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FRBSF ECONOMIC LeTTer
2003-37

December 19, 2003

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The Current Strength of the U.S. Banking Sector
John Krainer and Jose A. Lopez
Bank performance and condition
Changes in bank regulation
Changes in bank supervision
Conclusion
References
During the 2001 recession and the recovery, bank performance has been remarkably strong. To be sure,
banks tightened their lending standards as the economy softened, lessening their exposures to problem
areas such as the technology and telecommunications sectors. But it is also notable that banks’ lending
strategies during the late 1990s boom never resulted in a buildup of loan losses once the economy
weakened, as has happened so often in the past.
There are a number of possible reasons for the banking sector’s resilience. In fact, we cannot rule out
simple good fortune. Perhaps the 2001 recession was different from previous recessions in that it did
not have a great impact on the sectors the banks had exposure to. Indeed, the technology firms hardest
hit by the recession are relatively less dependent on banks for external finance than firms in other
sectors. It may also be that banking has changed over time, and that these changes have had an impact
on the cyclicality of banking. Today’s large bank has more capital, derives relatively more of its income
from nonlending sources, contains a different mix of loans in the loan portfolio, and is much better able
to hedge its financial risks than it was in the past. These changes could have resulted in better
performance during this downturn. Finally, the 1990s were notable for changes in regulation. Much of
this change was in reaction to the banking crisis of the late 1980s. Thus, it could be that the supervision
has changed and that the 2001 recession should be viewed as the first real test of the efficacy of these
changes. In this Economic Letter we will investigate these possibilities, focusing particularly on the
changes in regulation and supervision.
Bank performance and condition
The clearest indication of the banking sector’s resilience in

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Federal Reserve Bank San Francisco | The Current Strength of the U.S. Banking Sector |

the most recent downturn can be seen in the aggregate
performance measures. Aggregate return on equity (Figure
1) has remained remarkably stable throughout the late
1990s following the recovery from the banking crisis. The
figure also shows that it is relatively unusual to see steep
contemporaneous declines in bank performance as the
economy enters into recession. In this regard, bank
performance during the 1990-1991 recession was quite
different from that in previous downturns.
Bank conditions, as measured by the book equity capital
ratio and the nonperforming loan ratio, also illustrate that
the banking sector was well-positioned for the most recent
recession (see Figure 2). Simply put, the banking sector
today is better capitalized now than it was in the early
1990s. This is particularly clear when one looks at the total
capital ratio.
The banking sector has changed in distinct ways over our
sample period: the number of banks has shrunk through
consolidation and failure, banks have substituted
commercial and industrial lending for real estate lending,
and banks have gradually expanded their business lines to
reduce their reliance on interest income from lending.
Perhaps more importantly, the improvements in risk
management offered by securitization, loan syndication,
and hedging via derivatives instruments have helped banks
shed unwanted risks.
These developments in the banking sector all coincide with
higher stock market capitalization rates for banks and lower
stock return volatility. Indeed, bank stocks have
outperformed the market since 1995, and particularly
during the 2001 recession (see Figure 3); evidently,
investors viewed banks as better positioned than the
overall market to flourish in the slowing economy.
Changes in bank regulation
Certain changes in bank regulation during the 1990s led to
changes in bank behavior, and we highlight three of the
most significant initiatives. Two regulatory initiatives
focused on the amount of capital held by banks. The first,
the Basel Capital Accord of 1988, standardized capital
requirements for internationally active banks at 8% of riskweighted assets. While the capital standards in the first
Accord did not apply to the vast majority of U.S. banks, the
change in regulatory environment did spill over to domestic
bank regulators, putting new emphasis on risk and the
varying capital needed to support portfolios with different exposures.
Capital regulation took on further prominence with the passage of the FDIC Improvement Act (FDICIA) of

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Federal Reserve Bank San Francisco | The Current Strength of the U.S. Banking Sector |

1991, which laid out a list of privileges, or eligible operations, for banks deemed to be well-capitalized.
If a bank held at least 8% total equity capital, it could engage in operations such as merger and
acquisition activity and securities underwriting, and it would be eligible for insurance for its brokered
deposits. Linked to FDICIA was the new mandate of prompt corrective action, which required regulators
to shut down any bank with capital ratio below 2%. The key features of FDICIA were to reduce the
scope for moral hazard at the banks by requiring them to hold more capital and to provide greater
incentives to protect that capital.
Both regulatory changes had a clear impact on the capital U.S. banks held. For example, Furlong (1992)
shows that the average target capital ratios for all banks rose from about 7% during the 1985-1989
period to almost 9% during the 1990-1991 period. This increase was observed for both large banks,
which were more likely to be affected by these regulatory changes, and for small banks. All of the
reported increases were found to be statistically significant.
The third regulatory initiative was the passage of the Riegle-Neal Act of 1994, which paved the way for
interstate banking. By 1998, most states had implemented its provisions. The overall effect of RiegleNeal was to provide for the potential of cross-state diversification, which, in theory, could reduce the
variance of bank condition variables, such as nonperforming loans. The wave of ensuing cross-state
mergers in the banking industry certainly suggest that banks believed there was diversification
potential.
Changes in bank supervision
The prudential oversight of the banking system includes both regulations and ongoing supervision. The
major regulatory changes discussed above had a major impact on the banking industry and changed
important tenets of banking in the U.S. It is reasonable to assume that such changes also led to
modifications in the supervisory process and in supervisory concerns. We can gain an insight into some
of these potential changes by looking at supervisory bank ratings. These ratings, like the agency ratings,
are based on an absolute scale and are intended to be comparable over time. Interestingly, research
has shown that both agency and supervisory rating standards may actually change over time. Blume,
Lim, and MacKinlay (1998) were among the first to report this for the case of the ratings agencies. They
observed that the apparent worsening of U.S. credit quality in the 1990s was not so much a
deterioration in corporate balance sheets as it was a change in behavior by the ratings agencies. In
essence, the authors estimated a simple model of ratings using data from a given year, extracted a set
of ratings agency standards from the model, and then applied those estimated standards to data
generated in a later year. They concluded that lower debt ratings in later years were driven in part by
tougher standards.
Studies of this sort have been conducted on the bank supervisory ratings as well. Berger, Kyle, and
Scalise (2001) suggest that commercial bank rating standards were “tougher” during the credit crunch
of the early 1990s, and then eased in the expansion. In our own empirical research, we model
supervisory ratings for bank holding companies (BHCs) during the 1990s. We relate a BHC’s supervisory
rating to variables such as the BHC’s lagged nonperforming loan ratio, its loan loss reserve ratio, the
capital ratio, return on assets, and its lagged rating. Our results for the early 1990s match those of
Berger, Kyle, and Scalise; moreover, we find that standards changed again in the late 1990s and early
2000. Specifically, the actual ratings assigned in the latter period were more strict than predicted by a
model based on empirical ratings standards from the mid-1990s.
It is important to note that all of these studies are model-based approaches, so they cannot include the
complete list of variables that supervisors use to rate banks. However, empirical results suggesting that
supervisory standards can change imply that specific banking outcomes—such as finding that a bank’s
nonperforming loan ratio is, say, 2%—have differing impacts on supervisory ratings at different points in
time. This is consistent with the notion that supervisors adjusted to the new economic and regulatory

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Federal Reserve Bank San Francisco | The Current Strength of the U.S. Banking Sector |

environment during the 1990s.
Conclusion
Banking has been thought to be a cyclical business, yet banks have actually enjoyed excellent
performance and health throughout the last cycle. In this Economic Letter we have investigated some of
the reasons for this good performance. While we cannot rule out the explanation that the 1990s and the
2001 recession were relatively tranquil economic times with no shocks large enough to destabilize the
banking sector, we argue that the good performance is at least in part due to changes in regulation and
changes in approach by supervisory staff.
John Krainer
Economist
Jose A. Lopez
Senior Economist
References
Berger, A., M. Kyle, and J. Scalise. 2001. “Did U.S. Bank Supervisors Get Tougher during the Credit
Crunch? Did They Get Easier during the Banking Boom? Did It Matter to Bank Lending?” In Prudential
Supervision: What Works and What Doesn’t, ed. Frederic S. Mishkin. Chicago: University of Chicago
Press.
Blume, M., F. Lim, and A. MacKinlay. 1998. “The Declining Credit Quality of U.S. Corporate Debt: Myth or
Reality.” Journal of Finance 53, pp. 1,389-1,413.
Furlong, F. 1992. “Capital Regulation and Bank Lending.” FRBSF Economic Review 3, pp. 23-33.
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do not necessarily reflect the views of the
management of the Federal Reserve Bank of
San Francisco or of the Board of Governors of
the Federal Reserve System. This publication is
edited by Sam Zuckerman and Anita Todd.
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