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F EDERAL R ESERVE B ANK

OF

P HILADELPHIA

First Quarter 2020
Volume 5, Issue 1

Banking Trends
No More Californias
Regulating Consumer
Credit and Protecting
(Behavioral) Borrowers
Research Update
Data in Focus

Contents
First Quarter 2020

1

Banking Trends: Do Stress Tests Reduce Credit Growth?

8

No More Californias

14

Regulating Consumer Credit and Protecting (Behavioral)
Borrowers

Volume 5, Issue 1

A publication of the Research
Department of the Federal
Reserve Bank of Philadelphia
Economic Insights features
nontechnical articles on monetary
policy, banking, and national,
regional, and international
economics, all written for a wide
audience.
The views expressed by the authors are not
necessarily those of the Federal Reserve.
The Federal Reserve Bank of Philadelphia
helps formulate and implement monetary
policy, supervises banks and bank and
savings and loan holding companies, and
provides financial services to depository
institutions and the federal government. It
is one of 12 regional Reserve Banks that,
together with the U.S. Federal Reserve
Board of Governors, make up the Federal
Reserve System. The Philadelphia Fed
serves eastern and central Pennsylvania,
southern New Jersey, and Delaware.

In ensuring that large banks can provide credit during the downturn, stress tests
may limit the credit supply today—or so some critics claim. Edison Yu examines both
sides of the debate.

As American mobility declines, some wonder if we've lost our pioneer spirit. Kyle
Mangum finds that the situation is more complicated than it appears.

As we consider how best to protect individual borrowers, Igor Livshits asks:
Why and from whom are we protecting these borrowers, and what policies may
be most effective?

20

Research Update

25

Data in Focus

Abstracts of the latest working papers produced by the Philadelphia Fed.

Partisan Conflict Index.

About the Cover
Production Possibility Frontier

Patrick T. Harker
President and
Chief Executive Officer
Michael Dotsey
Executive Vice President and
Director of Research
Adam Steinberg
Managing Editor, Research Publications
Brendan Barry
Data Visualization Manager

ISSN 0007–7011

This issue's cover depicts the production possibility frontier, a graphical representation of how much an economy can produce given existing resources. The
horizontal axis represents the production of services, the vertical axis the production
of goods. Once the economy reaches the curved line, or frontier, running through
the graph, there is a tradeoff between the two—it is impossible, at this point on the
graph, for the economy to produce more goods without cutting services, and vice
versa. If the economy is producing goods and services on a point along this frontier,
it is Pareto efficient. If it's producing goods and services anywhere beneath the
curve, it is Pareto inefficient, because it could produce more goods and services, if
it so chose.
Connect with Us
We welcome your comments at:
PHIL.EI.Comments@phil.frb.org

Twitter:
@PhilFedResearch

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Previous articles:
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Photo: lucky-photographer

Edison Yu is a senior economist at the
Federal Reserve Bank of Philadelphia.
The views expressed in this article are not
necessarily those of the Federal Reserve.

Banking Trends

Do Stress Tests
Reduce Credit Growth?
Stress tests are supposed to ensure your access to credit during the next
downturn, but some critics claim that they also limit your access to credit
today. We test that theory.
BY E D I S O N Y U

A

s we approach the 10th anniversary of the nation’s first
supervisory stress test, some analysts argue that stress tests
have gone too far and that large banks have inefficiently
restricted credit. This article explores the preliminary evidence
about the effects of stress tests on the credit supply. However,
before considering the evidence, we need to know how the stress
tests work in the U.S. and why the stress tests might reduce
credit growth.

What Is a Stress Test?

The goal of supervisory stress tests is to ensure that systemically
important banking institutions are adequately capitalized under
even very adverse economic conditions. Stress tests use models
to estimate a bank’s need for capital under these conditions.
Among other benefits, stress tests ensure that large banks can
provide credit to households and firms in a downturn, thus
reducing the severity of the downturn.
To restore public confidence in the largest financial institutions

at the height of the financial crisis in 2009, the Federal Reserve
and other banking supervisors implemented the first stress test,
the Supervisory Capital Assessment Program (SCAP), which
estimated the potential losses that would be incurred by the
largest U.S. banks if economic and financial conditions worsened.
Under SCAP, supervisors determined whether the largest
financial institutions in the U.S. had sufficient capital to weather
the recession and worsening financial conditions. They assessed
19 financial institutions’ capital buffers based on potential
macroeconomic scenarios in 2009 and into 2010. Building on
SCAP, the U.S. implemented two related stress test programs:
the Dodd–Frank Act Stress Test (DFAST) and the Comprehensive
Capital Analysis and Review (CCAR) program.
DFAST was created by the 2010 Dodd–Frank Wall Street Reform
and Consumer Protection Act (“Dodd–Frank”), which required
annual supervisory stress tests for all financial institutions that met
two criteria. First, the institution had to have total consolidated
assets of more than $50 billion. And second, its primary regulator
had to be federal. In addition to the supervisory tests, large

Banking Trends: Do Stress Tests Reduce Credit Growth?

2020 Q1

Federal Reserve Bank of Philadelphia
Research Department

1

FIGURE 1

Stress Test Timeline

The federal government instituted
stress tests as part of its response to the
2007–2009 financial crisis.
7 Fannie Mae and Freddie Mac nationalized
15 Lehman Brothers declares bankruptcy;
Bank of America acquires Merill Lynch
16 AIG nationalized
21 Goldman Sachs and Morgan Stanley
switch from investment firms to banks
26 Washington Mutual collapses
29 U.S. House rejects TARP bailout;
Citigroup acquires Wachovia;
Dow Jones drops 777 points
3 U.S. House passes TARP bailout

2 Dodd–Frank bill introduced in U.S. House
16 Federal Reserve target rate set at 0%

13 Stimulus act passed

Apr–May SCAP conducted

JUL
D N O S A

21 Dodd–Frank signed into law;
DFAST created

2010
2011

2

the Federal Reserve forecasts the bank’s
pre-provision net revenue and the
potential amount of losses due to adverse
economic conditions.2 After calculating
taxes and capital distributions such as dividends, the Federal Reserve projects banks’
regulatory capital ratios over the nine
quarters of the test. The Dodd–Frank Act
requires the Federal Reserve to publicly
disclose the DFAST results, but it does not
require any supervisory actions for banks
whose projected capital falls below regulatory minimums.
The more comprehensive CCAR program applies to the biggest and most
complex financial institutions, with assets
of at least $100 billion. Through 2019, CCAR,
like DFAST, has been conducted annually
by the Federal Reserve to ensure that
the largest and most complex financial
institutions have sufficient capital to
continue normal operations in times of
economic and financial distress. In 2019,
the 18 largest financial institutions were
subject to CCAR.
CCAR includes both a quantitative
assessment and a qualitative assessment.
The quantitative assessment starts with
banks submitting financial information and
their capital plans to the Federal Reserve.
The assessment includes tests run by the
banks and the supervisory tests run
by the Federal Reserve. The quantitative
assessment uses the projections of income

Changes in DFAST Thresholds

JUN

2009
MAY
APR

MAR

FEB

JAN

DEC

NOV

2008
OCT

SEPTEMBER

September 2008 to December 2011

banking organizations, or bank holding
companies (bhcs), are also required to
run internal stress tests.
Congress raised
the threshold of the
See Changes
supervisory tests to
in DFAST
$100 billion in 2018.
Thresholds.
As of that change,
bhcs with consolidated assets between
$100 billion and $250 billion are now only
subject to periodic supervisory stress
tests.1 (Banks with total consolidated assets
of more than $250 billion are still subject
to annual supervisory stress tests.)
The Federal Reserve conducts DFAST
using its own independent models to
project a bank’s income, loan loss, and
capital level over a nine-quarter planning
horizon under three
different hypothetiSee Stress Test
cal scenarios of the
Scenarios.
aggregate economy.
The three scenarios—baseline, adverse, and
severely adverse—hypothesize future
economic outcomes, including recessions
of different magnitudes. For example,
in the severely adverse scenario, the U.S.
falls into a deep recession with a large
increase in unemployment and sharp
declines in asset prices.
Each bank subject to the supervisory
stress tests submits detailed information
about its balance sheet to the Federal
Reserve. For each hypothetical scenario,

Dec 11 CCAR created

Federal Reserve Bank of Philadelphia
Research Department

The thresholds of stress test requirements have changed more than once. In 2009, banks with
consolidated assets over $100 billion were subject to the SCAP. Nineteen banks underwent
the 2009 supervisory stress test.
Originally, Dodd–Frank required all financial institutions with total consolidated assets of more
than $50 billion and whose primary regulator is a federal financial agency to be subject to
annual supervisory stress tests. In addition, banks with assets over $10 billion are required
to run internal stress tests. In May 2018, Congress passed the Economic Growth, Regulatory
Relief, and Consumer Protection Act, which increased the asset thresholds for the stress
tests. Effective from the 2019 stress test cycle, banks with assets less than $100 billion are no
longer subject to stress tests. Banks with assets between $100 billion and $250 billion are
subject to periodic supervisory stress tests, while banks with assets of over $250 billion
are subject to annual supervisory stress tests and are required to conduct periodic internal
company-run stress tests. As a result, the number of banks tested in the DFAST program
decreased from 35 in 2018 to 18 in 2019.
This article focuses on the effects of supervisory stress tests, but some of the cited articles
use information about the internal stress test results for their statistical analysis.

Banking Trends: Do Stress Tests Reduce Credit Growth?
2020 Q1

from DFAST and incorporates banks’ planned capital
actions, such as dividend payments and stock repurchases. A quantitative objection is based on whether
a bank maintains capital ratios above regulatory
minimums under both the projections by the Federal
Reserve and the bank’s own projections.3 In the qualitative assessment, the Federal Reserve evaluates how
the banks identify, measure, and determine capital
needs for their material risks. Until 2019, the Federal
Reserve could issue an objection to the banks’ capital
plan based on either the quantitative or the qualitative assessment, but as of 2019 the Federal Reserve has
eliminated the qualitative component for most
banks.4 Unlike under DFAST, supervisory actions can
be taken if the Federal Reserve objects to a bank’s
capital plan under CCAR. When this happens, the
bank may not make any capital distribution without
the Federal Reserve’s permission.5 (See Figure 2.)
Unlike a point-in-time capital requirement, the
supervisory stress tests look to the future. Financial
regulations such as Basel III typically require banks
to maintain a sufficient current percentage of their
balance sheet as capital. The stress tests, on the other
hand, focus on future capital planning, ensuring
banks have sufficient capital to maintain lending
during a major shock to the economy or firms.

How Do Stress Tests Affect Lending?

To avoid receiving a CCAR objection from the Federal
Reserve, a bank needs to hold more capital or reduce
its assets to keep its capital ratio above regulatory
minimums.6 A bank can increase its capital holdings
by either selling more stock, reducing capital distribution, or increasing retained earnings. Alternatively,
a bank can reduce its total assets by making fewer
and smaller loans and buying fewer and smaller
securities. If a bank chooses not to increase its capital
holding, then it must reduce the size of its assets to
avoid a CCAR objection, potentially reducing lending
to households and firms. (See Figure 3.)
But stress tests may also prompt a bank to shift the
composition of its portfolio. In an economic downturn
or during financial distress, banks typically lose more
money on riskier loans. Thus, banks that have riskier
loans on their portfolio must keep more capital on
hand in order to pass the stress test. Since holding
more capital is costly, stress tests encourage banks to
avoid risky borrowers and make safer loans even in
good times.
One important goal of stress tests is to ensure that
banks can continue their normal operations in a time
of distress, when higher loan losses reduce bank
capital. The higher capital provision during good
times takes into account the potential capital needed
due to loan losses in a time of distress. This can help
a bank absorb the larger losses and smooth the credit

supply during an economic downturn.
So there should be more available credit
during a time of distress than would be
the case without the stress tests. Thus, it
is important, when assessing the impact
of stress tests on lending, to also consider
the potential effects of stress tests on
lending during an economic downturn.
Some critics argue that the stress tests
have gone too far and inefficiently limit the
credit supply, especially to risky but profitable borrowers. After all, banks are in the
business of taking and managing risks,
not just making ultrasafe loans.7 Other
critics argue that the stress tests might
increase risky bank lending.8 By subjecting
a bank to a stress test, regulators may be
signaling that the bank is too big to fail.
This may lead to moral hazard: Because
the bank believes itself to be too big to fail,
it increases lending to riskier borrowers.
In addition, due to the higher capital
requirement of the stress tests, banks
may search for higher-interest returns by
making riskier loans in order to compensate for the higher capital costs.
So far we have focused on the impact
of stress tests on bank lending. But not all
loans are made by banks subject to the
stress tests, or, for that matter, by banks.
The overall aggregate impact of stress
tests on lending depends on the extent to
which borrowers can obtain credit from
smaller banks or nonbank lenders instead
of from larger banks. For example, if
borrowers could get all their mortgages
from fintech lenders such as Quicken
Loans rather than from banks, mortgages
overall may be unaffected even as banks
make fewer mortgage loans.
Recent empirical work tests these
claims.

Empirical Evidence

A fast-growing body of empirical literature
studies the impact of stress tests on bank
lending. And many of these studies try
to find out whether stress tests impede
credit growth. These papers use different
methods and focus on different loan
markets, such as mortgages, commercial
and industrial lending, and small-business
loans.
However, regardless of method or focus,
it is challenging to study the effects of
stress tests on bank lending. Supervisory

Banking Trends: Do Stress Tests Reduce Credit Growth?

2020 Q1

Stress Test
Scenarios
The stress test scenarios are
determined by the Federal
Reserve each year and are
published in its stress
test annual reports.21 The
scenarios consist of
macroeconomic conditions
that could occur in a downturn. The 2019 supervisory
stress test scenarios include
trajectories for 28 variables.
These variables capture
economic activity, asset
prices, and interest rates
in the U.S. and foreign
economies and financial
markets. For example, the
severely adverse scenario
used in 2019 is characterized by a severe global
recession, with the U.S. unemployment rate increasing
to 10 percent, real GDP
dropping by 8 percent, and
the U.S. stock market falling
by half.
Each stress test scenario
is not a forecast but rather
a hypothetical scenario
designed to assess the
strength of banks and their
resilience to an adverse
economic environment. The
scenarios used by the
Federal Reserve change over
time. For example, the 2013
DFAST supervisory stress test
included 26 variables in the
severely adverse scenario.

Federal Reserve Bank of Philadelphia
Research Department

3

FIGURE 2

Comparison of DFAST and CCAR
RULE OF LAW

Quantitative component

CAPITAL
PLANNING
ASSUMPTIONS

FREQUENCY
AS OF 2019

Legal requirement

COMPONENTS

DFAST

CCAR

Regulatory enforcement

Qualitative component
Annual test
Occasional test
Dividends

if
> $250bn
if
$100bn–$250bn

*

Fixed at
previous year

Current
capital
plan
Current
capital
plan

Stock repurchases

* Banks with $100 billion or more in assets are
subject to the qualitative component; banks with
$250 billion or more in assets are subject to both the
qualitative and quantitative components.
FIGURE 3

Responding to CCAR

Banks have two options for responding to
CCAR's capital requirement.
Banks must maintain a
ratio of capital-to-assets
above a certain threshold.
For this example, 10%…
BANK A
Ratio: 10%
Capital

If not, an underfunded
bank has two options
to bring itself within
regulations.
BANK B
Ratio: 2%

Assets

BANK B
Option 1 Increase capital
Ratio: 2% → 10%
Raise equity,
pay less
dividends, etc.

BANK B
Option 2 Reduce assets
Ratio: 2% → 10%

Lend less, lend
to less risky
firms, etc.

4

Federal Reserve Bank of Philadelphia
Research Department

stress tests were first implemented right
after the financial crisis, when many
banks were losing money and the economy
and regulations were changing, so it
is difficult to isolate the effects of the
stress tests by simply comparing lending
outcomes before and after they were
implemented. Furthermore, regulators
only stress-test larger banks, making
it difficult to identify which differences in
lending outcomes are due to stress tests
and which are due to the different sizes of
these banks.

Comparison of Stress-Tested and
Non–Stress-Tested Banks
Despite these empirical challenges, some
papers compare lending growth and
loan characteristics between stress-tested
banks and non–stress-tested banks.
In their 2018 paper, Viral Acharya and
his coauthors compared banks subject to
stress tests with those that were not. They
focused on the syndicated loan market
and used DealScan data on syndicated
loan origination from 2004 to 2014.9 They
found that banks subject to stress tests
reduced their credit supply (particularly
credit to relatively risky borrowers) and
that banks subject to stress tests extended
smaller loans, shortened loan maturities,
and charged higher spreads. This is all
consistent with banks lowering the risk of
their loan portfolios. They found similar
results using the bank-level data from the
Call Reports.10 In addition, by using the
data on small-business loans collected
under the Community Reinvestment Act
(CRA), they found that stress-tested banks
originated fewer small-business loans.
Because small-business loans are riskier,
they argued, the stress-tested banks’
decision to reduce small-business lending
was evidence that stress tests reduce
the supply of risky lending. In the last empirical exercise of the paper, the authors
showed that bank-level measures of risk,
such as the tier 1 capital ratio, improved
after a bank was subjected to stress tests.11
In their 2017 working paper, Paul Calem
and his coauthors also compared stresstested banks to non–stress-tested banks,
but they focused on mortgage markets.
They used Home Mortgage Disclosure
Act (HMDA) data and studied jumbo-loan
origination activities of banks from 2009 to

2014. From the banks’ perspective, jumbo
mortgage loans are riskier because they
cannot be sold to government sponsored
enterprises (GSEs) such as Freddie Mac
and Fannie Mae. (By definition, a jumbo
loan is larger than what a gse is willing to
buy.) Accordingly, they are not subject
to the GSEs’ underwriting standards and
are usually held in the bank’s loan portfolio. They found that, immediately
following the 2011 CCAR stress test, banks
subject to supervisory stress tests originated fewer jumbo mortgages as a total
share of the banks’ mortgages and had
lower jumbo mortgage approval rates. In
particular, the paper estimated that
stress-tested institutions’ share of jumbo
mortgage originations was 5 to 7 percentage points lower in 2011. But the effects
are not statistically significant for the
other years.12 They argued that the subsequent effects were small because banks
had become better capitalized and hence
the supervisory stress tests were no
longer binding.
In his 2018 paper, Francisco Covas
explicitly addressed the concern that the
stress-tested banks are also the largest
banks, which are subject to a range of
capital requirements.13 He showed that,
for most banks, the capital requirements
imposed by the stress tests are higher
than other capital requirements, such as
the point-in-time risk-based capital
requirement imposed by Basel III for some
classes of loans.14 In particular, the capital
charges imposed under the stress tests are
particularly stringent for small-business
loans and residential mortgages, so Covas
suggested that stress-tested banks might
shift lending away from small-business
loans and mortgages. By using Call Report
data from 2011 to 2016, he found that
growth in small-business lending was
significantly slower for banks after they
were subject to stress tests. In particular,
he estimated that the U.S. supervisory
stress tests led to a 4 percentage point
reduction in the annual growth of smallbusiness loans secured by nonfarm,
nonresidential properties.

Using an Instrument to Isolate the
Effects of Stress Tests
Although it seems intuitive to compare
lending outcomes of stress-tested and

Banking Trends: Do Stress Tests Reduce Credit Growth?
2020 Q1

non–stress-tested banks, drawing accurate conclusions can be
difficult because other factors are at play. Banks subject to stress
tests are primarily very large, and it is possible that these big
banks differ from smaller banks in other aspects that also affect
lending growth. The different lending outcomes between large
and small banks may thus be due to those other factors and
not to the stress tests. Simply comparing stress-tested and non–
stress-tested banks without accounting for these other factors
may lead to biased estimates.
Papers that use this comparison approach attempt to deal
with this problem by taking into account a host of observable
factors. However, the statistical problem may persist if their
statistical analysis fails to capture unobserved variables. For
example, larger banks are subject to other, stricter regulatory
requirements, such as higher leverage requirements and livingwill requirements. Some of these stricter requirements are
difficult to measure and quantify, but they could affect the lending supply, making it difficult to isolate the effects of stress tests.
To address this concern, a second group of papers constructed
an instrument that measures how strongly the regulations
pressured each stress-tested bank to adjust its lending behavior.15
In their 2018 working paper, William Bassett and Jose Berrospide
constructed a measure called the capital gap, which is the difference between the capital level required according to the
supervisory stress tests and the level of capital from the bank’s
own stress-test model. The larger the capital gap, the more
additional capital banks need to hold to pass the supervisory
stress tests.
Note that this measure avoids the problem of comparing
the largest banks to smaller banks and is also quite specific to the
stress-testing exercise, so the effect of the shortfall is plausibly
distinct from other supervisory requirements. The authors also
argued that banks have a limited ability to manage this gap,
because the models used for the supervisory tests by the Federal
Reserve are not disclosed to the banks. Hence the capital
shortfall is likely to be random and not correlated with other
confounding factors, such as the size of the bank, which might
affect lending outcomes. The randomness of the capital gap
that a bank faces is thus useful in statistical analysis for isolating
the effects of stress tests on lending growth.
Bassett and Berrospide used balance sheet data from the Call
Reports from 2013 to 2016 and found no significant relationship
between loan growth and the capital gap. This does not support
the notion that the supervisory stress tests are reducing loan
growth. In addition, they found a small effect of the capital gap
on improving lending standards, as measured by the Senior
Loan Officer Opinion Survey on Bank Lending Practices. Thus,
the authors also found no evidence for greater risk-taking.
Kristle Cortés and her coauthors use a similar approach in
their forthcoming article. They calculate the stress-test exposure
of a bank as the difference between the starting capital level of
a test period and the lowest capital level implied by the severely
adverse scenario of the supervisory stress test. They argue that
a larger value of the exposure indicates a bigger expected decline
in a bank’s equity capital should an economic downturn occur,
and that this would increase the likelihood that the regulators
will pressure the bank to hold more capital. Then they examine

the effects of the stress-test exposures on small-business loan
growth. They argue that the exposure measure is unlikely to be
correlated with unobserved factors, as the exposure measure
is driven by a bank’s entire loan portfolio, and small-business
lending is a small fraction of a bank’s portfolio.
Using the 2012–2015 data on small-business lending provided
under the CRA, Cortés and her coauthors find that banks with
larger stress-test exposure reduced the subsequent supply of the
riskier small-business loans in counties with more employment
risk.16 But they do not find evidence that stress tests affected
the supply of small-business loans in safer counties with less
employment risk. The paper then investigates the characteristics
of small-business loans, using data from the Survey of Terms of
Business Lending (STBL) from 2013 to 2016. They show that banks
with larger stress-test exposure charged higher interest rates
and shortened the maturity of riskier small-business loans,
evidence that the tested banks reduced the riskiness of their
small-business loans.

Aggregate Effects on Credit Supply
With the exception of Bassett and Berrospide, the papers above
found evidence that banks more affected by the supervisory
stress tests reduced their credit supply, and none of the papers
found evidence that these banks increased risk-taking. These
banks, however, are not the only bank lenders—the vast majority
of medium-size and small banks are not subject to the stress
tests. Indeed, banks are not the only lenders—for example, firms
may borrow from finance companies or sell bonds that are held
by insurance companies and other intermediaries. Perhaps the
stress tests have simply shifted borrowing away from stress-tested
banks to other banks and to nonbank lenders.
To examine the impact of stress tests on the overall credit
supply, the last group of papers studied the impact of stress
tests on lending in a geographic area in which large banks, small
banks, and nonbank lenders compete to provide loans to both
businesses and households. Studying the impact of stress tests in
a county, for example, allows the researchers to capture the substitution across types of lenders within the county. If they find
that a bank subject to the supervisory stress test reduces the credit
supply in the county, but that the overall credit supply in the
county does not change, they can infer that borrowers are able to
obtain credit through non–stress-tested banks or other lenders.
Cortés and her coauthors found no reduction of small-business
lending by banks in counties with more exposure to stress tests,
while small banks not subject to stress tests increased their market
share among all banks.17 So the total quantity of small-business
loans made by banks did not appear to decrease.
The data used by Cortés and her coauthors don’t permit an
examination of substitution from bank lending to nonbank
lending. In some markets, particularly for residential mortgages,
nonbank lenders have taken a significant market share in the
postcrisis years.18 Although they did not isolate the effects of the
stress tests from other factors affecting the largest banks, Brian
Chen and his coauthors were able to provide some evidence
about this margin by using a unique dataset of nonbank loans
through PayNet Inc. They found that the share of originations of

Banking Trends: Do Stress Tests Reduce Credit Growth?

2020 Q1

Federal Reserve Bank of Philadelphia
Research Department

5

Notes

small-business loans by the four largest
banks fell from 2010 to 2014, while the
market shares for both smaller banks and
nonbanks increased relative to those four
largest banks.19
Taken together, the evidence suggests
that small-business lending has shifted
from larger banks to smaller banks or
nonbanks while not affecting the overall
credit supply at the county level. This
implies that the overall vulnerability of
the market hasn’t changed but has shifted,
although further research is needed to
test this hypothesis.

1 Bank holding companies are the entities subject to the supervisory
stress tests. I will call them banks for the remainder of the article.
2 Pre-provision net revenue (PPNR) is defined as net interest income
(interest income minus interest expense) plus noninterest income minus
noninterest expense. The projection of PPNR includes projected losses
due to operational-risk events and expenses related to the disposition of
real-estate-owned properties. See “Dodd–Frank Act Stress Test 2019:
Supervisory Stress Test Results” for more details.
3 Before publishing the quantitative test results, the Federal Reserve
provides each bank with a onetime opportunity to adjust its planned
capital distributions after it receives the Federal Reserve’s preliminary
estimates of the bank’s poststress capital ratios. The original submitted
capital plan, the adjusted capital plan, and the decision of an objection
on the final capital plan are published after the adjustment. See “Comprehensive Capital Analysis and Review 2019: Assessment Framework
and Results” for more information.

Conclusion

So far, empirical work in the literature has
shown post–financial-crisis stress testing
tends to reduce the credit supplied by
banks more affected by the tests, with the
reduction mostly in riskier loans. In addition, there is evidence that the reduction
in the credit supplied by the large banks
is mostly offset by smaller banks or nonbanks, leading to no overall reduction in
the credit supply.
Whether this is optimal for financial
stability depends on whether increasing
the smaller banks’ or nonbanks’ share
of the loan market reduces systemic risk.
Stress tests are supposed to bolster the
financial stability of the banking system
by increasing the capital buffer of the
largest banks. If we believe that smaller
banks and nonbanks pose less systemic
risk to the financial system, shifting credit
or riskier lending from large to smaller
institutions may improve financial stability.20 We have not experienced an economic
downturn since the stress tests were
implemented, so all the empirical work so
far uses data collected during an economic
expansion. Stress-testing’s effectiveness
in ensuring financial stability and lending
during a downturn will be tested in the
next recession. Future research is needed
to examine the efficacy of the stress tests
during an economic downturn.

6

Federal Reserve Bank of Philadelphia
Research Department

4 The qualitative component still exists for some banks and in some
circumstances. For example, if a bank becomes subject to supervisory
stress tests for the first time and has not been subject to a qualitative
assessment before, the bank would still have to be reviewed by the
Federal Reserve through the CCAR qualitative assessment.
5 A bank that receives an objection from the Federal Reserve on its capital
plan is colloquially described as “failing” the stress test.
6 Capital ratio is defined as capital divided by its risk-weighted assets. To
increase that capital ratio, the bank needs to either increase the numerator
(capital) or reduce the denominator (assets).
7 See the 2017 Clearing House report, for example.
8 See the 2018 paper by Viral Acharya and his coauthors for a detailed
discussion of the potential impacts of stress tests on credit supply.
9 Syndicated loans are large corporate loans to large corporations. They
are often funded by a group of lenders, hence the name. For more
information, see Edison Yu's 2018 article.
10 The quarterly Consolidated Report of Condition and Income (or Call
Report) is a report filed with regulators by banks in the U.S. The report
summarizes a bank’s financial information, including its balance sheet,
regulating ratios, and loan portfolios.

Banking Trends: Do Stress Tests Reduce Credit Growth?
2020 Q1

11 The tier 1 capital ratio is the ratio of a bank’s core capital, such as equity
and retained earnings, to its risk-weighted assets. It is a key measure of
a bank’s financial health.
12 These years include 2009, when SCAP was conducted, and 2011–2014,
when CCAR was carried out.
13 For example, the largest banks are subject to extra capital charges
because they are systemically important, the so-called SIFI surcharge.
14 He estimated the stress-test models used by the Federal Reserve and
found that post–stress-test capital requirements are more stringent
than the point-in-time capital requirements of Basel III. The models used
by the Federal Reserve are not publicly released and hence needed to be
approximately estimated in the paper.
15 Formally, a regression has an endogeneity problem if the explanatory
variable is correlated with the error term of the regression (or unobserved variables). The regression-with-endogeneity problem can lead to
biased estimators. An instrument can be used to solve this problem. An
instrumental variable is one that is not correlated with the error term of
the regression but is correlated with the explanatory variable of interest.
16 Employment risk is measured as the sensitivity of the county unemployment rate to the national unemployment rate.

References
Acharya, Viral, Allen Berger, and Raluca Roman. “Lending Implications
of U.S. Bank Stress Tests: Costs or Benefits?” Journal of Financial
Intermediation, 34 (April 2018), pp. 58–90, https://doi.org/10.1016/j.
jfi.2018.01.004.
Bassett, William, and Jose Berrospide. “The Impact of Post Stress Tests
Capital on Bank Lending,” Federal Reserve Board of Governors Working
Paper 2018-087 (2018), https://dx.doi.org/10.17016/FEDS.2018.087.
Board of Governors of the Federal Reserve System. “2019 Supervisory
Scenarios for Annual Stress Tests Required Under the Dodd–Frank Act
Stress Testing Rules and the Capital Plan Rule” (2019).
Board of Governors of the Federal Reserve System. “Comprehensive
Capital Analysis and Review 2019: Assessment Framework and Results”
(2019).
Board of Governors of the Federal Reserve System. “Dodd–Frank Act
Stress Test 2019: Supervisory Stress Test Results” (2019).
Buchak, Greg, Gregor Matvos, Tomasz Piskorski, and Amit Seru. “Fintech,
Regulatory Arbitrage, and the Rise of Shadow Banks,” Journal of Financial
Economics (forthcoming).

17 The exposure variable is the average bank exposure in a given county.

Calem, Paul, Ricardo Correa, and Seung Jung Lee. “Prudential Policies and
Their Impact on Credit in the United States,” BIS Working Paper 635 (2017).

18 For example, Greg Buchak and his coauthors, in their forthcoming
article, find that the nonbank share of the U.S. mortgage market nearly
doubled from 2007 to 2015.

Chen, Brian, Samuel Hanson, and Jeremy Stein. “The Decline of Big-Bank
Lending to Small Business: Dynamic Impacts on Local Credit and Labor
Markets,” NBER Working Paper 23843 (2017).

19 The four largest banks are Bank of America, Citigroup, JPMorgan
Chase, and Wells Fargo.

Cortés, Kristle, Yuliya Demyanyk, Lei Li, Elena Loutskina, and Philip
Strahan. “Stress Tests and Small Business Lending,” Journal of Financial
Economics (forthcoming).

20 See Kohn and Liang (2019) for more details.
21 See 2019 Supervisory Scenarios for Annual Stress Tests Required
under the Dodd–Frank Act Stress Testing Rules and the Capital Plan Rule
for more details.

Covas, Francisco. “Capital Requirements in Supervisory Stress Tests
and Their Adverse Impact on Small Business Lending,” The Clearing
House Staff Working Paper 2017-2 (2018), https://dx.doi.org/10.2139/
ssrn.3071917.
Kohn, Donald, and Nellie Liang. “Understanding the Effects of the U.S.
Stress Tests,” in Stress Testing: A Discussion and Review (Federal Reserve
System Conference, July 9, 2019).
The Clearing Housing. “The Capital Allocation Inherent in the Federal
Reserve’s Capital Stress Test” (January 2017).
Yu, Edison. “Measuring Cov-lite Right,” Federal Reserve Bank of Philadelphia Economic Insights (Third Quarter 2018), pp. 1–8.

Banking Trends: Do Stress Tests Reduce Credit Growth?

2020 Q1

Federal Reserve Bank of Philadelphia
Research Department

7

1790
1950

1900

1850

Distance from previous census’s mean center of population
80 miles

60 miles

40 miles

2010

20 miles

0 miles

Notes: The center of the U.S. population has been shifting west and then southwest after every
census, but that shift has shortened over the last few decades.
Source: U.S. Census Bureau.

1800

‘50

1900

‘50

2000

Kyle Mangum is an economist at the
Federal Reserve Bank of Philadelphia. The
views expressed in this article are not
necessarily those of the Federal Reserve.

No More Californias
As American mobility declines, some wonder if we've lost our pioneer
spirit. A closer look at the data suggests that the situation is less dire—
and more complicated—than it at first appears.
BY K Y L E M A N G U M

T

he modern world moves fast, as the cliché goes, but in the
U.S. today, people move less frequently than their parents
did a generation ago. The decline in mobility is much
more than an academic curiosity. Economists widely view labor
mobility as the principal mechanism by which regions adjust
to local economic shocks. If local industries fall on hard times,
workers can leave; in places where labor demand is high, new
residents flow in. The decline has therefore generated concern
that the economy is less adaptable to local shocks, ultimately
resulting in labor misallocation, unrealized output, and lower
productivity.
More broadly, the decline runs counter to widely held notions
of American culture. The U.S. is a nation of immigrants and
pioneers, always on the move in search of better opportunities.
Paradoxically, in a time of easy transportation and information
access, this nation of pioneers has parked its wagons.
Before we identify a proper policy response, we need to
understand why mobility has declined. But to do that, we need
to consider the history of population expansion across the North

8

Federal Reserve Bank of Philadelphia
Research Department

American continent. Since European settlers landed on the East
Coast, the population of the U.S. has spread to the West and
South. This trend continued well into the 20th century, when
sparsely populated outpost towns in places such as California,
Florida, and Arizona burgeoned into the major metropolitan
areas known today.
This geographic expansion of population throughout the
continent was mostly complete by the 1980s. Recent population
growth is still far from uniform, but the regional component
has diminished; a city’s presence on the West Coast, for example,
is no longer a sufficient predictor of its population growth. So
the regional reallocation of population has declined, but rarely
is that what people mean when they talk about the decline
in migration.
There are two senses of migration, a word meaning generically
the movement of population from one settlement to another.
Net migration is the difference between inflows and outflows of
population, whereas gross migration is the total turnover resulting from those inflows and outflows. It is gross, not net, migration

No More Californias
2020 Q1

FIGURE 1

The Boom Moves South and West

Gross vs. Net Migration
If 100 people move into City
A and 100 move out, City A’s
turnover, or gross migration,
is 200, but its net migration
is zero. If 150 move into City
B and 50 move out, City B’s
turnover is also 200 but its net
migration is 100.

City A
100

City B
100

150

50

After booming first in the Northeast and
Midwest, metro population is booming in
the South and West.
Metro area populations, millions of people

Migration
Gross: 200
Net: 0

Migration
Gross: 200
Net: 100
City C

1980
400

300

Northeast Cities
20

2019
200

New York

15
100

Now imagine a third city, City
C. In 1980, 400 people moved
Migration
Migration
Gross: 700
Gross: 300
into City C and 300 moved
Net: 100
Net: 100
out, so in 1980 its turnover
was 700 and its net migration
was 100. Last year, however, only 200 people moved in and 100 moved out. Now its gross
migration is just 300, but its net migration is still 100. That’s what we observe in many
formerly fast-growing cities throughout the West and South.

10

0

that has notably declined in recent years.
By differentiating between the two, we
can better understand why mobility has
declined and, if we are to design policy, at
least craft it for the right object.

enough to generate the observed national
decline.1 Perhaps more importantly,
the decline is present within age groups,
so that young people today, for instance,
are also moving less than their parents
did at the same age. Moreover, aging has
occurred at similar rates across cities, so
Go West, Young Man!
there is no scope for aging to explain the
The first clue to understanding the causes
spatial differences in the decline.2
of the gross migration decline is its spatial
Instead, what’s important is that the
pattern. The decline is substantially
country itself, not just its population, has
different across regions of the country—
aged. Cities with high turnover were
and not randomly so. The decline has
the population growth destinations of the
predominantly occurred in cities with
20th century in newly developing regions.
typically high rates of turnover, while
This growth was the real-world manifesmany low-turnover places have shown no
tation of the famous 19th century advice,
change at all. With high-turnover cities
“Go West, young man.” The cities of the
being major sources of inflows to other
Northeast, already well established at the
places, total flows across the system have
founding of the country, have effectively
declined. Thus, the national decline is
grown at rates below the national average
really the sum of fast-turnover cities
since then (with a modest bump during
slowing down and slow-turnover cities
industrialization). As the country pushed
holding steady.
west and south, newly formed cities grew
The population of the U.S. has aged
explosively—Chicago and Cleveland in
during roughly the same period that
the late 1800s; Los Angeles, Miami, and
migration has declined. Older households
San Diego in the early 1900s; Phoenix, Las
tend to move less than younger houseVegas, and Orlando in the postwar period.3
holds, making aging an obvious candidate
(See Figure 1.)
for explaining the decline. It is true that
Major technological innovations caused—
the increase in average household age has
or at least facilitated—the development of
contributed to the reduction in the aggrethese new regions. Transportation undergate average rate of migration decline.
went a revolution. Railroads in the 1800s
Aging, however, cannot be the whole story. connected the coasts, crisscrossing
Researchers have shown that typical aging the continent and making its far reaches
differences are not quantitatively big
accessible for the first time. Automobiles
No More Californias

2020 Q1

Philadelphia

5

Boston

1790

2010

Midwestern Cities
20

15

10

Chicago

5

Detroit
Cleveland

0

1790

2010

Southern and Western Cities
20

15
Los Angeles
10

Miami

5

Phoenix
Las Vegas

0

1790

2010

Source: Jonathan Schroeder, Minnesota Population
Center, University of Minnesota.

Federal Reserve Bank of Philadelphia
Research Department

9

FIGURE 2

Sticky vs. Magnetic Cities

Some regions see more turnover than others.
Percent of people

e pe

r ro

ots
→

Magnetic: Metro Areas Drawing Transplants (% of people living in the metro area who were born there)
90%
West
South

De

80%
Cleveland
70%

40%

30%

Fewer transplants →

50%

Philadelphia

Chicago
Boston
New York
Northeast

Midwest

← More transplants

60%

Detroit

Los Angeles

Phoenix

20%

←S
h
roo allow
ts
er

Miami
Las Vegas

10%

More locals staying →
0% ← More locals leaving
40% 50%
60%
70%
80% 90%
Sticky (% of people born in the metro area who still live there)
Source: American Community Survey, 2005–2017, via IPUMS USA, University of Minnesota, www.ipums.org.

FIGURE 3

FIGURE 4

Turnover Varies by Region

Population Growth, Then and Now

Percent of people who moved into or out of a metro
area, summarized by census region
Move-out rate

Even some booming cities have seen
a slowdown in their population growth.
Percent change in metro area population

Move-in rate

Last Generation
1960–1990

Northeast
Midwest
Southeast
West
0%

1%

2%

3%

4%

5%

Source: American Community Survey, 2005–2017, via
IPUMS USA, University of Minnesota, www.ipums.org.

Current Generation
1990–2018

Higher Growth Rate This Generation
Charlotte
Nashville
0%

500%

Higher Growth Rate Last Generation
Las Vegas
Phoenix
Atlanta
Dallas
Denver
Stockton
Philadelphia
0%

500%

Source: U.S. Census Bureau.

10

Federal Reserve Bank of Philadelphia
Research Department

U.S. rate
for period

No More Californias
2020 Q1

soon followed, along with an expanding
highway system that substantially enhanced regional connections. In the later
20th century, air travel further closed
the gaps, turning a transcontinental trip
into less than a day’s affair.
Developing water technologies made
these new regions viable. Water delivery
systems (such as the aqueduct serving
Los Angeles) were vital to large-scale
population growth in the arid West. On
the other coast, in damp South Florida,
for instance, stormwater control and
swamp draining significantly enabled
development.
Finally, almost all of these newly developing regions were hot (and sometimes
also humid), so the expansion of air
conditioning was critical. Besides enhancing household comfort, air conditioning
was essential for making viable large-scale
buildings like apartment and office towers
and manufacturing plants.
The 20th century was then essentially
the last movement in the long transition
of population expansion across the
American continent. Aided by new
technologies, unpopulated areas filled
with residents relocating from older,
colder areas. As the technological shocks
abated, and as development blanketed
the once-vacant land, rates of population
change slowly converged across space.
Today, the growing areas are not new
cities in unpopulated regions but rather
the established midsize, interior cities
throughout all regions of the county.4

There’s No Place Like Home

Once the westward expansion was
complete, an older and arguably more
primal tendency became more apparent:
On average, all types of people show
a preference for their initial locations—an
attachment to home. Social scientists have
explored this phenomenon by looking
closely at trust-based social ties to family
and friends. These ties offer nonpecuniary
benefits such as the pleasure of close
relationships, but also pecuniary benefits
such as informal childcare arrangements
and financial support in times of personal
distress. Moreover, place familiarity—the
benefit of “knowing your way around”—
can offer myriad pecuniary and nonpecuniary benefits as well.

The New Normal

So perhaps the U.S. is finally in a “long-run
spatial equilibrium,” as some have suggested.6 The term suggests that households’
incentives to relocate have diminished,
either because places are more similar
than they used to be,7 or structural changes in the economy have caused real estate
and labor prices to rationalize spatial
differences,8 so that, in either case, relative
population adjustments across space are
no longer necessary.

It is difficult to know whether the
country is (or ever will be) truly in such
a state, but there is reason to expect that
massive population changes across
regions—of the degree seen from
colonization to westward expansion—will
no longer be business as usual. The
major differences in regional habitability
have diminished. Transportation has
crisscrossed the continent, water deliveryand-control infrastructure has been put
in place, and air conditioning is ubiquitous.
Technologies today focus on speed and
efficiency within cities, not on developing
new cities. And in the digital age, new
technologies are less spatial.9
Population growth today is more
balanced across locations compared to the
skewness of the early and middle 20th
century. Some recently established locations, such as Las Vegas, Phoenix, and
Orlando, are still growing at above-average
rates, but not at the extreme rates of
a generation ago. For the most part, population growth is highest in well-established
places with space to accommodate more
residents. For example, cities like Atlanta,
Charlotte, Dallas, Denver, and Nashville
were long-important regional centers that
recently achieved major city status on the
national stage. Some smaller cities near
major metropolitan areas, such as Port
St. Lucie, FL, Olympia, WA, and Stockton,
CA, are also growing above the national
rate.10 (See Figure 5.)
And this population growth is occurring more within regions than across
regions. To the extent that imbalances
exist, growing places are established
cities rising in the urban hierarchy, leaving
the rest of their home region behind
and largely drawing people from within
their region.11

FIGURE 5

Sunbelt Cities Boom

Metros in the West and South have seen
much bigger growth in population.
Percent change, 1990–2018
Las Vegas
Atlanta
Charlotte
Dallas
Denver
Nashville

Stockton

Monmouth

NEW JERSEY

U.S.

In principle, home attachment is
straightforward and intuitive, but empirically it is difficult to measure what
a person considers his or her “home.” One
somewhat crude but readily available
measure is the U.S. Census question about
state of birth. For some people, one’s birth
state has little connection to one’s sense
of home. Some respondents may not even
remember their birth state. Even so, it is
a remarkably strong predictor of one’s
propensity to migrate. People living near
their birthplace show a strong proclivity
to remain in their location compared with
people born out of state.5
A transplanted population, by contrast,
is more transient and more subject to
various idiosyncratic changes in circumstance. For example, if someone moved
to a new place for a job, and the job
dissolves for whatever reason, they are
likely to move away. Someone with strong
local ties whose job dissolves is more
inclined to search locally. Hence, turnover
rates are high in growing locations. (See
Figures 2 and 3.)
This propensity explains why the end
of westward expansion could lead,
a generation later, to a decline in mobility.
High gross migration was an echo effect
following population change. Cities with
a large share of out-of-state residents
lost a lot of their new arrivals, resulting
in high turnover rates. Then, as the major
shifts in regional population dissipated,
an increasing share of people in newly
formed locations were “from there” and
less susceptible to leaving, and rates of
gross migration fell. So the gross migration
decline attracting attention today is
actually the secondary effect of population
shifts that slowed several decades ago.
(See Figure 4.)

Philadelphia

On the Road Again

Now that we understand why mobility
has declined, we can ask, what if anything
should policymakers do about it?
If decreasing turnover is the result of
more people rationally deciding to remain
in place, the decline could be evidence
of increasing welfare across the economy.
Households no longer have to incur
the costs of relocation to find suitable
locations for themselves. Deepening
family and social capital, especially in
No More Californias

2020 Q1

−50%

Steubenville
OHIO
0%
50%

100%

150% 200%

Source: U.S. Census Bureau.

Federal Reserve Bank of Philadelphia
Research Department

11

once high-turnover locations, could have a wide
congestion in desirable, productive places. Regulations
range of benefits individually and socially. So maybe
that make it hard to build new homes increase costs
policymakers shouldn’t do anything about the
and prevent cities, especially those offering high
decline in mobility.
incomes or many amenities, from adding new resiHowever, these individually optimal decisions
dents.12 Suboptimal urban planning could lead cities
could have negative aggregate consequences. For
to be overly congested and below capacity. This is
instance, workers may choose less-productive jobs in
the more pessimistic perspective, suggesting that
their home city so they can be near family, which
restrictions on population growth restrain productivity
would be optimal for them but would reduce their
growth and exacerbate inequalities by prohibiting
labor market output. If such cases are pervasive,
access to the best spaces. In this case, policy (or
it could add up to a knock on aggregate productivity.
perhaps the removal thereof ) has more scope to
It is notable that the migration decline out of highimprove welfare. But the goal of these policies is not
turnover places has not been seen in older cities
to encourage people to move more frequently per se
developed in previous industrial transitions. Indeed,
but rather to enable desirable cities to accommodate
most examples of struggling labor markets, such
more residents.
as postindustrial cities in the Northeast and Midwest,
These two perspectives are not mutually exclusive,
show no trend at all. To some observers, there is
and the reality likely combines the two. The regional
a natural inclination to presume the migration decline transition is mostly complete (subject to the caveat
as one more force pummeling already-beleaguered
that there is always potential for new shocks), and the
cities, but as we have seen, this is not actually how the new trend in population growth is in the expansion
trend plays out. Those places (as well as some older
of existing cities (especially those away from the
cities with strong labor markets) show little mobility,
coasts) across various regions. This should assuage
and little mobility change, because they already had
the fears raised by the interregional migration decline,
well-established populations.
and there is really no clear role for policy here
In many of these cases, in light of the advantages of anyway. The real question is whether this natural new
personal place attachments, the ideal policy response phase of population growth is producing the optimal
would not be an incentive to move but rather an
distribution of population across cities, especially
enhancement to the productivity in the local job
across cities within each region.
market. Such place-based policies become more
This issue needs to be analyzed carefully. There is
appropriate as an economy becomes more locally tied. nothing inherently good or bad about rates of popuWould such place-based policies be sufficient?
lation growth being similar; indeed, they should be
Or should we also encourage the population shifts
different if some places are better than others. To the
America once experienced?
extent that there are market failures inhibiting
There are two perspectives on this question. One is population growth in some places, however, there is
that the expansion of population across the contia need for a policy intervention. If housing regulations
nent was simply a phase in the life cycle of American
are the result of rent-seeking on the part of current
development. Unsettled land was available, new
residents, or if additional population would enhance
technologies made it productive and habitable, and
worker productivity, or if poor urban planning leads
then the land filled with settlement and fixed
to unproductive (and unenjoyable) travel congestion,
investment until regions converged to an equilibrium
then a “benevolent social planner” would design the
size. Maybe there was nothing uniquely American
infrastructure (physical and legal) to accommodate
about high mobility (besides, perhaps, open land)
more people. In many cases, local interests may opand no reason to desire it now. The wagons reached
pose this (for individually rational reasons), but such
the coast, and there were no more Californias to settle. “growth positive” policy may nonetheless benefit
In this case, there is no problem for policy to fix.
society. If we are out of Californias—if, that is, there
The second perspective is that population change is are fewer new places to settle—we must manage the
unduly restricted by policy failures that create
urban frontier with great care.

12

Federal Reserve Bank of Philadelphia
Research Department

No More Californias
2020 Q1

Notes
1 See Molloy, Smith, and Wozniak (2011) and Kaplan and SchulhoferWohl (2017).

12 See, for example, Glaeser and Gyourko (2003), Glaeser (2017), Ganong
and Shoag (2017), Herkenhoff, Ohanian, and Prescott (2018), Hsieh and
Moretti (2019).

2 The cities with the largest declines have, if anything, aged less than
those with smaller or negligible declines.

References

3 Local industrial booms generated some off-path geographic patterns.
For example, Detroit grew later than Chicago—the automobile industry
took off in the early 20th century, after Chicago was well established—
and San Francisco grew as a gold rush town before most of the rest of
California was populated. However, the common pattern was explosive
growth as each city was established and then tapering growth as the
city matured.
4 Compared with the middle 20th century, domestic natural increase in
population has slowed, and a greater share of new population comprises
arrivals from foreign countries. Thus, while local population change in
the middle 20th century consisted of relocating Americans born in this
country, in the late 20th and early 21st centuries local population change
substantially consists of immigration from abroad.
5 Return rates are also high. Those living away from their birthplace are
far more likely to return there than are other similar people. This is
evidence that initial locations are “special places” to most people. If not
for this evidence, the observed inclination to stay put could merely
be the result of those people having a stronger distaste for moving
(anywhere, ever).

Ganong, Peter, and Daniel Shoag. “Why Has Regional Income Convergence in the U.S. Declined?” Journal of Urban Economics, 102 (2017):
pp. 76–90, https://doi.org/10.1016/j.jue.2017.07.002.
Glaeser, Edward L. “Reforming Land Use Regulations.” Brookings, April
24, 2017, https://www.brookings.edu/research/reforming-land-useregulations/.
Glaeser, Edward L., and Joseph Gyourko. “The Impact of Building
Restrictions on Housing Affordability,” Economic Policy Review, 9:2 (2003).
Gyourko, Joseph, Christopher Mayer, and Todd Sinai. “Superstar Cities,”
American Economic Journal: Economic Policy, 5:4 (2013), pp. 167–199,
https://doi.org/10.1257/pol.5.4.167.
Herkenhoff, Kyle F., Lee E. Ohanian, and Edward C. Prescott. “Tarnishing
the Golden and Empire States: Land-use Restrictions and the U.S.
Economic Slowdown,” Journal of Monetary Economics, 93 (2018), pp.
89–109, https://doi.org/10.1016/j.jmoneco.2017.11.001.
Hsieh, Chang-Tai, and Enrico Moretti. “Housing Constraints and Spatial
Misallocation,” American Economic Journal: Macroeconomics, 11:2 (2019),
pp. 1–39, https://doi.org/10.1257/mac.20170388.

6 See Partridge et al. (2012).
Kaplan, Greg, and Sam Schulhofer-Wohl. “Understanding the Long-run
Decline in Interstate Migration,” International Economic Review, 58:1
(2017), pp. 57–94, https://doi.org/10.1111/iere.12209.

7 See Kaplan and Schulhofer-Wohl (2017).
8 See, for example, Gyourko et al. (2013) and Ganong and Shoag (2017).
Partridge et al. (2012), in raising the prospect of a new “long-run
spatial equilibrium,” found evidence of a reduced population response
to observed regional differences in labor markets or amenities.
9 Among new technological advances, telecommuting may be a contributing factor to a migration decline because it detaches residence
from workplace, and job relocation is frequently a reason for relocation.
Although rates of telecommuting have increased, it is still a relatively
rare form of commuting; by census estimates, 5.3 percent of employed
persons “worked from home” in 2018, up from 3.3 percent in 2000
(2018 American Community Survey and 2000 U.S. Census, respectively).
Besides, telecommuting cannot sufficiently explain migration trends
across regions or among occupations with limited scope for working
from home.

Molloy, Raven, Christopher L. Smith, and Abigail Wozniak. “Internal
Migration in the United States,” Journal of Economic Perspectives, 25:3
(2011), pp. 173–196, https://doi.org/10.1257/jep.25.3.173.
Partridge, Mark D., Dan S. Rickman, M. Rose Olfert, and Kamar Ali.
“Dwindling U.S. Internal Migration: Evidence of Spatial Equilibrium or
Structural Shifts in Local Labor Markets?” Regional Science and Urban
Economics, 42:1-2 (2012), pp. 375–388, https://doi.org/10.1016/
j.regsciurbeco.2011.10.006.

10 This pattern holds within slower-growing regions as well. For example,
in the mid-Atlantic, Monmouth, NJ, is growing at about the national rate
but decidedly above the rates of nearby New York City and Philadelphia.
11 It would be naïve to assume that nothing will ever change. Climate
change, as one prominent example, could produce new dramatic shocks
to habitability, causing a new phase of shifts in population that renders
the population weakly attached all over again.
No More Californias

2020 Q1

Federal Reserve Bank of Philadelphia
Research Department

13

Public policy debate around consumer credit has focused on consumer
protection. But from whom are we protecting these borrowers?
BY I G O R L I VS H I T S

S

ince the financial crisis of 2007–2008, consumer credit has
gotten a lot of attention, especially as it relates to consumer
protection. And the attention is not just academic: The
Consumer Financial Protection Bureau (CFPB) and the Credit Card
Accountability Responsibility and Disclosure (CARD) Act, both
instituted after the crisis, have dramatically altered the regulatory
landscape of the consumer credit industry. A guiding principle
behind the creation of this new regulatory environment is that
consumers need protection from predatory lending practices.1
This article highlights some of the key considerations underlying
the design of such policies and possible pitfalls that arise in
implementing them.
In designing any regulation to protect consumers, we need to
first answer three questions. First, why do (some) consumers need
to be protected? The most basic answer is that (some) consumers
make “mistakes,” that is, they make decisions the regulator
deems suboptimal. There is a range of causes of these mistakes,
including various behavioral biases and a lack of information
or attention on the part of the consumer. I argue below that the

14

Federal Reserve Bank of Philadelphia
Research Department

details of this answer are very important for policy design, as
they affect how we answer the next two questions.
Second, whom do the consumers need to be protected from?
We consider three possible answers: lenders, more sophisticated
borrowers, and themselves.
Third, which policies offer effective protection? Here, the range
of answers includes financial education and restrictions on pricing
and contracts. The answer depends on the answers to the
previous two questions. If the regulations are based on a “wrong”
model, well-intentioned policies may backfire, causing harm
even to the borrowers they aim to protect. To complicate matters
further, protecting some (less sophisticated) borrowers may
come at the expense of limiting the (informed) choices of others.
As John Campbell put it in his 2016 Ely Lecture, “Financial regulators face a difficult tradeoff between the benefits of regulation
to households that make mistakes, and the cost of regulation to
other financial market participants.”2
This article briefly reviews the recent and ongoing research
on these issues. It is this rigorous economic research that allows

Regulating Consumer Credit and Protecting (Behavioral) Borrowers
2020 Q1

Photo: iStock.com/Tempura

Regulating Consumer
Credit and Protecting
(Behavioral) Borrowers

Igor Livshits is an economic
advisor and economist at
the Federal Reserve Bank
of Philadelphia. The views
expressed in this article are
not necessarily those of the
Federal Reserve.

us to formulate effective policies and evaluate the tradeoffs associated with the regulation of consumer finance.

Why Do Borrowers Need Protection?

The most conventional insight in standard economics is that wellfunctioning markets deliver efficient allocations. Economists
call this the first welfare theorem, and it assumes that economic
agents are fully rational and perfectly informed. If that were
true for all households in the consumer credit marketplace, they
wouldn’t need protection.
But the data (and common sense) suggest that borrowers are
not always fully rational. Many empirical observations may
be evidence of mistakes (from the point of view of a perfectly
rational and informed borrower). These observations include
the so-called “debt puzzle”: Laibson et al. (2003) pointed out
that 60 percent of all credit card holders carry a balance and
pay interest, whereas a standard model of rational borrowers
predicts that only 20 percent should do so.
An even more dramatic observation is the
“credit card debt puzzle,” documented by Gross
and Souleles (2002): Many credit-card borrowers
have liquid wealth they could use to fully pay the
balance on their credit cards, thus avoiding high
borrowing interest rates.3 The use of other, even
more costly borrowing outlets, such as payday
loans, is also hard to reconcile with the model
of fully rational borrowers, especially when one
considers how often these presumably very
short-term loans turn into extended indebtedness.4 Even the failure of many heavily indebted
households to utilize personal bankruptcy, as
documented by White (1998), may be evidence
of limited rationality (or limited information).5
Interventions in consumer credit markets are
thus typically motivated and justified by the idea
that borrowers make “wrong decisions,” or “mistakes.”6 These mistakes may arise from either limits to borrowers’ rationality, their
incorrect beliefs, or lack of information. Behavioral economics
is the study of these deviations from the assumptions of standard
(neoclassical) economics. Three behavioral deviations have
received the most attention: the “present bias,” temptation preferences, and incorrect beliefs. All three apply to consumer finance.7
Because these three behavioral deviations help explain the
empirical puzzles, they are a natural starting point for answering
the question “Why do borrowers need protection,” and for designing consumer protection in credit markets.

so-called “present bias” is a typical manifestation of time-inconsistent preferences. It refers to consumers’ elevated desire to
consume instantly rather than postponing consumption even by
a single period.8
Experimental evidence supports the conclusion that presentbias preferences shape human behavior.9 More importantly for
our purposes, present-bias preferences help explain a number of
aggregate phenomena in consumer credit markets. Laibson et al.
(2003) argued that present-bias preferences are needed to
reconcile an otherwise standard model with the “debt puzzle”—
the fact that 60 percent of credit card holders used their cards to
borrow, far more than a model with standard time preferences
would imply. Skiba and Tobacman (2019) argued that the present
bias (which naïve borrowers are unaware of ) is essential for
explaining consumer behavior in the payday-loan market.
Another behavioral deviation that justifies interventions in
consumer credit markets is temptation preferences. Models that
incorporate these preferences assume that individuals suffer
from temptation and have to exercise costly self-control to resist
it. Temptation preferences help explain a number of otherwise puzzling observations. Gathergood and Weber (2014) used
survey data to argue that self-control problems
(for example, impulsive spending behavior)
are the driving force behind the “co-holding
puzzle.”10 As documented by Gross and Souleles
(2002), many individuals carry balances (and
pay interest) on credit cards while having liquid
funds in low- or no-interest bank accounts.
This form of behavioral bias has a distinct set
of policy implications. Nakajima (2017) pointed
out that policies that restrict consumers’ ability
to borrow may benefit them by limiting their
temptation to consume early. Nakajima (2012)
also pointed out that by considering temptation
preferences, we may dramatically alter how
we think of the secular increase in consumer credit over the last
half-century.11 In the presence of temptation, rising indebtedness is not a sign of better consumption smoothing but rather of
overborrowing as individuals succumb to temptation.
The third deviation is incorrect beliefs or information. This
category bundles together such behavioral biases as overconfidence, overoptimism, and “cognitive limitation” in assessing
prospective contract terms or the market environment.12 These
biases’ key common feature is that they directly lead borrowers to
make financial “mistakes”—decisions that their fully rational,
fully informed selves would disagree with. The justification for
an intervention from a (better-informed) regulator is thus clear.

Interventions in
consumer credit
markets are
thus typically
motivated and
justified by
the idea that
borrowers make
“wrong decisions,”
or “mistakes.”

The Three Behavioral Biases

The classic example of behavioral deviation in consumer credit
From Whom Do Borrowers Need Protection?
is the idea that borrowers do not fully value or plan for the future, Politicians and consumer advocates often portray lenders as culwhich economists refer to as “time-inconsistent preferences.”
prits, and regulatory responses and proposals certainly take aim
Individuals subject to this bias fail to obey their own financial
at lenders’ practices (see, for example, the Credit CARD Act).
plans when those plans are optimal from the rational perspective. One illustrative quote comes from Bar-Gill and Warren (2008):
Or at least they want to deviate from these best-laid plans. This
“Sellers of credit products have learned to exploit the lack of
essentially defines the time-inconsistency of preferences. The
information and cognitive limitations of consumers.”
Regulating Consumer Credit and Protecting (Behavioral) Borrowers

2020 Q1

Federal Reserve Bank of Philadelphia
Research Department

15

From the point of view of economic modeling, this presumes
that lenders have monopoly power that allows them to exploit
behavioral borrowers. Indeed, Ausubel (1991) argued that the
credit card market displays signs of collusion among lenders,
and Herkenhoff and Raveendranathan (2020), pointing to the
profitability of transaction services, proposed a model of limited
competition.13 But I view the consumer credit market in its current
state as highly competitive.
Even so, contracts offered by competitive lenders may still be
predatory. Competitive lenders can offer exploitative contracts
in equilibrium, if borrowers are willing to accept such contracts.
Bar-Gill (2012) made the important observation that, in a competitive environment, lenders have little choice but to cater to
borrowers’ tastes, with all their biases and miscalculations. This
reasoning implies that policymakers need to protect borrowers
from themselves.
But there’s someone else who may take advantage of behavioral borrowers: other, “sophisticated” borrowers. That point was
well illustrated by Heidhues and Kőszegi (2010). Sophisticated
borrowers benefit from favorable prices that are subsidized
by the mistakes made by their behavioral peers. As a modeling
approach, this answer offers a helpful alternative to blaming
lenders (and demonstrates that policies benefiting one group of
borrowers may disadvantage another).

What Policies Offer Effective Protection of
Behavioral Borrowers?

The choice of policy instruments should be informed by
a specific market failure or behavioral bias.
Furthermore, it has to take into account
(equilibrium) market responses of both
lenders and borrowers, which may undo
or offset the intended effects. Failure
to do so may result in policy backfiring—
doing more harm than good.
Available policies include restrictions
on pricing (for example, interest caps
or restrictions on teaser rates), restrictions on the set of available contracts (for
example, limiting payday loans or the
lock-in features of long-term contracts),
information provision and counseling,
and various wedges (for example,
restricting which mortgages qualify
as conforming).
Interest rate caps (also known as usury laws) are widely
adopted though often sparsely enforced. These restrictions can
be justified either as limiting the ability of lenders to exploit
their monopoly power or as protecting behavioral borrowers
from undertaking excessively costly (that is, excessively risky or
excessively large) loans.
Restricting the kinds of contracts allowed in the marketplace
is another popular policy measure. The Credit CARD Act, for
example, is one set of such restrictions for credit cards.14 These
policies are often motivated by the (perceived) lack of accurate
information on the part of consumers, who may misunderstand

either details of the contract they are offered or the probability
of triggering certain aspects of the contract, such as late fees.
Another policy that can address such lack of understanding
is financial education, regarding both contract details and the
propensity of borrowers to be subject to penalty clauses. This
is the kind of policy prescription that arises from Heidhues and
Kőszegi (2010).
Lastly, rather than prohibiting certain contracts, policymakers
can use price wedges to make some contracts more or less
attractive. These wedges can range from taxes on certain
activities (making them more expensive) to de facto subsidies for
more desirable contracts. One example of the latter is the de
facto subsidy from government-sponsored enterprises (such
as Freddie Mac and Fannie Mae) that applies only to conforming
(desirable) mortgages.

Cautionary Tales: How Well-Intentioned
Policies Can Backfire

Not all policies designed to protect the consumer actually do
so. These well-intentioned policies are more likely to fail if
they misidentify the underlying behavioral friction or ignore
markets’ reaction to the policy. Unfortunately, these failures
are not unusual.
Cuesta and Sepulveda (2019) convincingly argued that the
introduction of interest rate caps in Chile led to a dramatic
decline in consumer welfare. The reduction in the interest rates
induced by the policy was not enough to compensate for
the dramatic reduction in the number of loans issued, even in
the most monopolistic submarkets.
Limiting the set of contracts is definitely
a double-edged sword. Restricting lock-in
clauses in contracts may help protect
behavioral borrowers who are unaware of
their biases. But the same policy harms
behavioral borrowers who are aware of
their bias and thus may want to use lock-in
features (such as large penalties for missing or adjusting payments) to discipline
their behavior by preventing themselves
from overconsuming in the future.15
Even financial education requirements
are not necessarily a slam-dunk policy prescription. Allcott et al. (2019) documented
that the majority of borrowers take on seemingly exploitative
contracts (payday loans) with their eyes wide open, fully aware
not only of the costs but also the likelihood that they will have
to roll these debts into yet another round of payday loans. And
financial counseling may be costly to prospective borrowers,
especially in terms of the time they would need to devote to it.
Kilborn (2016) argued that mandatory counseling for bankruptcy filers, implemented in Canada in 1992 and in the U.S. in
2005, is ineffective and misguided. While well intended, it
seems to have only made bankruptcy more costly for the most
vulnerable segment: single parents who had to not only make
time and pay for the counseling sessions, but also find and pay
for child care.

These well-intentioned
policies are more
likely to fail if they
misidentify the
underlying behavioral
friction or ignore
markets’ reaction
to the policy.

16

Federal Reserve Bank of Philadelphia
Research Department

Regulating Consumer Credit and Protecting (Behavioral) Borrowers
2020 Q1

When it comes to addressing borrowers’ overoptimism, Exler
et al. (2019) argued that none of the basic policies improves the
well-being of behavioral borrowers.16 Although overoptimistic
individuals borrow too much and default too little or too late,
policies that bluntly discourage borrowing or encourage default
backfire and make all (even behavioral) borrowers worse off.
Surprisingly, even “financial literacy” intervention can be
counterproductive, including for behavioral borrowers—it helps
these borrowers avoid mistakes, but it also shuts down crosssubsidization from rational borrowers to their behavioral peers.
Despite such examples of policy failures, other policies do
protect consumers.
Agarwal et al. (2015) found that implementation of the Credit
CARD Act yielded a substantial decline in fees paid by borrowers,
especially those with low credit scores, with no evidence of an offsetting increase in interest rates or a reduction in access to credit.
In an example from a different type of intervention, Carlin
et al. (2019) documented how an introduction of a mobile app,
which facilitated individuals’ access to their financial information, led to a significant reduction in high-interest debt and bank
fees. This suggests that some form of financial education may
indeed be effective. It also points to the effectiveness of subtle
“nudge” policies.

in excessive consumption. On the other hand, these same contracts can be simply predatory when borrowers are unaware of
their biases.
One aspect of the consumer credit market makes it distinct
from other markets, such as cellphone contracts, where exploitation of behavioral consumers is a concern: the possibility of
default. In many settings—including those with overoptimistic
households, for example—behavioral borrowers are more likely
not to repay their debts than are their sophisticated, fully
rational peers. This difference in default rates implies that when
the two types of borrowers take on the same contract, rational
borrowers tend to subsidize behavioral borrowers, and not the
other way around.
This point makes all the difference in policy prescriptions
resulting from Heidhues and Kőszegi (2010), who abstracted from
the possibility of default, versus those from Exler et al. (2019), who
treated default explicitly as a possible outcome.17 For example,
financial education is unequivocally beneficial in Heidhues and
Kőszegi (2010) but may backfire in Exler et al. (2019). Indeed,
Exler et al. (2019) argued that, rather than being exploited by
their rational peers, behavioral borrowers may instead benefit
from being pooled with less risky, rational borrowers.

Details Matter

Policy prescriptions depend critically on the details of the economic environment. Specifics of the behavioral biases that
motivate the intervention, borrowers’ awareness of their biases,
the extent of competition in the marketplace, the presence
of fully rational borrowers, and the prevalence of default—they
all matter when identifying the right regulation or intervention.
This points to the importance of both empirical analysis of
borrowers' behavioral biases and theoretical analysis of the
equilibrium responses of all market participants to any potential
market intervention.

Conclusion

Behavioral borrowers’ awareness of their own biases is critical for
the design of policy remedies. Although unaware behavioral
borrowers may be made better off (from a paternalistic perspective) by a regulation that limits the set of contracts available to
them, behavioral borrowers who are aware of their biases are
more likely to be hurt by such regulations. An “aware” behavioral
borrower may choose a credit card with high financing charges
(or a mortgage with high refinancing costs) over more flexible
products specifically in order to address their own behavioral bias,
by, for example, preventing their future selves from indulging

Notes
1 One of the key objectives of the Credit CARD
Act was the elimination of so-called “gotcha”
clauses in the fine print of credit card contracts.
I am not too proud to admit that I got “caught”
by at least four of the credit card features
subsequently outlawed by the Credit CARD Act.
And I tend to think of myself as a sophisticated
and attentive consumer.
2 According to the Financial Crisis Inquiry Commission (2011), this argument is one reason why
federal regulators didn’t rein in mortgage market excesses in the run-up to the crisis (p. 93).
3 Admittedly, Telyukova and Wright (2008) and
Telyukova (2013) offered a resolution of this
puzzle without relying on behavioral assumptions.

4 See Carter et al. (2011) and Skiba and Tobacman (2019).
5 Less prominent but still interesting puzzles
include “credit smoothing” (as opposed to
consumption smoothing), documented by
Hundtofte et al. (2019), and overborrowing in
response to windfalls, documented by Olafsson
and Pagel (2019).
6 Lack of competition may also justify policy
interventions as it distorts allocations, leads
to inefficiencies, and allows lenders with monopoly power to take advantage of borrowers.
However, arguments by Ausubel (1991) and
Herkenhoff and Raveendranathan (2020)
notwithstanding, the consumer credit market

Regulating Consumer Credit and Protecting (Behavioral) Borrowers

2020 Q1

is quite competitive, as discussed later in this
article. This is not an exhaustive list of reasons
for regulation. See Elul and Gottardi (2015) for
an example of a very different motivation.
7 Gathergood (2012) provided survey evidence
that behaviors associated with these biases
(namely, impulsive spending, heavy discounting, and financial illiteracy) are associated with
overindebtedness and financial distress.
8 O’Donoghue and Rabin (1999) offered the
accepted formal definition: “When considering
trade-offs between two future moments, present-biased preferences give stronger relative
weight to the earlier moment as it gets closer.”

Federal Reserve Bank of Philadelphia
Research Department

17

9 See Benhabib et al. (2010), Meier and Sprenger (2010), Balakrishnan et
al. (2017), and Bisin and Hyndman (2020), just to name a few.
10 Also known as “the credit card debt puzzle.” See Telyukova and Wright
(2008) and Telyukova (2013).
11 Nakajima (2012) focused on the staggering increase in the revolving
debt from practically zero in 1969 to 7 percent of GDP in 2009. (Today,
credit card debt amounts to about 5 percent of GDP). Increases in total
consumer debt (which excludes mortgages) and total household debt
were less dramatic but still substantial (from 12 percent of GDP to 19
percent today for consumer debt, and from 43 percent in 1982 to almost
100 percent at the peak for total household debt).
12 See Grubb’s (2015) discussion of the distinction between overconfidence, which he calls “overprecision,” and overoptimism.
13 A more promising approach to studying this aspect of the market
could be a search model of limited competition along the lines of Drozd
and Nosal (2008), Nosal and Galenianos (2015), Drozd and SerranoPadial (2013, 2017), and Raveendranathan (2019). But this branch of the
literature is still nascent.
14 The Credit CARD Act prohibits “universal default” (increasing the interest
rate on one card in response to a delinquency on another one) and
retroactive interest-rate increases. It also restricts “two-cycle billing,” the
marketing of credit cards on university campuses, credit limits offered to
young borrowers (under 21 years of age), and changes to interest rates
and other fees (for credit cards and gift cards). Under the Act, lenders
must also apply payments to the balance with the highest interest rate,
and they must disclose how long it would take to repay the balance by
making only minimal payments.
15 Even a mortgage prepayment penalty (or closing fee) may serve as
such a commitment device by making cash-out refinancing less attractive.
16 Overoptimism has been documented in various forms and settings.
Overoptimism regarding individuals’ income is documented by
Arabsheibani et al. (2000), Dawson and Henley (2012), and Balasuriya et
al. (2014). Gathergood (2012) offered evidence of unforeseen expenditures,
which amounts to overoptimism regarding expenses. Weinstein (1980)
found that people generally underestimate the probability of negative
events for themselves.
17 In other words, the model in Heidhues and Kőszegi (2010) ruled out
default by assumption: All debts are always repaid. Exler et al. (2019), by
contrast, explicitly modeled default as a possibility, thus reversing some
key forces, such as the direction of cross-subsidization.

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Pearson. “And a Vision Appeared unto Them of a Great Profit: Evidence
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https://doi.org/10.3386/w26604.
Hundtofte, Sean, Arna Olafsson, and Michaela Pagel. “Credit Smoothing,”
National Bureau of Economic Research Working Paper w26354 (2019),
http://doi.org/10.3386/w26354.

Weinstein, Neil D. “Unrealistic Optimism About Future Life Events,”
Journal of Personality and Social Psychology, 39:5 (1980), pp. 806–820.
White, Michelle J. “Why Don’t More Households File for Bankruptcy?”
Journal of Law, Economics, & Organization, 14:2 (1998), pp. 205–231.

Regulating Consumer Credit and Protecting (Behavioral) Borrowers

2020 Q1

Federal Reserve Bank of Philadelphia
Research Department

19

Research Update
These papers by Philadelphia Fed economists,
analysts, and visiting scholars represent
preliminary research that is being circulated
for discussion purposes.

Home Equity in Retirement

The views expressed in these papers are
solely those of the authors and should not
be interpreted as reflecting the views of
the Federal Reserve Bank of Philadelphia
or Federal Reserve System.

Bayesian Estimation and Comparison of Conditional
Moment Models

Retired homeowners dissave more slowly than renters, which suggests
that homeownership affects retirees’ saving decisions. We investigate
empirically and theoretically the life-cycle patterns of homeownership,
housing and nonhousing assets in retirement. Using an estimated
structural model of saving and housing decisions, we find, first, that
homeowners dissave slowly because they prefer to stay in their house
as long as possible but cannot easily borrow against it. Second, the
1996–2006 housing boom significantly increased homeowners’ assets.
These channels are quantitatively significant; without considering
homeownership, retirees’ net worth would be 28–44 percent lower,
depending on age.
Working Paper 19-50. Makoto Nakajima, Federal Reserve Bank of
Philadelphia Research Department; Irina A. Telyukova, Mulligan Funding.

We provide a Bayesian analysis of models in which the unknown
distribution of the outcomes is specified up to a set of conditional
moment restrictions. This analysis is based on the nonparametric
exponentially tilted empirical likelihood (ETEL) function, which is
constructed to satisfy a sequence of unconditional moments,
obtained from the conditional moments by an increasing (in sample
size) vector of approximating functions (such as tensor splines based
on the splines of each conditioning variable). The posterior distribution
is shown to satisfy the Bernstein-von Mises theorem, subject to
a growth rate condition on the number of approximating functions,
even under misspecification of the conditional moments. A largesample theory for comparing different conditional moment models
is also developed. The central result is that the marginal likelihood
criterion selects the model that is less misspecified, that is, the model
that is closer to the unknown true distribution in terms of the
Kullback-Leibler divergence. Several examples are provided to
illustrate the framework and results.
Working Paper 19-51. Siddhartha Chib, Olin Business School,
Washington University in St. Louis; Minchul Shin, Federal Reserve
Bank of Philadelphia Research Department; Anna Simoni, CREST,
CNRS, Ecole Polytechnique.

20

Federal Reserve Bank of Philadelphia
Research Department

Research Update
2020 Q1

Financial Constraints of Entrepreneurs and the
Self-Employed
Growth-oriented entrepreneurial start-ups generate more economic
growth than other self-employed businesses, yet they only constitute
a small fraction of start-ups. We examine whether financial constraints
impede these types of start-ups by exploiting lottery wins as
exogenous wealth shocks. We find that lottery-win magnitude
increases winners’ subsequent incorporation, implying that entrepreneurs face financial constraints, but not business registration, implying
that financial constraints do not bind as much for the self-employed.
Our results, that financial constraints bind for incorporations among
men, for serial entrepreneurs, during economic booms, and in
neighborhoods without local lenders, are important for understanding the financial impediments to entrepreneurial start-ups.
Working Paper 19-52. Vyacheslav Mikhed, Federal Reserve Bank of
Philadelphia Consumer Finance Institute; Sahil Raina, University of
Alberta; Barry Scholnick, University of Alberta and Federal Reserve
Bank of Philadelphia Consumer Finance Institute Visiting Scholar.

Owner-Occupancy Fraud and Mortgage
Performance
We use a matched credit bureau and mortgage dataset to identify
occupancy fraud in residential mortgage originations, that is, borrowers
who misrepresented their occupancy status as owner-occupants
rather than residential real estate investors. In contrast to previous
studies, our dataset allows us to show that–during the housing
bubble–such fraud was broad based, appearing in the governmentsponsored enterprise market and in loans held on bank portfolios
as well, and increases the effective share of investors by 50 percent.
We show that a key benefit of investor fraud was obtaining a lower
interest rate, particularly for riskier borrowers. Mortgage borrowers
who misrepresented their occupancy status performed substantially
worse than otherwise similar owner-occupants and declared
investors, and constituted one-sixth of the share of loans in default
by the end of 2008. We show that these defaults were also
significantly more likely to be “strategic,” further highlighting the
contribution of fraud in the housing bust.

Financial Consequences of Health Insurance:
Evidence from the ACA’s Dependent Coverage
Mandate
We study the financial effects of health insurance for young adults
using the Affordable Care Act’s dependent coverage mandate as
a source of exogenous variation. Using nationally representative,
anonymized credit report and publicly available survey data on medical
expenditures, we exploit the mandate’s implementation in 2010 and
its automatic disenrollment mechanism at age 26. Our estimates
show that increasing access to health insurance lowered young adults’
out-of-pocket medical expenditures, debt in third-party collections,
and the probability of personal bankruptcy. However, most improvements in financial outcomes are transitory, as they diminish after an
individual ages out of the mandate at age 26.
Supersedes Working Paper 18-03.
Working Paper 19-54. Nathan Blascak, Federal Reserve Bank of
Philadelphia Consumer Finance Institute; Vyacheslav Mikhed, Federal
Reserve Bank of Philadelphia Consumer Finance Institute.

Supersedes Working Paper 15-45.
Working Paper 19-53. Ronel Elul, Federal Reserve Bank of Philadelphia
Research Department; Aaron Payne, Federal Reserve Bank of
Philadelphia Research Department; Sebastian Tilson.

Research Update

2020 Q1

Federal Reserve Bank of Philadelphia
Research Department

21

Population Aging, Credit Market Frictions, and
Chinese Economic Growth
We build a unified framework to quantitatively examine population
aging and credit market frictions in contributing to Chinese economic
growth between 1977 and 2014. We find that demographic changes
together with endogenous human capital accumulation account
for a large part of the rise in per capita output growth, especially after
2007, as well as some of the rise in savings. Credit policy changes
initially alleviate the capital misallocation between private and public
firms and lead to significant increases in both savings and output
growth. Later, they distort capital allocation. While contributing to
further increase in savings, the distortion slows down economic
growth. Among factors that we consider, increased life expectancy
and financial development in the form of reduced intermediation cost
are the most important in driving the dynamics of savings and growth.
Supersedes Working Paper 19-21.
Working Paper 19-55. Michael Dotsey, Federal Reserve Bank of
Philadelphia Research Department; Wenli Li, Federal Reserve
Bank of Philadelphia Research Department; Fang Yang, Louisiana
State University.

The Trade-Comovement Puzzle
Standard international transmission mechanism of productivity shocks
predicts a weak endogenous linkage between trade and business
cycle synchronization: a problem known as the trade-comovement
puzzle. We provide the foundational analysis of the puzzle, pointing to
three natural candidate resolutions: i) financial market frictions; ii)
Greenwood–Hercowitz–Huffman preferences; and iii) dynamic trade
elasticity that is low in the short run but high in the long run. We
show the effects of each of these candidate resolutions analytically
and evaluate them quantitatively. We find that, while i) and ii) fall
short of the data, iii) goes a long way toward resolving the puzzle.
Appendix
Supersedes Working Paper 17-42.
Working Paper 20-01. Lukasz A. Drozd, Federal Reserve Bank of
Philadelphia Research Department; Sergey Kolbin, Amazon; Jaromir
B. Nosal, Boston College.

Capital Income Taxation with Housing
This paper quantitatively investigates capital income taxation in the
general-equilibrium overlapping generations model with household
heterogeneity and housing. Housing tax policy is found to affect
how capital income should be taxed, due to substitution between
housing and nonhousing capital. Given the existing U.S. preferential
tax treatment for owner-occupied housing, the optimal capital
income tax rate is close to zero (1 percent), contrary to the high
optimal capital income tax rate found with overlapping generations
models without housing. A low capital income tax rate improves
welfare by narrowing a tax wedge between housing and nonhousing
capital; the narrowed tax wedge indirectly nullifies the subsidies
(taxes) for homeowners (renters) and corrects overinvestment to
housing. Naturally, when the preferential tax treatment for owneroccupied housing is eliminated, a high capital income tax rate improves
welfare as in the model without housing.
Supersedes Working Paper 10-11.
Working Paper 20-02. Makoto Nakajima, Federal Reserve Bank of
Philadelphia Research Department.

22

Federal Reserve Bank of Philadelphia
Research Department

Research Update
2020 Q1

Self-Fulfilling Debt Crises, Revisited
We revisit self-fulfilling rollover crises by exploring the potential
uncertainty introduced by a gap in time (however small) between an
auction of new debt and the payment of maturing liabilities. It is
well known (Cole and Kehoe, 2000) that the lack of commitment at
the time of auction to repayment of imminently maturing debt can
generate a run on debt, leading to a failed auction and immediate
default. We show that the same lack of commitment leads to a rich
set of possible self-fulfilling crises, including a government that issues
more debt because of the crisis, albeit at depressed prices. Another
possible outcome is a “sudden stop” (or forced austerity) in which the
government sharply curtails debt issuance. Both outcomes stem from
the government’s incentive to eliminate uncertainty about imminent
payments at the time of auction by altering the level of debt issuance.
In an otherwise standard quantitative version of the model, including
such crises increases the default probabilities by a factor of five and
the spread volatility by a factor of 25.
Working Paper 20-03. Mark Aguiar, Princeton University and Visiting
Scholar, Federal Reserve Bank of Philadelphia Research Department;
Satyajit Chatterjee, Federal Reserve Bank of Philadelphia Research
Department; Harold L. Cole, University of Pennsylvania and Visiting
Scholar, Federal Reserve Bank of Philadelphia Research Department;
Zachary Stangebye, University of Notre Dame.

Concentration in Mortgage Markets: GSE Exposure
and Risk-Taking in Uncertain Times
When home prices threaten to decline, lenders bearing more of a
community’s mortgage risk have an incentive to combat this decline
with new lending that boosts demand. We test whether this incentive
drove the government-sponsored enterprises (GSEs) to guarantee
riskier mortgages in early 2007, as the chance of substantial declines
grew from small to significant. To identify the effect we relate new
risky lending to regional variation in the GSEs’ exposure and the interaction of this variation with home-price elasticity. We focus on the
GSEs’ discretion across potential purchases by reference to the credit-score threshold that triggers manual underwriting. We conclude
that this incentive helps explain the GSEs’ expansion of risky lending
shortly before the financial crisis.
Working Paper 20-04. Ronel Elul, Federal Reserve Bank of Philadelphia Research Department; Deeksha Gupta, Carnegie Mellon
University and Visiting Scholar, Federal Reserve Bank of Philadelphia
Research Department; David Musto, University of Pennsylvania
and Visiting Scholar, Federal Reserve Bank of Philadelphia Research
Department.

Health Insurance as an Income Stabilizer
We evaluate the effect of health insurance on the incidence of negative
income shocks using the tax data and survey responses of nearly
14,000 low-income households. Using a regression discontinuity (RD)
design and variation in the cost of nongroup private health insurance
under the Affordable Care Act, we find that eligibility for subsidized
Marketplace insurance is associated with a 16 percent and 9 percent
decline in the rates of unexpected job loss and income loss, respectively.
Effects are concentrated among households with past health costs
and exist only for “unexpected” forms of earnings variation, suggesting
a health-productivity link. Calculations based on our fuzzy RD
estimate imply a $256 to $476 per year welfare benefit of health
insurance in terms of reduced exposure to job loss.
Working Paper 20-05. Emily Gallagher, University of Colorado
Boulder and Federal Reserve Bank of Philadelphia Consumer Finance
Institute Visiting Scholar; Nathan Blascak, Federal Reserve Bank of
Philadelphia Consumer Finance Institute; Stephen P. Roll, Washington
University in St. Louis; Michal Grinstein-Weiss, Washington University
in St. Louis.

The Role of Startups for Local Labor Markets
There are substantial differences in startup activity across U.S. local
labor markets. We study the causes and consequences of these
differences. Startup productivity shocks are found to drive much of
these cross-city differences in startup activity: They explain half of
the forecast error variance of startup job creation, accounting for 40
percent of population growth and long-run changes in employment.
Shocks to barriers to firm entry have economywide effects similar
to those of startup productivity shocks but operate largely through
the number of startups, rather than their size. We use a novel spatial
panel VAR, identifying shocks using shift-share external instruments.
Appendix
Working Paper 17-31 Revised. Gerald Carlino, Federal Reserve Bank
of Philadelphia Research Department; Thorsten Drautzburg, Federal
Reserve Bank of Philadelphia Research Department.

Research Update

2020 Q1

Federal Reserve Bank of Philadelphia
Research Department

23

Debt Collection Agencies and the Supply of
Consumer Credit

“Don’t Know What You Got Till It’s Gone” — The
Community Reinvestment Act in a Changing Financial Landscape

This paper finds that stricter laws regulating third-party debt collection
reduce the number of third-party debt collectors, lower the recovery
rates on delinquent credit card loans, and lead to a modest decrease
in the openings of new revolving lines of credit. Further, stricter
third-party debt collection laws are associated with fewer consumer
lawsuits against third-party debt collectors but not with a reduction
in the overall number of consumer complaints. Overall, stricter thirdparty debt collection laws appear to restrict access to new revolving
credit but have an ambiguous effect on the nonpecuniary costs that
the debt collection process imposes on borrowers.

This study provides new evidence on the impact of the Community
Reinvestment Act (CRA) on mortgage lending by taking advantage of
an exogenous policy shock in 2014, which caused significant changes
in neighborhoods’ CRA eligibility in the Philadelphia market. The
loss of CRA coverage leads to an over 10 percent decrease in purchase
originations by CRA-regulated lenders. While nondepository institutions replace approximately half, but not all, of the decreased lending,
their increased market share was accompanied by a greater involvement in riskier and more costly FHA lending. This study demonstrates
how different lenders respond to the incentive of CRA credit.

Supersedes Working Paper 15-23.
Supersedes Working Paper 17-15.
Working Paper 20-06. Viktar Fedaseyeu, China Europe International
Business School and Federal Reserve Bank of Philadelphia Consumer
Finance Institute Visiting Scholar.

Working Paper 20-08. Lei Ding, Federal Reserve Bank of Philadelphia
Community Development and Regional Outreach; Leonard Nakamura,
Federal Reserve Bank of Philadelphia Research Department.

Supply Shock Versus Demand Shock: The Local
Effects of New Housing in Low-Income Areas
We study the local effects of new market-rate housing in low-income
areas using microdata on large apartment buildings, rents, and
migration. New buildings decrease nearby rents by 5 to 7 percent
relative to locations slightly farther away or developed later, and they
increase in-migration from low-income areas. Results are driven
by a large supply effect—we show that new buildings absorb many
high-income households—that overwhelms any offsetting endogenous amenity effect. The latter may be small because most new
buildings go into already-changing areas. Contrary to common
concerns, new buildings slow local rent increases rather than initiate
or accelerate them.
Working Paper 20-07. Brian J. Asquith, W.E. Upjohn Institute for
Employment Research; Evan Mast, W.E. Upjohn Institute for Employment Research; Davin Reed, Federal Reserve Bank of Philadelphia
Community Development and Regional Outreach.

24

Federal Reserve Bank of Philadelphia
Research Department

Research Update
2020 Q1

Data in Focus

Partisan Conflict Index
The Philadelphia Fed collects, analyzes, and shares useful data
about the Third District and beyond. Here's one example.
300
250

200

150

100
50

JAN

1981

JAN

1985

JAN

1990

JAN

1995

Note: Average of 1990 = 100. Shaded areas indicate NBER recessions.

The Philadelphia Fed’s Partisan Conflict
Index (PCI) tracks the degree of political
disagreement among U.S. politicians
at the federal level by measuring the
frequency of newspaper articles reporting
disagreement in a given month. Higher
index values indicate greater conflict
among political parties, Congress, and the
President. The horizontal axis represents
the years 1981 to 2020. The vertical axis
measures partisan conflict, with the solid
line representing the average level of
conflict in 1990. Stony Brook University
Professor Marina Azzimonti, who created
the PCI while working for the Philadelphia
Fed in 2014, writes in her 2018 Journal of

JAN

2000

JAN

2005

JAN

2010

Source: Federal Reserve Bank of Philadelphia

Monetary Economics article1 that partisan
conflict is associated with lower capital
investment rates at the firm level, even
when she controls for economic policy
uncertainty and macroeconomic conditions. She estimates that about 27 percent
of the decline in corporate investment
between 2007 and 2009 can be attributed
to a rise in partisan conflict. The Philadelphia Fed updates this index monthly
to allow researchers to observe how the
indicator moves in relation to the salient
economic policy issues of the day.

JAN

2015

Learn More
Online: philadelphiafed.org/
research-and-data/real-time-center/
partisan-conflict-index
E-mail: PHIL.PCI@phil.frb.org

1 https://doi.org/10.1016/j.jmoneco.2017.10.007

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2020

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