick Pahl,
senior coordinator, Banking Supervision and Regulation
division, at 314-444-8858 or patrick.pahl@stls.frb.org.

2 | Central Banker www.stlouisfed.org

Q u a r t e r ly r e p o r t

Performance Ratios Go from Bad
to Worse at District and U.S. Banks
By Michelle Neely

A

dismal banking environment and
a very weak economy continued
to wreak havoc on bank balance sheets
and income statements in the fourth
quarter, resulting in an awfully poor
showing in earnings and asset quality
at District banks and their U.S. peers.
At District banks, return on average
assets (ROA) fell 22 basis points to 0.45
percent in the fourth quarter. ROA was
down 49 basis points from its year-end
2007 level. (See table.) Profitability at
U.S. peer banks (banks with average
assets of less than $15 billion) plunged
in the fourth quarter, resulting in yearend ROA of just 0.15 percent, a 29 basis
point drop from its third quarter level
and a stunning 90 basis point decline
from its year-end 2007 level.
The double-digit declines in ROA in
the fourth quarter at both sets of banks
were due to large increases in net noninterest expense and loan loss provisions; the average net interest margin
stayed flat at 3.79 percent for District
banks and 3.82 percent at peer banks.
Loan loss provisions as a percent of
average assets climbed to 0.74 percent
at District banks and 1.03 percent at
U.S. peer banks. The LLP ratio has
more than doubled at District banks
and has almost tripled at peer banks
over the past year.
Despite the large increases in provisions, the coverage ratio (the loan loss
reserve as a percentage of nonperforming loans) has tumbled significantly at
both sets of banks over the past two
years. At year-end 2006, District banks
had $1.78 reserved for every dollar of
nonperforming loans; at year-end 2008,
the coverage ratio stood at just 84 cents.
U.S. peer banks had just 65 cents
reserved for every dollar of nonperforming loans, down dramatically from
$1.83 at year-end 2006.
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 1.76 percent
at District banks and 2.63 percent at
peer banks in the fourth quarter. In
the District, increases in nonperforming commercial and industrial loans
and commercial real estate loans were
the main contributors to the rise in the
composite nonperforming loan ratio.
More than 5 percent of District banks’
outstanding construction and land
development (CLD) loans were nonperforming at the end of the fourth quarter. At U.S. peer banks, the decline in
quality was even more pronounced,
with almost 9 percent of outstanding
CLD loans in nonperforming status.
Despite the dreary earnings and
asset quality numbers, District banks
remain on average well-capitalized. At
the end of the fourth quarter, only one
District bank (out of 700) failed to meet
at least one of the regulatory capital
minimums. District banks averaged a
leverage ratio of 8.99 percent.
Michelle Neely is an economist at the Federal
Reserve Bank of St. Louis.

From Bad to Worse
Q4 2007

Q3 2008

Q4 2008

0.94%
1.05

0.67%
0.44

0.45%
0.15

3.89
3.99

3.79
3.82

3.79
3.82

0.35
0.35

0.60
0.77

0.74
1.03

1.55
1.26

1.68
2.19

1.76
2.63

Return on average assets

District Banks
Peer Banks
Net interest margin

District Banks
Peer Banks
Loan Loss Provision Ratio

District Banks
Peer Banks
Nonperforming loans Ratio

District Banks
Peer Banks

SOURCE: Reports of Condition and Income for Insured Commercial Banks
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.

Central Banker Spring 2009 | 3

Ec o n o m i c F o c u s

Noncore Funding Growing in Importance
among Most Types of Banks
By Rajeev Bhaskar and Yadav Gopalan

N

oncore funding sources have
always played an important funding role for banks; however, in the last
decade, reliance on them has increased.
Noncore funding sources include
federal funds purchased, Federal Home
Loan Bank (FHLB) advances, subordinated notes and debentures, CDs of
more than $100,000 (jumbo CDs) and
brokered deposits. Aside from a blip
during the 2000-01 recession, reliance
on these noncore funds has increased

Figure 1

Percentage of Noncore Funds to Total Assets
43
38
All U.S. banks
33

All Eighth District
banks
Eighth District
community banks

18

2008

2007

2006

2005

2004

2003

2002

2001

1997

1996

2000

U.S. community banks

13

1999

23

All U.S. Banks

1998

28

NOTE: Data were captured on Sept. 30 of each year.

Figure 2

Eighth District Noncore Funding Activity as a
Percentage of Total Assests
35
30
25

Total noncore
funding

20
Jumbo CDs

Other borrowed
money

Fed funds purchased and repos

4 | Central Banker www.stlouisfed.org

2008

2004

2003

2002

2001

2000

1999

1998

1997

1996

NOTE: Data were captured on Sept. 30 of each year.

For all U.S. banks, average noncore
funding as a percentage of total assets
has grown by 11 percentage points
over the past 12 years. The ratio was
43 percent at the end of September
2008, compared with 32 percent at the
end of September 1996. For the larger
U.S. banks, which are weighted heavily
in all bank averages, foreign deposits make up the largest component of
noncore funding, followed by other
borrowed money (OBM) and jumbo
CDs. Since the credit crisis began,
both OBM and brokered deposits have
risen sharply. Other borrowed money
is a broad category and includes Federal Reserve discount window loans
and FHLB advances. The growth in
this category is not surprising, given
deterioration in the financial sector
and banks’ sudden inability to access
unsecured market sources.

Community Banks

Brokered deposits

Forgeign deposits

2005

5

2007

10

2006

15

0

steadily at banks of all sizes over the
last decade. (See Figure 1.)
As the financial services industry
has evolved over the past 10 to 20
years, depositors have had the opportunity to invest in the stock market,
mutual funds and money market
funds. As such, there has been a shift
in core deposits away from banks to
these alternate investment vehicles,
which have potentially higher return.
Banks, meanwhile, have experienced
tremendous growth in loans over the
same period. To keep up, banks have
turned to more nontraditional noncore
sources of funds.
As a percentage of assets, noncore
funds are more important to large
banks than community banks. Still,
the growth in noncore funding has
been much faster at community banks.

For all U.S. community banks—
banks with $500 million or less in total
assets—average noncore funding as a
percentage of total assets has doubled
over the period, rising from 14 percent

R egiona l Spot l igh t

Navigate the Financial Crisis
with New St. Louis Fed Web Site
at the end of September 1996 to 28 percent at the
end of September 2008. Despite the tremendous
growth, this ratio is still much lower than that of
all U.S. banks. Jumbo CDs make up the bulk of
this funding, followed by OBM. Like the trends
at all U.S. banks, there has been a noticeable
upsurge in brokered deposits and OBM since
mid-2007. However, the growth in jumbo CDs
has remained flat over this period.

Eighth District Banks
At most Eighth District banks (mostly community banks), the noncore-funding ratio remains
above that of U.S. community banks but less than
that of all U.S. banks. Noncore funds as a percentage of total assets rose 12 percentage points
from 21 percent in September 1996 to 33 percent
in September 2008. Here, too, jumbo CDs comprise the largest component of noncore funds.
Figure 2 shows the breakdown of the noncorefunding ratio by component at Eighth District
banks over the past 12 years. During the past
year and a half, the jumbo CD share has been
decreasing while the importance of OBM and
brokered deposits has been rising.
Trends at Eighth District community banks
have paralleled those at U.S. community banks.
In the past, the District’s community banks
relied on noncore funds (as a percent of assets)
slightly more than their peers did. (See Figure 1.)
However, peer banks caught up over the past few
quarters. The trend lines have merged: Noncore
funds to total assets now stands at 28 percent for
both U.S. and Eighth District community banks.
As is the case with most banks, both OBM—from
the Fed and the FHLB banks—and brokered deposits have spiked during the recent credit crisis.

Don’t get lost amid the stories, events, rumors,
analyses and actions surrounding the current financial
crisis. Make sense of it all with a new, dynamic St. Louis
Fed web site.
The Financial Crisis: A Timeline of Events and Policy
Actions site outlines events in financial markets from
February 2007 to the present. The web site includes
brief descriptions of market events and actions that
the Fed and other government agencies have taken,
links to relevant St. Louis Fed research papers, and
links to press releases, SEC filings, congressional testimony and other primary documents.
The site features charts and data showing the effects
of the Fed’s new lending facilities. It also answers
questions on the causes of the financial crisis and compares the current crisis with the Great Depression.
Interested bankers can subscribe to the site’s RSS
feed for the latest news and updates. (Look for the
Timeline RSS link near the top of the center column.)
“The Federal Reserve and other agencies have taken
many steps to contain the financial crisis and limit its
impact on the broader economy,” said St. Louis Fed
President Jim Bullard. “As we begin to move forward,
it is critically important that we clearly communicate
these actions to better ensure their success.”

Rajeev Bhaskar is a senior research associate and Yadav
Gopalan is a research associate, both with the Banking Supervision and Regulation division at the Federal
Reserve Bank of St. Louis.

>>v i e w o n li n e

www.stlouisfed.org/timeline
Central Banker Spring 2009 | 5

Bankers Invited To Explore Community Innovation
and Financing in Changing Times

C

hanging economic conditions are
presenting new challenges for
those working in community development. Financing, particularly in moderate- and low-income areas, is getting
more difficult, and understanding how
to leverage limited resources is more
important than ever.
The Federal Reserve Bank of
St. Louis is hosting an April 22-24
conference in St. Louis to address
financing, resources and other community development topics. The 2009
Exploring Innovation in Community
Development conference, “Innovation
in Changing Times,” will be of interest
to bank senior management, directors,
loan officers and Community Reinvestment Act officers.
Katherine D. Siddens, U.S. Bank in
St. Louis, attended the first Exploring Innovation conference, in 2007 “As
the community development manager
for U.S. Bank, I found the Exploring
Innovation conference to be extremely
beneficial to me, but also truly believe
it would be a worthwhile experience
for any bank representative who is
interested in better understanding
community needs,” Siddens says. “The
information helped me uncover new
opportunities to fulfill our CRA obligations and provided affirmation that

bankers can serve as important connectors between the financial industry
and the community at large.”
Loura Gilbert, a mortgage officer
with Commerce Bank in Clayton, Mo.,
who also went to the 2007 conference,
says “The regulators are continually
urging banks to be innovative in their
response to CRA guidelines. And I
welcome any opportunity to meet with
other bankers and experts to brainstorm ideas about these issues.”
This year’s conference will bring
together high-level leaders from across
the industry to explore best practices,
innovative policies, and thinking in
community and economic development. Topics will include:

Discount Window

determines that current market turmoil has ended.
Information regarding traditional
discount window programs is available
at www.frbdiscountwindow.org. Additional details regarding Section 13(3)
programs are available by e-mailing
the Federal Reserve Bank of New York
at general.info@ny.frb.org.

continued from Page 1

established to “unfreeze” securities
markets. These programs include the
Primary Dealer Credit Facility, the
Residential Mortgage-Backed Securities Facility and the Collateralized Debt
Obligations Facility.
Finally, the Fed created additional
Section 13(3) programs to focus on
supporting money market liquidity.
These programs include the AssetBacked Commercial Paper Money
Market Mutual Fund Liquidity Facility,
the Commercial Paper Funding Facility and the Money Market Investor
Funding Facility.
All of these programs are temporary
and will be unwound when the Board
6 | Central Banker www.stlouisfed.org

• expanding economic opportunities
through financing innovations,
• building wealth in urban
and rural areas,
• accelerating regional
development, and
• examining the future
of community development.
For more information, visit the conference web site at www.exploring
innovation.org. For an invitation, contact Cynthia Davis at 314-444-8761 or
communitydevelopment@stls.frb.org.

>> M o r e O n li n e

www.frbdiscountwindow.org
www.newyorkfed.org/markets/
Forms_of_Fed_Lending.pdf
Kim Nelson is a vice president in the St. Louis
Fed’s Banking Supervision and Regulation
division.

In-Depth

The Credit Crunch Reflects Collapse
of a “Shadow Banking System”
Financial Assets: Growth Since 2000
350
300
Issuers of private-label
asset-backed securities
250
Government-sponsored
enterprises

200
150

2009

2003

2006

Federally insured
depository institutions

100
2000

M

any consumers and business
owners are wondering: Have
banks stopped lending?
The answer depends on the status
of financial institutions. Most banks,
especially in the Eighth District,
remain in generally sound financial
condition and continue the economic
necessity of lending to customers with
good credit quality. However, some
banks are facing severe financial
distress, creating a need to preserve
capital—which gives the appearance
of a credit crunch. To improve their
regulatory capital-to-asset ratios, some
banks are reducing their total assets
on the balance sheet by reducing the
amount of loans outstanding. Some
banks are improving ratios by raising more capital either privately or
through recent government programs
if eligibility requirements are met.
In large part, the reduction in credit
availability can be attributed to the
partial collapse of the “shadow banking system.”
In its simplest sense, the shadow
banking system represents credit
instruments that exist outside of
the traditional commercial banking
system, especially those related to
consumer credit. Older parts of the
shadow system include financial assets
issued through government-supported
institutions, such as Fannie Mae and
Freddie Mac.
More interesting is the growth in
assets in the nongovernment-supported and nongovernment-insured
sectors. As shown in the chart, these
so-called private label assets grew at
a three-fold rate over the past eight
years. Some of these financial instruments, including the vast majority of
the subprime mortgage market, were
high-risk in nature as well. The securities created from these assets were
often complex, with poor transparency
and sometimes questionable suitability
for unsophisticated customers. The
intermediaries issuing and trading

Figure 1

Index levels set to 100 in Q1 2000

By Julie Stackhouse and Bill Emmons

the securities included nationally
and internationally active investment
banks, hedge funds and some insurance companies. Most of these entities
were not required to be supervised by
banking regulators.
It is this part of the lending market that has collapsed. According to
Federal Reserve data, total household
loans outstanding (mortgages and
other consumer credit) decreased during the six months ending Sept. 30,
2008. This marked the first six-month
decline since at least 1952, when comprehensive data first became available.
To the extent that the underpinnings
of the shadow banking system were
unsound, we should not expect that system to return anytime soon—especially
the market for securitized subprime
mortgages. For other segments, return
of the securitized market will depend on
investor confidence and a move toward
increased transparency for investors.
Julie Stackhouse is senior vice president of
Banking Supervision, Credit and the Center for Online Learning. Bill Emmons is an
officer and economist at the Federal Reserve
Bank of St. Louis.

Central Banker Spring 2009 | 7

Central Banker
Connected

Let Us Know What You Think
of the New Central Banker

See the online Version of Central
b a n k e r f o r m o r e i n - d e p t h f e at u r e s,
F e d n e w s a n d r e g u l ato ry s p ot l i g h t s.

By now, you’ve noticed that this issue of Central
Banker features a new look. We’ve expanded the
number of pages, loosened and simplified the
design to make articles easier to read, provided
more links to related online materials and rearranged some of the items for a more logical flow
of information.
Although the design is new, our goal of providing concise banking news from the Fed perspective remains the same. We value your time and
want to make sure that our information is easy
to absorb and use. You’ll get economic research
pertinent to the Eighth District; in-depth looks
at the facts of banking today; local perspectives on national issues; and explanations about
Fed-related topics, such as providing liquidity and
community programs.
Your feedback is important, too, and we’d like
to hear from you. What topics should we cover?
What would you like to know more about? What
did you like or not like in an issue?
Send your ideas and suggestions to Scott Kelly,
Central Banker editor, at scott.b.kelly@stls.frb.org
or call him at 314-444-8593.

VIE W S

• Dial “M” for monetary policy, says
St. Louis Fed President Jim Bullard
• Fed economist Dave Wheelock examines
Great Depression mortgage moratoria
TOOLS

• Prepare new board members
with Insights for Bank Directors
• Remind staff of check services consolidation
RE G ULATIONS

• Final credit card rules take effect in 2010
• Fed changing reserve requirements
> > 	O n l y O n l i n e

Read these features at
www.stlouisfed.org/cb

Federal Reserve Bank of St. Louis
P.O. Box 442
St. Louis, Mo. 63166-0442

FIRST-CLASS
US POSTAGE
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PERMIT NO 444
ST LOUIS, MO

CENTRAL BANKER | SPRING 2009
https://www.stlouisfed.org/publications/central-banker/spring-2009/dial-m-for-monetary-policy-says-bullard

Views: Dial “M” for Monetary Policy, Says Bullard
St. Louis Fed President Jim Bullard warned Feb. 17 that the U.S. runs the near-term risk of falling into a
deflationary trap, which could cause the U.S. housing market to further deteriorate and prolong the recession.
“A key near-term risk for 2009 is disinflation and possibly deflation,” Bullard said in a speech to the New York
Association of Business Economics’ Harvard Club in New York City. “With sustained deflation, the foreclosure
experience that we have seen in the subprime market could generalize to a wider spectrum of
homeownership.”
In normal times, the standard central bank policy response to very low inflation has been to establish a lower
effective target for a short-term nominal interest rate. In the current environment, however, because the
intended federal funds rate is effectively zero, the Fed cannot lower nominal interest rates further; so, a more
systematic approach is needed.
“To avoid the risk of deflation,” as it has been experienced in Japan, “it is important that the Fed provide a
credible nominal anchor for the economy,” Bullard said. “One way to do so is to set quantitative targets for
monetary policy, beginning with the growth rate of the monetary base.”
Bullard said that the Fed could signal that it intends to avoid the risk of deflation and the possibility of a
deflation trap by expanding the monetary base at an appropriate rate. Although the impact that a change in the
monetary base would have in the economy cannot be measured as precisely as that of a change in the
nominal interest rate target, “the effects are unmistakable and every bit as powerful,” he added. “This channel
can be used to support the committee’s medium-term inflation objective and head off a possible global
deflation trap and the counter-productive rise in real interest rates that would accompany that outcome.”
Since September 2008, the Fed has injected an astonishing amount of reserves into the banking system in
response to the intensified financial turmoil. “This is the normal central bank response to severe financial
market distress such as that experienced in 1998 or 2001. However, the scale of the response this past fall
dwarfed that of these earlier events, and the crisis has persisted much longer than in earlier episodes,” said
Bullard.
The increase in the Fed’s balance sheet can be divided into two components—persistent and temporary. The
liquidity injections associated with the lender-of-last resort function of monetary policy are of temporary nature
and can be reversed. “Much, but not all, of the recent increase in the balance sheet can reasonably be viewed
as temporary. The outright purchases of agency debt and MBS (mortgage-backed securities) are likely to be
more persistent, however, and it is these purchases that may provide enough expansion in the monetary base
to offset the risk of further disinflation and possible deflation,” said Bullard.

CENTRAL BANKER | SPRING 2009
https://www.stlouisfed.org/publications/central-banker/spring-2009/changing-the-rules-state-mortgage-moratoria-during-thegreat-depression

Views: Changing the Rules: State Mortgage
Moratoria during the Great Depression
Should the federal government and the states seek to halt mortgage foreclosures during hard financial times—
and do the costs outweigh the potential benefits? With Congress looking for ways to reform mortgage
bankruptcy rules, the experiences of the 1930s can help inform the decisions of the present.
In a recent Fed study titled “Changing the Rules,” Dave Wheelock, an assistant vice president and economist
at the St. Louis Fed, examined the mortgage cost/benefit tradeoff when foreclosure moratoria were imposed
during the 1930s. Faced with an unprecedented number of farm and residential foreclosures during the Great
Depression, many states imposed temporary halts to foreclosures alongside other mortgage relief efforts.
Wheelock looked at the data to see why some states imposed moratoria while others avoided them. In short,
while moratoria appear to have reduced the rate of foreclosures, they also appear to have reduced the
availability of loans and made credit more expensive. Which side of the equation a state fell on depended on
which was seen as more important.
“Over the longer run, foreclosure moratoria and other changes in mortgage laws may have made loans costlier
or more difficult to obtain,” Wheelock wrote. “Critics argued that foreclosure moratoria induce lenders to restrict
the supply of loans and raise interest rates to compensate for the possibility that their right to foreclose on
delinquent loans or to collect deficiency judgments will be constrained.
“(On the other hand) in many states, the societal costs of widespread foreclosures were viewed as exceeding
the costs of reduced loan-supply and higher interest rates borne by prospective borrowers,” Wheelock wrote.
“Furthermore, foreclosure moratoria generally were viewed as expedients to buy time for the economy to
recover and for the federal government to initiate programs to refinance delinquent mortgages.”
Now, with foreclosure rates not seen since the Great Depression, many policymakers are looking toward
methods used during that time. Policymakers should therefore look not only to what was done, but the
potential costs. “The evidence from the use of foreclosure moratoria during the Great Depression
demonstrates how legislative actions to reduce foreclosures can impose costs that should be weighed against
potential benefits,” Wheelock wrote.

CENTRAL BANKER | SPRING 2009
https://www.stlouisfed.org/publications/central-banker/spring-2009/prepare-your-new-board-members-with-eminsights-for-bankdirectorsem

Tools: Prepare Your New Board Members with
Insights for Bank Directors
When taking on a new bank director, you probably want them up to speed as quickly as possible.
Have your new board members take the Fed’s free Insights for Bank Directors course. Since 2004, tens of
thousands of new bank directors across the nation have prepared for their oversight duties through Insights for
Bank Directors, according to the creators of the course, the Fed’s Community Banking Organization
Management Group. The web-based course introduces directors to their duties and responsibilities, provides
general information on analyzing a bank’s financial performance and gives general guidelines on managing the
bank’s portfolio risks.
Based on feedback, bankers and directors have found the course useful and insightful. The course currently
covers seven general areas:
1. the job of the bank director,
2. evaluations of financial performance,
3. large loans that may present policy exceptions,
4. regulatory issues in lending,
5. allowances for loan and lease losses,
6. market and liquidity risks, and
7. operational risk.
While the course is designed for new directors at community banks, more-experienced directors and those of
larger banks often find the course useful as a refresher on their board responsibilities and regulatory issues.
The tenets of being a good bank director transcend bank size and it’s never too late to revisit director
responsibilities.
The course is built around events occurring at the fictional “Insights Bank & Trust,” a small community bank
where the participant serves as an outside director. Early parts of the course serve as a prelude to a board
meeting, which will offer information typically covered by directors. The course employs exercises and
examples, and offers links to other useful information.
You can take the course at your own pace, all at once or in pieces. Insights is the collaborative product of the
Federal Reserve banks of Kansas City and St. Louis, based on an onsite director training course developed by
the Kansas City Reserve Bank. The course is updated on a regular basis, with operational and compliance risk
content added in 2008.

CENTRAL BANKER | SPRING 2009
https://www.stlouisfed.org/publications/central-banker/spring-2009/check-services-consolidation-update

Tools: Check Services Consolidation Update
As you undoubtedly know, the Federal Reserve System consolidated check services a final time late last year,
and last month all St. Louis commercial paper check processing moved to the Atlanta Fed.
The St. Louis Fed’s check consolidation is now complete. For your staff’s information, here are some of the key
contact numbers for Fed check services to keep in mind:
Atlanta Check Services Customer Support: 877-553-9735
Check Operations: 404-498-8659
Check Reconcilement: 404-498-8471
Check Transportation: 404-498-8626
Check 21 Operations (file and quality image issues): 404-498-7885
Adjustments Check 21 specialist: 904-632-1024
More check numbers, services and fees are available at frbservices.org and on the Atlanta Fed’s web site. And
see here for any lingering questions about the consolidation.

CENTRAL BANKER | SPRING 2009
https://www.stlouisfed.org/publications/central-banker/spring-2009/regulatory-roundup

Regulatory Roundup
Final Credit Card Rules Take Effect in 2010
Banks and other issuers of credit cards will have stricter rules governing “plastic” in 16 months. Two months
ago, the Federal Reserve Board approved sweeping and comprehensive final rules that will prohibit certain
unfair acts or practices and improving consumer disclosures.
The rules, which take effect July 1, 2010, are designed to:
protect consumers from unexpected interest changes,
forbid banks from imposing interest charges using the “two-cycle” billing method,
require that consumers get reasonable time to make credit-card payments,
limit fees that reduce the amount of available credit and
prohibit payment allocation methods that unfairly maximize interest charges.
More than 60,000 individuals and representatives of financial institutions commented in 2008 on the proposed
changes.

>>Related
Regulation AA (Unfair or Deceptive Acts or Practices)

Fed Changing Reserve Requirements in Spring
The Federal Reserve is changing Regulation D (Reserve Requirements of Depository Institutions) to authorize
the establishment of limited purpose, or excess balance, accounts at Federal Reserve banks.
Excess balance accounts (EBA) will be intended for institutions eligible to receive earnings on their balances
maintained at Federal Reserve banks. The establishment of such accounts would let participants earn interest
at the excess balance rate in a Federal Reserve bank account managed by a correspondent or other agent,
without participants having to open a separate individual account with the Fed.
The Board of Governors is authorizing EBAs to address pressures on correspondent-respondent business
relationships in the current market environment. The Board will evaluate the continuing need for EBAs when
more normal market functioning is restored.
Public comment just ended just as this issue was published. Final rules will be issued during the summer.

>>Related
Regulation D (Reserve Requirements)

CENTRAL BANKER | SPRING 2009
https://www.stlouisfed.org/publications/central-banker/spring-2009/let-us-know-what-you-think-of-the-new-emcentral-bankerem

Let Us Know What You Think of the New Central
Banker
By now, you’ve noticed that this issue of Central Banker features a new look. We’ve expanded the number of
pages, loosened and simplified the design to make articles easier to read, provided more links to related online
materials and rearranged some of the items for a more logical flow of information.
Although the design is new, our goal of providing concise banking news from the Fed perspective remains the
same. We value your time and want to make sure that our information is easy to absorb and use. You’ll get
economic research pertinent to the Eighth District; in-depth looks at the facts of banking today; local
perspectives on national issues; and explanations about Fed-related topics, such as providing liquidity and
community programs.
Your feedback is important, too, and we’d like to hear from you. What topics should we cover? What would you
like to know more about? What did you like or not like in an issue?
Send your ideas and suggestions to Scott Kelly, Central Banker editor, at scott.b.kelly@stls.frb.org or call him
at 314-444-8593.